The provisions are all well and good, but it’s hardly the first time they’ve been ordered by the White House.
High-level orders just like this one come out with every administration, and they all essentially say the same thing: Thou Shalt Assess and Protect. The problem is that the follow-through usually doesn’t deliver the resources agencies need to get it done. Many of the security and compliance requirements, while necessary, are so onerous to implement that they obviate much of the value that agencies seek from cloud models. The question then becomes how well the administration can identify and eliminate the obstructions agencies face as they consider adopting cloud and shared services.
The first part of this, simply putting the audit reports together, shouldn’t be too difficult since agencies are likely to have most of this info on hand and will just need to assemble it. The bigger question is how OMB will manage to get through reports for every department of the federal government in only 60 days. Even if the reports are available tomorrow, (and they won’t be), that timeframe is … ambitious. It really doesn’t seem to be informed by a solid understanding of practicalities.