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- Application Development   Database Management   Mobile Computing   Project Management   Security
![]() "Why are agencies forced to pay twice to C&A systems?" said the exasperated and cash-strapped Federal IT exec. "If agency A wants to use a system from agency B - a system that has already been C&A'd - then agency A needs to pay for a completely new C&A. If we're spending more than 20 percent of our cyber security budget on C&A - and the average C&A costs $167,643 - shouldn't we look for efficiencies?" An observation over lunch was quickly validated by other Feds - IT execs battling with the double-headed budget and security dragon. Curious stuff. The FISMA C&A reciprocity riddle set me on a fool's errand to put a dollar figure on the cost of C&A redundancy. That said, it opened a new window on OMB's lack of transparency - quite astonishing in this era of open government. Take a look at OMB's 2009 report to Congress on FISMA implementation - and you should. Here's the run down:
But, back to the fool's errand. Disappointing to find there's no list of agency C&As in the report that would allow us to quantify the cost of redundant C&As. But, now the report gets really interesting. Take a gander at the charts on pages 14 and 15 of the report. The titles sound good - "C&A Cost by Agency" and "Testing Cost per Agency System." The Y axes show hard cost in dollars. However, the X axes are anathema to the principles of open government - "each dot represents an agency." OMB knows the agencies' identities, so why not attribute the dots on the graphs and show comparative costs? Why not map expenditure per system against FISMA grades to show taxpayers the value we're getting for every dollar? Okay, the FISMA C&A redundancy quantification quest did not pay off yet, but it did lead to some other interesting data - and a series of more questions. I'll leave you with these three - and if you've got the answers, I'm all ears:
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