October 24, 2018

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LETTER: TechNet Comments on the the White House's Federal Cloud Computing Strategy

October 24, 2018

Ms. Suzette Kent
Administrator and Federal Chief Information Officer
Office of E-Government and Information Technology, Office of Management and Budget
1650 Pennsylvania Avenue, NW
Washington, D.C. 20502

RE: Federal Cloud Computing Strategy

Dear Ms. Kent:

TechNet is the national, bipartisan network of innovation economy CEOs and senior executives.  Our diverse membership includes dynamic American businesses ranging from startups to the most iconic companies on the planet and represents over three million employees and countless customers in the fields of information technology, e-commerce, the sharing and gig economies, advanced energy, cybersecurity, venture capital, and finance.

We welcome the opportunity to submit comments on the draft Cloud Smart strategy, the Office of Management and Budget’s (OMB) roadmap for agencies to adopt cloud solutions that streamline digital transformation and embrace modern capabilities.  This notice-and-comment process helps ensure that this strategy will be productive and effective upon implementation, and we encourage you to continue using this type of process in the future when updating the various policies, guidance, and other documents referenced in the CIO Council Action Items.  As you continue to develop the federal government’s updated Cloud Smart strategy, we encourage you to work with Congress and our industry to ensure that federal agencies have the resources to implement this initiative and usher in a new era of smart government for the 21st century that results in improved services for the American people.

Cloud computing is revolutionary

To begin, we must acknowledge that the advent of cloud computing has revolutionized the way individuals, businesses, and governments store, secure, and utilize data for innovation and modern workplace solutions.  It has empowered businesses of all sizes to use and more easily share data across platforms and scale to quickly respond to increased demands.  Cloud computing has also been instrumental in improving data analytics and fueling the rise of artificial intelligence, allowing for data to be maximized in ways that we could have never imagined just years ago.  For instance, health care providers are leveraging this technology to help find cures and treatments for cancer, autism, and other diseases that have vexed physicians and researchers for decades.  The federal government can use this same technology to modernize its information technology (IT) systems for improved security, more efficient operations, and better analytics and decision-making.  Agencies can more effectively execute their missions and provide the American people with the services they need and deserve.  Efforts to further the usage and growth of cloud computing throughout the federal government should be encouraged so that we can accelerate solutions and outcomes that are beneficial for all of us.

The Cloud Smart strategy correctly focuses on “equipping agencies with the tools needed to make informative technology decisions in accordance with their mission needs, and leverages private sector solutions to provide the best services to the American people.”  TechNet and our member companies share many of the same goals outlined in the draft strategy, particularly surrounding the indispensable role of cloud-based solutions in IT modernization efforts, security, and workforce development.  To that end, we recommend that the Cloud Smart policy include a vision statement, much like the Cloud First policy, that aligns its efforts to building on existing cloud policies like the Report to the President on IT Modernization and the Modernizing Government Technology (MGT) Act — both championed by this Administration.  The policy should build on Cloud First and continue to direct agencies to move to the cloud because of the security, improved analytics, real-time data, and pay-as-you-go services that it offers.

Cloud-based solutions are key to modernizing government

Over the past several years, modernizing the federal government’s dangerously outdated and insecure IT systems has been a top priority for TechNet and our members.  Much of the federal government’s IT infrastructure is woefully outdated, forcing federal entities to spend nearly 80 percent of their total IT budgets on operating and maintaining existing (legacy) systems.  These obsolete technology systems are inefficient and susceptible to cyberattacks, which, among other challenges, put citizens’ personal information at risk.  Federal government technology officials need more flexible procurement programs — both contractually and financially — to enable them to move beyond the IT status quo that agencies and departments have been saddled with for too long.  In order to address this issue, contractually, the federal government should make better use of existing agreement vehicles and should have a clear and transparent process for updating their terms, policies, guidebooks, and templates to keep up to date with current commercial cloud best practices.

Adherence to existing federal laws regarding commercial item preferences is also essential.  The U.S. Federal Circuit Court of Appeals’ recent unanimous decision in Palantir USG, Inc. v. U.S. reinforced the importance of the 1994 Federal Acquisition Streamlining Act (FASA), which requires federal agencies to procure commercially available technology.  As the federal government continues adopting cloud computing to advance its many missions, agencies should be using the latest technology products that have been rigorously tested and improved by market competition, instead of spending taxpayer dollars on trying to recreate something that is already available.

In addition, one of the key financial mechanisms for improving government IT is the MGT Act, which authorizes two funding streams to accelerate the transition to cloud computing.  The MGT Act also facilitates the sound adoption of state-of-the-art technologies (including cloud computing), thus helping deliver new IT capabilities, operational efficiencies, and cost savings for the federal government and taxpayers.  After working to pass the MGT Act as part of the 2018 National Defense Authorization Act (NDAA) late last year, TechNet helped secure $100 million in funding for it in fiscal year 2018.  Although Congressional appropriators did not provide the full $250 million authorized by law, we believe this initial funding was an important first step toward 21st century government IT.  In fiscal year 2019 and beyond, sustained funding for the MGT Act will be critical to fulfilling the goals of Cloud Smart.

Security must be prioritized

TechNet agrees that the federal government’s approach to security needs to evolve and that relying on the perimeter approach through a limited number of Trusted Internet Connections no longer makes sense.  We also agree that increased attention must be devoted to data security, encryption, and identity management.

TechNet believes that the security focus should be on objectives and outcomes over compliance with processes and procedures.  The Federal Risk and Authorization Management Program (FedRAMP) and Authorization to Operate (ATO) processes, such as encouraging greater cross-leveraging, must continue to be streamlined and made more efficient.

Federal agencies and vendors should have a vulnerability disclosure policy (VDP).  The use of VDPs are an effective and efficient way to contribute to data protection, cybersecurity, and mitigation of risk across complex assets.

Education and workforce development will drive cloud innovation

TechNet agrees with the Cloud Smart strategy’s call for ensuring that federal agencies “infuse their own workforce with key skills to move the Cloud Smart strategy forward.”  We also agree that, “Improving the Federal Government’s technology infrastructure to enhance the quality, security, and impact of services agencies deliver to taxpayers, requires maturity of the Federal workforce.”

Right now, we are facing a serious and growing shortage of talented workers needed to sustain our innovation economy.  There are currently over 570,000 vacant computing jobs across the U.S. because our education system is not producing enough skilled workers each year to fill them.  This scarcity of highly trained workers only intensifies the already fierce competition for talent when the federal government is also in the job market trying to recruit from this limited pool of workers.  Closing this gap by boosting the overall pool of well-trained and highly skilled workers will be essential for the implementation of Cloud Smart.  As a supplement to boosting federal agencies’ recruiting efforts for technical talent, we encourage the administration to work with Congress and our industry to enact policies that establish a stronger pipeline for federal agencies to fill jobs that will move the Cloud Smart strategy forward.

Moreover, as cloud computing technology continues to rapidly advance, we must also promote apprenticeships, career and technical education, and lifelong learning, retraining, and reskilling policies and programs that empower workers to attain the education and skills they need to stay current as jobs evolve and advance their careers.  Many of our members have developed programs to place retrained workers in both government and private sector positions and plan to continue these efforts in the future.  One key area the federal government can lead on is equipping our service men and women with cloud computing and other advanced skills they need not only to advance their missions while serving in uniform, but that can also be easily transferred to post-service civilian careers in the federal government or private sector.  These and other programs can ensure the next generation of workers — from all backgrounds — have access to the training and education they need to fill the jobs of the future, particularly in federal government roles that are cloud-based.  

Our industry also believes that part of bolstering the STEM and cloud computing talent pipeline requires proactive efforts to better engage underrepresented groups.  We support policies and programs that focus on engaging and providing opportunities for female and minority students and workers in STEM and computer science.  We must also address this talent gap by ensuring historically black colleges and universities (HBCU) and Hispanic serving institutions (HSI) have the appropriate federal support to offer their students adequate opportunities in the STEM disciplines.

To help achieve these goals, TechNet has strongly advocated for $250 million in annual federal funding for computer science education to help expand programs across the country and ensure today’s students everywhere are ready to take on tomorrow’s challenges.  We were pleased by President Trump’s September 2017 commitment to allocate at least $200 million annually for computer science education funding.  Since then, the fiscal year 2018 and 2019 appropriations bills enacted by Congress have included some STEM and computer science education funding, but more needs to be done not just to address employer demands, but also for our economic competitiveness and national security.  We will continue our federal advocacy in this area going forward in addition to our efforts to advance similar education and workforce development policies at the state level.  

In sum, we believe that cloud-based solutions are vital for innovation in both the federal government and the private sector and we welcome the administration’s action on this Cloud Smart strategy.  Thank you again for the opportunity to submit our comments.  We look forward to continued engagement as you finalize and begin implementing this important initiative.

Sincerely,

Linda Moore
TechNet President and CEO

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