Software License Management

Purpose: 

This Order implements a software license management program. It establishes software license management rules, responsibilities, and procedures.

Background: 

1. The objective of software license management is to manage, control, and to protect software assets including management of the risks arising from the use of those software assets.
2. OMB Memorandum M-16-12, Category Management Policy 16-1: Improving the Acquisition and Management of Common Information Technology: Software Licensing dated June 2, 2016, requires agencies to have a software management program and a designated central oversight authority to manage software agreements. A centralized software management approach will optimize utilization of commercial and Commercial Off The Shelf (COTS) software licenses and maximize the use of best-in-class software purchasing and management solutions. 

Applicability: 

1. This Order is applicable to all Heads of Service and Staff Offices (HSSOs) and Regional Offices acquiring or using IT in the conduct of GSA business. The requirements of this order also apply to contractors or other third parties who access GSA IT resources to conduct business on behalf of, or with, GSA or GSA-supported Government organizations, and to all GSA IT resources which process or store GSA data, whether leased or owned.
2. IT within the scope of this policy includes: applicable software and applicable cloud services as referenced in CIO 2160.1H, GSA Information Technology (IT) Standards Policy.
3. This policy applies to the Office of Inspector General (OIG) only to the extent that the OIG determines it is consistent with the OIG’s independent authority under the IG Act and it does not conflict with other OIG policies or the OIG mission.
4. This policy applies to the Civilian Board of Contract Appeals (CBCA) only to the extent that the CBCA determines it is consistent with the CBCA’s independent authority under the Contract Disputes Act and other authorities and it does not conflict with the CBCA’s policies or the CBCA mission. 

Cancellation: 

This Order supersedes CIO 2108.2, Software License Management, dated December 21, 2018.

Summary of Changes: 

1. Updated document to conform with OAS 1832.1C.
2. Removed outdated material.
3. Updated outdated links.

Roles and Responsibilities:

1. GSA IT is responsible for:

• Appointing a software manager that is responsible for managing, through policy and procedure, all agency-wide commercial and COTS software agreements and licenses. The software manager shall report to the agency Chief Information Officer (CIO) and will work in collaboration with the offices of the CIO, the Chief Financial Officer, and other organizations as appropriate. The software manager shall lead the agency-wide effort to centralize license management, implement strategies to reduce duplication, ensure the adoption of software management best practices, and participate in the Enterprise Software Category Team (ESCT) as defined in M-16-12.
• Acquiring enterprise software and maintaining a continual agency-wide inventory of software licenses, including all licenses purchased (by GSA or for GSA by contractors), or in use, as well as spending on subscription IT services (to include provisional (i.e., cloud) software as a service (SaaS) agreements).
• Analyzing inventory data to ensure compliance with software license agreements, consolidate redundant applications, and identify other cost-saving opportunities.

2. HSSOs are responsible for:

• Reporting licensing information to GSA IT Asset Management Branch. See the Software License page on InSite for details.
• Following the IT Standards Profile process outlined in CIO 2160.1F CHGE 2, GSA Information Technology (IT) Standards Profile before acquiring IT.
• Providing support to the ESCT as defined in M-16-12.