The General Services Administration's hunt for an agency-specific entity identifier conflicts with the Office of Management and Budget's push for a governmentwide data strategy.
Data is essential to guide evidence-based decision-making, a critical best practice toward informed policy development. A recent Government Accountability Office report has taken the government to task for failing to properly implement empirically sound and evidence-based practices as part of their deliberative process.
To encourage evidence-based decision-making, the recent President’s Management Agenda laid out a new cross-agency priority goal—“Leveraging Data as a Strategic Asset”—to develop and implement a comprehensive federal data strategy. Over the course of the next year, with input from the full spectrum of government and non-government stakeholders, the first governmentwide data strategy will be developed, along with specific recommendations for implementation. Office of Management and Budget sought to inform this process by issuing a comment draft in June.
By most accounts, the commitment to an overarching federal data strategy is welcome and timely. Huge amounts of data collected and managed by the federal government can be applied in a large variety of ways to foster economic growth and social good.
However, there is a parallel development that raises many questions about the commitment to a unitary government data management framework. Contemporaneous with OMB’s efforts to rationalize data use and promote transparency in government-owned data, the General Services Agency issued a request for proposal—responses were due Oct. 1—to transform the identity management system for recipients of grants and contracts. The RFP states that its purpose is to support “a common, secure business environment which facilitates and supports cost-effective acquisition of, and payment for, goods and services; effective management of federal acquisition and assistance awards; and consistent transparency into federal acquisition and assistance awards.”
GSA intends to accomplish this objective through the System for Award Management, or SAM, a complex IT system with a history of problems that had to be rebuilt before it could provide basic functionality and needed security. This effort to upend a foundational data protocol at GSA would be a significant cost to the taxpayer, but no cost analysis has been released by GSA in formulating this RFP. The new RFP does not address security needs, which is a significant oversight.
SAM is predicated upon the consistent use of existing, proven participant identifier data elements—such as DUNS numbers and CAGE codes—that are uniform and standardized across multiple government platforms. By all measures, the current system is working well and performing its intended purpose, and improvements to the system should focus on increased security and additional functionality, not replacing a system which currently provides needed services from a proven commercial technology
The new SAM system would replace existing commercial technologies to aggregate, standardize and add value to existing government information. However, the technology currently in place tracks business data and all associated changes across a single program for entire organizations and government agencies. Using the existing system, agencies already conduct crosswalks to other agency-specific identifiers, and implementation of a new, government-unique data format creates the risk of a cascading burden across all agencies and could have significant disruptions of government services.
This provokes an important question: Will the system required by GSA’s RFP add sufficient value to warrant the risk of transition?
It’s hard to know the answer; independent cost estimates for the transition have not been disclosed. The flawed and problematic SAM system has a spotty operational record, at best. But the awardee under the GSA RFP will not be allowed to enhance or expand upon SAM.
How can GSA ensure that the new data schema won’t impact the operation or functionality of the SAM system or related compliance databases? Will the new system be any better or will its increased complexity grind SAM and government services to a halt? Migration and integration risk have should be addressed in more detail by GSA before this acquisition is rolled out. Given the criticality of the current Federal Procurement Data System-Next Generation system, it seems prudent for GSA to at a minimum, run parallel systems to ensure operational success before cutting over to a new data standard.
GSA should adopt both existing and future types of data—public, private as well as hybrid data—in designing and operating the SAM system. If commercially suitable solutions already exist and are working, why create technical and program risk with a new data standard?
The preference for commercial items seems to have fallen entirely by the wayside in this RFP. There is no indication that GSA’s new approach has been socialized with other agency stakeholders. Agencies may not choose to implement SAM and the new government-devised identifier it will be based upon. What happens then?
This RFP, which would be foundational to every other agency’s data management practices in the area of procurements and grants, could lock OMB into a specific data schema that forecloses use of hybrid and private data sources across the federal enterprise. GSA’s data rights provisions virtually foreclose the use of private or hybrid data because GSA intends to claim virtual ownership in the RFP (called “unlimited rights”) to not only the data, but to all uses of the data as well, squeezing out the private sector from innovative new services for this important information.
It’s time for GSA to go back to the drawing board and rethink what it wants to accomplish in a fashion which is consistent with OMB’s vision for a governmentwide data policy. OMB has stated, as part of its data CAP goal, to push for innovation by users of government data in the private sector. But pushing out the private sector from the content and use of critical award and solicitation data will have the opposite effect. Let OMB do its job with a comprehensive governmentwide data policy before we resort to parochial agency-specific data formats that further fragment government’s already complex data sets.
Richard Beutel is a principal at Cyrrus Analytics.