Information Technology
HUD Needs to Better Define Commitments and Disclose Risks for Modernization Projects in Future Expenditure Plans
Gao ID: GAO-11-72 November 23, 2010
In Process
The extent to which the fiscal year 2010 HUD expenditure plan met statutory conditions placed on the use of appropriated funds varied by IT modernization project. Specifically, the plan varied in the degree to which it described capabilities, expected mission benefits, estimated lifecycle costs, and key milestones for each of its eight modernization projects. Overall, however, it did not adequately satisfy all elements of the first of two conditions. For example, the plan described the expected mission benefits for three projects, but did not present specific and measurable benefits for the other five. Moreover, the plan, in combination with project management documentation, did not satisfy the second statutory condition that each project demonstrate that it is compliant with HUD's enterprise architecture, being managed in accordance with applicable lifecycle management policies, subject to HUD's capital planning and control requirements, and supported by an adequately staffed project office. Specifically, neither of the two projects assessed by GAO fully satisfied more than one of the elements of this condition. Officials attributed limitations in the plan's scope and content to the department's interpretation of the statutory requirements, as well as the unavailability of certain project documentation, and they stated that more detailed information would be included in future plans. Nevertheless, the plan is limited as a congressional oversight and decision-making mechanism. HUD has a range of actions under way to address GAO's prior recommendations and to evolve and strengthen its IT modernization management capabilities. However, it has yet to institutionalize these controls. Officials attributed the state of its controls largely to the fact that its new IT leadership team had only recently been established, and it is still in the process of introducing management improvements. Specifically, HUD (1) is redefining its enterprise architecture around core business functions, which is consistent with its modernization plans. However, the development of this new version has yet to commence, and HUD has not established a date for when it will be available. (2) has developed a conceptual construct for a new investment and lifecycle management framework, but is still developing the policies and process guidance needed to understand and consistently implement it. (3) is developing an approach to controlling investment portfolios and expects to begin implementing this approach by October 2010. (4) has begun developing a strategic IT human capital management plan, but it has not yet defined skill gap closure strategies and established milestones for completing and implementing the plan. The absence of institutionalized controls introduces risk to the success of HUD's modernization projects, and to the extent that future plans provide for expanded investment in the existing eight projects and additional ones, the risks associated with HUD's modernization efforts will increase. GAO is recommending that HUD ensure that future expenditure plans (1) fully satisfy all statutory conditions or disclose why any condition is not satisfied, along with any associated project risks and mitigation plans; and (2) describe the status of HUD's efforts to institutionalize key modernization management controls. GAO is also recommending that the number and scope of HUD's IT projects reflect the department's institutional capacity to manage them. In written comments on a draft of this report, HUD concurred with GAO's recommendations.
GAO-11-72, Information Technology: HUD Needs to Better Define Commitments and Disclose Risks for Modernization Projects in Future Expenditure Plans
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United States Government Accountability Office:
GAO:
Report to Congressional Committees:
November 2010:
Information Technology:
HUD Needs to Better Define Commitments and Disclose Risks for
Modernization Projects in Future Expenditure Plans:
Information Technology:
GAO-11-72:
GAO Highlights:
Highlights of GAO-11-72, a report to congressional committees.
Why GAO Did This Study:
Information technology (IT) is critical to the Department of Housing
and Urban Development‘s (HUD) ability to carry out its home ownership
and community development mission. By statutory mandate, HUD is to
develop and submit to Congress an expenditure plan for its efforts to
modernize the department‘s IT environment that satisfies certain
conditions, including being reviewed by GAO. GAO‘s objectives were to
determine the extent to which (1) HUD‘s expenditure plan meets
statutory conditions and (2) HUD has in place key institutional IT
modernization management capabilities. To accomplish this, GAO
assessed the plan against the statutory conditions and assessed
department documentation of efforts to institutionalize IT
modernization management capabilities against open GAO recommendations.
What GAO Found:
The extent to which the fiscal year 2010 HUD expenditure plan met
statutory conditions placed on the use of appropriated funds varied by
IT modernization project. Specifically, the plan varied in the degree
to which it described capabilities, expected mission benefits,
estimated lifecycle costs, and key milestones for each of its eight
modernization projects. Overall, however, it did not adequately
satisfy all elements of the first of two conditions. For example, the
plan described the expected mission benefits for three projects, but
did not present specific and measurable benefits for the other five.
Moreover, the plan, in combination with project management
documentation, did not satisfy the second statutory condition that
each project demonstrate that it is compliant with HUD‘s enterprise
architecture, being managed in accordance with applicable lifecycle
management policies, subject to HUD‘s capital planning and control
requirements, and supported by an adequately staffed project office.
Specifically, neither of the two projects assessed by GAO fully
satisfied more than one of the elements of this condition. Officials
attributed limitations in the plan‘s scope and content to the department
‘s interpretation of the statutory requirements, as well as the
unavailability of certain project documentation, and they stated that
more detailed information would be included in future plans.
Nevertheless, the plan is limited as a congressional oversight and
decision-making mechanism.
HUD has a range of actions under way to address GAO‘s prior
recommendations and to evolve and strengthen its IT modernization
management capabilities. However, it has yet to institutionalize these
controls. Officials attributed the state of its controls largely to
the fact that its new IT leadership team had only recently been
established, and it is still in the process of introducing management
improvements. Specifically, HUD:
* is redefining its enterprise architecture around core business
functions, which is consistent with its modernization plans. However,
the development of this new version has yet to commence, and HUD has
not established a date for when it will be available.
* has developed a conceptual construct for a new investment and
lifecycle management framework, but is still developing the policies
and process guidance needed to understand and consistently implement
it.
* is developing an approach to controlling investment portfolios and
expects to begin implementing this approach by October 2010.
* has begun developing a strategic IT human capital management plan,
but it has not yet defined skill gap closure strategies and
established milestones for completing and implementing the plan.
The absence of institutionalized controls introduces risk to the
success of HUD‘s modernization projects, and to the extent that future
plans provide for expanded investment in the existing eight projects
and additional ones, the risks associated with HUD‘s modernization
efforts will increase.
What GAO Recommends:
GAO is recommending that HUD ensure that future expenditure plans (1)
fully satisfy all statutory conditions or disclose why any condition
is not satisfied, along with any associated project risks and
mitigation plans; and (2) describe the status of HUD‘s efforts to
institutionalize key modernization management controls. GAO is also
recommending that the number and scope of HUD‘s IT projects reflect
the department‘s institutional capacity to manage them. In written
comments on a draft of this report, HUD concurred with GAO‘s
recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-11-72] or key
components. For more information, contact Randolph C. Hite at (202)
512-3439 or hiter@gao.gov.
[End of section]
Contents:
Letter:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Briefing for Staff Members of the Subcommittees on
Transportation, Housing and Urban Development, and Related Agencies,
Senate and House Committees on Appropriations:
Appendix II: Comments from the Department of Housing and Urban
Development:
Appendix III: GAO Contact and Staff Acknowledgments:
Abbreviations:
CIO: chief information officer:
EA: enterprise architecture:
FHA: Federal Housing Administration:
HUD: Department of Housing and Urban Development:
IT: information technology:
NGVMS: Next Generation Voucher Management System:
OCIO: Office of the Chief Information Officer:
[End of section]
November 23, 2010:
The Honorable Patty Murray:
Chair:
The Honorable Christopher Bond:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development, and
Related Agencies:
Committee on Appropriations:
United States Senate:
The Honorable John W. Olver:
Chairman:
The Honorable Tom Latham:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development, and
Related Agencies:
Committee on Appropriations:
House of Representatives:
The Department of Housing and Urban Development (HUD) submitted to
Congress on April 26, 2010, the first of a planned series of
incremental expenditure plans for information technology (IT)
modernization pursuant to the provisions in the Consolidated
Appropriations Act, 2010.[Footnote 1] IT plays a critical role in
HUD's ability to carry out its home ownership and community
development mission. For instance, the department reports that its
business areas rely on IT to process over 50,000 loan requests per
week, over 12,000 service calls per month, and more than 7,000 grant
requests annually for each of its grant programs. Despite this role,
HUD's current IT environment does not effectively support its ongoing
business operations. As we recently reported,[Footnote 2] its
information systems are overlapping and duplicative, are not
integrated, necessitate manual workloads, and employ antiquated
technologies that are costly to maintain. HUD is currently working to
address these issues and stated that its incremental IT expenditure
plans will allow the department to develop a strategy and operating
plan for enterprise transformation while beginning targeted new
projects and existing system modifications that are needed to respond
to pressing mission needs and statutory mandates.
As required by the appropriations act, we reviewed HUD's first
incremental fiscal year 2010 expenditure plan. We also reviewed the
department's capacity for IT modernization management. Our objectives
were to determine the extent to which (1) HUD's expenditure plan meets
statutory conditions[Footnote 3] and (2) HUD has in place key
institutional IT modernization management capabilities. On August 24,
2010, we provided the results of our review, including our findings,
conclusions, and recommendations, in a written briefing to the staffs
of the Senate and House Appropriations Subcommittees on
Transportation, Housing and Urban Development, and Related Agencies,
and we met with them on September 16, 2010, to discuss the briefing.
This letter summarizes and transmits the written briefing, which is
reprinted in appendix I.
We performed this performance audit from March 2010 to November 2010
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. Details on our
scope and methodology are in the briefing, which is reprinted in
appendix I.
In summary, we made the following major points:
* The extent to which HUD has satisfied the statutory conditions
placed on its expenditure plan varies by modernization project, but
overall the plan is limited as a congressional oversight and decision-
making mechanism. Specifically:
- According to the statute, the plan is to identify functional and
performance capabilities, expected mission benefits, estimated
lifecycle costs, and key milestones for all IT modernization projects
[Footnote 4] covered in the plan. However, the plan does not
adequately satisfy all elements of the statutory condition for all
projects. The HUD Deputy Chief Information Officer (CIO) attributed
these limitations in the information provided by the plan to the
department's interpretation and understanding of the project-level
information needed to satisfy the conditions of the appropriations
act. The Deputy CIO further stated, and we confirmed, that additional
detailed capability, benefit, cost, and milestone information on
several projects exists. According to the CIO, HUD intends to include
this more detailed information in future plans.
- According to the statute, the plan is to demonstrate that each IT
modernization project is, among other things, being managed in
accordance with applicable lifecycle management policies and guidance,
subject to HUD's capital planning and investment control requirements,
and supported by an adequately staffed project office. However, the
plan, in combination with project management documentation, does not
fully satisfy this statutory condition. Specifically, neither of the
two projects[Footnote 5] that we assessed fully satisfied more than
one of the condition's elements. This can be attributed to the fact
that HUD has yet to institutionalize each of the IT management
controls that are needed to meet this condition (as discussed below).
In the interim, HUD officials have employed compensatory measures to
minimize projects' exposure to risk, but neither the risks nor the
compensating measures are addressed in the expenditure plan.
* HUD has yet to institutionalize key IT modernization management
capabilities. We previously reported that an organization's ability to
effectively modernize its IT environment greatly depends on the extent
to which it has established and implemented a number of institutional
management controls or capabilities, including enterprise architecture
development and use, systems lifecycle management, IT investment
management, and IT human capital management.[Footnote 6] In July 2009,
we reported[Footnote 7] that HUD had to varying degrees established
many of these controls but that none had been fully defined and
implemented. Accordingly, we made recommendations aimed at defining
and implementing them. HUD's actions to evolve and strengthen each of
these controls and implement our recommendations are discussed below:
- Enterprise architecture: We previously reported that HUD's prior
version of its architecture had identified segments aligned with HUD
business units (e.g., single-family housing) and that only a few
segment architectures had been developed. Since then, HUD has moved to
defining its enterprise architecture around cross-department business
functions, and intends to develop a new version of its architecture.
However, development of this new version has yet to commence, although
related efforts are under way that should help to inform this new
version. HUD has to yet to establish when a new version of its
enterprise architecture will be available.
- Systems lifecycle management: Thus far, HUD has developed the
conceptual construct for a new integrated investment and lifecycle
management framework, but the policies and process guidance needed to
understand and consistently implement it are under development. HUD
reports that this framework will be defined to the point that projects
can consistently implement it by October 2010.
- IT investment management: We previously reported that while HUD had
defined and implemented IT investment management policies and
procedures to support the selection of investment portfolios, it had
yet to define and implement policies and procedures to control the
execution of these portfolios of investments. Since then, HUD reports
that while it is working to define and implement portfolio-based
investment control policies and procedures, it does not expect to
begin implementing them until October 2010.
- IT human capital: We previously reported that HUD had analyzed gaps
in its IT workforce but that this analysis was based on an incomplete
and outdated skills inventory. Since then, HUD has begun to develop a
strategic IT human capital plan, which includes an updated assessment
of knowledge and skills of current staff, but it has yet to define
skill gap closure strategies. Further, it has not established
milestones for completing and implementing this plan.
HUD officials attribute the state of the department's institutional
controls largely to the fact that the new HUD IT leadership team has
only recently been put in place, and it is still in the process of
introducing IT modernization management improvements.
Conclusions:
HUD has fallen short of the statutorily-mandated conditions placed on
its fiscal year 2010 IT modernization expenditure plan. As a result,
the utility of HUD's first incremental plan as an oversight, decision-
making, and accountability tool is limited. Until HUD can submit an
expenditure plan that satisfies the statutory conditions, as well as
discloses the risks associated with each project and plans for
mitigating them, its House and Senate Appropriations Subcommittees
will not have the information that they need to oversee HUD's
modernization projects and hold the department accountable for project
results.
Beyond the plan, and notwithstanding HUD's efforts to date to
establish key IT modernization management capabilities, much remains
to be accomplished before these capabilities can be considered
sufficiently institutionalized to reasonably ensure that each
modernization project is successfully completed. While HUD's new IT
leadership team has made important progress in developing these
capabilities, the extent to which future expenditure plans provide for
expanded investment in the eight modernization projects covered in the
first plan, while also proposing investment in additional projects,
will increase the risks associated with HUD's near-term modernization
efforts. As a result, it is important for HUD to balance the number of
projects in the plan, and the extent to which they are allowed to
proceed beyond definition and early design, with its institutional
capacity to execute them.
Recommendations for Executive Action:
To increase the usability and value of HUD's next expenditure plan to
its House and Senate Appropriations Subcommittees, we recommend that
the Secretary of HUD direct the CIO to ensure that future plans
satisfy each element of each statutory condition for each project in
the plan, or disclose why any element is not satisfied, along with any
associated project risks and plans for addressing those risks.
Furthermore, we recommend that the Secretary direct the CIO to ensure
that future plans clearly describe the status of HUD's efforts to
establish and implement each of these modernization management
controls, along with the project-specific risks and mitigation plans
associated with this status. In addition, we recommend that the
Secretary ensure that the number and scope of HUD's modernization
projects are commensurate with the department's institutional capacity
to execute them.
Agency Comments:
In written comments on a draft of this report, signed by the CIO, and
reprinted in appendix II, HUD concurred with our recommendations and
stated that the agency comments section of the transmitted briefing
adequately represented HUD's position and that the appropriate
clarifications and comments regarding HUD's compensating controls had
been incorporated into the report. Moreover, HUD commented that it
remained committed to establishing the key IT management and
modernization controls needed to ensure that its IT environment
supports mission-critical operations.
We are sending copies of this report to the Chairs and Ranking Members
of other Senate and House committees and subcommittees that have
authorization and oversight responsibilities for HUD IT modernization.
We are also sending copies to the Secretary of HUD and the Director of
the Office of Management and Budget. Copies of this report will also
be available at no charge on GAO's Web site at [hyperlink,
http://www.gao.gov].
If you or your staffs have any questions on matters discussed in this
report, please contact me at (202) 512-3439 or at hiter@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
have made significant contributions to this report are listed in
appendix III.
Signed by:
Randolph C. Hite:
Director, Information Technology Architecture and Systems Issues:
[End of section]
Appendix I: Briefing for Staff Members of the Subcommittees on
Transportation, Housing and Urban Development, and Related Agencies,
Senate and House Committees on Appropriations:
Information Technology: HUD Needs to Better Define Commitments and
Disclose Risks for Modernization Projects in Future Expenditure Plans:
Briefing for staff members of the Subcommittees on Transportation,
Housing and Urban Development, and Related Agencies Senate and House
Committees on Appropriations:
August 24, 2010:
Contents:
Introduction;
Scope and Methodology;
Results in Brief;
Background;
Results;
Conclusions;
Recommendations for Executive Action;
Agency Comments and Our Evaluation;
Attachment 1: Objectives, Scope, and Methodology.
Introduction:
Information technology (IT) plays a critical role in the Department of
Housing and Urban Development's (HUD) ability to carry out its home
ownership and community development mission. For instance, the
department reports that its business areas rely on IT to process over
50,000 loan requests per week, over 12,000 service calls per month,
and more than 7,000 grant requests annually for each of its major
grant programs.
Despite this role, HUD's current IT environment does not effectively
support its ongoing business operations. As we recently reported,
[Footnote 8] its information systems are overlapping and duplicative,
are not integrated, necessitate manual workloads, and employ
antiquated technologies that are costly to maintain.
HUD is currently working to address these issues through its
Transformation Initiative. This initiative consists of four related
components, one of which focuses on modernizing the department's IT
environment. For fiscal year 2010, the department intends to invest
$138 million in its modernization efforts, which is about one-half of
the total expected Transformation Initiative funding for the fiscal
year ($258 million).
The Consolidated Appropriations Act, 2010,[Footnote 9] states that HUD
may not obligate more than 25 percent of the funds made available for
IT modernization until the Senate and House Committees on
Appropriations receive a plan for expenditure that meets the following
sets of statutory conditions.
First, the plan must identify the following four elements for each
modernization project:
* functional and performance capabilities to be delivered,
* expected mission benefits,
* estimated lifecycle costs, and,
* planned key milestones.
Second, the plan must demonstrate the following four elements for each
modernization project:
* compliance with the department's enterprise architecture (EA),
* management in accordance with applicable lifecycle management
policies and guidance,
* conformance to the department's capital planning and investment
control requirements, and,
* support by an adequately staffed project office.
On April 26, 2010, HUD submitted what it described as the first in a
planned series of incremental expenditure plans to the House and
Senate Appropriations Subcommittees on Transportation, Housing and
Urban Development, and Related Agencies. According to HUD, the
incremental approach will allow it to develop a strategy and operating
plan for enterprise transformation while beginning targeted, high-
priority new projects and existing system modifications that are
needed to respond to pressing mission needs and statutory mandates.
The act also requires that GAO review this plan. As agreed with HUD's
appropriations subcommittees, our review objectives were to determine
the extent to which:
* HUD's expenditure plan meets statutory conditions, and,
* HUD has in place key institutional IT modernization management
capabilities.
Scope and Methodology:
To accomplish the first objective, we compared the information for the
IT modernization projects provided in the plan with each element of
the two sets of conditions, as specified in the act. For both
conditions, we determined whether the plan satisfied, partially
satisfied, or did not satisfy each[Footnote 10] element of the
condition.
* For the first condition, our scope included all eight projects in
the plan and focused on the contents of the plan because the act
required that the plan itself contain information to address each
element of the condition.
* For the second condition, we focused on two projects, the Federal
Housing Administration (FHA) Transformation: Infrastructure and the
Next Generation Voucher Management System (NGVMS). In doing so, we
analyzed information in the plan and relevant project management
documents to determine whether each element of the condition was
addressed. We focused on FHA Transformation: Infrastructure and NGVMS
because these projects were specifically cited in the act.
To accomplish the second objective, we compared available information,
including HUD IT management reports and departmental policies and
procedures, in draft and final form, for each of the institutional IT
modernization management capabilities cited in the act with our open
recommendations made in a prior report[Footnote 11] on the
department's management capacity in these areas.
For both of our objectives, we also interviewed cognizant officials.
(See attachment 1 for more detailed information on our objectives,
scope, and methodology.)
We conducted this performance audit at HUD offices in Washington,
D.C., from March 2010 to August 2010 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.
Results in Brief:
The extent to which HUD has satisfied the statutory conditions
associated with its expenditure plan varies by modernization project,
but overall HUD's plan is limited as a congressional oversight and
decision-making mechanism. (See table 1.)
Table 1: Summary of HUD's Satisfaction of Expenditure Plan Statutory
Conditions:
IT project: FHA Transformation: Infrastructure;
Statutory condition 1: Capabilities: [A];
Statutory condition 1: Mission benefits: [A];
Statutory condition 1: Lifecycle costs: [A];
Statutory condition 1: Key milestones: [A];
Statutory condition 2: EA compliance; [C];
Statutory condition 2: Project lifecycle management: [B];
Statutory condition 2: Capital planning and control: [C];
Statutory condition 2: Project staffing: [C].
IT project: NGVMS (Phase 1);
Statutory condition 1: Capabilities: [B];
Statutory condition 1: Mission benefits: [B];
Statutory condition 1: Lifecycle costs: [B];
Statutory condition 1: Key milestones: [A];
Statutory condition 2: EA compliance; [C];
Statutory condition 2: Project lifecycle management: [B];
Statutory condition 2: Capital planning and control: [C];
Statutory condition 2: Project staffing: [A].
IT project: Development Application Processing System;
Statutory condition 1: Capabilities: [A];
Statutory condition 1: Mission benefits: [B];
Statutory condition 1: Lifecycle costs: [B];
Statutory condition 1: Key milestones: [C].
IT project: FHA Transformation: Multifamily Housing Development and
Automated Underwriting Business Process Reengineering;
Statutory condition 1: Capabilities: [A];
Statutory condition 1: Mission benefits: [A];
Statutory condition 1: Lifecycle costs: [A];
Statutory condition 1: Key milestones: [A].
IT project: HUD Integrated Core Financial Management Improvement
Project;
Statutory condition 1: Capabilities: [C];
Statutory condition 1: Mission benefits: [B];
Statutory condition 1: Lifecycle costs: [B];
Statutory condition 1: Key milestones: [C].
IT project: Human Resources End-to-End Solution (Phase 1);
Statutory condition 1: Capabilities: [A];
Statutory condition 1: Mission benefits: [A];
Statutory condition 1: Lifecycle costs: [C];
Statutory condition 1: Key milestones: [B].
IT project: Improvement to Current Tenant-based Rental Assistance
System (Sept. 2010 Release);
Statutory condition 1: Capabilities: [B];
Statutory condition 1: Mission benefits: [B];
Statutory condition 1: Lifecycle costs: [C];
Statutory condition 1: Key milestones: [A].
IT project: Transformation Initiative/IT Project Assessment and
Program Support Services;
Statutory condition 1: Capabilities: [B];
Statutory condition 1: Mission benefits: [C];
Statutory condition 1: Lifecycle costs: [A];
Statutory condition 1: Key milestones: [C].
Source: GAO analysis based on HUD data.
[A] Satisfies all aspects of this element.
[B] Satisfies some, but not all, aspects of this element.
[C] Does not satisfy any aspect of this element.
[End of table]
Results in Brief:
HUD's Deputy Chief Information Officer (CIO) attributed limitations in
the plan's scope and content to the department's interpretation and
understanding of the project-level information needed to satisfy the
act's conditions as well as the unavailability of project management
documentation for several projects. The CIO also stated, and we
confirmed, that more detailed capability, benefit, cost, and milestone
information exists for several of the eight projects, and added that
such information is to be included in future expenditure plans.
Without an expenditure plan that provides HUD's appropriations
committees with sufficient insight and visibility into key aspects of
the modernization projects under way, or otherwise discloses the
unavailability of this information and the associated risks and plans
to mitigate these risks, the committees will lack the means for
effectively overseeing and making informed funding decisions.
HUD has a range of actions under way to evolve and strengthen its IT
governance approach; however, it has yet to institutionalize key IT
modernization management capabilities. Specifically:
* HUD intends to award a contract to develop a new version of its EA
because the current version is business-unit-based (e.g., single-
family housing) rather than core business function-based (e.g., grants
management), and thus is not consistent with its modernization plans.
However, this contract's award was recently protested, and thus HUD
does not yet know when it will have the first version of its new EA.
In the interim, HUD has EA-related work under way to analyze its
existing portfolio of 29 Transformation Initiative projects to, among
other things, identify potential duplication across the projects and
develop a target architecture, including an enterprise data management
strategy and a project transition strategy. According to HUD, this
work will, among other things, help to inform the next version of its
EA.
* HUD has developed the conceptual construct for a new integrated
investment and lifecycle management framework, but all the policies
and process guidance needed to understand and consistently implement
it are under development. HUD reports that this framework will be
defined to the point that projects can consistently implement it by
October 2010.
* HUD has defined and implemented IT investment management policies
and procedures to support selection of investment portfolios, but not
to control these portfolios of investments. HUD expects to have
defined and to begin implementing portfolio-based investment control
policies and procedures by October 2010.
* HUD has begun to develop a strategic IT human capital management
plan (e.g., it has mapped existing IT staff skill sets to its
strategic Office of the Chief Information Officer (OCIO) goals).
However, it has yet to define skill gap closure strategies. Further,
it has not established milestones for completing and implementing this
human capital management plan.
HUD's Deputy CIO attributed the state of the department's
institutional IT management controls to the limited amount of time
that the new IT leadership team has had to correct longstanding
weaknesses in the each of the areas, as well as competing demands for
key OCIO staff. The CIO also stated that these governance reforms are
significant in nature and thus will take time to accomplish.
The absence of any one of these institutional IT management controls
introduces an element of risk to each modernization project; however,
the combination of these missing capabilities introduces greater risk
that projects will not perform as intended and will cost more and take
longer than necessary to implement. While this risk is mitigated
somewhat by OCIO actions to implement interim, compensatory IT
management steps, such as the work on an enterprise transformation
operating plan which will inform the direction of the new EA, as well
as the fact that five of the eight projects in the expenditure plan
are still early in their lifecycles, it is nevertheless extremely
important for HUD to move quickly to follow through on its intentions
to establish and implement more robust IT governance before its
projects advance much further in their lifecycles.
To assist HUD in developing its next expenditure plan and striking a
proper balance between its need to introduce modernized systems and
prudently manage the risks inherent in doing so, we are recommending
that future expenditure plans (1) fully satisfy each set of statutory
conditions or otherwise disclose why any element of a statutory
condition is not satisfied, along with any associated project risks
and mitigation plans, and (2) describe the status of HUD's efforts to
institutionalize key modernization management controls, along with any
associated project risks and mitigation plans. We are also
recommending that HUD ensure that future plans reflect its
institutional capacity to manage the number and scope of projects in
the plans.
In commenting on a draft of this briefing, HUD officials did not
explicitly agree or disagree with our recommendations. However, they
emphasized that our findings and conclusions relative to the plan's
satisfaction of the statutory conditions do not indicate that the
projects in the plan are being poorly managed. Further, they stated
that the draft briefing did not sufficiently recognize the
compensatory measures that have been taken to mitigate risks
associated with the lack of institutionalized governance controls, and
they provided clarifying statements and documentation relative to
these measures, as well as a range of technical comments.
We agree with HUD's first comment on our findings relative to the
plan's satisfaction of statutory conditions. Accordingly, our
conclusions and recommendations are confined to the plan's value as an
oversight and accountability tool. With respect to the second comment
on compensatory measures, we have incorporated the additional
information that HUD provided, as appropriate, throughout the briefing.
Background: HUD Organization:
To carry out its mission, HUD is organized into five main components.
In carrying out their mission duties, these offices perform a range of
core business functions, such as grants management and voucher
processing management. The five components and their missions are
described below.
* Office of Housing Contributes to building and preserving healthy
neighborhoods and communities; maintains and expands home ownership,
rental housing, and health care opportunities; and stabilizes credit
markets in times of economic disruption. This office is composed of
two mission areas:
- Single-family housing programs provide mortgage insurance on loans
to purchase homes and refinance existing mortgages.
- Multifamily programs provide mortgage insurance to lenders on loans
for the development of housing projects and health care facilities.
* Office of Community Planning and Development: Provides housing,
living environment, and economic opportunities for people of low and
moderate income through partnerships with all levels of government,
the private sector, and nonprofit organizations.
* Office of Fair Housing and Equal Opportunity: Administers and
enforces federal laws that prohibit discrimination in housing, such as
the Fair Housing Act of 1968[Footnote 12] and the Civil Rights Act of
1964.[Footnote 13] Establishes and enforces policies intended to
ensure that all Americans have equal access to housing of their choice.
* Office of Public and Indian Housing: Administers and manages
programs authorized by the Housing Act of 1937[Footnote 14] to provide
housing to approximately 3.4 million households in order to ensure
housing and create opportunities for residents' self-sufficiency and
economic independence.
* Government National Mortgage Association: Expands affordable housing
by linking global capital markets to the nation's housing markets.
Guarantees investors timely payment and interest on mortgage-backed
securities backed by federally insured or guaranteed loans.
HUD also consists of a number of mission support offices, such as the
Office of Healthy Homes and Lead Hazard Control and the Office of
Faith-Based and Community Initiatives, as well as administrative
offices, such as the Office of the Chief Financial Officer, Office of
Chief Procurement Officer, and the OCIO. Figure 1 provides a
simplified view of the department's organizational structure.
Figure 1: Simplified HUD Organizational Chart:
[Refer to PDF for image: organizational chart]
Top level:
* Secretary[A].
Second level, reporting to Secretary:
* Deputy Secretary.
Third level, reporting to Deputy Secretary:
* Fair Housing and Equal Opportunity;
* Housing;
* Chief Procurement Officer;
* Chief Financial Officer;
* Community Planning and Development;
* Government National Mortgage Association;
* Public and Indian Housing;
* Chief Information Officer;
* Other support offices[B].
Source GAO based on HUD data.
[A] Other offices exist that directly report to the Office of the
Secretary, such as the Office of Hearings and Appeals.
[B] Other support offices include: Administration, Center for Faith-
Based and Community Initiatives, Congressional and Intergovernmental
Affairs, Departmental Equal Employment Opportunity, Departmental
Operations and Coordination, Field Policy and Management, General
Counsel, Healthy Homes and Lead Hazard Control, Inspector General,
Policy Development and Research, and Public Affairs.
[End of figure]
Background: HUD OCIO:
HUD's OCIO is responsible for the department's IT environment. To this
end, OCIO has established four IT strategic goals: (1) rapidly
modernizing IT to support key HUD business initiatives; (2)
transforming the IT infrastructure to adapt to and adopt emerging
technologies; (3) developing a cadre of highly capable IT
professionals with mission critical competencies; and (4) providing
secure, rapid, and reliable data and information to customers,
citizens, and business partners.
To accomplish these goals, OCIO is in the process of being
reorganized, and according to OCIO officials, the new organization
structure is being used to manage the IT modernization projects.
Further, they stated that the reorganization reflects an improved
focus on OCIO service to HUD's mission areas and a more streamlined
and transparent approach to investment decision-making.
Background: Institutional IT Modernization Management Controls and
Risks:
As we have previously reported, an organization's ability to
effectively and efficiently maintain and modernize its existing IT
environment depends in large part on how well it employs certain IT
management controls or disciplines that are embodied in statutory
requirements, federal guidance, and best practices. Key components of
an effective management structure include (1) IT strategic planning,
(2) EA development and use, (3) IT investment management, (4) systems
development and acquisition management, (5) information security
management, (6) information management, and (7) IT human capital
management.[Footnote 15] Further, the severity of the risks associated
with investing in IT systems without these management controls in
place and operating depends on where projects are in their lifecycles.
[Footnote 16] While such risks are not as severe early in a project's
lifecycle, when it is being planned (project definition and
preliminary system design), they escalate as a project is designed,
developed, and deployed.
Background: HUD Expenditure Plan:
HUD submitted the first incremental expenditure plan to its House and
Senate Appropriations Subcommittees on April 26, 2010. This plan seeks
to obligate about $28.1 million in Transformation Initiative funding
across eight projects, which HUD officials described as those projects
that are most critical to their transformation efforts. (See table 3
for a description of the eight projects, along with each project's
estimated obligations under the first incremental plan and total
estimated use of fiscal year 2010 appropriated funds.) According to
HUD officials, several of these projects receive additional funds
through HUD's Working Capital Fund. For example, the HUD Integrated
Core Financial Management Improvement Project is also receiving about
$26 million in working capital funds for fiscal year 2010.
Table 3: Summary of the April 2010 HUD Expenditure Plan:
IT modernization project: FHA Transformation: Infrastructure;
Purpose: To define a future technical infrastructure to support FHA
and related HUD services;
Estimated obligations for the first increment: $2.0 million;
Total estimated fiscal year 2010 appropriations[C]: $18.5 million.
IT modernization project: NGVMS (Phase 1)[A];
Purpose: To define a future technical infrastructure to support HUD
services related to rental housing assistance (phase 1). The other two
phases are the development and implementation of the system (phase 2),
and the independent validation and verification testing of the system
(phase 3);
Estimated obligations for the first increment: $6.5 million;
Total estimated fiscal year 2010 appropriations[C]: $28.0 million.
IT modernization project: Development Application Processing System;
Purpose: To enhance the existing system with the ability to identify
the various HUD offices processing FHA insurance applications; ensure
the accuracy of the amount of funds being awarded; and ensure that all
available funds are awarded in accordance with published criteria;
Estimated obligations for the first increment: $0.4 million;
Total estimated fiscal year 2010 appropriations[C]: $0.4 million.
IT modernization project: FHA Transformation: Multifamily Housing
Development and Automated Underwriting Business Process Reengineering;
Purpose: To analyze current environment and make recommendations on IT
solutions that streamline and optimize Office of Multifamily Housing
operations;
Estimated obligations for the first increment: $2.0 million;
Total estimated fiscal year 2010 appropriations[C]: $2.0 million.
IT modernization project: HUD Integrated Core Financial Management
Improvement Project[A];
Purpose: To implement an integrated financial management system to
bring HUD into full compliance with the relevant financial management
laws and regulations;
Estimated obligations for the first increment: $10.0 million;
Total estimated fiscal year 2010 appropriations[C]: $10.0 million.
IT modernization project: Human Resources End-to-End Solution (Phase
1)[A];
Purpose: To replace HUD‘s current human resources system provided by
the Department of the Treasury with an in-house system using a phased
migration approach; phase one is to provide staffing and
classification services across HUD;
Estimated obligations for the first increment: $3.6 million;
Total estimated fiscal year 2010 appropriations[C]: $10.0 million.
IT modernization project: Improvement to Current Tenant-based Rental
Assistance System (Sept. 2010 Release)[A];
Purpose: To incrementally modify the current Voucher Management
System. The first release of the modified system, set for Sept. 17,
2010, is to include the addition of new fields, enhancements to the
user interface, and the addition of forecasting and reporting
capability;
Estimated obligations for the first increment: $0.6 million;
Total estimated fiscal year 2010 appropriations[C]: $3.0 million.
IT modernization project: Transformation Initiative/IT Project
Assessment and Program Support Services[B];
Purpose: To provide analytical and consulting services related to
architecture development and also to provide management support to HUD‘
s modernization project teams. Among other things, it includes
analysis of the scope and potential duplication across the 29
modernization projects in the Transformation Initiative portfolio,
development of target architecture concepts and direction, and
development of a Transformation Initiative Operating Plan;
Estimated obligations for the first increment: $3.0 million;
Total estimated fiscal year 2010 appropriations[C]: $3.0 million.
Total:
Estimated obligations for the first increment: $28.1 million;
Total estimated fiscal year 2010 appropriations[C]: $74.9 million.
Source: GAO analysis of HUD data.
[A] This project also receives HUD Working Capital Funds.
[B] According to HUD officials, this effort is not a project in the
sense of delivering a modernized system solution, and it was included
as a project in the expenditure plan because they wanted to ensure
transparency of all Transformation Initiative funding.
[C] These appropriations are available for obligation through
September 30, 2012.
[End of table]
Objective 1: Statutory Conditions: First Set of Conditions:
Condition 1. The expenditure plan varies in the degree to which it
describes functional and performance capabilities, expected mission
benefits, estimated lifecycle costs, and key milestones for each of
the eight IT projects, but overall does not adequately satisfy all
elements of the condition for all projects. (See table 4.)
Table 4: Summary of GAO Assessment of HUD's Expenditure Plan against
Statutory Condition 1:
IT project: FHA Transformation: Infrastructure;
Capabilities: Satisfies all aspects of this element;
Mission benefits: Satisfies all aspects of this element;
Lifecycle costs: Satisfies all aspects of this element;
Key milestones: Satisfies all aspects of this element.
IT project: NGVMS (Phase 1);
Capabilities: Satisfies some, but not all, aspects of this element;
Mission benefits: Satisfies some, but not all, aspects of this element;
Lifecycle costs: Satisfies some, but not all, aspects of this element;
Key milestones: Satisfies all aspects of this element.
IT project: Development Application Processing System;
Capabilities: Satisfies all aspects of this element;
Mission benefits: Satisfies some, but not all, aspects of this element;
Lifecycle costs: Satisfies some, but not all, aspects of this element;
Key milestones: Does not satisfy any aspect of this element.
IT project: FHA Transformation: Multifamily Housing Development and
Automated Underwriting Business Process Reengineering;
Capabilities: Satisfies all aspects of this element;
Mission benefits: Satisfies all aspects of this element;
Lifecycle costs: Satisfies all aspects of this element;
Key milestones: Satisfies all aspects of this element.
IT project: HUD Integrated Core Financial Management Improvement
Project;
Capabilities: Does not satisfy any aspect of this element;
Mission benefits: Satisfies some, but not all, aspects of this element;
Lifecycle costs: Satisfies some, but not all, aspects of this element;
Key milestones: Does not satisfy any aspect of this element.
IT project: Human Resources End-to-End Solution (Phase 1);
Capabilities: Satisfies all aspects of this element;
Mission benefits: Satisfies all aspects of this element;
Lifecycle costs:
Key milestones: Satisfies some, but not all, aspects of this element.
IT project: Improvement to Current Tenant-based Rental Assistance
System (Sept. 2010 Release);
Capabilities: Satisfies some, but not all, aspects of this element;
Mission benefits: Satisfies some, but not all, aspects of this element;
Lifecycle costs: Does not satisfy any aspect of this element;
Key milestones: Satisfies all aspects of this element.
IT project: Transformation Initiative/IT Project Assessment and
Program Support Services;
Capabilities: Satisfies some, but not all, aspects of this element;
Mission benefits: Does not satisfy any aspect of this element;
Lifecycle costs: Satisfies all aspects of this element;
Key milestones: Does not satisfy any aspect of this element.
Source: GAO analysis of HUD data.
[End of table]
Functional and Performance Capabilities:
As we have previously reported,[Footnote 17] system capabilities can
be viewed in terms of what the system is to do (functions) and how
well the system is to perform these functions (performance). To
facilitate project oversight, decision-making, and accountability,
information about these capabilities should be defined to a level that
permits meaningful understanding of what capabilities are to be
delivered and measurement of progress in doing so. For four of the
eight projects, the plan describes the functional and performance
capabilities that are to be delivered. For example, the plan states
that the Development Application Processing System project is to
modify the first 11 reports generated by this system to clearly
identify the name of the field office that processed a case.
However, the plan does not include similarly detailed information for
the other four projects. For example, for the Improvements to Current
Tenant-based Rental Assistance Systems (Sept. 2010 Release) project,
the plan only states that it is to provide unspecified enhancements to
the user interface and forecasting/reporting capabilities. Similarly,
for the HUD Integrated Core Financial Management Improvement Project,
the plan states that the project will deliver a modern IT
infrastructure for current and future financial management
applications, and that the resulting system will be fully compliant
with relevant financial management laws and regulations and will
provide accurate and timely information. However, it does not provide
any information on what constitutes modern capabilities, such as the
processing capacity, and it does not specify any of the functions
needed to comply with applicable laws and regulations or what the
relevant laws and regulations are. Further, it does not specify the
performance levels needed for the information to be accurate and
timely.
Mission Benefits:
As we have previously reported,[Footnote 18] the benefits to accrue
from a proposed system solution should be specific and measurable, and
they should be linked to specific capabilities. The plan describes
expected mission benefits for three of the eight projects. For
example, the Human Resource End-to-End Solution project links
measurable benefits to explicit system capabilities. Specifically, the
plan states that this project is to deliver a reengineered staff
acquisition process that will decrease the number of the customer
complaints to no more than three per employee during a rating period
and will reduce the average time to hire candidates from 110 days to
79 days.
However, the plan does not present benefits that are specific and
measurable for the other five projects. For example, the plan states
that the Transformation Initiative/IT Project Assessment and Program
Support Services project will improve employee skills in program and
project management and consolidated business requirements. However,
these improved skills are not linked to expected outcomes (i.e.,
benefits) that can be measured, such as reductions in project and
program cost and schedule variances.
Estimated lifecycle costs:
As we have previously reported,[Footnote 19] a project's lifecycle
cost estimate should include all direct and indirect costs associated
with planning, designing, developing, procuring, deploying, operating
and maintaining, and disposing of the system. To support project
oversight, decision-making, and accountability, information about this
estimate should include enough detail to understand and measure the
expenditure funds for major project work activities and deliverables.
The plan contains estimated lifecycle costs for three of the eight
projects. For example, for the FHA Transformation: Multifamily Housing
Development and Automated Underwriting Business Process Reengineering
project, a $2 million lifecycle cost estimate is provided. Moreover,
this estimate is decomposed into meaningful work activities, such as
the following three phases: business process reengineering, change
management, and program management support.
For the remaining five projects, the plan cites estimated project
costs for just fiscal year 2010, as well as what portion of these
costs are for a given lifecycle phase (e.g., definition or acquisition
phases). However, a total lifecycle cost estimate is not provided for
these projects. Further, the decomposition of each project's costs is
not consistent. For example, the Development Application Processing
System project's costs are broken down by general work areas, such as
design specifications, development (coding), and testing, while the
Human Resources End-to-End Solution project's costs are broken down by
the contract's base year and option years.
Milestones:
As we have previously reported,[Footnote 20] project milestones should
be tied to the capabilities to be delivered and should permit progress
to be measured. The plan describes key milestones for four of the
eight projects. For example, for the Improvements to Current Tenant-
based Rental Assistance Systems (Sept. 2010 Release) project, the plan
shows a schedule that contains a series of key milestones, including
system design (April 20, 2010”April 30, 2010), integration and test
(June 10, 2010”August 31, 2010), and installation and deployment
(August 30, 2010”September 30, 2010).
For the other four projects, the plan does not sufficiently specify
key milestones. For example, the plan shows that the development phase
for the Development Application and Processing System project is to be
completed sometime between June 1, 2010, and November 15, 2010.
Moreover, it does not cite interim milestones associated with
completing system development activities, such as when key test events
will occur.
HUD's Deputy CIO attributed these limitations in the plan's scope and
content to the department's interpretation and understanding of the
project-level information needed to satisfy the act's conditions and
to the unavailability of more detailed project management information
for several projects. The CIO also stated, and we confirmed, that more
detailed capability, benefit, cost, and milestone information on
several projects, such as the HUD Integrated Core Financial Management
Improvement Project, does exist. Further, the CIO stated that HUD
intends to include this more detailed project information in future
expenditure plans.
Objective 1: Statutory Conditions: Second Set of Conditions:
Condition 2. The expenditure plan, in combination with project
management documentation, does not satisfy the statutory condition
that each project demonstrate that it is (a) compliant with the
department's EA, (b) being managed in accordance with applicable
lifecycle management policies and guidance, (c) subject to the
department's capital planning and control requirements, and (d)
supported by an adequately staffed project office. Specifically,
neither the FHA Transformation: Infrastructure nor the NGVMS project
fully satisfies more than one of the elements of the condition. (See
table 5.)
Table 5: Summary of GAO Assessment of Two HUD Modernization Projects
against Statutory Condition 2:
IT Project: FHA Transformation: Infrastructure;
EA compliance: Does not satisfy any aspect of this element;
Project lifecycle management: Satisfies some, but not all, aspects of
this element;
Capital planning and control: Does not satisfy any aspect of this
element;
Project staffing: Does not satisfy any aspect of this element.
IT Project: NGVMS (Phase 1);
EA compliance: Does not satisfy any aspect of this element;
Project lifecycle management: Satisfies some, but not all, aspects of
this element;
Capital planning and control: Does not satisfy any aspect of this
element;
Project staffing: Satisfies all aspects of this element.
Source: GAO analysis of HUD data.
[End of table]
The degree to which the plan and project management documentation
satisfy this condition can be attributed to the fact that each of the
four corporate IT management controls that are needed to meet this
condition has yet to be institutionalized, as discussed later in this
briefing. In the interim, HUD officials have employed compensatory
measures to minimize the project's exposure to risk, which are also
described later in this briefing. However, neither this risk exposure
nor the compensating measures are addressed in the expenditure plan.
The extent to which the plan and project management documentation
meets each element of the condition is discussed in more detail below.
EA Compliance:
Neither the plan nor available project documentation demonstrates that
the FHA Transformation: Infrastructure and NGVMS projects are
currently in compliance with the HUD EA because the department's
current version of its EA is no longer operative and a new version has
yet to be developed. (The status of HUD's EA is discussed later in
this briefing.) Specifically,
* The plan does not address EA compliance for the FHA Transformation:
Infrastructure project, and according to FHA officials, the project
has not been assessed for compliance. However, the project has defined
the FHA "as-is" and "to-be" (or target) architectures, and conducted
market research of commercially available system solutions. In
addition, officials stated that the HUD Chief Architect is a member of
the FHA integrated project team and that FHA has an active leadership
role in the new EA development effort.
* The plan states that NGVMS EA compliance will not be determined
until October 2011. NGVMS officials told us that EA compliance
analysis any sooner than this would be premature since the project is
very early in its lifecycle (e.g., business process reengineering and
requirements definition have yet to begin). However, given that
project definition activities are currently under way, and are to
produce a number of artifacts that should be traceable to and aligned
with the EA, such as business processes and requirements, data
requirements and definitions, process performance measures, and a
technology architecture, it is not clear why a compliance
determination will not occur for more than a year.
Lifecycle Management:
The plan, in combination with project documentation, partially
demonstrates that these two projects are being managed in accordance
with applicable lifecycle management policies and guidance.
Specifically,
* The plan provides a schedule for the FHA Transformation:
Infrastructure project that reflects the lifecycle phases in HUD's
recently defined conceptual framework for integrated investment
lifecycle management. For example, the plan states that the FHA
Concept of Operations, a key deliverable under this framework for
exiting the need/concept phase, was to be completed in May 2010. Based
on project documentation, it was completed in May 2010.
* The plan discusses the NGVMS project in the context of HUD's prior
systems development methodology framework. However, project officials
told us that the project is transitioning to the new lifecycle
management framework. To this end, project documentation shows that
the project work breakdown structure has been revised to reflect the
new lifecycle phases and work activities.
However, because HUD has not yet fully defined key aspects of its new
lifecycle management process, as is discussed in the next section of
this briefing, these projects' adoption of this process remains a work
in progress.
Capital Planning and Investment Control:
The plan does not provide any information as to whether the FHA
Transformation: Infrastructure or NGVMS projects are subject to HUD's
capital planning and investment control requirements. Moreover, OCIO
officials told us that neither project was subject to HUD's new
investment management process (details of which are discussed later in
this briefing). According to these officials, this is because the
expenditure plan was submitted while its revised IT governance
approach was being established, and thus these projects could not be
subjected to the formal executive reviews and investment evaluation
criteria associated with this new structure and approach.
Instead, OCIO officials explained that these projects were subject to
compensatory management control measures. Specifically, they were
managed and reviewed by the HUD Integrated Product Team, which is a
review body comprised of various technical, programmatic, financial,
and procurement officials. According to these officials, this team
determined each project's readiness to proceed based on the completion
and quality of their respective project plans, detailed budgets, and
requirements.
OCIO officials further stated that the HUD Integrated Product Team
continues to review these projects and provides progress updates and
recommendations on the advancement of these projects to the oversight
boards that are part of HUD's new in-process governance structure.
Nevertheless, these compensatory measures were not described
in the plan.
Project Office Staffing:
While the plan does not demonstrate that the FHA Transformation:
Infrastructure project or the NGVMS project is currently supported by
an adequately staffed project office, project management documentation
does show that this latter project is at least adequately staffed for
the current fiscal year. Specifically,
* The plan does not provide information as to whether the FHA
Transformation: Infrastructure project is adequately staffed. Instead,
the plan identifies the names of key project management personnel,
including the executive sponsor and IT project manager. While project
officials told us that they believe that the project is adequately
staffed, this position was not supported by any documented analysis of
strategic gaps in staffing needs versus capabilities. According to
project officials, should additional staff be needed, they will work
with OCIO informally to address these needs.
* The plan does not provide information on the adequacy of NGVMS
project staffing. However, the project office completed an analysis of
its staffing levels for fiscal years 2010 through 2016, and based on
this analysis, the project is adequately staffed in 2010, but may not
be in future years. Specifically, the analysis shows that multiple
staff will be expected to perform tasks well in excess of a normal
work day in later stages of the project, which is an indication of
future staffing challenges.
Objective 2: HUD's Institutional IT Modernization Capabilities:
HUD Has Yet to Fully Establish Key Institutional IT Modernization
Management Capabilities:
As we have previously reported,[Footnote 21] an organization's ability
to effectively modernize its IT environment greatly depends on the
extent to which it has established and implemented a number of
institutional IT modernization management controls or capabilities.
These controls include EA development and use, systems lifecycle
management, IT investment management, and IT human capital management.
To date, HUD has yet to adequately establish any of these corporate IT
management controls, in large part because a new HUD IT leadership
team has only recently been put in place, and it is still in the
process of introducing a new approach to IT governance, which HUD
described as significant in nature and requiring time to accomplish.
Nevertheless, HUD continues to invest in multiple IT modernization
projects, and may expand on the number of projects in the near term.
As we have previously reported,[Footnote 22] the absence of these
institutional modernization management controls introduces an
unnecessary element of modernization risk that while manageable early
in a project's lifecycle, increases exponentially as a project
progresses to later lifecycle stages.
With regard to HUD's first expenditure plan, five of the eight
projects are very early in their lifecycles, and thus their exposure
to risk is not as significant as the other three. However, it is
extremely important for HUD to expeditiously establish and implement
each of these institutional controls across its projects before any of
the projects proceed beyond early definition and design, and before
more projects are initiated. To do less increases the risk that the
projects will ultimately encounter cost, schedule, and performance
shortfalls. According to the CIO, pursuit of its institutional IT
governance reforms in parallel with its modernization projects will be
challenging, and to address this challenge its OCIO will work closely
with the mission-area teams that are responsible for the projects to
minimize the associated risks.
Enterprise Architecture:
An EA is a corporate blueprint for modernizing IT systems and
transforming mission operations and serves as a bridge between an
organization's strategic plans and its implementation of individual
programs and system solutions. As such, it provides the information
details needed to guide and constrain investments in a consistent,
coordinated, and integrated fashion”thereby improving
interoperability, reducing duplicative efforts, and optimizing mission
operations. One approach to developing the EA content needed to
adequately inform program and system solution implementations is to
divide the architecture into segments and to develop more detailed
architectures for each segment.
In July 2009, we reported[Footnote 23] that HUD had a version of its
EA that identified and prioritized segments that were aligned with HUD
business units (e.g., single-family housing, multifamily housing
finance). However, only a few segment architectures had been
developed, segment priorities were not being adhered to, and those
segments that had been developed were out of date and did not reflect
important elements of federal guidance. Accordingly, we made
recommendations aimed at improving HUD's segment architectures.
Since then, HUD's OCIO has decided to reexamine and redefine the
department's EA segments based on HUD business functions that
transcend business units (e.g., business intelligence, grants
management, and workflow management). To accomplish this, HUD intended
to award a contract to develop a new version of its EA in March 2010.
However, this contract's award was recently protested, and thus HUD
does not yet know when it will have an initial version of its new EA.
In the interim, HUD has EA-related work under way as part of its
Transformation Initiative/IT Project Assessment and Program Support
Services project, which is to among other things, develop an
enterprise transformation operating plan and inform the direction of
the new EA. According to the statement of work, the contractor is to
analyze HUD's existing portfolio of 29 Transformation Initiative
projects to, among other things, identify potential duplication across
the projects and develop a target architecture, including (1) an
enterprise data management strategy, (2) project transition strategy,
and (3) restructured EA segments. HUD officials stated that this work
will be completed by October 2010.
Notwithstanding the value of this work in informing HUD's EA, it is
not clear when the department will have an initial version of this EA.
Without it to guide and constrain IT modernization projects, HUD will
be at increased risk of investing in systems that are not well
integrated, are potentially duplicative, and do not support optimized
mission operations.
Systems Lifecycle Management:
Following a disciplined lifecycle management process in which key
activities and phases of a project are conducted in a logical and
orderly process and are fully documented helps ensure that IT
modernization programs achieve intended goals within acceptable levels
of cost and risk.[Footnote 24] Such a process typically begins with
initial concept definition and continues through requirements
determination and system design and development, including testing,
and concludes with final testing, deployment, and operations and
maintenance.
HUD has not yet fully defined and implemented comprehensive lifecycle
management policies and procedures. Specifically, HUD has developed a
conceptual construct for a new integrated investment management
lifecycle framework that identifies eight major phases: need/concept,
definition, financial planning, acquisition, design, development,
deployment, and operations and maintenance. This conceptual framework
specifies some of the activities and project artifacts associated with
each of these phases, such as an IT project planning template to
support standardization across new projects.
However, work is still under way to define the remaining process
guidance needed to understand and consistently implement the
framework. Among other things, OCIO officials told us the majority of
project tools and standard templates expected to be used by the IT
project teams have not been developed. They also said the framework
will be defined to the point that projects can begin to consistently
implement it by October 2010. However, the CIO also acknowledged that
the project-related contracts already in place are aligned to the
prior lifecycle model, and thus while new contracts and option year
actions on existing contracts will incorporate the new lifecycle
management language, OCIO will need to work with the project teams on
a one-on-one basis to ensure appropriate practices are employed to the
extent possible to minimize risks on other existing contracts.
Until the framework is defined and consistently implemented, HUD will
not have the kind of repeatable process needed to ensure that each
modernization project is executed in a rigorous and disciplined manner
across the department.
IT Investment Management:
Investment management includes the selection and control of
investments to ensure that they produce business value in the
investment decision-making process. If managed effectively, IT
investments can have a dramatic impact on an organization's
performance and accountability. Our framework[Footnote 25] for
assessing federal agencies' IT investment management practices
consists of five progressive stages of maturity, with Stage 1
representing immature and undisciplined processes, and Stage 5
representing optimized maturity focused on continuous improvement.
Stage 3, which is the focus of our review, is where an organization
moves from project-centric to portfolio-based investment processes.
Through a portfolio-based approach, the organization can consider new
investment proposals, along with previously funded investments, and
identify the appropriate mix and synergies of these investments to
best meet mission needs. This level of investment involves the
implementation of four critical processes: (1) defining the portfolio
criteria; (2) creating the portfolio; (3) evaluating (i.e.,
controlling) the portfolio; and (4) conducting post-implementation
reviews.
In July 2009, we reported[Footnote 26] that HUD had executed all but
one of these four critical investment processes. In particular, HUD
had established the IT investment management policies and procedures
for developing investment portfolios but not for effectively
controlling them. As such, we made recommendations aimed at improving
HUD's IT portfolio evaluation processes.
HUD is in the process of addressing our recommendations. For example,
work is under way to establish a new IT governance structure intended
to increase portfolio transparency and facilitate portfolio decision-
making. Specifically,
* The Executive Investment Board (also called the Transformation
Initiative Fund Board), which is chaired by the HUD Secretary and
includes the Chief Financial Officer, CIO, and Chief Operating
Officer, has been established. This board is responsible for
developing and implementing HUD's strategic plan and making final
funding decisions.
* The Customer Care Committee, which is chaired by the CIO and
includes the General Deputy Assistant Secretaries, Associate CIOs, and
program/mission representatives, has been established. This board is
responsible for ensuring investments and projects are aligned to HUD's
strategic plan by managing and monitoring the performance of the IT
portfolio and providing portfolio and funding recommendations to the
Executive Investment Board.
* Investment Review and Technical Review Subcommittees, which are
comprised of OCIO and project leadership, have been established. These
two subcommittees are responsible for providing all necessary analysis
to the Customer Care Committee related to IT investment and portfolio
reviews and IT project control gate reviews, respectively.
The charters for these governing boards (outlining their membership
and detailed roles and responsibilities) have been drafted but are not
yet approved. However, we have confirmed that, with the exception of
the Technical Review Subcommittee, these boards have been actively
meeting since February 2010 as an interim control measure. According
to OCIO, approved charters for these groups, as well as the
implementation of the remaining subcommittee, will occur by October
2010. OCIO officials stated that until the Technical Review
Subcommittee is in place, the HUD Integrated Product Team (as
discussed earlier in this briefing) serves as the review body to
determine the completion and quality of tasks and documentation for
each phase of the integrated investment management lifecycle.
HUD is also in the process of restructuring and combining its
inventory of modernization and business mission projects under a
single IT investment portfolio, which it reports should be completed
by October 2010. In addition, OCIO stated that they have drafted
procedures for evaluating portfolios, and expect department-level
approval by late August 2010, and to define and begin implementing
criteria for assessing portfolio performance by October 2010.
Notwithstanding these efforts to improve IT investment portfolio
governance, the department will continue to be limited in its ability
to control the risks and achieve the benefits associated with its
portfolios until it has institutionalized its governance boards and
defined and implemented IT investment portfolio control practices,
including criteria for assessing portfolio performance.
IT Human Capital Management:
Having a sufficient IT workforce is essential to a successful systems
modernization program. As we have previously reported, accomplishing
this involves determining the critical skills and competencies needed
to deliver current and future project results, analyzing the gaps
between current skills and future needs, and developing strategies for
filling gaps.[Footnote 27] If performed effectively, these activities
can ensure that organizations have the right people, at the right
time, and with the right skills to execute projects and portfolios of
projects.
We previously reported[Footnote 28] that HUD had analyzed gaps in its
IT workforce in fiscal year 2008 and developed a strategy for
addressing them but that this analysis was based on an incomplete and
outdated inventory of human capital skill levels. Accordingly, we
recommended that HUD establish and execute IT human capital gap
closure strategies based on a complete and current inventory of its
existing IT workforce skills.
In May 2010, HUD began work on a strategic IT human capital management
plan. Thus far, OCIO has mapped the knowledge and skills of its
current staff to its four strategic goals to determine whether
resource gaps exist, and has awarded a contract for expert advice and
assistance in preparing this plan. Among other things, the contractor
is expected to review and provide guidance on IT human capital gap
closure strategies. However, a timeframe for completing this plan has
yet to be established.
As an interim measure, OCIO officials told us that the Transformation
Initiative/IT Project Assessment and Program Support Services project
contractor is to provide basic project management training to existing
IT staff to prepare them to implement the new IT institutional
management controls. Nevertheless, until HUD adopts a strategic
approach to IT human capital management, it will likely not have the
people it needs to successfully deliver modernized systems.
HUD has fallen short of the statutorily-mandated conditions associated
with its fiscal year 2010 IT modernization expenditure plan. As a
result, the utility of HUD's first incremental plan as an oversight,
decision-making, and accountability tool is limited. Until HUD can
submit an expenditure plan that satisfies the statutory conditions, as
well as discloses the risks associated with each project and plans for
mitigating them, its House and Senate Appropriations Subcommittees
will not have the information that they need to oversee HUD's
modernization projects and hold the department accountable for project
results.
Beyond the plan, and notwithstanding HUD's efforts to date to
establish key IT modernization management capabilities, much remains
to be accomplished before these capabilities can be considered
sufficiently institutionalized to reasonably ensure that each
modernization project is successfully completed. While HUD's new OCIO
leadership team has made important progress in developing these
capabilities, it also plans to submit the next incremental expenditure
plan. To the extent that this next plan provides for expanded
investment in the eight modernization projects covered in the first
plan, while also proposing investment in additional projects, the
risks associated with HUD's near-term modernization efforts will
increase. As a result, it is important for HUD to balance the number
of projects in the plan, and the extent to which they are allowed to
proceed beyond definition and early design, with its institutional
capacity to execute them.
Recommendations for Executive Action:
To increase the usability and value of HUD's next expenditure plan to
its House and Senate Appropriations Subcommittees, we recommend that
the Secretary of Housing and Urban Development direct the CIO to
ensure that future plans satisfy each element of each statutory
condition for each project in the plan, or disclose why any element is
not satisfied, along with any associated project risks and plans for
addressing those risks.
Because we have previously made recommendations addressing each of the
four IT modernization management controls discussed in this briefing,
we are not making additional recommendations at this time relative to
institutionalizing them. However, we recommend that the Secretary
direct the CIO to ensure that future plans clearly describe the status
of HUD's efforts to establish and implement each of these
modernization management controls, along with the project-specific
risks and mitigation plans associated with this status. In addition,
we recommend that the Secretary ensure that the number and scope of
HUD's modernization projects are commensurate with the department's
institutional capacity to execute them.
Agency Comments and Our Evaluation:
In commenting on a draft of this briefing, HUD officials, including
the CIO, did not explicitly agree or disagree with our
recommendations. However, they emphasized that our findings and
conclusions relative to the plan's satisfaction of the statutory
conditions do not mean that the projects addressed in the plan are not
being effectively managed. Further, they stated that the draft
briefing did not sufficiently recognize their management actions to
compensate for the fact that new IT governance controls were not yet
in place, and they provided clarifying statements and documentation
relative to these compensatory governance controls. In addition, they
provided a range of technical comments to improve the accuracy and
currency of the briefing.
We agree with HUD's first comment on our findings relative to the
plan's satisfaction of statutory conditions, which is why our
conclusions and recommendations relative to the plan's scope and
content are explicitly confined to the plan's value as a tool for the
appropriation subcommittees in overseeing HUD's modernization and
holding the department accountable for results. With respect to the
second comment on compensatory measures, we have modified the
briefing, as appropriate, to incorporate the clarifying statements,
documentation, and technical comments provided. As a result, we
believe that this briefing fully recognizes both the correct status of
HUD's efforts to institutionalize key IT management controls and the
range of interim measures to compensate for this status.
Attachment 1: Objectives, Scope, and Methodology:
Our objectives were to determine the extent to which (1) the
Department of Housing and Urban Development's (HUD) expenditure plan
meets statutory conditions specified in the Consolidated
Appropriations Act, 2010 and (2) HUD has in place key institutional IT
modernization management capabilities.
To accomplish our first objective, we determined whether the
expenditure plan satisfies, partially satisfies, or does not satisfy
the two sets of conditions, as specified in the act. Specifically,
* For condition 1, we reviewed the plan to determine whether it
contained, for each IT modernization project,[Footnote 29] the
following four elements: a detailed accounting of the functional and
performance capabilities to be delivered, expected mission benefits,
estimated lifecycle costs, and planned key milestones.
* For condition 2, we reviewed and analyzed information in the plan
for two projects[Footnote 30] and other available programmatic
documents (e.g., project plans, integrated master schedules, cost
estimates, staffing plans), augmented as appropriate by interviews
with cognizant officials to determine whether the plan, in combination
with supporting documentation, contained sufficient basis for each of
the four elements of the condition: compliance with the department's
enterprise architecture (EA), management in accordance with applicable
lifecycle policies and guidance, conformance with capital planning
requirements, and support by an adequately staffed project office.
To have satisfied, partially satisfied, or not satisfied a given
element associated with condition 1, the plan had to meet all aspects
of each element for a given condition, meet some (but not all) aspects
of each element for a given condition, or not meet any aspect of each
element for a given condition, respectively. To have satisfied,
partially satisfied, or not satisfied a given element associated with
condition 2, the plan, in combination with project management
documentation, had to similarly meet all, some (but not all), or no
aspects of each element for a given condition, respectively.
To accomplish our second objective, we compared available department
information related to each of the institutional IT modernization
management capabilities cited in the act against our open
recommendations made in a prior report[Footnote 31] on HUD's IT
management controls: EA management, project lifecycle management, IT
investment management, and IT human capital management. We interviewed
cognizant officials to corroborate our understanding of the
department's activities. More specifically:
* For EA management, we reviewed available HUD architecture-related
documentation, including contractor statement of work and project
plans for EA-related assessment activities.
* For project lifecycle management, we reviewed all relevant HUD
planning documentation, where available, including the conceptual
framework for the integrated investment lifecycle, project plan
templates, and draft systems development methodology documents.
* For IT investment management, we reviewed HUD's draft IT governance
plan, past and current versions of the HUD IT Investment Management
Process Guide, executive governance board charters, and meeting
presentations and minutes.
* For IT human capital management, we reviewed available relevant
documents, including the HUD OCIO human capital assessment and program
support vendor contract statement of work.
We determined that project funding and schedule data provided by HUD
were sufficiently reliable for the purposes of this briefing. We based
our decision on an assessment for each area by questioning cognizant
HUD officials about the source of the data and policies and procedures
to maintain the integrity of these data.
We conducted this performance audit at HUD offices in Washington,
D.C., from March 2010 to August 2010 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.
[End of section]
Appendix II: Comments from the Department of Housing and Urban
Development:
U.S. Department Of Housing And Urban Development:
Chief Information Officer:
Washington, DC 201410-3000:
October 22, 2010:
Mr. Randolph C. Hite:
Director:
Information Technology:
Architecture and Systems Issues:
U.S. Government Accountability Office:
441 G Street NW:
Washington, DC 20548:
Dear Mr. Hite:
Thank you for the opportunity to comment on the Government
Accountability Office (GAO) draft report entitled, Information
Technology: HUD Needs to Better Define Commitments and Disclose Risks
jOr Modernization Projects in Future Expenditure Plans (GAO-11-72).
The Department of Housing and Urban Development reviewed the draft
report and concurs with the recommendations for Executive Action. The
"Agency Comments" in the draft report adequately represent HUD's
position, and the appropriate clarifications and comments regarding
HUD's compensating controls have been incorporated into the report.
The Agency remains committed to the establishment of key IT management
and modernization controls needed to ensure the IT environment
maintains mission-critical operations. To this end, we will dedicate
resources toward achieving the three Executive Actions recommended by
GAO.
If you have any questions or require additional information, please
contact Joyce M. Little, Director, Office of Investment Strategies
Policy and Management at (202) 402-7404.
Sincerely,
Signed by:
[Illegible] for:
Jerry E. Williams:
Chief Information Officer:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Randolph C. Hite, (202) 512-3439 or hiter@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Carol Cha (Assistant
Director), Clayton Brisson, Sher'rie Bacon, Elena Epps, Kendrick
Johnson, Lee McCracken, and Freda Paintsil made key contributions to
this report.
[End of section]
Footnotes:
[1] Pub. L. No. 111-117, 123 Stat. 3034, 3093-94 (Dec. 16, 2009).
[2] GAO, Information Technology: HUD Needs to Strengthen Its Capacity
to Manage and Modernize Its Environment, [hyperlink,
http://www.gao.gov/products/GAO-09-675] (Washington, D.C.: July 31,
2009).
[3] According to the statute, not less than $80 million and not more
than $180 million shall be available for IT modernization. The
statutory conditions restrict HUD from obligating funds made available
for IT modernization in the 2010 appropriation until HUD submits an
expenditure plan that satisfies all of the conditions.
[4] These projects are: Development Application Processing System;
Federal Housing Administration Transformation: Infrastructure; Federal
Housing Administration Transformation: Multifamily Housing Development
and Automated Underwriting Business Process Reengineering; HUD
Integrated Core Financial Management Improvement Project; Human
Resources End-to-End Solution (Phase 1); Improvement to Current Tenant-
based Rental Assistance System (Sept. 2010 Release); Next Generation
Voucher Management System (Phase 1); and Transformation Initiative/IT
Project Assessment and Program Support Services.
[5] These are the Federal Housing Administration Transformation:
Infrastructure and Next Generation Voucher Management System (Phase 1)
projects.
[6] GAO, Department of Homeland Security: Formidable Information and
Technology Management Challenge Requires Institutional Approach,
[hyperlink, http://www.gao.gov/products/GAO-04-702] (Washington, D.C.:
Aug. 27, 2004).
[7] GAO-09-675.
[8] GAO, Information Technology: HUD Needs to Strengthen Its Capacity
to Manage and Modernize Its Environment, [hyperlink,
http://www.gao.gov/products/GAO-09-675] (Washington, D.C.: July 31,
2009).
[9] Pub. L No. 111-117 (Dec. 16, 2009). According to the act, not less
than $80 million and not more than $180 million shall be available for
IT modernization.
[10] For the first condition, these are (1) performance and functional
capabilities, (2) mission benefits, (3) estimated lifecycle costs, and
(4) key milestones. For the second condition, these are (1) compliance
with the department's EA, (2) management in accordance with applicable
lifecycle policies and guidance, (3) compliance with capital planning
and control requirements, and (4) support by an adequately staffed
project office.
[11] [hyperlink, http://www.gao.gov/products/GA0-09-675].
[12] Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as
amended, prohibits discrimination in the sale, rental, and financing
of dwellings, and in other housing-related transactions, based on
race, color, national origin, religion, sex, familial status
(including children under the age of 18 living with parents or legal
custodians, pregnant women, and people securing custody of children
under the age of 18), and handicap (disability).
[13] Title VI of the Civil Rights Act of 1964 prohibits discrimination
on the basis of race, color, or national origin in programs and
activities receiving federal financial assistance.
[14] Under the U.S. Housing Act of 1937, Congress created a federal
public housing program to provide decent and safe rental housing for
eligible low-income families, the elderly, and persons with
disabilities.
[15] GAO, Department of Homeland Security: Formidable Information and
Technology Management Challenge Requires Institutional Approach,
[hyperlink, http://www.gao.gov/products/GAO-04-702] (Washington, D.C.:
Aug. 27, 2004).
[16] GAO, Business Systems Modernization: IRS Needs to Better Balance
Management Capacity with Systems Acquisition Workload, [hyperlink,
http://www.gao.gov/products/GAO-02-356] (Washington, D.C.: Feb. 28,
2002).
[17] GAO, Homeland Security: U.S. Visitor and Immigrant Status
Indicator Technology Program Planning and Execution Improvements
Needed, [hyperlink, http://www.gao.gov/products/GAO-09-96]
(Washington, D.C.: Dec. 12, 2008).
[18] [hyperlink, http://www.gao.gov/products/GA0-09-96].
[19] [hyperlink, http://www.gao.gov/products/GA0-09-96].
[20] [hyperlink, http://www.gao.gov/products/GA0-09-96].
[21] [hyperlink, http://www.gao.gov/products/GA0-04-702].
[22] GAO, Information Technology: DHS Needs to Fully Define and
Implement Policies and Procedures for Effectively Managing
Investments, [hyperlink, http://www.gao.gov/products/GAO-07-424]
(Washington, D.C.: Apr. 27, 2007) and GAO-09-675.
[23] [hyperlink, http://www.gao.gov/products/GA0-09-675.
[24] GAO, Aviation Security: Significant Management Challenges May
Adversely Affect Implementation of the Transportation Security
Administration's Secure Flight Program, [hyperlink,
http://www.gao.gov/products/GAO-06-374T] (Washington, D.C.: Feb. 9,
2006).
[25] GAO, Information Technology Investment Management: A Framework
for Assessing and Improving Process Maturity, [hyperlink,
http://www.gao.gov/products/GAO-04-394G] (Washington, D.C.: March
2004).
[26] [hyperlink, http://www.gao.gov/products/GA0-09-675].
[27] GAO, Human Capital: Key Principles for Effective Strategic
Workforce Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39]
(Washington, D.C.: Dec. 11, 2003).
[28] [hyperlink, http://www.gao.gov/products/GA0-09-675].
[29] These projects are: (1) Federal Housing Administration (FHA)
Transformation: Infrastructure, (2) Next Generation Voucher Management
System (Phase 1), (3) Development Application Processing System, (4)
FHA Transformation: Multifamily Housing Development and Automated
Underwriting Business Process Reengineering, (5) HUD Integrated Core
Financial Management Improvement Project, (6) Human Resources End-to-
End Solution (Phase 1), (7) Improvements to Current Tenant-based
Rental Assistance System (Sept. 2010 Release), and (8) Transformation
Initiative/Information Technology Project Assessment and Program
Support Services.
[30] FHA Transformation: Infrastructure and Next Generation Voucher
Management System (Phase 1).
[31] [hyperlink, http://www.gao.gov/products/GA0-09-675].
[End of section]
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