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entitled 'Information Technology: Early Releases of Customs Trade 
System Operating, but Pattern of Cost and Schedule Problems Needs to Be 
Addressed' which was released on May 14, 2004.

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Report to Congressional Committees: 

May 2004: 

INFORMATION TECHNOLOGY: 

Early Releases of Customs Trade System Operating, but Pattern of Cost 
and Schedule Problems Needs to Be Addressed: 

[Hyperlink, http: //www.gao.gov/cgi-bin/getrpt?GAO-04-719]: 

GAO Highlights: 

Highlights of GAO-04-719, a report to the Subcommittees on Homeland 
Security, Senate and House Committees on Appropriations 

Why GAO Did This Study: 

The Department of Homeland Security’s (DHS) Bureau of Customs and 
Border Protection (CBP) is conducting a multiyear, multibillion-dollar 
acquisition of a new trade processing system planned to support the 
movement of legitimate imports and exports and strengthen border 
security. By congressional mandate, expenditure plans for this system, 
called the Automated Commercial Environment (ACE), must meet certain 
conditions, including GAO review. This study addresses the extent to 
which the latest plan, for fiscal year 2004, satisfies these 
conditions, provides information about DHS’s efforts to implement GAO’s 
recommendations for improving ACE management, and makes observations 
about ACE.

What GAO Found: 

The DHS fiscal year 2004 ACE expenditure plan provides for certain 
activities, including system implementation infrastructure and support, 
operations and maintenance, and the definition and design of two future 
releases. This plan, including related program documentation and 
program officials’ statements, largely satisfies the legislative 
conditions imposed by the Congress. Some of the recommendations that 
GAO has previously made to strengthen ACE management have been 
addressed, and DHS has committed to addressing those that remain. 
However, much remains to be done before these recommendations are fully 
implemented. Specifically, progress on overcoming human capital 
challenges has been slow.

GAO made several observations about ACE. Specifically, the first two 
ACE releases, which have been deployed, are operating largely as 
intended. However, achieving this initial operating capability has been 
difficult. DHS has established a pattern of borrowing resources from 
future releases to address problems of near-term releases, which has 
adversely affected the cost, schedule, and capability commitments of 
ongoing releases. In particular, the delay in completing the second ACE 
release has introduced a pattern of increased reliance on concurrent 
activities to meet the dictated schedule, continued release schedule 
delays, and cost overruns for the ongoing releases, as the figure below 
indicates. This domino effect is continuing into Release 3 and beyond. 
This pattern is not likely to change unless the degree of concurrence 
among activities within and between releases is better controlled, 
which will require that the reasons for release quality problems that 
led to the concurrent activity be addressed. Until the reasons for this 
pattern are pinpointed and corrected, in part through implementation of 
GAO’s unaddressed recommendations, DHS will not be positioned to 
deliver promised capabilities on time and within budget, or produce 
mission value commensurate with investment cost.

What GAO Recommends: 

To assist DHS in managing ACE and increasing the chances that future 
releases will deliver promised capabilities on time and within budget, 
GAO is making recommendations to the Secretary of Homeland Security 
aimed at addressing recurring cost and schedule problems. DHS concurred 
with GAO’s recommendations and described specific actions that it is 
taking to respond to each.

www.gao.gov/cgi-bin/getrpt?GAO-04-719

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Randolph C. Hite at (202) 
512-3439 or hiter@gao.gov.

[End of section]

Contents: 

Letter: 

Compliance with Legislative Conditions: 

Status of Open Recommendations: 

Observations on Management of ACE: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: IT: Early Releases of Customs Trade System Operating, but 
Pattern of Cost and Schedule Problems Needs to be Addressed: 

Appendix II: Comments from the U.S. Department of Homeland Security: 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Staff Acknowledgments: 

ACE: Automated Commercial Environment: 

CBP: Customs and Border Protection: 

CBPMO: Customs and Border Protection Modernization Office: 

DHS: Department of Homeland Security: 

IDIQ: indefinite delivery/indefinite quantity: 

ITDS: International Trade Data System: 

IV&V: independent verification and validation: 

I2V2: integrated independent verification and validation: 

OIG: Office of Inspector General: 

OMB: Office of Management and Budget: 

PTR: program trouble report: 

SA-CMM: Software Acquisition Capability Maturity Model: 

SAT: system acceptance test: 

SEI: Software Engineering Institute: 

SIT: system integration test: 

SWIT: software integration test: 

UAT: user acceptance test: 

US-VISIT: United States Visitor and Immigrant Status Indicator 
Technology: 

Letter May 13, 2004: 

The Honorable Thad Cochran: 
Chairman: 
The Honorable Robert C. Byrd: 
Ranking Minority Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
United States Senate: 

The Honorable Harold Rogers: 
Chairman: 
The Honorable Martin Olav Sabo: 
Ranking Minority Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
House of Representatives: 

In January 2004, U.S. Customs and Border Protection (CBP) within the 
Department of Homeland Security (DHS) submitted to the Congress its 
fiscal year 2004 expenditure plan, seeking release of $318.7 million 
for its Automated Commercial Environment (ACE) program. ACE is to be 
CBP's new trade system. The program's goals include facilitating the 
movement of legitimate trade through more effective trade account 
management and strengthening border security by identifying import and 
export transactions that have an elevated risk of posing a threat to 
the United States. As required by CBP's fiscal year 2004 
appropriations,[Footnote 1] we reviewed the expenditure plan. Our 
objectives were to (1) determine whether the ACE fiscal year 2004 
expenditure plan satisfies certain legislative conditions, (2) 
determine the status of our open ACE recommendations, and (3) provide 
any other observations about the expenditure plan and DHS's management 
of the ACE program.

On March 8, 2004, we briefed your offices on the results of this 
review. This report transmits the results of our work. The full 
briefing, including our scope and methodology, is reprinted as appendix 
I.

Compliance with Legislative Conditions: 

The expenditure plan satisfied or partially satisfied the conditions 
specified in DHS's appropriations act. Specifically, the plan, 
including related program documentation and program officials' 
statements, satisfied or provided for satisfying all key aspects of (1) 
meeting the capital planning and investment control review requirements 
of the Office of Management and Budget (OMB), (2) complying with the 
DHS enterprise architecture,[Footnote 2] and (3) review and approval by 
DHS and OMB. The plan partially satisfied the condition that specifies 
compliance with the acquisition rules, requirements, guidelines, and 
systems acquisition management practices of the federal 
government.[Footnote 3]

Status of Open Recommendations: 

CBP is making progress in addressing our open recommendations. Each 
recommendation, along with the status of CBP's actions to address it, 
is summarized below.

* Before building each ACE release (i.e., beginning detailed design and 
development), certify to Customs' House and Senate appropriations 
subcommittees that the enterprise architecture has been sufficiently 
extended to provide the requisite enterprise design content, and has 
been updated to ensure consistency and integration across business 
areas.

With respect to the fiscal year 2004 expenditure plan, CBP has 
completed action to implement this recommendation by using a process 
developed by the former Customs Service to certify ACE releases against 
the former Customs enterprise architecture. Further, DHS is developing 
a process to ensure alignment of ACE with the departmentwide enterprise 
architecture it is developing to replace DHS component agency and 
bureau architectures.

* Develop and implement a rigorous and analytically verifiable cost-
estimating program that embodied the tenets of effective estimating as 
defined in the Software Engineering Institute's (SEI) institutional and 
project-specific estimating guidance.[Footnote 4]

CBP is in the process of implementing this recommendation. It has 
developed and begun to implement a cost-estimating program that 
embodies SEI's models. For example, CBP hired a contractor to define 
and implement a cost-estimating program and develop independent cost 
estimates. Additionally, it has defined and documented processes for 
estimating expenditure plan costs, and tasked contractors with ensuring 
that expenditure plan estimates are evaluated against SEI criteria for 
validating software cost and schedule estimates.

* Immediately develop and implement a human capital management strategy 
that provides both near-and long-term solutions to program office human 
capital capacity limitations, and report quarterly to the 
appropriations committees on the progress of efforts to do so. These 
efforts should include defining the office's skill and capability needs 
in terms that will allow the program office to attract qualified 
individuals and that will provide sufficient rewards and training, 
linked to performance, to promote their retention.

CBP is in the process of implementing this recommendation, and it has 
reported on these actions to the Congress. In particular, the program 
office developed and began implementing a human capital management plan 
that called for addressing several areas, including filling vacant 
positions. However, the program office has continued to experience 
difficulty in filling key positions and has begun implementing a new 
staffing plan intended to address DHS's concern that the program office 
has insufficient government program management staff.

* Develop and implement process controls for SEI's Software Acquisition 
Capability Maturity Model (SA-CMM[Footnote 5]) level 2 key process 
areas and for the level 3 acquisition risk management key process area; 
develop and implement each of the missing SA-CMM key practices for 
these key process areas, and until this is accomplished, report to the 
appropriations committees quarterly on the progress of efforts to do 
so.

CBP has implemented this recommendation. In November 2003, SEI assigned 
the program a level 2 rating, meaning that the program had established 
basic acquisition management processes. Further, CBP had addressed the 
two weaknesses SEI identified in the level 3 acquisition risk 
management area, and has reported to the Congress on the status of its 
acquisition management improvement activities.

* Establish an independent verification and validation (IV&V) function 
to assist CBP in overseeing contractor efforts, such as 
testing.[Footnote 6]

CBP is in the process of implementing this recommendation. The program 
office has established an IV&V function and has designated its IV&V 
contractor. However, program documentation describes roles for the IV&V 
contractor that are so integral to ACE development, testing, and 
deployment, as well as to ACE program management, that they raise 
questions about how the contractor could also perform independent ACE-
related assessments. CBP officials stated that they plan to address 
this situation.

* Have future ACE expenditure plans specifically address any proposals 
or plans, whether tentative or approved, for extending and using ACE 
infrastructure to support other homeland security applications, 
including any impact on ACE of such proposals and plans.

CBP plans to implement this recommendation. Program officials 
acknowledged the potential for ACE infrastructure to support other DHS 
system applications and the potential for integrating ACE data and 
applications with those systems. According to program officials, to 
begin preparing for this potential, they have focused initially on 
discussing collaboration opportunities with DHS's United States Visitor 
and Immigrant Status Indicator Technology (US-VISIT) program.[Footnote 
7]

Observations on Management of ACE: 

We recognize accomplishments to date, including the deployment of the 
first 2 of 10 planned ACE releases, and address the need for rigorous 
and disciplined program management practices relating to managing ACE's 
costs, schedule, and requirements, as well as the degree of concurrent 
system development activities. An overview of the observations follows: 

* Release 1 and 2 testing revealed a sufficient volume and significance 
of system defects to affect schedule commitments. Release 1 testing 
revealed system defects, which were corrected about 3 months after the 
testing was concluded. Release 2 testing revealed more system defects 
than expected; addressing these defects required more time than 
originally planned for Release 2 testing.

* Requirements planned for Releases 1 and 2 have been deferred to later 
releases. Releases 1 and 2 were originally planned as a single release 
that would satisfy 465 requirements. Subsequently, 103 of these 
requirements, which included capabilities related to document 
management, data recovery, and security, were deferred to Releases 3 
and 4, and 14 were deferred to later releases, for a total of 117 
deferred requirements.

* Release 2 delays have set in motion a pattern of increased reliance 
on concurrent activities, continued release delays, and cost overruns. 
The time required to resolve defects resulted in overlap of Release 2 
test phases. Delays in completing Release 2 increased its overlap with 
Release 3 and have contributed to Release 3 delays. Likewise, Release 3 
delays will increase overlap with Release 4 and could cause Release 4 
delays.

Finally, the increased concurrency and schedule delays resulted in 
Releases 1 through 4 costing more than planned.[Footnote 8]

* Releases 1 and 2 are largely operating according to adjusted 
requirements, defect density has stabilized, and the system is mostly 
up and running when needed. Defects prevalent in Releases 1 and 2 have 
stabilized, but nontrivial defects remain. Releases 1 and 2, however, 
are mostly available when needed.

* Following problems with Release 1, steps were taken to avoid future 
problems, but the success of these actions is unclear. As a result of 
Release 1 cost overruns and schedule delays, CBP directed its 
contractor to develop and implement a plan to improve program 
performance. The objective of this plan was to demonstrate serious, 
tangible, and measurable actions to resolve program issues. However, 
program officials could not point to metrics that demonstrated improved 
performance, and the cost to develop and implement the corrective 
action plan is unknown.

* Initial releases represent a small fraction of the total ACE 
software. Releases 1, 2, 3, and 4 account for only about 14 percent of 
ACE software and are to be designed, developed, and deployed within 
about 3 years. In contrast, the remaining six ACE releases constitute 
86 percent of ACE software but are to be designed, developed, and 
deployed within about 3-1/2 years. CBP officials stated that they are 
currently studying the extent to which off-the-shelf software can be 
employed in the remaining six releases.

* The reliability of key cost estimates in the expenditure plan is 
unclear. The cost estimates in the expenditure plan varied from 
independent cost estimates, and the derivation of the expenditure plan 
estimates only partially satisfied SEI guidance for assessing the 
effectiveness of processes used to derive cost estimates.

Conclusions: 

The fiscal year 2004 ACE expenditure plan, along with program 
documentation and officials' commitments, largely satisfies the 
legislative conditions imposed by the Congress. Further, many of the 
recommendations that we have made to strengthen ACE management have 
been addressed, and CBP leadership has committed to addressing those 
that remain. However, much must still be done before these 
recommendations are fully implemented. Particularly, progress has been 
slow on overcoming human capital challenges.

To CBP's credit, the first two ACE releases are operating largely as 
intended. Achieving this initial operating capability, however, has not 
occurred without difficulty, such as borrowing resources from future 
releases to overcome problems on near-term releases; similar 
difficulties that could affect cost, schedule, and capability 
commitments are being experienced on ongoing releases. This pattern is 
not likely to change unless the degree of concurrency among activities 
within and between releases is better controlled, and the underlying 
reasons for introducing this concurrency are addressed. While time and 
resources were invested in management improvements over a year ago to 
address root causes, the absence of meaningful measures for determining 
whether these investments will be successful, coupled with limited 
progress on some of our previous recommendations, makes CBP's chances 
of delivering future ACE release capabilities on time and within budget 
uncertain at best.

Recommendations for Executive Action: 

To assist CBP in managing ACE and increasing the chances that future 
releases will deliver promised capabilities on time and within budget, 
we recommend that the Secretary of Homeland Security, through the Under 
Secretary for Border and Transportation Security and the CBP 
Commissioner, direct the CBP Chief Information Officer to take the 
following actions: 

* Ensure the independence of its IV&V agent.

* Ensure that future expenditure plans are based on cost estimates that 
are reconciled with independent cost estimates.

* Reconsider the ACE acquisition schedule and cost estimates in light 
of early release problems, including these early releases' cascading 
effects on future releases and their relatively small size compared 
with later releases and in light of the need to avoid the past levels 
of concurrency among activities within and between releases.

* Define measures, and collect and use associated metrics, for 
determining whether prior and future program management improvements 
are successful.

* Report quarterly to the House and Senate Committees on Appropriations 
on efforts to address the above, as well as on our previous but 
unaddressed recommendations.

Agency Comments and Our Evaluation: 

In written comments on a draft of this report signed by the director, 
DHS Bankcard Programs and GAO/OIG Liaison, DHS concurred with our 
recommendations and stated actions that it is taking or plans to take 
to implement each. DHS also provided recommendations for disclosing 
certain sensitive information included in our draft report. We modified 
this report in accordance with DHS's recommendations. DHS's comments 
are reprinted in appendix II.

: 

We are sending copies of this report to the Chairmen and Ranking 
Minority Members of other Senate and House committees and subcommittees 
that have authorization and oversight responsibilities for homeland 
security. We are also sending copies to the Secretary of Homeland 
Security, the Under Secretary for Border and Transportation Security, 
the CBP Commissioner, and the Director of OMB. In addition, the report 
will be available at no charge on the GAO Web site at [Hyperlink, 
http: //www.gao.gov].

Should you or your offices have any questions on matters discussed in 
this report, please contact me at (202) 512-3439 or by e-mail at 
[Hyperlink, hiter@gao.gov]. Other contacts and key 
contributors to this report are listed in appendix III.

Signed by: 

Randolph C. Hite: 
Director, Information Technology Architecture and Systems Issues: 

[End of section]

Appendixes: 

Appendix I: IT: Early Releases of Customs Trade System Operating, but 
Pattern of Cost and Schedule Problems Needs to Be Addressed: 

[See PDF for image]

[End of figure]

[End of section]

Appendix II: Comments from the U.S. Department of Homeland Security: 

U.S. Department of Homeland Security 
Washington, DC 20528:

Homeland Security:

DATE: April 30, 2004:

MEMORANDUM FOR RANDOLPH C. HITE:

U.S. GENERAL ACCOUNTING OFFICE:

FROM: Anna F. Dixon:

Director, Bankcard Programs and GAO/OIG Liaison:

SUBJECT: General Accounting Office (GAO) Draft Report: Information 
Technology: Early Releases of Customs Trade System Operating, but 
Pattern of Cost and Schedule Problems Needs to be Addressed (GAO-04-
587):

Thank you for providing us with a copy of your draft report and the 
opportunity to discuss the issues in this report.

U.S. Customs and Border Protection (CBP) either has underway or has 
completed actions responsive to the recommendations in the report. 
Responses to the specific recommendations are included as Attachment 1.

Additionally, it is CBP's recommendation that specific budget line item 
amounts contained in the Fiscal Year 2004 Modernization Expenditure 
Plan be excluded from the final version of the GAO report. Continuing 
to report the total expenditure plan funding amount (318M) is 
acceptable and does not impact upcoming contract negotiations. Specific 
edits to the draft GAO report to resolve this issue are included as 
Attachment 2.

If you have any questions regarding these comments, please contact Ms. 
Michele Donahue at (202) 927-0957.

Signed for: 

Anna F. Dixon:

Director, Bankcard Programs and GAO/OIG Liaison:

Attachments as stated:

Attachment 1:

U.S. Customs Service General Accounting Office (GAO) Review of Fifth 
Automated Commercial Environment (ACE) Expenditure Plan:

To assist CBP in managing ACE and increasing the chances that future 
releases will deliver promised capabilities on time and within budget, 
we recommend that the DHS Secretary, through the Under Secretary for 
Border and Transportation Security and the CBP Commissioner, direct the 
CBP CIO to:

Recommendation 1: Ensure the independence of its IV&V agent:

Response:

CBP will address GAO's concern about the independence of its IV&V agent 
by clarifying that management and financial oversight of the agent is 
separate from the Customs and Border Protection Modernization Office 
(CBPMO) and rests with the Special Assistant for Audit and Quality 
Management.

Milestone Date: May 31, 2004:

Recommendation 2: Ensure that future expenditure plans are based on cost 
estimates that are reconciled with independent cost estimates.

Response:

The CBPMO's Expenditure Plan Development and Approval Process has been 
updated to reflect a more significant role for CBPMO's independent cost 
estimating (ICE) contractor. The ICE contractor will be actively 
involved in the development process and will be the primary source of 
cost, schedule and risk input.

Milestone Date: July 1, 2004:

Recommendation 3: Reconsider the ACE acquisition schedule and cost 
estimates in light of early release problems, including these early 
releases' cascading effects on future releases and their relatively 
small size compared to later releases, and in light of the need to 
avoid the past levels of concurrency among activities within and 
between releases.

Response:

CBP will respond to this recommendation through the current effort to 
develop the next ACE program plan.

Milestone Date: July 31, 2004:

Recommendation 4: Define measures, and collect and use associated 
metrics, for determining whether prior and future program management 
improvements are successful.

Response:

CBP has taken recent steps responsive to this recommendation. CBPMO has 
developed a metrics plan that is currently undergoing final review. 
This plan draws upon measures that have been used as well as 
incorporating new metrics into a balanced scorecard to enable analysis 
within CBP and with eCP regarding program performance trends.

Milestone Date: May 15, 2004 for final plan approval:

Recommendation 5: Report quarterly to the House and Senate 
Appropriations Committees on efforts to address the above, as well as 
our previously made but still open recommendations.

Response:

CBP will respond to this recommendation by continuing its practice of 
incorporating status reports on its progress addressing GAO open 
recommendations in its quarterly reports to the Appropriations and 
Authorization Committees.

Milestone Date: Considered closed based upon prior congressional 
reports.

ATTACHMENT 2:

Pages 29 and 84 of the draft GAO report contain specific budget 
information that, if published, could weaken the government's 
negotiating position in a number of upcoming contract actions that 
total approximately $60 million. The CBP recommends removing the 
detailed budget line data as illustrated in the modified versions of 
pages 29 and 84 below and adding the appropriate disclaimer in the 
footnote of each page.

Summary of Expenditure Plan Funding:

[See PDF for image]

[End of figure]

[End of section]

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark Bird, (202) 512-6260: 

Staff Acknowledgments: 

In addition to the person named above, Barbara Collier, Bill Cook, Neil 
Doherty, Scott Farrow, Michael P. Fruitman, Tamra Goldstein, Neela 
Lakhmani, and Freda Paintsil made key contributions to this report.


(310282): 

FOOTNOTES

[1] P.L. 108-90 (October 1, 2003).

[2] An enterprise architecture is an institutional blueprint for 
guiding and constraining investments in business process change and 
systems.

[3] In June 2003, the Department of the Treasury's Office of Inspector 
General (OIG) issued a report on the ACE program's contract, concluding 
that the former Customs Service, now CBP, did not fully comply with 
Federal Acquisition Regulation requirements in the solicitation and 
award of the contract. CBP disagrees with the Treasury OIG conclusion. 
To resolve the disagreement, DHS asked us to render a formal decision. 
We are currently reviewing the matter.

[4] SEI's institutional and project-specific estimating guidelines are 
defined in Robert E. Park, Checklists and Criteria for Evaluating the 
Cost and Schedule Estimating Capabilities of Software Organizations, 
CMU/SEI-95-SR-005 (Pittsburgh, Pa.: Carnegie Mellon University 
Software Engineering Institute, 1995) and A Manager's Checklist for 
Validating Software Cost and Schedule Estimates, CMU/SEI-95-SR-004 
(Pittsburg, Pa: 1995), respectively.

[5] Capability Maturity Model (CMM) is a service mark of Carnegie 
Mellon University, and CMM is registered in the U.S. Patent and 
Trademark Office. The SA-CMM identifies key process areas that are 
necessary to effectively manage software-intensive system 
acquisitions. Level 2 is the second level of the SA-CMM's five-level 
scale; achieving this level means that an organization has the software 
acquisition rigor and discipline to repeat project successes. 

[6] IV&V involves having an independent organization conduct unbiased 
reviews of management processes, products, and results with the goal of 
verifying and validating that these meet stated requirements and 
standards.

[7] US-VISIT is a governmentwide program to collect, maintain, and 
share information on foreign nationals in order to enhance national 
security and facilitate legitimate trade and travel while adhering to 
U.S. privacy laws and policies.

[8] Our March 8, 2004, briefing to the staffs of the Subcommittees on 
Homeland Security, Senate and House Committees on Appropriations, 
reported a $23.3 million overrun for Releases 1 and 2 in addition to a 
$36.2 million overrun for Releases 3 and 4. Subsequently, CBP's ACE 
development contractor revised the estimated overrun for Releases 3 and 
4 to $46 million.

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