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STOP 6Addresses V-1, SE-1, SE-4

Stop: Treating standardization and COTS adoption as the transformation lever

The bottom line

Buying COTS is not transformation.

See the thinking

The RFI’s premise is that movement toward standards-based COTS modular solutions will fix fragmentation, variability, and lock-in. Our experience says the causality mostly runs the other way: fragmentation, variability, and lock-in are produced by the conditions under which states buy and build, and COTS purchased under those same conditions reproduces the same results with a different logo. The most damaging pattern is buying COTS as a forcing function to standardize business processes around vendor constraints rather than mission requirements. It consistently produces poor outcomes and governments locked into costly solutions, which is a condition the RFI seeks to avoid.

It is also worth highlighting the discrepancy between the stated goal of this RFI (addressing barriers to MES transformation) and the gist of many of its questions (how to standardize COTS products). Ironically, that notion may itself be one of the primary barriers to MES transformation: treating the standardization of COTS products as the goal rather than one potential means to it. If standards are applied to business processes as they exist today, the result is the current experience made uniform and harder to change, which benefits no one being served. Standardization creates value when it locks in what transformation has proven better, not when it substitutes for transformation and hopes value follows.

There is also a timing consideration, developed fully in S4: software build economics are shifting fast enough that a standards program hard-coding the current COTS landscape as its target state will be standardizing on a ceiling that is about to become a floor. Emerging standards worth watching (question SE-1) matter less than emerging build economics.

Supporting Content

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  • Lauren SiegelSep 4, 2026

    It seems CMS is concerned about buying things that are so customized. I don't see a ton in the RFI around "transformation" and the value it brings. It might be worth adding information about the need for "transformation" as opposed to just standardizing things and hope how things are standardized creates value for the people served.

    0 likes Reply
    • Kevin SutherlandSep 5, 2026

      Agreed and added. The response now names the discrepancy directly: the RFI's stated goal is addressing barriers to MES transformation, but many of its questions treat standardizing COTS as the goal itself. That mistake may be one of the barriers. Thanks for pushing on this.

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