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Conditional user access is not an MFA project. To meet OMB M-22-09, it is an enterprise ICAM operating model tied to attributes, privileged access, policy enforcement, monitoring, and ATO boundaries. Agencies are trying to build that while operating under continuing resolution uncertainty, lean IT staffing, FedRAMP procurement constraints, and production systems that cannot be taken offline for identity redesign. This blog details how to get it right with the right sequencing