Back to the Future: Bring back the Raines Rules for IT procurement?

Two key contributors to the 1996 Clinger-Cohen Act say there is nothing wrong with the current IT management laws. Agencies and Congress just need to improve ho...

The rollout of once again shined a bright light on systemic technology and procurement management problems, raising the ghosts of past reform efforts.

A vocal group of former and current federal officials is calling for the return to the Raines Rules.

“The Raines Rules are a framework that the OMB Director Frank Raines during the Clinton administration came up with shortly after the passage of the Clinger-Cohen act, which sort of memorialized good IT management practices, some high-level management questions that really needed to be asked at federal agencies that simply weren’t being asked,” said Paul Brubaker, the director of planning and performance management for the Defense Department’s deputy chief management officer. “They were things like: Is this function a function that should remain in government, or is it something that should be outsourced? Should we do this in- house or should we look to a private sector source? Have we reengineered our business processes before we buy IT? These were all just basically good management practices that remain good management practices today. I think that there are some lessons that can be drawn if folks are willing to get in the Hot Tub Time Machine and go back to 1996 and dust them off and look at them. I think there are things that would obviate some of the challenges we see today.”

Brubaker and Mark Forman, the CEO of Government Transaction Services and a former administrator of e-government and IT at the Office of Management and Budget, played key roles in writing the 1996 Clinger-Cohen Act, which currently governs federal IT management.

Failed oversight, poor implementation

Brubaker and Forman, who spoke at the Government IT Forum sponsored by 1105 Government Information Group in Washington Tuesday, are two of the more outspoken federal IT experts who believe the management processes put in place under Clinger-Cohen remain applicable today, but just aren’t followed closely enough by agencies.

Forman said the failings of is yet another example of the lack of oversight by Congress and poor implementation by agencies of the Clinger-Cohen Act.

“Bringing back something like the Raines Rules is really basic IT management practices that I think a lot of us feel that ought to be applied,” Forman said. “I think things got lost. A number of management practices and tools were put in place in the Clinton and Bush administrations that were eroded. People viewed this as they do with FISMA and Exhibit 300 business cases as a compliance process. It takes an awful lot of management acumen to get the folks to understand this is really about innovation and how government can do its work better.”

And with the Senate likely to approve a version of the Federal IT Acquisition Reform Act as part of the National Defense Authorization Act for 2014 next week that mirrors the House amendment, the idea of legislating better IT management once again is up for debate.

Forman said he’s concerned about several provisions of FITARA, including how it changes the role of the agency chief information officer and potentially creates the opposite intent of the Clinger-Cohen Act.

“It puts a lot of pressure on the departmental CIO to be a gatekeeper,” he said. “FITARA has a heavy focus on the CIO as a gatekeeper, because like — and there is no question that’s part of the energy behind it especially in the Senate — people are saying, ‘Wait the government is not buying the technology right. There are these horror stories, we have to stop them.’ The approach that I think we are discussing here is to say, ‘Let’s not focus on stopping them, the bad things, that’s part of it. But there is a lot of value in that technology. But what do we have to do and what is the CIO’s role to take advantage of this technology?'”

Ask the right questions

Forman added the role of the CIO needs to be better defined as it relates to the deputy secretary and other political appointees.

“Everyone really should be focused on taking advantage of the technology, but it requires that mixture of business transformation for success,” he said. “It’s almost always going to be risky, and you can’t say we are not going to take the risk because then we are not solving the problems the taxpayers need solved.”

Agencies continue to struggle with the idea of transforming business processes through IT.

Brubaker said Raines Rules helps agencies ask the right questions to focus on changing the business model instead of just applying technology.

Brubaker said one reason agencies struggle with asking the right questions is a lack of cost data. He said unless agencies are just buying services, they don’t know what the true cost of a program is and therefore can’t develop an accurate business case.

He said the share-in-savings was one of the provisions that never took off because agencies didn’t know the cost baseline to calculate savings.

“Understanding that cost is so critically important to being able to construct that business case and monitoring over time so you can realize savings,” Brubaker said.

Forman said another concern about FITARA and how it positions the CIO is it seems to take them out of the role of pushing innovation.

“Do we need now to create a new position or really develop the career person in each of the agencies whose job it is to manage change or be that transformation guru? A number of things have been tried, the Business Transformation Agency and the Business Transformation Office in the intelligence community and the organizations haven’t been kind to the people holding those positions,” he said. “So that being said, if the CIO loses that innovation role that was envisioned in the Clinger-Cohen Act, agencies still need to have a leadership position that has the vision, the understanding of procurement processes, the financial processes, the HR processes, because workforce is a key part of this, and of course, IT, the leveraging of technology. What we are looking for is not a change in the technology, but the use of technology to enable mission improvement in the agencies. With FITARA likely to pass, it’s time now for the government reform community to take a look at that missing link.”

Not grumpy old men

Some may say Brubaker and Forman are highlighting the Raines Rules and Clinger- Cohen, and pushing back against FITARA because it would supersede in some respects the legislation they helped write 17 years ago.

But Brubaker said the problems that led to the Clinger-Cohen Act are the same as the ones with

At a recent Defense Business Council meeting where a representative from McKinsey and Company detailed a report on the challenges DoD is having with its Enterprise Resources Planning (ERP), Brubaker said he realized how little the problems have changed over the years for large IT projects.

“Thematically, everything they were talking about, the up-front planning challenges, the requirements challenges, the shifting requirements challenges, all of those things were delineated in the Computer Chaos report that we issued in October 1994,” Brubaker said. “It’s not new. We’ve been at this rodeo before. I think it would behoove us to embrace those lessons learned of the past and maybe dust some of those practices off that we were trying to promote, but got lost over time, today.”


CIOs still not meeting spirit, intent of Clinger-Cohen law, GAO finds

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