Immigration Benefits System:

Better Informed Decision Making Needed on Transformation Program

GAO-15-415: Published: May 18, 2015. Publicly Released: Jun 17, 2015.

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chac@gao.gov

 

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What GAO Found

The U.S. Citizenship and Immigration Services' (USCIS) currently expects that its Transformation Program will cost up to $3.1 billion and be fully deployed no later than March 2019, which is an increase of approximately $1 billion and delay of over 4 years from its initial July 2011 baseline. In March 2012, the program began to significantly change its acquisition strategy to address various technical challenges (see table).


Key Changes to the Transformation Program's Acquisition Strategy

Key change

Previous approach

New approach

Software development

Waterfall: sequential phases, often with delivery years after start

Agile: delivery in small, short increments

Contracting approach

Single contractor

Multiple contractors with USCIS as system integrator

Program architecture

Wide use of proprietary commercial off the shelf products

Wide use of open source software (i.e., publicly available)

Source: GAO analysis of USCIS documentation. | GAO-15-415

These changes have significantly delayed the program's planned schedule, which in turn has had adverse effects on when USCIS expects to achieve cost savings, operational efficiencies, and other benefits. Among other things, USCIS has yet to achieve the goal of enhancing national security by authenticating users and integrating with external agency databases.

While the program's two key governance bodies have taken actions aligned with leading IT management practices, neither has used reliable information to make decisions and inform external reporting (see table). For example, one governing body's vote in March 2013 to migrate to a new architecture was based in part on savings that did not account for the added costs of merging data from the old architecture. The ability of USCIS, DHS, and Congress to effectively monitor program performance may be limited until these bodies more effectively use reliable information to inform their program evaluations.


Extent to Which Program Governance Bodies Met Leading Practices for Oversight

Leading practice

Acquisition Review Board

Executive Steering Committee

Monitor project's performance and progress toward predefined cost and schedule

Ensure that corrective actions are identified and assigned to the appropriate parties at the first sign of cost, schedule, or performance problems

Ensure that corrective actions are tracked until the desired outcomes are achieved

Rely on complete and accurate data to review performance against stated expectations

● Implemented ◐ Partially implemented ○ Not implemented

Source: GAO analysis of USCIS documentation. | GAO-15-415

Why GAO Did This Study

Each year, the Department of Homeland Security's (DHS) USCIS processes millions of applications for persons seeking to study, work, visit, or live in the United States. USCIS has been working since 2005 to transform its outdated systems into an account-based system with electronic adjudication and case management tools that will allow applicants to apply and track the progress of their application online. In 2011, USCIS reported that this effort, called the Transformation Program, was to be completed no later than June 2014 at a cost of up to $2.1 billion.

Given the critical importance of the Transformation Program, GAO was asked to review it. This report (1) discusses the program's current status, including the impact of changes made, and (2) assesses the extent to which DHS and USCIS are executing effective program oversight and governance.

To do so, GAO reviewed DHS and USCIS documents, interviewed relevant officials, and compared program documentation and actions to DHS and USCIS policy and guidance and GAO and industry leading information technology practices.

What GAO Recommends

GAO is making recommendations to DHS components and offices to improve governance and oversight of the Transformation Program. DHS agreed with the recommendations, but did not agree with GAO's evaluation of the impact of changes made to the acquisition strategy. GAO maintains its position on the impact of changes, as discussed in the report.

For more information, contact Carol R. Cha at (202) 512-4456 or chac@gao.gov.

 

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In May 2015, the Department of Homeland Security provided an approved acquisition program baseline and supporting documentation, including the Acquisition Decision Memorandum signed by the Acting Deputy Under Secretary for Management. These documents demonstrate that the department has approved a re-baseline of cost, schedule, and performance expectations for the remainder of the Transformation Program. This re-baseline helps ensure that progress made by the program can be monitored against established and approved parameters.

    Recommendation: To help ensure that progress made by the Transformation Program can be monitored against established and approved parameters, the Secretary of DHS should direct the department's Under Secretary for Management to re-baseline cost, schedule, and performance expectations for the remainder of the Transformation Program.

    Agency Affected: Department of Homeland Security

  2. Status: Open

    Comments: As of August 2017, the Department of Homeland Security (DHS) had demonstrated that it had taken steps to address this recommendation, but additional steps were needed. Since we issued this recommendation in May 2015, the Office of Program Accountability and Risk Management (PARM), which serves as the Acquisition Review Board (ARB) executive secretariat and is to oversee DHS's acquisition portfolio, in coordination with the Office of the Chief Information Officer, has actively increased program oversight. For example, beginning in May 2015, the U.S. Citizenship and Immigration Services (USCIS) demonstrated that it submitted data supporting cost, schedule, and technical performance metrics to DHS on a monthly basis. The ARB has also held a number of meetings to discuss the Transformation Program and issued associated Acquisition Decision Memoranda with related action items. In addition, in February 2016, PARM demonstrated that DHS developed a procedure to help ensure acquisition decision memorandum actions, including corrective actions, are tracked until the desired outcomes are achieved. However, as of August 2017, the USCIS Transformation Program was in breach of its previously approved schedule expectations and was taking a strategic pause in developing new software while working to re-baseline cost and schedule expectations. During this strategic pause, the program is working to complete various action items assigned by the Acquisition Review Board, including completing an updated Release Roadmap and submitting it to PARM no later than December 29, 2017; updated Lifecycle Cost Estimate and providing it to the Cost Analysis Division no later than December 29, 2017; updated Test and Evaluation Master Plan and submitting it to the Office of Test and Evaluation no later than January 31, 2018; and an updated Acquisition Program Baseline and providing it to PARM no later than December 29, 2017. We will continue to monitor DHS?s efforts to re-baseline the USCIS Transformation Program and the Acquisition Review Board's efforts to monitor the Transformation Program's performance and progress toward a predefined cost and schedule; ensure that corrective actions are tracked until the desired outcomes are achieved; and rely on complete and accurate program data to review the performance of the Transformation Program against stated expectations until and after a new baseline is established.

    Recommendation: To improve Transformation Program governance, the Secretary of DHS should direct the Under Secretary for Management to ensure that the Acquisition Review Board is effectively monitoring the Transformation Program's performance and progress toward a predefined cost and schedule; ensuring that corrective actions are tracked until the desired outcomes are achieved; and relying on complete and accurate program data to review the performance of the Transformation Program against stated expectations.

    Agency Affected: Department of Homeland Security

  3. Status: Open

    Comments: As of August 2017, the Department of Homeland Security (DHS) had demonstrated that it had taken steps to address this recommendation, but additional steps were needed. More specifically, as of July 2016, the U.S. Citizenship and Immigration Services (USCIS) Transformation program office provided evidence that the Executive Steering Committee (ESC) continued to discuss cost, schedule, and operational performance metrics as part of the program's ESC meetings. However, as of August 2017, the USCIS Transformation Program was in breach of its previously approved schedule expectations and was taking a strategic pause in developing new software while working to re-baseline its cost and schedule expectations. During this strategic pause, the program is working to complete various action items assigned by the Acquisition Review Board, including completing an updated Release Roadmap and submitting it to the Office of Program Accountability and Risk Management (PARM) no later than December 29, 2017; updated Lifecycle Cost Estimate and providing it to the Cost Analysis Division no later than December 29, 2017; updated Test and Evaluation Master Plan and submitting it to the Office of Test and Evaluation no later than January 31, 2018; and an updated Acquisition Program Baseline and providing it to PARM no later than December 29, 2017. In addition, according to the program?s August 2017 Acquisition Decision Memorandum, the ESC has been transformed into a component-only body with no headquarters involvement, and the program was to establish a Program Management Integrated Product Team, which was to meet bi-weekly beginning in September 2017. We will continue to monitor DHS's efforts to re-baseline the USCIS Transformation Program, the impact of changes to the ESC, and the ESC?s efforts to effectively monitor the Transformation Program's performance and progress toward a predefined cost and schedule and rely on complete and accurate program data to review the performance of the Transformation Program against stated expectations until and after a new program baseline is established.

    Recommendation: To improve Transformation Program governance, the Secretary of DHS should direct the DHS Under Secretary for Management, in coordination with the Director of US Citizenship and Immigration Services, to ensure that the Executive Steering Committee is effectively monitoring the Transformation Program's performance and progress toward a predefined cost and schedule and relying on complete and accurate program data to review the performance of the Transformation Program against stated expectations.

    Agency Affected: Department of Homeland Security

  4. Status: Open

    Comments: As of September 2017, the Department of Homeland Security (DHS) had demonstrated that it had taken steps to address this recommendation, but additional steps were needed. In particular, in February 2016, the DHS Office of the Chief Information Officer (OCIO), in coordination with the Office of Program Accountability and Risk Management (PARM), had consolidated the department's Investment Management System and Next Generation Periodic Reporting System tools into a single enterprise information management and repository system named Investment Evaluation, Submission, and Tracking (INVEST). According to the department, this effort should improve the reliability of the metrics used by OCIO's Enterprise Business Management Office (EBMO), as well as the other line of business and component program offices, and ensure data integrity. The data reported in INVEST include cost, schedule, and operational performance metrics that are to align with the OMB's Information Technology (IT) Dashboard reporting requirements. In addition, as of September 2017, the program was listed as a high-risk program on the federal IT dashboard, in contrast to its April 2015 rating of medium risk. However, as of August 2017, the program was in breach of its previously approved schedule expectations and was taking a strategic pause in developing new software while working to re-baseline its cost and schedule expectations. We will continue to monitor DHS?s efforts to re-baseline the USCIS Transformation Program and the Office of the Chief Information Officer's efforts to use accurate and reliable information to update the federal IT dashboard until and after a new program baseline is established.

    Recommendation: To help ensure that assessments prepared by the Office of the Chief Information Officer in support of the department's updates to the federal IT Dashboard more fully reflect the current status of the Transformation Program, the Secretary of DHS should direct the department's Chief Information Officer to use accurate and reliable information, such as operational assessments of the new architecture and cost and schedule parameters approved by the Under Secretary of Management.

    Agency Affected: Department of Homeland Security

 

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