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IT Acquisition Policy

U.S. Department of Commerce
Office of the Chief Information Officer

Information Technology Acquisition Policy

What documentation is required for an information technology (IT) acquisition initiative?
What is an IT acquisition initiative?

What is "information technology"?

Who established this policy?
Who does this policy apply to?

Why was this policy established?

How does this revision of the policy differ from previous issuances?

Why should you document your IT acquisition initiative?

Will the Exhibit 300 satisfy any external requirements?

When should an Exhibit 300 be revised?

What is the dollar threshold and who has to approve an IT acquisition initiative?

What are the requirements for IT acquisition initiatives below the dollar threshold?

Are there other requirements that must be met for IT acquisition initiatives?

How do you obtain CIO approval?

When should you submit the required documentation to the CIO?

Who can answer questions about this policy?

What documentation is required for an information technology (IT) acquisition initiative?

An Exhibit 300, “Capital Asset Plan and Business Case Summary,” defined in Office of Management and Budget (OMB) Circular A-11, must be used to document acquisition initiatives for IT hardware, software, telecommunications, and support services. This requirement is subject to the dollar thresholds defined below and applies regardless of the acquisition vehicle, method, or source. See Instructions for Completing the OMB Exhibit 300 for specifics.

What is an IT acquisition initiative?

An IT acquisition initiative is an investment that requires the expenditure of funds for information technology. An IT acquisition initiative could address a single acquisition; a logical grouping of hardware, software, telecommunications, and support services that will involve multiple acquisitions; or a project that will take place either within a particular fiscal year or over a longer life cycle and involve multiple acquisitions. An initiative might be a proposal for new funding within the budget process or it might be a new proposal for a major IT acquisition for an ongoing project.

What is "information technology"?

The Clinger-Cohen Act of 1996 (40 U.S. Code 1401, § 5002) defines information technology as “any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by the executive agency. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources."

Who established this policy?

The Office of the Chief Information Officer (OCIO) and the Office of Acquisition Management and Financial Assistance (OAMFA) are jointly responsible for this policy.

Who does this policy apply to?

This policy applies to the Office of the Secretary and all operating units of the Department of Commerce, except the U.S. Patent and Trademark Office.

Why was this policy established?

This policy was established to eliminate duplicative documentation requirements for major IT acquisitions. It establishes the Exhibit 300, which is required by OMB and Commerce’s Office of Budget, as the primary document required to justify a major IT acquisition.

How does this revision of the policy differ from previous issuances?

The substantive revision is that, to better align with the provisions of the Clinger-Cohen Act, the CIO will no longer issue a Delegation of Procurement Authority (DPA). The CIO will issue “Information Technology Investment Authority” (ITIA) on recommendation of the Commerce IT Review Board (CITRB).

The CITRB function and process will not substantially change. The CITRB will continue to perform oversight and reviews of major IT investments; however, the output decision will be the “Information Technology Investment Authority (ITIA)” to proceed. The Procurement Executive is a member of the CITRB and will review the Acquisition Plan for the IT investment as part of the CITRB process.

Why should you document your IT acquisition initiative?

Documenting your IT acquisition initiative will help you define your requirements, ensuring that the requirements support your mission and are consistent with the Commerce’s enterprise architecture. It will also help you define your acquisition strategy, which will facilitate your acquisition process.

Will the Exhibit 300 satisfy any external requirements?

Yes. Agencies are required to establish and maintain a capital planning process. Use of the Exhibit 300 provides essential information for Commerce’s Capital Planning and Investment Control Process. Other regulations require documentation of plans for certain acquisitions.

The specific requirements are as follows:

    • Section 5022 of the Clinger-Cohen Act requires an executive agency to define a process to "...provide for the selection of information technology investments to be made by the executive agency, the management of such investments, and the evaluation of the results of such investments."

    • The Federal Acquisition Regulation (FAR) Part 7, “Acquisition Planning,” requires Agency Heads to establish criteria and thresholds at which written acquisition plans shall be prepared.

    • OMB Circular A-130, “Management of Federal Information Resources,” states, "Agencies must establish and maintain a capital planning and investment control process that links mission needs, information, and information technology in an effective and efficient manner...The capital planning and investment control process includes all stages of capital programming, including planning, budgeting, procurement, management, and assessment.”

When should an Exhibit 300 be revised?

The Exhibit 300 is a living document and should be revised over the life cycle of the investment. An Exhibit 300 for a specific IT acquisition initiative may go through several iterations. The initial Exhibit 300 justifying a budget proposal might be broad and conceptual. As research on alternatives progresses, plans should become firmer and more specific. An Exhibit 300 that supports an acquisition or forms the basis of the Operational IT Plan should be detailed and explicit, identifying the expenditure stream and schedules for the life cycle of the investment.

What is the dollar threshold and who has to approve an IT acquisition initiative?

If the total life cycle cost (total contract value, including options, for all IT acquisitions within the IT acquisition initiative) is $10 million or greater, you must receive an IT Investment Authority (ITIA) from the Chief Information Officer. An ITIA is the CIO's permission to pursue an IT investment and will be contingent on the sponsor having budget authority for the IT investment. The CIO must grant an ITIA before the Procurement Executive can issue a Delegation of Procurement Authority (DPA) and proceed with the IT acquisition initiative.

To receive an ITIA, submit an Exhibit 300 to the CIO for approval. The investment sponsor will generally be required to brief the Commerce Information Technology Review Board (CITRB), which advises the CIO. The CIO, at his discretion, may waive the requirement to brief the CITRB for routine initiatives for maintenance, operations, or support, or refer the investment to the Commerce Acquisition Review Board.

To obtain an ITIA, you must also complete an Acquisition Plan. An Acquisition Plan is required regardless of the acquisition vehicle, method, or source. The Acquisition Plan must be available, at least in draft form, before the CITRB meets to evaluate the IT acquisition initiative.

After successful review, evaluation, and approval by the CITRB, the CIO will, at his discretion, issue the ITIA to proceed with the IT investment. The Procurement Executive, at his discretion, will then issue a DPA. Both approvals are required to proceed to follow-on phases of activity for the IT acquisition initiative, such as a Request for Proposal.

What are the requirements for IT acquisition initiatives below the dollar threshold?

On a selected basis, the CITRB may also review IT acquisitions that are highly visible, technically complex, or have a high degree of risk even though they are below the $10 million dollar threshold. These IT acquisition initiatives will require the same documentation as those at or above the dollar threshold.

For other IT acquisition initiatives where the total life cycle cost of the IT acquisition initiative is less than $10 million, the IT approval requirements and the standards for the level of documentation will be determined by the operating unit CIO.

Are there other requirements that must be met for IT acquisition initiatives?

Yes. IT acquisition initiatives must meet other requirements as follows:

How do you obtain CIO approval?

To request the approval of your IT initiative and issuance of an IT Investment Authority (ITIA), submit the following to the Commerce CIO through your operating unit CIO:

    • A cover memorandum describing the proposed IT investment and requesting an ITIA,

    • An Exhibit 300, and

    • An Acquisition Plan.

When should you submit the required documentation to the CIO?

For IT acquisition initiatives requiring an ITIA, contact the CITRB Secretariat, Terri Ware at 202-482-3138 or TWare@doc.gov, to schedule the briefing, allowing sufficient time for the briefing to be held consistent with the acquisition schedule. This should generally be done several months in advance of the desired time frame. Submit the Exhibit 300 and Acquisition Plan at least two weeks before the CITRB briefing.

Who can answer questions about this policy?

Direct questions on the overall process and IT policy and procedures to Stuart Simon at (202) 482-0275 or ssimon@doc.gov and on acquisition policy and procedures to Barbara Fallat at (202) 482-3780 or bfallat@doc.gov.

Supersedes policy dated: February 9, 2001
Origination date: October 23, 2007
Approved by: Suzanne Hilding, Acting Deputy Chief Information Officer, for Barry C. West, Chief Information Officer, October 30, 2007
Revision status: None