Using Voluntary Consensus Standards


Statement of the problem
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 paper 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.

Implementation Options
The implementation that is correct for a particular federal agency is the one that is in-synch with the agency culture and its way of managing IT. One agency may feel comfortable with a top-down approach whereas another agency may be more comfortable with a bottom-up approach. Yet another agency may find that a combination or hybrid of these two diverse approaches is most effective. This paper describes four models – Directive, Project, Consensus, and Hybrid.

Directive Model
Description: The CIO determines that it is advantageous for the agency to adopt voluntary consensus standards and signs that directive. The CIO staff will then develop an implementation strategy and guidelines for implementation. The directive is binding for all internal system or software development. Although OMB Circular A-119 does not mandate the use of voluntary consensus standards by external contractors, it does mandate their use in regulatory and procurement activities, and the CIO could make a determination that the agency will evaluate contractor deliverables against these standards. Also, the CIO could make the determination that any externally produced system utilizing the agency backbone or connecting to an in-house system must be developed using voluntary consensus standards.

Advantages: The specifics of implementation are specified. Project managers know what they have to do. All members of projects immediately are held accountable. This model is best used by an organization with a well-defined chain-of-command.

Disadvantages: Some IT program managers may push back because they have not been consulted and/or because their programs are developed outside of the CIO’s arena. They may neglect to use the standards or they may not monitor the use of the standards. There is no opportunity to validate the guidelines before they are implemented.

Project Model
Description: Pilot the transition to voluntary consensus standards using a highly visible project to learn from and improve the implementation process. In this model, the program manager declares that voluntary consensus standards are to be used on the project, and the applicable voluntary standards are provided by the agency. As a result, all documentation generated

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