Requirements for achieving efficiency, transparency, and innovation through reusable and open source software

Understand the policy framework: Federal Source Code Policy and OMB M-16–21

What is the Federal Source Code Policy?

In August 2016, the Office of Management and Budget (OMB) issued M-16-21, Federal Source Code Policy: Achieving Efficiency, Transparency, and Innovation through Reusable and Open Source Software (PDF, 188 KB, 15 pages).

The Federal Source Code Policy is designed to support the reuse of and public access to custom-developed federal source code. It requires new, custom-developed source code developed specifically by or for the federal government to be made available for sharing and re-use across all federal agencies. Furthermore, the policy supports publishing open source software (OSS).

Agencies are required to perform several tasks in order to satisfy the objectives of the policy:

  1. Updated agency policy: Agencies must update their policies to be consistent with the Federal Source Code Policy.
  2. Updated acquisition language: Agencies must update acquisition language to capture new custom code, whether built by a contractor or federal employee.
  3. Updated code inventory: Agencies must create and update an agency source code inventory to be placed online on their agency website.

Why is it important?

Each year, the federal government spends billions of dollars on software. Federal agencies do not always make their new code broadly available for reuse across the government; if they do make their source code available, it may not be in a consistent way.

When federal agencies make their custom-developed source code broadly available, it can reduce duplicative acquisitions, save taxpayer money, and increase quality.

What does it mean to achieve efficiency, transparency, and innovation through reusable and open source software?

OMB’s policy guidance in M-16-21 requires all executive branch agencies to conduct a three-step analysis in meeting their software needs.

  1. Conduct strategic analysis and analyze alternatives
  2. Consider existing commercial solutions
  3. Consider custom development

The analysis helps teams identify alternatives and mitigate additional spending on custom-developed software.

Conduct strategic analysis and analyze alternatives

Step 1 (Conduct Strategic Analysis and Analyze Alternatives): Each agency must conduct research and analysis prior to initiating any technology acquisition or custom code development. The strategic analysis should consider not only agency mission and operational needs, but also external public initiatives and interagency initiatives such as Cross-Agency Priority Goals. Having conducted the strategic analysis, agencies shall then conduct an alternatives analysis, evaluating whether to use an existing Federal software solution or to acquire or develop a new software solution. The alternatives analysis shall give preference to the use of an existing Federal software solution. 25

25 Existing Federal software solutions are those for which appropriate rights are already held by the Government, which may include commercial or custom-developed software solutions.

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The purpose of this step is to ensure your agency — not just your acquisition team, but also your technology team, program management team, and leadership, among others — has a complete, strategic view of what offerings exist before determining that an acquisition is required.

This step asks teams to do market research to discover what federal and non-federal solutions are already available before buying or building software.

Strategic analysis considerations

 

Consider existing commercial solutions

Step 2 (Consider Existing Commercial Solutions): If an agency’s alternatives analysis concludes that existing Federal software solutions cannot efficiently and effectively meet the needs of the agency, the agency must explore whether its requirements can be satisfied with an appropriate commercially-available solution. 26

26 Preference must first be given to procurement of existing commercial solutions through best-in-class vehicles identified by category management policies.

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