ICYMI: The Department of Defense’s Anything-as-a-Service Pilot Program

The Department of Defense (DOD) has been on a roll recently when it comes to providing the public with information concerning how it plans to use cloud computing in the years to come. Last week’s short article offered a few observations on the DOD’s new software modernization strategy, which is basically the department’s updated cloud strategy. This week’s article deals with another DOD initiative – the forthcoming Anything-as-a-Service Pilot Program.

Required by Section 809 in the National Defense Authorization Act for Fiscal Year 2024, the AaaS Pilot is guided by a recently released memorandum from the office of the Director, Defense Pricing, Contracting, and Acquisition Policy (DPCAP). Industry partners should read through the brief document to get an idea of the types of aaS that the pilot program will cover. They should also be aware of the garbled mess into which the DOD has turned aaS.

Defining "as-a-Service"

According to the standard definition in the National Institute of Standards and Technology’s Special Publication 800-145, any cloud-based capability provided as-a-Service must fall into one of three categories: Software-as-a-Service, Platform-as-a-Service, or Infrastructure-as-a-Service. See the NIST document for particulars. The recent DPCAP guidance, however, offers the following definitions listed as Product and Service Codes (PSCs). Under Software-as-a-Service (SaaS) one finds the following:

• DB10: IT and Telecom - Compute as a Service: Mainframe/Servers
• DC10: IT and Telecom - Data Center as a Service
• DE10: IT and Telecom - End User as a Service
• DG10: IT and Telecom - Network as a Service
• DJ10: IT and Telecom - Security and Compliance as a Service
• DK10: IT and Telecom - Storage as a Service

None of these services is SaaS, but the DPCAP will consider them as such for the purposes of AaaS Pilots.

Some of these PSCs, such as DB10, DC10, and DK10, are clearly Infrastructure-as-a-Service. DE10, meanwhile, includes hardware, such as leased computing devices. DG10 also includes hardware, since it is impossible to deliver a voice capability without some network communications equipment, including telephones. Lastly, DJ10 is more often than not a professional service. SaaS capabilities may be leveraged for compliance, but these are ancillary.

Think this mess is bad? It gets worse. Take a look at the PSCs under so-called Data-as-a-Service (DaaS).

• DC01: IT and Telecom - Data Center Support Services
• DE11: IT and Telecom - Mobile Device as a Service
• DH10: Platform as a Service: Database, Mainframe, Middleware

Data Center Support Services include personnel-based technical support. Mobile Device aaS I can’t even bring myself to comment on. Then there is DH10 which literally says “Platform as a Service.”

But wait! DPCAP isn’t finished. They provide a third category of “Space-as-a-Service (facility) PSCs.” These include:

• X1AA: Lease / Rental of Office Buildings
• X1AB: Lease / Rental of Conference Space and Facilities
• X1AZ: Lease / Rental of Other Administrative Facilities and Service Buildings

Yep. Leasing buildings is now an “aaS” along the same lines as providing an online capability via a web browser or dedicated application. I’ll bet none of you knew Rent-a-Center is an as-a-Service furniture provider. Now you do.

Pilot Program Guidance

The new definitions of aaS are provided in the FY 2024 NDAA. It states, according to the memo, “Section 809 defines ‘anything-as-a-service’ as a model under which a technology-supported capability is provided to the Department of Defense using any combination of software, hardware or equipment, data, and labor or services providing a capability that is metered and billed based on actual usage at fixed price units.” Hence the blurring of the lines previously established by NIST.

Other important things to know include:

• Contracting officers, not program office personnel, apply for pilot program status for requirements they are trying to fill.
• Full and open competitions are not required. Sole sourcing will be the norm, although it must be justified.
• Requirements selected for aaS Pilots are “exempt from certified cost or pricing data requirements, [although] contracting officers shall determine price reasonableness for pilot program participants using any other methodology authorized in FAR subpart 15.4 and DFARS subpart 215.4, Contract Pricing.
• Products/services offered must be firm fixed price or on a subscription (metered) basis.

Given these parameters, industry partners may want to reach out to DOD contracting personnel and inquire about getting an upcoming contract recompete or known requirement classified as an aaS Pilot. It could be an easy way to quickly secure a sole source contract.