PSC Comments on Mobile Category Management Policy

[DavidMWennergren]

Here is both a pdf and plain text version of PSC's comments on the draft OMB Mobile Category Management policy

PSC Response to OMB Mobile Category Mgmt Policy - Final - 4-28-16.pdf

Mr. Tony Scott, U.S. Chief Information Officer & Administrator
Office of eGovernment and Information Technology
Office of Management & Budget
1650 Pennsylvania Avenue, NW
Eisenhower Executive Office Building
Washington, DC 20503

Dear Administrator Scott:

On behalf of the Professional Services Council (PSC), I am pleased to submit these comments on the proposed OMB Mobile Category Management policy posted for public comment. This draft guidance identifies a number of important steps that will ensure greater effectiveness and efficiency in government mobile device acquisition and management. We applaud this initiative and offer the following comments to help further improve on the intended outcomes of this effort.

PSC is the voice of the government technology and professional services industry, representing the full range and diversity of the government services sector. As a trusted industry leader on legislative and regulatory issues related to government acquisition, business and technology, PSC helps build consensus between government and industry. Our nearly 400 member companies represent small, medium, and large businesses that provide federal agencies with services of all kinds, including information technology, engineering, logistics, facilities management, operations and maintenance, consulting, international development, scientific, social, environmental services, and more. Through our Technology Council, we have ensured that the requisite expertise of our member companies and their employees are brought to bear on these vital IT challenges our government faces. Together, the trade association’s members employ hundreds of thousands of Americans in all 50 states.

Improve Inventory Management. Robust and accurate information on device inventory and data usage will drive more effective procurement decisions and, as GAO has noted, inventory tracking needs to be a centralized agency function rather than delegated down to component levels to separately manage. The guidance should be clear on the imperative for agency-wide inventory visibility to help drive better decision-making.

Pursue Contract Consolidation. A reduction in the number of mobile device contracts will reduce administrative burdens and may increase competition, driving down operating costs and accelerating industry bringing new offerings to market. That said though, during the initial implementation of this new approach, it will be important not to overreach; rather than consolidating all wireless requirements under a single GSA contract per carrier, there may be an advantage to having more than one wireless contract per carrier. Competition among even a smaller number of government contractors and contracts will allow agencies to compare device and service offerings as well as fees, preventing one contracting office from exerting substantial monopoly power over all end users. If agency customers feel that the fees paid exceed the value of their contracted services, or technology refresh is falling behind for them, they would be able to shop elsewhere. Past practices have shown that migration to a single contract or GSA Schedule does not necessarily achieve the innovations and efficiencies sought by agencies. In addition, with a lack of contracting office choice, fees and delivery delays can increase. Finally, agency requirements vary widely, e.g., national security organization requirements differ from organizations working with underserved rural communities, etc., and these critical mission differences must be able to be accommodated in any policy or consolidation.

Refresh Rates. Over the longer term, agencies should consider decoupling carrier-subsidized devices from data plans, a direction that the commercial sector is already moving towards. For the purposes of the current draft memo, which still focuses on plans with device refreshes, the policy should require upgrades every 24 months rather than the 18 month timeframe proposed in the current draft. By increasing the time to refresh to two years, device replacement will better align with release schedules for new models, reducing costs and increasing the likelihood that the next device purchased will have greater capabilities and capacity.

Don’t Procure Old Devices. The current draft encourages procuring older devices, which may achieve short-term savings, but over the long term, costs savings from buying old devices may be illusory. Older devices are often not supported by the latest software improvements, increasing the risk that these devices will be more susceptible to cyber vulnerabilities and attack or be more rapidly obsolete. In addition, older devices typically have more limited functionality, lower performance and may be more costly to maintain. Today, the rapid pace at which new devices with additional capabilities come to market at little extra cost argues to equip the government workforce with the most secure and effective devices available at a reasonable price as the needs arise. Agency CIOs need to support their user communities’ needs, not the other way around.

Facilitate Innovation and Experimentation. The challenge faced by both government and the private sector is the rate at which technologies like wireless, which was once limited to devices and data, is now evolving into a complex, interconnected ecosystem, i.e., the Internet of Things (IoT). As the government expands its IoT efforts, flexibility will be needed so that new forays into IoT solutions aren’t viewed through the same commodity-focused lens as personal mobile phone account management. IoT efforts will include a wide range of devices, to include autonomous sensors and actuators (e.g. active RFID tags, facilities management tools, access controls, etc.) all generating, consuming and transmitting data. As such, where properly used, IoT promises huge leaps in technology adoption for federal agencies and cost savings will likely be obtained and have to be recognized in a different way than the efficiencies associated with better mobile phone management. This draft policy should be limited to mobile device acquisition and management.

To keep up with trends like IoT and Mobile Cloud, federal contracts need to be nimble, flexible, easily modifiable, and support a diverse and changing set of offerings. In December 2015, PSC published a report on “Best Practices for Federal Agency Adoption of Commercial Cloud Solutions” which highlighted practical advice for government buyers to improve the pace and effectiveness of cloud adoption. As noted above, there is much still to be learned in the government engagement in the cloud and IoT markets; this policy should focus exclusively on the well-defined area of mobile device management and not constrain new approaches and innovations to meet changing demands and technologies.
 
Thank you for the opportunity to comment on this policy. PSC would be pleased to discuss our recommendations with you and others. In the interim, please feel free to contact me by email at [email protected] or by phone at 703-778-7557, if you have any questions or need additional information.