Effects of new legislation vary from agency to agency

We now have a year's experience with the Information Technology Management Reform Act or as it more commonly known the Clinger-Cohen Act. It is time to take a brief look at how the agencies are carrying out the new law.

One thing you quickly discover is that agencies were positioned very differently when Clinger-Cohen came along. The Federal Aviation Administration for example created a chief information officer several years before a CIO was required by law. The Agriculture Department also was moving in the direction of a CIO in advance of the statute's passage. These agencies were ahead of the curve in the maturity of their thinking as well as in specific actions while others had to start from scratch.

The Capitol Hill staff involved in passing the law and the Office of Management and Budget staff engaged in implementation oversight are unanimous in believing that the CIO is a full-time job for a senior executive. As a corollary these folks also think that whoever is CIO ought not to be the agency's chief financial officer or else the agency isn't really taking Clinger-Cohen seriously.

A couple of agencies lump the two posts into one. At the Commerce Department the same individual is CIO CFO and the assistant secretary for administration. At the Department of Health and Human Services the CIO is also the CFO not to mention having recently returned from a stint as acting commissioner of the Social Security Administration.

I'm of two minds about this sort of thing. These individuals no doubt are highly talented. Still it is entirely reasonable to wonder whether a combined CIO/CFO gives scant attention to some important duties and the entire agency suffers as a result. So collapsing the two into one person seems like a bad idea.

On the other hand almost all who hold the CIO title also had another full-time job before that they have not relinquished. So if everyone's doing it can it be that bad?

Another measure of an agency's earnestness of intent is whether the CIO has some kind of direct reporting access to the head of the agency even if it's a dotted line on the organization chart. Almost all the agencies I've talked to have managed to achieve this.

Still another indicator is whether an agency has a capital planning and investment review board focusing just on information technology. Again most agencies have established boards although in some the charter goes beyond it.I have one big problem with Clinger-Cohen as with many other laws: Clinger-Cohen lays responsibilities on only the top-level entity in an agency. This means for example that under the law the Treasury Department must have a CIO (it does) but the law leaves it up to the department to decide whether major subagencies such as the Internal Revenue Service and the Bureau of Alcohol Tobacco and Firearms have CIOs (in this case they do). The law does not tell the large and powerful subagencies what to do it only prescribes action for a potentially weak top-level agency organization. The result is that agencies vary enormously in the extent to which their subagencies mirror the structure of CIO and capital planning and investment review boards for IT.

Despite this drawback I do not suggest that Clinger-Cohen has had little effect only that the effects are variable. In the final analysis agencies seem to realize that Clinger-Cohen makes excellent business sense and forges a much-needed link between an agency's IT and its strategic financial planning.

--Sprehe is president of Sprehe Information Management Associates Washington D.C. He can be reached via the Internet at jtsprehe@intr.net.