• How the PROTECT the Grid Act expands federal ITAM responsibilities for smart devices
• 5 essential preparation steps agencies should implement now
• A practical 12-month phased implementation roadmap
• Why proactive preparation typically reduces emergency compliance costs by 15-30%

Senator Rick Scott's recently introduced PROTECT the Grid Act is making waves in federal IT circles, and for good reason. Introduced in late July and currently under consideration by the Senate Banking Committee, the legislation targets foreign-linked smart appliances in federal facilities, particularly those connected to the electrical grid. While the details are still being worked out, one thing is clear: federal agencies need to start preparing their IT asset management (ITAM) programs now.

This isn't just another regulatory checkbox. Smart technology has quietly proliferated across federal facilities, from intelligent HVAC systems to connected lighting controls. According to the Government Accountability Office's most recent survey, 62% of federal agencies (56 of 90 surveyed) actively use IoT technologies, with applications ranging from environmental monitoring to building access control. Yet many agencies lack complete visibility into these assets, creating both security risks and regulatory challenges.

The good news? Organizations that take proactive steps today will be well-positioned when final requirements are published. Here's how to prepare your ITAM program for the coming changes.

The proposed PROTECT the Grid Act reflects growing concerns about supply chain security in critical infrastructure, specifically targeting high-wattage Internet-of-Things (IoT) equipment that consumes or controls more than 500 watts of power. While traditional ITAM programs focus on computers, servers, and network equipment, this new reality expands the scope to include seemingly mundane equipment like smart thermostats, connected security systems, and intelligent power management tools.

Government IT leaders need to think beyond their current asset inventories. That smart water heater in the basement? It might be on the network. The building automation system managing conference room lighting? It could have foreign-manufactured components requiring evaluation under the new legislation.

GAO data shows just how big this challenge is. Government organizations most commonly use IoT equipment to control or monitor systems (reported by 42 of 56 agencies using IoT), control access to facilities or equipment (39 agencies), and track physical assets like fleet vehicles (28 agencies). However, a 2024 GAO report revealed that 9 agencies missed the September deadline for completing their IoT inventories under the IoT Cybersecurity Improvement Act of 2020, highlighting the difficulties organizations face in managing these expanding technology ecosystems.

The challenge isn't just identifying these units—it's understanding their software components, supply chain origins, and potential security implications. This is where software bills of materials (SBOMs) become critical for government organizations, especially given the strengthened SBOM requirements under recent executive orders.

Traditional network scanning tools might miss devices that communicate infrequently or use non-standard protocols. Start by conducting a comprehensive facility walk-through with your physical security and facilities management teams.

The scope of this challenge is significant. GAO surveys reveal that government organizations report cybersecurity issues as their most significant challenge with IoT adoption (43 of 74 agencies), followed by interoperability problems (30 organizations) and lack of knowledgeable personnel (30 organizations). Yet agencies also report substantial benefits, with 43 organizations able to accomplish more with existing resources through IoT implementation.

Given these realities, a systematic approach to asset discovery becomes essential. Create an expanded asset category framework that includes:

• Building automation systems and components
• Intelligent environmental controls (HVAC, lighting, etc.)
• Connected security equipment (cameras, access controls, sensors)
• Smart power management systems
• Any equipment with network connectivity or embedded software

Don't just catalog what equipment you have—dig deeper into how it connects. Document network connections, communication protocols, and management interfaces. This comprehensive baseline will be crucial when regulators come calling.

Your existing vendor risk assessment processes likely focus on traditional IT suppliers. Smart technology vendors often have different risk profiles, supply chains, and security practices.

Develop specific evaluation criteria for intelligent equipment vendors that address:

• Manufacturing location and supply chain transparency
• Software development practices and security testing
• Firmware update processes and lifecycle support
• Component sourcing documentation and country of origin
• Compliance with relevant industry standards and frameworks

Consider creating a tiered assessment approach where higher-risk equipment categories require more rigorous vendor evaluation. Organizations that proactively implement these vendor management capabilities typically see 15-30% reductions in emergency compliance costs and improved leverage during contract negotiations.

Staying compliant means keeping good records from day one. Create standardized processes for capturing and maintaining the information you'll need for regulatory reporting.

Develop templates and workflows for:

• Initial equipment deployment and risk assessment documentation
• Regular adherence status reviews and updates
• Vendor communication and SBOM collection tracking
• Exception handling and risk mitigation documentation
• Audit trail maintenance for regulatory reporting

Your existing IT service management tools can help automate much of this documentation work while ensuring consistency across your organization.

Smart technology oversight shouldn't exist in isolation from your other cybersecurity efforts. Look for opportunities to integrate new requirements with existing NIST Cybersecurity Framework implementations and FISMA processes.

Consider how intelligent equipment risk assessments align with your current Authority to Operate (ATO) processes. Many organizations find that incorporating connected systems into existing security control assessments is more efficient than creating parallel tracks.

Update your continuous monitoring processes to include smart technology security posture. This might involve new scanning capabilities, additional log collection, or enhanced network monitoring for unusual equipment behavior.

While specific regulatory deadlines aren't yet defined, organizations benefit from starting preparation immediately. A phased approach allows you to build capabilities incrementally while learning from early implementations.

This timeline provides flexibility to adjust based on actual regulatory requirements while ensuring your organization stays ahead of deadline pressures.

Intelligent equipment oversight represents a broader evolution in government ITAM practices. The traditional boundaries between IT systems, facilities equipment, and operational technology continue to blur. Forward-thinking organizations are already adapting their asset management programs to address this convergence.

Success requires collaboration across traditional organizational boundaries. IT teams need to work closely with facilities management, physical security, and operational staff to gain complete visibility into connected technology deployments.

This team approach pays off beyond regulatory adherence. Organizations often discover opportunities to optimize equipment utilization, reduce security risks, and improve operational efficiency through better asset visibility.

The smart appliance legislation signals a new era of supply chain scrutiny for government organizations. While specific requirements are still being defined, the core ITAM capabilities needed for adherence are already well-understood.

Organizations that start building these capabilities now will have significant advantages when final regulations are published. They'll also discover immediate benefits from improved asset visibility and enhanced security posture. As this legislation signals broader government supply chain oversight, early adopters position themselves as leaders in establishing government-wide best practices that could shape future policy frameworks.

The key is taking that first step. Start with asset discovery expansion and vendor engagement. These foundational activities provide value regardless of specific regulatory requirements while positioning your organization for future success.

Ready to strengthen your agency's ITAM program for the evolving regulatory landscape? Contact our team for strategic guidance on intelligent equipment asset management, or schedule a discussion with our federal ITAM experts to explore tailored solutions for your organization's unique requirements.