Financial Management Systems
DHS Faces Challenges to Successfully Consolidating Its Existing Disparate Systems Gao ID: GAO-10-76 December 4, 2009In June 2007, GAO reported that the Department of Homeland Security (DHS) had made little progress in integrating its existing financial management systems and made six recommendations focused on the need for DHS to define a departmentwide strategy and embrace disciplined processes. In June 2007, DHS announced its new financial management systems strategy, called the Transformation and Systems Consolidation (TASC) program. House Report No. 110-862 directed GAO to determine whether DHS had implemented GAO's prior recommendations. GAO also assessed whether there were additional issues that pose unnecessary risks to the successful implementation of the TASC program. GAO reviewed relevant documentation, such as the January 2009 request for proposal and its attachments, and interviewed key officials to obtain additional information.
GAO's analysis shows that DHS has begun to take actions to implement four of the six recommendations made in the 2007 report; however, none of these recommendations have been fully implemented. GAO recognizes that DHS cannot fully implement some of the recommendations aimed at reducing the risk in accordance with best practices until the contract for the TASC program is awarded. DHS has taken, but not completed, actions to (1) define its financial management strategy and plan, (2) develop a comprehensive concept of operations, (3) incorporate disciplined processes, and (4) implement key human capital practices and plans for such a systems implementation effort. DHS has not taken the necessary actions on the remaining two recommendations, to standardize and reengineer business processes across the department, including applicable internal control, and to develop detailed consolidation and migration plans since DHS will not know the information necessary to develop these items until a contractor is selected. While some of the details of the department's standardization of business processes and migration plans depend on the selected new system, DHS would benefit from performing critical activities, such as performing a gap analysis and identifying all of its affected current business processes so that DHS can analyze how closely the proposed system will meet the department's needs. GAO's analysis during this review also identified two issues that pose unnecessary risks to the TASC program--DHS's significant risks related to the reliance on contractors to define and implement the new system and the lack of independence of the contractor hired to perform the verification and validation (V&V) function for the TASC program. DHS plans to rely on the selected contractor to complete key process documents for the TASC program such as detailed documentation that governs activities such as requirements management, testing, data conversion, and quality assurance. The extent of DHS's reliance on contractors to define and implement key processes needed by the TASC program, without the necessary oversight mechanisms to ensure that the processes are properly defined and effectively implemented, could result in system efforts plagued with serious performance and management problems. Further, GAO identified that DHS's V&V contractor was not independent with regard to the TASC program. DHS management agreed that the V&V function should be performed by an entity that is technically, managerially, and financially independent of the organization in charge of the system development, acquisition, or both that it is assessing. Accordingly, DHS officials indicated that they have restructured the contract to address GAO's concerns by changing the organization that is responsible for managing the V&V function.
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-10-76, Financial Management Systems: DHS Faces Challenges to Successfully Consolidating Its Existing Disparate Systems
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Report to Congressional Addressees:
United States Government Accountability Office:
GAO:
December 2009:
Financial Management Systems:
DHS Faces Challenges to Successfully Consolidating Its Existing
Disparate Systems:
GAO-10-76:
GAO Highlights:
Highlights of GAO-10-76, a report to congressional addressees.
Why GAO Did This Study:
In June 2007, GAO reported that the Department of Homeland Security
(DHS) had made little progress in integrating its existing financial
management systems and made six recommendations focused on the need for
DHS to define a departmentwide strategy and embrace disciplined
processes. In June 2007, DHS announced its new financial management
systems strategy, called the Transformation and Systems Consolidation
(TASC) program. House Report No. 110-862 directed GAO to determine
whether DHS had implemented GAO‘s prior recommendations. GAO also
assessed whether there were additional issues that pose unnecessary
risks to the successful implementation of the TASC program. GAO
reviewed relevant documentation, such as the January 2009 request for
proposal and its attachments, and interviewed key officials to obtain
additional information.
What GAO Found:
GAO‘s analysis shows that DHS has begun to take actions to implement
four of the six recommendations made in the 2007 report; however, none
of these recommendations have been fully implemented. GAO recognizes
that DHS cannot fully implement some of the recommendations aimed at
reducing the risk in accordance with best practices until the contract
for the TASC program is awarded. DHS has taken, but not completed,
actions to (1) define its financial management strategy and plan, (2)
develop a comprehensive concept of operations, (3) incorporate
disciplined processes, and (4) implement key human capital practices
and plans for such a systems implementation effort. DHS has not taken
the necessary actions on the remaining two recommendations, to
standardize and reengineer business processes across the department,
including applicable internal control, and to develop detailed
consolidation and migration plans since DHS will not know the
information necessary to develop these items until a contractor is
selected. While some of the details of the department‘s standardization
of business processes and migration plans depend on the selected new
system, DHS would benefit from performing critical activities, such as
performing a gap analysis and identifying all of its affected current
business processes so that DHS can analyze how closely the proposed
system will meet the department‘s needs.
GAO‘s analysis during this review also identified two issues that pose
unnecessary risks to the TASC program”DHS‘s significant risks related
to the reliance on contractors to define and implement the new system
and the lack of independence of the contractor hired to perform the
verification and validation (V&V) function for the TASC program. DHS
plans to rely on the selected contractor to complete key process
documents for the TASC program such as detailed documentation that
governs activities such as requirements management, testing, data
conversion, and quality assurance. The extent of DHS‘s reliance on
contractors to define and implement key processes needed by the TASC
program, without the necessary oversight mechanisms to ensure that the
processes are properly defined and effectively implemented, could
result in system efforts plagued with serious performance and
management problems. Further, GAO identified that DHS‘s V&V contractor
was not independent with regard to the TASC program. DHS management
agreed that the V&V function should be performed by an entity that is
technically, managerially, and financially independent of the
organization in charge of the system development, acquisition, or both
that it is assessing. Accordingly, DHS officials indicated that they
have restructured the contract to address GAO‘s concerns by changing
the organization that is responsible for managing the V&V function.
What GAO Recommends:
GAO makes seven recommendations and reaffirms its six prior
recommendations to mitigate DHS‘s risk in acquiring and implementing
the TASC program. DHS agreed with GAO‘s recommendations and described
actions it has taken and plans to take to address them. GAO agrees that
DHS has completed actions to address one recommendation, but further
action is needed to address the others. GAO also received technical
comments, which were incorporated as appropriate.
View [hyperlink, http://www.gao.gov/products/GAO-10-76] or key
components. For more information, contact Kay Daly at (202) 512-9095 or
Nabajyoti Barkakati at (202) 512-4499.
[End of section]
Contents:
Letter:
Background:
DHS Has Made Limited Progress in Implementing Our Prior
Recommendations:
Planned TASC Implementation Efforts Pose Unnecessary Risks:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Comments from the Department of Homeland Security:
Table:
Table 1: DHS's Progress toward Addressing GAO's Recommendations:
Figure:
Figure 1: Key Events Affecting the TASC Program:
Abbreviations:
CBP: U.S. Customs and Border Protection:
COTR: Contracting Officer Technical Representative:
COTS: commercial-off-the-shelf:
DHS: Department of Homeland Security:
eMerge2: Electronically Managing Enterprise Resources for Government
Effectiveness and Efficiency:
ERP: enterprise resource planning:
FEMA: Federal Emergency Management Agency:
FTE: full-time equivalent:
IEEE: Institute of Electrical and Electronics Engineers:
IV&V: independent verification and validation:
OCFO: Office of the Chief Financial Officer:
OIG: Office of Inspector General:
RMTO: Resource Management Transformation Office:
SBI: Secure Border Initiative:
TASC: Transformation and Systems Consolidation:
V&V: verification and validation:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
December 4, 2009:
Congressional Addressees:
Since the Department of Homeland Security (DHS) began operations in
March 2003, it has faced the daunting task of bringing together 22
diverse agencies and developing an integrated financial management
system. In January 2009,[Footnote 1] we reported that although DHS had
reduced financial internal control weaknesses, it had not yet
integrated its financial management systems and had not developed a
comprehensive plan for doing so. We recently testified[Footnote 2] that
while DHS has redefined its acquisition and investment management
policies and practices, the extent to which these policies and
practices on major programs have been implemented was at best
inconsistent and in many cases quite limited. Moreover, recent GAO
reviews have shown that major acquisition programs have not been
subjected to executive-level acquisition and investment management
reviews at key milestones.
DHS officials have long recognized the need to integrate their
financial management systems, which are used to account for over $40
billion in annual appropriated funds. The department's prior effort,
known as the Electronically Managing Enterprise Resources for
Government Effectiveness and Efficiency (eMerge2) project,[Footnote 3]
began in January 2004 and was expected to integrate financial
management systems departmentwide and address existing financial
management weaknesses. However, DHS officials ended the eMerge2 project
in December 2005, acknowledging that this project had not been
successful. DHS officials stated that they had identified existing
financial management systems, currently used by some of DHS's
components, which could be leveraged by migrating these existing
financial management systems to its other components.[Footnote 4]
In June 2007, we reported[Footnote 5] that the department had made
little progress since December 2005 in replacing its existing financial
management systems problems and that, from an overall perspective, the
decision to halt its eMerge2 project was prudent. We made six
recommendations focused on the need for DHS to define a departmentwide
strategy and embrace disciplined processes[Footnote 6] to reduce risk
to acceptable levels.[Footnote 7]
Also, in June 2007, DHS officials announced its new financial
management systems strategy, called the Transformation and Systems
Consolidation (TASC) program. At that time, the TASC program was
described as the migration of other DHS components' systems to two
existing financial management systems already in use at several
components. After a bid protest was filed regarding the proposed
approach, the TASC request for proposal was revised to acquire an
integrated financial, acquisition, and asset management commercial-off-
the-shelf software (COTS) solution to be implemented departmentwide.
The House Committee on Appropriations' September 2008 report on the
fiscal year 2009 Department of Homeland Security Appropriations Bill
[Footnote 8] included a mandate requiring us to review the TASC
program, including following up on DHS's efforts to implement the six
recommendations made in our June 2007 report. The Chairman, House
Committee on Homeland Security became a cosponsor of that follow-up
work. Further, the Ranking Member of the Senate Committee on Homeland
Security and Governmental Affairs also became a cosponsor as did the
Chairman of the Subcommittee on Federal Financial Management,
Government Information, Federal Services, and International Security,
Senate Committee on Homeland Security and Governmental Affairs.
Our objectives for this report were to determine whether DHS had
implemented our prior recommendations and assess whether there were
additional issues that pose unnecessary risks to the successful
implementation of the TASC program. We reviewed the January 2009
request for proposal and its attachments, such as the Statement of
Objectives and Solution Process Overview, to understand DHS's plans for
implementing the TASC program. We also reviewed other available
planning documents, such as the acquisition plan and the draft concept
of operations, and determined the status of these plans and others to
see if DHS had fully implemented our recommendations. We interviewed
key officials from DHS's Office of the Chief Financial Officer (OCFO)
and the Resource Management Transformation Office (RMTO), within OCFO,
including its Director and Deputy Director for elaboration and to
provide additional perspectives on the information contained in these
documents. We also reviewed the Statement of Work for an independent
verification and validation (IV&V) contractor and confirmed key
information about this contract with the Director of RMTO.
We conducted this performance audit from March 2009 through November
2009 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. In October
2009,[Footnote 9] we discussed our preliminary findings in a hearing
before the Subcommittee on Management, Investigations, and Oversight,
House Committee on Homeland Security. We requested comments on a draft
of this report from the Secretary of Homeland Security or her designee.
We received written comments from the DHS Acting Chief Financial
Officer, which are reprinted in appendix I.
Background:
DHS was established by merging 22 disparate agencies and organizations
with multiple missions, values, and cultures. Some of the agencies that
became DHS components include the Federal Emergency Management Agency
(FEMA), Federal Law Enforcement Training Center, Transportation
Security Administration, U.S. Coast Guard, and U.S. Secret Service.
Other former agencies were divided by function into new components or
had their responsibilities distributed within a DHS component. For
example, the former U.S. Customs Service became two DHS components--the
U.S. Customs and Border Protection (CBP) and the U.S. Immigration and
Customs Enforcement. Given the number of agencies that merged to become
part of DHS and the diversity of their missions, an integrated
financial management system that captures all of DHS's financial
activities is imperative to provide reliable, timely, and useful
information for managing day-to-day operations.
DHS has described the TASC program in its Solution Process Overview as
a departmentwide initiative to modernize, transform, and integrate the
financial, acquisition, and asset management capabilities of its
components. According to DHS officials, the new system is to be a COTS
package that is already configured and operating in the public sector.
Bid protests and related litigation have resulted in changes to DHS's
approach for the TASC program as well as contributing to a significant
delay in awarding a contract. The initial TASC approach was to migrate
its components to two financial management systems--Oracle Federal
Financials and SAP--already in use by several DHS components.[Footnote
10] Under its pre-protest timeline, DHS anticipated that several of its
smaller components, including the Office of Health Affairs and the
Directorate for Science and Technology, would have "gone live" with the
department's new baseline system by November 30, 2008. Because of
changes in the TASC approach and the delays shown in figure 1, DHS
officials stated that the department now expects to select a vendor by
the second quarter of fiscal year 2010.
Figure 1: Key Events Affecting the TASC Program:
[Refer to PDF for image: illustration]
August, 2007:
DHS issued a request for proposal for managing the migration of DHS‘s
five different financial management software solutions to a shared
system baseline (Oracle or SAP systems).
October, 2007:
DHS canceled the request for proposal because no offerors had submitted
proposals.
November, 2007:
DHS issued a new, revised request for proposal with the same purpose as
the 8/07 proposal.
January, 2008:
A financial services company, which was a potential offeror to DHS‘s
2007 request for proposal, filed a bid protest with the U.S. Court of
Federal Claims.[A]
March, 2008:
The Court enjoined DHS from proceeding with the November 2007 request
for proposal until DHS conducted a ’competitive procurement,“ in
accordance with the law.[B]
September, 2008:
DHS issued a notice concerning a new request for proposal to be issued
shortly.
October, 2008:
DHS issued a draft of a new request for proposal for public comment.
November, 2008:
The original protestor filed a motion with the Court to enforce the
March 2008 injunction.[C]
January, 2009:
DHS issued a new TASC request for proposal for provision of ’an
integrated financial management, asset management and acquisition
management systems solution and performance of TASC support services.“
[D]
February, 2009:
The original protestor filed a new bid protest with the Court, alleging
that DHS violated the March 2008 injunction by proceeding with the
January 2009 request for proposal.
April, 2009:
The Court dismissed the bid protestor‘s complaint, which allowed DHS to
proceed with its TASC request for proposal.
July, 2009:
The original protestor filed an appeal of the Court‘s April 2009
judgment.
September, 2009:
DHS responded to the July 2009 appeal.
October, 2009:
The protestor responded to DHS‘s September 2009 response.
Source: DHS.
[A] The offeror alleged that DHS had conducted an improper sole source
procurement.
[B] Under 28 U.S.C. § 1491(b), the U.S. Court of Federal Claims has
jurisdiction to render judgments and award relief to an interested
party objecting to a request for proposal issued by federal agencies.
The U.S. Court of Federal Claims issued an order enjoining DHS from
proceeding with this procurement until DHS conducted a competitive
procurement, in accordance with the Competition in Contracting Act (41
U.S.C. § 253), which generally requires executive agencies to procure
property and services through the use of competitive procedures that
allow for full and open competition.
[C] The potential offeror filed a motion with the U.S. Court of Federal
Claims alleging that DHS had violated the Court's March 2008 injunction
against proceeding with the original request for proposal.
[D] Unlike the first two TASC requests for proposal, this request was
issued to the public in anticipation of a new contract. The first two
requests for proposal were issued only to awardees of existing
indefinite delivery, indefinite quantity contracts with the expectation
of awarding a task order under one of the existing contracts.
[End of figure]
DHS Has Made Limited Progress in Implementing Our Prior
Recommendations:
DHS has begun to take actions toward the implementation of four of the
recommendations we made in June 2007,[Footnote 11] as shown in table 1.
However, all six recommendations remain open. We do recognize that DHS
cannot fully implement all of our recommendations until a contract is
awarded because of its selected acquisition approach.
Table 1: DHS's Progress toward Addressing GAO's Recommendations:
Recommendation: Clearly define and document a departmentwide financial
management strategy and plan to move forward with its financial
management system integration efforts;
Not completed: Some actions taken: [Check].
Recommendation: Develop a comprehensive concept of operations document;
Not completed: Some actions taken: [Check].
Recommendation: Utilize and implement these specific disciplined
processes to minimize project risk: (1) requirements management, (2)
testing, (3) data conversion and system interfaces, (4) risk
management, (5) configuration management, (6) project management, and
(7) quality assurance;
Not completed: Some actions taken: [Check].
Recommendation: Reengineer business processes and standardize them
across the department, including applicable internal control;
Not completed: No action taken: [Check].
Recommendation: Develop a detailed plan for migrating and consolidating
various DHS components to an internal shared services approach if this
approach is sustained;
Not completed: No action taken: [Check].
Recommendation: Carefully consider key human capital practices as DHS
moves forward with its financial management transformation efforts so
that the right people with the right skills are in place at the right
time;
Not completed: Some actions taken: [Check].
Source: GAO analysis of DHS information.
[End of table]
These recommendations, made to help DHS reduce the risks associated
with acquiring and implementing a departmentwide financial management
system, are based on four building blocks, which were developed in
accordance with industry best practices and our work at other federal
agencies. These four building blocks, integral to the success of DHS's
TASC program, are:
* developing a concept of operations,
* defining standard business processes,
* developing a migration strategy for DHS components, and:
* defining and implementing the disciplined processes necessary to
properly manage the project.
Fully embracing these four building blocks will be critical to the
success of the TASC program, once that program has been clearly defined
and documented. For example, defining standard business processes
promotes consistency in operations within the department. Further, by
reengineering and standardizing business processes, DHS should realize
productivity gains and staff portability among its components.
Underlying these four building blocks is the need for effective human
capital management, which includes having sufficient human resources
with the requisite training and experience to implement the system as
well as operate the system once it has been put into service.
DHS Faces Significant Challenges to Implementing Its Financial
Management Strategy and Plan:
DHS has developed certain elements for its financial management
strategy and plan for moving forward with its financial system
integration efforts but it faces significant challenges in completing
and implementing its strategy. DHS has defined its vision for the TASC
program, which is to consolidate and integrate departmentwide mission-
essential financial, acquisition, and asset management systems, by
providing a seamless, real-time, Web-based system to execute mission-
critical, end-to-end integrated business processes. DHS has also
established several major program goals for the TASC program which
include, but are not limited to:
* creating and refining end-to-end standard business processes and a
standard line of accounting;
* supporting timely, complete, and accurate financial management and
reporting;
* enabling DHS to acquire goods and services of the best value that
ensure that the department's mission and program goals are met; and:
* enabling consolidated asset management across all components.
DHS officials stated that the strategy for the TASC program is to
acquire a COTS-based system already configured and being used at a
federal entity as a starting point for the department's efforts. This
approach differs from other financial management system implementation
efforts we have reviewed in which an agency first acquired a COTS
product and then performed the actions necessary to configure the
product to meet the agency's specific requirements.[Footnote 12]
Our review found that the strategy being taken by DHS does not contain
the elements needed to evaluate whether the acquired system will
provide the needed functionality or meet users' needs. For example, it
does not require DHS to (1) perform an analysis of the current
processes to define the user requirements to be considered when
evaluating the various systems, (2) perform a gap analysis[Footnote 13]
before the system is selected,[Footnote 14] and (3) assess the extent
to which the COTS-based system used at another agency has been
customized for the respective federal entities. Studies have shown that
when an effective gap analysis was not performed, program offices and
contractors later discovered that the selected system lacked essential
capabilities. Furthermore, adding these capabilities required expensive
custom development and resulted in cost and schedule overruns that
could have been avoided.[Footnote 15] Without a comprehensive strategy
and plan for the TASC program that considers these issues, DHS risks
implementing a financial management system that will be unnecessarily
costly to maintain.
DHS Has Recently Developed a Concept of Operations for the TASC
Program:
The January 2009 request for proposal states that the selected
contractor will be required to provide a concept of operations for the
TASC program. This concept of operations is expected to provide an
operational view of the new system from the end users' perspective and
outline the business processes as well as the functional and technical
architecture for their proposed systems. In October 2009, DHS officials
provided us with a concept of operations for the TASC program and they
stated that the document was prepared in accordance with the Institute
of Electrical and Electronics Engineers (IEEE) standards.[Footnote 16]
However, it is unclear how the DHS-prepared concept of operations
document will relate to the selected contractor's concept of operations
document called for in the request for proposal.
According to the IEEE standards,[Footnote 17] a concept of operations
is a user-oriented document that describes the characteristics of a
proposed system from the users' viewpoint. A concept of operations
document also describes the operations that must be performed, who must
perform them, and where and how the operations will be carried out. DHS
needs to develop a concept of operations that is based on a vision
statement, outlined in the TASC strategy, and the enterprise
architecture. The concept of operations for the TASC program should,
among other things,
* define how DHS's day-to-day financial management operations are and
will be carried out to meet mission needs,
* clarify which component and departmentwide systems are considered
financial management systems,
* include a transition strategy that is useful for developing an
understanding of how and when changes will occur,
* develop an approach for obtaining reliable information on the costs
of its financial management systems investments, and:
* link DHS's concept of operations for the TASC program to its
enterprise architecture.
A completed concept of operations prior to issuance of the request for
proposal would have benefited the offerors in developing their
proposals so that they could identify and propose systems that more
closely align with DHS's vision and specific needs.
DHS Has Not Fully Incorporated Disciplined Processes into the TASC
Program:
While DHS has draft risk management, project management, and
configuration management plans, DHS officials told us that other key
plans relating to these disciplined processes generally considered to
be best practices will not be completed until after the TASC contract
is awarded. These other plans include the requirements management,
[Footnote 18] data conversion and system interfaces,[Footnote 19]
quality assurance, and testing plans.[Footnote 20] Offerors were
instructed in the latest request for proposal to describe their
testing, risk management, and quality assurance approaches as well as
component migration and training approaches. The approaches proposed by
the selected contractor will become the basis for the preparation of
these plans. While we recognize that the actual development and
implementation of these plans cannot be completed until the TASC
contractor and system have been selected, it will be critical for DHS
to ensure that these plans are completed and effectively implemented
prior to moving forward with the implementation of the new system.
Disciplined processes represent best practices in systems development
and implementation efforts that have been shown to reduce the risks
associated with software development and acquisition efforts to
acceptable levels and are fundamental to successful system
implementations. The key to having a disciplined system development
effort is to have disciplined processes in multiple areas, including
project planning and management, requirements management, configuration
management, risk management, quality assurance, and testing. Effective
processes should be implemented in each of these areas throughout the
project life cycle because change is constant. Effectively implementing
the disciplined processes necessary to reduce project risks to
acceptable levels is hard to achieve because a project must effectively
implement several best practices, and inadequate implementation of any
one may significantly reduce or even eliminate the positive benefits of
the others.
As we have previously reported, other agencies' business transformation
efforts have failed because of a lack of commitment to disciplined
processes. For example, we reported[Footnote 21] in 2005 that the
Navy's failure to adhere to requirements management contributed to a
largely wasted investment of approximately $1 billion in four pilots of
enterprise resource planning (ERP)[Footnote 22] solutions. Because the
pilots would not meet its overall requirements, the Navy started over
and developed a new ERP system to standardize the Navy's business
processes across its dispersed organizational environment.[Footnote 23]
DHS Has Not Yet Identified All Business Processes Needing Reengineering
and Standardization across the Department:
Although DHS has identified nine end-to-end business processes[Footnote
24] that will be addressed as part of the TASC program, the department
has not identified all of its existing business processes that will be
reengineered and standardized as part of the TASC program. It is
important for DHS to identify all of its business processes so that the
department can analyze the offerors' proposed systems to assess how
closely each of these systems aligns with DHS's business processes.
Such an analysis would position DHS to determine whether a proposed
system would work well in its future environment or whether the
department should consider modifying its business processes. Without
this analysis, DHS will find it challenging to assess the difficulties
of implementing the selected system to meet DHS's unique needs.
For the nine processes identified, DHS has not yet begun the process of
reengineering and standardizing those processes. DHS has asked offerors
to describe their proposed approaches for the standardization of these
nine processes to be included in the TASC system. According to an
attachment to the TASC request for proposal, there will be additional
unique business processes or subprocesses, beyond the nine standard
business processes identified, within DHS and its components that also
need to be supported by the TASC system. For DHS's implementation of
the TASC program, reengineering and standardizing these unique business
processes and subprocesses will be critical because the department was
created from 22 agencies with disparate processes. A standardized
process that addresses, for example, the procurement processes at the
U.S. Coast Guard, FEMA, and the U.S. Secret Service, as well as the
other DHS components, is essential when implementing the TASC system
and will be useful for training and ensuring the portability of staff.
DHS Has Not Yet Developed Plans for Migrating the New System to Its
Components:
Although DHS officials have stated that they plan to migrate the new
system first to its smaller components and have recently provided a
high-level approach the department might use, DHS has not outlined a
conceptual approach or plan for accomplishing this goal throughout the
department. Instead, DHS has requested that TASC offerors describe
their migration approaches for each of the department's components, as
well as data conversion, overall migration strategy, training approach,
and staffing.
While the actual migration approach will depend on the selected system
and events that occur during the TASC program implementation, critical
activities include (1) developing specific criteria requiring component
agencies to migrate to the new system rather than attempting to
maintain legacy business systems; (2) defining and instilling new
values, norms, and behaviors within component agencies that support new
ways of doing work and overcoming resistance to change; (3) building
consensus among customers and stakeholders on specific changes designed
to better meet their needs; and (4) planning, testing, and implementing
all aspects of the migration of the new system. For example, a critical
part of a migration plan for the new system would describe how DHS will
ensure that the data currently in legacy systems are fully prepared to
be migrated to the new system.
An important element of a migration plan is the prioritizing of the
conversion of the old systems to the new systems. For example, a FEMA
official stated that the agency has not replaced its outdated financial
management system because it is waiting for the implementation of the
TASC program. However, in the interim, FEMA's auditors are repeatedly
reporting weaknesses in its financial systems and reporting, an
important factor to be considered by DHS when preparing its migration
plan. Because of the known weaknesses at DHS components, it will be
important for DHS to prioritize its migration of components to the new
system and address known weaknesses prior to migration where possible.
Absent a comprehensive migration strategy, components within DHS may
seek other financial management systems to address their existing
weaknesses. This could result in additional disparate financial
management systems instead of the integrated financial management
system that DHS needs.
DHS Has Begun Hiring, but Has Not Developed a Human Capital Plan for
the TASC Program:
While DHS's RMTO has begun recruiting and hiring employees and
contractors to help with the TASC program, the department has not
identified the gaps in needed skills for the acquisition and
implementation of the new system. DHS officials have said that the
department is unable to determine the adequate staff levels necessary
for the full implementation of the TASC program because the integrated
solution is not yet known; however, as of May 2009, the department had
budgeted 72 full-time equivalents (FTE)[Footnote 25] for fiscal year
2010. The 72 FTEs include 38 government employees and 34 contract
employees, (excluding an IV&V contractor). DHS officials told us that
this level of FTEs may be sufficient for the first deployments of the
new system.
In its comments dated November 16, 2009, DHS stated that RMTO staff
included the following: 1 level III program manager, 13 project
management professionals, 14 certified contracting officer technical
representatives, 3 certified public accountants, 5 level II program
managers, and 5 level I program managers. In addition, according to
RMTO officials, the OCFO and some of DHS's larger components, such as
U.S. Immigration and Customs Enforcement have dedicated staff to work
on the TASC program. Moreover, as stated in its agency comments, DHS
plans to continue to build the capabilities within RMTO.
Many of the department's past and current difficulties in financial
management and reporting can be attributed to the original stand-up of
a large, new, and complex executive branch agency without adequate
organizational expertise in financial management and accounting. Having
a plan that includes sufficient human resources with the requisite
training and experience to successfully implement a financial
management system is critical to the success of the TASC program.
Planned TASC Implementation Efforts Pose Unnecessary Risks:
While updating the status of the six prior recommendations, we
identified two issues that pose unnecessary risks to the success of the
TASC program. These risks are DHS's significant reliance on contractors
to define and implement the new system and the lack of independence of
DHS's V&V function[Footnote 26] for the TASC program.
Significant Reliance Placed on Contractors to Define and Implement the
TASC Program:
The department plans to have the selected contractor prepare a number
of key documents including plans needed to carry out disciplined
processes, define additional business processes to be standardized, and
propose a migration approach. However, DHS has not developed the
necessary contractor oversight mechanisms to ensure that its
significant reliance on contractors for the TASC program does not
result in an unfavorable outcome.
Other systems acquisition and implementation efforts that have placed
too much reliance on contractors have resulted in systems efforts
plagued with serious performance and management problems. For example,
regarding the U.S. Coast Guard's Deepwater Program,[Footnote 27] we
reported[Footnote 28] that the Commandant of the U.S. Coast Guard
stated in April 2007 that the U.S. Coast Guard had relied too heavily
on contractors to do the work of the government and that both industry
and government had failed to accurately predict and control costs. The
Commandant announced improvements to program management and oversight
that would "change the course of Deepwater." The major change was that
the U.S. Coast Guard took over the lead role in systems integration. As
part of this shift to an acquisition managed and controlled by the U.S.
Coast Guard, the Commandant noted his plan to build a government
workforce to manage this large acquisition, citing the dearth of
federal contracting expertise and a loss of focus on critical
government roles and responsibilities for managing and overseeing
systems acquisitions such as Deepwater.[Footnote 29]
Moreover, in a recent report,[Footnote 30] DHS's Office of Inspector
General (OIG) reported that CBP had not established adequate controls
and effective oversight of contract workers responsible for providing
Secure Border Initiative (SBI) program support services. Given the
department's aggressive SBI program schedule and shortages of program
managers and acquisition specialists, CBP relied on contractors to fill
the staffing needs and get the program under way. However, CBP had not
clearly distinguished between roles and responsibilities that were
appropriate for contractors and those that must be performed by
government employees. CBP also had not provided an adequate number of
contracting officer's technical representatives (COTR) to oversee
support services contractors' performance. As a result, according to
the OIG report, contractors were performing functions that should have
been performed by government workers. According to the OIG, this heavy
reliance on contractors increased the risk of CBP relinquishing its
responsibilities for SBI program decisions to support contractors,
while remaining responsible and accountable for program outcomes.
Verification and Validation (V&V) Review Function for the TASC Program
Was Not Independent:
We found that DHS's V&V contractor was not an independent reviewer
because RMTO was responsible for overseeing the contractor's work and
authorizing payment of the V&V invoices. Specifically, the V&V
contractor was reporting on work of RMTO, the program manager for the
TASC program, and the RMTO Director was serving as the COTR[Footnote
31] for the V&V contract. As part of the COTR's responsibilities, RMTO
approved the V&V contractor's invoices for payment. On October 21,
2009, DHS officials indicated that they had restructured the V&V
contract to address our concerns by changing the reporting relationship
and the organization that is responsible for managing the V&V contract.
However, at that time, these officials did not provide us with
documentation to support this reorganization. The independence of the
V&V contractor is a key component of a reliable verification and
validation function.
Use of the V&V function is a recognized best practice for large and
complex system development and acquisition projects, such as the TASC
program. The purpose of the V&V function is to provide management with
objective insight into the program's processes and associated work
products. For example, the V&V contractor would review system strategy
documents that provide the foundation for the system development and
operations. According to industry best practices, the V&V activity
should be independent of the project and report directly to senior
management to provide added assurance that reported results on the
project's status are unbiased.[Footnote 32] An effective V&V review
process should provide an objective assessment to DHS management of the
overall status of the project, including a discussion of any existing
or potential revisions to the project with respect to cost, schedule,
and performance. The V&V reports should identify to senior management
the issues or weaknesses that increase the risks associated with the
project or portfolio so that they can be promptly addressed. DHS
management has correctly recognized the importance of such a function;
however, to be effective, the V&V function should be performed by an
entity that is technically, managerially, and financially independent
of the organization in charge of the system development, or
acquisition, or both that it is assessing.
Conclusions:
Six years after the department was established, DHS has yet to
implement a departmentwide, integrated financial management system. DHS
receives billions of taxpayer dollars and continues to need a financial
management systems solution that will help it overcome its financial
management deficiencies, while strengthening its ability to meet
programmatic and mission needs. DHS has started, but not completed
implementation of the six recommendations we made in June 2007, aimed
at helping the department to reduce risk to acceptable levels, while
acquiring and implementing an integrated departmentwide financial
management system. We reaffirm the open recommendations from our prior
report, as they continue to be vital to the success of the TASC
program. In addition, as DHS moves toward acquiring and implementing a
departmentwide financial management system, it has selected a path
whereby it is relying heavily on contractors to define and implement
the TASC program. Therefore, adequate DHS oversight of key elements of
the system acquisition and implementation will be critical to reducing
risk. Given the approach that DHS has selected, it will be critical
that DHS develop oversight mechanisms to minimize risks associated with
contractor-developed documents such as the concept of operations,
migration plans, and plans associated with a disciplined development
effort including requirements management plans, quality assurance
plans, and testing plans. Another important factor will be having the
right people with the right skills to acquire and implement the system.
Moreover, independence of DHS's V&V function is important to provide
objective information to key decision makers. In closing, DHS faces a
monumental challenge in consolidating and modernizing its financial
management systems. Failure to minimize the risks associated with this
challenge could lead to the department developing a system that does
not meet cost, schedule, and performance goals.
Recommendations for Executive Action:
To mitigate the risks of heavy reliance on contractors for acquiring
and implementing an integrated departmentwide financial management
system, we recommend that the Secretary of Homeland Security take the
following seven actions:
* Direct RMTO to expedite the completion of the development of the TASC
financial management strategy and plan so that the department is well
positioned to move forward with an integrated solution.
* Identify the business processes needing standardization to facilitate
implementation of the new system.
* Establish contractor oversight mechanisms to monitor the TASC
program. Such oversight mechanisms should emphasize the following
critical elements for guiding and implementing the TASC program:
- completion of the concept of operations to guide the acquisition and
implementation of the integrated solution;
- development and implementation of disciplined process plans, such as
those for requirements management, data conversion and system
interfaces, quality assurance, and testing to minimize the risks
associated with systems acquisition and implementation efforts; and:
- completion of migration plans, including consideration of existing
financial management weaknesses, to determine the order in which the
new system will be implemented in the components.
- Develop a human capital plan for the TASC program that identifies
needed skills for the acquisition and implementation of the new system.
- Designate a COTR for the IV&V contractor that is not in RMTO, but at
a higher level of departmental management, in order to achieve the
independence needed for the V&V function.
Agency Comments and Our Evaluation:
We received written comments on a draft of this report from the DHS
Acting Chief Financial Officer, which are reprinted in appendix I. In
commenting on the report, the department agreed with our
recommendations and appreciated that GAO had recognized that progress
on addressing certain recommendations will not be made until after the
contract award. The department agreed that it must be vigilant and
disciplined in its oversight and management of major acquisition
projects, such as the TASC program, to ensure their success. Regarding
our recommendation to designate a COTR for the verification and
validation contractor that is independent of RMTO, DHS noted in its
comments that it had taken immediate actions to do so. On November 18,
2009 DHS provided us with documentation confirming that the new COTR
was independent of RMTO. We are encouraged that DHS acted so
expeditiously to address this recommendation. DHS also described
actions it has taken and plans to take regarding our other
recommendations. We are particularly concerned that some of the actions
DHS described in its comments may not fully address the recommendations
we made related to the concept of operations document and the financial
management strategy.
In its comments, DHS stated that the department has developed a robust
concept of operations in accordance with the IEEE standard, as
recommended by GAO. DHS also acknowledges in its comments that the
concept of operations document will need to be updated when the system
is acquired to include system-specific information. Further, as we
discussed in the report, DHS has also asked the selected contractor to
provide a concept of operations document for the TASC program, so it is
unclear which concept of operations document will ultimately be used to
implement the program.
With respect to our recommendation that DHS complete the development of
a financial management strategy and plan, in commenting on the report,
DHS stated that it has a clearly defined strategy and plan to move
forward with its financial management systems integration efforts.
However, we take exception with this statement because as we stated
earlier in the report, the approach being taken by DHS does not contain
the elements needed to evaluate whether the acquired system will
provide the needed functionality or meet users' needs. For example, one
of the most critical missing elements in DHS's strategy and plan is the
gap analysis. DHS does not plan to perform a gap analysis before the
system is selected. When an effective gap analysis is not performed,
program offices and contractors have later discovered that the selected
system lacked essential capabilities. Further this strategy does not
consider the current business processes needed to define the user
requirements to be considered when evaluating the various systems. As a
result, DHS cannot determine with any certainty which of the
department's current business processes that must be reengineered until
the configured system is selected. By selecting an already configured
system from another federal entity, the department is also purchasing
the other entity's reengineered processes, which may or may not address
the DHS's mission and component needs.
DHS also provided technical comments on a draft of this report that we
have incorporated throughout the report, as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security, and other interested
parties. The report is available at no charge on the GAO Web site at
[hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report or wish to
discuss the matter further, please contact Kay L. Daly at (202) 512-
9095 or dalykl@gao.gov or Nabajyoti Barkakati at (202) 512-4499 or
barkakatin@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this
report. Other key contributors include Chris Martin, Senior Level
Technologist; Chanetta Reed, Assistant Director; Sandra Silzer; and
Michael Grimes.
Signed by:
Kay L. Daly:
Director:
Financial Management and Assurance:
Signed by:
Nabajyoti Barkakati:
Director:
Center for Technology and Engineering:
List of Congressional Addressees:
The Honorable David E. Price:
Chairman:
The Honorable Harold Rogers:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
House of Representatives:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Bennie G. Thompson:
Chairman:
Committee on Homeland Security:
House of Representatives:
The Honorable Robert C. Byrd:
Chairman:
The Honorable George V. Voinovich:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
United States Senate:
The Honorable Thomas R. Carper:
Chairman:
Subcommittee on Federal Financial Management, Government Information,
Federal Services, and International Security:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
[End of section]
Appendix I: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
[hyperlink, http://www.dhs.gov]
November 16, 2009:
Ms. Kay L. Daly:
Director:
Financial Management and Assurance:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Thank you for the opportunity to review and comment on the draft
Government Accountability Office's (GAO) report GAO-10-76, Financial
Management Systems: DHS Faces Challenges to Successfully Consolidate
Its Existing Disparate Systems.
The Department of Homeland Security (DHS) appreciates the guidance and
oversight that GAO has provided to strengthen the Transformation and
Systems Consolidation (TASC) program and looks forward to working
collaboratively with the GAO to successfully consolidate, modernize,
and integrate the Department's financial and business systems. The
Department agrees with the GAO recommendations and continues to make
significant progress against them, such as taking immediate action to
ensure the independence of the Verification and Validation function.
The Department appreciates that GAO recognizes progress on addressing
certain recommendations will not be made until after contract award.
However, the Department agrees it must be vigilant and disciplined in
its oversight and management of major acquisition projects, such as
TASC, to ensure their success.
Attached is a summary of the actions DHS has taken and plans to take to
continue to address the GAO recommendations. I appreciate the continued
support GAO has shown the Department and look forward to working with
you to make the TASC program a success. If you have any questions,
please feel free to contact me at (202) 447-5751.
Sincerely,
Signed by:
Peggy Sherry:
Acting Chief Financial Officer:
Enclosure:
[End of letter]
Following is a summary of the actions taken and planned to continue to
address the GAO recommendations discussed in the draft report GAO-10-
76, Financial Management Systems: DHS Faces Challenges to Successfully
Consolidate Its Existing Disparate Systems.
The purpose of the Transformation and Systems Consolidation (TASC)
project is to provide a Department-wide integrated financial,
acquisition and asset management system solution with standardized
business processes using a common DHS accounting structure. DHS plans
to procure a system solution that is operational in the federal space
and complies with the Financial Systems Integration Office (FSIO)
standard business processes. DHS is in the process of acquiring the
system solution and is on target to select a vendor by the second
quarter of fiscal year (FY) 2010. This project will enhance mission
support and improve the Department's ability to report accurate and
timely financial data.
Recommendation 1: Clearly define and document a department-wide
financial management strategy and plan to move forward with its
financial management system integration efforts.
Response: DHS has a clearly defined strategy and plan to move forward
with its financial management systems integration, articulated in
multiple business planning documents as required by the DES System
Engineering Lifecycle and Acquisition Review Board processes. For
example, the TASC Mission Needs Statement documents the DHS need to
take action to resolve serious shortfalls in our ability to
consistently and accurately track and report on our resources; the TASC
Operational Requirements Document (ORD) describes the operational
performance and related operational parameters for a consolidated
system solution. Additionally, the TASC Request for Proposals (RFP)
Statement of Objectives clearly describes the strategy for implementing
the TASC solution. The solution demonstration step of the proposal
evaluation process was a key part of our strategy to ensure the
solution will meet DHS requirements, support our business processes,
and mitigate the risks associated with significant system
customizations. The acquisition strategy is to award a five-year
indefinite delivery, indefinite quantity contract with five option
years to migrate to and support a consolidated system solution. The DHS
Chief Financial Officer (CFO) will centrally fund Component migrations,
lead the business process standardization groups to include internal
controls and the standard accounting line, and oversee organizational
change management.
Recommendation 2: Develop a comprehensive concept of operations
document.
Response: The Department acknowledges the importance of a well-written
Concept of Operations (ConOps) that describes the characteristics of
the system from the viewpoint of the user. DHS has developed a robust
ConOps, following the Institute of Electrical and Electronics Engineers
standard. As recommended by GAO, the TASC ConOps includes:
* an overview of current and future day-to-day financial management,
acquisition and asset operations;
* discussion of current Component systems and the process that will be
followed in implementing the system solution;
* a discussion of the roles of the stakeholders involved throughout the
process;
* a notional time and schedule for phased migration to the TASC
solution; and;
* costs for current financial management systems.
The ConOps establishes the overarching framework for the proposed
solution and allows for the inclusion of further system-specific
information once a solution is selected. The description of the
proposed system incorporates extensive component user input and is
comprised of operational scenarios for the proposed solution. The
overview of the proposed system in the ConOps also aligns with
requirements included in the RFP. To maintain a full and open
competition, the ConOps could not be tailored to a specific system
solution. The Resource Management Transformation Office (RMTO) serves
as the Program Management Office (PMO) for DHS and will update the
ConOps as needed during the system engineering life cycle, beginning
after contract award.
Recommendation 3: Utilize and implement these specific disciplined
processes to minimize project risk: (1) requirements management, (2)
testing, (3) data conversion and system interfaces, (4) risk
management, (5) configuration management, (6) project management, and
(7) quality assurance.
Response: The CFO agrees the success of TASC is predicated on having a
disciplined set of processes from requirements management to quality
assurance. DHS has begun to take action to establish specific
disciplined processes but additional work is required once the system
solution is selected. The following are specific areas where progress
has been made:
* Developed a governance plan and program management office charter,
which define the decision making and change control processes for the
program;
* Completed a Component engagement toolkit that defines a clear and
replicable engagement process with Components;
* Continuing to define the FSIO compliant business standardization
processes;
* Developing a standard accounting structure using the common
government-wide accounting classification elements; and;
* Completed the component systems architecture and inventory discovery
activities that describe the process for engaging Components in
understanding their core financial, asset, and acquisition systems'
enterprise architecture.
RMTO will develop additional processes for testing and configuration
management at later stages in the project life cycle. RMTO has hired a
full time, government Configuration Manager for the TASC effort. The
TASC initiative is supported by seasoned leadership with extensive
experience in systems migrations and data conversion. RMTO is
leveraging extensive lessons learned from financial management system
implementations at other Federal agencies. Additionally, since TASC
will be implemented in a phased migration approach, DHS will build upon
the successes and lessons learned with each subsequent migration and
will refine its repeatable methodology for each migration. DHS will use
lessons learned to refine contractor requirements in each subsequent
task order.
Recommendation 4: Reengineer business processes and standardize them
across the department, including applicable internal control.
Response: DHS has several efforts underway to make progress on this
recommendation. The Department has identified nine end-to-end business
processes that represent the full lifecycle of FSIO compliant core
financial, asset and acquisition management processes. Component-
specific business processes, gathered during the various phases prior
to and during the TASC acquisition process, will he addressed through
the detailed analysis prior to component migration. Additionally, the
Department has identified and initiated a comprehensive common
Government-wide Accounting Classification (CGAC) working group to
develop a standard DHS accounting line structure. The extensive work
done by the DHS Internal Controls PMO will be incorporated. The
proposed system solution must support these processes, which serve as
the core departmental financial management functions. Additionally, as
detailed in the TASC Business Process Standardization document, teams
from across DHS will work together to review and reengineer, as needed,
these nine processes, and standardize them for Department-wide
implementation. These processes will align to FSIO's process standards
and FSIO system requirements.
DHS has compared current component processes to the standard FSIO
processes and has begun identifying and resolving gaps. Additional
analysis is needed after the system solution is selected. Internal
controls are a focal point of TASC as the proposed systems must follow
OMB Circular A-123 objectives with system-controlled segregation of
duties to safeguard against unauthorized use or misappropriation. A-123
objectives include providing effectiveness and efficiency of
operations, reliability of financial reporting with transaction-level
detail, and compliance with applicable laws and regulations, such as
Federal Managers' Financial Integrity Act (FMFIA).
Recommendation 5: Develop a detailed plan for migrating and
consolidating various DHS components to an internal shared services
approach if this approach is sustained.
Response: DHS acknowledges the importance of developing a detailed
migration strategy which prioritizes component migrations to the system
solution and addresses known weaknesses prior to migration. The
Department has created a phased notional migration schedule and
conceptual migration approach and priorities. Once the system solution
is selected, the Department will update its notional schedule to create
a comprehensive migration schedule that aligns with the chosen
solution. Additionally, the TASC PMO developed a Component Engagement
Toolkit to map out a clear and repeatable engagement process with
Components, the PMO, CFO and Chief Information Officer (CIO). The PMO
team is leveraging the Toolkit to create Component Integrated Project
Teams to identify TASC partners in each Component and prepare
Components for the data clean-up and project planning work that will
occur.
Recommendation 6: Carefully consider key human capital practices as DHS
moves forward with its financial management transformation efforts so
that the right people with the right skills are in place at the right
time.
Response: The Department agrees with this recommendation and recognizes
that a strong, well-structured PMO is critical to implementing and
succeeding in financial management systems transformation. GAO
identified the need to ensure necessary contractor oversight mechanisms
are in place. Among other things, DHS learned from the eMerge2 program,
as well as other efforts, that diligent monitoring of contractor
performance with clearly defined deliverables is necessary for the
success of this project. As a result, DHS has taken steps to ensure
adequate staffing, including putting in place a team of full-time
federal employees with expertise in project management, systems
accounting, change management, acquisition management, business
intelligence, accounting services and systems to successfully manage
TASC.
While a contractor will be engaged to support the migration and
operations of the system solution, RMTO is responsible for setting
requirements and performance standards, and for actively monitoring and
overseeing contract execution. RMTO will monitor the contractor's
performance in several ways. First, contract task order requirements
will be established up front and will be performance based where the
successful execution of each task will be evaluated and managed against
established performance metrics. Each individual task order will begin
with a pre-task order award meeting which identifies clear deliverables
and measurements for success and end with a post-task order assessment.
Task orders will be monitored using standard practices such as a
Quality Assurance Surveillance Plan (QASP), Earned Value Management
Systems reports (EVMS), Service Level Agreements (SLAs), monthly
reporting, monthly invoices and task order close out reports. The QASP
defines acceptable quality levels and surveillance methodology that the
government will use to evaluate contractor performance. The government
will use monthly EVMS reports to track costs and schedule against work
completed. RMTO will also use FSIO performance metrics in defining SLAs
and measuring contractor performance. RMTO has taken a proactive
approach to planning for contractor management and plans to continue to
build the capabilities within the PMO.
To help build the right program office management structure, the
recommendations of an independent third party assessment of the PMO
structure was incorporated into staffing plans. Currently, RMTO staff
includes the following: one Level III Program Manager, thirteen Project
Management Professionals, fourteen Certified Contracting Officer
Technical Representatives, three Certified Public Accounts, five Level
II Program Managers, and five Level I Program Managers.
[End of section]
Footnotes:
[1] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[2] GAO, Homeland Security: Despite Progress, DHS Continues to Be
Challenged in Managing Its Multi-Billion Dollar Annual Investment in
Large-Scale Information Technology Systems, [hyperlink,
http://www.gao.gov/products/GAO-09-1002T] (Washington, D.C.: Sept. 15,
2009).
[3] The eMerge2project was expected to establish the strategic
direction for migration, modernization, and integration of DHS's
financial, accounting, procurement, personnel, asset management, and
travel systems, processes, and policies.
[4] Statement by Scott Charbo, Chief Information Officer, and Eugene
Schied, Deputy Chief Financial Officer, Department of Homeland
Security, March 29, 2006.
[5] GAO, Homeland Security: Departmentwide Integrated Financial
Management Systems Remain a Challenge, [hyperlink,
http://www.gao.gov/products/GAO-07-536] (Washington, D.C.: June 21,
2007), and Homeland Security: Transforming Departmentwide Financial
Management Systems Remains a Challenge, [hyperlink,
http://www.gao.gov/products/GAO-07-1041T] (Washington, D.C.: June 28,
2007).
[6] Disciplined processes represent best practices in systems
development and implementation efforts that have been shown to reduce
the risks associated with software development and acquisition efforts
to acceptable levels and are fundamental to successful system
implementations.
[7] The use of the term "acceptable levels" acknowledges the fact that
any systems acquisition has risks and can suffer the adverse
consequences associated with defects.
[8] The mandate is in House Report No. 110-862, Homeland Security
Appropriation Bill, 2009, (H.R. 6947), Title I, Departmental Management
and Operations, Financial System Transformation, at p. 21 (Sept. 18,
2008).
[9] GAO, Financial Management Systems: DHS Faces Challenges to
Successfully Consolidate Its Existing Disparate Systems, [hyperlink,
http://www.gao.gov/products/GAO-10-210T] (Washington, D.C.: Oct. 29,
2009).
[10] Oracle Federal Financials was already in use within the U.S. Coast
Guard, the Transportation Security Administration, and the Domestic
Nuclear Detection Office. SAP was already in use within U.S. Customs
and Border Protection.
[11] [hyperlink, http://www.gao.gov/products/GAO-07-536].
[12] GAO, Business Modernization: Improvements Needed in Management of
NASA's Integrated Financial Management Program, [hyperlink,
http://www.gao.gov/products/GAO-03-507] (Washington, D.C.: Apr. 30,
2003), and DOD Business Systems Modernization: Navy ERP Adherence to
Best Business Practices Critical to Avoid Past Failures,[hyperlink,
http://www.gao.gov/products/GAO-05-858] (Washington, D.C.: Sept. 29,
2005).
[13] A gap analysis is an evaluation performed to identify the gaps
between needs and system capabilities.
[14] Software Engineering Institute, Rules of Thumb for the Use of COTS
Products, CMU/SEI-2002-TR-032 (Pittsburgh: December 2002).
[15] Department of Defense, Commercial Item Acquisition: Considerations
and Lessons Learned (Washington, D.C., June 26, 2000).
[16] IEEE Guide for Information Technology - System Definition -
Concept of Operations (ConOps) Document, Standard 1362-1998.
[17] IEEE Standard 1362-1998.
[18] According to the Software Engineering Institute, requirements
management is a process that establishes a common understanding between
the customer and the software project manager regarding the customer's
business needs that will be addressed by a project. A critical part of
this process is to ensure that the requirements development portion of
the effort documents, at a sufficient level of detail, the problems
that need to be solved and the objectives that need to be achieved.
[19] Data conversion is defined as the modification of existing data to
enable them to operate with similar functional capability in a
different environment.
[20] Testing is the process of executing a program with the intent of
finding errors.
[21] [hyperlink, http://www.gao.gov/products/GAO-05-858].
[22] An ERP solution is an automated system using COTS software
consisting of multiple, integrated functional modules that perform a
variety of business-related tasks such as payroll, general ledger
accounting, and supply chain management.
[23] As we later reported, the Navy had later effectively implemented
an important requirements management activity, traceability, in its
ERP.
[24] These nine processes are Request to Procure, Procure to Pay,
Acquire to Dispose, Bill to Collect, Record to Report, Budget
Formulation to Execution, Grants Management, Business Intelligence
Reporting, and Reimbursable Management.
[25] According to Office of Management and Budget guidance, an FTE or
work year generally includes 260 compensable days or 2,080 hours. These
hours include straight-time hours only and exclude overtime and holiday
hours.
[26] Institute of Electrical and Electronics Engineers Standard 1012-
2004--Standard for Software Verification and Validation (June 8, 2005)
states that the verification and validation processes for projects are
used to determine whether (1) the products of a given activity conform
to the requirements of that activity and (2) the software satisfies its
intended use and user needs. This determination may include analyzing,
evaluating, reviewing, inspecting, assessing, and testing software
products and processes. The verification and validation processes
should assess the software in the context of the system, including the
operational environment, hardware, interfacing software, operators, and
users.
[27] The Deepwater Program, using a system-of-systems approach, is
intended to recapitalize the U.S. Coast Guard's fleet and includes
efforts to build or modernize five classes each of ships and aircraft
and procure other key capabilities.
[28] GAO, Coast Guard: Change in Course Improves Deepwater Management
and Oversight, but Outcome Still Uncertain, [hyperlink,
http://www.gao.gov/products/GAO-08-745] (Washington, D.C.: June 24,
2008).
[29] U.S. Coast Guard leadership has increased accountability by
bringing the Deepwater Program in-house and restructuring its
acquisition function and vesting its government project managers with
responsibilities formally held by the system integrator. U.S. Coast
Guard project managers are now responsible for defining, planning, and
executing the acquisition projects within established cost, schedule,
and performance constraints.
[30] Department of Homeland Security, Office of Inspector General,
Better Oversight Needed of Support Services Contractors in Secure
Border Initiative Programs, OIG-09-80 (Washington, D.C., June 17,
2009).
[31] COTRs are responsible for monitoring the contractors' progress in
fulfilling the technical requirements specified in the contracts. COTRs
often approve invoices submitted by contractors for payment.
[32] To provide this objective evidence, V&V contractors analyze,
evaluate, review, inspect, assess, and test software products and
processes.
[End of section]
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