Federal Enterprise Risk Management Turns Five

On July 16, 2016, the U.S. Office of Management and Budget (OMB) issued a revision to Circular A-123 setting forth expectations for federal agencies to implement and practice Enterprise Risk Management (ERM). The requirements were intentionally flexible, providing substantial leeway in how agencies chose to go about setting up their ERM program. That approach by design was to help get ERM off the ground in a manner that could be tailored to the structure, culture, and needs of each agency, and to avoid the enactment of ERM purely as a compliance exercise.

Know Your Agency’s Risk Profile

Now more than 100-days into the Biden Administration, with a new team of political appointees gradually filling out agency leadership roles, there is renewed relevance to a call that was made in 2019 for leaders to embrace Enterprise Risk Management (ERM). While no magic bullet, ERM can help these new government leaders navigate through a landscape of escalating threats and challenges by equipping them with enhanced organizational and individual capabilities for identifying, assessing and managing risks to agency missions.

How Mature is the Federal Government’s Practice of Enterprise Risk Management (ERM)?

Last week, while speaking at the 2021 AGA and AFERM ERM Workshop, I had an opportunity to obtain viewpoints from the ERM community on this very question. 

Tom Brandt

Tom Brandt has served as the IRS’s Chief Risk Officer since 2014, leading the enterprise risk management program and enabling the identification, prioritization, evaluation and mitigation of key risks to achieving the IRS mission. Previously, Tom was the Director of Planning and Research in the IRS’s Large Business and International Division, with responsibility for the Division’s workload selection and risk identification processes, and development of the annual compliance plan.

Chief Risk Officer
Internal Revenue Service
United States

Tom Brandt has served as the IRS’s Chief Risk Officer since 2014, leading the enterprise risk management program and enabling the identification, prioritization, evaluation and mitigation of key risks to achieving the IRS mission. Previously, Tom was the Director of Planning and Research in the IRS’s Large Business and International Division, with responsibility for the Division’s workload selection and risk identification processes, and development of the annual compliance plan. In 2016, Tom served as the Head of the Tax Administration Unit at the Organization for Economic Cooperation and Development (OECD) in Paris, France where he led the work of the Forum on Tax Administration (FTA), a unique body that brings together the leaders of tax administrations from 50 countries to enhance tax administration around the world. Tom has also provided tax administration advisory and capacity building assistance to numerous tax administrations through projects of the International Monetary Fund and OECD. Tom began federal service in 1994 as a Presidential Management Intern.