Immigration Benefits:

Consistent Adherence to DHS's Acquisition Policy Could Help Improve Transformation Program Outcomes

GAO-12-66: Published: Nov 22, 2011. Publicly Released: Nov 22, 2011.

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Each year, the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS) processes millions of applications for immigration benefits using a paper-based process. In 2005, USCIS embarked on a major, multiyear program to transform its process to a system that is to incorporate electronic application filing, adjudication, and case management. In 2007, GAO reported that USCIS was in the early stages of the Transformation Program and that USCIS's plans partially or fully met key practices. In 2008, USCIS contracted with a solutions architect to help develop the new system. As requested, GAO evaluated the extent to which USCIS has followed DHS acquisition policy in developing and managing the Transformation Program. GAO reviewed DHS acquisition management policies and guidance; analyzed transformation program planning and implementation documents such as operational requirements; compared schedule and cost information with GAO best practice guidance; and interviewed USCIS officials..

USCIS has not consistently followed the acquisition management approach that DHS outlined in its management directives in developing and managing the Transformation Program. USCIS awarded a solutions architect contract in November 2008, in effect selecting an acquisition approach before completing documents required by DHS management directives. Specifically, DHS's acquisition policy requires that prior to selecting an acquisition approach, programs establish operational requirements, develop a program baseline against which to measure progress, and complete a plan that outlines the program's acquisition strategy. However, USCIS did not complete an Operational Requirements Document until October 2009, which was to inform the Acquisition Program Baseline and the Acquisition Plan. Consequently, USCIS awarded a solutions architect contract to begin capability development activities prior to having a full understanding of the program's operational requirements and the resources needed to execute the program. GAO has previously reported that firm requirements must be established and sufficient resources must be allocated at the beginning of an acquisition program, or the program's execution will be subpar. The lack of defined requirements, acquisition strategy, and associated cost parameters contributed to program deployment delays of over 2 years. In addition, through fiscal year 2011, USCIS estimates it will have spent about $703 million, about $292 million more than the original program baseline estimate. USCIS expects to begin deployment of the first release of the Transformation Program in December 2011. However, USCIS is continuing to manage the program without specific acquisition management controls, such as reliable schedules, which detail work to be performed by both the government and its contractor over the expected life of the program. As a result, USCIS does not have reasonable assurance that it can meet its future milestones. USCIS has established schedules for the first release of the Transformation Program, but GAO's analysis shows that these schedules are not reliable as they do not meet best practices for schedule estimating. For example, program schedules did not identify all activities to be performed by the government and solutions architect. Moreover, as outlined by DHS acquisition management guidance, a life-cycle cost estimate is a required and critical element in the acquisition process. USCIS has developed and updated the $1.7 billion life-cycle cost estimate for the Transformation Program, but USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, raising questions about the credibility of the program's life-cycle cost estimates. Because some program costs such as labor, supervision, and facilities cost more if the program takes longer, reliable schedules can contribute to an understanding of the cost impact if the program does not finish on time. Collectively, and moving forward, not meeting best practices increases the risk of schedule slippages and related cost overruns, making meaningful measurement and oversight of program status and progress, and accountability for results, difficult to achieve. GAO recommends that USCIS ensure its program schedules and life-cycle cost estimates are developed in accordance with best practices guidance. DHS concurred with GAO's recommendations and outlined the actions that USCIS is taking or has taken to address each recommendation.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In November 2011 , we reported that U.S. Citizenship and Immigration Services (USCIS) had not consistently followed the acquisition management approach that the Department of Homeland Security (DHS) outlined in its management directives in developing and managing the Transformation Program. In particular, USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, raising questions about the credibility of the program's life-cycle cost estimates. Thus, we recommended that USCIS ensure program schedules are consistent with the nine estimating best practices. On May 4, 2015, DHS approved a new Transformation Program Acquisition Program Baseline and supporting documentation. In October 2015, we interviewed USCIS officials related to the Integrated Master Schedule (IMS) for the Transformation Program and, in December 2015, USCIS provided us with an updated version of the IMS and supporting documentation. On the basis of our review of USCIS documentation, we determined that the Transformation Program schedule did not meet one best practice, minimally met one best practice, partially met two best practices, and substantially met five best practices. While the IMS submitted for assessment in November 2015 does not meet all best practices, we note that USCIS has made substantial improvements in the quality of the schedule since our report. In particular, key best practices such as sequencing logic, horizontal and vertical integration, establishing critical paths through projects, and updating the status of the schedule have improved since the report was issued. Thus, we are closing this recommendation, as implemented. Having reliable and integrated schedules for the Transformation Program should help provide a road map for systematic project execution and a means to gauge progress, identify and resolve potential problems, and promote accountability at all levels of the program.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should ensure program schedules are consistent with the nine estimating best practices.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

  2. Status: Closed - Implemented

    Comments: In November 2011, we reported that U.S. Citizenship and Immigration Services (USCIS) did not have an integrated master schedule (IMS) for the entire Transformation program. We reported that, according to program officials, when the Transformation Program's planning efforts began, USCIS was unable to develop an integrated master schedule for the Transformation Program due to the complexity of integrating the numerous individual schedules and the lack of skilled staff necessary to develop and manage such an integrated master schedule. In addition, we reported that program officials explained that scheduling software to develop and maintain individual schedules was not used by every organization performing transformation work. Thus, we recommended that USCIS develop and maintain an IMS for the Transformation Program consistent with GAO's best practices for schedule estimating. On the basis of our review of USCIS documentation, we found that USCIS had taken action to consolidate all of its planned efforts into an IMS. Specifically, the planned effort spans software releases out to 2018 and program management activities through 2020. Having an IMS for the Transformation Program that is consistent with GAO's best practices should help integrate all the scheduled work, including the effort necessary from all government, contractor, and other key parties.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should develop and maintain an Integrated Master Schedule consistent with these same best practices for the Transformation Program.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

  3. Status: Closed - Implemented

    Comments: In November 2011, GAO reported that U.S. Citizenship and Immigration Services (USCIS) lacked reliable schedules for its Transformation Program. Therefore, GAO found that USCIS's ability to develop reliable life-cycle cost estimates for the Transformation Program was hampered. As outlined by Department of Homeland Security (DHS) acquisition management guidance, a life-cycle cost estimate (LCCE) is a required and critical element in the acquisition process. GAO reported that USCIS had developed and updated the LCCE for the Transformation Program, but USCIS's individual schedules for the Transformation Program did not meet best practices for schedule estimating, thus raising questions about the credibility of the program's LCCEs. As a result, GAO recommended that USCIS ensure that the LCCE for the Transformation Program is informed by milestones and associated tasks from reliable schedules that are developed in accordance with the nine best practices that GAO identified. USCIS approved a new Transformation Program Acquisition Program Baseline, on May 4, 2015, and provided it to GAO. In addition, in October 2015, we interviewed USCIS officials related to the Integrated Master Schedule (IMS) for the Transformation Program and, in December 2015, USCIS provided us with an updated version of the IMS and supporting documentation. On the basis of our review of USCIS documentation, we determined that the Transformation Program schedule did not meet one best practice, minimally met one best practice, partially met two best practices, and substantially met five best practices. While the IMS submitted for assessment in November 2015 did not meet all best practices, we note that USCIS has made substantial improvements in the quality of the schedule since our report. In particular, key best practices such as sequencing logic, horizontal and vertical integration, establishing critical paths through projects, and updating the status of the schedule have improved since the report was issued. According to USCIS officials, the Department of Homeland Security's Chief Financial Officer approved a revised LCCE in April 2013, which USCIS updated further December 2014 before a final version was approved in April 2015. On the basis of our analysis of the LCCE and related schedule for the Transformation Program, we found that the cost estimate defines the program and reflects the current schedule, which we have determined is generally consistent with GAO best practices. Having a LCCE that is informed by reliable schedules should help USCIS determine the basis for informed investment decision making, realistic budget formulation and program resourcing, meaningful progress measurement, proactive course correction when warranted, and accountability for results.

    Recommendation: To help ensure that USCIS takes a comprehensive and cost-effective approach to the development and deployment of transformation efforts to meet the agency's goals of improved adjudications and customer services processes, the Director of USCIS should ensure that the life-cycle cost estimate is informed by milestones and associated tasks from reliable schedules that are developed in accordance with the nine best practices we identified.

    Agency Affected: Department of Homeland Security: United States Citizenship and Immigration Services

 

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