Executive Office of the President
Analysis of Mandated Report on Key Information Technology Areas
Gao ID: GAO-02-779R June 28, 2002
Congress limited the Executive Office of the President's use of systems modernization funds until the White House gave Congress a report that included an enterprise architecture, a description of information technology (IT) capital planning and investment control processes, a capital investment plan, and an IT human capital plan. The White House submitted its report to Congress in March 2002. GAO reviewed the report and found progress in the following four areas: (1) developing an officewide blueprint for modernizing its enterprise architecture; (2) defining officewide IT capital planning and investment control processes for implementing the enterprise architecture consistent with best practices; (3) correcting existing system problems and introducing infrastructure upgrades consistent with its defined technical rules and definitions; and (4) facilitating ongoing and planned efforts to complete the enterprise architecture, expand the capital planning and investment process, and manage the implementation of its fiscal year 2002 and 2003 capital investment plans. The White House has also begun using effective IT human capital management practices. Theses efforts should be considered a work in progress rather than a completed task. Therefore, the success of the White House's modernization effort depends on its ability and resolve in fulfilling its plans and commitments.
GAO-02-779R, Executive Office of the President: Analysis of Mandated Report on Key Information Technology Areas
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June 28, 2002:
The Honorable Byron L. Dorgan:
Chairman:
The Honorable Ben Nighthorse Campbell:
Ranking Minority Member:
Subcommittee on Treasury and General Government:
Committee on Appropriations:
United States Senate:
The Honorable Ernest J. Istook, Jr.
Chairman:
The Honorable Steny H. Hoyer:
Ranking Minority Member:
Subcommittee on Treasury, Postal Service, and General Government:
Committee on Appropriations:
House of Representatives:
Subject: Executive Office of the President: Analysis of Mandated Report
on Key Information Technology Areas:
In the fiscal year 2002 appropriations act covering the Executive
Office of the President (EOP), [Footnote 1] the Congress limited the
office‘s use of systems modernization funds until EOP submitted a
report to the House and Senate Committees on Appropriations that
included an enterprise architecture (blueprint for modernization), a
description of an information technology (IT) capital planning and
investment control process, a capital investment plan (portfolio of
planned investments for fiscal year 2003), and an IT human capital plan
(an approach to meeting strategic human capital needs). As specified in
the act, the report was to be approved by the Office of Management and
Budget (OMB) and reviewed by us.
EOP submitted its enterprise architecture, investment control process
description, and capital investment plan on March 13, 2002; the IT
human capital plan followed on March 18, 2002. These submissions
constitute EOP‘s report, which OMB subsequently approved on April 19,
2002. As we agreed with your offices, our review objective was to
determine EOP‘s progress and plans relative to the four areas covered
by the report.
To accomplish our objective, we reviewed the EOP report to ensure that
it satisfied the conditions specified by the Congress, including that
it addressed each of the key IT management areas cited in the
legislation. In addition, we met with EOP officials, including the
Chief Information Officer (CIO) and Deputy CIO, to determine how each
of the four areas in the report was derived and what plans existed to
further develop each. In doing so, we obtained and reviewed additional
management documentation, such as the enterprise architecture
development plan, descriptions of organizational roles and
responsibilities, and memoranda relating to actions already under way.
We also compared the content of the report and the plans for each topic
area to relevant IT management best practices and federal guidance.
[Footnote 2] We conducted our work from March 2002 through May 2002 in
accordance with generally accepted government auditing standards.
In summary, EOP has made progress, and it has made plans and future
commitments relative to each of the four areas addressed in its report.
First, the office is in the process of developing an officewide
blueprint for modernizing its operations and supporting technology,
commonly referred to as an enterprise architecture. Thus far, it has
developed parts of the architecture, most notably the rules and
definitions governing the technical characteristics of IT investments
and explaining EOP-wide technical service categories (e.g., network
services, security services, etc.). Moreover, the steps it has taken to
complete the architecture are consistent with recognized best
practices. For example, these steps include designating a chief
architect, using an architecture framework and an automated repository
tool, and having a detailed project management plan.
Second, EOP has taken steps toward defining an officewide IT capital
planning and investment control process that is to be used to implement
the enterprise architecture, and these initial steps are also
consistent with best practices. For example, it has established a
council that is to have executive representation from across EOP and
that is intended to function as a corporate investment decision-making
board.
Third, recognizing that both of these key elements of IT management are
not yet mature, the office has defined a portfolio of projects in its
fiscal year 2003 capital investment plan that appropriately focuses on
correcting existing system problems and introducing infrastructure
upgrades that are consistent with its defined technical rules and
definitions.
Fourth, to facilitate its ongoing and planned efforts to complete the
enterprise architecture, expand the capital planning and investment
control process, and manage the implementation of its fiscal year 2002
and 2003 capital investment plans, EOP has also begun employing
effective IT human capital management practices. For example, it has
analyzed its existing human capital capabilities, identified its future
needs, and is taking steps to address shortfalls, such as hiring new
staff, training existing staff, and contracting for missing expertise
and support.
EOP‘s efforts at this juncture should be viewed as work in progress, as
opposed to completed tasks. This means that the office‘s modernization
success largely depends on its ability and resolve in fulfilling its
plans and commitments in each of these areas. To assist the
appropriations committees in overseeing EOP‘s IT management activities,
we have highlighted the office‘s key commitments in this report.
Background:
EOP is a confederation of 12 agencies and offices as well as several
supporting organizations that provide policy and administrative advice
and support to the President in his role as Chief Executive and
Commander in Chief. [Footnote 3] Their missions span such diverse
matters as the economy, national defense, homeland security,
environmental quality, domestic policy, drug control policy, federal
budget formulation and execution, and financial management; the size of
their organizations ranges from 6 to 600 staff. Despite these
differences, these offices and agencies share common functions, such as
the receipt and transfer of information, as well as common
administrative processes, such as human capital and financial
management.
One of EOP‘s offices is the Office of Administration, which is directed
by a Special Assistant to the President. The mission of this office is
to provide EOP-wide administrative services, including financial, human
capital, IT management, and systems support.
In fiscal year 2002, EOP established a CIO organization within the
Office of Administration. The CIO office consists of three groups: the
Information Assurance group, whose mission is to protect information
throughout the EOP from external and internal threats; the Information
Systems and Technology group, whose mission is to deliver IT
capabilities to EOP staff to assist them in efficiently performing
their daily activities; and the Concepts, Requirements, and Systems
Engineering group, whose mission is to champion and promote the use of
an EOP architecture, well-defined system requirements, and structured
development methods. As is represented by the solid and dotted lines in
figure 1, the CIO has structured the operations of these three groups
so that they are individually accountable to the CIO but are to work
collaboratively in achieving their respective missions.
Figure 1: CIO Organizational Chart:
Source: Executive Office of the President, Office of Administration,
Information Technology Architecture, 2001 Annual Update , Version 1.0
(March 1, 2002).
[End of Figure]
Since being established, the CIO organization has been developing and
implementing various IT management plans and processes. Many of these
plans and processes are described in the March 2002 report that the
Director of the Office of Administration submitted in response to the
legislative direction in the fiscal year 2002 appropriations act.
[Footnote 4]:
On April 19, 2002, OMB approved EOP‘s report to the appropriations
committees. In its approval letter, OMB stated that the architecture
and capital planning submissions were an initial step, and that EOP had
much more work to do in creating a fully defined enterprise
architecture and associated investment processes. It also stated that
EOP‘s human capital plan conformed to existing concepts and objectives
driving human capital management in the federal government, but that a
more robust and integrated human capital planning process should follow
in parallel with EOP‘s future enterprise architecture and capital
investment planning efforts.
EOP‘s Report Addresses Four Key Areas of IT Management:
Each of the four areas discussed in EOP‘s report to the appropriations
committees is a key element of IT management. For each of these four
areas, a brief description is provided below. (These four areas should
not be construed as exhaustive, however: other key areas, such as
system life cycle management processes and computer security, for
example, are not addressed in EOP‘s report or our report.)
Enterprise architecture: An enterprise architecture is a blueprint for
operational and systems modernization. In simple terms, an enterprise
is any purposeful activity, and an architecture is the structure (or
structural description) of any activity. More specifically, enterprise
architectures are systematically derived and captured blueprints or
descriptions--in useful models, diagrams, and narrative--of the mode of
operation for a given enterprise, which can be (1) a single
organization or (2) a functional or mission area that transcends more
than one organizational boundary (e.g., financial management,
acquisition management, logistics management). The architecture
describes the enterprise‘s operations in both (1) logical terms, such
as interrelated business processes and business rules, information
needs and flows, work locations and users, and applications, and (2)
technical terms, as defined in a technical standards profile and
technical reference model, [Footnote 5] such as the attributes and
performance standards of hardware, software, data, communications, and
security. The architecture provides these perspectives both for the
enterprise‘s current or ’as is“ environment and for its target or ’to
be“ environment, as well as a sequencing plan for moving from the ’as
is“ to the ’to be“ environment.
IT Capital Planning and Investment Control Process: The IT capital
planning and investment control process is the means by which the
enterprise architecture is implemented. Under this process, new and
ongoing projects originate from business and mission needs of the
components as well as from the sequencing plan for transitioning from
the current to the target architecture; these projects are proposed as
part of a portfolio of investment options for approval by one or more
investment boards. The board(s) make decisions on projects on the basis
of costs, benefits, and risks, using defined selection criteria, such
as positive return on investment and appropriate alignment with the
enterprise architecture and with mission goals and objectives. The
process also provides for controlling these projects throughout their
life cycles to ensure that cost and benefit expectations are being met
and risk is at an acceptable level. As projects are selected and
controlled under this process, deviations from the architecture may be
warranted, and these are used as the basis for updating the
architecture.
IT Capital Investment Plan: The IT capital investment plan (CIP) is a
primary output of the capital planning and investment control process.
The CIP identifies the portfolio of approved IT projects, including
descriptive information about each project, such as statements of
mission needs, descriptions of project capabilities, estimates of cost
and schedule, and projections of return on investment and risk. If the
CIP is developed within the context of an effective investment
management process and a well-defined enterprise architecture, each
project will be linked to mission, goals, and a positive return on
investment.
IT Human Capital Plan: An IT human capital plan is the means by which
effective CIO organizations ensure that they have the right people on
board at the right time to successfully deliver IT projects and
associated services. To be effective, these plans provide for
inventorying and assessing the organization‘s existing knowledge and
skills set; identifying the knowledge and skill sets needed to
implement the target enterprise architecture, supporting sequencing
plan, and annual CIPs; determining the gap between existing
capabilities and needed capabilities; and defining a strategy for
filling the gap, such as new hiring, proactive retention, training, and
use of contractor support.
Enterprise Architecture Progress Is Being Made, and Plans for
Completion Are in Place:
The importance of developing, implementing, and maintaining an
enterprise architecture is a basic tenet of effective IT management.
Used in concert with other IT management controls, such as an IT
capital planning and investment control process, a well defined and
applied architecture can appreciably increase the chances that an
enterprise‘s operations and systems will be structured in a way that
optimizes mission performance. We have found that attempting to
modernize operations and systems without an architecture leads to
operational and systems duplication, lack of integration, and
unnecessary expense. Our best practices research on successful public
and private sector organizations has similarly identified enterprise
architectures as essential to effective business and technology
transformation. [Footnote 6]:
Using our experience and research in enterprise architecture, we teamed
with the federal CIO Council to produce guidance on effective
architecture management, including practices that are critical to
successfully developing one. [Footnote 7] Among other things, this
guidance emphasizes that the following practices are critical to
effectively developing an architecture: (1) establishing a steering
committee to guide and direct the architecture effort and ensuring that
this committee is composed of executives who represent the entire
enterprise, (2) designating a chief architect under the CIO to manage
the architecture effort, (3) using a framework to govern the structure
and content of the architecture that includes views of the enterprise
from its business, data, applications, and technology perspectives,
(4) using an automated tool to capture the content of the architecture,
and (5) managing the architecture effort as a formal program, including
having a detailed plan and work breakdown structure.
EOP is satisfying each of these practices. In particular:
* The Special Assistant to the President and Director of the Office of
Administration has established an Information Resources Management
Executive Council, which is intended, among other things, to serve as
the enterprise architecture steering committee and to ensure that EOP
business processes are identified and used as the driver in selecting
and aligning supporting IT projects and initiatives. The council
membership is to consist of senior executives from 18 different EOP
customer groups. The council is to be supported by the Enterprise
Technology Task Force, which is to focus on technical architectural
issues across the office.
* The Director of Concepts, Requirements, and Systems Engineering, who
reports to the EOP CIO, is the designated chief architect.
* The chief architect is using the Federal Enterprise Architecture
Framework, which includes business, data, application, and technology
components.
* The chief architect is using a commercially available automated
repository tool to capture EOP‘s architectural artifacts.
* The chief architect is managing the architecture effort as a formal
program. For example, an Enterprise Architecture Development and
Sustainment Process and Concept of Operations has been developed that
describes the activities, key players (including their roles and
responsibilities), and major outputs of the program. Also, a
development plan has been prepared that includes a detailed breakdown
of tasks and milestones. Two key milestones against which future
progress can be measured are the development of a target architecture
and the development of a plan for sequencing from the baseline to the
target architecture, both of which are to be completed by September 16,
2002.
In addition to EOP‘s plans for completing its enterprise architecture,
it has already developed certain architectural components. For example,
EOP has described the current or ’as is“ business processes and
information requirements unique to its offices and agencies, as well as
those shared among several (or all) offices and agencies. It has also
described the existing networks and infrastructure across the office.
Further, EOP has defined the principles and goals that are to govern
the content of its target architecture, and it has defined a technical
reference model and a technical standards profile to guide and
constrain near-term investments in its IT infrastructure. For example,
it has developed standards profiles to govern the characteristics of
new software and hardware across a number of domains, including
operating platforms, data management, data interchange, and network
services.
EOP owes its progress and commitments in enterprise architecture
largely to the CIO office‘s understanding of the importance and value
of this IT management tool. Assuming that progress continues and the
architecture development plan is effectively implemented, EOP‘s ability
to effectively invest in IT should benefit from its architecture
efforts.
EOP-wide Capital Planning and Investment Control Process Is Planned:
The need for a well-defined and implemented capital planning and
investment control process, sometimes referred to as an investment
management process, is also a fundamental tenet of effective IT
management. Our research on successful public and private sector
organizations shows that these organizations have institutional and
disciplined approaches to identifying, selecting, controlling, and
evaluating IT investments. As this research also shows, the approach of
these organizations is to establish corporate investment boards with
responsibility for investment decisionmaking and to link decisions
about competing investment options to defined criteria, such as mission
needs and outcomes, return on investment, and investment risk. Using
this research, we published a framework to assist organizations in
establishing effective IT investment management processes. [Footnote 8]
In addition, OMB has issued guidance requiring agencies to have such a
process. [Footnote 9]:
In developing and executing its fiscal year 2003 CIP and budget
request, the EOP CIO office has followed a systematic approach to
identifying, selecting, and controlling its IT project investments. For
example, EOP identified and selected IT projects based on defined
criteria, and it mapped each project to one or more IT strategic plan
goals. As part of the decision criteria, each proposal was to include
the following elements:
* project description, including scope, actions to be taken,
relationship to other systems, and alignment with technical standards
profile and reference model;
* cost (including capital investment and maintenance) and funding
sources;
* users‘ needs to be resolved;
* benefits and returns, including cost and time savings and
productivity gains; and:
* mission impact if the project is not selected and funded.
Further, the CIO office is using a structured process to control
project execution. According to the Deputy CIO, project managers are
required to follow a standard briefing template in reporting monthly to
the CIO and Deputy CIO on the status of their respective projects. In
these sessions, project progress is evaluated against cost, schedule,
and performance commitments; business cases justifying investment in
the project are examined; and project risks are addressed.
Recognizing the value of having an EOP-wide investment management
process, the CIO office plans to extend and expand the existing
process, so that it includes all EOP IT user groups and makes use, for
example, of the enterprise architecture now under development. As a
first step, EOP is in the process of establishing the Information
Resources Management Executive Council, which is to guide and direct
definition of this process and also to function as the EOP corporate
investment board. According to EOP officials, specific plans and
milestones for defining and implementing an EOP-wide investment
management process have not yet been established because the office was
waiting for the council, as an EOP corporate body, to lead this effort.
According to a CIO official, the council is to convene in June 2002 to
begin formulating plans. Assuming EOP follows through on its stated
commitments, it would be in a position to establish a critical
capability for effectively managing its IT investments.
Current CIP Focuses on Near-Term Needs, Future
Infrastructure, and IT Management Tools:
In cases where federal agencies have yet to complete an enterprise
architecture and a corporate investment management process, we have
recommended that IT investments focus on certain near-term priorities.
These priorities include projects that introduce enabling IT
infrastructure and conform to agreed upon technical characteristics and
service categories; projects that are intended to establish IT
management capabilities (e.g., the architecture and an investment
management process); projects that allow the organization to ’stay in
business,“ meaning that they correct known performance problems with
existing systems; and projects that represent low risk and high payoff.
[Footnote 10]
EOP‘s fiscal year 2003 CIP focuses on investments that are consistent
with our prior recommendations to other agencies. Funding in the CIP is
devoted to projects that improve the office‘s existing IT
infrastructure. For example, one of the largest planned investments ($5
million) is for the redesign and relocation of the EOP data center to
address issues of security and continuity of operations that were
raised after the terrorist attacks of September 11, 2001. Other planned
infrastructure investments include $1.5 million for customer service
and desktop systems, and about $1 million for upgrading existing
network communications.
The narrow focus of the range of projects in the CIP reflects the CIO
office‘s awareness of the kinds of investments that are appropriate at
this early stage in the office‘s IT modernization agenda. According to
CIO officials, projects aimed at business process reform will not be
proposed until, for example, the architecture and investment
decisionmaking process governing such reform are in place. This
narrowly focused CIP should allow EOP to make the best near-term use of
its available IT resources and capabilities and allow it to position
itself for its longer term modernization.
IT Human Capital Plan Is Being Implemented:
As we have previously reported, [Footnote 11] strategic human capital
centers on viewing people as assets whose value to an organization can
be enhanced through investment. As the value of its people increases,
so does the performance capacity of the organization. To maintain and
enhance the capabilities of IT staff specifically, an organization
should (1) assess the IT knowledge and skills needed to effectively
support agency mission goals, (2) inventory the knowledge and skills of
current IT staff, (3) identify gaps between needs and current
capabilities, and (4) develop and implement plans to fill the gaps.
EOP officials stated that they recognize the importance of
understanding the office‘s unmet IT human capital requirements and of
planning how best to acquire, develop, and retain resources to meet
these requirements. To this end, the office has developed an IT human
capital plan for meeting these requirements, based on (1) a definition
of needed IT knowledge and skills, (2) an inventory of its current IT
workforce knowledge and skills, and (3) a gap analysis of shortfalls.
More specifically, EOP‘s CIO office used its planned IT initiatives and
projects, combined with the perspectives of senior CIO staff, to
identify 14 core knowledge and skill areas needed to support current
and future operations. For example, its analysis showed that the CIO
organization is becoming increasingly reliant on contractor support,
and that improvements in project management and contractor oversight
capabilities were needed. Accordingly, both are now included in the 14
core knowledge and skill competencies. The CIO office then surveyed and
summarized the knowledge and skill sets of onboard staff (government
and contractor), including their technical training and certification
and years of experience. Next, a gap analysis was performed that
compared the needed IT knowledge and skills with the inventory of
current IT workforce knowledge and skills. Using this analysis, the CIO
office identified shortfalls in nine areas, including project
management, enterprise architecture, and staff support for the data
center. With respect to project management, for example, the analysis
identified project management as the primary role of the CIO office‘s
government staff, and recognized the need for skills in such project
management areas as managing people, planning, documenting, project
performance, cost analysis, and risk management.
To begin addressing human capital shortfalls, EOP has developed a plan
consisting of various initiatives, most of which are under way. For
example, it has begun training staff in project management, contractor
oversight, and enterprise architecture management. It plans to hire
additional government staff and intends to fill the remaining gaps in
IT knowledge and skill sets using contractor staff, once it has re-
competed its systems engineering and technical assistance contract,
which expires in September 2002.
Moreover, the CIO office has made several future commitments that
recognize the need to continually evaluate its needs and develop and
retain its IT human capital in order to support EOP‘s mission. These
include:
* assessing the effect on IT human capital capabilities of each
architecture update or organizational realignment;
* maintaining the existing staff knowledge and skills inventory;
* working with each staff member to ensure that CIO organizational
goals and objectives are understood, identifying individual training
needs, and developing training plans; and:
* providing training in core skills and knowledge areas using in- house
expertise and outside resources.
EOP owes its progress and commitments in IT human capital largely to
the CIO office‘s understanding of the importance and value of this
strategic asset. Assuming that progress continues and plans are
effectively implemented, EOP‘s ability to effectively invest in IT
should benefit from its IT human capital program.
Concluding Observations:
EOP and OMB have satisfied their legislative requirements to report to
the appropriation committees on certain IT management areas and to
approve the report, respectively. In doing so, they have recognized
that EOP has work remaining to mature in each of these areas. This is
consistent with the results of our analysis. To this end, EOP has made
plans and future commitments, which can be used to measure its progress
in each area.
Agency Comments and Our Evaluation:
In oral comments on a draft of this report, the Associate Counsel to
the President stated that EOP‘s CIO was satisfied with the substance of
the report and that the White House had no substantive comments. The
Associate Counsel provided additional information on EOP agencies and
offices. We have incorporated this information into the report as
appropriate.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of other Senate and House committees and subcommittees
that have appropriations, authorization, and oversight
responsibilities for EOP. We are also sending copies to the Director of
the EOP Office of Administration, the EOP CIO, and the OMB Director.
Copies will also be made available to others upon request.:
Should you or your staff have any questions on matters discussed in
this report, please contact me at (202) 512-3439. I can also be reached
by E-mail at hiter@gao.gov . Major contributors of this report include
William G. Barrick, Barbara Collier, Larry E. Crosland, Lester P.
Diamond, Richard B. Hung, and David L. McClure.
Randolph C. Hite:
Director, Information Technology Architecture and Systems Issues:
Signed by Randolph C. Hite.
(310436):
FOOTNOTES
[1] Treasury and General Government Appropriations Act for Fiscal Year
2002 (Public Law 107-67).
[2] Chief Information Officers Council, Architecture Alignment and
Assessment Guide, (October 2000); Chief Information Officers Council, A
Practical Guide to Federal Enterprise Architecture, Version 1.0
(February 2001); Office of Management and Budget, Management of Federal
Information Resources, Circular No. A-130 (November 30, 2000); U.S.
General Accounting Office, Information Technology Investment
Management: A Framework for Assessing and Improving Process Maturity,
Exposure Draft, GAO/AIMD-10.1.23 (Washington D.C.: May 2001). U.S.
General Accounting Office, Human Capital: Attracting and Retaining a
High-Quality Information Technology Workforce, GAO-02-113T
(Washington, D.C.: October 4, 2001).
[3] The agencies/offices are the White House Office (includes, for
example, the Office of Homeland Security), Office of the Vice
President, Council on Environmental Quality, Office of Management and
Budget, Office of Policy Development, President‘s Foreign Intelligence
Advisory Board, Office of Administration, Office of Science and
Technology Policy, Office of National Drug Control Policy, National
Security Council, Council of Economic Advisors, and the U.S. Trade
Representative; the supporting organizations include the White House
Communications Agency, a support office of the General Services
Administration, the U. S. Secret Service, and the White House Branch of
the U.S. Postal Service.
[4] Treasury and General Government Appropriations Act for Fiscal Year
2002 (Public Law 107-67).
[5] As defined in a guide on enterprise architectures published by the
CIO Council, a technical standards profile is the set of rules that
govern system implementation and operation; a technical reference model
is a taxonomy of enterprise service areas, interface categories, and
relationships to address interoperability and open-systems issues.
[6] U.S. General Accounting Office, Executive Guide: Improving Mission
Performance through Strategic Information Management and Technology,
GAO/AIMD-94-115 (Washington, D.C.: May 1994).
[7] Chief Information Officers Council, Architecture Alignment and
Assessment Guide (October 2000); Chief Information Officers Council, A
Practical Guide to Federal Enterprise Architecture, Version 1.0
(February 2001).
[8] GAO/AIMD-10.1.23.
[9] Office of Management and Budget, Management of Federal Information
Resources, Circular No. A-130 (November 30, 2000).
[10] See, for example, U.S. General Accounting Office, Information
Technology: INS Needs to Strengthen Its Investment Management
Capability, GAO-01-146 (Washington, D.C.: December 29, 2000), and U.S.
General Accounting Office, Tax Administration: IRS‘ Fiscal Year 1999
Budget Request and Fiscal Year 1998 Filing Season, GAO/T-GGD/AIMD-98-
114 (Washington, D.C.: March 31, 1998).
[11] GAO-02-113T.