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Technology Requirements for Its New Pay System' which was released on 
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Report to the United States General Accounting Office:

GAO:

Military Personnel:

GAO-04-149R:

United States General Accounting Office:

Washington, DC 20548:

October 20, 2003:

The Honorable Donald H. Rumsfeld The Secretary of Defense:

Subject: Military Personnel: DFAS Has Not Met All Information 
Technology Requirements for Its New Pay System:

In early January 2003, we initiated a review of the Defense Integrated 
Military Human Resource System (DIMHRS) to get an understanding of the 
program, its goals, its present status, and the problems it is designed 
to resolve. During this review, we became aware that in April 2003 the 
Department of Defense (DOD) authorized the Defense Finance and 
Accounting Service (DFAS) to initiate a pilot project to demonstrate 
its ability to develop an interim military pay system, called Forward 
Compatible Military Pay, before DIMHRS is fully operational. DFAS 
maintains that an interim system should be developed as soon as 
possible for two reasons: (1) the planned personnel and pay system that 
DOD is currently developing as part of the larger DIMHRS[Footnote 1] 
will be implemented later than its projected target date of 
December 2006 and (2) the current military pay system--the Defense 
Joint Military Pay System--is aging, unresponsive, and fragile and has 
become a major impediment to efficient and high quality customer 
service. It is estimated that the Forward Compatible Military Pay 
system could be operational by March 2006 at a design and development 
cost ranging from about $17 million to $30 million.[Footnote 2]

Since the planned interim Forward Compatible Military Pay system is 
considered an information technology acquisition program under DOD 
Acquisition Regulations, DFAS must comply with specific legal and 
administrative requirements before moving forward with the development 
of this project. In this regard, DFAS must comply with requirements 
contained in:

* the Bob Stump National Defense Authorization Act for Fiscal Year 
2003;[Footnote 3]

* Office of the Under Secretary of Defense (Comptroller) 
Memorandum;[Footnote 4] and:

* the Clinger-Cohen Act of 1996.[Footnote 5]

We reviewed DFAS's development of the Forward Compatible Military Pay 
system pilot project to determine whether DFAS had complied with the 
above requirements. We did not evaluate the cost and benefit, return on 
investment, or break-even point analyses that were prepared by DFAS. 
We conducted our review from June 6, 2003, to September 15, 2003, in 
accordance with generally accepted government auditing standards.

Results in Brief:

In moving forward with the development of the Forward Compatible 
Military Pay system, DFAS has not complied with specific legal and 
administrative requirements applicable to DOD's information technology 
investments. It did complete cost and benefit, return on investment, 
and break-even point analyses as required by the Comptroller's 
memorandum. However, DFAS has not submitted the forward pay proposal to 
the responsible domain to determine its compliance with DOD's Business 
Enterprise Architecture,[Footnote 6] which guides DOD's investments in 
financial systems. Because DFAS has not submitted the proposal to the 
responsible domain, the DOD Comptroller has not met its responsibility 
under the authorization act to ensure compliance with the Business 
Enterprise Architecture. Further, DFAS has not completed the necessary 
documents to support compliance with the Clinger-Cohen Act. For 
example, DFAS has not completed the Acquisition Strategy or the 
Acquisition Program Baseline document, as required by DOD Acquisition 
Regulations. By failing to complete all required studies and analyses, 
DOD lacks assurance that it is meeting its goal of making quality 
information technology investments, as required. We are recommending 
that DFAS complete all required steps before proceeding with the 
Forward Compatible Military Pay project.

Background:

By the end of fiscal year 2003, DOD estimates that it will have spent 
about $360 million to conceptualize and plan a major new departmentwide 
integrated military pay and personnel system, known as DIMHRS. In 2002, 
DOD estimated that DIMHRS would be fully deployed by fiscal year 2007 
at a development cost of about $427 million. However, our review of the 
fiscal year 2004 information-technology budget request shows the 
amounts required for fiscal years 2004 and 2005 are $122 million for 
2004 and $95 million for 2005. (When added to the amount spent through 
fiscal 2003, the amounts round to a total of $577 million.) DOD further 
estimates that it would cost about $1.5 billion to operate and maintain 
DIMHRS through fiscal year 2017. However, DOD expects that the winning 
contractor will revise the deployment schedule and cost estimates by 
early 2004. Although the development of DIMHRS has not yet begun, the 
original schedule has already slipped by about 15 months. Among its 
various components, DIMHRS will include a military pay component. As a 
result of the schedule slippage, DFAS has decided that an interim 
military pay system is needed to meet its short-term needs until the 
DIMHRS' military pay component is available, which is projected for 
calendar year 2006 or 2007.

The development of the interim military pay system--the Forward 
Compatible Military Pay system--is considered an information technology 
acquisition program, according to DOD acquisition policy. Congress 
enacted laws to govern DOD's information technology investments, 
e.g., Section 1004 of Bob Stump National Defense Authorization Act for 
Fiscal Year 2003 and the Clinger-Cohen Act of 1996. In addition to 
these laws, DOD's acquisition policy also mandates sound information 
technology investment decisions.

DFAS Has Not Completed All Required Documentation nor Obtained 
Necessary Approval for Forward Compatible Military Pay System:

In moving forward with the development of the interim military pay 
system, DFAS has not complied with the Bob Stump National Defense 
Authorization Act for Fiscal Year 2003, the Comptroller Memorandum, and 
the Clinger-Cohen Act requirements. GAO reported in March 2003[Footnote 
7] that DFAS failed to complete the required documentation for four 
other systems undergoing modernization. In that report we recommended 
that all remaining DFAS information technology projects be evaluated to 
ensure they are being implemented at acceptable cost and within 
reasonable time frames.

National Defense Authorization Act for Fiscal Year 2003 and the 
Comptroller Memorandum:

The Bob Stump National Defense Authorization Act for Fiscal Year 
2003 requires that any investment in excess of $1 million to improve a 
defense financial system be consistent with DOD's Business Enterprise 
Architecture,[Footnote 8] which lays out a frame of reference governing 
information technology management. The DOD Comptroller's March 2003 
memorandum details how compliance with the authorization act will be 
determined. Specifically, the memorandum requires several analyses to 
demonstrate the costs and benefits; return on investment; break-even 
point; and overall compliance with the enterprise architecture for any 
initiative in excess of $1 million. The Comptroller's administrative 
requirements do not preclude or eliminate any other required approvals 
or processes within DOD.

DFAS has not fully complied with the Comptroller's March 7, 2003, 
memorandum. While DFAS briefed a cost and benefit, return on 
investment, and break-even point analysis to the DOD Comptroller's 
Office, the briefing did not include a determination that the Forward 
Compatible Military Pay initiative is in compliance with the enterprise 
architecture. Such a determination has not been made because, to date, 
DFAS has not submitted the proposal to the domain[Footnote 9] owner for 
its evaluation of compliance with the architecture. By determining 
compliance with the architecture DOD can be sure that the Forward 
Compatible Military Pay initiative will not result in a system that 
performs the same tasks or stores the same data as existing systems, 
cannot communicate with other DOD systems, and is costly to operate 
and maintain.

In addition, the Secretary of Defense's Office of Program Analysis and 
Evaluation raised concerns over the accuracy of the information in the 
presentation. Specific areas of concern included cost, schedule, and 
the underlying assumptions made in support of the initiative.

Clinger-Cohen Act and DOD Acquisition Regulations:

The Clinger-Cohen Act of 1996 requires agencies to establish a process 
to maximize value and assess and manage the risks of information 
technology investments, including specific quantitative and 
qualitative criteria for comparing and prioritizing alternative 
information technology projects. The primary objective of DOD's 
acquisition-implementing policy is to acquire quality products that 
satisfy user needs and contain measurable improvements to mission 
capability and operational support, in a timely manner and at a fair 
and reasonable price.

DFAS has not met all of the requirements of the Clinger-Cohen Act 
applicable to its forward compatible pay initiative. The act requires a 
variety of actions, and DOD, in its acquisition regulations, requires 
evidence that the actions have been completed. For example, the act 
requires clearly established measures and accountability for program 
progress. Documents such as the Acquisition Strategy and Acquisition 
Program Baseline documents would contain this information.

Conclusion:

DFAS has not complied with each of the Bob Stump National Defense 
Act, Clinger-Cohen, and administrative requirements for information 
technology investments. As a result, DOD lacks assurance that it is 
meeting its goal of making quality information technology investments. 
Further, the Forward Compatible Military Pay system proposal has 
not been reviewed for compliance with DOD's Business Enterprise 
Architecture. As a result, the system may duplicate the functions of 
existing systems, may not be able to communicate with other DOD 
systems, and may add to overall operating and maintenance costs.

Recommendations for Executive Action:

To ensure that the proposed investment in the Forward Compatible 
Military Pay system is a prudent business decision for DOD, you 
should direct:

* DFAS to submit its Forward Compatible Military Pay system proposal 
to the domain owner for determination that it is in compliance with 
DOD's Business Enterprise Architecture;

* the DOD Comptroller to meet its responsibility under the Bob 
Stump National Defense Authorization Act for Fiscal Year 2003, 
Public Law 107-314, to determine compliance with the Business 
Enterprise Architecture; and:

* the DOD Comptroller to require DFAS to demonstrate that it has 
complied with its responsibilities under the Clinger-Cohen Act of 1996, 
Public Law 104-106.

The DOD Comptroller and DFAS should complete these steps before the 
final decision is made to invest in the Forward Compatible Military Pay 
system.

As you know, 31 U.S.C. 720 requires the head of a federal agency to 
submit a written statement of the actions taken on our recommendations 
to the Senate Committee on Governmental Affairs and the House Committee 
on Government Reform not later than 60 days after the date of this 
report. A written statement must also be sent to the House and Senate 
Committees on Appropriations within 60 days after the date of this 
report.

Agency Comments:

DOD provided official comments on a draft of this letter. The Principal 
Deputy and Deputy Under Secretary of Defense (Management Reform) 
concurred with the letter and recommendations. DOD stated that if the 
decision is made to pursue the Forward Compatible Military Pay system, 
DFAS will finalize the appropriate documentation to satisfy 
requirements of the Clinger-Cohen Act of 1996, the DOD Business 
Enterprise Architecture, the DOD acquisition lifecycle management 
process, and provisions of current governing legislation. The Forward 
Compatible Military Pay system then will be reviewed through the 
Business Management Modernization Program process. DOD's comments 
appear in their entirety in enclosure I.

We are sending copies of this report to the appropriate congressional 
committees. We will place a copy of this letter on GAO's Web site at 
http://www.gao.gov. If you have any questions concerning the 
information provided, please call me on (202) 512-5559 or Donald C. 
Snyder on (202) 512-7204.

Sincerely yours,

Derek B. Stewart 
Director, Defense Capabilities and Management:

Signed by Derek B. Stewart

Enclosure:

[End of section]

Enclosure I: Comments from the Department of Defense:

UNDER SECRETARY OF DEFENSE:

1100 DEFENSE PENTAGON WASHINGTON, DC 20301-1100:

OCT 1-2003:

COMPTROLLER:

Mr. Derek B. Stewart:

Director, Defense Capabilities and Management U.S. General Accounting 
Office:

Washington, D.C. 20548:

Dear Mr. Stewart:

This is the Department of Defense (DoD) response to the GAO draft 
report, GAO-03-1163R, "MILITARY PERSONNEL: DFAS Has Not Met All 
Information Technology Requirements for Its New Pay System," dated 
September 24, 2003, (GAO Code 350295).

The Forward Compatible Payroll (FCP) is a replacement of the aging 
Defense Joint Military Pay System (DJMS), which currently services all 
active, reserve, and guard members of the Departments of Army, Navy, 
and Air Force. The FCP will replace DJMS with a modern, technologically 
efficient integrated active/reserve/guard payroll capability, until 
the fully integrated (military personnel and pay) DIMHRS is developed 
and deployed. The FCP will utilize the same Commercial Off-The-Shelf 
foundation software (PeopleSoft) as DIMHRS and, indeed, will use the 
DoD enterprise software license for PeopleSoft that the DIMHRS Program 
has acquired.

Consistent with the GAO request, enclosed is our written response to 
the draft report. In general, we concur with the report and 
recommendations. The report indicates DFAS has not complied with 
specific information technology reporting requirements. If the decision 
is made to pursue FCP, DFAS will finalize the appropriate documentation 
to satisfy requirements of the Clinger-Cohen Act of 1996, the DoD 
Business Enterprise Architecture, the DoD acquisition lifecycle 
management process, and provisions of current governing legislation. 
The FCP then will be reviewed through the Business Management 
Modernization Program process.

In summary, DFAS is in the process of completing the documentation and 
review requirements to establish whether the FCP initiative is a viable 
information technology investment. The primary action officer is Mr. 
Edward Grysavage, 703-607-5032:

Sincerely,

Signed by: 

Lawrence J. Lanzillotta:

Principal Deputy and Deputy Under Secretary of Defense (Management 
Reform):

Enclosure: As stated:

GAO CODE 350295/GAO-03-1163R:

"MILITARY PERSONNEL: DFAS HAS NOT MET ALL INFORMATION TECHNOLOGY 
REQUIREMENTS FOR ITS NEW PAY SYSTEM":

DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATIONS:

RECOMMENDATION 1: The GAO recommended that the Secretary of Defense 
direct the DFAS to submit its Forward Compatible Military Pay system 
proposal to the domain owner for determination that it is in compliance 
with DoD's Business Enterprise Architecture. (Page 6/Draft Report):

DoD RESPONSE: Concur. As discussed with GAO staff on several occasions, 
DFAS is in the process of submitting the FCP system initiative through 
the BMMP domain review process. Currently, Life-Cycle Management 
documents are in the review and coordination phase.

RECOMMENDATION 2: The GAO recommended that the Secretary of Defense 
direct the DoD Comptroller to meet its responsibility under the Bob 
Stump National Defense Authorization Act for Fiscal Year 2003, Public 
Law 107-314, to determine compliance with the Business Enterprise 
Architecture. (Page 6/Draft Report):

DoD RESPONSE: Concur. As discussed with GAO staff, DFAS will report to 
the appropriate entities to show compliance with the Business 
Enterprise Architecture.

RECOMMENDATION 3: The GAO recommended that the Secretary of Defense 
direct the DoD Comptroller to require DFAS to demonstrate that it has 
complied with its responsibilities under the "Clinger-Cohen Act of 
1996," Public Law 104-106. (Page 6/Draft Report):

DoD RESPONSE: Concur. As discussed with GAO staff, DFAS has drafted and 
is finalizing program documentation that demonstrates compliance with 
the "Clinger-Cohen Act of 1996.":

RECOMMENDATION 4: The GAO recommended that the DoD Comptroller and DFAS 
should complete recommendations 1, 2, and 3 before the final decision 
is made to invest in Forward Compatible Pay. (Page 6/Draft Report):

DoD RESPONSE: Concur. As discussed with GAO staff, DFAS will submit the 
FCP initiative through the BMMP domain process. Acquisition program 
life-cycle documentation will also be developed.

Note: Report number was changed to GAO-04-149R.

Note: Page numbers in the draft report may differ from those in this 
report.

FOOTNOTES

[1] DOD is currently developing the DIMHRS that is designed to provide 
DOD and the services one integrated, standardized personnel and pay 
system that will track service members and their dependents.

[2] DFAS program officials estimate the cost at $16.8 million, but a 
Program Analysis and Evaluation estimate came in at $29.9 million 
because it included costs that had been left out of the program 
officials' estimate.

[3] Public Law 107-314 (Dec.2, 2002), section 1004, Development and 
Implementation of Financial Management Enterprise Architecture, which 
requires that the investment in excess of $1 million to improve a 
defense financial system be consistent with DOD's enterprise 
architecture, among other things.

[4] The memorandum (dated Mar. 7, 2003) provides additional information 
on how DOD will determine compliance with section 1004 of the Bob Stump 
National Defense Authorization Act.

[5] The Federal Acquisition Reform Act of 1996 (FARA) and the 
Information Technology Management Reform Act of 1996 (ITMRA) were 
renamed the Clinger-Cohen Act of 1996 by the 1997 Omnibus Consolidated 
Appropriations Act P.L. 104-208 (Sept. 30, 1996). Both the FARA and the 
ITMRA were passed as sections D and E in the National Defense 
Authorization Act for Fiscal Year 1996, P.L. 104-106 (Feb. 10, 1996), 
which requires federal agencies to maximize the value and assess and 
manage the risks associated with investments in information technology.

[6] In May 2003, the DOD Comptroller changed the architecture name from 
the Financial Management Enterprise Architecture to the Business 
Enterprise Architecture to reflect the transformation of departmentwide 
business operations and supporting systems. The Business Enterprise 
Architecture is a "blueprint" to guide and constrain DOD's investments 
in financial management operations and systems.

[7] U.S. General Accounting Office, DOD Business Systems Modernization: 
Continued Investment in Key Accounting Systems Needs to be Justified, 
GAO-03-465 (Washington, D.C.: Mar. 28, 2003).

[8] GAO reported in September 2003 that DOD's initial version of the 
Business Enterprise Architecture does not adequately address all the 
requirements in the National Defense Authorization Act for Fiscal Year 
2003. Further, DOD has not yet defined and implemented an effective 
approach to select and control business systems investments for 
obligations exceeding $1 million while the architecture is being 
developed and after it is completed. See U.S. General Accounting 
Office, DOD Business Systems Modernization: Important Progress Made to 
Develop Business Enterprise Architecture, but Much Work Remains, GAO-
03-1018 (Washington, D.C.: Sept. 19, 2003).

[9] As outlined in DOD's Business Management Modernization Program 
governance guidance, domains are based on existing functional business 
lines. The 7 domains are: (1) Acquisition; (2) Finance, Accounting 
Operations and Financial Management; (3) Human Resource Management; (4) 
Installations and Environment; (5) Logistics; (6) Strategic Planning 
and Budgeting; and (7) Technical Infrastructure. Domain owners have the 
authority, responsibility, and accountability for business 
transformation, implementation of the Business Enterprise 
Architecture, and portfolio management within their domains. Owners' 
responsibilities include: leading business transformation; 
establishing and maintaining a domain governance process; performing 
system reviews and approving initiative funding; assisting in the 
extension of the architecture; enforcing compliance with the 
architecture; guiding implementation activities; and representing the 
domain on cross-domain issues.