Coast Guard
Observations on Changes to Management and Oversight of the Deepwater Program
Gao ID: GAO-09-462T March 24, 2009
GAO has a large body of work examining government agencies' approaches to managing their large acquisition projects. GAO has noted that without sufficient knowledge about system requirements, technology, and design maturity, programs are subject to cost overruns, schedule delays, and performance that does not meet expectations. The Deepwater Program, intended to replace or modernize 15 major classes of Coast Guard assets, accounts for almost 60 percent of the Coast Guard's fiscal year 2009 appropriation for acquisition, construction and improvements. GAO has reported over the years on this program, which has experienced serious performance and management problems such as cost breaches, schedule slips, and assets designed and delivered with significant defects. To carry out the Deepwater acquisition, the Coast Guard contracted with Integrated Coast Guard Systems (ICGS) as a systems integrator. In April 2007, the Commandant acknowledged that the Coast Guard had relied too heavily on contractors to do the work of government and announced that the Coast Guard was taking over the lead role in systems integration from ICGS. This testimony reflects our most recent issued work on Deepwater, specifically our June 2008 report, Coast Guard: Change in Course Improves Deepwater Management and Oversight, but Outcome Still Uncertain, GAO-08-745.
Over the past two years, the Coast Guard has reoriented its acquisition function to position itself to execute systems integration and program management responsibilities formerly carried out by ICGS. The acquisition directorate has been consolidated to oversee all Coast Guard acquisitions, including the Deepwater Program, and Coast Guard project managers have been vested with management and oversight responsibilities formerly held by ICGS. Another key change has been to manage the procurement of Deepwater assets on a more disciplined, asset-by-asset approach rather than as an overall system of systems, where visibility into requirements and capabilities was limited. For example, cost and schedule information is now captured at the individual asset level, resulting in the ability to track and report breaches for assets. Further, to manage Deepwater acquisitions at the asset level, the Coast Guard has begun to follow a disciplined project management process that requires documentation and approval of program activities at key points in a program's life cycle. These process changes, coupled with strong leadership to help ensure the processes are followed in practice, have helped to improve Deepwater management and oversight. However, the Coast Guard still faces many hurdles going forward and the acquisition outcome remains uncertain. The consequences of not following a disciplined acquisition approach for Deepwater acquisitions and of relying on the contractor to define Coast Guard requirements are clear now that assets, such as the National Security Cutter, have been paid for and delivered without the Coast Guard's having determined whether the assets' planned capabilities would meet mission needs. While the asset-based approach is beneficial, certain cross-cutting aspects of Deepwater--such as command, control, communications, computers, intelligence, surveillance, and reconnaissance (C4ISR) and the overall numbers of each asset needed to meet requirements--still require a system-level approach. The Coast Guard is not fully positioned to manage these aspects. One of the reasons the Coast Guard originally contracted with ICGS as the systems integrator was the recognition that the Coast Guard lacked the experience and depth in workforce to manage the acquisition itself. The Coast Guard has faced challenges in building an adequate government acquisition workforce and, like many other federal agencies, is relying on support contractors--some in key positions such as cost estimating and contract support. GAO has pointed out the potential concerns of reliance on contractors who closely support inherently governmental functions.
GAO-09-462T, Coast Guard: Observations on Changes to Management and Oversight of the Deepwater Program
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Testimony:
Before the Subcommittee on Coast Guard and Maritime Transportation,
Committee on Transportation and Infrastructure, House of
Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Tuesday, March 24, 2009:
Coast Guard:
Observations on Changes to Management and Oversight of the Deepwater
Program:
Statement of John P. Hutton, Director:
Acquisition and Sourcing Management:
GAO-09-462T:
GAO Highlights:
Highlights of GAO-09-462T, a testimony before the Subcommittee on Coast
Guard and Maritime Transportation, Committee on Transportation and
Infrastructure, House of Representatives.
Why GAO Did This Study:
GAO has a large body of work examining government agencies‘ approaches
to managing their large acquisition projects. GAO has noted that
without sufficient knowledge about system requirements, technology, and
design maturity, programs are subject to cost overruns, schedule
delays, and performance that does not meet expectations.
The Deepwater Program, intended to replace or modernize 15 major
classes of Coast Guard assets, accounts for almost 60 percent of the
Coast Guard‘s fiscal year 2009 appropriation for acquisition,
construction and improvements. GAO has reported over the years on this
program, which has experienced serious performance and management
problems such as cost breaches, schedule slips, and assets designed and
delivered with significant defects.
To carry out the Deepwater acquisition, the Coast Guard contracted with
Integrated Coast Guard Systems (ICGS) as a systems integrator. In April
2007, the Commandant acknowledged that the Coast Guard had relied too
heavily on contractors to do the work of government and announced that
the Coast Guard was taking over the lead role in systems integration
from ICGS.
This testimony reflects our most recent issued work on Deepwater,
specifically our June 2008 report, Coast Guard: Change in Course
Improves Deepwater Management and Oversight, but Outcome Still
Uncertain, GAO-08-745.
What GAO Found:
Over the past two years, the Coast Guard has reoriented its acquisition
function to position itself to execute systems integration and program
management responsibilities formerly carried out by ICGS. The
acquisition directorate has been consolidated to oversee all Coast
Guard acquisitions, including the Deepwater Program, and Coast Guard
project managers have been vested with management and oversight
responsibilities formerly held by ICGS. Another key change has been to
manage the procurement of Deepwater assets on a more disciplined, asset-
by-asset approach rather than as an overall system of systems, where
visibility into requirements and capabilities was limited. For example,
cost and schedule information is now captured at the individual asset
level, resulting in the ability to track and report breaches for
assets. Further, to manage Deepwater acquisitions at the asset level,
the Coast Guard has begun to follow a disciplined project management
process that requires documentation and approval of program activities
at key points in a program‘s life cycle.
These process changes, coupled with strong leadership to help ensure
the processes are followed in practice, have helped to improve
Deepwater management and oversight. However, the Coast Guard still
faces many hurdles going forward and the acquisition outcome remains
uncertain.
* The consequences of not following a disciplined acquisition approach
for Deepwater acquisitions and of relying on the contractor to define
Coast Guard requirements are clear now that assets, such as the
National Security Cutter, have been paid for and delivered without the
Coast Guard‘s having determined whether the assets‘ planned
capabilities would meet mission needs.
* While the asset-based approach is beneficial, certain cross-cutting
aspects of Deepwater”such as command, control, communications,
computers, intelligence, surveillance, and reconnaissance (C4ISR) and
the overall numbers of each asset needed to meet requirements”still
require a system-level approach. The Coast Guard is not fully
positioned to manage these aspects.
* One of the reasons the Coast Guard originally contracted with ICGS as
the systems integrator was the recognition that the Coast Guard lacked
the experience and depth in workforce to manage the acquisition itself.
The Coast Guard has faced challenges in building an adequate government
acquisition workforce and, like many other federal agencies, is relying
on support contractors”some in key positions such as cost estimating
and contract support. GAO has pointed out the potential concerns of
reliance on contractors who closely support inherently governmental
functions.
View [hyperlink, http://www.gao.gov/products/GAO-09-462T] or key
components. For more information, contact John P. Hutton at (202) 512-
4841 orhuttonj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I appreciate the opportunity to be here today to discuss Coast Guard
acquisitions, specifically its Deepwater Program, the largest
acquisition in the Coast Guard's history. GAO has a significant body of
work examining government agencies' approaches to managing their large
acquisition projects, including Department of Defense weapon systems,
Department of Homeland Security (DHS) major investments, and large,
high-risk information technology investments across the government. We
have pointed to the need for more discipline and accountability in the
acquisition process to help ensure that programs are not initiated
until sufficient knowledge exists about system requirements,
technology, and design maturity. Without this knowledge, programs are
subject to cost overruns, schedule delays, and performance
deficiencies. The Deepwater Program represents the largest portion of
the Coast Guard's appropriation for acquisition, construction, and
improvements--almost 60 percent in fiscal year 2009.[Footnote 1]
Unfortunately, Deepwater has experienced serious performance and
management problems such as cost breaches, schedule slips, and assets
designed and delivered with significant defects.
The Deepwater Program is intended to replace or modernize 15 major
classes of Coast Guard assets--five each of vessels and aircraft, and
five other projects, including command, control, communications,
computers, intelligence, surveillance, and reconnaissance (C4ISR)
systems. To carry out this acquisition, the Coast Guard awarded a
contract in June 2002 to Integrated Coast Guard Systems (ICGS), a joint
venture formed by Lockheed Martin Corporation and Northrop Grumman Ship
Systems, as a systems integrator. In April 2007, the Coast Guard
Commandant acknowledged that the Coast Guard had relied too heavily on
contractors to do the work of government and that government and
industry had failed to control costs. He announced several major
changes to the acquisition approach to Deepwater, the key one being
that the Coast Guard was taking over the lead role in systems
integration from ICGS, with future work on individual assets
potentially bid competitively outside of the existing contract.
My statement today will focus on the progress the Coast Guard has made
in improving its acquisition approach to the Deepwater Program and the
challenges it continues to face. We have ongoing work on Deepwater
acquisitions issues--specifically, the Coast Guard's acquisition
workforce, the cost of the Deepwater Program, and challenges associated
with C4ISR and other "system-of-systems" aspects--for the House and
Senate appropriations committees and expect to issue a report later
this summer. We also have ongoing work for the same committees
examining the potential operational gaps the Coast Guard may encounter
based on delays in delivery of the National Security Cutter (NSC) and
its accompanying package of small boats and unmanned aircraft systems;
the Coast Guard's mitigation strategies for addressing these potential
gaps; and how the Coast Guard plans to handle maintenance of the NSC
while still operating and maintaining its legacy high endurance
cutters. That report is also expected to be issued this summer.
This statement is based on our issued work on the Coast Guard's
Deepwater Program, specifically the information in our June 2008
report, Coast Guard: Change in Course Improves Deepwater Management and
Oversight, but Outcome Still Uncertain.[Footnote 2] That work was
conducted in accordance with generally acceptable government audit
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.
Background:
The Coast Guard is a multimission, maritime military service within
DHS. The Coast Guard's responsibilities fall into two general
categories--those related to homeland security missions, such as port
security and vessel escorts, and those related to non-homeland security
missions, such as search and rescue and polar ice operations. To carry
out these responsibilities, the Coast Guard operates a number of
vessels and aircraft and, through its Deepwater Program, is currently
modernizing or replacing those assets. At the start of Deepwater in the
late 1990s, the Coast Guard chose to use a system of systems
acquisition strategy that was intended to replace the assets with a
single, integrated package of aircraft, vessels, and communications
systems. As the systems integrator, ICGS was responsible for designing,
constructing, deploying, supporting, and integrating the assets. The
decision to use a systems integrator for the Deepwater Program was
driven in part because of the Coast Guard's lack of expertise in
managing and executing an acquisition of this magnitude. Under this
approach, the Coast Guard provided the contractor with broad, overall
performance specifications--such as the ability to interdict illegal
immigrants--and ICGS determined the specifications for the Deepwater
assets. According to Coast Guard officials, the ICGS proposal was
submitted and priced as a package; that is, the Coast Guard bought the
entire solution and could not reject any individual component.
Deepwater assets are in various stages of the acquisition process.
Some, such as the NSC and Maritime Patrol Aircraft, are in production.
Others, such as the Fast Response Cutter, are in design, and still
others, such as the Offshore Patrol Cutter, are in the early stages of
requirements definition.
Coast Guard Has Made Improvements but Faces Continued Challenges in
Managing Deepwater Acquisitions:
Since the Commandant's April 2007 announcement that the Coast Guard was
taking over the lead role in systems integration from ICGS, the Coast
Guard has undertaken several initiatives that have increased
accountability for Deepwater outcomes within the Coast Guard and to
DHS. The Coast Guard's Blueprint for Acquisition Reform sets forth a
number of objectives and specific tasks with the intent of improving
acquisition processes and results. Its overarching goal is to enhance
the Coast Guard's mission execution through improved contracting and
acquisition approaches. One key effort in this regard was the July 2007
consolidation of the Coast Guard's acquisition responsibilities--
including the Deepwater Program--into a single acquisition directorate.
Previously, Deepwater assets were managed independently of other Coast
Guard acquisitions within an insulated structure. The Coast Guard has
also vested its government project managers with management and
oversight responsibilities formerly held by ICGS.
The Coast Guard is also now managing Deepwater under an asset-based
approach, rather than as an overall system-of-systems as initially
envisioned. This approach has resulted in increased government control
and visibility. For example, cost and schedule information is now
captured at the individual asset level, resulting in the ability to
track and report cost breaches for assets.[Footnote 3] Under the prior
structure, a cost breach was to be tracked at the overall Deepwater
Program level, and the threshold was so high that a breach would have
been triggered only by a catastrophic event.
To manage Deepwater acquisitions at the asset level, the Coast Guard
has begun to follow a disciplined project management process using the
framework set forth in its Major Systems Acquisition Manual. This
process requires documentation and approval of program activities at
key points in a program's life cycle. The process begins with
identification of deficiencies in Coast Guard capabilities and then
proceeds through a series of structured phases and decision points to
identify requirements for performance, develop and select candidate
systems that meet those requirements, demonstrate the feasibility of
selected systems, and produce a functional capability. Previously, the
Coast Guard authorized the Deepwater Program to deviate from the
structured acquisition process, stating that the requirements of the
process were not appropriate for the Deepwater system-of-systems
approach. Instead, Deepwater Program reviews were required on a
schedule-driven--as opposed to the current event-driven--basis.
Further, leadership at DHS is now formally involved in reviewing and
approving key acquisition decisions for Deepwater assets. We reported
in June 2008 that DHS approval of Deepwater acquisition decisions as
part of its investment review process was not required, as the
department had deferred decisions on specific assets to the Coast Guard
in 2003. We recommended that the Secretary of DHS direct the Under
Secretary for Management to rescind the delegation of Deepwater
acquisition decision authority. In September 2008, the Under Secretary
took this step, so that Deepwater acquisitions are now subject to the
department's investment review process, which calls for executive
decision making at key points in an investment's life cycle.
We also reported this past fall, however, that DHS had not effectively
implemented or adhered to this investment review process; consequently,
the department had not provided the oversight needed to identify and
address cost, schedule, and performance problems in its major
investments.[Footnote 4] Without the appropriate reviews, DHS loses the
opportunity to identify and address cost, schedule, and performance
problems and, thereby, minimize program risk. We reported that 14 of
the department's investments that lacked appropriate review experienced
cost growth, schedule delays, and underperformance--some of which were
substantial. Other programs within DHS have also experienced cost
growth and schedule delays. For example, we reported in July 2008 that
the Coast Guard's Rescue 21 system was projected to experience cost
increases of 184 percent and schedule delays of 5 years after
rebaselining.[Footnote 5] DHS issued a new interim management directive
on November 7, 2008, that addresses many of our findings and
recommendations on the department's major investments. If implemented
as intended, the more disciplined acquisition and investment review
process outlined in the directive will help ensure that the
department's largest acquisitions, including Deepwater, are effectively
overseen and managed.
Consequences of Prior Deepwater Acquisition Approach May Be Costly:
While the decision to follow the Major Systems Acquisition Manual
process for Deepwater assets is promising, the consequences of not
following this acquisition approach in the past--when the contractor
managed the overall acquisition--are now apparent for assets already in
production, such as the NSC, and are likely to pose continued problems,
such as increased costs. Because ICGS had determined the overall
Deepwater solution, the Coast Guard had not ensured traceability from
identification of mission needs to performance specifications for the
Deepwater assets. In some cases it is already known that the ICGS
solution does not meet Coast Guard needs, for example:
* The Coast Guard accepted the ICGS-proposed performance specifications
for the long-range interceptor, a small boat intended to be launched
from larger cutters such as the NSC, with no assurance that the boat it
was buying was what was needed to accomplish its missions. Ultimately,
after a number of design changes and a cost increase from $744,621 to
almost $3 million, the Coast Guard began to define for itself the
capabilities it needed and has decided not to buy any more of the ICGS
boats.
* ICGS had initially proposed a fleet of 58 fast response cutters,
subsequently termed the Fast Response Cutter-A (FRC-A), which were to
be constructed of composite materials (as opposed to steel, for
example). However, the Coast Guard suspended design work on the FRC-A
in February 2006 to assess and mitigate technical risks. Ultimately,
because of high risk and uncertain cost savings, the Coast Guard
decided not to pursue the acquisition, a decision based largely on a
third-party analysis that found the composite technology was unlikely
to meet the Coast Guard's desired 35-year service life. After
obligating $35 million to ICGS for the FRC-A, the Coast Guard pursued a
competitively awarded fast response cutter based on a modified
commercially available patrol boat. That contract was awarded in
September 2008.
System-Level Aspects Pose Additional Challenges under Revised
Acquisition Approach:
Although the shift to individual acquisitions is intended to provide
the Coast Guard with more visibility and control, key aspects still
require a system-level approach. These aspects include an integrated
C4ISR system--needed to provide critical information to field
commanders and facilitate interoperability with the Department of
Defense and DHS--and decisions on production quantities of each
Deepwater asset the Coast Guard requires to achieve its missions. The
Coast Guard is not fully positioned to manage these aspects under its
new acquisition approach but is engaged in efforts to do so.
C4ISR is a key aspect of the Coast Guard's ability to meet its
missions. How the Coast Guard structures C4ISR is fundamental to the
success of the Deepwater Program because C4ISR encompasses the
connections among surface, aircraft, and shore-based assets and the
means by which information is communicated through them. C4ISR is
intended to provide operationally relevant information to Coast Guard
field commanders to allow the efficient and effective execution of
their missions. However, an acquisition strategy for C4ISR is still in
development. Officials stated that the Coast Guard is revisiting the
C4ISR incremental acquisition approach proposed by ICGS and analyzing
that approach's requirements and architecture. In the meantime, the
Coast Guard is continuing to acquire C4ISR through ICGS.
As the Coast Guard transitions from the ICGS-based system-of-systems
acquisition strategy to an asset-based approach, it will need to
maintain a strategic outlook to determine how many of the various
Deepwater assets to procure to meet Coast Guard needs. When deciding
how many of a specific vessel or aircraft to procure, it is important
to consider not only the capabilities of that asset, but how it can
complement or duplicate the capabilities of the other assets with which
it is intended to operate. To that end, the Coast Guard is modeling the
planned capabilities of Deepwater assets, as well as the capabilities
and operations of existing assets, against the requirements for Coast
Guard missions. The intent of this modeling is to test each planned
asset to ensure that its capabilities fill stated deficiencies in the
Coast Guard's force structure and to inform how many of a particular
asset are needed. However, the analysis based on the modeling is not
expected to be completed until the summer of 2009. In the meantime,
Coast Guard continues to plan for asset acquisitions in numbers very
similar to those determined by ICGS, such as 8 NSCs.
Challenges in Building an Acquisition Workforce:
Like many federal agencies that acquire major systems, the Coast Guard
faces challenges in recruiting and retaining a sufficient government
acquisition workforce. In fact, one of the reasons the Coast Guard
originally contracted with ICGS as a systems integrator was the
recognition that the Coast Guard lacked the experience and depth in its
workforce to manage the acquisition itself.
The Coast Guard's 2008 acquisition human capital strategic plan sets
forth a number of workforce challenges that pose the greatest threats
to acquisition success, including a shortage of civilian acquisition
staff, its military personnel rotation policy, and the lack of an
acquisition career path for its military personnel. The Coast Guard has
taken a number of steps to hire more acquisition professionals,
including the increased use of recruitment incentives and relocation
bonuses, utilizing direct hire authority, and rehiring government
annuitants. The Coast Guard also recognizes the impact of military
personnel rotation on its ability to retain people in key positions.
Its policy of 3-year rotations of military personnel among units,
including to and from the acquisition directorate, limits continuity in
key project roles and can have a serious impact on acquisition
expertise. While the Coast Guard concedes that it does not have the
personnel required to form a dedicated acquisition career field for
military personnel, such as that found in the Navy, it is seeking to
improve the base of acquisition knowledge throughout the Coast Guard by
exposing more officers to acquisition as they follow their regular
rotations.
In the meantime, the lack of a sufficient government acquisition
workforce means that the Coast Guard is relying on contractors to
supplement government staff, often in key positions such as cost
estimators, contract specialists, and program management support. While
support contractors can provide a variety of essential services, when
they are performing certain activities that closely support inherently
governmental functions their use must be carefully overseen to ensure
that they do not perform inherently governmental roles. Conflicts of
interest, improper use of personal services contracts, and increased
costs are also potential concerns of reliance on contractors.[Footnote
6]
Concluding Observations:
In response to significant problems in achieving its intended outcomes
under the Deepwater Program, the Coast Guard leadership has made a
major change in course in its management and oversight by re-organizing
its acquisition directorate, moving away from the use of a contractor
as the systems integrator, and putting in place a structured, more
disciplined acquisition approach for Deepwater assets. While the
initiatives the Coast Guard has underway have begun to have a positive
impact, the extent and duration of this impact depend on positive
decisions that continue to increase and improve government management
and oversight.
Mr. Chairman, this concludes my prepared statement. I will be pleased
to answer any questions you or members of the subcommittee may have at
this time.
GAO Contact:
For further information about this testimony, please contact John P.
Hutton, Director, at 202-512-4841 or huttonj@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this testimony.
[End of section]
Footnotes:
[1] The Coast Guard's fiscal year 2009 appropriation includes an
additional $300 million for acquisition, construction, and improvements
for necessary expenses related to the consequences of 2008 natural
disasters and flooding. In addition, the American Recovery and
Reinvestment Act of 2009, signed into law on February 17, 2009,
authorized $98 million for the Coast Guard to spend on, among other
things, "priority procurements due to materials and labor cost
increases." The Coast Guard is required to submit an expenditure plan
to Congress within 45 days after enactment.
[2] 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).
[3] DHS requires cost breaches of 8 percent or higher to be reported to
the department.
[4] GAO, Department of Homeland Security: Billions Invested in Major
Programs Lack Appropriate Oversight, [hyperlink,
http://www.gao.gov/products/GAO-09-29] (Washington, D.C.: Nov. 18,
2008).
[5] See GAO, Information Technology: Agencies Need to Establish
Comprehensive Policies to Address Changes to Projects' Cost, Schedule,
and Performance Goals, [hyperlink, http://www.gao.gov/products/GAO-08-
925] (Washington, D.C.: July 31, 2008). Rescue 21 is a command,
control, and communication system that improves mission execution in
coastal zones to help the Coast Guard meet its search and rescue
program goals. It is intended to result in improved response to
distress calls and better coordination and interoperability with other
government agencies and first responders.
[6] The issue of support contractors in acquisition is not unique to
the Coast Guard. In our March 2008 report on the acquisition of major
weapons systems in the Department of Defense, we found that it too
relies heavily on contractors to perform roles in program management,
cost estimation, and engineering and technical functions. GAO, Defense
Acquisitions: Assessments of Major Weapons Programs, [hyperlink,
http://www.gao.gov/products/GAO-08-467SP] (Washington, D.C.: Mar. 31,
2008).
[End of section]
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