Friday Flash, 11.14.17

FAR & Beyond Blog: Unsettled Forecast for DoD Cloud

On October 30, the Department of Defense (DoD) published a Request for Information (RFI) seeking input from industry regarding how to best acquire an enterprise-wide cloud services architecture to support the needs of DoD both domestically and internationally. Specifically, the RFI requests information pertaining to commercial cloud providers’ lessons learned, pricing and services, current presence in the Federal space, and policy/regulatory barriers that impede further expansion into the Federal market.

The RFI raises several concerns related to its potential impact on the Federal market for providers of cloud services. In particular, the level of specificity in the RFI appears to be directed toward a single provider result. DoD, as a purchaser is unique, unlike not only a typical commercial customer, but also other Federal agencies, as its needs are mission-focused, diverse, and dynamic across its services and numerous agency components. Recognizing DOD’s diverse needs and mission requirements, it is not clear why the RFI would signal an approach that could eliminate the potential for multiple cloud services providers from the DoD market.

A multiple award IDIQ approach that offers diversified solutions from the commercial market will facilitate a culture of experimentation, adaption, and risk-taking and increase the speed of technology development and procurement, as envisioned by the recent cloud acceleration memorandum by Deputy Secretary of Defense Patrick Shanahan. In contrast, a single award DoD Enterprise Cloud Acquisition contract would lock-in DoD to a single approach, and, by so doing, give rise to performance and national security risks.

In addition, although the Coalition strongly supports the focus on commercial solutions to meet the DoD’s cloud requirements, the RFI appears to raise in priority the needs of the supplier above the needs of the customer for issues, like national security. Specifically, the RFI asks industry to comment on what policies and federal regulations serve as barriers to the proposed cloud services solution and states that, “DoD is prepared to pursue the revision of existing policies and federal regulations to remove barriers to success.” The RFI’s references to law and policy barriers for securing anticipated cloud services and its questions related to how DoD can alter its process to accommodate a potential commercial supplier (rather than the conventional notion of a seller attempting to meet the critical needs of its customer), raise serious concerns related to the “Balkanization” of the procurement process into multiple, product-centric processes. Thus, the Coalition recommends that this assessment include research into why any identified revision recommendations should not be applied generally to IT services, rather than limited to only the cloud services solution contemplated by the DoD Enterprise Cloud Acquisition. Without a rational, mission-based justification, simply waving rules for specific products is inconsistent with the overall goal of increasing access to the innovation and process efficiency DoD needs as it addresses a challenging security environment.

Additional concerns in the RFI relate to the appearance that it is directed at cloud service providers that support third-parties, and the need for input from the intelligence community. Without any details regarding the relevance of this third-party support or any solicited input from the third-parties, this approach prompts additional concerns that the RFI’s focus is on a single commercial supplier. At a minimum, the RFI should seek more specific feedback regarding, not only the experiences of the cloud service provider offering support of third-parties, but the experiences of those third-parties as well. Further, given the intent to address needs in the classified space, it would be helpful to secure the input of intelligence community customers on their experiences with these services and with their cloud environment generally.

The Coalition appreciates the DoD Cloud Executive Steering Group (CESG) for its outreach to industry and its efforts to accelerate the adoption of a modern enterprise cloud services solution through the commercial marketplace. We urge the CESG to ensure that the future DoD Enterprise Cloud Acquisition is open to multiple solutions in the interest of our national security and to incentivize cloud innovation moving forward under the new contract.