OMB GENERAL COUNSEL MEMORANDA FULL
OMB GENERAL COUNSEL MEMORANDA SOFTWARE

Federal Information Security Management Act (FISMA) Implementation Project.) FISMA requires annual evaluations of the information security program at each federal agency, which are reviewed by DHS and OMB, and incorporated into an annual report to Congress. With FISMA, information security requirements were set forth based on NIST compliance documents. Management and Oversight of Federal Information Technology.)

OMB GENERAL COUNSEL MEMORANDA SOFTWARE

Governmentwide Software Purchasing Program ( OMB M-15-14.

Maximizing the Benefit of the Federal Strategic Sourcing Initiative.

Expansion of Training and Use of IT Cadres.

Federal Data Center Consolidation Initiative.

Enhanced Transparency and Improved Risk Management in IT Investments.

National Defense Authorization Act for Fiscal Year 2015.) Per OMB M-15-14, the specific requirements of FITARA include: With FITARA, the Common Baseline was set forth and the role of Agency CIOs was expanded with increased responsibilities through the National Defense Authorization Act for Fiscal Year 2015. The two major policies and guidelines are FITARA and FISMA. The Federal CIO heads OMB’s Office of E-Government and Information Technology (E-Gov), which develops and provides direction in the use of Internet-based technologies. As a part of this core function, OMB develops and ensures implementation of policies and guidelines that drive enhanced technology performance and budgeting across the Executive Branch.

OMB GENERAL COUNSEL MEMORANDA FULL

Grantees and subgrantees should closely monitor the requirements for any funding and exercise great diligence to ensure full compliance and mitigate later audit risks and deobligation of funding.įor more information please contact Wendy Huff Ellard, or any member of Baker Donelson's Disaster Recovery Group.OMB is responsible for overseeing Federal agencies’ information technology practices. However, OMB's directives also indicate enhanced oversight from OMB, and the agencies, and likely a robust audit plan for all programs funded pursuant to the ARP. and other OMB guidance as noted in the memo will certainly increase accountability for these funds. OMB indicates that compliance exceptions will only be allowed if imposition of the requirement would present insurmountable challenges to program implementation.Ĭompliance with 2 C.F.R. to OMB for approval prior to program administration and award issuance. OMB 'doubles-down' on its mandate that agencies must comply with all requirements, as the memo requires that, for any new programs under the ARP, agencies must submit their proposed implementation plan of 2 C.F.R. This applies to all types of financial assistance awards funded through the ARP, including the application of those provisions that would typically apply only to grants and cooperative agreements, and including applicability to assistance provided to for-profits. to federal financial assistance funded through the ARP to the maximum extent authorized by law. OMB directs that, to provide the highest integrity in the management of financial assistance, agencies must apply the requirements of 2 C.F.R. In the memo, OMB confirms its continuing work with the Pandemic Response Accountability Committee (PRAC) and agency inspectors general to strengthen payment integrity to minimize the risk of waste, fraud, and abuse. OMB's memo, referenced as M-21-20, also imparts a duty to all agencies to maintain effective stewardship of these funds, which includes supporting all Americans, and as such, requires advancing racial equity and supporting underserved communities across our country. The Acting Director of the Office of Management and Budget (OMB) has issued a guidance memorandum to all executive departments and agency heads to emphasize the importance of accountability and transparency of federal government spending with respect to assistance provided under the American Rescue Plan Act of 2021 (ARP).

Omb general counsel memoranda