Recommendation: The Administrator of CMS should develop formal procedures that include specific steps to be taken in the APD review process, including how CMS will document the review (including the name of the reviewer, date of review, and what was reviewed); what documentation should be retained after the review; as well as decision-making criteria for approval or denial decisions for state Medicaid IT funding requests. (Recommendation 1)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should, as part of the APD review process and prior to approval, verify that all of the required information (e.g. alternatives analysis, feasibility study, and cost benefit analysis) is included in the funding request. (Recommendation 2)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should ensure that all APD-related artifacts are retained within the designated CMS document management system, including documentation of key information from meetings and email communications with the states, the MITA self-assessment and independent verification and validation reports, when creating APD decision packages. (Recommendation 3)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should require analysts to maintain relevant MMIS and E&E system artifacts based on the entire system life cycle instead of individual APDs. (Recommendation 4)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should, in consultation with the HHS and CMS CIOs, develop a documented, comprehensive, and risk-based process for how CMS will select IT projects for technical assistance and provide recommendations to states to assist them in improving the performance of the systems, with consideration to those that are high-cost and performing poorly. (Recommendation 5)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should encourage state Medicaid program officials to consider involving state CIOs in overseeing Medicaid IT projects. (Recommendation 6)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should establish a timeline for implementing the outcome-based certification process for MMIS and E&E systems. (Recommendation 7)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should establish documented procedures for how the results of the outcome-based certification process will be used for conducting oversight and making funding decisions. The procedures should include specific steps that CMCS will take to oversee individual state MMIS and E&E projects and how it will demonstrate that the steps have been taken. (Recommendation 8)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: Prior to approving funding for MMIS and E&E systems, the Administrator of CMS should identify areas of duplication or common functionality, such as core MMIS modules, in order to facilitate sharing, leveraging, or reusing Medicaid technologies. CMS should share the results of the review with the state or territory requesting federal funding for a duplicative or similar project and take steps to encourage states to share, leverage, or reuse Medicaid technologies, where possible. (Recommendation 9)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for IMF fully addresses greater utilization of technology or consolidation of investments to better meet organizational goals. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In August 2019, IRS provided its fiscal year 2018 Operational Analysis Results report, dated June 24, 2019. The report demonstrated that IRS, in response to our recommendation, had ensured that the operational analysis for IMF fully addressed greater utilization of technology or consolidation of investments to better meet organizational goals. However, the operational analysis did not reflect IRS's progress to date in modernizing IMF and the associated challenges. As we reported, this omission is concerning given the risk exposure from the agency's continued use of the legacy assembly language code. In order to close the recommendation, IRS needs to update the operational analysis to reflect its progress modernizing IMF.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for Telecommunications Systems and Support (TSS) addresses the extent to which the investments support customer processes as designed, and how well the investments are delivering the goods or services they were designed to deliver. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In August 2019, IRS provided its fiscal year (FY) 2018 Operational Analysis Results report, dated June 24, 2019. While the report included a summary of the FY 2018 operational analysis for TSS, it did not identify the metrics used to determine whether TSS supported customer processes or delivered the goods and services that it is intended to deliver. To close this recommendation, IRS will need to provide the detailed operational analysis for TSS incorporating these metrics. As of December 2019, IRS has not provided the full TSS operational analysis to GAO. Upon receiving the document, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for TSS includes a comparison of current performance with a pre-established cost baseline. (Recommendation 4)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In August 2019, IRS provided GAO its fiscal year (FY) 2018 Operational Analysis Results report. While the report included a summary of the FY 2018 operational analysis for the Telecommunications Systems and Support (TSS) investment , including planned and actual cost figures for FY2018, the report did not indicate whether the planned cost figure for FY2018 accounted for reimbursable costs and user fees, as we reported. To address this recommendation, IRS will need to provide a full operational analysis for TSS, as well as documentation showing whether reimbursable costs and user fees are included in the planned cost figure. As of December 2019, IRS has not provided a full TSS operational analysis to GAO. Upon receiving the document, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for End User Systems and Services includes a comparison of current performance with a pre-established cost baseline. (Recommendation 5)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In August 2019, IRS provided its fiscal year (FY) 2018 Operational Analysis Results report, dated June 24, 2019. While the report included a summary of the FY 2018 operational analysis for End User Systems and Services (EUSS) investment, including planned and actual cost figures for FY2018, it did not specify whether the planned cost figure accounted for multi-year funding and user fees, as we reported. To address this recommendation, IRS will need to provide a full operational analysis for EUSS, as well as documentation showing whether multi-year funding and user fees are included in the planned cost figure. As of December 2019, IRS has not provided the full EUSS operational analysis to GAO. Upon receiving it, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the IMF investment. (Recommendation 7)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the IMF investment. (Recommendation 8)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice for prioritizing risk for the IMF investment. (Recommendation 9)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the IMF investment. (Recommendation 10)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the IMF investment. (Recommendation 11)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the IDRS investment. (Recommendation 12)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the IDRS investment. (Recommendation 13)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the IDRS investment. (Recommendation 14)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the IDRS investment. (Recommendation 15)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the MSSS investment. (Recommendation 16)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019. While the plan addressed most of the activities associated with the preparing for risk management key practice, it did not identify risk constraints, risk assumptions, or risk tolerance for the MSSS investment. Upon receiving further information, we will review it to determine if IRS has fully addressed this recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the MSSS investment. (Recommendation 18)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has implemented the activities associated with the Analyze Risk key practice. Specifically, while the plan describes a risk analysis process in which risks are classified as high, medium, or low risk, neither the plan nor any of the other documents describes criteria for evaluating and quantifying risk likelihood and severity (impact) levels. Additionally, the Risk Management Plan does not indicate whether analysis of MSSS risks includes both inherent and residual risks. Upon receiving additional information indicating that IRS has addressed these activities, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the MSSS investment. (Recommendation 19)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has established threshold values for MSSS risk categories or alternative courses of action for critical risks. Upon receiving additional information indicating that it has addressed these activities. we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the MSSS investment. (Recommendation 20)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframes and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has fully implemented all of the activities associated with the monitoring, reporting, and controlling key practice. Specifically, our review of the documents shows that IRS has not established threshold values for MSSS risk categories, and as a result is unable to compare the status of risks to acceptability thresholds to determine the need for implementing a risk mitigation plan. In addition, although the MSSS Risk Management Plan was updated in October 2019, its previous revision occurred in October 2017, indicating that IRS has not yet reviewed all aspects of the risk management program at least once a year. Upon receiving additional information that IRS has addressed these activities, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement IT workforce planning practices, including the following actions (1) setting the strategic direction for workforce planning; (2) analyzing the workforce to identify skill gaps; (3) developing strategies and implementing activities to address skill gaps; and (4) monitoring and reporting on progress in addressing skill gaps. (Recommendation 21)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In September 2018, IRS told GAO it had initiated efforts to address workforce planning agency-wide. The agency stated that the Human Capital Office in coordination with the Information Technology organization prioritizes critical skills gaps to develop gap mitigation strategies, which are implemented through IT annual training plans and succession planning efforts. IRS also stated that the mitigation plans will be monitored in the current Project and Portfolio Management System and that the Human Capital and Information Technology organizations will monitor resource capacity, skills, assigned work effort, and staff availability. In addition, IRS stated that it would utilize special hiring authorities as a competency and staffing mitigation strategy. The agency noted that the special authorities are subject to the availability of resources and agency approval. Further, IRS stated that, due to the diversion of IT resources to the Tax Cuts and Jobs implementation, development of a plan for scaling and expansion of workforce planning efforts will commence after the opening of Filing Season 2020. IRS stated that, due to those constraints, it could not provide a date for fully implementing the recommendation. As of December 2019, IRS has not provided any updates indicating whether it has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.