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Title page 1

Contents 3

Highlights 2

Letter 7

Background 13

Multi-Cloud Environments Have a Variety of Attributes 16

Federal Oversight and Guidance for Cloud Services 20

Federal Cloud Contracting 30

GAO Previously Reported on Federal Cloud Implementation and Private Sector Cloud Use 33

Agencies and OMB Used Imprecise Cloud Procurement Data 37

Agencies and OMB Primarily Used Historical Data to Help Make Decisions 37

Obligations on Cloud Contract Data in FPDS Were Imprecise 40

Agencies Reported Governance, Contracting, and Training Practices Assisted Cloud Procurements 43

Governance Among Stakeholders Facilitated Management and Oversight of Cloud Procurements 44

Agencies Identified Contracting Approaches Used to Facilitate Procurement of Cloud Services 47

Training Staff Enhanced Cloud Procurement Expertise 51

OMB and GSA Taking Action to Implement Executive Order on Government-wide IT Procurement Consolidation 53

OMB and GSA Have Not Fully Addressed Agency-Identified Cloud Procurement Challenges 54

Agency Cloud Cost Management Remains an Ongoing Agency Challenge 55

Conflicting Guidance Hindered Agency Cloud Software Compliance; Additional CISA Guidance Needed 61

Outdated IT Areas in the FAR Have Impeded Agency Cloud Procurement Efforts; Efforts Do Not Fully Address Challenges 65

Agencies Took Action to Address FedRAMP Authorization Challenges; OMB and GSA are Making Changes 79

Agencies' Multi-Vendor Cloud Procurements Impacted by Insufficient CIO Council Guidance 85

Agency Resource Constraints Hampered Cloud Procurement Workforce; GSA and CIO Council Are Developing Guidance 89

Conclusions 91

Matters for Congressional Consideration 92

Recommendations for Executive Action 92

Agency Comments and Our Evaluation 93

Appendix I: Objectives, Scope, and Methodology 100

Appendix II: Comments from the Department of Homeland Security 109

Appendix III: Comments from the General Services Administration 113

Appendix IV: Comments from the Social Security Administration 115

Appendix V: Comments from the Department of Defense 116

Appendix VI: Comments from the Small Business Administration 118

Appendix VII: GAO Contact and Staff Acknowledgments 120

Tables 3

Table 1. Assessment of Federal Acquisition Regulation (FAR) Overhaul Revisions That Address the Agency-Reported Cloud Computing... 76

Figures 4

Figure 1. Illustration of a Cloud Computing Environment 14

Figure 2. Depiction of Multi-Cloud Architecture and Multiple Cloud Architecture 17

Figure 3. An Illustration of a Cloud Container Environment 19

Figure 4. Illustration of a Software Bill of Materials with the Software Components Identified in Federal Guidance 27

Figure 5. Stages in a Federal Competitive Acquisition Process 31

Figure 6. FinOps Practices That Can Be Used by Federal Agencies to Optimize Cloud Environments and Achieve Cost Savings 58

Figure 7. Required Actions and Deadlines Established in Office of Management and Budget Memorandum M-24-15 Regarding Planned... 82

Figure 8. Current and Planned Implementation Phased Activities for FedRAMP 20x, as of May 2026 84

Figure 9. Four Areas Agencies Need to Consider for Containerization Management According to Federal Guidance 87

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