Homeland Security
Risks Facing Key Border and Transportation Security Program Need to Be Addressed
Gao ID: GAO-03-1083 September 19, 2003
The Department of Homeland Security (DHS) plans to establish a program to strengthen management of the pre-entry, entry, status, and exit of foreign nationals who travel to the United States. The goals of the program, known as the United States Visitor and Immigrant Status Indicator Technology (US-VISIT), are to facilitate legitimate trade and travel, enhance national security, and adhere to U.S. privacy laws and policies. By congressional mandate, DHS is to develop and submit for approval an expenditure plan for US-VISIT that satisfies certain conditions, including being reviewed by GAO. GAO was asked to determine, among other things, whether the plan satisfies these conditions and to provide observations about the plan and DHS's management of the program.
DHS's fiscal year 2003 US-VISIT expenditure plan and related documentation partially satisfied the conditions imposed by the Congress, which include meeting the capital planning and investment control review requirements of the Office of Management and Budget (OMB). For example, DHS fulfilled the OMB requirement that agencies state whether projects are approved by investment review boards and reviewed by Chief Financial and Procurement Officers; the plan was conditionally approved by DHS's review board, which includes DHS's Chief Financial and Procurement Officers. On the other hand, OMB guidance requires that agency plans summarize life cycle costs and include a cost/benefit analysis that covers return on investment. DHS has not yet established a date and plan for developing these for US-VISIT, although program officials stated that they intend to do so. GAO also identified 10 factors affecting US-VISIT and concluded that the program is a very risky endeavor. Some risk factors are inherent to the program, such as its mission criticality, its size and complexity, and its enormous potential costs. Others, however, arise from the program's relatively immature state of governance and management. For example, although the program has governmentwide scope, an accountable governance structure to direct and oversee the program that reflects this scope is not yet established. In addition, a US-VISIT program management capability has yet to be established, important aspects defining the program's operating environment are not decided, facility needs are unclear and challenging, and the mission value to be derived from the program's initial operating capability is unknown. Because of the risk factors, GAO concluded that it is uncertain that US-VISIT will be able to measurably and appreciably achieve DHS's stated goals for the program. Further, DHS's near-term investment in the program is at risk of not delivering promised capabilities on time and within budget and not producing mission value commensurate with investment costs.
Recommendations
Our 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.
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GAO-03-1083, Homeland Security: Risks Facing Key Border and Transportation Security Program Need to Be Addressed
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Report to Congressional Committees:
September 2003:
HOMELAND SECURITY:
Risks Facing Key Border and Transportation Security Program Need to Be
Addressed:
GAO-03-1083:
GAO Highlights:
Highlights of GAO-03-1083, a report to Subcommittees on Homeland
Security, Senate and House Committees on Appropriations
Why GAO Did This Study:
The Department of Homeland Security (DHS) plans to establish a program
to strengthen management of the pre-entry, entry, status, and exit of
foreign nationals who travel to the United States. The goals of the
program, known as the United States Visitor and Immigrant Status
Indicator Technology (US-VISIT), are to facilitate legitimate trade
and travel, enhance national security, and adhere to U.S. privacy laws
and policies. By congressional mandate, DHS is to develop and submit
for approval an expenditure plan for US-VISIT that satisfies certain
conditions, including being reviewed by GAO. GAO was asked to
determine, among other things, whether the plan satisfies these
conditions and to provide observations about the plan and DHS‘s
management of the program.
What GAO Found:
DHS‘s fiscal year 2003 US-VISIT expenditure plan and related
documentation partially satisfied the conditions imposed by the
Congress, which include meeting the capital planning and investment
control review requirements of the Office of Management and Budget
(OMB). For example, DHS fulfilled the OMB requirement that agencies
state whether projects are approved by investment review boards and
reviewed by Chief Financial and Procurement Officers; the plan was
conditionally approved by DHS‘s review board, which includes DHS‘s
Chief Financial and Procurement Officers. On the other hand, OMB
guidance requires that agency plans summarize life cycle costs and
include a cost/benefit analysis that covers return on investment. DHS
has not yet established a date and plan for developing these for US-
VISIT, although program officials stated that they intend to do so.
GAO also identified 10 factors (see figure) affecting US-VISIT and
concluded that the program is a very risky endeavor. Some risk factors
are inherent to the program, such as its mission criticality, its size
and complexity, and its enormous potential costs. Others, however,
arise from the program‘s relatively immature state of governance and
management. For example, although the program has governmentwide
scope, an accountable governance structure to direct and oversee the
program that reflects this scope is not yet established. In addition,
a US-VISIT program management capability has yet to be established,
important aspects defining the program‘s operating environment are not
decided, facility needs are unclear and challenging, and the mission
value to be derived from the program‘s initial operating capability is
unknown. Because of the risk factors, GAO concluded that it is
uncertain that US-VISIT will be able to measurably and appreciably
achieve DHS‘s stated goals for the program. Further, DHS‘s near-term
investment in the program is at risk of not delivering promised
capabilities on time and within budget and not producing mission value
commensurate with investment costs.
What GAO Recommends:
GAO is making a number of recommendations to the Secretary of DHS
aimed at minimizing the risks facing US-VISIT, including (1)
establishing an executive body, composed of appropriate stakeholder
representatives, to guide and direct the program, be held accountable
for the program‘s progress and outcomes, and address key program
issues and make associated decisions and (2) taking steps to establish
an effective program management capability. DHS concurred with our
recommendations and stated that it has made progress toward addressing
them.
www.gao.gov/cgi-bin/getrpt?GAO-03-1083
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Randolph C. Hite at
(202) 512-3439 or hiter@gao.gov.
[End of section]
Contents:
Letter:
Recommendations for Executive Action:
Agency Comments:
Appendixes:
Appendix I: Briefing to the Staffs of the Subcommittees on Homeland
Security, Senate and House Committees on Appropriations:
Appendix II: Comments from the Department of Homeland Security:
Abbreviations:
ADIS: Arrival Departure Information System:
APIS: Advance Passenger Information System:
CCD: Consular Consolidated Database:
CLAIMS 3: Computer Linked Application Information Management: System
3:
CLASS: Consular Lookout and Support System:
DHS: Department of Homeland Security:
EA: enterprise architecture:
IBIS: Interagency Border Inspection System:
IDENT: Automated Biometric Identification System:
INS: Immigration and Naturalization Service:
IRB: Investment Review Board:
IT: information technology:
NIIS: Non-Immigrant Information System:
NSEERS: National Security Entry-Exit Registration System:
OMB: Office of Management and Budget:
POE: port of entry:
SA-CMM®: Software Acquisition Capability Maturity Model®:
SEI: Software Engineering Institute:
SEVIS: Student Exchange Visitor Information System:
US-VISIT: U.S. Visitor and Immigrant Status Indicator Technology:
Letter September 19, 2003:
The Honorable Thad Cochran
Chairman
The Honorable Robert C. Byrd
Ranking Minority Member
Subcommittee on Homeland Security
Committee on Appropriations
United States Senate:
The Honorable Harold Rogers
Chairman
The Honorable Martin Olav Sabo
Ranking Minority Member
Subcommittee on Homeland Security
Committee on Appropriations
House of Representatives:
Pursuant to the Consolidated Appropriations Resolution, 2003,[Footnote
1] the Department of Homeland Security (DHS) submitted to Congress in
June 2003 its fiscal year 2003 expenditure plan for the United States
Visitor and Immigrant Status Indicator Technology (US-VISIT) program.
US-VISIT is a governmentwide program intended to improve the nation's
capacity for collecting information on foreign nationals who travel to
the United States, as well as control the pre-entry, entry, status, and
exit of these travelers. The goals for US-VISIT are to facilitate
legitimate travel and trade, enhance national security, and adhere to
U.S. privacy laws and policies. As also required by the Consolidated
Appropriations Resolution, 2003, we reviewed the expenditure plan. Our
objectives were to (1) determine whether the US-VISIT fiscal year 2003
expenditure plan satisfies certain legislative conditions specified in
the Consolidated Appropriations Resolution, 2003; (2) determine the
status of our US-VISIT open recommendations; and (3) provide any other
observations about the expenditure plan and DHS's management of US-
VISIT. The specified legislative conditions are that the plan meet the
capital planning and investment control review requirements established
by the Office of Management and Budget (OMB), including OMB Circular A-
11, part 3; that it comply with the acquisition rules, requirements,
guidelines, and systems acquisition management practices of the federal
government; and that it be reviewed by GAO.
On July 18, 2003, we provided your offices a written briefing detailing
the results of our review. This report summarizes and transmits this
briefing. The full briefing, including our scope and methodology, is
reprinted as appendix I.
Concerning our first objective, DHS partially satisfied those
legislative conditions specified in the Consolidated Appropriations
Resolution, 2003, that are applicable to it. That is, the plan,
including related program documentation and program officials'
statements, satisfied or provided for satisfying many, but not all of
the key aspects of (1) OMB's capital planning and investment control
review requirements; and (2) federal acquisition rules, requirements,
guidelines, and systems acquisition management practices. For example,
DHS fulfilled the OMB requirement that agencies state whether projects
are approved by investment review boards and reviewed by Chief
Financial and Procurement Officers; the plan was conditionally approved
by DHS's review board, which includes DHS's Chief Financial and
Procurement Officers. On the other hand, OMB guidance requires that
agency plans summarize life cycle costs and include a cost/benefit
analysis that covers return on investment. DHS has not yet established
a date and plan for developing a current life cycle cost and a cost/
benefit analysis for US-VISIT, although program officials stated that
they intend to do so.
Concerning our second objective, DHS has initiated action to implement
or has partially implemented most, but not all of the recommendations
contained in our report on the fiscal year 2002 expenditure
plan.[Footnote 2] Each recommendation, along with the status of each,
is summarized below.
* We recommended that DHS develop a system security plan and privacy
impact assessment. The department has action under way to address this
recommendation. Specifically, DHS reported that it has defined security
and privacy requirements and has drafted a security plan and a privacy
impact assessment.
* We recommended that DHS ensure that controls in the area of
acquisition planning, solicitation, requirements management, program
management, contract tracking and oversight, and evaluation are
implemented in accordance with the Software Engineering Institute's
(SEI) guidance.[Footnote 3] The department plans to implement this
recommendation. Specifically, DHS has recently approved a program
management structure that includes functions consistent with these
controls; however, it has not yet developed explicit plans or time
frames for defining and implementing them.
* We recommended that DHS ensure that future expenditure plans are
provided to the department's House and Senate Appropriations
Subcommittees in advance of US-VISIT funds being obligated. With
respect to the fiscal year 2003 expenditure plan, DHS partially
satisfied this recommendation. Specifically, it provided this plan to
the Senate and House Appropriations Subcommittees on Homeland Security
in June 2003. However, following DHS's request for use of $5 to $7
million in March 2003, the April 2003 House Conference Report[Footnote
4] recommended that DHS use $5 million for US-VISIT. DHS subsequently
allocated the $5 million to the US-VISIT program.
* We recommended that DHS ensure that future expenditure plans fully
disclose US-VISIT system capabilities, schedule, cost, and benefits.
With respect to the fiscal year 2003 expenditure plan, DHS has
partially satisfied this recommendation. Specifically, this plan
describes high-level capabilities by increment, high-level schedule
estimates, and categories of expenditures. However, the plan does not
associate these categories of expenditure to incremental capabilities,
time frames, and benefits. Moreover, the plan does not identify
expected benefits in tangible, measurable, and meaningful terms, nor
does it associate benefits with increments.
Finally, we identified 10 factors that make US-VISIT a risky endeavor.
Some of these risk factors are inherent to the program, and others are
a product of the program's relatively immature state of governance and
management. The specific risk factors that we identified are as
follows:
* US-VISIT is critical to the department's mission in preventing the
entry of persons who pose a threat to our nation into the United
States. The missed entry of just one of these persons could have severe
consequences.
* US-VISIT is large in scope and complex. For example, the program is
to (1) support a large governmentwide process involving multiple
departments and agencies, (2) modify and expand facilities at over 150
land ports of entry, and (3) interconnect about 20 existing systems.
* To meet US-VISIT's daunting milestones,[Footnote 5] DHS has chosen to
implement temporary solutions, largely because over the last 7 years,
limited progress has been made in addressing key legislative
requirements. For example, to meet deadlines at land ports of entry,
DHS plans to develop and implement interim, or temporary, system and
facility solutions.
* The program will be a costly undertaking. In February 2003, DHS
estimated that the program would cost about $7.2 billion through fiscal
year 2014. However, this estimate is outdated and does not include, for
example, the State Department's cost to implement visas with
biometrics, which we previously estimated could add as much as $15
billion to the program's cost through 2014.[Footnote 6]
* The performance of initial increments of the US-VISIT system depends
on the performance of existing systems that are to be interfaced. Some
of these systems, such as the Student and Exchange Visitor Information
System[Footnote 7] and the Computer Linked Application Information
Management System 3,[Footnote 8] have known system availability
problems that could limit US-VISIT system performance.
* US-VISIT is not currently directed and overseen by an accountable
governance structure that reflects the program's governmentwide scope
and that includes the appropriate leaders from each stakeholder
organization, that is, those who can make and enforce decisions and
commit resources.
* The US-VISIT program office does not have the capabilities (people,
processes, and tools) to effectively manage the program. For example,
this office has not yet been adequately staffed, specific roles and
responsibilities have not been defined, and acquisition management
process controls have not been developed and implemented. Moreover, DHS
has not defined specific plans and time frames for doing so.
* Key information about the operational context surrounding US-VISIT
that is necessary to effectively define, establish, and implement the
program is not yet available. As a result, DHS is making certain
assumptions and decisions in order to meet near-term deadlines, such as
the use of a two-fingerprint biometric; these assumptions and decisions
would require system rework if they prove inconsistent with subsequent
operational context policy or standards decisions.
* Construction of US-VISIT facility solutions, both interim and
permanent, pose serious challenges for a number of reasons. For
example, existing facilities do not support existing entry and exit
processes at a number of land ports of entry, border crossing wait
times are very sensitive to very small increases in processing times at
certain high-volume land ports of entry, and interim facility solutions
must satisfy yet-to-be defined program requirements.
* The mission value to be gained from the initial US-VISIT operational
capability planned for December 31, 2003, is not currently known. In
particular, DHS has not defined specific, measurable benefits expected
from this initial operating capability, in large part because it has
yet to define the processes that will govern how entry and exit
activities will be performed. This uncertainty is compounded by the
fact that this initial operating capability is to be constrained by
existing facilities and personnel and it is not to result in increases
in border crossing wait times.
In conclusion, US-VISIT is a risky undertaking because it is to support
a critical mission, its scope is large and complex, it must meet a
demanding implementation schedule, and its potential cost is enormous.
Generally, these risk factors are inherent to the program and cannot be
easily changed. However, compounding these inherent risk factors are a
number of others that are attributable to the program's current state
of governance and management and its acquisition approach, as described
above. Further, DHS did not fully satisfy the legislative conditions
imposed by the Congress and has yet to fully implement our previous
recommendations, both of which were aimed at reducing risk. Because of
all these risk factors, it is uncertain that US-VISIT will be able to
measurably and appreciably achieve DHS's stated goals of facilitating
legitimate travel and trade, enhancing national security, and adhering
to U.S. privacy laws and policies. Moreover, DHS's near-term investment
in the program is at risk of not delivering promised capabilities on
time and within budget, and not producing mission value commensurate
with investment costs. Thus, it is imperative that the factors that
contribute to this level of risk be addressed thoroughly and
expeditiously.
Recommendations for Executive Action:
To address US-VISIT as a governmentwide program and to minimize the
risks facing the program, we recommend that the Secretary of Homeland
Security, in collaboration with cabinet officials from US-VISIT
stakeholder departments and agencies,
* establish and charter an executive body, chaired by the Secretary's
designee, potentially co-chaired by the leadership from key stakeholder
departments and agencies, and composed of appropriate senior-level
representatives from DHS and each stakeholder organization, to guide
and direct the US-VISIT program; and:
* direct this executive body to immediately take steps to (1) ensure
that the human capital and financial resources are expeditiously
provided to establish a fully functional and effective US-VISIT program
office and associated management capability, (2) clarify the
operational context within which US-VISIT must operate, and (3) decide
whether proposed US-VISIT increments will produce mission value
commensurate with costs and risks and disclose to the Congress planned
actions based on this body's decisions.
Further, we recommend that the Secretary, through the Under Secretary
for Border and Transportation Security, direct the US-VISIT Program
Director to expeditiously establish an effective program management
capability, including immediately:
* defining program office positional roles, responsibilities, and
relationships;
* developing and implementing a human capital strategy that provides
for staffing these positions with individuals who have the requisite
core competencies (knowledge, skills, and abilities);
* developing and implementing a plan for satisfying key SEI acquisition
management controls, to include acquisition planning, solicitation,
requirements development and management, project management,
contractor tracking and oversight, evaluation, and transition to
support;
* developing and implementing a risk management plan and ensuring that
all high risks and their status are reported regularly to the executive
body;
* defining performance standards for each US-VISIT system increment
that are measurable and reflect the limitations imposed by relying on
existing systems for these system increments; and:
* developing an analysis of incremental program costs, benefits, and
risks, and providing this analysis to the executive body, to assist it
in the body's deliberations and decision making.
Agency Comments:
In written comments on a draft of this report signed by the Director,
US-VISIT, DHS concurred with our recommendations and stated that it has
recently made progress toward addressing them. In particular, DHS
stated that it has approved the proposed US-VISIT organizational
structure and identified necessary staff positions, and that it is
working with the Office of Personnel Management to draft position
descriptions and prepare for recruitment. Also, it stated that the US-
VISIT program office is staffed with 51 detailees from various DHS
components and agencies. Last, it stated that it has in place an
Investment Review Board that has twice reviewed US-VISIT, has
established a DHS framework for addressing policy questions, and has
plans to establish a US-VISIT Advisory Council. DHS's comments are
reprinted in appendix II.
:
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 homeland
security. We are also sending copies to the Secretary of State 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 Seto
Bagdoyan, Barbara Collier, Deborah Davis, Neil Doherty, Rebecca
Gambler, Tamra Goldstein, James Houtz, Richard Hung, Tammi Nguyen, and
Mark Tremba.
Signed by:
Randolph C. Hite
Director, Information Technology Architecture and Systems Issues:
[End of section]
Appendixes:
Appendix I: Briefing to the Staffs of the Subcommittees on Homeland
Security, Senate and House Committees on Appropriations:
[See PDF for image]
[End of figure]
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
September 3, 2003:
Mr. Randolph C. Hite:
Director, Information Technology Architecture And Systems Issues:
U.S. General Accounting Office 441 G Street, NW Washington, DC 20548:
Dear Mr. Hite:
Thank you for the opportunity to review the draft report, Information
Technology: Risks Facing Key Homeland Security Program Need to Be
Addressed (GAO-03-1083). We appreciate the time the General Accounting
office has taken to review the FY 2003 spending plan for the United
States Visitor and Immigrant Status Technology (US-
VISIT) Program. Overall, we concur with your recommendations to
establish an effective program management capability and a proper
governance structure. We are pleased to report that, subsequent to your
findings, significant progress has been made in both areas.
Nevertheless, we realize that much needs to be done.
In terms of your specific findings and observations, we believe the US-
VISIT program has made considerable progress, and we recommend that you
consider adding these updates to your final report.
The proposed organizational structure for US-VISIT has received
Departmental approval. The necessary staff positions have been
identified and work has begun with the Office of Personnel Management
to draft position descriptions and prepare for recruitment. Meanwhile,
the current staff of 51 includes detailees and dedicated personnel from
Customs and Border Protection, Immigration and Customs Enforcement,
other components within the Department of Homeland Security (DHS), and
other agencies who have been brought on board to ensure that essential
work is performed pending full staffing with 115 government employees,
including 8 senior executives. In coordination with the General
Services Administration, adequate office space has been identified and
is being secured.
In the area of program governance, a DHS Investment Review Board is
already in place; US-VISIT was the first program to undergo a review by
this board, and it has now been reviewed twice. In addition, a DHS
policy framework is now in place through which important policy
questions can be addressed. Finally, we are in the process of setting
up a US-VISIT Advisory Council.
If you have any questions, please contact me, or a member of your staff
may contact Thomas Hamer at (202) 305-0845.
Sincerely,
James A. Williams:
Director, US-VISIT Program:
[End of section]
(310266):
FOOTNOTES
[1] P.L. 108-7 (Feb. 20, 2003).
[2] U.S. General Accounting Office, Information Technology: Homeland
Security Needs to Improve Entry Exit System Expenditure Planning, GAO-
03-563 (Washington, D.C.: June 9, 2003).
[3] Carnegie Mellon Software Engineering Institute, Software
Acquisition Capability Maturity Model", Version 1.03 (March 2002)
defines acquisition process management controls for planning, managing,
and controlling software-intensive system acquisitions.
[4] H.R. Conf. Rep. No. 108-76, at 80 (2003).
[5] For example, the Immigration and Naturalization Service Data
Management Improvement Act of 2000 (P.L. 106-215, June 15, 2000)
requires that US-VISIT be implemented at all air and sea ports of entry
by December 31, 2003; at the 50 highest volume land ports of entry by
December 31, 2004; and at all remaining ports of entry by December 31,
2005.
[6] U.S. General Accounting Office, Technology Assessment: Using
Biometrics for Border Security, GAO-03-174 (Washington, D.C.: Nov. 15,
2002).
[7] The Student and Exchange Visitor Information System contains
information on foreign students.
[8] The Computer Linked Application Information Management System 3
contains information on foreign nationals who request benefits, such as
change of status or extension of stay.
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