Agency Developed Standards May Not Pass Muster

It has been more than 10 years since The Office of Management and Budget (OMB) issued Circular A-119 (Revised) directing federal agencies to use voluntary consensus standards, both domestic and international, in its regulatory and procurement activities. This circular defined voluntary consensus standards as having the following attributes: openness; balance of interest; due process; an appeals process; and consensus. Standards that meet these criteria include ISO, IEEE, and ANSI standards. It was expected that the agencies, including the Department of Defense, would cease using their own agency-specific standards which were often modeled after the proprietary standards of the contractors hired to develop those standards.

Although the circular is not specific as to its use in the external development of systems and/or software, it is specific in stating that the agencies must use voluntary consensus standards in its regulatory and procurement activities. For example, agencies could, if they desired, state via the RFP that their evaluation of a contract deliverable would be based on its conformance to the applicable voluntary consensus standard. Since the release of Circular A-119 (Revised) few if any of the federal agencies have attempted to bring their System Development Life Cycle standards into alignment with the circular. Recently, OMB issued Circular A-11 which references the use of voluntary consensus standards in Section 53. However, legacy systems continue to be upgraded and new systems continue to be built with little or no standardization across agencies or within individual agencies.

Assuming the federal agencies want to conform to OMB Circular A-119 (Revised), the unanswered question is – what precludes conformance? Some possible answers include: it will be too expensive; our operations and maintenance contractors won’t cooperate; our CPIC group doesn’t care how IT is done; our project managers don’t know how to do it or think it will take too much effort to implement. These arguments are all realistic albeit not very logical.

Perhaps the unspoken reason is that the federal agencies do not know how to implement the use of voluntary consensus standards. This blog is specific to the use of such standards in the development of systems and software and will propose several implementation options ranging from directive to consensus.

Subsequent blogs will describe a number of options for implementing the use of consensus standards.

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