NASCIO Executive Director
According to Robinson, concerns about REAL ID generally fall into three broad categories:
1) project scope;
2) cost and funding; and
3) project schedule.
REAL ID is a federally mandated program that will eventually replace U.S. driver’s licenses and provide identification for those without driver's licenses. The new ID will also provide access to all federally controlled places, including airports and national parks, and will be required to obtain federal services such as Social Security payments. The new system has great potential to standardize and optimize driver's license issuance and identity verification across the country, but many concerns are being voiced about the initiative.
In a recent interview with Techlines, Doug Robinson, executive director of the National Association of State Chief Information Officers (NASCIO), shared his insight into the REAL ID Act. Because of his daily interaction with the nation's top IT leaders, Robinson is well aware of the benefits associated with the initiative and its issues, including, some would say, an unfeasible implementation date.
The REAL ID Act, which was enacted into law in May 2005, established the U.S. Department of Homeland Security (DHS) as the sole agency responsible for setting REAL ID requirements and technical specifications. It also established May 2008 as the effective date for REAL ID's new requirements to officially take effect. For the last two years, NASCIO closely collaborated with the National Governors Association (NGA), the American Association of Motor Vehicle Administrators (AAMVA) and the National Conference of State Legislatures (NCSL) regarding REAL ID's specifications and implications. Earlier this year, those organizations provided joint recommendations to DHS regarding the forthcoming REAL ID regulations. An overview of their recommendations may be found online at: www.nga.org/Files/pdf/0604REALIDRECOMMEND.PDF.
Robinson was enthusiastic about REAL ID's potential for improving the business processes involved with the states' issuance of driver's licenses. He noted that the states now have widely differing requirements for verifying identity, issuing licenses, storing and retaining related electronic records and sharing information. Although REAL ID probably won't eliminate all differences, it is almost sure to provide a much greater level of consistency in driver's license issuance and identity verification between the states. Robinson refers to this as harmonizing the business processes behind driver's license issuance across the states. It will also provide a unique opportunity for the states to use the REAL ID effort to re-engineer their authentication, identification and credentialing systems. REAL ID will allow the states to take a comprehensive, or holistic, approach to these activities, which typically evolve with minimal coordination.
Despite these opportunities, there are a number of issues that have emerged surrounding the REAL ID initiative. According to Robinson, concerns about REAL ID generally fall into three broad categories: 1) project scope; 2) cost and funding; and 3) project schedule.
Project Scope – Full implementation of the REAL ID Act will be a massive undertaking. There are approximately 240 million driver's licenses in the United States, all of which must be reissued. Add to this the other forms of identification that will also have to be reissued and the project scope is staggering. By size alone, the REAL ID effort will be one of the largest IT projects ever undertaken.
Cost and Funding – Although the final REAL ID requirements are yet to be issued, enough is known to allow the states to begin estimating the total cost of implementation. AAMVA is currently coordinating an effort to compile a comprehensive estimate of the anticipated implementation costs for all 50 states. The AAMVA estimate is expected to be released by early September. Many state's preliminary estimates are well over $100 million, for their state alone. Unfortunately, DHS was only authorized to issue grants from FY 2005-09 to carry out the provisions of the act. So far, only Kentucky and New Hampshire have received grants for pilot projects, and those were only $3 million each.
Project Schedule – The May 2008 compliance deadline is quickly approaching, but DHS has not yet issued the draft REAL ID implementation regulations. They are expected to be sent to the federal Office of Management and Budget in the next month, but the delay to allow for public comments will likely push the release of final regulations to spring of 2007 before becoming official. That means the states will have slightly more than a year to implement one of the most massive projects in the history of information technology.
According to Robinson, NASCIO will consider making a statement during the official comment period for technology-related issues surrounding REAL ID. For now, he continues to tell federal agencies and anyone who will listen that the REAL ID Act will have a far greater impact than the Help America Vote Act (HAVA) since it will have a direct and personal impact on anyone who carries a driver's license. He also compares REAL ID to another massive, federally imposed change, the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Robinson says that if timeline and funding issues are not resolved, REAL ID is "potentially a HIPAA train wreck times 10." Considering Robinson's years of IT experience and successful track record with NASCIO, his concerns are not to be taken lightly.
A summary of the provisions in the REAL ID Act of 2005, provided by the National Conference of State Legislatures.
Testimony by Scott Carr, Executive Vice President of Digimarc Corporation, before the Homeland Security Task Force of the National Conference of State Legislatures (NCSL), August 17, 2006.
"REAL ID: Challenges - and Opportunities," GOVERNING.com, June 21, 2006.
"Long Waits Looming for License Renewals," San Francisco Chronicle, July 24, 2006.