USCIS Transformation
Improvements to Performance, Human Capital, and Information Technology Management Needed as Modernization Proceeds Gao ID: GAO-07-1013R July 17, 2007GAO and Inspector General (IG) reports have noted that the U.S. Citizenship and Immigration Service (USCIS) efforts to modernize over the last 4 years have been unfocused, conducted in an ad hoc and decentralized manner, and, in certain instances, duplicative. In 2006, USCIS decided to reexamine its modernization effort within the context of an agencywide organizational and business transformation initiative. The agency embarked on a transformation of its business processes and technology aimed at increasing national security and integrity, improving customer service, and achieving operational efficiency. We agreed with this approach and recommended that USCIS employ key practices for successful organizational transformations to better ensure the success of its efforts. USCIS plans to complete its transformation by 2013 at an estimated cost of up to $536 million, mostly funded by fee revenues. The Department of Homeland Security (DHS) Appropriations Act for fiscal year 2007 mandated that GAO review USCIS' transformation plans before the agency can obligate $47 million in funding for the transformation. Congress also requested that specific information be included in USCIS' plan: all resources associated with transformation efforts (appropriations and fees), including a detailed breakout of costs for fiscal year 2007, and the impact of availability of fee revenue; alignment of the transformation process with DHS' enterprise architecture; and details on expected project performance and deliverables. Pursuant to the Department of Homeland Security Appropriations Act, 2007, USCIS, in May 2007, submitted to the congressional appropriations committees its Transformation Program Strategic Plan and Expenditure Plan. As required by the act, we reviewed these plans. Our objectives were to (1) describe the extent to which USCIS' plans incorporate key practices identified by GAO for organizational transformations, and (2) describe if and how USCIS' plans include congressionally requested information.
USCIS' plans partially or fully address most key practices for organizational transformations. For example, USCIS has taken initial steps in addressing problems identified with past efforts to modernize by establishing a Transformation Program Office (TPO) that reports directly to the USCIS Deputy Director to ensure leadership commitment; dedicating people and resources to the transformation; establishing a mission, vision, and integrated strategic goals; focusing on a key set of priorities and defining core values; and involving employees. However, more attention is needed in certain areas, including: (1) Performance Measurement: Leading organizations recognize that setting goals and measuring performance can create powerful incentives to influence organizational and individual behavior. USCIS has developed some draft performance measures for the transformed organization, but has not defined targets for the desired level of performance to be achieved, and many of the measures are ill-defined or difficult to evaluate. (2) Strategic Human Capital Management: USCIS' plans do not sufficiently address important elements of strategic workforce planning. For example, the agency's plans do not identify the skills and competencies needed in the transformed organization, outline a strategy to maintain ongoing coordination with the Office of Human Capital, or address past and present leadership fluctuations. In addition, while the TPO has established performance expectations for its own staff, it has not formally evaluated the performance of its staff against those expectations. Further, USCIS as a whole has not developed transformation-related performance expectations and competencies for its executives and employees to hold them accountable for achieving the goals of the transformation. (3) Communications: Creating an effective, ongoing strategy for communicating with employees and stakeholders is critical to the success of any organizational transformation. USCIS has made efforts to communicate information about the transformation to its employees and stakeholders, and has developed an overall communication strategy. However, this strategy does not contain a clearly defined plan to conduct outreach beyond the current fiscal year, and lacks a detailed approach for targeting communications to individual government partners and stakeholders. (4) Information Technology (IT) Management: It is important that USCIS acquire IT systems and services in a way that employs leading IT management practices, such as those embodied in federal guidance that we and others have issued relative to enterprise architecture management, IT systems development and acquisition, and IT services acquisition. USCIS is early in the process of developing its own enterprise architecture. However, USCIS' plans do not include a performance element, an important architectural component. Moreover, while the agency is following DHS' procedures to align the transformation with DHS' enterprise architecture, we have previously reported that these procedures are not sufficient, and that DHS' enterprise architecture is not complete. USCIS plans provide some information on transformation costs and revenues, but USCIS has not finalized its acquisition strategy and therefore cost estimates remain uncertain. In addition, the plans do not sufficiently discuss enterprise architecture alignment and expected project performance. USCIS is in the very early stages of its transformation and its plans for transformation reflect at least partially most of the practices associated with successful organizational transformations. However, the gaps we have identified in USCIS' plans create risks that could undermine its success as it begins to implement its plans.
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-07-1013R, USCIS Transformation: Improvements to Performance, Human Capital, Communications, and Information Technology Management Needed as Modernization Proceeds
This is the accessible text file for GAO report number GAO-07-1013R
entitled 'USCIS Transformation: Improvements to Performance, Human
Capital, Communications, and Information Technology Management as
Modernization Proceeds' which was released on July 17, 2007.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
July 16, 2007:
Chairman, Honorable David E. Price:
Ranking Member, Honorable Harold Rogers:
Subcommittee on Homeland Security:
House Committee on Appropriations:
Chairman, Honorable Robert C. Byrd:
Ranking Member, Honorable Thad Cochran:
Subcommittee on Homeland Security:
Senate Committee on Appropriations:
Subject: USCIS Transformation: Improvements to Performance, Human
Capital, Communications, and Information Technology Management Needed
as Modernization Proceeds:
The U.S. Citizenship and Immigration Services (USCIS) adjudicates
benefits requests and petitions for individuals seeking to become
citizens of the United States or to study, live, or work in this
country. However, as previously reported,[Footnote 1] USCIS' ability to
annually process more than 7 million benefit applications has been
hindered by inefficient, paper-based processes, resulting in:
* a backlog that peaked in 2004 at more than 3.8 million cases,
* tens of thousands of files that are missing or not easily located,
* difficulties in verifying the identity of applicants and providing
other government agencies with the information necessary to identify
criminals and potential terrorists, and:
* benefits that were issued to applicants whose eligibility and
potential risk to national security were not yet determined.
USCIS also faces a potentially significant increase in workload as a
result of proposed legislation for a guest worker program, which could
further add to its performance problems.
Background:
GAO and Inspector General (IG) reports have noted that USCIS efforts to
modernize over the last 4 years have been unfocused, conducted in an ad
hoc and decentralized manner, and, in certain instances, duplicative.
In 2006, USCIS decided to reexamine its modernization effort within the
context of an agencywide organizational and business transformation
initiative. The agency embarked on a transformation of its business
processes and technology aimed at increasing national security and
integrity, improving customer service, and achieving operational
efficiency. We agreed with this approach and recommended that USCIS
employ key practices for successful organizational transformations to
better ensure the success of its efforts[Footnote 2] (see appendix I in
enclosure I for a list of the practices).[Footnote 3] USCIS plans to
complete its transformation by 2013 at an estimated cost of up to $536
million, mostly funded by fee revenues.
The Department of Homeland Security (DHS) Appropriations Act for fiscal
year 2007 mandated that GAO review USCIS' transformation plans before
the agency can obligate $47 million in funding for the transformation.
Congress also requested that specific information be included in USCIS'
plan: all resources associated with transformation efforts
(appropriations and fees), including a detailed breakout of costs for
fiscal year 2007, and the impact of availability of fee revenue;
alignment of the transformation process with DHS' enterprise
architecture; and details on expected project performance and
deliverables.
Pursuant to the Department of Homeland Security Appropriations Act,
2007,[Footnote 4] USCIS, in May 2007, submitted to the congressional
appropriations committees its Transformation Program Strategic Plan and
Expenditure Plan. As required by the act, we reviewed these plans. Our
objectives were to (1) describe the extent to which USCIS' plans
incorporate key practices identified by GAO for organizational
transformations, and (2) describe if and how USCIS' plans include
congressionally requested information.
Scope and Methodology:
To accomplish the objectives, we reviewed the USCIS Transformation
Program Strategic Plan, Expenditure Plan, subsidiary plans, and related
documents. We also reviewed related reports by GAO, the Inspector
General, and the USCIS Ombudsman. We interviewed officials from USCIS
Headquarters, the DHS Office of the Inspector General, the Office of
the USCIS Ombudsman, and the American Federation of Government
Employees. We compared USCIS' transformation and expenditure plans to
our key practices for organizational transformations and other good
management practices we have identified, such as in the areas of
information technology management, strategic planning, performance
measurement, and strategic human capital management. See appendix II in
enclosure I for a list of the reports from which we drew the practices.
We also reviewed the USCIS transformation and expenditure plans to
determine whether they included congressionally requested information.
Because USCIS is in the early planning phases of its transformation, we
did not assess USCIS' efforts to implement its plans. Further, we did
not assess the quality of the technical solutions USCIS is considering
as a part of the transformation.
We conducted our work from December 2006 to May 2007 in accordance with
generally accepted government auditing standards. We provided USCIS
with a draft of the information in the enclosure. They provided us with
comments that reprinted in their entirety in enclosure II.
On June 27, 2007, and July 2, 2007, we briefed your offices on the
results of this review to satisfy the requirements of this mandate.
This report transmits the results of our work. The full briefing is
enclosed.
Results in Brief:
USCIS' plans partially or fully address most key practices for
organizational transformations (see table on page 10 in the enclosure I
for a summary of our findings). For example, USCIS has taken initial
steps in addressing problems identified with past efforts to modernize
by establishing a Transformation Program Office (TPO) that reports
directly to the USCIS Deputy Director to ensure leadership commitment;
dedicating people and resources to the transformation; establishing a
mission, vision, and integrated strategic goals; focusing on a key set
of priorities and defining core values; and involving employees.
However, more attention is needed in certain areas, including:
* Performance Measurement: Leading organizations recognize that setting
goals and measuring performance can create powerful incentives to
influence organizational and individual behavior. USCIS has developed
some draft performance measures for the transformed organization, but
has not defined targets for the desired level of performance to be
achieved, and many of the measures are ill-defined or difficult to
evaluate.
* Strategic Human Capital Management: USCIS' plans do not sufficiently
address important elements of strategic workforce planning. For
example, the agency's plans do not identify the skills and competencies
needed in the transformed organization, outline a strategy to maintain
ongoing coordination with the Office of Human Capital, or address past
and present leadership fluctuations. In addition, while the TPO has
established performance expectations for its own staff, it has not
formally evaluated the performance of its staff against those
expectations. Further, USCIS as a whole has not developed
transformation-related performance expectations and competencies for
its executives and employees to hold them accountable for achieving the
goals of the transformation.
* Communications: Creating an effective, ongoing strategy for
communicating with employees and stakeholders is critical to the
success of any organizational transformation. USCIS has made efforts to
communicate information about the transformation to its employees and
stakeholders, and has developed an overall communication strategy.
However, this strategy does not contain a clearly defined plan to
conduct outreach beyond the current fiscal year, and lacks a detailed
approach for targeting communications to individual government partners
and stakeholders.
* Information Technology (IT) Management: It is important that USCIS
acquire IT systems and services in a way that employs leading IT
management practices, such as those embodied in federal guidance that
we and others have issued relative to enterprise architecture
management, IT systems development and acquisition, and IT services
acquisition. USCIS is early in the process of developing its own
enterprise architecture. However, USCIS' plans do not include a
performance element, an important architectural component. Moreover,
while the agency is following DHS' procedures to align the
transformation with DHS' enterprise architecture, we have previously
reported that these procedures are not sufficient, and that DHS'
enterprise architecture is not complete.[Footnote 5]
USCIS plans provide some information on transformation costs and
revenues, but USCIS has not finalized its acquisition strategy and
therefore cost estimates remain uncertain. In addition, the plans do
not sufficiently discuss enterprise architecture alignment and expected
project performance (see table on page 11 of enclosure I for a summary
of our findings).
USCIS is in the very early stages of its transformation and its plans
for transformation reflect at least partially most of the practices
associated with successful organizational transformations. However, the
gaps we have identified in USCIS' plans create risks that could
undermine its success as it begins to implement its plans.
Recommendations:
To improve its transformation strategy and fully address
congressionally requested information, we are making recommendations to
the Secretary of the Department of Homeland Security to direct the
Director of USCIS to address gaps in its plans in the areas of
performance measurement, strategic human capital management,
communications, and information technology management practices. The
specific recommendations are listed on pages 52-53 of the enclosure.
We are sending copies of this report to the Chairmen and Ranking
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 the Department
of Homeland Security, the Director of USCIS, and upon their request, to
other interested parties. In addition, the report is available at no
charge on the GAO Web site at http://www.gao.gov.
Should you or your offices have any questions on matters discussed in
this report, please contact me at (202) 512-6543 or at
steinhardtb@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 were Elizabeth Curda, Assistant
Director; Randy Hite; Anh Le; Jessica Lemke; and Martha Tracy.
Signed by:
Bernice Steinhardt:
Director, Strategic Issues:
Enclosures:
[End of section]
Enclosure I: Briefing to Congressional Staff:
USCIS Transformation: Improvements to Performance, Human Capital, and
Information Technology Management Needed as Modernization Proceeds:
Briefing to Congressional Staff:
June 27, 2007:
Congressional Requesters:
Chairman, Honorable David E. Price:
Ranking Member, Honorable Harold Rogers:
Subcommittee on Homeland Security:
House Committee on Appropriations:
Chairman, Honorable Robert C. Byrd:
Ranking Member, Honorable Thad Cochran:
Subcommittee on Homeland Security:
Senate Committee on Appropriations:
Briefing Overview:
Introduction:
Objectives:
Scope and Methodology:
Results in Brief:
Background:
Results:
* Key Practices for Organizational Transformations:
* Congressionally Requested Information:
Conclusions:
Recommendations for Executive Action:
Appendix 1: Description of Key Practices for Organizational
Transformations:
Appendix 2: Sources For Good Management Practices Used in This Review:
Introduction:
The U.S. Citizenship and Immigration Service (USCIS) adjudicates
benefits requests and petitions for individuals seeking to become
citizens of the United States or study, live, or work in this country.
USCIS' ability to annually process the more than 7 million immigration
benefit applications it receives is hindered by inefficient, paper-
based processes, resulting in:
* a backlog that peaked in 2004 at more than 3.8 million cases,
* tens of thousands of files that are missing or not easily located,
* difficulties in verifying the identity of applicants and providing
other government agencies with the information necessary to identify
criminals and potential terrorists, and:
* benefits that were issued to applicants whose eligibility and
potential risk to national security were not yet determined.
USCIS also faces a potentially significant increase in workload as a
result of proposed legislation for a guest worker program, which could
further add to its performance problems.
To meet these challenges, USCIS began a series of modernization efforts
to upgrade existing technology and achieve operational efficiency.
GAO and Department of Homeland Security (DHS) Inspector General reports
have noted that USCIS efforts to modernize over the last 4 years have
been unfocused, conducted in an ad hoc and decentralized manner, and,
in certain instances, duplicative.
In 2006, USCIS decided to reexamine its modernization effort within the
context of an agencywide organizational and business transformation
initiative.
USCIS embarked on a transformation of its business processes and
technology aimed at increasing national security and integrity,
improving customer service, and achieving operational efficiency.
We agreed with this approach and recommended that USCIS employ key
practices for successful organizational transformations to better
ensure the success of its efforts.*
* GAO, Information Technology. Near-Term Effort to Automate Paper-Based
Immigration Files Needs Planning Improvements, GAO-06-375 (Washington,
D.C.: Mar. 31, 2006).
In previous reports, GAO has identified key practices that have
consistently been found at the center of successful organizational
transformations:*
1. Ensure top leadership drives the transformation.
2. Establish a coherent mission and integrated strategic goals to guide
the transformation.
3. Focus on a key set of principles and priorities at the outset of the
transformation.
4. Set implementation goals and a timeline to build momentum and show
progress from day one.
5. Dedicate an implementation team to manage the transformation
process.
6. Use the performance management system to define responsibility and
assure accountability for change.
7. Establish a communication strategy to create shared expectations and
report related progress.
8. Involve employees to obtain their ideas and gain ownership for the
transformation.
9. Build a world-class organization.
These practices can serve as a basis for federal agencies, such as
USCIS, that seek to transform their cultures and business processes to
become more results-oriented, customer-focused, and collaborative in
nature.
* GAO previously identified a number of key practices found at the
center of successful mergers, acquisitions, and transformations in a
forum convened by the Comptroller General. See GAO, Highlights of a GAO
Forum: Mergers and Transformation: Lessons Learned for a Department of
Homeland Security and Other Federal Agencies, GAO-03-293SP (Washington,
D.C.: Nov. 14, 2002) and Results-Oriented Cultures: Implementation
Steps to Assist Mergers and Organizational Transformations, GAO-03-669
(Washington, D.C.: July 2, 2003).
USCIS plans to complete its transformation by 2013 at an estimated cost
of up to $536 million, mostly funded by fee revenues.
The DHS Appropriations Act for fiscal year 2007 mandated that GAO
review USCIS' transformation plans before the agency can obligate $47
million in fiscal year 2007 funding provided for the transformation.
Congress also requested that specific information be included in USCIS'
plan:
a. All resources associated with transformation efforts appropriations
and fees), including a detailed breakout of costs for fiscal year 007,
and the impact of availability of fee revenue.
b. Alignment of the transformation process with DHS' enterprise
architecture (EA).
c. Details on expected project performance and deliverables.
This briefing is intended to satisfy GAO's responsibility to review
USCIS' plan under this mandate.
The objectives of our work are to assess:
* The extent to which USCIS' strategic transformation plans incorporate
key practices identified by GAO for organizational transformations,
and:
* If and how USCIS' transformation plans include congressionally
requested information.
Scope and Methodology:
To accomplish the first objective, we:
* Analyzed documentation related to USCIS' transformation, such as:
- USCIS Transformation Program Strategic Plan and Expenditure Plan,
among others:
- Related GAO and Inspector General reports:
- Ombudsman annual reports:
- Meeting minutes related to transformation activities * Interviewed
officials from:
* USCIS Headquarters:
- DHS Inspector General Office:
- USCIS Ombudsman Office:
- American Federation of Government Employees:
* Compared USCIS' transformation plans to our key practices for
organizational transformations and other good management practices we
have identified, such as in the areas of information technology
management, strategic planning, performance measurement, and strategic
human capital management.
In addition to analyzing USCIS' primary plans (the Strategic Plan and
Expenditure Plan), we also examined USCIS' subsidiary plans, to the
extent they included information related to our objectives. Because
USCIS is in the early planning phases of its transformation, we did not
assess USCIS' efforts to implement its plans. Further, we did not
assess the quality of the technical solutions USCIS is considering as a
part of the transformation.
To accomplish the second objective, we:
* Reviewed the Transformation Program Strategic Plan and Expenditure
Plan to determine whether they included congressionally requested
information.
* Interviewed USCIS officials to determine if additional plans or
actions were underway to satisfy congressionally requested information.
* Compared USCIS plans for aligning its transformation process with
DHS' enterprise architecture to our guidance on such alignment.
Note: Information in text boxes describes good management practices we
used in our review. These practices are drawn from our work in the
areas of transformation planning, information technology, performance
measurement, and strategic human capital management. A complete list of
sources can be found in appendix 2.
We conducted our work from December 2006 to May 2007 in accordance with
generally accepted government auditing standards.
Results in Brief:
USCIS' plans partially or fully address most key practices for
organizational transformations.
Key practice: 1. Ensure top leadership drives the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has taken several actions to ensure top
leadership drives the transformation, such as establishing a
Transformation Program Office that directly reports to the USCIS Deputy
Director.
Key practice: 2. Establish a coherent mission and integrated startegic
goals to guide the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has established a mission, vision, and
strategic goals in its Strategic Plan that could be used to guide the
transformation.
Key practice: 3. Focus on a key set of principles and priorities at the
outset of the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has identified priorities and a succinct set
of core values with which to guide the transformation and help build a
new agencywide culture.
Key practice: 4. Set implementation goals and a timeline to build
momentum and show progress from day one;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has established high-level implementation
goals and a timeline for the transformation, but has not shared them
with all employees and stakeholders, a step that would help build
momentum and illustrate progress.
Key practice: 5. Dedicate an implementation team to manage the
transformation process and involve key stakeholders;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has dedicated an implementation team to
manage the transformation and involved stakeholders on an as-needed
basis; however, its Federal Stakeholder Advisory Board has not yet
convened.
Key practice: 6. Use the performance management system to define
responsibility and assure accountability for change;
Fully addressed: [Empty];
Partially addressed: [Empty];
Not addressed: Check;
Summary of findings: USCIS is not using its performance management
system to define expectations and hold employees accountable for the
transformation.
Key practice: 7. Establish a communication strategy to create shared
expectations and report related progress;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has completed an initial communication
strategy and begun exchanging information with employees and
stakeholders. However, the strategy for 2008 and beyond is not clearly
defined, and lacks an effective approach for communicating with
stakeholders.
Key practice: 8. Involve employees to obtain their ideas and gain
ownership for the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: transformation, and is planning for additional
involvement as the transformation progresses.
Key practice: 9. Build a world-class organization using leading
practices in strategic human capital management, performance
measurement, and IT management;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS is conducting benchmarking research to
identify leading business processes but its plans do not adequately
consider IT management controls, strategic human capital management,
and performance measurement to build a world-class organization.
[End of table]
USCIS plans provide some information on transformation costs and
revenues, but according to USCIS, the cost estimates remain uncertain.
In addition, plans do not sufficiently address enterprise architecture
alignment and expected project performance.
Congressionally requested: 1. All resources associated with
transformation efforts (appropriations and fees), including a detailed
breakout of coss for fiscal year 2007, and the impact of availability
of fee revenue;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS‘ Expenditure Plan indicates that
the transformation will cost up to $536 million through 2013. However,
USCIS expects costs to be lower, since its estimates were based on a
higher-cost acquisitions approach”an approach the agency is not
pursuing. Available resources for the transformation include $81.6
million appropriated in fiscal years 2006 and 2007, and $463.9 million
in fee revenues beginning in fiscal year 2007. While the plan does not
detail the impact of availability of fee revenue overall, it does state
that estimated fee support for fiscal year 2007 will be $12 million
below initial budget estimates. The $12 million will be used to fund
core operations instead. However, USCIS believes the level of fee
revenue currently projected will be sufficient to support
transformation programs.
Congressionally requested: 2. Information on the alignment of the
transformation process with DHS' enterprise architecture;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS' approach to aligning its
transformation to the DHS EA is to (1) develop its own EA that is
aligned to the DHS EA and to use its EA to guide IT modernization
decision making and (2) comply with the DHS process for aligning
programs to the DHS EA. USCIS has begun developing aspects of an EA,
but much remains to be done. It is following DHS‘ process for aligning
programs to the DHS EA. However, we have reported this process is
limited because it does not include criteria or a methodology for
determining alignment.
Congressionally requested: 3. Details on expected project performance
and deliverable;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS provides a high-level discussion
of expected deliverables and performance capabilities, such as
providing a work environment that promotes success. However, plans do
not include clear and measurable performance measures and targets for
transformation projects or for the transformed agency.
[End of table]
We are recommending that USCIS address the gaps in its transformation
plans by making improvements to performance measurement, strategic
human capital management, communications, and information technology
management.
We provided a draft of this briefing to the Director of USCIS for
review. USCIS provided written comments on June 25, 2007, which are
presented in their entirety in enclosure II. In its comments, USCIS
generally agreed with our findings and recommendations. The letter also
discusses activities the agency has planned to address each
recommendation.
Background:
The agency outlined its overall transformation strategy in its
Transformation Program Strategic Plan and 2007 Expenditure Plan. These
primary documents are supported by numerous other planning documents,
including:
* Mission Needs Statement;
* Program Management Plan;
* Governance Plan;
* Change Management Plan;
* Acquisition Plan;
* Concept of Operations.
The objectives of the transformation are to transition from paper
intensive, forms-centric processes to electronic, customer-centric
processes. The new processes are intended to enhance national security,
improve customer service, and increase operational efficiency by:
* Increasing ability to share data with immigration partners,
* Uniquely identifying individuals,
* Creating customer accounts, and:
* Implementing a single worldwide case management system.
USCIS' approach is to transform in phases called "increments". For each
increment, USCIS plans to develop and implement the technologies and
business processes needed to produce major categories of benefits.
* By transforming in increments, USCIS intends to take advantage of
lessons learned, to gradually transition agency operations into the new
business model, and to avoid the pitfalls associated with a large
transformation being implemented all at once.
Increment/Line of business: Increment 1 - Citizenship;
Benefit types: Naturalization, Military naturalization, International
adoption.
Increment/Line of business: Increment 2 - Immigrant;
Benefit types: Permanent residence.
Increment/Line of business: Increment 3 - Humanitarian;
Benefit types: Refugee, Asylum, Temporary protected status.
Increment/Line of business: Increment 4 - Nonimmigrant;
Benefit types: Nonimmigrant Worker.
[End of table]
* During the first increment, USCIS intends to develop its common
business capabilities such as account setup, workflow management, and
digitization of records that will 1) result in a redesigned business
process specific to citizenship, 2) provide immediate value for the
other lines of business, and 3) provide core services for future
increments.
Before implementing the first increment, USCIS plans to identify and
test the key technologies and other capabilities needed to support the
overall transformation using four pilot projects:
* Two of these pilots involve testing the agency's capacity to assign a
unique number to each applicant that is linked to a set of fingerprint
and other biographic data, and to store and retrieve this information
(Enumeration and Biometrics Storage System).
* A third pilot involves converting paper immigration records to an
electronic format, and housing them in a single repository where they
can be searched and retrieved (Digitization).
* A fourth pilot is a "proof of concept", which uses the international
adoption process to demonstrate the processing capability of the case
management system and verify that this system can be used to view
digitized files.
USCIS initially considered an acquisition approach in which USCIS would
select a single Systems Integrator to manage a long-term partnership of
vendors that would build and integrate the required capabilities. The
Systems Integrator would propose ownership and operating strategies
based on the individual service being performed.
* For example, a given service could be government-owned/contractor-
operated (GOCO), where TPO management maintains primary responsibility
for developing and deploying the increments and employs contract staff
to perform noncore functions, such as intake and document issuance.
Alternatively, the service could be contractor-owned/contractor-
operated or fully privatized.
USCIS is now considering acquiring services through a competitive
subcontracting process to support the transformed work process.*:
* In this proposal, each service would be procured separately,
integrated, and deployed in an incremental fashion.
* USCIS would determine an appropriate ownership and operating strategy
for each service as part of the procurement process.
* GAO has not assessed USCIS' proposed acquisitions strategy. However,
we have previously identified practices and underlying critical success
factors that provide the basis for an effective IT outsourcing process
(see GAO-02-214 and GAO-03-371).
According to the Expenditure Plan and agency officials, fiscal year
2006 transformation activities were funded by direct appropriation.
In fiscal year 2007, USCIS plans on using a combination of appropriated
funds ($47 million) and fee revenue ($53 million) to support the
transformation.
* To date, USCCS has not obligated or expended any fiscal year 2007
budget authority, according to agency officials.
Beginning in fiscal year 2008, USCIS intends to allocate revenue
derived from premium processing fees to the transformation; these fees
are paid by certain customers in exchange for expedited processing and
improved access to customer service.*:
* According to the Expenditure Plan, the agency is not planning to
request appropriated funds for the transformation in fiscal year 2008
or beyond.
In its Expenditure Plan, USCIS estimates that the agency will take in
$139 million in premium processing fees in fiscal year 2008, and
between $64 and $71 million for each of the next 4 fiscal years.
USCIS has estimated total transformation costs to be approximately $536
million from fiscal year 2006 through fiscal year 2012. However, these
estimates were based on a GOCO approach to acquisitions-an approach the
agency is not pursuing.
Because USCIS is still considering its acquisitions approach, these
figures are subject to change. According to USCIS, the estimated $536
million is the maximum amount the agency expects to spend on the
transformation during this time period.
* The fee for the premium processing service is set by regulation at
$1,000. 8 C.F.R § 103.7 (b) The regulations governing the service are
found at 8 C.F.R. § 103.2(f).
* USCIS established its current Transformation Program in February 2006
with the creation of the Transformation Program Office (TPO).
[See PDF for image]
[End of figure]
Objective 1:
USCIS' plans and subsidiary plans partially or fully address most key
practices for organizational transformations.
Key practice: 1. Ensure top leadership drives the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has taken several actions to ensure top
leadership drives the transformation, such as establishing a
Transformation Program Office that directly reports to the USCIS Deputy
Director.
Key practice: 2. Establish a coherent mission and integrated strategic
goals to guide the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has established a mission, vision, and
strategic goals in its Strategic Plan that could be used to guide the
transformation.
Key practice: 3. Focus on a key set of principles and priorities at the
outset of the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has identified priorities and a succinct set
of core values with which to guide the transformation and help build a
new agencywide culture.
Key practice: 4. Set implementation goals and a timeline to build
momentum and show progress from day one;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has established high-level implementation
goals and a timeline for the transformation, but has not shared them
with all employees and stakeholders, a step that would help build
momentum and illustrate progress.
Key practice: 5. Dedicate an implementation team to manage the
transformation process and involve key stakeholder;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has dedicated an implementation team to
manage the transformation and involved stakeholders on an as-needed
basis; however, its Federal Stakeholder Advisory Board has not yet
convened.
Key practice: 6. Use the performance management system to define
responsibility and assure accountability for change;
Fully addressed: [Empty];
Partially addressed: [Empty];
Not addressed: Check;
Summary of findings: USCIS is not using its performance management
system to define expectations and hold employees accountable for the
transformation.
Key practice: 7. Establish a communicate strategy to create shared
expectations and report related progress;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS has completed an initial communication
strategy and begun exchanging information with employees and
stakeholders. However, the strategy for 2008 and beyond is not clearly
defined, and lacks an effective approach for communicating with
stakeholders.
Key practice: 8. Involve employees to obtain their ideas and gain
ownership for the transformation;
Fully addressed: Check;
Partially addressed: [Empty];
Not addressed: [Empty];
Summary of findings: USCIS has taken several steps to involve employees
in the transformation, and is planning for additional involvement as
the transformation progresses.
Key practice: 9. Build a world-class organization using leading
practices in strategic human capital management, performance
measurement, and IT management;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Summary of findings: USCIS is conducting benchmarking research to
identify leading business processes but its plans do not adequately
consider IT management controls, strategic human capital management,
and performance measurement to build a world-class organization.
[End of table]
Practice 1. Ensure top leadership drives the transformation:
Actions Planned or Taken:
USCIS has established the TPO with an allocation of 20 full-time
employees to oversee and manage the transformation.
* In contrast to earlier reform efforts, the TPO was established as a
direct report to the USCIS Deputy Director rather than placing the
program within a USCIS office.
USCIS has also dedicated financial resources, such as fee revenues
derived from premium processing, to support and fund transformation
activities.
USCIS created a Transformation Leadership Team, which is the primary
decision-making body for the program. This team includes the USCIS
Deputy Director, Chief of Staff, Chief Counsel, Chief of TPO, Chief
Financial Officer, Chief Information Officer, and the Associate
Director for each of the agency's three Directorates.
In April 2006, the USCIS Director communicated his commitment to the
transformation in his first message to the agency.
Practice 2. Establish a coherent mission and integrated strategic goals
to guide the transformation:
Actions Planned or Taken:
The USCIS strategic plan established a mission and vision that could be
used to guide the transformation:
* Mission: U.S. Citizenship and Immigration Services will secure
America's promise as a nation of Immigrants by providing accurate and
useful information to our customers, granting immigration and
citizenship benefits, promoting an awareness and understanding of
citizenship, and ensuring the integrity of our immigration system.
* Vision: U.S. Citizenship and Immigration Services will strengthen
America's future by becoming a customer-focused innovator of benefits
processing, a catalyst for citizenship, education, instruction and
outreach, a recognized and credible source of useful information, and
leading contributor to the security of the United States.
The Transformation Office Strategic Plan also established strategic
goals for the transformation that are aligned with the strategic goals
of USCIS and DHS.
[See PDF for image]
Source: USCIS Transformation Program Strategic Plan:
[End of figure]
Practice 3. Focus on a key set of principles and priorities at the
outset of the transformation:
Actions Planned or Taken:
USCIS has identified a set of 10 principles to guide internal decision
making throughout the course of the transformation:
1. Primacy of Purpose;
2. Strategic Business Focus;
3. Compliance with Legislative Mandates;
4. Interoperability;
5. Maximum Benefit;
6; Comprehensive Communication and Collaboration.
7; Efficient Data Collection, Storage, and Access.
8; Security-in-Depth.
9; Privacy.
10; Customization.
USCIS has also identified a set of priorities for the transformation,
including national security, customer service, and operational
efficiency. These priorities help to define the mission of the TPO and
are reflected in the strategic goals for the transformation.
Finally, the USCIS Strategic Plan lists and defines three core values:
Integrity, Respect, and Ingenuity. These values can help build the new
culture of the agency and to serve as an anchor as personnel, programs,
and processes change.
Practice 4. Set implementation goals and a timeline to build momentum
and show progress from day one:
Actions Planned or Taken:
USCIS has set some implementation goals (key events) for the
transformation.
Table: USCIS Transformation Key Events*:
Milestone: DHS Funding Authorization**;
Description: DHS authorized USCIS expenditure of FY06 appropriated
funds on planning and pilot projects;
Date: Q3FY06.
Milestone: Conduct and evaluate initial increments;
Description: Design, develop, implement initial pilots to a) test and
evaluate revised business processes and technology solutions, b)
support life cycle cost estimation and planning for implementation;
Date: Q1FY07-Q3FY07.
Milestone: Investment review board approval**;
Description: Obtain DHS Alternative Selection Milestone approval with
focus on acquisition program baseline;
Date: Q2FY07.
Milestone: Finalize Increment 1 Components;
Description: Finalize business requirements and design of business
processes for first increment;
Date: Q3FY07.
Milestone: Increment 1 Development and Change Management;
Description: Design, develop and test increment 1. Conduct change
management, communications, and training;
Date: Q1FY08-Q4FY08.
Milestone: Implement Increment 1;
Description: USCIS customers will begin electronic filing of selected
benefits and establishment of accounts. USCIS staff will begin
utilizing the electronic case file;
Date: Q1FY09-Q2FY09.
Milestone: Finalize remaining increments;
Description: develop detailed planning documents for subsequent
increments based on experiences of Increment 1;
Date: Q3FY09-Q4FY09.
Milestone: Increment 2 Development and Change Management;
Description: Design, develop, and test Increment 2. Conduct change
management, communications, and training;
Date: Q1FY10-Q2FY10.
Milestone: Implement Increment 2;
Description: Expand electronic filing of additional benefits;
Date: Q3FY10-Q4FY10.
Milestone: Increment 3 Development and Change Management;
Description: Design, develop and test Increment 3. Conduct change
management, communications, and training;
Date: Q1FY11-Q4FY11.
Milestone: Implement Increment 3;
Description: Expand electronic filing of additional benefits;
Date: Q1FY12-Q2FY12.
Milestone: Additional increments as needed;
Description: Ongoing identification, development, and change
management, and implementation of additional increments;
Date: TBD.
Source: USCIS Transformation Program Management Plan.
* USCIS has noted that dates may shift due to fluctuations in
priorities, resources, or nationally critical initiatives.
** According to DHS documentation. this key event has already occurred.
[End of table]
Practice 4. Set implementation goals and a timeline to build momentum
and show progress from day one:
Actions Planned or Taken:
* USCIS has created a timeline for the transformation. Timelines have
also been developed for each of the pilot projects.
Figure: USCIS Transformation Timeline:
[See PDF for image]
Source: Timeline provided by USCIS officials:
[End of figure]
USCIS has shared these timelines with upper-level management and union
leadership through field office presentations conducted by TPO.
Gaps or Limitations:
USCIS has not finalized plans to communicate its implementation goals
and timelines to all employees and relevant stakeholders, to show that
progress is being achieved and to differentiate this transformation
effort from past modernization efforts.
* USCIS officials said that they were waiting for funding approval to
solidify timelines and communicate to employees about key milestone
dates.
* USCIS' lack of a long-term, comprehensive communication strategy is
discussed in further detail under Practice 7.
A transformation is a substantial commitment that can take years to
complete. As a result, agencies should demonstrate progress towards
transformation goals and communicate this progress to interested
parties and stakeholders. Demonstrating progress towards transformation
goals helps to build momentum within the agency, thereby helping to
ensure the transformation's successful completion.
Impact:
If USCIS is not able to demonstrate incremental progress towards its
key transformation goals, the agency runs the risk of losing momentum
and employee buy-in.
Practice 5. Dedicate an implementation team to manage the
transformation process and involve key stakeholders:
Actions Planned or Taken:
The TPO provides a centralized management structure to oversee all
transformation initiatives within USCIS.
Within TPO, an Increment Division is to manage the development and
implementation of each increment.
* Each increment is to be led by an Integrated Project Team (IPT) under
the leadership of an Increment Manager.
* The Increment Manager is to be supported by Business, Information
Technology (IT), and Change Management Leads.
* The responsibilities of the IPT include:
- Developing a project management plan for each increment to establish
the scope, expectations, and management processes, and to identify the
roles of I PT members.
- Developing the work breakdown structure, cost estimates, and
performance measures for the increment.
In addition, USCIS has engaged external stakeholders to discuss
transformation plans on an as-needed basis.
* USCIS has met with federal agency stakeholders, including US-VISIT,
Immigration and Customs Enforcement (ICE), Customs and Border
Protection (CBP), and the U.S. Department of State (DOS).
- For example, USCIS and DOS signed a Memorandum of Understanding (MOU)
in May 2006. The MOU is intended to enable these agencies to more
efficiently share information critical to national security through
shared access to each others' systems.
* USCIS has also involved customers and their advocates as
stakeholders.
- For example, in April 2007 the TPO Chief participated in a federal
panel to discuss the Inter-Country Adoptions proof of concept at the
Joint Council for International Children's Services Conference.
According to USCIS plans, a Federal Stakeholder Advisory Board is to
advise on planning and implementation efforts. The board is to include
CBP, ICE, US-VISIT, DOJ, DOS, U.S. Department of Labor, U.S. Department
of Treasury, the Social Security Administration, and the Office of
Management and Budget.
* USCIS has drafted a charter for the board.
Gaps or Limitations:
To date, the Federal Stakeholder Advisory Board has not convened.
* TPO officials told us that they plan to involve the board once the
transformation plans are approved by DHS and the Office of Management
and Budget.
Successful transformation requires the collaboration of not only the
separate components of the agency, but of the agency's business
partners as well. Engaging customers and key stakeholders is central to
forming the partnerships that are needed to develop and implement the
organization's strategies.
Impact:
Without adequate involvement from stakeholders and customers, USCIS
risks developing or purchasing systems that are not aligned with the
strategic direction, priorities, and resources of stakeholder
operations and do not meet customer needs.
By only involving stakeholders on an as-needed basis, USCIS limits
stakeholders' opportunities to identify issues and mitigation
strategies early in the process. Further, the current approach only
allows for USCIS to determine when stakeholders need to be involved,
rather than allowing stakeholders to identify when their input is
needed.
Practice 6. Use the performance management system to define
responsibility and assure accountability for change:
Actions Planned or Taken:
According to agency officials, TPO officials and selected USCIS senior
executives have performance work plans that include expectations
related to the transformation.
Gaps or Limitations:
The performance work plans have not yet been used to formally evaluate
performance.
* TPO leadership told us they used informal methods to hold employees
accountable for the transformation, such as discussions at weekly team
meetings.
* Note: In their comments, USCIS indicated that the TPO conducted mid-
year evaluations for staff in June, 2007 (see appendix 3).
Further, the agency's plans do not discuss the development of
transformation-related performance expectations for employees
throughout USCIS.
An agency's performance management system can be a vital tool for
aligning employees with desired results and creating a "line of sight"
showing how team, unit, and individual performance can contribute to
overall organizational results.
To be successful, transformation efforts must have leaders, managers,
and employees who have the individual competencies to integrate and
create synergy among the multiple organizations involved in the
transformation effort.
Individual performance and contributions can be evaluated on
transformation-related competencies such as change management, cultural
sensitivity, teamwork and collaboration, and information sharing.
Impact:
By not establishing transformation-related performance expectations for
its employees, USCIS will be hampered in its ability to hold executives
and other employees accountable for achieving the goals of the
transformation.
Practice 7. Establish a communication strategy to create shared
expectations and report related progress:
Actions Planned or Taken:
According to agency officials, USCIS has:
* Established a Change Management Division (CMD) within TPO, which is
responsible for managing the messages and communications that are
distributed to the various TPO stakeholders.
* Completed an initial Communication Strategy to guide communications
efforts.
* Created communication planning documents that cover three of the four
pilot projects, which are underway and scheduled to be implemented and
evaluated by the end of 2007.
- According to USCIS officials, the communications plan for the
Biometric Storage System pilot will be completed by August 15, 2007.
* Solicited a contractor to provide recommendations for future change
management planning. According to officials, this study will be used to
identify change management and training needs.
* Begun to communicate to staff regarding the transformation through
activities such as: * Sending electronic newsletters:
- Visiting field offices and conducting presentations:
- Launching a transformation intranet site:
- Conducting focus groups with employees:
* Identified additional communication tools to be used in the future,
such as a survey tool, points of contact embedded in the field, and
"frequently asked questions" documents.
Union officials told us that they have seen unprecedented attention to
change management during this transformation compared to previous
modernization efforts.
Gaps or Limitations:
USCIS' Communications Strategy has several limitations:
* Few planned activities in the strategy extend past the current fiscal
year. In addition, the timing of certain activities is vague, and some
activities are behind schedule.
* The strategy does not offer an effective approach to engage
government partners and stakeholders. Plans are not tailored to the
needs of individual partners and stakeholders, and do not contain a
sufficient level of detail to guide future communications.
The CMD Division is not fully staffed-two of the five CMD positions are
vacant.
Union officials we spoke with said that communicating to employees was
the most important issue that needed to be addressed for a successful
transformation and indicated that additional agencywide communications
about the transformation were needed.
* According to these officials, in some service centers employees were
given limited time to obtain and review agency communications and may
need additional opportunities to learn about the transformation.
Communication is key to the success of any organizational
transformation. We have found that the time spent on delivering
messages to employees about a transformation should not be
underestimated. To that end, creating an effective, on-going
communication strategy is essential. A comprehensive communication
strategy:
* reaches out to employees, customers, and stakeholders and seeks to
genuinely engage them in the transformation process, *ensures
consistency of message,
* encourages two-way communication, and:
* provides information early and to meet specific needs of employees.
An effective communication strategy can help USCIS build trust and
diminish uncertainty among employees, resulting in increased support
for the transformation.
Impact:
Without an effective communication strategy, USCIS risks undermining
support for the transformation by creating uncertainty and mistrust
among employees about the changes.
Practice 8. Involve employees to obtain their ideas and gain ownership
for the transformation:
Actions Planned or Taken:
USCIS conducted 71 focus groups and 9 individual interviews with staff
from its Field Offices, Regional Offices, District Offices, Asylum
Offices, and Service Centers to obtain feedback on the transformation,
information on change management issues, and provide a forum to hear
concerns.
* According to agency officials, information gathered from focus groups
will be used to create feedback surveys and to develop messages and web
page content.
USCIS assigned a union representative to the TPO.
* The union representative noted that this arrangement has resulted in
a new and better way for management and the union to work together
outside of traditional bargaining, and has saved both time and
resources.
* TPO officials agree that they have benefited from the union's
participation in TPO, which has enabled TPO to resolve issues before
they become major problems.
* In addition, officials stated that the collaboration has enabled TPO
to identify 85 field employees to serve as points of contact for the
transformation.
According to officials, USCIS is engaging employees in work process
flow documentation and validation.
* Through Integrated Project Teams, field staff have been requested to
serve as members, subject matter experts for working groups, and pilot
testers.
USCIS plans further involvement, including:
* Holding conference calls with pilot participants in order to gather
feedback on the new systems and identify training needs.
* Identifying managers and supervisors as Change Champions, who will
assume ownership of the change effort within their offices.
* Using nonmanagerial Points of Contact in designated offices to help
organize conference calls, distribute information, and forward employee
feedback to TPO.
* Constructing and disseminating a readiness survey to monitor employee
attitudes regarding the transformation.
Practice 9. Build a world-class organization:
Summary:
In previous reports, GAO has outlined a number of leading practices
that high-performing public and private sector organizations have used
to successfully achieve their performance goals and objectives.
USCIS has made efforts to adopt some of these leading practices:
* USCIS has participated in benchmarking to identify other public and
private sector organizations processes, practices, and systems that can
provide a model for reform.
* In addition, USCIS' transformation strategy discusses plans for
addressing some of the range of IT management controls required by a
large-scale IT modernization effort.
However, USCIS' planning efforts do not adequately incorporate other
important practices:
* USCIS' plans do not consider strategic workforce planning.
* USCIS has not developed clear and measurable performance measures and
targets for the transformed agency to show progress towards the goals
in its Strategic Plan.
* USCIS officials have stated that they are still in the early stages
of developing an enterprise architecture (EA) to help inform future
business and technology decisions.
Benchmarking:
Actions Planned or Taken:
USCIS is conducting mission-and technology-related benchmarking and
best practice reviews across comparable commercial and governmental
organizations, including:
* Canadian Citizenship and Immigration Services:
* The Australian Department of Immigration and Multicultural Affairs:
* The Internal Revenue Service's Earned Income Tax Program:
* Nationwide Insurance:
* Toyota Financial Services:
Strategic Workforce Planning:
Gaps or Limitations:
USCIS' transformation plans do not consider strategic workforce
planning.
Strategic human capital management is the centerpiece of an
organization's efforts to transform. Strategic workforce planning, an
integral part of human capital management, helps ensure that an
organization has the staff with the necessary skills and competencies
to accomplish its future strategic goals.
USCIS has neither planned for the critical skills and competencies that
will be needed to achieve future programmatic results nor developed
strategies to address gaps in employee numbers, deployment, and skills
and competencies.
* Additionally, USCIS has not planned for the resources and skills it
will need in TPO to manage the transformation over time.
* USCIS' plans do not address its ability to obtain or develop the IT
human capital with the appropriate skills and competencies to manage a
large-scale technology modernization effort.
- Currently, there is a significant shortage of IT personnel in the
Office of Information Technology (OIT). OIT has 150 authorized
positions, of which 23 are unfilled.
- The Chief of the Enterprise Architecture Division is acting and all
five positions in the Division are vacant.
- Officials we spoke to indicated that having adequate IT personnel to
support the transformation was a key to success and the lack of
adequate IT support was causing delays.
USCIS has not planned for ensuring continuity in key transformation
leadership positions and addressing impacts to time frames when key
personnel leave.
* At USCIS, past and present fluctuations in agency leadership involved
with the transformation have made it difficult to maintain continuity
and momentum.
* TPO currently has 4 vacancies (out of a total of 21 positions), and
one division chief is acting.
* Further, a number of other high-level positions at USCIS are recent
appointments, including the Chief Human Capital Officer and Chief
Strategist.
Leadership is essential to providing the accountable, committed,
consistent, and sustained attention needed to address human capital and
related organization transformation issues.
TPO has not established or planned for establishing formal
communication and coordination with the Office of Human Capital (OHC).
* There has been limited coordination between the TPO and OHC. Also,
the Chief Human Capital Officer is not formally involved in
transformation leadership activities.
* OHC is working on its own change initiatives, such as restructuring
the training function and conducting a skills gap analysis. OHC
officials noted that these initiatives must be aligned with the
transformation to avoid duplicative or contradictory efforts.
* Officials from OHC expressed an interest in being more involved in
TPO activities.
* TPO officials acknowledge that eventually there must be increased
coordination between the two offices to ensure that human capital
issues are properly considered.
Impact:
Without a strategy to address these important human capital issues,
USCIS risks:
* Lacking critical talent within TPO and OF necessary to support a
successful transformation;
* Modernizing its technology without developing a workforce that has
the right people with the right skills in the right place to use new
technologies to achieve the objectives of the transformation;
* Losing momentum and support for the transformation; and:
* Developing contradictory or duplicative solutions.
Measuring Performance:
Actions Planned or Taken:
In the Expenditure Plan, USCIS lists capabilities expected from the
transformation program:
* Minimize the burden to customers interacting with the agency.
* Inform customers in a manner most likely to result in understanding
and appropriate action.
* Provide benefits, quickly, consistently, and accurately to those who
are entitled.
* Deliver an open and transparent work environment.
* Enable managers to match work and resources on a needs basis.
* Provide a work environment that promotes success.
* Increase security by accurately identifying individuals at each
interaction with USCIS.
* Increase security by timely sharing of data with partner agencies.
* Improve immigration benefits system integrity by standardizing
processes and systems throughout the agency.
* Improve immigration system integrity by cultivating a culture that
respects and protects privacy.
* Improve ability to detect and investigate fraudulent activity through
improved tools and data access.
In addition, USCIS is developing a Performance Measurement Plan that
describes TPO performance measurement methodologies, presents draft TPO
measures, and defines roles and responsibilities.
However, it is unclear the extent to which TPO will be involved in the
development of performance measures going forward. For example, the
agency has stipulated in its draft Statement of Objectives that bidding
contractors should provide a Quality Assurance and Surveillance Plan
that includes performance goals and acceptable quality levels. This
plan will be part of the contract that TPO ultimately awards.
Gaps or Limitations:
While USCIS has developed some measures related to the transformation,
the draft Performance Measurement Plan does not have targets associated
with these measures.
In addition, many of the measures are ill-defined or difficult to
evaluate.
* For example, one measure in the plan is "Quality of IDDMP data."
Measuring performance allows organizations to track the progress they
are making toward their goals and gives managers crucial information on
which to base their organizational and management decisions. Leading
organizations recognize that performance measures can create powerful
incentives to influence organizational and individual behavior.
Successful performance measures are results-oriented, objective,
reliable, balanced, limited to the vital-few, measurable, and aligned
with organizational goals.
Impact:
Without articulating clear performance measures and targets, USCIS
risks developing or selecting new business processes and systems/
services that will not achieve the goals of the transformation.
Actions Planned or Taken:
USCIS' transformation strategy describes some of the range of IT
management controls required by a large-scale IT modernization effort,
such as risk management, quality management, configuration management,
and earned value management, among others.
* Note: GAO did not evaluate the quality of these controls.
Gaps or Limitations:
According to agency officials, USCIS is early in the process of
developing an EA. For example, agency officials noted that work has
just begun on the service reference model and business reference model.
* This means that USCIS is proceeding with its transformation plans
without key elements of its EA.
The Chief of the EA Division is acting and all five positions in the
Division are vacant.
Our research and experience with federal agencies has shown that
executing modernization projects without sufficiently defined
enterprise architecture increases the chances of acquiring systems/
services that are duplicative, not well integrated, and do not provide
promised capabilities on time and within budget.
Impact:
It is important that USCIS have a well-defined EA that is aligned with
the DHS EA. Without such a context to provide a common frame of
reference to guide and constrain the transformation, USCIS risks
investing in programs and systems/services that are duplicative, are
not interoperable, and do not optimize mission operations for USCIS and
DHS.
Objective 2:
USCIS plans provide some information on transformation costs and
revenues, but according to USCIS, the cost estimates remain uncertain.
In addition, plans do not sufficiently address enterprise architecture
alignment and expected project performance.
Congressionally requested: 1. All resources associated with
transformation efforts (appropriations and fees), including a detailed
breakout of costs for fiscal year 2007, and the impact of availability
of fee revenue;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS‘ Expenditure Plan indicates that
the transformation will cost up to $536 million through 2013. However,
USCIS expects costs to be lower, since its estimates were based on a
higher-cost acquisitions approach”an approach the agency is not
pursuing. Available resources for the transformation include $81.6
million appropriated in fiscal years 2006 and 2007, and $463.9 million
in fee revenues beginning in fiscal year 2007. While the plan does not
detail the impact of availability of fee revenue overall, it does state
that estimated fee support for fiscal year 2007 will be $12 million
below initial budget estimates. The $12 million will be used to fund
core operations instead. However, USCIS believes the level of fee
revenue currently projected will be sufficient to support
transformation programs.
Congressionally requested: 2. Information on the alignment of the
transformation process with DHS‘s enterprise architecture;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS' approach to aligning its
transformation to the DHS EA is to (1) develop its own EA that is
aligned to the DHS EA and to use its EA to guide IT modernization
decision making and (2) comply with the DHS process for aligning
programs to the DHS EA. USCIS has begun developing aspects of an EA,
but much remains to be done. It is following DHS‘ process for aligning
programs to the DHS EA. However, we have reported this process is
limited because it does not include criteria or a methodology for
determining alignment.
Congressionally requested: 3. Details on expected project performance
and deliverables;
Fully addressed: [Empty];
Partially addressed: Check;
Not addressed: [Empty];
Information provided by USCIS: USCIS provides a high-level discussion
of expected deliverables and performance capabilities, such as
providing a work environment that promotes success. However, plans do
not include clear and measurable performance measures and targets for
transformation projects or for the transformed agency.
[End of table]
1. Resources associated with transformation efforts, including a
detailed breakout of costs for fiscal year 2007, and the impact of
availability of fee revenue.
The Expenditure Plan includes information on how resources will be
allocated across components of the transformation in fiscal year 2007:
Transformation component: Planning;
Prior year carryover: 0;
FY 07 funding*: $23.0.
Transformation component: Operations and Maintenance;
Prior year carryover: 0;
FY 07 funding*: $19.3.
Transformation component: Increment On Development Cost for IT
Services;
Prior year carryover: 0;
FY 07 funding*: $45.8.
Transformation component: Security;
Prior year carryover: 0;
FY 07 funding*: $7.9.
Transformation component: Management Reserve;
Prior year carryover: 0;
FY 07 funding*: $4.0.
Transformation component: Total;
Prior year carryover: 0;
FY 07 funding*: $100.0.
* Dollars in millions:
[End of table]
In fiscal year 2007, USCIS reported having $100 million in budget
authority, available until expended, for the business transformation.
This amount includes $47 million appropriated in the 2007 DHS
Appropriations Act and $53 million from fee collections.
The Expenditure Plan discusses the impact of availability of fee
revenue for fiscal year 2007.
* According to the Expenditure Plan, USCIS revised estimated fee
support for fiscal year 2007 transformation activities from $65 million
to $53 million and will use the excess revenue to fund its core
operations. USCIS considers this level of support to be sufficient.
* Agency officials did not express concern that fee revenues would fall
short of projections in fiscal year 2007 or beyond.
The Expenditure Plan also includes information on total resources to be
directed towards transformation efforts, including a more detailed
breakout of costs for fiscal year 2007.
Planning.
Program Management;
FY06: $5.85;
FY07: $11;
FY08: $10.2;
FY09: $4.3;
FY10: $4.3;
FY11: $4.3;
FY12: $4.3;
Total: [Empty].
Change management;
FY06: 1.5;
FY07: 6;
FY08: 4.4;
FY09: 1.8;
FY10: 1.8;
FY11: 1.8;
FY12: 1.8;
Total: [Empty].
Reengineering/Requirements/Enterprise Architecture;
FY06: 1.5;
FY07: 4;
FY08: 4.4;
FY09: 1.8;
FY10: 1.8;
FY11: 1.8;
FY12: 1.8;
Total: [Empty].
Independent Verification and Validation;
FY06: 0;
FY07: 2;
FY08: 2.9;
FY09: 1.2;
FY10: 1.2;
FY11: 1.2;
FY12: 1.2;
Total: [Empty].
Acquisition and Implementation.
Secure Information Mgt. System;
FY06: 0;
FY07: 59.2;
FY08: 4.5;
FY09: 3.4;
FY10: 2.2;
FY11: 5.6;
FY12: 0;
Total: [Empty].
Scheduler;
FY06: 0;
FY07: 2.0;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Data warehouse;
FY06: 0;
FY07: 1.8;
FY08: 1.2;
FY09: .1;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Electronic filing/Prepopulation;
FY06: 0;
FY07: 4.0;
FY08: .1;
FY09: .6;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Knowledge Management;
FY06: 0;
FY07: 2.8;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Data Sharing/ESB;
FY06: 2.6;
FY07: 0;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Digitization;
FY06: 3.4;
FY07: 3.3;
FY08: 3.4;
FY09: 3.5;
FY10: 3.7;
FY11: .1;
FY12: 0;
Total: [Empty].
Enumeration;
FY06: 2.3;
FY07: 0;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Biometric Storage System;
FY06: 2.6;
FY07: 1.8;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Adoption;
FY06: 1.1;
FY07: 2.0;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0;
Total: [Empty].
Hardware and software;
FY06: 3.8;
FY07: 14.1;
FY08: 17.4;
FY09: 3.6;
FY10: 3.6;
FY11: 3.6;
FY12: 3.6;
Total: [Empty].
Operations and Maintenance;
FY06: 10.0;
FY07: 19.3;
FY08: 36.7;
FY09: 45.2;
FY10: 46.5;
FY11: 48.7;
FY12: 48.1;
Total: [Empty].
Security;
FY06: 0;
FY07: 7.9;
FY08: 3.3;
FY09: 3.3;
FY10: 3.3;
FY11: 3.3;
FY12: 3.3;
Total: [Empty].
Total;
FY06: 34.65;
FY07: 141.2;
FY08: 88.5;
FY09: 68.8;
FY10: 68.4;
FY11: 70.4;
FY12: 64.1;
Total: 536.05.
* Dollars in millions. Estimated program costs for amounted to $141.2
million, exceeding the $100 million in budget authority. However, not
anticipate a shortfall, because aspects of Increment 1 planned for FY07
will not be implemented until the end of FY08, when FY08 funds are
available.
[End of table]
The estimates above represent costs for IT services in a government-
owned, contractor-operated acquisitions approach. However, USCIS has
not yet finalized its acquisitions approach, and anticipates costs to
be lower.
According to a provision in USCIS' proposed new fee rule, starting in
fiscal year 2008 all premium processing fees will be dedicated to
USCIS' business transformation efforts.
* Agency officials indicated that USCIS does not intend to seek direct
appropriations for the transformation in fiscal year 2008 or beyond.
* In its Expenditure Plan, USCIS projects that fee revenue from premium
processing fees will equal costs beginning in fiscal year 2009.
Direct Appropriated;
FY06: 34.65;
FY07: 47.0;
FY08: 0;
FY09: 0;
FY10: 0;
FY11: 0;
FY12: 0.
Fee revenue;
FY06: 0;
FY07: 53.0;
FY08: 139.2;
FY09: 68.8;
FY10: 68.4;
FY11: 70.4;
FY12: 64.1.
Total;
FY06: 34.65;
FY07: 100.0;
FY08: 139.2;
FY09: 68.8;
FY10: 68.4;
FY11: 70.4;
FY12: 64.1.
* Dollars in millions:
[End of table]
However, in USCIS' Exhibit 300 form, submitted in September 2006, the
agency estimated that premium processing fees would amount to $139
million per year for fiscal years 2008 through 2011, and approximately
$151 million in fiscal year 2012.
In addition, data obtained from agency officials indicates that the
amount USCIS has collected in premium processing fees has historically
been much higher than the estimates given in the Expenditure Plan:
Amount USCIS collected in Premium Processing Fees;
FY02*: 111.0;
FY03: 159.7;
FY04: 201.5;
FY05: 139.1;
FY06: 160.0.
* Dollars in millions. Note: Fiscal year 2002 is the first full year
that USCIS was authorized to collect Premium Processing Fees.
[End of table]
* Officials have noted that premium processing fees are traditionally a
fairly stable revenue source.
USCIS estimates that the transformation may cost up to $501 million
from fiscal year 2007 to 2012. However, using USCIS' previous estimate
of annual premium processing fees ($139 million per year), the agency
could have available $834 million in funds for the transformation
during this same time period.
2. Alignment of the transformation process with DHS's GAO enterprise
architecture:
In addition to creating its own EA, USCIS' strategy for aligning the
transformation with DHS' EA involves following established departmental
processes.
The process involves submitting a number of alignment documents to the
DHS Enterprise Architecture Center of Excellence (EACOE), which is
responsible for ensuring architecture alignment reviews are conducted
during the investment review process.
The table below shows TPO's schedule for completing EA alignment
documents:
Enterprise Architecture Program Alignment Document: Program alignment
decision request package template;
Estimated Date: March 2007;
Date Submitted to EACOE*: April 2007.
Enterprise Architecture Program Alignment Document: Program alignment
matrix;
Estimated Date: March 2007 (updated in July/after solutions architect
selection);
Date Submitted to EACOE*: April 2007.
Enterprise Architecture Program Alignment Document: Program alignment
mapping to DHS OCIO Portfolios;
Estimated Date: March 2007;
Date Submitted to EACOE*: April 2007.
Enterprise Architecture Program Alignment Document: Program alignment
mapping to lines of business;
Estimated Date: March 2007;
Date Submitted to EACOE*: April 2007.
Enterprise Architecture Program Alignment Document: DHS Privacy Office
Privacy Threshold Analysis;
Estimated Date: March 2007;
Date Submitted to EACOE*: Not yet submitted.
Enterprise Architecture Program Alignment Document: Program alignment
data architecture mapping;
Estimated Date: July 2007;
Date Submitted to EACOE*: Not yet submitted.
Enterprise Architecture Program Alignment Document: EDMO Metadata
Management Criteria;
Estimated Date: After solutions architect selection;
Date Submitted to EACOE*: Not yet submitted.
Enterprise Architecture Program Alignment Document: Program alignment
mapping technology standards;
Estimated Date: After solutions architect selection;
Date Submitted to EACOE*: Not yet submitted.
Enterprise Architecture Program Alignment Document: Security activity
alignment;
Estimated Date: After solutions architect selection;
Date Submitted to EACOE*: Not yet submitted.
Enterprise Architecture Program Alignment Document: EACOE - Section 508
review Criteria and Instructions;
Estimated Date: After solutions architect selection;
Date Submitted to EACOE*: Not yet submitted.
* According to USCIS officials Source: USCIS Expenditure Plan:
[End of table]
GAO has not assessed the quality of these alignment activities and
documents.
However, we have previously reported that DHS' EA alignment process
lacks a methodology and criteria to judge programs' alignment with DHS'
architecture. We also recently reported that the DHS EA was missing
important content, thus limiting its completeness, consistency, and
usability. DHS has since issued a new version of its EA that it reports
addresses many of our concerns. We have not reviewed this latest
version.
Furthermore, USCIS' schedule does not indicate its plans for completing
performance-related documents.
* According to USCIS' Chief Information Officer, USCIS has just begun
work on a performance model.
* As stated previously, USCIS lacks clear and measurable performance
measures and targets for the transformed organization that could be
used to create such alignment.
According to federal guidance, agency enterprise architectures should
include key architectural elements, including a performance model.
Performance models are intended to provide a common set of general
performance outputs and measures for agencies to use to achieve
business goals.
Officials also stated that USCIS coordinates with several DHS EA
working groups. For example, it interacts with the Service Oriented
Architecture Tactical Focus Group, which is responsible for developing
a common DHS-wide methodology and standards for implementing service
provisioning.
Given that DHS' EA is incomplete and USCIS' EA is still in the early
stages, USCIS may encounter difficulties as it attempts to align its EA
to DHS' architecture. While USCIS is taking steps to follow DHS'
process for aligning transformation activities to the DHS EA, this
process has significant shortcomings. Because of these factors, USCIS
may face challenges as it attempts to modernize its systems in a way
that promotes interoperability, minimizes redundancy, and optimizes
mission performance.
3. Details on expected project performance and deliverables:
USCIS has not provided details on expected project performance in its
Transformation Program Strategic Plan or Expenditure Plan.
USCIS has a Project Management Plan for each pilot program, which
includes:
* Project schedule:
* Roles and responsibilities of project team:
* Associated deliverables:
However, as noted earlier, USCIS has not identified specific
performance measures and targets for the pilots or increments.
USCIS officials told us that expected project performance and
deliverables for Increment 1 are under development.
Conclusions:
USCIS is charged with providing immigration and citizenship services
and benefits, ensuring the integrity of the nation's immigration
system, and contributing to the nation's security. Further, USCIS faces
a significant increase in workload from proposed immigration reform
legislation. To accomplish this efficiently and effectively, USCIS must
transform from its current unreliable, inefficient, and paper-intensive
environment.
Organizational transformations require sustained commitment and
resources. USCIS has taken the first steps in addressing problems
identified with past efforts to modernize by demonstrating top
leadership commitment; dedicating people and resources to the
transformation; establishing a mission, vision, and integrated
strategic goals; focusing on a key set of priorities and defining core
values; establishing a timeline; and involving employees.
High-performing organizations have found that using performance
measures and targets can help track progress towards goals, provide
data to inform programmatic decisions, and create a results-oriented
culture within the transformed agency. USCIS has not established a
clear and measurable set of performance measures and targets for the
transformed agency.
Because people are an organization's most important asset, strategic
human capital management, including workforce planning, should be at
the centerpiece of any effort to transform government agencies.
Although some human capital planning is taking place at USCIS, it is
being done separately from planning for the transformation. Further,
USCIS has not outlined a strategy to address past and present
fluctuations in key transformation leadership positions.
An effective employee performance management system can be an important
strategic tool in driving internal change and achieving desired
results. USCIS has incorporated transformation-related expectations and
competencies into performance plans for TPO officials. However, USCIS
has not yet used these plans to formally evaluate employee performance,
and has not developed transformation-related performance expectations
and competencies for all of its executives and employees to hold them
accountable for achieving the goals of the transformation.
An important key for planning successful transformations is
communicating early and often to build trust among employees and
stakeholders and help them to understand upcoming changes. USCIS has
made efforts to communicate present and future transformation
activities, and has developed an overall Communication Strategy.
However, this strategy does not contain a clear, long-term approach for
the agency to share information over the course of the transformation,
and does not provide a detailed plan for meeting the specific needs of
government stakeholders.
It is important that USCIS acquire IT systems and services in a way
that employs leading IT management practices, such as those embodied in
federal guidance that we and others have issued relative to enterprise
architecture management, IT systems development and acquisition, and IT
services acquisition. By doing so, USCIS can better ensure that its
system and service modernization projects perform as intended, are
delivered on time and within budget, and otherwise support optimal
agency mission performance. Thus far, its architecture management
efforts fall short of such practices in that the USCIS architecture
lacks, among other things, a performance component. Further, while
USCIS is following established departmental processes for aligning its
transformation program with the DHS enterprise architecture, these
processes are limited because they do not include explicit alignment
criteria and an associated methodology, and because the DHS enterprise
architecture is not yet sufficiently complete.
Recommendations for Executive Action:
To improve its transformation strategy and fully address
congressionally requested information, we recommend that the Secretary
of Homeland Security direct the Director of USCIS to:
* Document specific performance measures and targets for the pilots,
increments, and the transformed organization that are outcome-oriented,
objective, reliable, balanced, limited to the vital-few, measurable,
and aligned with organizational goals.
* Increase USCIS' focus on strategic human capital management for the
transformation, including:
- Increasing coordination between TPO and OHC to ensure transformation
and human capital change initiatives are aligned.
- Planning for the number and types of human resources required in TPO
to carry the transformation through 2012.
- Planning for obtaining and developing the IT human capital necessary
to support the transformation.
- Determining the critical skills and competencies that will be needed
to achieve future programmatic results as well as strategies to address
gaps in employee numbers, deployment, and skills and competencies.
- Addressing continuity in key transformation leadership positions and
addressing impacts to time frames when key personnel leave.
- Use performance expectations and competencies to hold USCIS
executives and employees accountable for achieving the goals of the
transformation.
Complete a comprehensive communication strategy that involves
communicating early and often to build trust, ensuring consistency of
message, and encouraging two-way communication. Further, the
communication strategy should address:
* Plans for communicating implementation goals and timelines to
demonstrate progress.
* Plans for formally engaging internal and external stakeholders
throughout the transformation, and tailoring information to meet these
stakeholders' specific needs.
* Plans for a long-term, detailed strategy to share information with
employees and stakeholders over the course of the transformation.
Continue to develop an enterprise architecture that sufficiently guides
and constrains the transformation plans, as DHS works to address
limitations in its own enterprise architecture and alignment processes.
Appendix 1: Description of Key Practices for Organizational
Transformations:
Practice: 1. Ensure top leadership drives the transformation;
Description: Leadership must set the direction, pace, and tone and
provide a clear, consistent rationale that brings everyone together
behind a single mission.
Practice: 2. Establish a coherent mission and integrated strategic
goals to guide the transformation;
Description: A clear mission and strategic goals must become the focus
of the transformation, define the culture, and serve as a vehicle for
employees, customers, and stakeholders to rally around. Further,
effective implementation of this practice includes adopting leading
practices for results-oriented strategic planning and reporting, such
as establishing specific, measurable, outcome-oriented performance
measures for the transformed organization.
Practice: 3. Focus on a key set of principles and priorities at the
outset of the transformation;
Description: A clear set of principles and priorities serves as a
framework to help the agency create a new culture and drive employee
behaviors. Principles are the core values of the transformed
organization and remain valid and enduring while organizations,
personnel, programs, and processes may change.
Practice: 4. Set implementation goals and a timeline to build momentum
and show progress from day one;
Description: It is essential to track implementation goals and
establish a timeline to pinpoint performance shortfalls and suggest
midcourse corrections. Also, by demonstrating progress towards
transformation goals, the agency builds momentum.
Practice: 5. Dedicate an implementation team to manage the
transformation process and involve key stakeholders;
Description: Dedicating a strong and stable implementation team that
will be responsible for the transformation‘s day-to-day managements is
important to ensuring that it receives the focused, full-time attention
needed to be sustained and successful.
Practice: 6. Use the performance management system to define
responsibility and assure accountability for change;
Description: A performance management system can be a vital tool for
aligning the organization with desired results and creating a ’line of
sight“ showing how team, unit, and individual performance can
contribute to overall results.
Practice: 7. Establish a communication strategy to create shared
expectations and report related progress;
Description: A transforming organization must develop a comprehensive
communication strategy that reaches out to employees, customers, and
stakeholders and seeks to genuinely engage them in the transformation
process. This includes communicating early and often to build trust,
ensuring consistency of message, encouraging two-way communication, and
providing information to meet specific needs of employees.
Practice: 8. Involve employees to obtain their ideas and gain ownership
for the transformation;
Description: A successful transformation must involve employees and
their representatives from the beginning to gain their ownership for
the changes that are occurring in the organization. This includes
involving employees in planning and sharing performance information and
incorporating employee feedback into new policies and procedures.
Practice: 9. Build a world-class organization using leading practices
in strategic human capital management, performance measurement, and IT
management;
Description: Building on a vision of improved performance, the
organization adopts the most efficient, effective, and economical
personnel, system, and process changes and continually seeks to
implement best practices.
[End of table]
Appendix 2: Sources For Good Management Practices GAO Used in This
Review:
Key Practices for Organizational Mergers and Transformations:
Results-Oriented Cultures: Implementation Steps to Assist Mergers and
Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2,
2003):
Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned
for a Department of Homeland Security and Other Federal Agencies, GAO-
03-293SP (Washington, D.C.: November 14, 2002):
Strategic Human Capital Planning:
Human Capital: Building on the Current Momentum to Transform the
Federal Government, GAO-04-976T (Washington, D.C.: July 20, 2004):
Human Capital: Federal Workforce Challenges in the 21st Century, GAO-
07-556T (Washington, D.C.: March 6, 2007):
Results-Oriented Cultures: Creating a Clear Linkage between Individual
Performance and Organizational Success, GAO-03-488 (Washington, D.C.:
March 14, 2003):
Human Capital: Key Principles for Effective Strategic Workforce
Planning, GAO-04-39 (Washington, D.C.: December 11, 2003):
Information Technology Management:
Information Technology Investment Management: A Framework for Assessing
and Improving Process Maturity, GAO-04-394G (Washington, D.C.: March 1,
2004):
Information Technology: Leading Commercial Practices for Outsourcing of
Services, GAO-02-214 (Washington, D.C.: November 30, 2001):
Information Technology: A Framework for Assessing and Improving
Enterprise Architecture Management, GAO-03-584G (Washington, D.C.:
April 1, 2003):
Performance Measurement:
Comptroller General's Forum: High-Performing Organizations: Metrics,
Means, and Mechanisms for Achieving High Performance in the 21 st
Century Public Management Environment, GAO-04-343SP (Washington, D.C.:
February 13, 2004):
Managing For Results: Enhancing Agency Use of Performance Information
for Management Decision Making, GAO-05-927 (Washington, D.C.: September
9, 2005):
Tax Administration: IRS Needs to Further Refine Its Tax Filing Season
Performance Measures, GAO-03-143 (Washington, D.C.: November 22, 2002):
[End of section]
Enclosure II: Agency Comments:
U.S. Department of Homeland Security:
Washington, DC 20528:
June 25, 2007:
Ms. Bernice Steinhardt:
Director, Strategic Issues:
Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Steinhardt:
RE: Draft Report: USCIS Transformation: Improvements to Performance,
Human Capital, Communications, and Information Technology Management
Needed as Modernization Proceeds (GAO-07-1013R):
The Department of Homeland Security (DHS) appreciates the opportunity
to comment on the Government Accountability Office's (GAO's) draft
report. We thank you for the comprehensive review and value added
recommendations. As discussed in your meetings with U.S. Citizenship
and Immigration Services (USCIS), the Spend Plan and Strategic Plan GAO
reviewed narrowly focused on the business process aspects of USCIS
Transformation and not the large scale agency improvements also
underway. We emphasize this distinction to give context for the readers
of the GAO report.
The following represents USCIS' response to the recommendations
contained in the draft report. As indicated below, USCIS was in the
process or has begun implementing GAO's recommendations.
Recommendation 1: Document specific performance measures and targets
for the pilots, increments, and the transformed organization that are
outcome-oriented, objective, reliable, balanced, limited to the vital-
few, measurable, and aligned with organizational goals.
Response: USCIS agrees that performance measures are critical to
holding employees accountable and ensuring success of the program.
USCIS' Transformation Program Office (TPO) is refining its performance
measures. USCIS intends to develop sets of performance metrics that
relate to the products and processes delivered as well as the
performance related to the manner in which the Transformation Program
is managed. USCIS believes that both sets of metrics are necessary to
ensure effective management and results. Also, USCIS' Transformation
Program Office has begun cascading performance expectations to its
staff to ensure goal alignment throughout the program. USCIS
understands that it needs to complete the work associated with
identification and base lining of performance metrics and will develop
meaningful and measurable criteria.
Recommendation 2: Increase USCIS' focus on strategic human capital
management for the transformation.
Response: USCIS agrees that it should increase its focus on strategic
human capital and has begun developing a strategy for recruiting,
hiring, developing and retaining USCIS personnel. This strategy
addresses the skill and competency requirements that USCIS will need to
acquire in order to fully realize the benefits of Transformation.
Further, USCIS' Transformation Program Office will ensure that proper
alignment exists with the Office of the Chief Human Capital Officer and
that as shifts are identified in required knowledge, skills, and
abilities, appropriate planning is incorporated into the timelines to
ensure that offices are properly staffed and trained.
Recommendation 3: Complete a comprehensive communication strategy that
involves communicating early and often to build trust, ensuring
consistency of message, and encouraging two-way communication.
Response: USCIS is expanding its communication activities and will
discuss appropriate information with internal and external
stakeholders. USCIS' Transformation Program Office and Office of
Communications are revising communication plans and will incorporate
the specific recommendations from GAO.
Recommendation 4: Continue to develop an enterprise architecture that
sufficiently guides and constrains the transformation plans, as DHS
works to address limitations in its own enterprise architecture and
alignment processes.
Response: USCIS will continue developing its enterprise architecture
and align it with the developing DHS enterprise architecture.
Significant work has been completed with the DHS Enterprise
Architecture Community of Excellence (EACOE). On June 11, 2007, the
EACOE put to a vote and approved the USCIS Transformation Program for
Milestone Decision Point One. USCIS will continue to work through the
EACOE to ensure alignment and concurrence.
In addition to responding to the recommendations, USCIS wishes to
clarify some statements in the cover letter and draft report. Page 1 of
the cover letter states "tens of thousands of files that are missing or
not easily located." This information was documented in the GAO report
titled Additional Efforts Needed to Help Ensure Alien Files are Located
when Needed, GAO-07-85, October 2006. The USCIS maintains over 67
million physical A-Files and has developed an extensive National File
Tracking System (NFTS), to track and manage the movement of these
records. The system was designed to improve accountability and has the
capability to identify a file's location to not only an office, but to
a desk or file cabinet within an office. The NFTS is used by USCIS
offices around the world as well as U.S. Immigration and Customs
Enforcement (ICE) and U.S. Customs and Border Protection (CBP) offices.
The deployment of NFTS has facilitated the recovery of thousands of
files that were previously identified as "lost" when complete audits
and system reconciliation efforts were performed.
USCIS believes the majority of files marked as "lost" are the result of
human error and erroneous file tracking entries. It is anticipated that
with the deployment of NFTS to its three additional large file control
offices, the remaining 12 percent of USCIS files will be accounted for,
and the number of files previously thought to be lost will be reduced
even further. This transition is expected to be competed by early 2008.
USCIS takes its records management responsibilities seriously and
continually explores options to improve its records management program
and is taking steps towards transitioning to an electronically managed
records keeping environment. Last September, USCIS began a new effort
to digitize A-Files. This initiative serves as a starting point for the
USCIS electronic re-engineering effort. The effort will gradually
eliminate the need for a physical file and eliminate the potential for
additional lost files in the future.
Page 3 of the cover letter states, "In addition, while the TPO has
established performance expectations for its own staff, it has not
formally evaluated the performance of its staff against those
expectations." USCIS' Transformation Program Office conducted its mid-
year evaluations for staff in early June.
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.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
(450555):
FOOTNOTES
[1] Department of Homeland Security, Office of Inspector General, USCIS
Faces Challenges in Modernizing Information Technology, OIG-05-41
(Washington, D.C.: September 2005).
[2] GAO, Information Technology: Near-Term Effort to Automate Paper-
Based Immigration Files Needs Planning Improvements, GAO-06-375
(Washington, D.C.: Mar. 31, 2006).
[3] GAO previously identified a number of key practices found at the
center of successful mergers, acquisitions, and transformations in a
forum convened by the Comptroller General. See GAO, Highlights of a GAO
Forum: Mergers and Transformation: Lessons Learned for a Department of
Homeland Security and Other Federal Agencies, GAO-03-293SP (Washington,
D.C.: Nov. 14, 2002) and Results-Oriented Cultures: Implementation
Steps to Assist Mergers and Organizational Transformations, GAO-03-669
(Washington, D.C.: July 2, 2003).
[4] Pub. L. No. 109-295, 120 Stat. 1355, 1374.
[5] GAO, Homeland Security: DHS Enterprise Architecture Continues to
Evolve but Improvements Needed, GAO-07-564 (Washington, D.C.: May 9,
2007).
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site (www.gao.gov). Each weekday, GAO posts
newly released reports, testimony, and correspondence on its Web site.
To have GAO e-mail you a list of newly posted products every afternoon,
go to www.gao.gov and select "Subscribe to Updates."
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. Government Accountability Office 441 G Street NW, Room LM
Washington, D.C. 20548:
To order by Phone: Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 U.S.
Government Accountability Office, 441 G Street NW, Room 7125
Washington, D.C. 20548:
Public Affairs:
Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, D.C. 20548:
