Customs Service Modernization
Automated Commercial Environment Progressing, but Further Acquisition Management Improvements Needed Gao ID: GAO-03-406 February 28, 2003The U.S. Customs Service is conducting a multiyear, multibillion dollar project, the Automated Commercial Environment (ACE), a new trade processing system that is planned to support effective and efficient movement of goods into the United States. By congressional mandate, Customs' expenditure plans for ACE must meet certain conditions, including being reviewed by GAO. This study addresses whether Customs' latest plan satisfies these conditions and provides observations about the plan and Customs' efforts to implement GAO's open recommendations for improving ACE management.
Customs' November 2002 ACE expenditure plan, the fourth in a series of legislatively required plans, provides for certain project management tasks as well as the definition, design, and development of the first release of the second of four planned ACE increments. GAO's analysis of the plan shows that it meets the legislative conditions imposed by the Congress. In its series of reports on Customs' management of ACE, GAO has made a number of recommendations, which Customs is currently addressing. However, Customs has been slow to correct weaknesses in two areas fundamental to effective acquisition management--people and processes. These weaknesses increase the risk that ACE will be late, cost more than necessary, and not perform as intended. While the Customs Modernization Office (CMO) has developed a human capital strategy, neither the strategy nor supporting documentation identifies how the commitments made in the strategy will be met, including what steps will be taken and what resources are needed to execute the steps. Further, based on the strategy's timeline, it will be over a year before the CMO fully implements the strategy. Customs has made slow progress in implementing key acquisition practices, such as project office management and acquisition risk management, which GAO first recommended Customs do in 1999. Since that time many practices have been developed, but almost none of them have been implemented. Additionally, Customs' ACE contractor is conducting system tests in accordance with best practices, initial test results are positive, and indicators suggest the contractor is delivering a quality product. However, Customs is not employing independent verification and validation (IV&V) in overseeing ACE testing, which is one way to mitigate the acquisition weaknesses cited above. Without IV&V, Customs states that it is relying on the contractor's reputation and maturity level as guarantors of system quality, which is not adequate for a complex and risky program like ACE.
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-03-406, Customs Service Modernization: Automated Commercial Environment Progressing, but Further Acquisition Management Improvements Needed
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Report to Congressional Committees:
February 2003:
Customs Service Modernization:
Automated Commercial Environment Progressing, but Further Acquisition
Management Improvements Needed:
GAO-03-406:
GAO Highlights:
Highlights of GAO-03-406, a report to Congressional committees:
Why GAO Did This Study:
The U.S. Customs Service is conducting a multiyear, multibillion
dollar project, the Automated Commercial Environment (ACE), a
new trade processing system that is planned to support effective and
efficient movement of goods into the United States. By congressional
mandate, Customs‘ expenditure plans for ACE must meet certain
conditions, including being reviewed by GAO. This study
addresses whether Customs‘ latest plan satisfies these conditions and
provides observations about the plan and Customs‘ efforts to
implement GAO‘s open recommendations for improving ACE management.
What GAO Found:
Customs‘ November 2002 ACE expenditure plan, the fourth in a series of
legislatively required plans, provides for certain project management
tasks as well as the definition, design, and development of the first
release of the second of four planned ACE increments. GAO‘s analysis
of the plan shows that it meets the legislative conditions imposed by
the Congress.
In its series of reports on Customs‘ management of ACE, GAO has made
a number of recommendations, which Customs is currently addressing.
However, Customs has been slow to correct weaknesses in two areas
fundamental to effective acquisition management”people and processes.
These weaknesses increase the risk that ACE will be late, cost more
than necessary, and not perform as intended.
* While the Customs Modernization Office (CMO) has developed a human
capital strategy, neither the strategy nor supporting documentation
identifies how the commitments made in the strategy will be met,
including what steps will be taken and what resources are needed to
execute the steps. Further, based on the strategy‘s timeline, it will
be over a year before the CMO fully implements the strategy.
* Customs‘ has made slow progress in implementing key acquisition
practices, such as project office management and acquisition risk
management, which GAO first recommended Customs do in 1999. Since
that time many practices have been developed, but almost none of
them have been implemented, as shown in the figure below.
Additionally, Customs‘ ACE contractor is conducting system tests in
accordance with best practices, initial test results are positive,
and indicators suggest the contractor is delivering a quality product.
However, Customs is not employing independent verification and
validation (IV&V) in overseeing ACE testing, which is one way to
mitigate the acquisition weaknesses cited above. Without IV&V, Customs
states that it is relying on the contractor‘s reputation and maturity
level as guarantors of system quality, which is not adequate for a
complex and risky program like ACE.
What GAO Recommends:
To ensure that Customs is positioned to effectively manage
the acquisition of ACE, GAO is making recommendations to the
commissioner aimed at improving Customs‘ acquisition management
capabilities. Customs concurred with GAO‘s recommendations and
described specific actions that it is taking to respond to each.
Contents:
Letter:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Customs‘ Fourth Automated Commercial Environment (ACE)
Expenditure Plan:
Appendix II: Comments from the U.S. Customs Service:
Abbreviations:
ACE: Automated Commercial Environment:
CIO: Chief Information Officer:
CMM: Capability Maturity Model:
CMO: Customs Modernization Office:
IV&V: independent verification and validation:
OMB: Office of Management and Budget:
SA-CMM: Software Acquisition Capability Maturity Model:
SAT: system acceptance tests:
SEI: Software Engineering Institute:
February 28, 2003:
The Honorable Ben Nighthorse Campbell
Chairman
The Honorable Byron L. Dorgan
Ranking Minority Member
Subcommittee on Treasury and General Government
Committee on Appropriations
United States Senate:
The Honorable Ernest J. Istook, Jr.
Chairman
The Honorable Steny H. Hoyer
Ranking Minority Member
Subcommittee on Transportation, Treasury, Postal Service,
and General Government
Committee on Appropriations
House of Representatives:
In November 2002, the U.S. Customs Service submitted to Congress its
fourth expenditure plan, seeking release of $314 million for its
Automated Commercial Environment (ACE) project. ACE is to be Customs‘
new trade processing system and the first project under the Customs
Modernization Program. As required by Customs‘ fiscal year 2002
appropriation and continuing resolutions,[Footnote 1] we reviewed the
expenditure plan. Our objectives were (1) to determine whether the
fourth ACE expenditure plan satisfies certain legislative conditions,
(2) to determine whether the plan is consistent with our open ACE
recommendations, and (3) to provide observations about the plan and
Customs‘ management of ACE.
On December 27, 2002, we briefed your offices on the results of this
review. This report transmits the results of our work. The full
briefing, including our scope and methodology, is reprinted as appendix
I.
Concerning our first objective, Customs‘ expenditure plan satisfies the
legislative conditions specified in Customs‘ appropriations act. That
is, the plan provides for (1) meeting the capital planning and
investment control review requirements of the Office of Management and
Budget (OMB); (2) complying with Customs‘ enterprise
architecture;[Footnote 2] and (3) complying with federal acquisition
rules, requirements, guidelines, and systems acquisition management
practices. Further, the plan was reviewed and approved by the Joint
Capital Investment Review Board[Footnote 3] and OMB.
Concerning our second objective, Customs is making progress in
addressing our open recommendations, which are as follows:
* Justify and make investment decisions incrementally.
* Before building each ACE release, certify to Customs‘ appropriations
subcommittees that Customs‘ enterprise architecture has been
sufficiently extended and updated.
* Develop and implement a rigorous and analytically verifiable cost
estimating program that embodies the tenets of effective estimating as
defined in the Software Engineering Institute‘s (SEI) institutional and
project-specific estimating guidance.
* Immediately develop and implement a human capital management strategy
for the Customs Modernization Office (CMO).
* Limit future expenditure plan requests for management reserve funds
to 10 percent of the total funds requested for the program, or
adequately justify any management reserve requests in excess of 10
percent.
* Develop and implement process controls consistent with SEI‘s Software
Acquisition Capability Maturity Model (SA-CMM[Footnote 4]), and by
September 30, 2002, assess and report to Customs‘ appropriation
subcommittees on the maturity of CMO‘s software acquisition process.
* Address the risks associated with the accelerated ACE acquisition
strategy and report on the strategy going forward and plans for
mitigating the risks associated with this strategy.
While Customs has taken actions to address each of these
recommendations, its actions to develop and implement a human capital
strategy and acquisition management process controls were only
partially consistent with our recommendations. Specifically, while the
CMO developed a human capital strategy that specified high-level
commitments and satisfied some best practices, there are some notable
omissions, including how these commitments will be met. Further, based
on the timeline in the strategy, it will be over a year before key
practices are implemented.
Also, while Customs reported to its House and Senate appropriations
subcommittees on its development of SA-CMM processes, it did not report
on implementation. Further, while many of the acquisition processes
have been developed, Customs has not yet implemented most of them.
Finally, we made the following observations:
* System integration and acceptance testing performed by the ACE
contractor is being conducted in accordance with best practices. The
contractor has established a test organization and built an
infrastructure for test activities. It has completed system integration
and system acceptance tests (SAT) for ACE increment 1, release 1.1, and
these test activities were consistent with test management best
practices.
* The results of SAT performed by the ACE contractor are positive. All
but seven ACE increment 1, release 1.1 requirements successfully passed
their test cases for SAT. For those that did not pass, only noncritical
system defects resulted, and acceptable workarounds were identified.
* Data provided by the ACE contractor on all unresolved system defects
for ACE increment 1, release 1.1, show a recent downward trend,
suggesting that the contractor is delivering a quality product.
* Customs‘ oversight of contractor testing does not provide for
independent verification and validation (IV&V). Industry best practices
include IV&V as a part of effective managerial oversight and control.
* The potential for ACE infrastructure to support other Department of
Homeland Security applications could affect both cost and schedule for
ACE. Customs is one of several agencies to be merged into the
Department of Homeland Security, and it has proposed that the ACE
infrastructure be used by these agencies. Because a meaningful
understanding of the effect of the new department‘s use of the ACE
infrastructure is not yet known, there is the potential for existing
ACE cost and schedule commitments to change.
Recommendations for Executive Action:
To ensure that Customs has the requisite capability to manage its ACE
acquisition, we recommend that the Customs Service Commissioner
designate strengthening CMO human capital and acquisition processes as
priority matters. To this end, we recommend that the Commissioner
direct the Chief Information Officer (CIO) to immediately:
* develop and implement each of the missing SEI SA-CMM practices for
the key process areas discussed in this report, and until this is
accomplished, report to its appropriations subcommittees quarterly on
the progress of its efforts to do so;
* develop and implement the missing human capital management practices
discussed in this report, and until this is accomplished, report to its
appropriations committees quarterly on the progress of its efforts to
do so; and:
* establish an IV&V function to assist Customs in overseeing contractor
efforts, such as testing.
Additionally, we recommend that the Commissioner take steps, as
appropriate in light of Customs‘ merger into the Department of Homeland
Security, to have future ACE expenditure plans specifically address any
proposals or plans, whether tentative or approved, for extending and
using ACE infrastructure to support other homeland security
applications, including any impact on ACE of such proposals and plans.
Agency Comments and Our Evaluation:
In written comments on a draft of this report signed by the acting
director, Office of Planning, Customs stated that it was pleased with
the report, agreed with our recommendations, and described specific
actions that are being taken to implement each. Customs‘ comments are
reprinted in appendix II.
Customs also provided additional information regarding our
recommendation that it establish an IV&V function to assist in
overseeing contractor efforts, such as testing. Specifically, Customs
stated that it wanted to modify its earlier statement that it relies on
the contractor‘s reputation and maturity level as guarantors of system
quality. Customs said that its modified position is based on a number
of practices that it believes are elements of an integrated approach to
IV&V. However, the practices that Customs described as elements of
IV&V, while additive to system quality, are not independent from
program cost and schedule pressures, and therefore do not constitute
IV&V.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of other Senate and House committees and subcommittees
that have authorization and oversight responsibilities for the Customs
Service. We are also sending copies to the Secretary of Homeland
Security, the Secretary of the Treasury, the Commissioner of the
Customs Service, and the Director of OMB. We also will make copies
available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at http://www.gao.gov.
Should you or your staff have any questions on matters discussed in
this report, please contact me at (202) 512-3439. I can also be reached
by E-mail at HiteR@gao.gov. Key contributors to this report were Mark
Bird, Harold Brumm, Jr., Barbara Collier, Scott Farrow, Joanne Fiorino,
Tamra Goldstein, Michael Holland, Freda Paintsil, Madhav Panwar, Karen
Richey, Randolph Tekeley, and Aaron Thorne.
Signed by Randolph C. Hite:
Randolph C. Hite
Director, Information Technology Architecture
and Systems Issues:
[End of section]
Appendixes:
[End of section]
Appendix I: Customs‘ Fourth Automated Commercial Environment (ACE)
Expenditure Plan:
[See PDF for image] - graphic text:
[End of figure] - graphic text:
[End of section]
Appendix II: Comments from the U.S. Customs Service:
U.S. Customs Service Memorandum:
DATE: February 13, 2003:
MEMORANDUM FOR RANDOLPH C. HITE:
U.S. GENERAL ACCOUNTING OFFICE:
FROM: Acting Director Office of Planning:
SUBJECT: General Accounting Office (GAO) Draft Report: Customs Service
Modernization Automated Commercial Environment (ACE) Progressing, but
Further Acquisition Management Improvements Needed:
Thank you for providing us with a copy of your draft report and the
opportunity to discuss the issues in this report.
Overall, we are pleased with the GAO report. GAO concludes that Customs
has met the legislative requirements imposed by Congress and continues
to progress in addressing prior GAO recommendations. GAO also reports a
positive assessment of the testing practices and results of the ACE
contractor.
GAO characterizes progress in implementing a human capital strategy and
key acquisition management practices as slow and recommends quarterly
reporting of progress to the appropriations committees. While we
certainly agree with the recommendations, we briefly note actions taken
that show that Customs continues to work diligently to address these
two critical program management dimensions.
Customs continues to implement its Modernization Strategic Human
Capital Management Plan (HCMP) in accordance with the GAO principles.
Priority attention was given to gaining Commissioner approval for an
expanded Customs Modernization Office (CMO) organizational structure
and
filling these positions. This has been accomplished, and a talented
cadre
of executives is trained and functioning to oversee the Modernization
task
orders. In addition, our quarterly report will show that we have taken
responsive actions across the range of GAO principles, such as the
following:
* Integration of human capital functional staff into management teams
through the inclusion of the OF Resources Management Group (RMG) in the
RCMP implementation and through participation of the Director of the
RMG and Customs Office of Human Resources Management in the
Modernization Management Team.
* Issuance of the new ’Customs Leadership Development Guide“ in
December
2002 that clearly identifies a comprehensive leadership competency
model, as well as a Customs Succession Management System.
* Establishment of performance plans for the CMO staff in October 2002,
and the inclusion of Modernization objectives in the performance plans
of an array of OIT executives and managers. *CMO recognition of staff
for their contributions at a quarterly ceremony with both cash and non-
traditional awards.
The CMO is also continuing to implement key acquisition practices. Its
January assessment found substantial progress in implementing key
practices, but Customs agrees that much more progress is needed. To
ensure that progress is made:
* CMO and other Customs managers and personnel have been assigned
responsibilities to manage and implement the acquisition processes and
have been trained on the process improvement goals, timeframes, and
their roles in achieving these goals.
* The CMO continues to internally assess progress against the CMO
process improvement goals. Additionally, Customs is contracting with
the Software Engineering Institute (SEI) to conduct both rated and non-
rated Software Acquisition -Capability Maturity Model (SA-CMM)
assessments to measure progress towards becoming a Level 2
organization.
* Deficiencies identified in the process asset audit have been
distilled
into Corrective Action Requests (CARs) that are tracked in an OF
database. The CMO is aggressively working to close these CARs and
continues to move as rapidly as possible through process
implementation.
These are examples of the progress Customs will include in its
quarterly report.
OF also agrees to implement actions responsive to GAO‘s recommendation
relative to an independent verification and validation function (IV&V).
However, OF wishes to modify the characterization of its IV&V function
provided to GAO in the short timeframe we had for a response. To state
that we rely upon the contractor‘s reputation and maturity level as
guarantors of system quality is not reflective of the range of
practices the CMO has implemented as part of its integrated
approach to IV&V. Such practices have included;
* Independent review of the e-Customs Partnership (eCP) requirements
products by end users.
* Involvement of the OIT Software Development and Infrastructure
Services Divisions in conducting IV&V of the technical design and
implementation products.
* Engagement of the MITRE Corporation, as the CMO‘s Federally Funded
Research and Development Center (FFRDC), to provide technically
knowledgeable and independent reviews of all critical eCP products.
These practices represent elements of an Integrated Independent
Verification and Validation (12V2) function that enables us to
accomplish the needs of a complex Modernization program. Customs
recognizes that these functions could benefit from being formalized
into a process. As a result, where appropriate, Customs will strengthen
and formalize this process, as well as establish formal accountability
for the 12V2 function, including formal sign-off. MITRE, as the Customs
FFRDC, will take the lead in reviewing, documenting, and strengthening
the 12V2 process.
If you have any questions regarding these comments, please contact Ms.
Michele Donahue at (202) 927-0957.
Signed by Brenda B. Smith:
Brenda B. Smith:
Attachment:
U.S. Customs Service General Accounting Office (GAO) Review of Fourth
Automated Commercial Environment (ACE) Expenditure Plan:
Recommendation 1: Develop and implement the missing human capital
management, practices discussed in this briefing, and until this is
accomplished, report to its (Customs) appropriations committees
quarterly on the progress of its (Customs) efforts to do so.
Response:
Customs concurs with GAO‘s recommendation to implement the actions
identified in the Modernization Strategic Human Capital Management Plan
(HCMP) and further develop the Customs Modernization Office (CMO) human
capital practices. Customs also shares GAO‘s desire to speed
implementation and thereby mitigate program risks. Customs will report
quarterly on its progress in implementing its HCMP.
Milestone Date:March 31, 2003 for CMO concurrence on Job and Core
Competencies:
Recommendation 2: Develop and implement each of the missing Software
Engineering Institute (SEI) Software Acquisition-Capability Maturity
Model (SA-CMIM) practices for the key process areas discussed in this
briefing, and until this is accomplished, report to its (Customs)
appropriations subcommittees quarterly on the progress of its efforts
to do so.
Response:
Customs agrees with GAO on the immediate need to develop and implement
all of the SEI SA-CMM practices in the key process areas, and believes
substantial progress is being made toward that end. Customs will
provide quarterly progress reports to Customs appropriations committees
in accordance with Congressional direction.
Milestone Date:April 2003 for updated, process asset audit:
Recommendation 3: Establish an independent verification and validation
(IV&V) function to assist Customs in overseeing contractor efforts,
such as testing.
Response:
The opportunity afforded by the comment period on the GAO draft report
leads the Office of Information and Technology (OIT) to modify the
position it took in responding to GAO‘s short turnaround request of
December 26, 2002 for a characterization of its IV&V activities. OIT
believes it has in place a number of elements of an Integrated
Independent Verification and Validation (12V2) function that conforms
to contemporary practices and has provided value in terms of reduced
risks. However, Customs recognizes that these functions could benefit
from being formalized into a process. As a result, where appropriate,
Customs will strengthen and formalize this process, as well as
establish formal accountability for the 12V2 function, including formal
sign-off. MITRE, as the Customs Federally Funded Research and
Development Center FFRDC), will take the lead in reviewing,
documenting, and strengthening the I V2 process.
Milestone Date:May 30, 2003 for an 12V2 strategic plan July 31, 2003
for documented 12V2 process:
Recommendation 4: Take steps, as appropriate in light of Customs merger
into the Department of Homeland Security, to have future ACE
expenditure plans specifically address any proposals or plans, whether
tentative or approved, for extending and using ACE infrastructure to
support other homeland security applications, including any impact on
ACE of such proposals and plans.
Response:
Customs recognizes the importance of apprising the appropriations
committees of any changes in ACE plans that might arise from merger
into the Department of Homeland Security. However, Customs questions
the appropriateness of the GAO recommendation that ’tentative proposals
or plans“ be included. Customs will continue its practice of providing
the appropriations committees with expenditure plans that are well
justified and are vetted and approved across the Executive Branch. When
the ACE infrastructure is used or extended to support other Homeland
Security applications, this will be noted in the appropriate
Expenditure Plans.
Milestone Date:August 2003 for release of Expenditure Plan to the
Congress and GAO:
FOOTNOTES
[1] For example, P. L. 108-2 appropriated such amounts as may be
necessary under the authority and conditions provided in the applicable
appropriations act for fiscal year 2002 for continuing projects or
activities that were conducted in fiscal year 2002, at a rate for
operations not exceeding the current rate, and for which
appropriations, funds, or other authority was made available in the
Treasury and General Government Appropriations Act, 2002, P. L. 107-67,
115 Stat. 514, 520 (2001). These appropriations shall be available to
the extent and in the manner which would be provided by the fiscal year
2002 Treasury Appropriations Act.
[2] An enterprise architecture is an institutional blueprint for
guiding and constraining investments in business process change and
systems.
[3] To expedite reviews of ACE expenditure plans, the Customs and
Treasury Investment Review Boards were consolidated to form the Joint
Capital Investment Review Board.
[4] Capability Maturity Model (CMM) is a service mark of Carnegie
Mellon University, and CMM is registered in the U.S. Patent and
Trademark Office. The SA-CMM identifies key process areas that are
necessary to effectively manage software-intensive system
acquisitions. Level 2 is the second level of the SA-CMM‘s five-level
scale; achieving this level means that an organization has the software
acquisition rigor and discipline to repeat project successes.
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