MEMORANDUM TO THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
Jacob J. Lew
Minimizing Regulatory and Information Technology Requirements That Could Affect Progress Fixing the Year 2000 Problem
As you know, the Year 2000 problem presents a major challenge to each
of our organizations as well as to the many organizations with whom we relate.
As your agency continues to make progress on this problem, it is important that
you consider the potential effect of regulatory actions or changes to information
technology (IT) systems on the Year 2000 readiness of regulated entities and your
agency. To the extent you can do so while meeting your statutory responsibilities,
your agency should not establish requirements that would have an adverse effect on
that readiness, if such requirements can be delayed or if there is an alternative
that would not have an adverse effect.
While I understand the importance of agencies achieving their regulatory
goals, it is important that these goals be timed in such a way that time-sensitive
work on the Year 2000 problem not be jeopardized. Implementing a regulation often
requires changes to the information systems of regulated entities. Accordingly,
before issuing a final regulation, please use your existing process for reviewing
regulations to consider the effect of the regulation on the Year 2000 readiness of
regulated entities and consider alternatives to minimize that effect, such as
postponing the effective date of the regulation. I have asked Desk Officers in the
Office of Information and Regulatory Affairs to assist your Regulatory Policy Officer
on this matter and to provide assistance in assessing any effects on Year 2000
readiness in reviewing agency rules.
New information technology requirements can introduce Year 2000 risk
into systems that have been certified as Year 2000 compliant. Moreover, new
information technology requirements can divert resources from other Year 2000
efforts. While I appreciate that all work cannot stop, we can avoid substantial
problems in January of 2000 by following a policy that only allows system changes
where absolutely necessary. Accordingly, please establish a process to assure
that the effect on year 2000 readiness is considered prior to establishing
new requirements or changes to IT systems. Your Chief Information Officer can
help ensure that the impact of new requirements or changes on Year 2000 readiness
is appropriately considered.
In your next quarterly report to OMB on Year 2000 progress, briefly
summarize how you have implemented this memorandum. Thank you for your
continued efforts to address this critical problem. By working together,
both within and with others outside of government, we increase the chance
of a smooth transition into the next millennium.