Agencies resist changes to Exhibit 300s

Office of Management and Budget officials are considering both large and small changes to the Exhibit 300, a form agency officials use to make business cases for major information technology investments.

OMB officials will examine possible revisions to Circular A-11, including Section 300, which governs how agency business cases are judged, said Karen Evans, OMB’s administrator for e-government and IT. “That’s under review right now,” she said.

Many agency officials have begun working on their latest business cases, which they must submit to OMB by September for inclusion in the fiscal 2007 budget. OMB officials encountered resistance from agency officials last year when they tried to introduce significant changes to the Exhibit 300.

Chief information officers “appreciate the 300 process now, and they don’t want to radically change it because they’re using it for management,” said a federal IT official close to the situation who asked not to be named.

Agency CIOs rejected a variety of proposed revisions last year, including one that would have simplified the business cases and another that would have required them to collect additional information on enterprise architectures.

As a result, only minor alterations will appear in the revised Exhibit 300 guidance this year, the IT official said, adding that “one or two data elements will be strengthened, but it’ll primarily be the same.”

“The agencies use it so much, and so much progress has been made that the decision was a no-brainer this year — just leave it alone,” the official added.

But an OMB official who declined to be identified said no options have been eliminated. OMB officials did not release their final revision of Circular A-11 last year until mid-July.

The agencies’ rebuff last year was an example of the CIO Council’s processes working as intended, Evans said. “We give them draft documents,…they make recommendations, and I make the final decision.”

Mark Forman, Evans’ predecessor, approved the support of current agency business case processes. Agency executives’ initial resistance to submitting business cases to OMB has turned into reliance on Exhibit 300’s documentation, Forman said. “They wanted OMB to provide cover for getting to this data,” he said.

Reduce the Exhibit 300 burden, experts say

As Office of Management and Budget officials ponder revisions to the Exhibit 300 process, some experts suggest that federal officials would welcome a few changes.

“They would like to see basically much of the current structure retained, but a lot of the questions eliminated that they don’t feel necessarily add value,” said Russ Caple, director of management consulting at Fujitsu Consulting.

Others acknowledge that some changes could be helpful. “I always thought there was a bit more data being requested than we really needed,” said Mark Forman, former OMB administrator for e-government and information technology. He said a better solution for making the process more efficient would be for OMB officials to reduce the number of business cases agencies have to submit.

“If OMB, at the very beginning, had said, ‘We’re just not going to support improvements to programs based on the [Program Assessment Rating Tool] scores last year,’ ” what ends up being a futile effort would not be compounded by the time and money it takes to build a business case, Forman said.

Annual policy guidance from OMB’s director should include IT spending priorities, Forman said, adding that the existence of a program doesn’t justify IT spending.

But Caple said requiring chief financial officers to sign off on business cases has already worked to reduce superfluous Exhibit 300s. “That stops all sorts of [unreasonable] requests coming through,” he said, because CFOs must be certain that the money is appropriate and aligned with the Bush administration’s goals. “It’s the difference between telling somebody something and having them sign for it.”

— David Perera

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