Recommendation: The Director of the Bureau of Land Management (BLM) should create and implement a policy for standard posting requirements regarding comments and their identity information, particularly for duplicate comments, and should clearly communicate this policy to the public on the BLM website. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM concurred with the recommendation. In December 2019, BLM indicated that it will develop and issue policy for standard posting requirements regarding public comments and associated identity information as well as duplicative comments which will be available on BLM's website. BLM officials estimate that this will be completed in March 2020. Until these items are completed, our recommendation to BLM remains open.

Recommendation: The Administrator of Centers for Medicare & Medicaid Services (CMS) should create and implement a policy for standard posting requirements regarding comments and their identity information, particularly for duplicate comments, and should clearly communicate this policy to the public on the CMS website. (Recommendation 2)

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

Comments: In January 2020, the Department of Health and Human Services stated that CMS already has policies for standard posting requirements, and noted that they would update their policy and communicate it on the CMS website. However, while CMS provided us with an excerpt of the updated language, as written, it does not include information about how the agency posts duplicate comments. Further, CMS did not provide us with this policy, and our review of the website does not indicate any changes have been made. HHS stated it would provide additional follow up actions by 7/23/2020. Given that we found significant variation in the way that CMS posts comments, even within a single docket, we continue to believe that it is important for CMS to develop and implement a standard policy for posting duplicate comments and their identity information, in addition to communicating this policy to the public on the CMS website.

Recommendation: The Director of the Consumer Financial Protection Bureau (CFPB) should finalize its draft policy for posting comments and their identity information, particularly for duplicate comments, and clearly communicate it to the public on the CFPB website. (Recommendation 3)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: CFPB concurred with the recommendation. In December 2019, CFPB indicated that it will develop new language for consumerfinance.gov to better explain the Bureau's "post all" policy, and any exceptions to it. Additionally, CFPB is finalizing internal procedures for posting comments. Until these items are completed, our recommendation to CFPB remains open.

Recommendation: The Assistant Secretary of Labor for the Employee Benefits Security Administration (EBSA) should
1. create and implement a policy for standard posting requirements regarding comments and their identity information, particularly for duplicate comments;
2. clearly communicate this policy to the public on the EBSA website; and
3. evaluate the duplicative practice of replicating rulemaking dockets on the EBSA website, to either discontinue the practice or include a reference to Regulations.gov and explanation of how the pages relate to one another. (Recommendation 4)

Agency: Department of Labor: Employee Benefits Security Administration
Status: Open

Comments: EBSA concurred with the recommendation. In September 2019, EBSA stated that it will develop a written policy regarding posting of comments, including that of duplicate comments. This information will be available on their website. Additionally, EBSA will post a reference to Regulations.gov as part of each Notice of Proposed Rulemaking (NPRM) webpage that includes public comments together with an explanation of its relation to Regulations.gov as a means to access public comments on EBSA's rulemaking initiatives. EBSA officials did not provide a date by which these actions will be implemented. Additionally, while EBSA noted that internal and external users prefer the agency's current practice of replicating rulemaking dockets, the agency did not provide evidence that a formal evaluation had been conducted, and did not identify plans to do so. As a result, at this time our recommendation to EBSA remains open.

Recommendation: The Administrator of the Environmental Protection Agency (EPA) should finalize its draft policy for posting comments and their identity information, particularly for duplicate comments, and clearly communicate it to the public on the EPA website. (Recommendation 5)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA concurred with the recommendation. In January 2020, EPA indicated that it will finalize its Docket Center's Document Processing Standard Operating Procedure as well as its website. This update will include information detailing when all duplicate comments are posted to Regulations.gov and when just one representative sample of a duplicate comment is posted. EPA officials estimate that this will be completed in February 2020. Until these items are completed, our recommendation to EPA remains open.

Recommendation: The Director of the Fish and Wildlife Service (FWS) should create and implement a policy for standard posting requirements regarding comments and their identity information, particularly for duplicate comments, and should clearly communicate this policy to the public on the FWS website. (Recommendation 6)

Agency: Department of the Interior: United States Fish and Wildlife Service
Status: Open

Comments: FWS concurred with the recommendation. In December 2019, FWS stated that it will update its service manual to include all standard posting requirements regarding public comments and their identity information. Additionally, FWS will include a statement on the FWS' website to inform the public about posting of public comments and identity information to regulations.gov. FWS officials estimate that this will be completed in June 2020. Until these items are completed, our recommendation to FWS remains open.

Recommendation: The Administrator of the Wage and Hour Division (WHD) should clearly communicate its policy for posting comments and their identity information, particularly for duplicate comments, to the public on the WHD website. (Recommendation 8)

Agency: Department of Labor: Wage and Hour Division
Status: Open

Comments: WHD concurred with the recommendation. In August 2019, WHD indicated that it will add text to each webpage for any rulemaking that invites public comments which states that any personal information included in the comments (including duplicate) will be posted to Regulations.gov without change. However, the text provided by officials does not explain WHD's policy of posting duplicate comments as a group under a single document ID, and therefore does not clearly communicate the agency's posting practices to the public. As a result, at this time our recommendation to WHD remains open.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of Commerce
Status: Open

Comments: We reported that the Department of Commerce did not meet the following software application inventory practice: regularly updates the inventory with quality controls to ensure reliability. Specifically, the department did not provide evidence of a process to regularly update its inventory or quality controls to ensure the reliability of the data collected. In October 2017, the department reported that application inventory information will be captured through the Department of Commerce Capital Planning and Investment Control (CPIC) system, as part of its regular updating of investment information. Further, the department stated that it will update its CPIC handbook to provide guidance on quality control to ensure reliability of the data collected. In November 2018 and November 2019 we followed-up with Commerce on the status of their efforts; however, as of January 2020, we had not received an update. We plan to continue to follow up with Commerce to monitor the status of these planned actions.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of Energy
Status: Open

Comments: We reported that the Department of Energy partially met the following three software application inventory practices, (1) includes systems from all organizational components, (2) specifies basic application attributes, and (3) is regularly updated with quality controls to ensure reliability. In May 2017, the department reported that it plans to implement automated monitoring and inventory tools by the end of fiscal year 2020, which it expects will address the key practices. In December 2019, the department reported that it anticipates completing a refresh of its application inventory by the end of February 2020. We plan to monitor the department's efforts to implement the tools and to develop a complete application inventory.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of Housing and Urban Development
Status: Open

Comments: We reported that the Department of Housing and Urban Development (HUD) partially met the following three software application inventory practices, (1) includes systems from all organizational components, (2) specifies basic application attributes, and (3) is regularly updated with quality controls to ensure reliability. In June 2017, the department reported that it is working to identify applications in field offices, and planned for this effort to be completed in fiscal year 2018. In addition, the department stated it planned to update the inventory to include business functions for each system by the end of fiscal year 2017. Further, department officials stated that to ensure the accuracy and reliability of the application inventory, the department planned to conduct quarterly portfolio reviews starting in fiscal year 2018. In October 2018, HUD officials reported that CTO performed a technical assessment of HUD's IT assets, which resulted in identifying systems in the inventory that had been decommissioned and will be decommissioned. In addition, the department provided its strategy for performing the assessment. In August 2019, HUD reported that it completed an assessment of its legacy applications and the current inventory system is outdated. However, as of January 2020, HUD had not yet provided an updated inventory. We plan to continue to monitor the department's efforts to address the recommendation.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Social Security Administration
Status: Open

Comments: We reported that the Social Security Administration (SSA) partially met the following two software application inventory practices, (1) includes systems from all organizational components, and (2) regularly updates the inventory with quality controls to ensure reliability. In March 2017, SSA officials reported that the agency's Office of Systems and Office of Operations continue to collaborate on integrating application information into the Enterprise Application Inventory. The officials reported that regionally developed applications that have been granted authority to operate have been imported into the enterprise application inventory. In addition, the officials stated that the Office of Operations was in the process of redesigning their repository to accommodate requirements to support the Enterprise Application Inventory, including the ability to update and maintain application information in the enterprise repository. Lastly, SSA officials reported that its Office of Information Security and Office of Systems were continuing to work to identify additional headquarters applications and develop process and automation to include applications in the inventory. In June 2019, SSA officials reported that they were continuing to make progress to update the inventory to include systems from all organizational components. However, as of January 2020, we had not received an updated inventory. We will continue to monitor SSA's efforts to develop a complete application inventory.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of Labor
Status: Open

Comments: We reported that the Department of Labor did not meet one software application inventory practice, and partially met three practices. Specifically, we reported that the department did not meet the practice to ensure that the inventory is regularly updated with quality controls to ensure reliability, and partially met the practices to (1) include business and enterprise IT systems, (2) include systems from all organizational components, and (3) specify basic application attributes. In March 2018, department officials provided an updated inventory, which included business and enterprise IT systems from all organizational components, and specified basic attributes, including the name, owner, and business function. In addition, officials stated that they plan to update the inventory on a periodic basis as necessary, at minimum annually, as part of the department's IT budgeting process. Further, in June 2019, officials reported that the department performs biannual reviews of all IT investments and associated systems and applications to verify reported data. The officials also reported that the department uses quality control processes and procedures to ensure consistent, standard, and complete reporting to align with all investment artifacts. However, the department did not provide evidence of these data quality efforts. In June 2019, officials also reported that the department is implementing a new system in order to maintain an ongoing comprehensive inventory of all IT assets, including applications, which it expects to have fully operational by the end of the second quarter of fiscal year 2020. We will continue to monitor the department's efforts.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of the Treasury
Status: Open

Comments: We reported that the Department of the Treasury had partially met the following two practices for establishing a complete software application inventory, (1) specifies basic application attributes, and (2) is regularly updated with quality controls to ensure reliability. In September 2017, the department provided evidence showing that it had taken steps to address these practices. Specifically, the department provided an export of its inventory, which showed that most of the systems listed contained a system description. According to department officials, some systems do not have a system description because the department's inventory policy allows bureaus to attach documents to the inventory, which include the system description, instead of populating the system description field. Further, the policy does not require a system description for systems in the disposal state. Moreover, the inventory did not include the business segment or function that the system supports. According to Treasury officials, the Bureau and Functional Unit fields within the inventory allow the department to map the systems to the business segments that they support. We followed up with the department to obtain this mapping. However, as of January 2020, the department had not provided it. We will continue to monitor the department's efforts to ensure that the inventory is regularly updated with quality controls to ensure its reliability.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of State
Status: Open

Comments: We reported that the Department of State partially met the following software application inventory practices: (1) specifies basic application attributes; and (2) is regularly updated with quality controls to ensure reliability. Specifically, we reported that while the inventory included basic application attributes (e.g. name, description), it did not include the business function for the majority of inventory entries. Further, we reported that the agency did not provide evidence that quality control processes were in place to ensure the reliability of the data in the inventory. In July 2017, department officials stated that the department recently began a department-wide data call to obtain information on all IT assets and applications from each bureau, including aligning the assets and applications to a business function. Further, officials stated that they plan to analyze the results against their current data to ensure the accuracy and reliability of the IT asset inventory. In June 2019, the department provided evidence demonstrating that its inventory includes the business function for IT assets. In addition, State officials stated that the IT asset inventory that is posted internally for review is a high-level summary to facilitate monthly validation. However, as of January 2020, the department has not provided documentation showing that it has implemented the quality control processes to ensure the reliability of the data. We plan to continue to monitor the department's efforts to address the recommendation.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Environmental Protection Agency
Status: Open

Comments: We reported that the Environmental Protection Agency had fully met three of the four practices to establish a complete application inventory, and partially met one. Specifically, the agency partially met the practice for including application attributes in the inventory, as although EPA did not identify the business function for every application. In December 2019, Environmental Protection Agency officials stated that the inventory now requires the business function to be included, and provided inventory update instructions that show the business function is to be included. In addition, agency officials provided instructions for senior information managers to update the inventory in fiscal year 2019. However, as of January 2020, agency officials had not provided an updated inventory, and thus we were not able to verify that the business function was added for all applications. We will follow up with the agency to obtain the updated inventory.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Office of Personnel Management
Status: Open

Comments: We reported that the Office of Personnel Management (OPM) partially met the software application inventory practice to regularly update the inventory with quality controls to ensure reliability. In November 2016, OPM officials stated that they were validating the data in the application inventory. In addition, officials stated that they were making progress in using automated scanning tools to update the inventory, including coordinating with the General Services Administration's Software Management Group which is working to standardize the use of automated inventory tools across the government. In June 2017, November 2018, and November 2019, we followed up with OPM to obtain documentation of these reported actions; however, as of January 2020, the agency had not yet provided supporting documentation. We are continuing to follow up with OPM to obtain documentation of its reported actions.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the Secretaries of Defense, Homeland Security, the Interior, and Labor; and the Director of the National Science Foundation should direct the CIOs and other responsible officials to modify existing investment management processes to address applications more completely. Specifically, the Secretary of Defense should direct the responsible official to modify the department's existing processes to collect and review cost, technical, and business information for the enterprise and business IT systems within the Enterprise Information Environment Mission Area applications which are currently not reviewed as part of the department's process for business systems.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense did not concur with our recommendation, noting, among other things, in its written response to our draft report, that a majority of the Enterprise Information Environment Mission Area systems are IT infrastructure, and not applications. However, we reported that the mission area nevertheless included a large number of enterprise and business IT applications which could benefit from rationalization, and we therefore believed our recommendation was still warranted. In March 2020, the department stated that it is formalizing a guide to assist components with implementing an application rationalization process, that will be used to rationalize the Enterprise Information Environment Mission Area systems. The department stated that it plans to perform annual reviews, and expects to start by the end of fiscal year 2020.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the Secretaries of Defense, Homeland Security, the Interior, and Labor; and the Director of the National Science Foundation should direct the CIOs and other responsible officials to modify existing investment management processes to address applications more completely. Specifically, the Secretary of Homeland Security should direct the department's CIO to identify one high-cost function it could collect detailed cost, technical, and business information for and modify existing processes to collect and review this information.

Agency: Department of Homeland Security
Status: Open

Comments: In April 2018, DHS officials stated that they identified FOIA systems as a high cost function, and will modify existing processes to collect and review the cost, technical, and business information. In November 2019, DHS reported that it is continuing to make progress in acquiring a new enterprise-wide FOIA system by reviewing current capabilities. We plan to continue to monitor the department's efforts.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the Secretaries of Defense, Homeland Security, the Interior, and Labor; and the Director of the National Science Foundation should direct the CIOs and other responsible officials to modify existing investment management processes to address applications more completely. Specifically, the Secretary of Labor should direct the department's CIO to consider a segmented approach to further rationalize and identify a function for which it would modify existing processes to collect and review application-specific cost, technical, and business value information.

Agency: Department of Labor
Status: Open

Comments: In February 2017, department officials stated that the department's portfolio of IT investments, which includes the systems, sub-systems, and applications in the IT asset inventory, are rationalized bi-annually as part of the Office of the Chief Information Officer's IT Capital Planning and Investment Control (CPIC) review processes. Further, officials stated that the systems and applications were also being rationalized as part of the process for updating the IT asset inventory. Officials stated that the department plans to review and update the department's CPIC guide to describe the IT asset inventory management process including the basic quality controls. In July 2019, officials reported that the department plans to have the updated guide completed by the end of fiscal year 2019. However, as of January 2020, the department had not provided documentation supporting these efforts. We plan to follow-up with the department to obtain documentation of its efforts to address the recommendation.