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FCW : June 30, 2015
HOW IT WORKS to Standards for Internal Control in the Federal Government (commonly known as the Green Book) and to con- sider how evolution of the Green Book might influence internal controls policy reflected in OMB Circular A-123, Man- agement’s Responsibility for Internal Control. With the release of the exposure draft on internal controls by GAO in fall 2013, OMB sought to encourage a more robust consideration of risk management than the check-the-box compliance attitude sometimes seen at federal agencies. The awareness of ERM was at least partly respon- sible for the effort to move beyond a focus on internal controls in A-123 to a broader view of risk management. The next version of A-123 (at the time this report was published) is thus expected to broaden the role of A-123 beyond internal controls to include other aspects of risk management. In parallel with those develop- ments, in 2013, OMB asked the CFO Council for suggestions on what OMB and the CFO Council might focus on as initiatives in the coming year. The No. 1 suggestion from the CFO Coun- cil was ERM. In 1988, the General Services Administra- tion’s Federal Telecommunications System contract incorporated just six services. Its successor, FTS 2001, had more than 20. Now in a sign of how the smartphone has revolutionized telecom services, GSA’s next-generation $50 billion, 15-year Enter- prise Infrastructure Solutions contract has 54. EIS anchors GSA’s Network Services 2020 strategy and will replace Networx, which had to connect to 15,000 wire centers in the lower 48 states, said Fred Haines, GSA’s program manager for the EIS acquisition. Only a few companies — such as Verizon, AT&T and Century- Link — could make all those physical connections, which limited the pool of providers. EIS aims to take a different path with NS2020 as telecom continues to evolve from landlines and switching centers to the Internet, IP and beyond. To make that transition, the EIS contract will have: • Fewer entry requirements to attract nontraditional bidders. Haines said “dark horse” companies such as Amazon Web Services could be interested in entering the competition because of the looser requirements. • Fewer predefined contract line item numbers. The term is arcane but important because CLINs are central to federal agen- cies’ service ordering. CLINs lock down the services providers must make avail- able and force them to adhere to specific requirements, possibly at the expense of more innovative options. • Reduced contract modifications and more flexibility for buyers. GSA will del- egate procurement authority to agency contracting officers, who will be able to create task orders for line items. The move will streamline the process so agencies can get what they need faster. The added authority will also allow providers to more quickly tailor solutions to specific needs. • On-ramp capabilities. The streamlined contracting process will allow vendors to add innovative solutions more quickly, which Haines said might be the path that nontraditional providers take as EIS progresses. n How EIS will address increasing telecom complexity BY MARK ROCKWELL CFOs felt they were doing a good job of financial management and risk management within financial man- agement but were struggling with other types of risk. OMB thus start- ed a working group on ERM under the CFO Council. One result of this working group was to convene a CFO Council forum. The forum had most of the CFO Council in attendance and was both an educational discussion of the meaning and practices of ERM and a discussion of next steps in the coun- cil’s engagement with ERM. In October 2014, OMB Controller David Mader said during a panel dis- cussion that “we have begun talking about how do we think about risk more broadly than just financial risk? I think when you look at [circulars] A-11 and A-123, those were all born out of the CFO Act. So everyone is narrowly focused on ‘Well, it’s about financial risk and it’s about internal controls.’ What we are doing now is stepping back and thinking isn’t there really a way to take the lessons learned and what we’ve accomplished with A-11 and A-123 and broaden that perspective across the entire organi- zation, particularly around mission programs?” Mader went on to state that OMB believes there needs to be an enter- prise risk protocol across govern- ment and that OMB would provide that guidance late in 2015. n Douglas W. Webster is a senior fellow at George Washington University’s Center for Excellence in Public Lead- ership, where he teaches enterprise risk management. He is also director of government-to-government risk management at the U.S. Agency for International Development and founder and former president of Cambio Consulting Group. Thomas H. Stanton teaches at Johns Hop- kins University. He is also presi- dent of the Association for Federal Enterprise Risk Management and a former member of the federal Senior Executive Service. 20 June 30, 2015 FCW.COM 0630fcw_012-025.indd 20 6/10/15 9:40 AM
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July 15, 2015