Governing the future: A strategic framework for federal HR IT modernization
The federal government is preparing to undertake one of the most ambitious IT transformations in decades: Modernizing and unifying human resources information technology across agencies. The technology itself is not the greatest challenge. Instead, success will hinge on the governmentโs ability to establish an effective, authoritative and disciplined governance structure capable of making informed, timely and sometimes difficult decisions.
The central tension is clear: Agencies legitimately need flexibility to execute mission-specific processes, yet the government must reduce fragmentation, redundancy and cost by standardizing and adopting commercial best practices. Historically, each agency has evolved idiosyncratic HR processes โ even for identical functions โ resulting in one of the most complex HR ecosystems in the world.
We need a governance framework that can break this cycle. It has to be a structured requirements-evaluation process, a systematic approach to modernizing outdated statutory constraints, and a rigorous mechanism to prevent โcorner casesโ from derailing modernization. The framework is based on a three-tiered governance structure to enable accountability, enforce standards, manage risk and accelerate decision making.
The governance imperative in HR IT modernization
Modernizing HR IT across the federal government requires rethinking more than just systems โ it requires rethinking decision making. Technology will only succeed if governance promotes standardization, manages statutory and regulatory constraints intelligently, and prevents scope creep driven by individual agency preferences.
Absent strong governance, modernization will devolve into a high-cost, multi-point, agency-to-vendor negotiation where each agency advocates for its โuniqueโ variations. Commercial vendors, who find arguing with or disappointing their customers to be fruitless and counterproductive, will ultimately optimize toward additional scope, higher complexity and extended timelines โ that is, unless the government owns the decision framework.
Why governance is the central challenge
The root causes of this central challenge are structural. Agencies with different missions evolved different HR processes โ even for identical tasks such as onboarding, payroll events or personnel actions. Many โrequirementsโ cited today are actually legacy practices, outdated rules or agency preferences. And statutes and regulations are often more flexible than assumed, but in order to avoid any risk of perceived noncompliance or litigation.
Without centralized authority, modernization will replicate fragmentation in a new system rather than reduce it. Governance must therefore act as the strategic filter that determines what is truly required, what can be standardized and what needs legislative or policy reform.
A two-dimensional requirements evaluation framework
Regardless of the rigor associated with the requirements outlined at the outset of the program, implementers will encounter seemingly unique or unaccounted for โrequirementsโ that appear to be critical to agencies as they begin seriously planning for implementation. Any federal HR modernization effort must implement a consistent, transparent and rigorous method for evaluating these new or additional requirements. The framework should classify every proposed โneedโ across two dimensions:
- Applicability (breadth): Is this need specific to a single agency, a cluster of agencies, or the whole of government?
- Codification (rigidity): Is the need explicitly required by law/regulation, or is it merely a policy preference or tradition?
This line of thinking leads to a decision matrix of sorts. For instance, identified needs that are found to be universal and well-codified are likely legitimate requirements and solid candidates for productization on the part of the HR IT vendor. For requirements that apply to a group of agencies or a single agency, or that are really based on practice or tradition, there may be a range of outcomes worth considering.
Prior to an engineering discussion, the applicable governance body must ask of any new requirement: Can this objective be achieved by conforming to a recognized commercial best practice? If the answer is yes, the governance process should strongly favor moving in that direction.
This disciplined approach is crucial to keeping modernization aligned with cost savings, simplification and future scalability.
Breaking the statutory chains: A modern exception and reform model
A common pitfall in federal IT is the tendency to view outdated laws and regulations as immutable engineering constraints. There are in fact many government โrequirementsโ โ often at a very granular and prescriptive level โ embedded in written laws and regulations, that are either out-of-date or that simply do not make sense when viewed in a larger context of how HR gets done. The tendency is to look at these cases and say, โThis is in the rule books, so we must build the software this way.โ
But this is the wrong answer, for several reasons. And reform typically lags years behind technology. Changing laws or regulations is an arduous and lengthy process, but the government cannot afford to encode obsolete statutes into modern software. Treating every rule as a software requirement guarantees technical debt before launch.
The proposed mechanism: The business case exception
The Office of Management and Budget and the Office of Personnel Management have demonstrated the ability to manage simple, business-case-driven exception processes. This capability should be operationalized as a core component of HR IT modernization governance:
- Immediate flexibility: OMB and OPM should grant agencies waivers to bypass outdated procedural requirements if adopting the standard best practice reduces administrative burden and cost.
- Batch legislative updates: Rather than waiting for laws to change before modernizing, OPM and OMB can โbatch upโ these approved exceptions. On a periodic basis, these proven efficiencies through standard processes to modify laws and regulations to match the new, modernized reality.
This approach flips the traditional model. Instead of software lagging behind policy, the modernization effort drives policy evolution.
Avoiding the โcorner caseโ trap: ROI-driven decision-making
In large-scale HR modernization, โcorner casesโ can become the silent destroyer of budgets and timelines. Every agency can cite dozens of rare events โ special pay authorities, unusual personnel actions or unique workforce segments โ that occur only infrequently.
The risk is that building system logic for rare events is extraordinarily expensive. These edge cases disproportionately consume design and engineering time. And any customization or productization can increase testing complexity and long-term maintenance cost.
Governance should enforce a strict return-on-investment rule: If a unique scenario occurs infrequently and costs more to automate than to handle manually, it should not be engineered into the system.
For instance, if a unique process occurs only 50 times a year across a 2-million-person workforce, it is cheaper to handle it manually outside the system than to spend millions customizing the software. If the government does not manage this evaluation itself, it will devolve into a โping-pongโ negotiation with vendors, leading to scope creep and vulnerability. The government must hold the reins, deciding what gets built based on value, not just request.
Recommended governance structure
To operationalize the ideas above, the government should implement a three-tiered governance structure designed to separate strategy from technical execution.
- The executive steering committee (ESC)
- Composition: Senior leadership from OMB, OPM and select agency chief human capital officers and chief information officers (CHCOs/CIOs).
- Role: Defines the โNorth Star.โ They hold the authority to approve the โbatch exceptionsโ for policy and regulation. They handle the highest-level escalations where an agency claims a mission-critical need to deviate from the standard.
The ESC establishes the foundation for policy, ensures accountability, and provides air cover for standardization decisions that may challenge entrenched agency preferences.
- The functional control board (FCB)
- Composition: Functional experts (HR practitioners) and business analysts.
- Role: The โgatekeepers.โ They utilize the two-dimensional framework to triage requirements. Their primary mandate is to protect the standard commercial best practice. They determine if a request is a true โneedโ or just a preference.
The FCB prevents the โpaving cow pathsโ phenomenon by rigorously protecting the standard process baseline.
- The architecture review board (ARB)
- Composition: Technical architects and security experts.
- Role: Ensures that even approved variations do not break the data model or introduce technical debt. They enforce the return on investment (ROI) rule on corner cases โ if the technical cost of a request exceeds its business value, they reject it.
The ARB enforces discipline on engineering choices and protects the system from fragmentation.
Federal HR IT modernization presents a rare opportunity to reshape not just systems, but the business of human capital management across government. The technology exists. The challenge โ and the opportunity โ lies in governance.
The path to modernization will not be defined by the software implemented, but by the discipline, authority, and insight of the governance structure that guides it.
Steve Krauss is a principal with SLK Executive Advisory. He spent the last decade working for GSA and OPM, including as the Senior Executive Service (SES) director of the HR Quality Service Management Office (QSMO).
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