Agencies should instead abide by the 1994 Federal Acquisition Streamlining Act and purchase commercial products when possible, according to the Alliance for Digital Innovation.

SSA "requires a suite of COTS tools, including implementation and integration support, for the enhanced automated management of its diverse cloud hosting environments."

The VA proposes migrating its Veterans Information Systems and Technology Architecture, better known as VistA, to a COTS, software-as-a-service platform.