OSFA responds to draft “Shared First” policy

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Open Source for America applauds OMB’s effort to increase the efficiency of the Federal IT budget through the principles of commoditization, reuse, sharing, and collaboration described in the draft IT Shared Services Policy distributed on December 8th, 2011. These principles are also the hallmarks of open source software, and while there is no explicit mention of open source in the plan at this time, we believe that there should be. We see a unique opportunity for open source to improve the effectiveness of Shared First.

“A number of barriers exist which have prevented the broader adoption of shared IT services. Lack of information sharing among the Federal agencies, budgetary restrictions, acquisition issues, and other factors have all contributed to a culture in which proprietary, specialized systems are the norm.”

We could not agree more. We believe that OMB should explicitly mention open source as a recommended method for overcoming these barriers. Open source software itself, of course, can reduce costs and ease acquisition challenges. We can assume that many agencies will naturally use open source software as part of their Shared First implementation.

Embracing the open source approach, though, and using it to encourage sharing between agencies, departments, other governments, and the general public is the purest expression of the goals of the Shared First policy. Open source excels at the Shared First Design Goals, including visibility, commoditization, reusability, extensibility, and standardization, and we believe it should be actively and explicitly encouraged by the policy.

Much of the draft is concerned with the sharing of existing infrastructure, and is in this way very similar to the Federal Data Center Consolidation Initiative. As the scope of the Shared First policy is much broader than the FDCCI, and concerns itself with LoB information systems and applications, we would like OMB to consider expanding the scope of the mandate to include the sharing of development resources, and not just their ongoing operations and maintenance.

As the policy encourages agencies to “move up the stack,” and share ever-more complex layers of their information systems, agencies will need to perform more customization to meet their specific mission needs. If they were to use proprietary commercial offerings or systems developed for just one agency, this can become very difficult and very expensive.

If agencies were to instead employ open source software, or better still: share their taxpayer-funded software under an open source license, customization would become easier, and the need for customization would be reduced, owing to the natural modularity of open source projects.

In the process, agencies would be making themselves available to contributions and improvements from their partner agencies as well as state and local governments who also have a use for that same software. Certainly, it is possible to share complex application software amongst agencies without open source software. We believe, however, that releasing software under an open source license can simplify this process, and simultaneously encourage sharing among other state and local governments, and the private sector as well. This approach has already been successful at NASA and the National Institutes for Health. We see no reason why other agencies cannot realize the same benefits.

“Open source is… the most concrete form of civic participation.”

— Macon Phillips, White House New Media Director

An excellent example of this is the effort currently underway at the EPA to develop a shared management system for Freedom of Information Act (FOIA) responses, one of the goals of the President’s National Action Plan under the Open Government Initiative. Almost as soon as the FOIA project was announced, it became clear that many citizens, state and local governments were interested in developing this platform alongside the EPA.

Should this project succeed, there would be a single, common platform for handling FOIA responses that would be freely available to the 93 agencies required to perform this task. Rather than 93 purpose-built systems, agencies could take advantage of each other’s innovation, the innovation of the private sector, and the innovation of thousands of state, local, municipal, and tribal governments who have their own Freedom of Information requirements.

Unlike working with proprietary FOI software, the number of agency-specific customizations would be drastically reduced, and since customizations can be contributed back to the main project, the ongoing maintenance burden of these customizations would be reduced, as well.

This kind of inter-, intra-, and extra-agency collaboration using the open source model is already finding success throughout the government, including the Veterans’ Administration Open Source VistA program, the National Security Agency’s SELinux project, and the OMB’s own data.gov.

It’s not difficult to imagine that these projects can encourage the growth of small businesses specializing in the implementation and maintenance of this software. Incorporating these stakeholders would bring to bear on the EPA’s FOIA platform far more development and testing resources than the EPA could muster on its own. Because the software assets have been commoditized, the EPA and other agencies would no longer be beholden to a single vendor for its FOIA software. This is the kind of relationship that OMB would like with its software assets, and this is precisely the kind of collaboration and commoditization that the current Shared First policy encourages. This is why we believe that the policy should make the role of open source explicit.

Open source software is particularly useful when the Federal government mandates action by state governments. The New York State Office of Temporary Disability Assistance has had great success in sharing open source eligibility logic with its counterparts in other states, allowing them all to share the burden of implementing CMS eligibility requirements. The Office of the National Coordinator for Health IT has employed open source software to encourage the adoption of its CONNECT standards for electronic health records. Without open source, these efforts would rely on potentially expensive proprietary software, which would have to be either unfunded or subsidized by the Federal partner to encourage adoption of their mandates. Instead, these organizations can now work collaboratively and transparently to solve their common missions.

Releasing agency software as open source has other benefits, as well. One of the primary concerns of the draft policy is to encourage visibility: agencies cannot share with each other if they do not know what’s being shared. The open source community has largely solved this discoverability problem through tools like sourceforge.net and github.com, both of which may be used, free of cost, by Federal staff and the public.

Open Source for America is excited by this renewed focus on agency collaboration and transparency. We strongly support the Shared First policy, and believe that it is one of the best tools available to meet agencies’ current challenges. We look forward to working together with OMB and the implementing agencies to make the policy successful. We also believe that by encouraging agencies to open source their software, and to share that software with each other, we can together ensure that agencies are putting their existing budgets to their best and highest use.