Immigration Benefits:

Consistent Adherence to DHS's Acquisition Policy Could Help Improve Transformation Program Outcomes

GAO-12-66: Published: Nov 22, 2011. Publicly Released: Nov 22, 2011.

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Each year, the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS) processes millions of applications for immigration benefits using a paper-based process. In 2005, USCIS embarked on a major, multiyear program to transform its process to a system that is to incorporate electronic application filing, adjudication, and case management. In 2007, GAO reported that USCIS was in the early stages of the Transformation Program and that USCIS's plans partially or fully met key practices. In 2008, USCIS contracted with a solutions architect to help develop the new system. As requested, GAO evaluated the extent to which USCIS has followed DHS acquisition policy in developing and managing the Transformation Program. GAO reviewed DHS acquisition management policies and guidance; analyzed transformation program planning and implementation documents such as operational requirements; compared schedule and cost information with GAO best practice guidance; and interviewed USCIS officials..

USCIS has not consistently followed the acquisition management approach that DHS outlined in its management directives in developing and managing the Transformation Program. USCIS awarded a solutions architect contract in November 2008, in effect selecting an acquisition approach before completing documents required by DHS management directives. Specifically, DHS's acquisition policy requires that prior to selecting an acquisition approach, programs establish operational requirements, develop a program baseline against which to measure progress, and complete a plan that outlines the program's acquisition strategy. However, USCIS did not complete an Operational Requirements Document until October 2009, which was to inform the Acquisition Program Baseline and the Acquisition Plan. Consequently, USCIS awarded a solutions architect contract to begin capability development activities prior to having a full understanding of the program's operational requirements and the resources needed to execute the program. GAO has previously reported that firm requirements must be established and sufficient resources must be allocated at the beginning of an acquisition program, or the program's execution will be subpar. The lack of defined requirements, acquisition strategy, and associated cost parameters contributed to program deployment delays of over 2 years. In addition, through fiscal year 2011, USCIS estimates it will have spent about $703 million, about $292 million more than the original program baseline estimate. USCIS expects to begin deployment of the first release of the Transformation Program in December 2011. However, USCIS is continuing to manage the program without specific acquisition management controls, such as reliable schedules, which detail work to be performed by both the government and its contractor over the expected life of the program. As a result, USCIS does not have reasonable assurance that it can meet its future milestones. USCIS has established schedules for the first release of the Transformation Program, but GAO's analysis shows that these schedules are not reliable as they do not meet best practices for schedule estimating. For example, program schedules did not identify all activities to be performed by the government and solutions architect. Moreover, as outlined by DHS acquisition management guidance, a life-cycle cost estimate is a required and critical element in the acquisition process. USCIS has developed and updated the $1.7 billion life-cycle cost estimate for the Transformation Program, but USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, raising questions about the credibility of the program's life-cycle cost estimates. Because some program costs such as labor, supervision, and facilities cost more if the program takes longer, reliable schedules can contribute to an understanding of the cost impact if the program does not finish on time. Collectively, and moving forward, not meeting best practices increases the risk of schedule slippages and related cost overruns, making meaningful measurement and oversight of program status and progress, and accountability for results, difficult to achieve. GAO recommends that USCIS ensure its program schedules and life-cycle cost estimates are developed in accordance with best practices guidance. DHS concurred with GAO's recommendations and outlined the actions that USCIS is taking or has taken to address each recommendation.

Recommendations for Executive Action

  1. Status: Open

    Comments: In November 2011, GAO reported that the U.S. Citizenship and Immigration Services (USCIS) had not consistently followed the acquisition management approach that the Department of Homeland Security (DHS) outlined in its management directives in developing and managing the Transformation Program. In particular, USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, raising questions about the credibility of the program's life-cycle cost estimates. Thus, GAO recommended that USCIS ensure program schedules are consistent with the nine estimating best practices. USCIS officials briefed GAO several times throughout 2012 on actions that they are taking to implement this recommendation as they transition to an Agile Development Framework for systems development. USCIS has been working to implement several of the best practices from GAO's report. For example, USCIS has taken steps to identify all resources working on agile teams and allocated those resources to their corresponding activities; integrate schedule activities horizontally and vertically; establish the critical path for all activities; conduct a risk analysis; and, establish a baseline. On May 4, 2015, USCIS approved a new Transformation Program Acquisition Program Baseline and supporting documentation. This baseline allows for an approximate $1 billion increase in life cycle costs, and an extension of over four years from the original deployment date. The Transformation Program is expected to deliver the same core operational requirements as initially intended, but the plan for deployment has been revised. To fully implement GAO's recommendation, USCIS should provide the revised program schedules to GAO. GAO will assess the new baseline documentation, including the program schedules, to ensure that the schedules are consistent with the nine estimating best practices.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should ensure program schedules are consistent with the nine estimating best practices.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

  2. Status: Open

    Comments: In November 2011, GAO reported that the U.S. Citizenship and Immigration Services (USCIS) had not consistently followed the acquisition management approach that the Department of Homeland Security (DHS) outlined in its management directives in developing and managing the Transformation Program. In particular, GAO reported that USCIS had established the Transformation Program as a long-term program made up of five releases to procure, test, deploy, and maintain the USCIS Electronic Immigration System (ELIS), but USCIS officials stated that there was no integrated master schedule for the entire Transformation Program. Therefore, GAO recommended that USCIS develop and maintain an Integrated Master Schedule (IMS) consistent with the nine best practices that GAO identified. According to best practices, an integrated master schedule is to contain the detailed tasks necessary to ensure program execution and is a required document to develop key acquisition planning documents under DHS acquisition management guidance. USCIS officials briefed GAO several times throughout 2012 on actions that they are taking to implement this recommendation as they transition to an Agile Development Framework for systems development. In February 2013, USCIS told GAO that it formed an Operations and Maintenance Agile team that would be responsible for developing and maintaining an IMS. On May 4, 2015, USCIS approved a new Transformation Program Acquisition Program Baseline. According to the USCIS component lead in the Office of Program Accountability and Risk Management (PARM), in support of this new baseline, the Transformation Program developed and PARM approved a revised IMS. The new program baseline allows for an approximate $1 billion increase in life cycle costs and an extension of over four years from the original deployment date. The Transformation Program is expected to deliver the same core operational requirements as initially intended, but the plan for deployment has been revised. To fully implement GAO's recommendation, USCIS should provide the revised IMS to GAO. GAO will assess the new baseline documentation, including the IMS, to ensure that it is consistent with best practices.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should develop and maintain an Integrated Master Schedule consistent with these same best practices for the Transformation Program.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

  3. Status: Open

    Comments: In November 2011, GAO reported that U.S. Citizenship and Immigration Services (USCIS) lacked reliable schedules; therefore, GAO found that its ability to develop reliable life-cycle cost estimates for the Transformation Program was hampered. As outlined by Department of Homeland Security (DHS) acquisition management guidance, a life-cycle cost estimate (LCCE) is a required and critical element in the acquisition process. GAO reported that USCIS had developed and updated the LCCE for the Transformation Program, but USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, thus raising questions about the credibility of the program's LCCEs. Thus, GAO recommended that USCIS ensure that the LCCE for the Transformation Program is informed by milestones and associated tasks from reliable schedules that are developed in accordance with the nine best practices that GAO identified. USCIS officials briefed GAO several times throughout 2012 and 2013 on actions that they are taking to implement this recommendation. USCIS approved a new Transformation Program Acquisition Program Baseline, including a new LCCE, on May 4, 2015, and provided it to GAO. The new program baseline allows for an approximate $1 billion increase and an extension of over four years from the original deployment date. GAO will assess USCIS's new baseline documentation, including the LCCE, to ensure that reliable schedules were used to project costs and develop the LCCE. To fully implement this recommendation, USCIS needs to demonstrate that the LCCE was informed by milestones and associated tasks from reliable schedules in accordance with the nine best practices GAO identified.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should ensure that the life-cycle cost estimate is informed by milestones and associated tasks from reliable schedules that are developed in accordance with the nine best practices we identified.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

 

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