Pursuant to legislative direction, the Immigration and Naturalization Service (INS), now part of the Department of Homeland Security, plans to acquire and deploy an entry exit system to assist in monitoring the flow of foreign nationals in and out of the United States. By separate legislative direction, INS must submit to the Senate and House Committees on Appropriations a plan for this system that meets certain conditions, including being reviewed by GAO, before funds can be obligated. This report satisfies GAO's mandated review obligation by (1) addressing whether the plan submitted by INS, along with related INS documentation and plans, meets required conditions and (2) providing observations about the plan and INS's management of the system.
INS's initial expenditure plan and associated system acquisition documentation and plans for the entry exit system partially meet the legislative conditions imposed by the Congress. That is, INS has implemented or has defined plans for implementing most of the legislatively mandated requirements for the plan's content, which include such areas as capital planning and investment control, acquisition, and systems acquisition management. However, key issues related to understanding and implementing system requirements, such as developing a system security plan and assessing system impact on the privacy of individuals, remain to be addressed. Moreover, INS reported that it had obligated some entry exit funding before it submitted the plan to the Appropriations Committees. Since then, INS officials told GAO that they have de-obligated and reclassified these obligations to other available funding sources. GAO observed that INS has preliminary plans showing that it intends to acquire and deploy a system that has functional and performance capabilities that satisfy the general scope of capabilities required under various laws. These include the capability to (1) collect and match alien arrival and departure data electronically; (2) be accessible to the border management community (including consular officers, federal inspection agents, and law enforcement and intelligence agencies responsible for identifying and investigating foreign nationals); and (3) support machine-readable, tamper-resistant documents with biometric identifiers at ports of entry. Each of these capabilities is integral to supporting our nation's border security process. However, GAO also observed that the initial plan does not provide sufficient information about INS commitments for the system, such as what specific system capabilities and benefits will be delivered, by when, and at what cost, and how INS intends to manage the acquisition to provide reasonable assurance that it will meet these commitments. Without sufficiently detailed information on system plans and progress, the Congress will be impeded in its efforts to oversee the system.
Recommendations for Executive Action
|Management Directorate||To help ensure the effective management and acquisition of the entry exit system, the Secretary of Homeland Security should, through whatever entry exit program governance structure is established, direct the entry exit program manager to ensure that planned investment and acquisition management controls, including the development of a business case, are fully implemented in accordance with recognized best practices and relevant federal requirements and guidance.|
|Management Directorate||At a minimum, the Secretary of Homeland Security's direction should include having the entry exit program manager immediately develop and begin implementing a system security plan. At the same time, the Secretary should have the program manager perform a privacy impact analysis and use the results of this analysis in near-term and subsequent system acquisition decision-making.|
|Management Directorate||In light of INS's recent transition to the new department and potential changes to system investment and acquisition controls provided for in the first plan, we recommend that controls in the areas of acquisition planning, solicitation, requirements management, project management, contract tracking and oversight, and evaluation should be implemented in accordance with Software Engineering Institute guidance.|
|Management Directorate||The Secretary of Homeland Security should ensure that future expenditure plans be provided to the department's Senate and House Appropriations Subcommittees in advance of entry exit system funds being obligated.|
|Management Directorate||The Secretary of Homeland Security should ensure that future expenditure plans fully disclose what entry exit system capabilities and benefits are to be delivered, by when, and at what cost, and how it intends to manage the acquisition to provide reasonable assurance that these system capability, benefit, schedule, and cost commitments will be met.|