Telecommunications
Agencies Are Generally Following Sound Transition Planning Practices, and GSA Is Taking Action to Resolve Challenges Gao ID: GAO-08-759 June 27, 2008The General Services Administration (GSA) is responsible for ensuring that federal agencies have access to the telecommunications needed to meet mission requirements. GSA's current telecommunications program, called FTS2001, has contracts in place that will expire by June 2010. Thus, agencies face the difficult task of transitioning their services to a successor program, known as Networx. GAO was asked to determine (1) the extent to which agencies are following sound transition planning practices and (2) the actions GSA is taking to identify and resolve common transition challenges affecting agencies. In performing this work, GAO selected six agencies based on, among other things, their FTS2001 charges; reviewed transition planning at these agencies and GSA; and analyzed GSA documentation of actions to address transition challenges.
Selected agencies--the Departments of Homeland Security, Commerce, and Agriculture and the Small Business Administration, U.S. Army Corps of Engineers, and the U.S. Nuclear Regulatory Commission--are generally following sound transition planning practices previously identified by GAO. For example, all have established telecommunications inventories, and most have established transition plans that include transition preparation tasks and time lines. However, other key practices are not being fully implemented at three agencies. For example, Commerce does not plan to clearly define all key transition roles and responsibilities, Homeland Security does not plan to identify local and regional points of contact, and the Nuclear Regulatory Commission does not plan to establish measures of success based on its transition objectives. With limited time available to finalize planning and begin transitions, agencies that do not address gaps in their planning or follow through on plans risk delaying their transitions and increase the likelihood of incurring unnecessary costs. As facilitator for all transition management activities, GSA has identified numerous common challenges that agencies face in making the transition to Networx, and it is taking action to resolve them. GSA uses various forums to identify these challenges, which include ensuring cooperation from incumbent contractors, defining agencies' responsibilities for information security during the transition, and the use of a transition inventory application developed by GSA. To resolve these challenges, GSA has, among other things, modified FTS2001 contracts to help ensure contractor cooperation, developed guidance to clarify information security responsibilities, and established support teams to assist agencies in using the inventory application developed by GSA. GSA's actions should reduce the likelihood that these challenges will hinder transition efforts.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-759, Telecommunications: Agencies Are Generally Following Sound Transition Planning Practices, and GSA Is Taking Action to Resolve Challenges
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Report to the Committee on Homeland Security and Governmental Affairs,
U.S. Senate:
United States Government Accountability Office:
GAO:
June 2008:
Telecommunications:
Agencies Are Generally Following Sound Transition Planning Practices,
and GSA Is Taking Action to Resolve Challenges:
GAO-08-759:
GAO Highlights:
Highlights of GAO-08-759, a report to the Committee on Homeland
Security and Governmental Affairs, U.S. Senate.
Why GAO Did This Study:
The General Services Administration (GSA) is responsible for ensuring
that federal agencies have access to the telecommunications needed to
meet mission requirements. GSA‘s current telecommunications program,
called FTS2001, has contracts in place that will expire by June 2010.
Thus, agencies face the difficult task of transitioning their services
to a successor program, known as Networx. GAO was asked to determine
(1) the extent to which agencies are following sound transition
planning practices and (2) the actions GSA is taking to identify and
resolve common transition challenges affecting agencies. In performing
this work, GAO selected six agencies based on, among other things,
their FTS2001 charges; reviewed transition planning at these agencies
and GSA; and analyzed GSA documentation of actions to address
transition challenges.
What GAO Found:
Selected agencies”the Departments of Homeland Security, Commerce, and
Agriculture and the Small Business Administration, U.S. Army Corps of
Engineers, and the U.S. Nuclear Regulatory Commission”are generally
following sound transition planning practices previously identified by
GAO (see table below). For example, all have established
telecommunications inventories, and most have established transition
plans that include transition preparation tasks and time lines.
However, other key practices are not being fully implemented at three
agencies. For example, Commerce does not plan to clearly define all key
transition roles and responsibilities, Homeland Security does not plan
to identify local and regional points of contact, and the Nuclear
Regulatory Commission does not plan to establish measures of success
based on its transition objectives. With limited time available to
finalize planning and begin transitions, agencies that do not address
gaps in their planning or follow through on plans risk delaying their
transitions and increase the likelihood of incurring unnecessary costs.
As facilitator for all transition management activities, GSA has
identified numerous common challenges that agencies face in making the
transition to Networx, and it is taking action to resolve them. GSA
uses various forums to identify these challenges, which include
ensuring cooperation from incumbent contractors, defining agencies‘
responsibilities for information security during the transition, and
the use of a transition inventory application developed by GSA. To
resolve these challenges, GSA has, among other things, modified FTS2001
contracts to help ensure contractor cooperation, developed guidance to
clarify information security responsibilities, and established support
teams to assist agencies in using the inventory application developed
by GSA. GSA‘s actions should reduce the likelihood that these
challenges will hinder transition efforts.
Table: Sound Transition Planning Practices:
1. Establish an accurate telecommunications inventory and an inventory
maintenance process.
2. Identify strategic telecommunications requirements and use this to
shape the agency‘s management approach and guide efforts when
identifying resources and developing a transition plan.
3. Establish a structured management approach that includes a dedicated
transition management team, key management processes (project
management, configuration management, and change management), and clear
lines of communication.
4. Identify the funding and human capital resources that the transition
effort will require.
5. Develop a transition plan that includes transition objectives,
measures of success, a risk assessment, and a detailed time line.
Source: GAO.
[End of table]
What GAO Recommends:
GAO recommends that Commerce, Homeland Security, and the Nuclear
Regulatory Commission address gaps in transition planning. Commenting
on a draft, Commerce agreed with the report, Homeland Security
disagreed with five of seven recommendations, while the Nuclear
Regulatory Commission agreed with one of two. However, failure to
follow sound planning practices could put agency transitions at risk.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-759]. For more
information, contact Linda Koontz at (202) 512-6240 or KoontzL@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Selected Agencies Are Generally Following Sound Transition Planning
Practices:
GSA Is Taking Action to Identify and Resolve Common Transition
Challenges:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the General Services Administration:
Appendix III: Comments from the Department of Commerce:
Appendix IV: Comments from the U.S. Nuclear Regulatory Commission:
Appendix V: Comments from the Department of Homeland Security:
Appendix VI: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Telecommunications Inventory:
Table 2: Strategic Analysis of Telecommunications Requirements:
Table 3: Structured Transition Management Approach:
Table 4: Resource Identification:
Table 5: Transition Plan:
Figures:
Figure 1: Expiration of FTS2001 Contracts:
Figure 2: Transition Time Line:
Abbreviations:
ACE: U.S. Army Corps of Engineers:
DHS: Department of Homeland Security:
DOC: Department of Commerce:
FAR: Federal Acquisition Regulation:
GSA: General Services Administration:
IMC: Interagency Management Council:
IT: Information Technology:
NRC: U.S. Nuclear Regulatory Commission:
OMB: Office of Management and Budget:
SBA: Small Business Administration:
TWG: Transition Working Group:
USDA: U.S. Department of Agriculture:
United States Government Accountability Office:
Washington, DC 20548:
June 27, 2008:
The Honorable Joseph Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs: United States
Senate:
The General Services Administration (GSA) is responsible for ensuring
that federal agencies have access to the telecommunications services
and solutions that they need to meet mission requirements. As federal
agencies have evolved in their use of telecommunications, so too has
GSA's development of contracts to help support their needs. Currently,
these telecommunications contracts not only support agencies' basic
telephony needs, but also provide an acquisition vehicle for wireless
and satellite services, as well as managed network services and
information technology (IT) security services. In fiscal year 2007
alone, federal agencies spent approximately $960 million on services
acquired through the contracts under GSA's current telecommunications
program, known as FTS2001. The FTS2001 contracts are set to expire by
June 2010.
In preparation for the end of its current telecommunications contracts,
GSA developed a successor program, known as Networx, and awarded
telecommunications contracts under this program in March and May 2007.
Agencies must now undertake the difficult task of transitioning their
telecommunications services to the Networx contracts. This transition
will involve more than 135 agencies, about 50 types of services, and
thousands of voice and data circuits. It could be the largest
telecommunications services transition ever undertaken by the federal
government and will require coordination among agencies, GSA, and a
host of telecommunications contractors.
This report responds to your request that we determine (1) the extent
to which federal agencies are following sound transition planning
practices and (2) the actions GSA is taking to identify and resolve
common transition challenges affecting agencies.
To determine the extent to which agencies are following sound
transition planning practices, we selected six agencies for review from
those that incurred FTS2001 charges in excess of $1 million for fiscal
year 2006. We selected agencies that would ensure a representation of
(1) executive departments, subagencies, and independent agencies; (2)
varying levels of attendance in the Transition Working Group, an agency
forum that is assisting GSA in its efforts to plan for the transition;
and (3) a range of agency spending for FTS2001 in excess of $1 million.
Based on these criteria, we selected the Departments of Homeland
Security, Commerce, and Agriculture and the Small Business
Administration, U.S. Army Corps of Engineers, and U.S. Nuclear
Regulatory Commission. We then obtained and reviewed documentation
(including strategic plans, telecommunications inventories, and
transition-related plans) and interviewed officials from each of the
selected agencies. We assessed this agency information against sound
telecommunications transition planning practices that we identified in
a report issued in 2006.[Footnote 1] In that report, we stated that
organizations preparing for a telecommunications transition should:
* establish a telecommunications inventory,
* perform a strategic analysis of telecommunications requirements,
* establish a structured transition management approach,
* identify resources, and:
* develop a transition plan.
Each of these sound planning practices consists of various components
(for example, developing a transition plan consists of (1) identifying
and documenting objectives and measures of success, (2) determining
risks that could affect success, and (3) defining transition
preparation tasks and developing a time line for these tasks). For the
current report, we classified the status of agency transition planning
efforts to address the practice components as "fully implemented," if
the agency has fully implemented the sound practice component; "plans
to fully implement," if the agency has plans to fully implement the
component; or "no plans to fully implement," if the agency does not
have plans to fully implement it. We discussed our assessments with
agency officials and made adjustments as appropriate.
To determine actions that GSA is taking to identify and resolve
challenges, we analyzed transition guidance and other Networx
documentation developed by GSA and the Interagency Management Council's
Transition Working Group, such as presentations, meeting minutes,
projected time lines, and a pre-award transition guide. We also
interviewed officials from GSA, FTS2001 incumbent vendors, Networx
vendors, and the six agencies selected for review.
We conducted this performance audit from September 2007 through June
2008, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. A detailed
discussion of our objectives, scope, and methodology can be found in
appendix I.
Results in Brief:
The selected agencies are generally following sound telecommunications
transition planning practices that we previously identified. For
example, all have established telecommunications inventories for
conducting their transitions, and all have ensured that identified
telecommunications needs and opportunities are aligned with their
respective missions, long-term IT plans, and enterprise architecture
plans. Further, most have established transition plans that include
transition preparation tasks and a time line that allows for periodic
reporting. However, three agencies are not fully implementing other key
practices and do not plan to do so. For example, Commerce does not plan
to define all key transition roles and responsibilities, Homeland
Security does not plan to identify local and regional points of
contact, and the U.S. Nuclear Regulatory Commission does not plan to
establish measures of success based on transition objectives--all of
which activities are components of the sound management practices that
we identified. Agency officials provided various reasons for not
following these practices, including reliance on other entities and
processes to carry them out. For example, Commerce officials stated
that the department did not plan to define all responsibilities for the
transition because the department's transition manager and each of its
components will be responsible for undefined roles. Homeland Security
officials stated that they do not plan to identify local contacts
because they believe the department's current process for communicating
telecommunications changes will be adequate for the transition. U.S.
Nuclear Regulatory Commission officials stated that instead of
establishing measures to assess progress toward the agency's transition
goals, they plan to use GSA-established measures related to transition
progress. Nonetheless, the time remaining for agencies to conduct their
telecommunications transitions is limited; thus, agencies that do not
address gaps in transition planning and follow through on their plans
risk delaying their transitions and increase the likelihood that the
government will incur unnecessary costs.
GSA has identified a number of challenges facing agencies in making the
transition to Networx contracts, and it is taking actions to resolve
them. Through the use of various forums, such as the Interagency
Management Council's Transition Working Group, GSA has identified
challenges such as ensuring cooperation from incumbent contractors,
defining agencies' responsibilities for information security during the
transition, and using a transition inventory application developed by
GSA. To resolve the challenges identified, GSA has taken a number of
actions, including modifying FTS2001 contracts to help ensure
contractor cooperation, developing guidance to clarify information
security responsibilities, and establishing support teams to assist
agencies in using the inventory application. GSA's actions should
reduce the likelihood that these challenges will affect transition
efforts.
To reduce the risk that transition delays could lead to disruptions in
agency telecommunications services or increased costs, we are making
recommendations to the Secretaries of Commerce and Homeland Security
and the Chairman of the U.S. Nuclear Regulatory Commission aimed at
addressing gaps in their agencies' transition planning.
We received comments on a draft of our report from five of the seven
agencies reviewed. GSA, Commerce, the Nuclear Regulatory Commission,
and Homeland Security provided written comments (which are reproduced
in apps. II through V), and the Small Business Administration provided
comments via e-mail. Two agencies, Agriculture and U.S. Army Corps of
Engineers, indicated via e-mail that they had no comments.
Three of the agencies generally agreed with our report, and two
partially agreed. Agencies generally agreeing were GSA, the Department
of Commerce, and the Small Business Administration. The Nuclear
Regulatory Commission and the Department of Homeland Security disagreed
with aspects of our findings and recommendations.
* The Nuclear Regulatory Commission indicated that our report generally
reflects the issues surrounding agency preparedness for transition.
However, the responding official suggested that we remove our
recommendation for the Commission to evaluate the costs and benefits of
new technology or alternatives, because such an evaluation had been and
would be conducted as part of its normal planning processes.
Nonetheless, our recommendation remains because the Commission did not
perform this activity for the transition to Networx. Commission
officials also provided technical comments, which we incorporated into
our report as appropriate.
* Homeland Security agreed with two and disagreed with five of the
seven recommendations directed toward the department, and it did not
concur with one finding. The department agreed with our recommendations
that it establish goals and measures of success and perform a
transition risk assessment for the department's transition. It
disagreed with the remaining recommendations, indicating that it was
already taking actions in these areas. However, these actions are
already reflected in our assessment and do not meet the sound practice
standards on which we based our recommendations. For example, regarding
telecommunications inventory maintenance, the department's comments
acknowledged that it has not published a process document for
maintaining its inventory of telecommunications service assets, but
stated that it instructed its components to use documented GSA
procedures to maintain their inventories. However, sound practices call
for the agency to document the process to be used by its components for
inventory maintenance to lessen the risk that changes to the inventory
during and after transition would not be consistently and accurately
captured. Finally, the department stated that it does not concur with a
finding related to defining communications plans, indicating that the
charter for its transition working group defines essential
communications responsibilities and activities. Our report acknowledges
that lines of communication have been established; however, the
department's communications planning is incomplete because Homeland
Security did not identify local and regional points of contact, as
advocated by sound practices.
Background:
GSA's existing FTS2001 program is the successor to a line of programs
that have provided long-distance telecommunications to the federal
government. Made up of two large governmentwide contracts--one awarded
to Sprint[Footnote 2] in December 1998 and one awarded to MCI[Footnote
3] in January 1999--the program is designed to meet agency needs for
various telecommunication services. It also includes contractors that
had been awarded local telecommunications contracts for selected
metropolitan areas. GSA allowed these contractors to also offer long-
distance services on the FTS2001 contracts--termed "crossover
contracts."[Footnote 4]
The original terms of the two FTS2001 contracts were set to expire in
December 2006 and January 2007. However, to give itself time to
finalize the contracts intended to succeed the FTS2001 contracts and to
provide its customer agencies additional time to complete their
transitions once the Networx contracts were awarded, GSA negotiated
sole-source contracts (termed FTS2001 bridge contracts) with Sprint and
MCI to provide continuity of service for agencies. These bridge
contracts, which extend the terms of the FTS2001 contracts for no more
than 42 months,[Footnote 5] began in December 2006 and January 2007 and
are to expire at the end of May and June 2010, respectively.
In October 2003, GSA announced its plans for the Networx program. In
conjunction with a group of senior federal information resource
officials known as the Interagency Management Council (IMC),[Footnote
6] GSA identified eight strategic goals for the program:
* Service continuity--Contracts should include all services currently
available under FTS2001 to facilitate a smooth transition.
* Competitive prices--Prices should be better than those available
elsewhere in the telecommunications marketplace.
* High-quality service--Contracts should ensure a high quality of
service throughout the life of the contracts using enforceable
agreements.
* Full service vendors--Vendors should be capable of providing a broad
array of services and provide follow-on services to avoid duplication
of administrative and contracting costs.
* Alternative services--Agencies should be able to choose from a
greater number of competing vendors that provide new, enhanced services
and emerging technologies.
* Transition support--Contracts should include provisions that
facilitate transition coordination and support.
* Performance-based contracts--Contracts should be performance based
and include service-level agreements where possible.
* Operations support--GSA should provide fully integrated ordering,
billing, and inventory management.
In addition, GSA identified goals specific to the Networx transition
and indicated that the ability of GSA and the Networx contractors to
deliver against these goals is essential to the overall success of the
transition effort. These goals include:
- minimizing service impact,
- transitioning telecommunications services before the FTS2001
contracts expire,
- expediting the availability of new services, and:
- minimizing transition expenses.
Under the Networx program, GSA awarded two multiple-award task and
delivery order contracts--Networx Universal and Networx Enterprise--
having a combined estimated value of $20 billion. The contracts were
awarded in March and May 2007, respectively.
* GSA awarded Networx Universal contracts to AT&T, Verizon Business
Services, and Qwest Government Services. Networx Universal offers voice
and data services, wireless services, and management and application
services, including video and audio conferencing, as well as mobile and
fixed satellite services, with national and international coverage.
* GSA awarded Networx Enterprise contracts to AT&T, Verizon Business
Services, Qwest Government Services, Level 3 Communications, and Sprint
Nextel. Networx Enterprise offers services similar to those of Networx
Universal, with a focus on those that are Internet-based, and does not
require coverage of as large a geographic area as does Networx
Universal.
Transition Responsibilities:
Central to the successful transition from FTS2001 to Networx are
transition planning and execution activities that involve GSA, the
agencies, and FTS2001 and Networx contractors. GSA serves as a
facilitator for all transition management activities and is using
contracted support to assist in tracking transition activities in order
to avoid delays and other problems that can arise throughout the
process.
GSA's primary responsibility is program management of both the FTS2001
and Networx programs. As part of this, GSA is responsible for:
* providing guidance and assistance to agencies for the transition to
Networx to ensure that unnecessary delays in agency transitions are
avoided;
* developing an overall Networx transition strategy, minimizing agency
transition costs, and ensuring that all telecommunications services are
transitioned in a timely manner; and:
* tracking daily progress of transition efforts, performing program-
level analysis to support transition goals and objectives, and
resolving transition issues.
The GSA organization carrying out these responsibilities is the Federal
Acquisition Service, an organization formed in 2006 from the merger of
GSA's Federal Technology Service, which had managed the FTS2001
program, and GSA's Federal Supply Service.
To assist agencies with their transitions from the FTS2001 contracts,
GSA is working with representatives of federal agencies, both directly
and through the IMC. A subgroup of the IMC, the Transition Working
Group (TWG), was established in May 2004 to assist with developing a
consensus on common transition issues that affect multiple agencies.
The TWG coordinates with GSA, agencies, and industry partners to ensure
thorough advance planning and preparation efforts for the transition to
Networx. The TWG also serves as a conduit for communications among GSA
and its customer agencies.
GSA's customer agencies--those federal agencies acquiring services
through the FTS2001 program--have principal responsibility for the
transition. These agencies are responsible for coordinating transition
efforts with the incumbent and Networx contractors to ensure that
existing services under FTS2001 are disconnected and that new services
are ordered. GSA and the IMC have requested each of the customer
agencies to appoint a transition manager and establish a transition
team that will:
- manage the agency's internal transition planning, preparation, and
execution efforts and:
- be responsible for interfacing with GSA, the IMC, and officials
within the agency.
Both the Networx contractors and incumbent FTS2001 contractors are
responsible for supporting agencies in their transition planning and
execution efforts:
* Networx contractors will be responsible for delivering services
ordered, developing program-level and agency-level transition plans,
and communicating the status of transition activities with scheduled
notices and reports.
* Incumbent FTS2001 contractors are expected to complete all FTS2001
service disconnect orders requested by agencies and assist agency
efforts to prepare for the transition by, for example, helping to
identify inventory information and system requirements.
GSA and Agencies Have Taken Steps to Address Difficulties Encountered
in a Previous Transition:
The previous transition of federal telecommunications services was a
large and complex task that underscored the importance of proper
transition management practices. In 2001, we reported[Footnote 7] that
the transition to the current FTS2001 federal telecommunications
contracts encountered delays and took more than 24 months, which
hindered the timely achievement of program goals. We also reported that
transition delays resulted in raised telecommunications costs. In
total, an estimated $74 million in savings was lost due to delays in
completing the transition to FTS2001.
Subsequently, the TWG, in conjunction with GSA, identified 27 lessons
learned from the previous transition. For example, lessons learned
include (1) the need for GSA and agencies to identify funding for the
transition early to ensure that resources are available and (2) the
need to ensure that local agency sites are not responsible for delays
due to access issues. Of the 27 lessons learned, 13 related to
transition planning, 11 to transition execution, and 3 to transition
monitoring. Together, the lessons learned affirmed that applying
adequate transition practices--including planning, executing, and
monitoring the transition--increases the likelihood of a successful
transition from FTS2001 contracts to Networx.
GSA and representatives of its customer agencies have taken actions to
address these lessons learned. For example, to address funding for the
transition, GSA and the TWG developed a Taxonomy and Allocation of
Transition Costs document, which the IMC approved, that describes each
type of transition cost and whether GSA or the agency would be
responsible. And to help ensure that local agency sites are not
responsible for delays, GSA has provided guidance to agencies on
creating staffing and training plans to better ensure that those
involved are prepared for the transition effort.
GSA has also developed numerous guidance documents and presentations
related to the transition, as well as several tools. Much of this
information is maintained by GSA in two locations on the Internet--its
public Web site at [hyperlink, http://www.gsa.gov/networx] and a Web
site accessible only to agency transition managers and TWG members.
Documentation developed includes, for example, a guide to assist
agencies in selecting the vendor best suited to provide required
services while giving all vendors fair opportunity to be considered for
each order--known as the fair opportunity process[Footnote 8]. GSA has
also developed numerous presentations on the transition from FTS2001
and briefings presented to agency transition managers. Further, GSA has
developed tools specifically designed to aid agencies as they
transition to Networx, such as a transition inventory application to
help agencies identify and validate their transition inventories and a
tool that agencies can use to price their services against the various
Networx contract offerings.
GSA Has Provided Agencies Incentives to Transition Early:
With GSA's FTS2001 contracts set to expire by June 2010--within the
next 2 years--agencies have a limited time frame within which to
complete their transitions (see fig. 1). As mentioned earlier, the
FTS2001 bridge contracts expire in May and June 2010. In addition,
GSA's FTS2001 crossover contracts with Qwest, Verizon, AT&T, Winstar
Communications, and SBC will expire between January 2008[Footnote 9]
and May 2010. Therefore, agencies have approximately 2 years to
transition all FTS2001 services before all FTS2001 contracts expire.
Figure 1 depicts these expiration dates.
Figure 1: Expiration of FTS2001 Contracts:
This figure is a timeline of expiration of FTS2001 contracts.
[See PDF for image]
Source: GAO analysis of GSA data.
[A] Upon contract expiration or termination, a continuity of service
period provides an agency additional time to use FTS2001 services until
the agency is able to transition to a successor contract.
[End of figure]
To address the approaching expirations, GSA is taking several actions.
First, to provide an incentive to transition early, GSA and the IMC
agreed upon milestones and associated criteria that, if met, would
allow agencies to be reimbursed by GSA for certain transition-related
costs. Second, in meetings with agency Chief Information Officers, GSA
has emphasized the importance of conducting an efficient and timely
transition as well as garnering executive-level buy-in for transition
support. Third, GSA's Technology Service Managers have been in contact
with agencies to ensure that they are working toward transitioning
their FTS2001 services. Fourth, the collection of GSA documents,
presentations, and tools is geared toward assisting agencies in
planning and executing their transitions.
Specifically, to qualify for reimbursements, an agency must comply with
the following milestones (fig. 2 depicts these milestones against the
transition time line):
* By September 30, 2008, agencies are to complete "fair opportunity"
decisions--that is, select their vendors--for all services to be
transitioned from FTS2001 telecommunications contracts.
* By January 1, 2010, agencies must submit all transition orders that
will incur costs related to parallel operations. GSA will not reimburse
any costs for parallel operations an agency orders after this date.
* By April 1, 2010, agencies must submit all transition orders. GSA
will not reimburse any costs for transition orders an agency places
after this date.
Figure 2: Transition Time Line:
This figure is a timeline showing transition.
[See PDF for image]
Source: GAO analysis of GSA data.
[End of figure]
Our Prior Work Has Addressed Telecommunications Transition Planning:
We have issued several reports on issues surrounding GSA's FTS2001 and
Networx telecommunications programs. Specifically, we reported on
difficulties encountered during the previous transition, agency
preparation for the transition to Networx, sound transition planning
practices, and GSA's cost estimation for the transition to Networx.
In 2001, we reported on difficulties encountered during the transition
to the FTS2001 program.[Footnote 10] We found that the collective
effect of delays encountered during this complex transition jeopardized
the timely achievement of FTS2001's program goals. Delays occurred for
several reasons. For example, delays occurred because agency efforts to
order services were impeded by the inability of GSA and the long-
distance contractors to rapidly add, through a contract modification
process, transition-critical services to the FTS2001 contracts. Other
identified reasons for transition delays included that agencies were
slow to place orders for transition services and that contractors had
issues with staffing and billing that impaired their efforts to support
agencies' transition activities. We also reported that encountered
delays would, among other things, cause agency telecommunications costs
to rise.
In 2006, we reported on sound transition planning practices that
agencies could use to improve the likelihood of a smooth
transition.[Footnote 11] These planning practices are to:
* establish a telecommunications inventory,
* perform a strategic analysis of telecommunications requirements,
* establish a structured transition management approach,
* identify resources, and:
* develop a transition plan.
Each of these sound planning practices consists of various components
(for example, developing a transition plan consists of (1) identifying
and documenting objectives and measures of success; (2) determining
risks that could affect success; and (3) defining transition
preparation tasks and developing a time line for these tasks).
We assessed the progress of six agencies in preparing for the
transition and reported that although agencies were early in the
planning process, they were generally planning to employ sound
transition planning practices in their transition management efforts.
However, officials at two of the agencies stated that they did not plan
to fully identify necessary resources. Specifically, officials at the
Department of Justice indicated that they would not need additional
financial resources, even though they could not provide an analytical
basis for their decision, and officials from the Department of Energy
believed that because the agency's transition would be straightforward,
identifying human capital needs would not be necessary. We also
reported that GSA had provided agencies with guidance on performing
some but not all of the sound transition planning practices we
identified.
As a result, we recommended that:
* the Attorney General ensure that the Department of Justice's planning
efforts include an analysis of the extent to which current financial
resources would be sufficient to conduct an effective transition;
* the Secretary of Energy ensure that the department's planning efforts
included identification of human capital resources needed to conduct an
effective transition; and:
* the Administrator of General Services, in working with the IMC,
develop and distribute guidance to ensure that our identified sound
practices for transition planning were used.
In response, the three agencies took action or indicated that they
planned to take action to implement our recommendations. The Department
of Justice's Chief Information Officer indicated that the department
intended to analyze and determine its financial and other resource
requirements for transition in the near future. However, as of April 1,
2008, it had not yet done so. The Department of Energy provided a
transition plan that indicated that the need for human capital
resources for the transition would be dependent on the Networx
contractor or contractors chosen; once contractors were selected, the
agency planned to re-examine its human capital needs to ensure that
adequate support would be provided for transition execution. Finally,
GSA provided guidance to agencies that addresses our identified sound
transition planning practices.
In 2007, we reported on GSA's development of cost estimates for the
transition to Networx, stating that while it had adequate funding to
support its anticipated transition costs, it did not use sound analysis
when developing its estimate.[Footnote 12] Accordingly, to ensure that
future cost estimates by GSA were sound and could be used as a reliable
basis for decisions, we recommended that the Administrator of General
Services establish an agencywide policy requiring that cost estimates
be developed using best practices. In addition, we recommended that the
Administrator revise the transition cost estimate for Networx using
best practices after the award of contracts under the Networx program.
To address these recommendations, GSA established an agencywide policy
requiring that its cost estimates be developed using best practices.
Regarding the revision of its transition cost estimate, GSA officials
indicated that once a significant number of agencies have made their
fair opportunity decisions, it will recalculate the transition cost
estimate, brief the IMC, and provide the results to us. Officials
stated that GSA will brief the IMC in June 2008 on the revised
transition estimate.
Selected Agencies Are Generally Following Sound Transition Planning
Practices:
The selected agencies are generally following the sound
telecommunications transition planning practices that we identified in
our 2006 report.[Footnote 13] For example, all have established
telecommunications inventories for conducting their transitions, and
all have ensured that identified telecommunications needs and
opportunities are aligned with their respective missions, long-term IT
plans, and enterprise architecture plans. However, key practices are
not being fully implemented at three agencies: Commerce, Homeland
Security, and the U.S. Nuclear Regulatory Commission. Officials of
these agencies provided various reasons for not following these
practices, including reliance on other entities and processes to carry
them out. For example, for the key practice of establishing a
structured transition management approach, one of the practice
components is identifying key local and regional transition officials
and points of contact who are responsible for disseminating
information. Homeland Security did not plan to identify such local and
regional points of contact; officials stated that when
telecommunications changes occur, the department will rely on processes
already in place to convey information through departmental channels to
local contacts. However, in view of the potentially large number of
locations and short time frames involved in the transition, relying on
the standard process could be risky. If Homeland Security does not
identify all of its local points of contact before it begins
transitioning services, communication difficulties could produce delays
in providing the required site access for vendors (such delays occurred
during the previous transition). Agencies that do not address such gaps
in transition planning and follow through on their plans risk delaying
their transitions and increase the likelihood that the government will
incur unnecessary costs.
Agencies Have Identified Transition Inventories, but Processes for
Maintaining Them Are Not Yet in Place:
As described in our 2006 report, sound transition planning practices
include establishing an accurate inventory of current
telecommunications assets and services. First, agencies should have a
detailed and complete transition inventory that represents all of their
facilities, components, field offices, and any other managed sites. It
should include information such as telecommunications services, traffic
volumes, equipment, and applications being used. Second, agencies
should have a documented inventory maintenance process that can be used
to ensure that inventories remain current and reflect changes leading
up to, during, and after the transition. Once established, an inventory
maintenance process can ensure that changes are captured and allow
agencies to audit vendor bills against their inventories throughout the
life of the contract.
Agencies should begin efforts to establish a telecommunications
inventory early because the development of an accurate and reliable
inventory is important to ensuring that the agency will be prepared to
transition quickly. Agencies can use their transition inventories to
identify opportunities for optimizing their current technology during
strategic planning and to help determine areas for optimization and/or
sharing of IT resources across the agency.
Table 1 summarizes the extent to which transition planners have
established telecommunications inventories at the U.S. Army Corps of
Engineers (ACE), Department of Homeland Security (DHS), Department of
Commerce (DOC), U.S. Nuclear Regulatory Commission (NRC), Small
Business Administration (SBA), and U.S. Department of Agriculture
(USDA).
Table 1: Telecommunications Inventory:
Sound practice components: The agency has identified complete
telecommunications inventories at every site, facility, and component
for the transition from FTS2001;
ACE: Practice component has been fully implemented;
DHS: Practice component has been fully implemented;
DOC: Practice component has been fully implemented;
NRC: Practice component has been fully implemented;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Sound practice components: The agency has a documented process for
updating and maintaining its inventories;
ACE: Practice component has been fully implemented;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Agency plans to fully implement practice component.
Source: GAO analysis.
[End of table]
As the table shows, all agencies have addressed the first of the two
components of this practice. All six identified telecommunications
inventories that are sufficient for conducting their
transitions.[Footnote 14] Those agencies with established
telecommunications transition inventories are likely to be better
prepared to address strategic considerations and avoid unnecessary
transition delays associated with inventory identification.
However, four of the six agencies had not documented a process to
maintain their inventories to ensure that they remain current, although
three had developed plans to do so:
* Agriculture and Commerce have drafted inventory maintenance
processes.
* NRC's transition manager stated that the agency plans to develop a
maintenance process as part of its efforts to establish an expense
management system.
Homeland Security does not plan to develop such a process. Homeland
Security's transition manager stated that the department did not have a
documented inventory maintenance process or policy at its headquarters
or any of its components. The transition manager stated that the
department has instructed its components to maintain their inventories.
However, there was no documentation of this instruction, and the
department did not have plans to document a maintenance process.
Without a documented inventory maintenance process, agencies may not
consistently and accurately capture the changes to their
telecommunications inventories during and after transition, hindering
their ability to ensure that they are billed appropriately by the
vendor or to determine areas for optimization and sharing of
telecommunications and IT resources across the agency.
Half of the Agencies Have Incorporated Strategic Needs into Transition
Planning:
Sound transition planning practices, as described in our earlier work,
include identifying strategic telecommunications requirements and
incorporating them into transition planning. To accomplish this,
agencies should use an inventory of existing services to determine
current and future telecommunications needs. Agencies should also use
the transition as an opportunity to identify areas for optimization or
sharing of telecommunications and IT resources across the agency. The
costs and benefits of introducing new technology and alternatives for
meeting the agency's telecommunications needs should be evaluated.
Further, the identified needs and opportunities should be aligned with
the agency's mission, long-term IT plans, and enterprise architecture
plans.[Footnote 15] The agency's telecommunications requirements should
shape the agency's management approach to the transition and guide
other efforts, such as identifying and allocating resources and
developing a transition plan.
Table 2 summarizes the extent to which the six agencies have performed
a strategic analysis of telecommunications requirements.
Table 2: Strategic Analysis of Telecommunications Requirements:
Sound practice components: The agency has identified current and future
telecommunications needs, areas for optimization and sharing, and the
costs and benefits of any options;
ACE: Practice component has been fully implemented;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency does not plan to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Sound practice components: The agency has determined that needs and
opportunities are aligned with its mission, long-term IT plans, and
enterprise architecture plans;
ACE: Practice component has been fully implemented;
DHS: Practice component has been fully implemented;
DOC: Practice component has been fully implemented;
NRC: Practice component has been fully implemented;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Source: GAO analysis.
[End of table]
As the table shows, all six agencies have addressed the second of the
two components of this practice: all have determined that needs and
opportunities are aligned with their missions, long-term IT plans, and
enterprise architecture plans. However, only half (Agriculture, ACE,
and SBA) have fully implemented the other component: identifying
current and future telecommunications needs, areas for optimization and
sharing, and the costs and benefits of any options. One agency
(Commerce) has plans to fully implement this component. That is,
Commerce has determined its current and future telecommunications needs
and, according to officials, plans to identify areas for optimization
and sharing, as well as costs and benefits, before completing the fair
opportunity process.
However, two agencies (NRC and Homeland Security) do not have plans to
fully implement this practice:
* NRC had identified current and future needs and established long-term
plans to meet those needs, but it does not plan to evaluate the costs
and benefits of alternatives to meeting its telecommunications needs
for this transition. NRC officials stated that they plan to transition
only existing services, and alternatives would not be evaluated until
after transition.
* Although Homeland Security's transition plans address strategic
needs, the department did not evaluate the costs and benefits of new
technology or alternatives for meeting its telecommunications needs.
Homeland Security officials stated that they felt this activity was not
appropriate because they did not have the choice not to transition to
Networx.
Without assessing the costs and benefits of alternatives for meeting
their needs, NRC and Homeland Security may not be taking full advantage
of the transition as an opportunity to optimize their
telecommunications services, such as by upgrading and optimizing their
telecommunications services, or shifting service to more cost-effective
technology. Further, if agencies do not incorporate strategic
requirements into their planning, they risk making decisions that are
not aligned with their long-term goals.
Most Agencies Have Developed or Plan to Develop a Structured Transition
Management Approach:
The sound transition planning practices that we identified in our
earlier work include establishing a structured transition management
approach. This entails establishing a transition management team
involved in all phases of the transition and clearly defining
responsibilities for key transition activities, such as project
management, asset management, contract and legal expertise, human
capital management, and information security management. The agency
should also ensure a comprehensive understanding of the transition by
identifying those who will be involved and how transition plans,
including transition objectives, will be communicated. This also
involves communicating what is going to happen and when, such as the
frequency of status updates and meetings, and should include alerting
and educating end users to changes or disruptions. Key local and
regional transition officials and points of contact should be
identified who are responsible for disseminating information to
employees and working with the vendor to facilitate transition
execution.
In addition, the agency should ensure that it uses established project
management, configuration management, and change management processes
during the transition. Project management processes can be used to plan
and manage transition-related activities, providing a structure that
incorporates performance measurement and project-level control.
Configuration management processes help ensure integrity and
traceability as change occurs. Change management processes help
employees prepare for the procedure and technology changes that may
accompany a transition, reducing the risk that improvement efforts will
fail.
Table 3 summarizes the extent to which the six agencies have
established a structured transition management approach.
Table 3: Structured Transition Management Approach:
Sound practice components: The agency has established a transition
management team and clearly defined responsibilities for key transition
roles;
ACE: Practice component has been fully implemented;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency does not plan to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Agency plans to fully implement practice component;
USDA: Agency plans to fully implement practice component.
Sound practice components: The agency has identified communication
plans in order to facilitate information sharing during transition
planning and execution;
ACE: Agency plans to fully implement practice component;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Agency plans to fully implement practice component.
Sound practice components: The agency is using project management,
configuration management, and change management processes in the
management of its transition planning efforts;
ACE: Practice component has been fully implemented;
DHS: Agency plans to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Agency plans to fully implement practice component;
USDA: Agency plans to fully implement practice component.
Source: GAO analysis.
[End of table]
With regard to the first component of this practice, one agency (ACE)
established a transition management team and defined all key transition
roles and responsibilities; the remaining five agencies have
established management teams, but have yet to define all roles and
responsibilities. Specifically, three agencies had not yet defined
responsibilities for certain roles, but planned to do so:
* Agriculture had not defined the role of legal expertise in its
transition efforts, but it has requested support and was awaiting a
response from its Office of General Counsel.
* SBA had yet to define responsibility for asset management, but
officials indicated that they plan to do so.
* NRC had yet to define responsibility for information security
management, but officials indicated that they planned to do so.
The remaining two agencies did not plan to fully implement this sound
practice component:
* Commerce officials stated that the responsibilities for asset and
human capital management will rest with the department's transition
manager and each individual component; therefore, the department did
not plan to define responsibilities for these roles.
* Homeland Security officials stated that roles such as asset
management, legal expertise, human capital management, and information
security management would not be assigned by name because expertise in
these areas would be available as needed.
However, by not defining key roles and responsibilities for the
transition, these agencies risk extending their transition period as
they attempt to assign appropriate personnel and update them on
transition progress and issues.
With regard to the second component of this practice, one agency (SBA)
identified communications plans and local and regional points of
contact. Four additional agencies plan to fully address this sound
practice component. Specifically:
* Agriculture developed a communications plan, and its transition plans
indicated that it will identify transition points of contact by the end
of fiscal year 2008.
* Commerce officials stated that they plan to develop transition and
communications plans that will include transition points of contact.
* A contractor supporting ACE's transition is required to develop a
communications plan, and the ACE transition plan indicates that the
contractor is in the process of identifying transition points of
contact.
* NRC officials stated that they plan to develop a communications plan
as part of the agency's transition plan, which is to include transition
points of contact.
However, one agency (Homeland Security) does not plan to fully
implement this sound practice component. Specifically, although it has
established lines of communication, it had not identified local and
regional points of contact to facilitate transition execution, because,
according to department officials, when telecommunications changes
occur, the department has a process in place to convey information
through departmental channels to local contacts, and officials believe
that this process will be adequate for any changes that are part of the
transition. However, in view of the potentially large number of
locations and short time frames involved in the transition, relying on
the standard process could be risky. If Homeland Security does not
identify all of its local points of contact before it begins
transitioning services, communication difficulties could produce delays
in providing the necessary site access for vendors (such delays
occurred during the previous transition).
With regard to the third component of this practice, ACE is the only
agency currently using all three key management processes--project
management, configuration management, and change management processes-
-in the management of its transition, but the other five agencies were
using at least one of these management processes and planned to use all
three. Officials at the five agencies generally provided policies or
other documents indicating that all three processes would be used or
stated that they planned to implement those not yet in use.[Footnote
16]
Agencies that do not use a sound management approach risk additional
financial costs, extended time lines, and disruptions to the continuity
of their telecommunication systems. Further, without establishing lines
of communication and identifying local and regional points of contact,
agencies may lack the quality of information that is necessary for
comprehensive understanding, accountability, and shared expectations at
all levels.
Most Agencies Have Identified or Plan to Identify Resources Necessary
for the Transition:
Our sound transition planning practices include ensuring that the
resources required to successfully plan for the transition are
identified. To do so, the agency should identify any funding
requirements for its transition planning efforts to ensure that
resources needed are available. The organizational need for investments
should be identified and the agency should assess benefits versus costs
to justify any resource requests. Cost-benefit analyses and return-on-
investment calculations are common methods used to justify requests.
Transition planning costs that should be considered include transition
project management, software and hardware upgrades, and establishing
reliable inventories.
The agency should also determine staffing levels that may be required
throughout the transition effort, as well as ensure that personnel with
the right skills are in place to support the transition effort. As
mentioned earlier, some of the skills needed are project management,
asset management, contract and legal expertise, human capital
management, and information security expertise. Further, the agency
should require training for those carrying out the transition or
operating and maintaining newly transitioned technology.
Identifying the need for resources early in the planning process is
likely to help to avoid unnecessary spending and delays during the
transition. Further, the resources allocated to the transition effort
should reflect the level of change identified in the agency's strategic
analysis of telecommunications requirements; that is, if the agency
chooses to implement new technology, it must budget resources
accordingly.
Table 4 summarizes the extent to which the six agencies have identified
resources for their transitions.
Table 4: Resource Identification:
Sound practice components: The agency has identified the level of
funding needed to support transition planning, and justified
organizational resource requests;
ACE: Agency does not plan to fully implement practice component;
DHS: Agency does not plan to fully implement practice component;
DOC: Practice component has been fully implemented;
NRC: Agency does not plan to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Sound practice components: The agency has identified human capital
needs for the entire transition effort;
ACE: Agency plans to fully implement practice component;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Sound practice components: The agency has required training for the
transition;
ACE: Practice component has been fully implemented;
DHS: Practice component has been fully implemented;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Agency plans to fully implement practice component.
Source: GAO analysis.
[End of table]
As table 4 shows, three agencies addressed the first component of this
practice, having identified the level of funding needed to support
transition planning efforts and justified organizational resource
requests. However, three did not: Homeland Security, NRC, and ACE did
not address funding requirements for their transition planning efforts
before planning their transitions and, among other things, identifying
inventories. Instead, the three agencies moved forward with performing
transition planning using existing resources without having analyzed
the sufficiency of these resources. At this late point in the planning
process, performing such an analysis is no longer feasible.
With regard to the second component, two agencies (SBA and Agriculture)
have identified staffing levels that will be needed throughout the
transition, and three plan to do so. ACE and Commerce provided evidence
of efforts under way to identify staffing resources that will be
needed, and NRC officials stated that they plan to address staffing
levels in the agency's transition plan.
Homeland Security indicated that although staffing specific to the
transition effort was not identified, staffing for the transition was
taken into consideration as part of the department's acquisition for a
wide-area network under Networx. However, Homeland Security did not
provide documentation to demonstrate that this sound practice component
had been addressed. Without determining staffing needs for its
transition effort, Homeland Security risks underestimating the
complexity and demands of the transition, which may lead to delays and
unexpected costs.
As the table shows, three agencies have fully implemented the third
component: Homeland Security, ACE, and SBA have required training for
those involved in the transition. Of the remaining agencies, Commerce
has a draft policy requiring those involved with the transition to meet
certain training requirements, and a draft Agriculture transition plan
indicated that training requirements will be addressed. NRC officials
stated that they plan to identify training requirements in the agency's
transition plan.
As illustrated by lessons learned from the previous transition,
agencies that do not fully analyze their transition-related resource
needs may be underestimating the complexity and demands of the
transition effort. Further, unexpected costs may arise that lead to
delays and unnecessary spending that could have been avoided.
The Agencies Have Generally Established Transition Plans, but None Have
Established Measures of Success:
The sound transition planning practices we identified include
developing a transition plan that identifies transition objectives,
measures of success, and risks, and that approaches the transition
planning process as a critical project with a detailed time line. To
facilitate this practice, agencies' transition management teams should
undertake the following three activities:
* The agency should identify transition objectives and measures of
success. Transition objectives should be based on the agency's
strategic analysis of telecommunications requirements and aligned with
the agency's overall mission and business objectives. Measures of
success should be based on these transition objectives. They are a key
tool to help managers assess progress.
* The agency should identify agency-specific risks that could affect
transition success. The importance of the risks should be evaluated
relative to the agency's mission-critical systems and continuity of
operations plans. Knowing what risks exist and how to mitigate them
appropriately will lessen problems and delays during the transition.
This risk assessment should also include an analysis of information
security risks to determine what controls are required to protect
networks and what level of resources should be expended on controls.
* The agency should develop a transition plan that depicts a management
strategy with clearly defined transition preparation tasks and includes
a time line that allows for periodic reporting. This time line should
take into account priorities relative to the agency's mission-critical
systems, contingency plans, and identified risks.
Table 5 identifies the extent to which the agencies have developed
plans for the transition.
Table 5: Transition Plan:
Sound practice components: The agency has identified and documented
agency-specific transition objectives and measures of success;
ACE: Agency plans to fully implement practice component;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency does not plan to fully implement practice component;
SBA: Agency plans to fully implement practice component;
USDA: Agency plans to fully implement practice component.
Sound practice components: The agency has identified agency-specific
risks that could affect transition success including information
security risks;
ACE: Agency plans to fully implement practice component;
DHS: Agency does not plan to fully implement practice component;
DOC: Agency plans to fully implement practice component;
NRC: Agency plans to fully implement practice component;
SBA: Agency plans to fully implement practice component;
USDA: Agency plans to fully implement practice component.
Sound practice components: The agency has clearly defined transition
preparation tasks and developed a time line;
ACE: Agency plans to fully implement practice component;
DHS: Practice component has been fully implemented;
DOC: Practice component has been fully implemented;
NRC: Agency plans to fully implement practice component;
SBA: Practice component has been fully implemented;
USDA: Practice component has been fully implemented.
Source: GAO analysis.
[End of table]
Four of the agencies have plans to fully implement the first component
of this sound practice, with three having documented agency-specific
transition objectives and the remaining planning to do so. And while
none had yet established measures of success, officials at all four
stated that they plan to do so. However, NRC and Homeland Security do
not plan to fully address this component.
* Although NRC officials stated that they plan to establish transition
objectives, they do not plan to establish measures of success. Instead
of establishing measures to assess progress toward agency goals, NRC
officials stated that they plan to use GSA-established measures related
to governmentwide transition progress.
* Homeland Security officials stated that transition goals were
discussed, but evidence was not provided, and the department had no
plans to establish measures of success. Without documenting objectives
for the transition, Homeland Security may find it difficult to provide
those involved in the transition with clear expectations.
Those agencies that do not establish measures of success based on
documented objectives will lack information that could be used to track
progress toward transition objectives and inform management decisions.
Five agencies plan to fully implement the second component of this
sound practice: identifying agency-specific risks that could affect
transition success. Specifically, for ACE, Agriculture, and Commerce,
the agencies' transition plans indicate that agency-specific transition
risks will be identified. For SBA, a memorandum indicated that a formal
risk assessment will be performed before the transition to Networx. For
NRC, officials stated that risks will be addressed in the agency's
transition plan and that information security risks will be addressed
during the agency's fair opportunity process.
One agency, however, did not have plans to fully address this sound
practice component. Homeland Security performed a high-level risk
assessment, but this assessment did not address risks to mission-
critical systems, continuity of operations plans, or information
security risks, which are key components of this practice. Homeland
Security officials stated that information security risk assessments
will be performed in accordance with federal requirements, but they do
not intend to identify information security risks specific to their
transition effort. If they do not analyze risks relevant to the
transition, agencies may encounter problems and delays during the
transition because they are not adequately prepared to mitigate risks.
Four of the agencies fully implemented the third step of this practice,
having transition plans that depicted a management strategy with
clearly defined transition preparation tasks and included a time line
that allowed for periodic reporting. The remaining two agencies'
transition plans indicate that they will fully implement this sound
practice component.
Agencies that do not document measurable objectives and clearly define
transition tasks that take into account agency priorities and risks may
find it difficult to provide those involved in the transition with
clear expectations or gauge transition success. Specifically, without
measurable objectives, managers will lack information that could be
used to track progress toward transition objectives and inform
management decisions.
GSA Is Taking Action to Identify and Resolve Common Transition
Challenges:
GSA is working with agencies and various forums to identify and resolve
transition challenges facing agencies in making the transition to the
Networx contracts. In working with agencies and vendors through such
forums as the Interagency Management Council's Transition Working
Group, and a transition help desk, GSA has identified challenges
related to incumbent contractor support during the transition, defining
responsibilities of agencies during the transition to ensure
information security compliance, and use of a transition inventory
application developed by GSA. To resolve the challenges, GSA has, among
other things, modified incumbent FTS2001 contracts to help ensure
contractor support during the transition, developed guidance to clarify
agencies' information security responsibilities, and established
support teams to assist agencies in using the inventory application
developed by GSA.
GSA Is Working through Various Forums to Identify Common Transition
Challenges:
As the lead agency for the Networx transition, GSA is responsible for
ensuring that unnecessary delays in agency transitions are avoided, as
well as minimizing agency transition costs and ensuring that all
telecommunications services are transitioned in a timely manner. As
part of its efforts to address its transition responsibilities, GSA is
using various forums to identify transition challenges:
* Transition Working Group (TWG)--A subgroup of the Interagency
Management Council, TWG was created in May 2004 and serves as the
primary avenue through which common transition challenges affecting
agencies are identified. TWG is a bi-weekly forum for agency
representatives. It promotes collective government planning related to
the transition and assists with developing a consensus on common issues
that affect multiple agencies.
* Direct interaction with individual agencies--GSA interacts directly
with agencies to provide them with individual assistance related to its
various contract offerings, including FTS2001 and Networx. GSA has
Technology Service Managers who are assigned to specific agencies to
serve as single points of contact for GSA's contract offerings and
provide support to agencies for, among other things, selection,
ordering, implementation, and maintenance of FTS2001 and Networx
services. GSA indicated that agencies can contact their Technology
Service Managers to raise challenges specific to their agency. In
addition to the Technology Service Managers, GSA's Director of Network
Services Programs has been meeting individually with agency Chief
Information Officers and other executive-level leadership to educate
them on the benefits of Networx and prepare for the transition from
FTS2001.
* Regular interaction with vendors--GSA interacts with vendors in a
number of ways, including regular meetings, vendor-required reporting
to GSA, and GSA-initiated information requests. Specifically, GSA meets
regularly with FTS2001 and Networx vendors (as often as weekly) to
facilitate information sharing and to identify and resolve concerns or
challenges. Vendors are also required to submit monthly status reports
to GSA as well as provide quarterly program reviews. GSA has also
requested information from its vendors to address specific issues. For
example, GSA recently sent a request for information to the vendors to
solicit strategies for enabling agency compliance with a recent
initiative by the Office of Management and Budget (OMB) to improve
governmentwide information security by reducing the number of Internet
connections.
* Networx Help Desk--The help desk is a resource for agencies and GSA
to track and resolve agency-reported issues such as transition planning
concerns, assistance with GSA tools, and identification of transition
inventories. This help desk is part of GSA's Transition Coordination
Center, a GSA-established team of GSA personnel and contractors tasked
with facilitating the transition to Networx. The help desk addresses
individual agency concerns or questions and develops weekly reports of
help desk tickets that are reviewed and tracked by GSA. Using these
tickets, GSA has created a knowledge database and identified frequently
asked questions that are available for review by agencies. GSA
officials stated that through the help desk they could likely identify
vendors who deliver services late or provide inadequate support during
the transition. As a result of GSA's efforts, a number of challenges
have been identified:
* Incumbent contractor cooperation--The FTS2001 contracts lacked
requirements for the incumbent vendors to provide a certain level of
support to meet agencies' needs during the transition to Networx.
* Organizational conflicts of interest--Agencies found that they were
unable to use current contractors providing telecommunications support
to assist with the transitions to Networx if the particular contractors
were also subcontractors of a Networx vendor.
* Information security compliance--Agencies did not have a clear
understanding of their responsibilities during the transition related
to existing information security requirements.
* GSA transition inventory application--Agencies encountered
difficulties using an application developed by GSA to assist agencies
in identifying their transition inventories.
* Agencies' statements of work--Delays in the transition process could
result from statements of work developed by agencies that include
unclear requirements.
* Contract modification process--Modifications to the Networx contracts
require time and effort of both GSA and the vendors and may extend the
amount of time required for an agency to transition.
* OMB security initiative--The OMB initiative to reduce the number of
government Internet connections (mentioned previously) may require
agencies to revisit their Networx transition planning efforts.
* Expansion of protest rights--Recent legislation permits protests of
orders above $10 million under multiple-award task and delivery order
contracts such as Networx; if an order is protested, it may delay an
agency's transition.
More detail on these challenges is presented in the discussion
following.
GSA Has Taken Action to Resolve Common Transition Challenges:
GSA has taken various actions to resolve the identified common
transition challenges.
Incumbent Contractor Cooperation:
In September 2006, TWG members expressed concern that FTS2001 incumbent
vendor contracts did not include certain transition-related provisions.
Specifically, the contracts did not require FTS2001 incumbent vendors
to assist in the transition process by providing the ability for
agencies to "fall back" on the incumbent vendors' services if a
specific transition effort encountered difficulties. Agencies requested
clarification on the level of effort required of the incumbent vendor
to reestablish agency telecommunications services until transition
issues could be remedied.
GSA modified the FTS2001 contracts, including the FTS2001 crossover
contracts, to address these issues. Specifically, all but two FTS2001
crossover contracts were modified to include requirements for incumbent
vendors to restore agency services in the event of problems with
transition to new services. (GSA officials indicated that the remaining
two contracts already included language to address this concern.)
Modifications included provisions for the incumbent contractors to make
a reasonable effort to promptly reactivate service if there was a
problem with the successor contractor's service and it was necessary to
fall back to the incumbent's service. In addition, modifications state
that the incumbent contractor's point of contact should be available
during scheduled cutovers to handle fallback requests. The inclusion of
these terms in the FTS2001 contracts should help to reduce the risk
that agencies' telecommunications transitions will be disrupted by the
lack of cooperation by incumbent contractors, as well as help to ensure
that unnecessary delays are avoided if agencies encounter difficulties
in transitioning to a new contractor.
Organizational Conflicts of Interest:
During a September 2007 meeting, TWG members identified a concern
regarding contractor organizational conflicts of interest.[Footnote 17]
Specifically, agencies found that they were unable to use certain
current contractors providing telecommunications support to assist with
the transition to Networx because these contractors were also
subcontractors of Networx vendors, and the agencies' use of such a
subcontractor could give a Networx vendor an unfair competitive
advantage. The Federal Acquisition Regulation (FAR) calls for the
exercise of good judgment to resolve a potential organizational
conflict of interest and requires appropriate action to avoid,
neutralize, or mitigate the potential conflict.[Footnote 18]
To address this challenge, GSA has modified Networx contracts to allow
agencies to use their existing contractor support within defined
boundaries. For example, the modification requires contractors
supporting an agency to (1) avoid situations with the risk of
unauthorized disclosure of information, (2) refuse to divulge
information about the agency's program, and (3) report conflicts of
interest. The modification also calls for contractors to train their
employees on the Procurement Integrity Act[Footnote 19] and its
penalties. Thus, GSA has established a framework for agencies and
contractors to follow that is intended to address potential or actual
organizational conflicts of interest. Agencies remain responsible for
taking steps to avoid, neutralize, and mitigate conflicts of interest
in using contractors.
Information Security Compliance:
The TWG expressed concern that responsibilities related to the Federal
Information Security Management Act of 2002[Footnote 20] were unclear.
Specifically, agencies were unsure of their responsibilities for
information security under Networx versus those of GSA and the vendors.
For example, agencies requested clarification on government
responsibility to certify and accredit[Footnote 21] the public network
during transition and GSA's information security responsibilities as
the agency providing the contract vehicle for telecommunications
services.
GSA, in consultation with OMB, has provided guidance to agencies that
addresses information security concerns for transition. Specifically, a
GSA briefing to agencies clarifies that agencies are responsible for
determining the impact of the transition on the certification and
accreditation of their systems. In addition, GSA clarified that its
responsibilities, as the manager of the contract vehicle, includes,
among other things, reviewing contractor security plans and reports in
accordance with the provisions of the contract; monitoring and
resolving security issues during the life of the contract; conducting
post-award certification and accreditation of contract awardees'
support systems; and conducting certification and accreditation on
GSA's billing system related to Networx. GSA's actions should help
ensure that information security during the transition will be
adequately addressed.
GSA Transition Inventory Application:
The TWG indicated that agencies were having difficulties using an
application developed by GSA to validate their telecommunications
inventories for the transition. In January 2007, GSA created an initial
governmentwide inventory using FTS2001 vendor billing reports, with the
intention of using it to track transition status and aid agencies in
planning for their transitions. To assist in this effort, GSA required
agencies to validate their inventory using a GSA inventory application.
As agencies worked to validate these inventories, the TWG indicated
that agencies encountered difficulties with the application and that
the process for validating their inventories was not clearly defined.
To address this challenge, GSA has taken several actions. GSA has
issued user guidance for its inventory application and has briefed the
TWG on the inventory validation process. GSA has also established
inventory assistance teams to work with agencies to identify and
validate their inventories. These inventory assistance teams are
assigned at the request of an agency and include GSA personnel and
contracted support staff. From September to December 2007, inventory
assistance teams worked with 43 agencies to provide assistance with
validating their inventories. As a result, when GSA established a
baseline in January 2008 of the government's inventory to be used to
measure transition progress, federal agencies had validated about 92
percent of the almost 4.1 million records in the inventory. As a result
of its actions, GSA has increased the chances of a successful
transition by helping to ensure that agencies have available to them
accurate inventory information.
Agencies' Statements of Work:
GSA and several of the Networx vendors identified concerns about the
quality of agency statements of work and possible delays as a result of
unclear statements of work. An agency will develop a statement of work
when its telecommunications requirements cannot be met using existing
offerings in the Networx contract. Since statements of work are
particular, those with unclear requirements could extend the time
required for GSA to review and determine whether a modification is
necessary. According to Networx vendors, an unclear statement of work
may also require additional time as they review it to clarify and
understand agency requirements. Lack of clarity may also result in an
agency receiving disparate proposals from vendors, which may not all
meet the agency's particular needs. Finally, GSA officials stated that
there are fewer contracting staff (the personnel responsible for
reviewing agency statements of work) assigned to Networx than were
assigned to FTS2001. A limited number of staff may increase the amount
of time needed for GSA's review of agency statements of work.
GSA is taking action to address concerns related to the quality of
statements of work. First, GSA has developed a "Fair Opportunity and
Statement of Work Guide," intended to provide agencies with a set of
uniform ordering guidelines to obtain services under the Networx
contacts. This guide addresses the definition and documentation of
agency requirements, describes how to determine if a statement of work
is needed, and states that GSA has advisory and consulting services
available to agencies. Second, GSA officials stated that after an
agency submits its finalized statement of work to GSA, it is reviewed
for possible legal, pricing, contracting, management, and technical
issues, as well as to determine whether there are opportunities for the
agency's needs to be met using existing Networx service offerings. If
concerns or errors are identified, the statement of work is rejected,
the agency is briefed on the cause of rejection, and the agency must
revise its statement of work. Finally, to address the limited number of
contracting staff, GSA officials stated that they plan to add
additional staff to better facilitate the contract review process. The
actions being taken by GSA should help address issues regarding the
quality of statements of work developed by agencies and submitted to
vendors.
Contract Modification Process:
Contract modifications require time and effort, from both GSA and the
vendors, to negotiate the terms of the modification and eventually
extend the amount of time required for an agency to transition. In
addition to its responsibility for overseeing the transition, GSA has
administrative responsibility for processing and authorizing contract
modifications. Modifications to the Networx contract are essential to
allow agencies to place orders against requirements that are within the
scope of the Networx contract, but that are not currently available as
fixed price contract items. Contract modifications can also be
initiated (1) by a vendor desiring to add or change specific service
offerings or (2) as a result of a Networx program need determined by
GSA. Also, as previously discussed, GSA officials stated that they have
fewer personnel assigned to Networx who are responsible for reviewing
and incorporating contract modifications than were assigned to the
transition to FTS2001.
To address concerns with the contract modification process, GSA
identified existing and planned actions. First, the initial review of
agencies' statements of work is, in part, designed to identify whether
a modification is necessary. Second, GSA developed a contract
modification guide to inform those involved of the process for
modifying contracts. Third, in April 2008, it took steps to automate
certain aspects of the contract modification process. For example,
contractors can now draft, submit, and update contract modifications
using an Internet-based application. In addition, according to GSA
officials, contractors can also use this application to track the
modification throughout the process. Last, the previously mentioned
planned increase in contract review staff will also be used to
facilitate the processing of contract modifications.
As a result of actions taken, GSA is making progress in meeting its
goals for processing contract modifications. Its "Fair Opportunity and
Statement of Work Guide" indicates that the majority of modifications
should be completed within 30 business days. As of May 2008, the time
to complete a contract modification varied from 1 business day to more
than 106 business days; about 49 percent of its modifications had been
made within 30 days. However, many of these took place before GSA had
implemented its automated contract modification tools. These tools and
the other actions GSA has taken have the potential to minimize contract
modification delays.
OMB Security Initiative:
In November 2007, OMB issued a memorandum to improve governmentwide
information security. This initiative, called the Trusted Internet
Connections initiative, seeks to lessen information security risks by
reducing the number of Internet connections maintained by the
government. OMB has asked agencies to analyze and resolve any effects
of this initiative on, among other things, planning related to the
agencies' use of the Networx contracts. Therefore, agencies may have to
revisit their Networx transition planning efforts if, for example, they
find it necessary to reconfigure their networks to enable the use of
fewer Internet connections.
In response to this initiative, GSA asked Networx vendors to identify
(1) how they can help agencies to meet the goals of the initiative and
(2) any concerns. GSA summarized the vendors' feedback and on February
25, 2008, it presented the results to OMB, which is leading the
initiative in conjunction with Homeland Security. The summary indicated
multiple areas of support that vendors are willing to provide agencies,
such as assisting agencies in performing a complete inventory and
discovery of all agency Internet connections. In addition, it indicated
that the Networx contracts may need to be modified to allow vendors to
offer several of these services. GSA stated that detailed requirements
for this initiative have yet to be fully developed by Homeland Security
and that, as of May 2, 2008, no specific modifications to existing
Networx contract offerings have been identified as necessary. GSA is,
however, working with Homeland Security to define detailed requirements
for a new service offering under Networx to provide a trusted Internet
portal service; it expects this service to be available to the agencies
by November 2008. The actions GSA is taking and has planned should help
to ensure that the Networx contracts can be used by agencies to address
OMB's Trusted Internet Connections initiative.
Expansion of Protest Rights:
Recent legislation permits protests of orders above $10 million under
multiple-award task and delivery order contracts such as
Networx.[Footnote 22] Beginning May 27, 2008, the recently enacted
National Defense Authorization Act for Fiscal Year 2008 authorizes bid
protests of such orders; previously, protests were authorized only when
an order increased the scope, period, or maximum value of the contract
under which the order was issued. The protest of an agency's order may
affect the time available to the agency to complete its transition.
Although officials stated that the impact of this legislation on agency
transitions cannot be known at this time, GSA has briefed IMC members,
TWG members, and agency transition managers on this legislation. The
briefing provided information on the terms of the legislation, and
informed agencies of their expected responsibilities as well as GSA's
expected role. For example, the briefing indicated that GSA may be
asked to provide input in the event of a protest, but the agency that
issued the order would have primary responsibility to defend the
protest. In addition, GSA revised its "Fair Opportunity and Statement
of Work Guide" to reflect this new legislation. Further, officials
stated that they are responding to agency questions, through the
Networx help desk, regarding the bid protest process. GSA's actions
have helped to inform agency transition officials of their
responsibilities and the impact this legislation may have on their
ordering process.
Conclusions:
Transitioning federal telecommunications services is a large and
complex undertaking. The previous transition resulted in significant
delays and increased costs, taking more than 2 years to complete, which
underscores the importance of making necessary preparations before
starting such an effort. For the current transition, selected agencies
are generally following our sound transition practices, which should
help them avoid some of the delays experienced previously. However,
Homeland Security, Commerce, and NRC are not planning to fully
implement key sound practices. Because the period to conduct their
telecommunications transitions is limited, agencies will be better
prepared if they consistently implement all of the sound practices. If
they do not, they risk being unable to complete their transitions
before the expiration of the FTS2001 contracts and increase the
likelihood that the government will incur unnecessary costs.
In managing its $20 billion Networx program, GSA has taken actions to
identify and resolve common transition challenges, including developing
guidance for agency statements of work and creating teams to assist
agencies in establishing transition inventories. These actions should
help to reduce the risk that challenges will lead to unnecessary
transition delays and costs for agencies. Going forward, GSA's
responsibility as facilitator for the Networx transition will continue
to require it to proactively identify and resolve common transition
challenges, complete actions planned to resolve already identified
challenges, and monitor transition progress.
Recommendations for Executive Action:
To reduce the risk that transition delays could lead to disruptions in
service and increased costs, we are making the following 10
recommendations:
We recommend that the Secretary of Commerce direct the department's
Chief Information Officer to define the roles of asset and human
capital management for the department's transition.
We recommend that the Chairman of the U.S. Nuclear Regulatory
Commission direct the commission's Chief Information Officer to:
* establish measures of success based on the transition objectives that
the agency plans to develop and:
* evaluate the costs and benefits of new technology or alternatives to
meeting its telecommunications needs.
We recommend that the Secretary of Homeland Security direct the
department's Chief Information Officer to address the gaps in its
transition planning. Specifically, the Chief Information Officer
should:
* document the department's processes for maintaining
telecommunications inventories;
* evaluate the costs and benefits of new technology or alternatives to
meeting its telecommunications needs;
* clearly define the roles of asset management, legal expertise, human
capital management, and information security expertise for the
department's transition;
* identify local and regional points of contact;
* include in the department's planning efforts the identification of
human capital resources needed to conduct an effective transition;
* establish goals and measures of success for the department's
transition efforts to help managers assess progress; and:
* perform a transition risk assessment that addresses risks to mission-
critical systems, continuity of operations plans, and risks to
information security.
Agency Comments and Our Evaluation:
In commenting on a draft of our report, three of the seven agencies
reviewed generally agreed with our report, and two agencies partially
agreed. GSA, Commerce, NRC, and Homeland Security provided written
comments (which are reproduced in apps. II through V), and SBA provided
comments via e-mail. Two agencies, Agriculture and U.S. Army Corps of
Engineers, indicated via e-mail that they had no comments.
Officials from GSA, Commerce, and SBA generally agreed with our
findings:
* The Acting Administrator of GSA concurred with the information
pertaining to GSA and expressed appreciation for our acknowledgment of
the actions the agency had taken.
* Commerce's Chief Information Officer indicated that the report
provided a fair assessment of the department's progress and status to
date.
* A program manager in SBA's Office of Congressional and Legislative
Affairs indicated that SBA was satisfied with our findings regarding
the agency.
NRC and the Department of Homeland Security partially agreed with our
report. NRC's Executive Director for Operations indicated that our
report generally reflects the issues surrounding agency preparedness
for transition. However, the official suggested that we remove our
recommendation that the Commission evaluate the costs and benefits of
new technology or alternatives because such an evaluation had been and
would be conducted as part of the agency's normal planning processes.
However, our recommendation remains because the Commission did not
perform this activity specifically for the transition to Networx.
Performing such an analysis would provide the Commission with the
opportunity to optimize its telecommunications services in the light of
its present and projected needs. The Executive Director also provided
technical comments, which we incorporated into our report as
appropriate; our assessment of these comments is contained in appendix
IV.
The Acting Director of Homeland Security's Departmental Audit Liaison
Office indicated partial agreement with our report. In particular,
regarding our recommendations that Homeland Security establish goals
and measures of success and perform a transition risk assessment, the
department agreed that a more structured communication of transition
objectives and a specific risk management process for transition would
be beneficial. However, this official indicated that the department
disagreed with five of our recommendations and with a finding regarding
its transition communications planning. The department's comments
reiterated information on actions that it had taken in these areas that
it considered to meet the goals of the sound practices. However, these
actions are already reflected in our assessment. The specific areas of
disagreement are as follows:
* Regarding our recommendation that the department document its
processes for maintaining telecommunications inventories, the official
acknowledged that the department does not have a documented inventory
maintenance process, but stated that our observation was in conflict
with our finding that it had identified a complete telecommunications
inventory. The official added that the department has instructed its
components to maintain their inventories using a GSA tool and
documented GSA procedures. However, our finding that the department had
established an inventory for transition is not in conflict with the
recommendation. While the department had addressed one component of
this sound practice by establishing an inventory for transition, it had
not taken the necessary action to address the other component; it had
not documented the process to be used by its components for inventory
maintenance. Specifically, this sound practice component calls for a
documented inventory maintenance process to lessen the risk that
changes to the inventory during and after transition would not be
consistently and accurately captured.
* Regarding our recommendation that the department evaluate the costs
and benefits of new technology or alternatives to meeting its
telecommunications needs, the official indicated that this was in
conflict with our related finding that the department had aligned needs
and opportunities with its mission, long-term IT plans, and enterprise
architecture plans. The official added that its fair opportunity
efforts will include service and cost analyses. However, our
recommendation is not in conflict with the identified finding.
Specifically, although the department's transition plans addressed
strategic needs, it had not performed an analysis of costs and benefits
of new technology or alternatives for meeting those needs. Regarding
decisions made during the fair opportunity process, our recommendation
refers to the sound transition practice of performing a strategic
analysis based on agencywide telecommunications needs, with the results
of this analysis being used to shape the agency's transition management
approach, transition plan development, and allocation of resources. In
contrast, the fair opportunity process involves selecting a vendor for
the agency's service orders; at that point in the process, the agency
should have already identified services to order. Therefore, to be
effective, an agency's evaluation of costs and benefits of new
technology and alternatives would need to take place before the
department's fair opportunity efforts.
* Regarding our recommendation that the department clearly define the
roles of asset management, legal expertise, human capital management,
and information security expertise, the official indicated that the
department can call upon these specialty disciplines as needed.
However, by taking this approach, Homeland Security risks encountering
delays as officials attempt to assign personnel in a time of need and
bring them up to date on transition progress and issues. Defining such
roles at the outset, as advocated by sound transition planning
practices, would help avoid such delays.
* Regarding our recommendation that the department identify local and
regional points of contact, the official stated that we had suggested
that the department should identify all personnel that might be
involved in any kind of telecommunication change and stated that such
an effort would include thousands of individuals across the department
and all IT field support personnel. Rather than contacting all these
personnel, the Acting Director indicated that the department had taken
steps to alert key managers at each component. However, this sound
practice does not involve identifying all personnel that might be
involved in any telecommunications change, but rather only identifying
those contacts that will be responsible for facilitating the
transition. For example, a contact is needed for each location where
service is provided to facilitate physical access to equipment during a
transition. Homeland Security's decision to not identify all contacts
responsible for facilitating the transition does not follow sound
transition planning practices and increases the risk that it will
experience delays in providing the necessary site access for vendors.
* Regarding our recommendation that the department identify human
capital resources needed to conduct an effective transition, the
official indicated the department did identify funding and staffing for
transition planning. However, our recommendation is that Homeland
Security determine human capital resources needed throughout the entire
transition effort--not simply the planning effort.
* The official acknowledged that Homeland Security had not published a
Networx transition communications plan, but stated that the charter for
its transition work group defined essential communications and
activities. Our report indicates that the department has established
lines of communication in its charter, but as previously discussed, it
had not identified local and regional points of contact. Thus, the
department's communications planning is incomplete. If Homeland
Security does not identify all of its local points of contact before it
begins transitioning services, communication difficulties could produce
delays in providing the necessary site access for vendors.
As agreed with your staff, unless you publicly announce the contents of
this report earlier, we plan no further distribution of this report
until 30 days from the report date. At that time, we will send copies
of this report to other interested congressional committees, the
Administrators of General Services and the Small Business
Administration; the Chairman of the U.S. Nuclear Regulatory Commission;
and the Secretaries of Agriculture, Commerce, Defense, and Homeland
Security. We will also make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site
at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-6240 or by e-mail at koontzl@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Key contributors to this
report are listed in appendix VI.
Signed by:
Linda D. Koontz:
Director, Information Management Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to determine (1) the extent to which federal
agencies are following sound transition planning practices and (2) the
actions the General Services Administration (GSA) is taking to identify
and resolve common transition challenges affecting agencies.
To determine the extent to which agencies are following sound
transition planning practices, we selected six agencies for review.
Using FTS2001 billing data provided by GSA, we identified total charges
for each agency for fiscal year 2006. These totals ranged from over
$145,000,000 to as low as $28 for 127 separate entities. We then
reduced the number of entities under consideration to a more manageable
number by identifying agencies with total charges in excess of $1
million for fiscal year 2006. From this group of agencies, we made a
judgmental selection of six agencies that were representative of (1)
varying types of organization, including executive departments,
subagencies, and independent agencies; (2) varying levels of attendance
in the Transition Working Group, an agency forum that is assisting GSA
in its efforts to plan for the transition; and (3) the entire range of
agency charges in excess of $1 million. The departments and agencies
selected for review were the Department of Homeland Security;
Department of Commerce; U.S. Department of Agriculture; Small Business
Administration; U.S. Army Corps of Engineers, a component of the
Department of Defense; and U.S. Nuclear Regulatory Commission.
Because we judgmentally selected the agencies in our review, we cannot
conclude that our results represent the entire federal government's
level of preparation. However, the six cases studied illustrate various
challenges that agencies may face in planning for the transition to
Networx.
To determine the extent to which the selected agencies have made
adequate preparations for their upcoming transitions, we obtained and
reviewed agency documentation, including but not limited to strategic
plans, telecommunications inventories, and transition-related plans,
and interviewed agency officials. We then assessed this information
against the five sound transition planning practices identified in our
prior report on agency transition planning.[Footnote 23] These
practices are (1) establish a telecommunications inventory, (2) perform
a strategic analysis of telecommunications requirements, (3) establish
a structured transition management approach, (4) identify resources,
and (5) develop a transition plan. Each of these sound planning
practices consists of various components (for example, developing a
transition plan consists of (1) identifying and documenting objectives
and measures of success; (2) determining risks that could affect
success; and (3) defining transition preparation tasks and developing a
time line for these tasks).
Based on our assessment, we classified the status of agency transition
planning efforts to address each sound practice component as "fully
implemented," if the agency has fully implemented the sound practice
component; "plans to fully implement," if the agency has plans to fully
implement the component; or "no plans to fully implement," if the
agency does not have plans to fully implement it. We discussed our
assessments with agency officials and made adjustments as appropriate.
To evaluate one of the sound practices, establishing a
telecommunications inventory, we developed criteria to assess the
extent to which agencies had identified complete transition
inventories. First, based on data provided by GSA, we determined
whether each agency had validated 90 percent or more of its inventory.
Second, we administered a questionnaire to determine whether each
agency had adequate quality control mechanisms in place to identify and
maintain its inventory.[Footnote 24] If these two criteria were met, we
considered the inventory to be sufficient for a telecommunications
transition.
To determine the actions that GSA is taking to identify and resolve
common transition challenges affecting agencies, we reviewed transition
guidance and other Networx documentation developed by GSA and the
Transition Working Group (TWG) of the Interagency Management Council
(IMC), including presentations, meeting minutes, projected time lines,
GSA's "Fair Opportunity and Statement of Work Guide," and the TWG's
"Networx Transition Guide (Pre-Award)"; interviewed FTS2001 incumbent
vendors and Networx vendors (AT&T, Level3 Communications, Qwest,
Sprint, and Verizon Business) and the six agencies selected for review;
and interviewed GSA officials to identify challenges, guidance, and GSA
current and planned actions for the Networx transition. We assessed
GSA's efforts to resolve identified challenges by analyzing
documentation and testimonial evidence from GSA on any actions taken to
address them.
We performed our work at the Washington, D.C., area offices of the
Department of Homeland Security, Department of Commerce, Department of
Defense, Small Business Administration, U.S. Army Corps of Engineers,
U.S. Department of Agriculture, U.S. Nuclear Regulatory Commission, and
the General Services Administration. We conducted this performance
audit from September 2007 through June 2008, in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
[End of section]
Appendix II: Comments from the General Services Administration:
GSA:
U.S. General Services Administration:
1800 F Street. NW:
Washington, DC 20405-0002:
Telephone (202) 501.0800 Fax: (202) 2t9-1243
[hyperlink, http://www.gsa.gov]:
GSA Administrator:
June 11, 2008:
The Honorable Gene L. Dodaro:
Acting Comptroller General of the United States:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Dodaro:
The U.S. General Services Administration (GSA) thanks you for the
opportunity to review and comment on the draft report,
"Telecommunications: Agencies Are Generally Following Sound Transition
Planning Practices, and GSA Is Taking Action to Resolve Challenges"
(GAO-08-759). We concur with the information pertaining to GSA and
appreciate your acknowledgement of the actions we have taken.
If you have any questions, please contact me. Staff inquiries may be
directed to Mr. Kevin Messner, Associate Administrator, Office of
Congressional and Intergovernmental Affairs, at (202) 501-0563.
Sincerely,
Signed by:
David L. Bibb:
Acting Administrator:
cc:
Ms. Linda Koontz:
Director:
Information Management Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
[End of section]
Appendix III: Comments from the Department of Commerce:
United States Department Of Commerce:
Chief Information Officer:
Washington, D.C. 20230:
June 12, 2008:
Ms. Linda Koontz:
Director, Information Management Issues:
Government Accountability Office:
441 G. Street, N.W.:
Washington, D.C. 20548:
Dear Ms. Koontz:
Thank you for the opportunity to review the draft report, GAO 08-729 –
Telecommunications: Agencies Are Generally Following Sound Transition
Planning Practices, and GSA Is Taking Action to Resolve Challenges,
dated June 2008.
The report provides a thorough examination and assessment of Federal
government activities, and procedures to support the transition from
the GSA's Telecommunications program, FTS2001 to the successor program,
Networx. The report provides a fair assessment of the Department of
Commerce progress and status to date.
We have no substantial comments or changes to recommend at this time.
Please let us know if you have questions or need additional
information. Our Department of Commerce point of contact is Ms.
Demetria Blyther, she can be reached at (202) 482-0267 or at
DBlytheru@doc.gov.
Sincerely,
Signed by:
Suzanne Hilding:
Chief Information Officer:
[End of section]
Appendix IV: Comments from the U.S. Nuclear Regulatory Commission:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
United States Nuclear Regulatory Commission:
Washington 20555-0001:
June 13, 2008:
Ms. Linda Koontz, Director:
Information Management Issues:
Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Ms. Koontz:
The U.S. Nuclear Regulatory Commission (NRC) appreciates the
opportunity to provide comments on the draft report entitled,
"Telecommunications: Agencies Are Generally Following Sound Transition
Planning Practices, and GSA Is Taking Action to Resolve Challenges"
(GAO-08-759). The NRC's comments are enclosed for your consideration
and inclusion in the final report as mentioned in your letter of May
27, 2008.
Please direct any questions or concerns that you may have on NRC's
comments to Mr. Jesse Arildsen, at (301) 415-1785 or email to
Jesse.Arildsen@nrc.gov.
Sincerely,
Signed by:
R. W. Borchardt:
Executive Director for Operations:
Enclosure: As stated:
cc: J. Sweetman, GAO:
U.S. Nuclear Regulatory Commission Comments on GAO Draft Report,
"Telecommunications: Agencies Are Generally Following Sound Transition
Planning Practices, And GSA is Taking Action To Resolve Challenges"
(GAO-08-759):
In general, the document reflects the issues surrounding agency
preparedness to transition from the existing FTS 2001 Bridge contracts
to the new Networx contracts provided by the General Services
Administration (GSA). However, additional credit could be given to the
Interagency Management Council (IMC) for solving agency problems. Many
of the solutions that were put in place by GSA were as a result of a
collegial effort between the IMC member agencies and the GSA Networx
Program Management Office. (Reference Page 6, second paragraph first
sentence)
(See comment 1.):
The U.S. Nuclear Regulatory Commission's (NRC) telecommunications
infrastructure requirements are driven by the Information Technology
requirements in support of the agency mission and goals. The FTS 2001
and FTS 2001 Bridge contracts offered many full service features which
allowed the NRC to expand its telecommunications infrastructure in
support of agency requirements. NRC has been able to realize cost
avoidance measures and other benefits while participating in the
program. As NRC infrastructure and application requirements mature, the
agency will evaluate the Networx advanced offerings which may prove
beneficial. The telecommunications infrastructure at the NRC is planned
as a component of the overall agency Enterprise Architecture and future
enhancements will be vetted through our Capital Planning and Investment
Control processes. (Reference Page 24, second paragraph).
(See comment 2.):
The GSA Networx Program Management Office in conjunction with the IMC
Transition Working Group (TWG) spent a considerable amount of time and
effort to define how the Government would monitor, track, collate, and
report Transition status and progress. Tools were developed such as the
Transition Management Portal (TMP) to allow both GSA and the Agencies
to view the status of transition from both a government wide
perspective as well as individual agency perspective. This tool along
with others (i.e. Transition Baseline Inventory (TBI)) was developed in
order to conform to previous GAO guidance with respect to the
transition. (Reference Page 32, second paragraph.)
(See comment 3.):
The introduction of the Office of Management and Budget (OMB) Trusted
Internet Connection (TIC) as a "transition" challenge is not
categorized correctly. The transition of services as defined by GSA is,
". as the movement of services from the FTS2001 contracts to Networx
and continues until the disconnection of all services from the FTS2001
contracts." Since the TIC is not a current service offering under
either the FTS 2001 or the Networx contracts, it should be considered
as an implementation rather than a transition issue. An agency that
takes time to consider the TIC alternatives as part of their transition
will experience delays in their Fair Opportunity selections and
execution of transition tasks. (Reference Page 36, fifth paragraph.)
(See comment 4.):
Two recommendations are made to the NRC in the report. It is suggested
that the first suggestion be modified to say:
* establish measures of success based upon agency specific transition
objectives that the agency plans to develop using the tools provided by
GSA and the IMC as source data
It is further suggested that the second suggestion be removed, since an
evaluation of costs and benefits of new technology or alternatives to
meet the agency telecommunications needs has been and will be conducted
as a part of NRC's normal planning processes. (Reference Page 45
"Recommendations", third paragraph.)
(See comment 5.):
Enclosure:
The following is GAO's response to the U.S. Nuclear Regulatory
Commission's letter dated June 13, 2008.
GAO Comments:
1. We clarified our report to better reflect the role of the IMC.
2. NRC's comment references our statement that it did not plan to
evaluate the costs and benefits of alternatives to meeting its
telecommunications needs. The official stated that, as its requirements
mature, the agency will evaluate the Networx advanced offerings that
may prove beneficial. However, sound transition planning calls for
performing a cost benefit and analysis specifically for the agency's
transition effort as part of a strategic analysis that should be used
to shape the agency's transition management approach, transition plan
development, and allocation of resources. NRC has not performed this
activity for the transition.
3. NRC's comment references our statement that it did not plan to
establish measures of success to assess progress toward its goals. NRC
indicated that it plans to use GSA-established measures related to
transition progress and identified various tracking tools. However, NRC
has not established agency-specific objectives for its transition and,
by limiting measures of success to those established by GSA, NRC may
lack information that could be used to track its progress in achieving
its own goals and to inform its own management decisions.
4. We disagree with NRC's statement that the introduction of the Office
of Management and Budget's Trusted Internet Connection (TIC) initiative
should not be characterized as a transition issue. As NRC goes on to
state, agencies that take time to address considerations relative to
TIC may experience delays in their efforts to transition. We consider
this a challenge that may affect agency transitions.
5. We do not agree with the suggested modification to our
recommendation. NRC's suggestion would limit its measures of success to
those emphasized by GSA, such as measures of transition progress.
However, sound practices call for agencies to establish measures for
each of its transition objectives to help managers assess the extent to
which those objectives are achieved.
[End of section]
Appendix V: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
Homeland Security:
June 16, 2008:
Ms. Linda D. Koontz:
Director, Information Management Issues:
United States Government Accountability Office:
Washington, DC 20548:
Dear Ms. Koontz:
Thank you for the opportunity to review and comment on the Government
Accountability Office's (GAO's) Draft Report GAO-08-759 entitled
Telecommunications: Agencies are Generally Following Sound Transition
Planning Practices, and GSA Is Taking Action to Resolve Challenges. In
regard to the recommendations in the draft report, the Department has a
few concerns regarding GAO's portrayal of the state of the Department
of Homeland Security's (DHS's) Networx transition activities.
Recommendation #1” DHS does not concur:
* document the department's processes for maintaining
telecommunications inventories;
Response:
GAO indicated that DHS has not published a process document for
inventory of telecommunications service assets. This observation is in
conflict with the related finding that we have identified a complete
telecommunications inventory. It is true the DHS HQ has not published a
process document for inventory of telecommunications service assets.
Instead, via our Networx Transition Work Group (NTWG), DHS has
instructed all components to maintain the GSA Transition Baseline
Inventory, housed at GSA, using documented GSA procedures for doing so.
DHS HQ, with GSA input, monitors and reports the degree to which
components comply with this inventory methodology. DHS provided
artifacts of the monitoring effort, hence the finding that DHS has a
complete telecommunications inventory.
Recommendation #2 - DHS does not concur:
* evaluate the costs and benefits of new technology or alternatives to
meeting its telecommunications needs;
Response:
This observation is in conflict with a related finding that DHS has
aligned needs, opportunities and plans. DHS briefed the GAO audit team
on several occasions regarding the enabling role that Networx
transition plays in our Infrastructure Transformation Program. GAO
representatives were also briefed and provided artifacts regarding the
fair opportunity efforts for OneNet and non-OneNet telecommunication
services. DHS fair opportunity efforts represent service and cost
analyses which are subject to formal contracting officer approval.
Recommendation #3 - DHS does not concur:
* clearly define the roles of asset, legal, human capital, and
information security management for the department's transition;
Response:
GAO indicated that DHS has not established a transition management team
and has not assigned, by name, key transition roles. DHS has formally
chartered the NTWG with membership from all major components. The NTWG
meets biweekly and artifacts of meeting proceedings were provided to
GAO. DHS provided names for those responsible for managing the
telecommunications service inventory (NTWG members), the name of the
contracting officer assigned to the OneNet fair opportunity and the
name of the attorney that was consulted on the OneNet fair opportunity,
and the name of the Chief Information Security Officer. It is true that
DHS did not provide the name of a member of the Chief Human Capital
Officer's staff, as the Networx transition effort had not required such
services. All specialty disciplines (legal, contracting, human capital,
information security) are available to the NTWG as needed and have been
called upon where needed. DHS has demonstrated the ability to draw upon
these services where needed.
Recommendation # 4 - DHS does not concur:
* identify local and regional points of contact;
Response:
GAO indicated that DHS had not properly identified local and regional
points of contact for transition efforts. GAO has requested we identify
the national, regional and local telecommunications ordering officials
involved in the transition effort. GAO subsequently clarified this
request to be all personnel that might be involved in any kind of
telecommunication change. We advised GAO that this would be thousands
of individuals across the Department and, most notably, all the IT
field support personnel. The draft report fails to recognize that
implementation of telecommunication changes, as entailed in the
Transition to Networx, is executed by individual components of the
Department, with each component having a differing command and control
infrastructure. The Department has taken proactive steps to engage,
alert and inform the key managers at each component and is tracking
overall migration progress.
Recommendation #5 - DHS does not concur:
* include in the department's planning efforts the identification of
human capital resources needed to conduct an effective transition;
Response:
GAO indicated that DHS did not identify funding for transition planning
and did not identify funding for human capital needs. It is a
meaningful clarification that GAO queries in this area are not
associated with the transition work itself, but are instead focused on
the exactitude to which DHS planned to plan. DHS did identify funding
and staffing for OneNet transition planning as part of the
Infrastructure Transformation Program. DHS offered artifacts to this
effect, but was advised such artifacts were not applicable. It is true
that DHS did not identify funding or staffing for the planning of non-
OneNet services (e.g., switched voice, calling cards, etc.), but
execution of the transition activities (e.g., an effective working
group, a complete inventory, fair opportunity decisions, etc.) are
clear indicators of success.
Recommendation #6 & #7 - DHS concurs:
* establish goals and measures of success for the department's
transition efforts to help managers assess progress;
* perform a transition risk assessment that addresses risks to mission-
critical system systems, continuity of operations plans, and risks to
information security.
Response:
Transition objectives are defined as part of the Infrastructure
Transformation Program in the form of wide area network consolidation
goals and the project plan for OneNet. Transition objective for non-
OneNet services (i.e., transfer of all FTS2001 services to Networx
before FTS2001 contract expiration) was set at initial NTWG meeting.
Meeting minutes for this initial NTWG session did not clearly
articulate this goal. Risk management is a key element in the OneNet
solicitation, which was provided as an artifact. Risk management is
also inherent in the OneNet, and all information systems, certification
and accreditation processes, dictated under the Federal Information
Security Management Act, with which DHS complies. DHS agrees that more
structured communication of transition objectives and a specific risk
management process for transition would be beneficial.
GAO Finding (pages 25 and 27) - DHS does not concur:
* lack of a communications plan;
Response:
While it is true the DHS has not published a Networx transition
communications plan, the NTWG charter, provided to GAO, defines
essential communications responsibility and activities.
Thank you again for the opportunity to comment on this draft report and
we look forward to working with you on future homeland security issues.
Penelope G. McCormack:
Acting Director:
Departmental Audit Liaison Office:
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
Linda D. Koontz (202) 512-6240 or koontzl@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, key contributions were made
to this report by James R. Sweetman, Jr., Assistant Director; Gerard
Aflague; Barbara Collier; Jamey A. Collins; Eric Costello; Joel
Grossman; Amos Tevelow; Hai V. Tran; and Merry Woo.
[End of section]
Footnotes:
[1] GAO, Telecommunications: Full Adoption of Sound Transition Planning
Practices by GSA and Selected Agencies Could Improve Planning Efforts,
GAO-06-476 (Washington, D.C.: June 6, 2006).
[2] Sprint Corporation merged with Nextel Communications, Inc., to form
Sprint Nextel Corporation in August 2005.
[3] MCI merged with Verizon to form Verizon Business in January 2006.
[4] In August 2001, GSA allowed contractors that had been awarded local
telecommunications contracts in selected metropolitan areas, through
GSA's Metropolitan Area Acquisition program, to offer long-distance
services on the FTS2001 contracts. This process is termed "crossover."
[5] GSA negotiated sole-source contracts for a 24-month period with
three 6-month optional periods, for a total of 42 months.
[6] The council was established in 1992 to provide a forum and focal
point for agency participation in planning and overseeing GSA's long-
distance telecommunications services.
[7] GAO, FTS2001: Transition Challenges Jeopardize Program Goals, GAO-
01-289 (Washington, D.C.: Mar. 30, 2001).
[8] 41 U.S.C. § 253j(b) requires civilian agencies to provide all
contractors awarded multiple award task-and-delivery order contracts a
fair opportunity to be considered for each order in excess of $2,500
that is to be issued under any of the contracts, unless one of the
statute's exceptions applies. As recently amended, subsection 253j(d)
establishes enhanced competition requirements for this process
applicable to orders over $5 million. Similar requirements apply to the
Department of Defense under 10 U.S.C. § 2304c. In addition, section 803
of the National Defense Authorization Act for Fiscal Year 2002 requires
that an order for services in excess of $100,000 issued under a
multiple award contract by or on behalf of the Department of Defense be
made on a competitive basis unless a contracting officer justifies an
exception in writing. Pub. L. No. 107-107 (Dec. 28, 2001).
[9] Verizon's FTS2001 crossover contract is currently operating under a
continuity of service clause that provides an additional 24 months for
agencies to transition to a new contract.
[10] GAO-01-289 and GAO, FTS2001: Contract Transition Delays and Their
Impact on Program Goals, GAO-01-544T (Washington, D.C.: Apr. 26, 2001).
[11] GAO, Telecommunications: Full Adoption of Sound Transition
Planning Practices by GSA and Selected Agencies Could Improve Planning
Efforts, GAO-06-476 (Washington, D.C.: June 6, 2006).
[12] GAO, Telecommunications: GSA Has Accumulated Adequate Funding for
Transition to New Contracts but Needs Cost Estimation Policy, GAO-07-
268 (Washington, D.C.: Feb. 23, 2007).
[13] GAO-06-476.
[14] In determining the extent to which agencies had established
transition inventories, we reviewed agency data quality controls in
place as well as the extent to which each agency had validated its
transition inventory. If an agency had sufficient controls in place and
had validated at least 90 percent of its inventory, its inventory was
considered sufficient for conducting a transition. See appendix I for a
complete description of our methodology.
[15] An enterprise architecture is an institutional blueprint that
defines how an enterprise operates today, in both business and
technology terms, and how it intends to operate in the future.
[16] Specifically, Agriculture and Homeland Security are currently
using certain management processes, and agency policies indicate that
all will be used. SBA is currently using project management, and
officials stated they plan to use change and configuration management
processes. Commerce provided a draft policy and evidence of contractor
support to indicate that project, configuration, and change management
processes will be used in its management of the transition. NRC
provided agency policy requiring the use of these processes and
officials stated that they plan to use them.
[17] "Organizational conflicts of interest" means that because of other
activities or relationships with other persons, a person is unable or
potentially unable to render impartial assistance or advice to the
government, or the person's objectivity in performing the contract work
is or might be otherwise impaired, or a person has an unfair
competitive advantage. FAR 2.101.
[18] FAR 9.505.
[19] Among its requirements, the Procurement Integrity Act prohibits
the disclosure of source selection and contractor bid or proposal
information before the award of a federal agency procurement contract
to which the information relates. 41 U.S.C. § 423.
[20] The Federal Information Security Management Act of 2002 (FISMA)
sets forth a comprehensive framework for ensuring the effectiveness of
information security controls over information resources that support
federal operations and assets. E-Government Act of 2002, Title III,
Pub. L. No. 107-347 (Dec. 17, 2002).
[21] Certification and accreditation is the requirement that agency
management officials formally authorize information systems to process
information, thereby accepting the risk associated with their
operation.
[22] Pub. L. No. 110-181, § 843 (Jan. 28, 2008) (to be codified in
relevant part at 10 U.S.C. § 2304c (defense) and 41 U.S.C. § 253j
(civilian)).
[23] GAO-06-476.
[24] In one case in which the GSA was not able to provide inventory
information (NRC), we used that agency's responses to the questionnaire
on quality control to determine whether both criteria were met.
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