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entitled 'Business Systems Modernization: IRS Needs to Better Balance 
Management Capacity with Systems Acquisition Workload' which was 
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United States General Accounting Office: 
GAO: 

Report to Congressional Committees: 

February 2002: 

Business Systems Modernization: 

IRS Needs to Better Balance Management Capacity with Systems 
Acquisition Workload: 
	
GAO-02-356: 

GAO Highlights: 

Highlights of GAO-02-356, a report to the Subcommittee on Treasury and 
General Government, Senate Committee on Appropriations and the 
Subcommittee on Treasury, Postal Service and General Government House 
Committee on Appropriations. 

Why GAO Did This Study: 

The Internal Revenue Service (IRS) has underway a multiyear, 
multibillion-dollar business systems modernization program. Since 
1995, GAO has designated this program high-risk, in part because of 
its size and complexity and its immense importance to improving IRS 
mission performance and accountability. The Congress has mandated that 
GAO review IRS's plans for spending funds on this program. This study 
responds to that mandate by providing the results of GAO's review of 
IRS's November 2001 expenditure plan. 

What GAO Found: 

IRS's November 2001 expenditure plan defines the next incremental set 
of management and systems acquisition activities that are intended to 
move IRS closer to its systems modernization. Related to the 
activities proposed in this plan, IRS has to date made important 
progress in establishing the systems infrastructure needed to allow 
the introduction of future business application systems. Similar 
progress has also been made in establishing the key modernization 
management controls needed to achieve the kind of systems acquisition 
activities provided for in this plan. Nevertheless, as IRS moves 
forward to implement the plan, it faces increasing risk that it will 
be unable to deliver promised system capabilities on time and within 
budget. Reasons for this include: 

* IRS lacks certain modernization management controls and 
capabilities. For example, it lacks a human capital management 
strategy for the program and a reliable project cost-estimating 
process. It has also yet to implement mature systems and software 
acquisition process controls; its plans for correcting this allow core 
modernization projects to continue for at least 2 more years without 
such controls. 

* Interdependencies among ongoing systems acquisition projects and the 
complexity of associated activities to be performed during the period 
covered by the plan are an order of magnitude greater than those of 
the previous plan. This workload increase raises concern, because IRS 
was not able to meet many of the project cost and schedule commitments 
made in the less demanding prior plan. 

* IRS's plan provides for increasing its workload by starting 
additional projects that will further tax existing capability. 

In attempting to balance the need for introducing modern systems and 
their associated benefits as soon as possible, with the need for 
greater management capacity to ensure that these systems are 
introduced successfully, IRS's November 2001 plan emphasizes the 
former. This emphasis adds significant risk that escalates as the 
program advances. 

[Figure: multiple line graph: Refer to PDF for image] 

This graph plots management capability against project workload, with 
line depicting actual and desired. The gap between actual and desired 
is indicated as risk. 

[End of figure] 

What GAO Recommends: 

To address the escalating risks facing IRS in this critical program, 
GAO recommends that the IRS commissioner reconsider the planned scope 
and pace of the program as defined in the November 2001 expenditure 
plan. This is necessary to better balance the number of systems 
acquisition projects underway and planned with IRS's capacity to 
manage this workload. GAO is providing specific recommendations to the 
commissioner on how to strike such a balance. In response, the 
commissioner agreed with GAO's recommendations, and described planned 
and ongoing efforts to address each. 

This is a test for developing highlights for a GAO report. The full 
report, including GAO's objectives, scope, methodology, and analysis, 
is available at [hyperlink, http://www.gao.gov/products/GAO-02-356]. 
For additional information about the report, contact Randolph C. Hite 
(202-512-3439). To provide comments on this test highlights, contact 
Keith Fultz (202-512-3200) or E-mail HighlightsTest@gao.gov. 

[End of section] 

Contents: 

Letter: 

Recommendations for Executive Action: 

Agency Comments: 

Appendixes: 

Appendix I: Briefing Slides from December 10 and 11, 2001, Briefings 
to the Senate and House Appropriations Subcommittee Staffs: 

Appendix II: Comments from the Internal Revenue Service: 

Appendix III: GAO Contacts and Staff Acknowledgments: 
GAO Contact: 
Acknowledgments: 

Abbreviations: 

BSM: Business Systems Modernization: 

IRS: Internal Revenue Service: 

OMB: Office of Management and Budget: 

SA-CMM: Software Acquisition Capability Maturity Model: 

[End of section] 

United States General Accounting Office: 
Washington, D.C. 20548: 

February 28, 2002: 

The Honorable Byron L. Dorgan: 
Chairman: 
The Honorable Ben Nighthorse Campbell: 
Ranking Minority Member: 
Subcommittee on Treasury and General Government: 
Committee on Appropriations: 
United States Senate: 

The Honorable Ernest J. Istook, Jr. 
Chairman: 
The Honorable Steny H. Hoyer: 
Ranking Minority Member: 
Subcommittee on Treasury, Postal Service and General Government: 
Committee on Appropriations: 
House of Representatives: 

Pursuant to the Department of the Treasury's fiscal year 2002 
appropriations act, the Internal Revenue Service (IRS), in November 
2001, submitted to the congressional appropriations committees its 
fifth expenditure plan, requesting $391 million from its Business 
Systems Modernization (BSM) fund.[Footnote 1] As required by the act, 
we reviewed the plan. Our objectives were to (1) determine whether the 
plan satisfied the conditions specified in the act,[Footnote 2] (2) 
determine IRS's progress in implementing modernization management 
controls and capabilities, and (3) provide any other observations 
about the plan and IRS's BSM program. 

On December 10 and 11, 2001, we briefed your respective offices on the 
results of our review. This report transmits the materials used at 
those briefings, and reiterates the recommendations to the 
commissioner of internal revenue that we specified in the briefings. 
The full briefing materials, including our scope and methodology, are 
reprinted in appendix I. In summary, we made the following five major 
points: 

* IRS's November 2001 expenditure plan satisfied the conditions 
specified in the appropriations act. However, while the plan provided 
for satisfying these conditions, IRS must still fully implement the 
controls and capabilities described in the plan. 

* Since our June 2001 report,[Footnote 3] IRS has made important 
progress in implementing modernization management controls and 
capabilities and addressing our past recommendations. Nevertheless, 
IRS's modernization management capacity is still not where it needs to 
be, given (1) the number of systems acquisition projects that the 
November 2001 plan identifies as being underway, (2) the fact that 
several of these ongoing projects have already entered the critical 
building stage of their life cycles (milestone 3) and are to begin 
deployment (milestone 4) during this year, and (3) IRS's plan to begin 
additional projects. Examples of modernization management controls and 
capabilities that are not yet fully implemented include software 
acquisition management,[Footnote 4] configuration management,[Footnote 
5] quality assurance, risk management, enterprise architecture 
[Footnote 6] implementation, human capital management, integrated 
program scheduling, and cost and schedule estimating. 

* The increased risk of IRS's proceeding without these controls and 
capabilities has contributed to actual project cost, schedule, and 
performance shortfalls For example, in the fifth plan, IRS reports 
that the Customer Account Data Engine's (release 1) milestone 4 date 
has been delayed by 6 months, and its cost has increased by $5 million 
(13 percent above the fourth plan's funding level). Also, since 
submitting the fifth plan for approval, IRS announced that the 
Security and Technology Infrastructure Release's milestone 4 date has 
been delayed by 3 months, and its cost has increased by $6 million (24 
percent above the fourth plan's funding level). 

* IRS acknowledges the need to strengthen its modernization management 
controls, and recognizes that these controls become more critical as 
the size and complexity of the BSM program continues to increase. It 
also has actions underway to fully implement these controls and, until 
then, plans to compensate for their immaturity by applying experienced 
human capital. 

* In our view, reliance on a combination of existing immature 
processes and individual expertise and heroic efforts is a short-term 
solution to a long-term need. Given that the immaturity of these 
controls has already contributed to project cost, schedule, and 
performance shortfalls, and will likely continue to do so, IRS needs a 
better strategy for mitigating the risks it faces in implementing its 
fifth expenditure plan. To assist IRS in striking a proper balance 
between the need to quickly introduce modernized systems yet prudently 
manage the risks inherent in such an undertaking, we made the 
following recommendations to the commissioner of internal revenue. 

Recommendations for Executive Action: 

To address the escalating risks facing IRS on its BSM program, we 
recommend that the commissioner of internal revenue reconsider the 
planned scope and pace of the BSM program as defined in the fifth 
expenditure plan, with the goal of better balancing the number of 
systems acquisition projects underway and planned with IRS's capacity 
to manage this workload. At a minimum, the commissioner's 
reconsideration should include: 

* slowing ongoing projects and delaying new project starts to reduce 
Business Systems Modernization Office resource demands, 

* making correcting modernization management weaknesses a top priority 
and a matter of top management attention, and, 

* reapplying resources—-financial and human capital-—available from 
slowed and delayed projects toward correction of control weaknesses. 

We further recommend that the commissioner take the following actions 
with respect to each of the modernization management weaknesses that 
we identified. 

First, for software acquisition management, 

* immediately assess critical BSM projects (i.e., Customer Account 
Data Engine, Security and Technology Infrastructure Release, and e-
Services) against the Software Engineering Institute's Software 
Acquisition Capability Maturity Model® (SA-CMM®) level 2 requirements; 

* based on this assessment, develop a plan for correcting identified 
weaknesses for these projects, including having an independent SACMM 
evaluation performed on them before submission of the next BSM 
expenditure plan; 

* submit, with the next expenditure plan, the results of this 
independent evaluation, along with a plan for ensuring that all BSM 
projects that have passed milestone 3 will meet SA-CMM level 2 
requirements; and; 

* require all projects that did not pass milestone 3 as of December 
31, 2001, to be assessed as SA-CMM level 2, and have a plan for 
correcting any project weaknesses found as a condition of milestone 3 
approval. 

Second, for configuration management, risk management, enterprise 
architecture implementation, human capital strategic management, 
integrated program scheduling, and cost and schedule estimating, 
ensure that commitments discussed herein for addressing residual 
weaknesses are implemented as planned, and report any deviations from 
these planned commitments to IRS's appropriations subcommittees.
Third, until contractor quality assurance weaknesses are corrected, 
increase the level of IRS oversight, scrutiny, and quality assurance 
of contractor activities. 

Finally, to allow for effective congressional oversight of the 
program, we reiterate our prior recommendation that the commissioner 
report to IRS's appropriations subcommittees any changes to 
expenditure plan commitments concerning systems requirements/ 
capabilities to be delivered and the associated benefits to be 
realized, and continue to report such performance measures in future 
expenditure plans. 

Agency Comments: 

In commenting on a draft of this report, the commissioner of internal 
revenue agreed with our recommendations, adding that IRS leadership 
understands the importance of correcting the issues that we identified 
and is moving aggressively to resolve them. In this regard, the 
commissioner described IRS's ongoing and planned efforts relating to 
addressing each of our recommendations. The commissioner's written 
comments are reprinted in appendix II. 

We are sending copies of this report to the chairmen and ranking 
minority members of other Senate and House committees and 
subcommittees that have appropriations, authorization, and oversight 
responsibilities for the Internal Revenue Service. We are also sending 
copies to the commissioner of internal revenue, the secretary of the 
treasury, the chairman of the IRS oversight board, and the director of 
the Office of Management and Budget. Copies are also available at our 
Web site at [hyperlink, http://www.gao.gov]. 

Should you or your offices have questions on matters discussed in this 
report, please contact me at (202) 512-3439. I can also be reached by 
e-mail at hiter@gao.gov. Key contributors to this report are listed in 
appendix III. 

Signed by: 

Randolph C. Hite: 
Director, Information Technology Architecture and Systems Issues: 

[End of section] 

Appendix I: Briefing Slides from December 10 and 11, 2001, Briefings 
to the Senate and House Appropriations Subcommittee Staffs: 

Information Technology: 

Results of Review of IRS' November 2001 Business Systems Modernization 
Expenditure Plan: 

Briefing to the Staffs of the Senate Committee on Appropriations, 
Subcommittee on Treasury and General Government	(on December 11, 2001): 

and: 

the House Committee on Appropriations, Subcommittee on Treasury, 
Postal Service,	 and General Government (on December 10, 2001): 
	
Briefings Overview: 
* Introduction; 
* Objectives; 
* Scope and Methodology; 
* Background; 
* Results in Brief; 
* Results; 
* Conclusions; 
* Recommendations. 

Introduction: 
		
As mandated by IRS' FY 2002 appropriations act, Business Systems 
Modernization (BSM) funds are unavailable until IRS submits to the 
congressional appropriations committees for approval, a modernization 
expenditure plan that: 

* Meets the Office of Management and Budget's (OMB) capital planning 
and information technology (IT) investment control review requirements; 

* Complies with IRS' enterprise architecture;[Footnote 1] 

* Meets IRS life cycle management requirements;[Footnote 2] 

* Is approved by IRS, Treasury, and OMB; 

* Is reviewed by GAO; and; 

* Complies with federal acquisition requirements and management 
practices. 

Since mid-1999, IRS has submitted a series of expenditure or 
"spending" plans requesting release of BSM appropriated funds. 

To date, about $968 million has been appropriated for BSM, including 
about $391 million for FY 2002. Of the $968, $577 million has been 
released; about $391 million remains. 

On November 13, 2001, IRS submitted its fifth plan, seeking release of 
the remaining $391 million. 

If the plan is approved, the BSM fund will have a zero balance. To 
replenish the fund, IRS plans to request $450 million via its FY 2003 
budget request. 

[Figure: time line and accompanying data: Refer to PDF for image] 

BSM Funds Requested For Release: 
First plan, 5/99: $35 million; 
Interim Plan, 12/99: $33 million; 
Second Plan, 3/00: $276 million; 
Interim Plan, 8/00: $33 million; 
Third Plan, 10/00: $200 million; 
Fourth Plan, 3/01: $128 million; 
Fifth Plan, 10/01: $391 million. 
						
BSM Funds Released Per Plan: 
First plan, 5/99: $35 million; 
Interim Plan, 12/99: $33 million; 
Second Plan, 3/00: $148 million; 
Interim Plan, 8/00: $33 million; 
Third Plan, 10/00: $200 million; 
Fourth Plan, 3/01: $128 million; 
Fifth Plan, 10/01: Amount to be determined. 

Cumulative Release of BSM Funds: 
First plan, 5/99: $35 million; 
Interim Plan, 12/99: $68 million; 
Second Plan, 3/00: $216 million; 
Interim Plan, 8/00: $249 million; 
Third Plan, 10/00: $449 million; 
Fourth Plan, 3/01: $577 million; 
Fifth Plan, 10/01: $Amount to be determined. 

[End of figure]  

[End of section] 

Objectives: 

As agreed with IRS' appropriations subcommittees, our objectives were 
to: 

* determine whether the fifth expenditure plan satisfies the 
legislative conditions, 

* determine what progress IRS has made in implementing modernization 
management controls and capabilities, and, 

* provide any other observations about the fifth plan and IRS' BSM 
program. 

[End of section] 

Scope and Methodology: 

To accomplish our objectives, we: 

* Reviewed the fifth expenditure plan and met with IRS program 
officials to understand the scope and content of the plan; 

* Analyzed the plan against the legislative conditions to identify any 
variances; 

* Reviewed program and project management reports and briefings to 
assess progress in implementing modernization management controls and 
capabilities; 

* Observed modernization executive steering committee and subcommittee 
meetings to, among other things, document how the plan was developed 
and reviewed; 

* Interviewed program and project management officials to corroborate 
our understanding of the plan and other BSM activities. 

* Analyzed available evidence on recent efforts to implement 
modernization management controls and capabilities. Specifically, we 
analyzed progress and plans for: 

- enterprise architecture (EA) definition and implementation, 

- ELC definition and implementation, including configuration
management, quality assurance and risk management, 

- software acquisition maturity, as defined by the Software 
Engineering Institute's (SEI) Software Acquisition Capability Maturity 
ModelTM (SA-CMM), 

- human capital management, 

- cost and schedule estimating practices, 

- integrated program schedule development, and, 

- key projects, such as the Security and Technology Infrastructure 
Release (STIR), the Customer Account Data Engine (CADE), e-Services, 
and the Internet Refund and Fact of Filing project. 

* Collaborated with the Treasury Inspector General for Tax 
Administration (TIGTA) to avoid duplication of effort in reviewing BSM 
initiatives and incorporated TIGTA results in this briefing where 
appropriate. 

- Projects addressed by TIGTA included Customer Communications, e-
Services, the Telecommunications Enterprise Strategic Program, and 
Customer Relationship Management-Exam. 

- Program-level processes addressed in a recent capping report on key 
system development processes (e.g. requirements management, 
configuration management, risk management). 

As agreed with your offices, we did not independently validate planned 
initiatives' cost estimates or confirm, through system and project 
management documentation, the validity of IRS-provided information on 
the initiatives' content and progress. 

We provided a draft of this briefing on December 7, 2001, to IRS BSM 
program executives (Deputy Associate Commissioners for Program 
Management and Systems Integration and the Executive Program Advisor 
for Risk Management), and have incorporated their comments where 
appropriate. 

We performed our work from October through December 2001 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Background: 

Table: Summary of IRS' Fifth Expenditure Plan ($000)[9]: 

Program Management and Architecture Activities: 

Program Management Office: $7,918; 
Business Transformation Planning: $10,461; 
Architecture & Systems Integration: $32,539; 
Quality Management and Assurance: $10,082; 
Federally Funded Research and Development Center - MITRE: $18,070; 
Subtotal: $79,070. 

Project Level and infrastructure Activities[4]: 

Core Infrastructure Support Projects (e.g. STIR: $107,959; 
Business Systems Support Projects (Customer Account Data Engine, 
Custodial Accounting Project, Core Financial Systems): $112,224; 
Business Systems Projects: $89,686; 
Subtotal: $309,869. 

Addition to Management Reserve: $2,061. 

Total: $391,000. 

Source: IRS. 

[End of table] 

IRS' plan is to (1) continue ongoing program-level initiatives through 
mid-November 2002 and 16 ongoing projects to their next milestones and 
(2) start 6 new projects. Examples of new projects are: 

* Reporting Compliance, which is to, among other things, select 
returns for examination. 

* Filing and Payment Compliance, which is to enable access to taxpayer 
data in CADE and the Custodial Accounting Project system to determine 
compliance and allow taxpayers to resolve account issues 
electronically. 

Compared to the total BSM funds requested in the third and fourth 
plans combined, the fifth plan represents an 18 percent decrease in 
program management spending and a 27 percent increase in project 
acquisition spending. 

The third and fourth plans generally provided funding for FY 2001, and 
the fifth plan does so for FY 2002. 

[Figure: 2 pie-charts: Refer to PDF for image] 

3rd and 4th Plans ($343 million): 
Project Acquisition Spending: $244.1 million; 
Program Management Spending: $99.4 million. 

5th Plan ($391 million): 
Project Acquisition Spending: $309.9 million; 
Program Management Spending: $81.1 million. 

[End of figure] 
	
Like its previous plans, IRS' fifth expenditure plan covers contractor 
costs, such as the Prime Systems Integration Support (PRIME) 
contractor and the systems engineering and technical assistance 
contractor (MITRE), and not IRS internal costs, such as IRS BSM 
program office (BSMO) staff costs. As we previously reported,[Footnote 
11] 
	
* IRS' actual use of prior BSM funding has been limited to the 
modernization program. 

* IRS' actual use of prior IS funding has included modernization 
activities. 
		
Summary of Prior GAO Expenditure Plan Reviews: 

To date, GAO has reviewed and reported on six requests for BSM funding 
releases.[Footnote 12] 

* Since mid-1999, we have reported[Footnote 13] on the risks 
associated with IRS' approach of concurrently building systems while 
developing and implementing program management capabilities such as 
having a fully operational program management office and implementing 
the ELC. 

In summary, we reported that attempting to acquire modernized systems 
before having the requisite management capability increases the risk 
that systems will experience cost, schedule, and performance 
shortfalls. 

EA, configuration management, quality assurance, and risk management, 
are but four of many management controls required under IRS' ELC, 
which is a structured method for managing system modernization program 
and project investments throughout their life cycles (see below 
simplified diagram of ELC). 

Figure: IRS' Enterprise Life Cycle Phases and Milestones: 

[Refer to PDF for image: illustration] 

ELC Phase: Vision and Strategy; 
ELC Milestones: (1) Strategic Plan. 

ELC Phase: Architecture; 
ELC Milestones: (2) Concept Definition; (3) System Design. 

ELC Phase: Development. 

ELC Phase: Integration. 

ELC Phase: Deployment; 
ELC Milestones: (4) Enterprise Deployment. 

ELC Phase: Operations and Support; 
ELC Milestones: Post-Deployment Evaluation. 

[End of figure] 

We have also reported[Footnote 14] that the risks associated with 
building systems without the requisite management controls are not as 
severe early in projects' life cycles when they are being planned 
(project definition and preliminary system design), but escalate as 
projects are built (detailed design and development) and implemented 
(enterprise deployment). 
	
In the case of IRS and its ELC, this point of risk escalation is ELC 
Milestone 3, as is shown in the following graphic. From this point 
through deployment (Milestone 4) to operations and support (Milestone 
5), risk can increase significantly. 

In June 2001 report,[Footnote 15] we identified key IRS projects that 
were approaching or had passed Milestone 3 that were beginning to 
experience such cost, schedule, and performance shortfalls, and 
concluded that program risks were increasing (see graphic on next 
page). 

Figure: Timeline Depicting Escalating Program Execution Risk as of 
April 2001: 

[Refer to PDF for image: illustrated timeline] 

Program Management Capability: Program Management Office; 
Start: 6/99; 
Management capability fully established: 
Milestone 3 - beginning of detailed design and development: 

Program Management Capability: ELC; 
Start: 6/99; 
Management capability fully established: 7/01. 

Program Management Capability: Enterprise Architecture; 
Start: 1/00; 
Management capability fully established, 1.0: 12/00; 
Management capability fully established, 1.1: 6/01; 
Management capability fully established, 2.0: 10/01. 

Selected Key Acquisition Projects:[A] CAP; 
Start: 2/99; 
Milestone 3 - beginning of detailed design and development: 8/00; 
Ongoing timeline: through 9/01. 

Selected Key Acquisition Projects:[A] STIR; 
Start: 2/99; 
Milestone 3 - beginning of detailed design and development: 1/01; 
Ongoing timeline: through 9/01. 

Selected Key Acquisition Projects:[A] CADE; 
Start: 6/99; 
Milestone 3 - beginning of detailed design and development: 6/01; 
Ongoing timeline: through 9/01. 

Selected Key Acquisition Projects:[A] e-Services; 
Start: 6/99; 
Milestone 3 - beginning of detailed design and development: 12/00; 
Ongoing timeline: through 9/01. 

Selected Key Acquisition Projects:[A] Other Projects (14); 
Start: 6/99; 
Ongoing timeline: through 9/01. 

[A] 4 of 18 total acquisition projects. 

[End of figure] 

[End of section] 

Results in Brief: 

Table: IRS' fifth plan satisfies each of six legislative conditions: 

Legislative Condition; 1. Meets OMB capital planning and investment 
control review requirements; 
Satisfies. 

Legislative Condition; 2. Complies with IRS' enterprise architecture; 
Satisfies. 

Legislative Condition; 3. Meets the requirements of IRS' life cycle 
program; 
Satisfies. 

Legislative Condition; 4. Approved by IRS, Treasury, and OMB; 
Satisfies. 

Legislative Condition; 5. Reviewed by GAO; 
Satisfies. 

Legislative Condition; 6. Complies with federal acquisition 
requirements and management practices[A]; 
Satisfies. 

[A] These acquisition requirements and practices are intended to 
establish acquisition management rigor and discipline, such as those 
defined in the Software Engineering Institute's acquisition model. Our 
analysis of the plan focused on satisfaction of this model's tenets. 

[End of table] 

While the plan provides for satisfying these conditions, IRS still has 
to fully implement the controls and capabilities described in the plan. 

Nevertheless, IRS' modernization management capability is still not 
where it should be given (1) the number of acquisition projects that 
are underway, (2) the fact that several of these projects have already 
entered the critical building stage of their life cycles (Milestone 3) 
and are to begin deployment (Milestone 4) during calendar year 2002, 
and (3) IRS' plan to begin additional projects. 

Modernization management controls and capabilities that are not yet 
fully implemented are: 

* Software acquisition management, 
* Configuration management, 
* Quality assurance, 
* Risk management, 
* EA implementation, 
* Human capital management, 
* Integrated program scheduling, and, 
* Cost and schedule estimating. 

The increased risk of proceeding without these controls and 
capabilities is now contributing to actual project cost, schedule, and 
performance shortfalls. For example, 

* In the fifth plan, IRS reports that CADE's (Release 1) Milestone 4 
date has slipped by 6 months, and its cost has increased by $5 million 
(13% above the fourth plan's funding level), and; 

* Since submitting the fifth plan for approval, IRS announced that 
STIR's Milestone 4 date has slipped by 3 months, and its cost has 
increased by $6 million (24% above fourth plan funding level). 

Since IRS submitted its fifth plan, we shared our findings and 
conclusions with IRS. In response, IRS: 

* acknowledges the need to strengthen its modernization management 
controls, 

* recognizes these controls are more critical as the size and 
complexity of the BSM program continues to increase, and, 

* has efforts underway intended to fully implement these controls, and 
until then, plans to compensate for their immaturity by applying 
experienced human capital. 

In our view, reliance on a combination of existing immature processes 
and individual expertise and heroic efforts is a short-term solution 
to a long-term need. Given that these controls' immaturity have 
already contributed to project cost, schedule, and performance 
shortfalls, and will likely lead to future shortfalls, IRS needs a 
better strategy for mitigating the risks it faces in implementing its 
fifth expenditure plan. 

To assist IRS in striking a proper balance between the need to quickly 
introduce modernized systems and prudently manage the risks inherent 
in doing so, we are making recommendations to the Commissioner of 
Internal Revenue. 

[End of section] 

Results: 

Table: Objective 1: Fifth plan satisfies the conditions in IRS' FY 
2002 appropriations act: 

Legislative Condition: 1. Meets the OMB capital planning and IT 
investment control review requirements. 
Expenditure Plan Provisions: IRS' fifth expenditure plan provides for 
managing investments as part of a portfolio through its Investment 
Decision Management process. This includes conducting periodic 
portfolio reviews to assess changes in business priorities and project 
schedules. The fifth plan provides for such an assessment in January 
2002. The fifth plan also provides for IRS to revise and implement its 
business case guidance to achieve better system investment decisions 
based on compelling return-on-investment justifications. 	
			
Legislative Condition: 2. Complies with IRS' enterprise architecture. 
Expenditure Plan Provisions: The fifth plan provides funds to continue 
definition and implementation of the enterprise architecture. For 
example, it provides for: 
* addressing issues raised during review and approval of EA releases 
1.0 and 1.1; 
* completing and issuing EA release 2.0; 
* addressing EA compliance certification for selected projects; 
* issuance of the 2002 and 2003 release architectures; 
* operation of the architecture engineering office. 

Legislative Condition: 3. Meets the requirements of IRS' life cycle 
program. 
Expenditure Plan Provisions: The plan provides funds for meeting the 
requirements in IRS' life cycle management program, which IRS refers 
to as ELC. For example, the plan calls for: 
* maintaining responsibility for coordinating, tracking, and 
integrating all program-wide costs, schedules, releases, issues, and 
risks; 
* maintaining the ELC; 
* completing the implementation of configuration management, including 
establishing configuration items for existing (legacy) systems 
impacted by near-term modernization projects (project releases to be 
deployed in 2002 and 2003), and developing and controlling a 
configuration management master log. 

Legislative Condition: 4. Approved by IRS, Treasury, and OMB. 
Expenditure Plan Provisions: 
* IRS - September 17, 2001; 
* Treasury - October 19, 2001; 
* OMB - October 29, 2001; 
* Submitted to IRS' appropriations subcommittees - November 13, 2001. 

Legislative Condition: 5. Reviewed by GAO. 
Expenditure Plan Provisions: 
* GAO: 
- December 10, 2001 briefing to IRS' House appropriation subcommittee; 
- December 11, 2001 briefing to IRS' Senate appropriation subcommittee. 

Legislative Condition: 6. Complies with the acquisition rules, 
requirements, guidelines, and systems acquisition management practices 
of the federal Government. 
Expenditure Plan Provisions: As part of the ELC, IRS has defined 
processes, roles, responsibilities, etc. for implementing Software 
Engineering Institute (SET) Software Acquisition Capability Maturity 
ModelTM practices within the level 2 key process areas.[A] These 
practices are consistent with federal acquisition requirements and 
management practices, and the plan calls for implementation of the ELC 
on all projects. 
		
[A] These are Acquisition Planning, Solicitation, Requirements 
Development and Management, Project Management, Contract Tracking and 
Oversight, Evaluation, and Transition to Support. 

[End of table] 

Objective 2: Despite important progress, key controls and capabilities 
have not yet been implemented. 

Since we reported on IRS' last plan,[Footnote 16] IRS has made 
important progress in implementing modernization controls and 
capabilities and addressing our recommendations. 

However, key controls and capabilities are still not fully implemented. 

Table: 

IRS Commitments Made in March 2001 and Previous Plans to Address 
Weaknesses and Recommendations:	Mature software acquisition 
capabilities; 
* Have all projects follow SA CMM level 2 processes by September 2001; 
Not Completed: (See pp. 30-32); 
Revised Commitments in November 2001 Plan: All projects to satisfy SA 
CMM level 2 requirements during FY 2004. 

* Perform internal SA CMM level 2 capability compliance assessment by 
September 2001; 
Not Completed: (See pp. 30-32); 
Revised Commitments in November 2001 Plan: Internal assessment by June 
2002. 

* Have an external evaluation (SCE) performed by independent assessor 
in March 2002 to ensure compliance with SEPs SA CMM level 2 
requirements; 
Not Completed: (See p. 30-32); 
Revised Commitments in November 2001 Plan: External evaluation in 
December 2002. 

IRS Commitments Made in March 2001 and Previous Plans to Address 
Weaknesses and Recommendations:	ELC definition and implementation 
(Configuration Management, Quality Assurance, Risk Management; 

Configuration Management: 

* Fully define and institutionalize PRIME standard configuration 
management procedures by July 2001; 
Completed. 

* Fully define and institutionalize BSMO standard configuration 
management procedures by July 2001; 
Not Completed: (See pp. 35-36); 
Revised Commitments in November 2001 Plan: To be completed by early 
2002.
	
* Establish configuration item baselines for 2002 Release 
modernization projects by May 2001; 	
Completed. 	
			
* Identify configuration items for current production environment 
impacted by near-term (2002 and 2003) modernization project releases 
by November 2001; 
Not Completed: (See pp. 35-36); 
Revised Commitments in November 2001 Plan: 2002 project releases by 
March 2002. 2003 project releases date not yet established. 

* Establish a centralized CM repository by November 2001; 
Not Completed: (See pp 15-16); 
Revised Commitments in November 2001 Plan: To be completed by early 
2002.
		
Quality Assurance: 

* Implement BSM program office quality assurance function by November 
2001; 
Completed. 

Risk Management: 

* Complete definition of risk management program by November 2001; 
Completed. 

* Complete initial training of BSMO/PRIME personnel by November 2001; 
Completed. 

* Fully implement risk management program by November 2001; 
Not Completed: (See pp. 41-42); 
Revised Commitments in November 2001 Plan: To be completed by February 
2002.
		
IRS Commitments Made in March 2001 and Previous Plans to Address 
Weaknesses and Recommendations:	Enterprise Architecture (EA); 

* Approve EA 1.1; 
Completed. 

* Ensure ongoing projects are aligned with EA in accordance with 
compliance certification process; 
Not Completed: (See p. 44.45); 
Revised Commitments in November 2001 Plan: To be completed by late-
December 2001. 

[End of table] 

IRS Has Not Implemented Effective Software Acquisition Processes: 

The Clinger-Cohen Act requires the establishment of effective IT 
management processes. SEI's Software Acquisition Capability Maturity 
ModelTM defines such processes for managing software acquisitions. 
Since 1995, we have recommended that IRS establish, at a minimum, the 
"repeatable" level of SEI's software acquisition management processes 
(Level 2).[Footnote 17] 

IRS has not completed implementation of SEI's Level 2 software 
processes, although it committed in its fourth plan to do so by 
September 2001. 

IRS officials attribute the delay to their underestimation of how long 
it takes to implement the practices. 

To effectively implement mature acquisition management processes, an 
organization needs to: 

* first assess its strengths and weaknesses and; 

* then develop a plan for leveraging existing strengths and correcting 
weaknesses, paying special attention to projects that are most 
critical and vulnerable to weaknesses. 

To address its acquisition management control weaknesses, IRS has 
recently: 

* engaged SEI to help better estimate how long this will take, and; 

* developed a plan for implementing these practices which includes: 

- focusing first on two new BSM projects, 

- having these two projects internally assessed by June 2002, 

- having these two projects independently evaluated by December 2002, 
and, 

- implementing the practices on remaining BSM projects during FY 2004. 

In effect, this plan means that IRS will not implement mature 
acquisition processes on key projects until after initial system 
increments have passed critical, later life cycle phases. As a result, 
IRS will continue to run the risk that these projects' promised 
capabilities will not be delivered on time and within budget. 

The significance of this risk is magnified in light of the multiple 
dependencies that exist among projects, where for example, delays in 
one can cause cascading delays in others. 

IRS Has Made Important Progress, But Does Not Yet Have Effective 
Configuration Management: 
	
Effective configuration management is an essential control for 
ensuring the integrity and consistency of system modernization program 
and project products throughout their life cycles. 

In June 2001, we reported[Footnote 18] BSM configuration management 
was ineffective. Accordingly, we made recommendations to address this 
weakness. 

IRS has made important progress in addressing our recommendations. For 
example, it has: 

* identified configuration items and components to be controlled for 
BSM projects, 

* had the PRIME revise its program configuration management plan and 
procedures, which was completed in July 2001, 

* trained contractor and selected BSM program office personnel in 
configuration management, 

* established baselines for approved program and project products, 

* initiated periodic internal configuration management process audits 
on selected projects to ensure plans and procedures are being 
followed, and, 

* established configuration control boards, including defining 
thresholds governing which board should address which request. 

However, effective configuration management, as we previously 
recommended, requires an enterprise-wide configuration management 
process, including plans and procedures governing PRIME, BSM program 
office, and IRS IT services organization products and systems. At a 
minimum, this also involves: 

* establishing an integrated program-wide configuration library (i.e., 
a repository), 

* defining and implementing a program-wide configuration status 
account reporting mechanism, and, 

* identifying configuration items and components for current (legacy) 
systems affected by near-term (2002 and 2003) BSM project releases. 

IRS officials acknowledge these steps have not been completed but have 
plans to do so by March 2002, except for the 2003 project releases, 
for which a date has not yet been established. 

IRS officials also stated that these steps have not yet been fully 
implemented because all the steps needed to implement an effective 
configuration management process were not originally understood. 

While IRS has made progress in implementing effective
configuration management, until it fully does so, IRS cannot 
adequately assure that systems are being designed and developed
in accordance with enterprise-wide needs and requirements, and thus 
the likelihood that projects will eventually require expensive rework 
is increased. 

IRS Quality Assurance Efforts Have Identified PRIME Problems: 

Quality assurance (QA) provides independent assessments of whether 
management process requirements are being followed and whether product 
standards and requirements are being satisfied. 

In 2000, IRS established a QA organization within its BSM program 
office to, among other things, determine how well: 

* the BSM program office was following ELC acquisition management 
processes and product standards and; 

* the PRIME's QA function was performing its role of assessing the 
PRIME's adherence to quality processes and standards in producing BSM 
deliverables. 

IRS reviewed the PRIME's QA function, and in March 2001, reported 5 
major findings and concluded that the PRIME's QA was not always 
effective. Examples of findings were that the PRIME's QA: 

* had not planned its work adequately, which contributed to inadequate 
process audits and product reviews, 

* had not defined program and project metrics for assessing process 
and product quality, and, 

* was not organizationally independent. 

To address these weaknesses, IRS defined 24 corrective actions for the 
PRIME. As of November 2001, IRS reported that the PRIME had 
implemented 7 of the corrective actions, but 17 remained open. 
Examples of open actions are: 

* Ensure that QA reviews and approves deliverables before they are 
transmitted to IRS; 

* Require PRIME program and project quality plans to adhere to ELC 
standards. 

Until the PRIME corrects these weaknesses, the probability of PRIME 
deliverables not meeting expectations is unnecessarily increased, and 
the level of IRS contract oversight and control needed to compensate 
for these weaknesses increases. 

Despite Progress, Risk Management Not Yet Fully Implemented: 

A risk represents a potential problem. The purpose of risk management 
is to identify program and project risks before they result in a 
problem, appropriately respond to a risk based on its significance 
(probability of occurrence times its potential impact), and to 
actively manage it. 

Effectively managing these risks is one way to minimize the chances of 
program and project cost, schedule, and performance problems 
occurring. Consistent with our efforts to constructively engage with 
IRS on BSM, in 1999 we orally recommended to IRS' former CIO that IRS 
implement this capability across the BSM program and projects. 

IRS has defined risk management policies and procedures for its ELC. 
These included processes to: 

* identify risks, 

* evaluate probability of occurrence and potential impact on each 
project and across the BSM program, 

* develop risk mitigation plans and track their disposition, 

* establish a repository to maintain an inventory of identified risks, 
and, 

* report on the status of risks and mitigation plans. 

Despite these steps, IRS has yet to fully implement its risk 
management program policies and procedures. For example, 

* IRS' inventory of BSM risks does not identify all known risks (e.g. 
lack of mature software processes, lack of effective configuration 
management). 

* IRS' inventory of BSM risks does not identify all known risks (e.g. 
lack of mature software processes, lack of effective configuration 
management). 

* Risk plans and their disposition are not in all cases being tracked 
and updated. 

To strengthen risk management, IRS hired a senior executive in June 
2001 to implement effective risk management. This official: 

* attributed IRS' delay in implementing risk management to a lack of 
incentives to report risks, and; 

* created an action team to review IRS' risk management procedures and 
develop a plan for "revitalizing" the program, including incorporating 
incentives for escalating risks. 

IRS plans to have risk management fully implemented by February 2002. 

Until this is done, IRS cannot assure it is adequately managing 
program and project risks. Thus, the likelihood of BSM projects 
experiencing further cost, schedule, and performance shortfalls is 
increased. 

IRS Has Established Processes To Certify Alignment of BSM Projects 
With EA, But Key Projects Yet To Be Certified: 

EA is an institutional blueprint defining how an enterprise operates 
today, in both business and technology terms, and how it wants to 
operate at some point in the future. An EA also includes a roadmap for 
transitioning between these environments. 

Since 1995,[Footnote 19] we have recommended that IRS: 

* define and implement an EA to guide and constrain the acquisition of 
its modernized systems and; 

* map BSM projects to the EA to ensure they are built in accordance 
with the EA, which reduces the risk of expensive rework, especially 
after projects have begun detailed design and development. 

We reported in our June 2001 report[Footnote 20] that while IRS has 
developed EA versions 1.0 and 1.1, it had not yet performed the 
requisite mappings. 

Accordingly, we also recommended that IRS not approve projects exiting 
Milestone 3 until the required assessments were performed to certify 
that projects are aligned with the EA. 

IRS has taken important steps to implement this recommendation. For 
example: 

* In September 2001, IRS issued processes for certifying project 
compliance with the EA at Milestone 3, before projects proceed with 
detailed design and development. 

Nevertheless, IRS has not yet certified all BSM projects that are at 
or past Milestone 3 via this process and the current EA version, 
including: 

* Security and Technology Infrastructure Release, 

* Internet Refund and Fact of Filing (IRFoF), and, 

* Custodial Accounting Project. 

IRS officials stated these projects were delayed in being certified 
because issuing a draft of EA version 2.0 in October 2001 for comment 
was their highest priority. Also, STIR and CAP were certified 
compliant with an earlier EA version. IRS plans to complete 
certification of these projects by late-December 2001. 

However, until this is done, IRS cannot provide assurance that the 
project requirements and design are properly aligned with the EA. 
Without this alignment being established early and continuously 
throughout a project's life cycle, IRS increases the chances that 
expensive project rework will be required to meet IRS business and 
systems needs. 

Weaknesses in Controls and Capabilities Increase Risks: 

Weaknesses in any one of the aforementioned modernization management 
controls introduces an unnecessary element of risk to the BSM program, 
but the combination of these weaknesses introduces a level of risk 
that increases exponentially over time. Given that the fifth plan 
provides funding for later phases of key projects, continued 
development of other projects, and starting of new projects, it is 
likely that BSM projects will encounter additional cost, schedule, and 
performance shortfalls. This combination of circumstances and events 
is represented in the following updated graphic. 

As discussed later in this briefing, IRS reported in the fifth plan 
that BSM projects have already encountered cost, schedule, and/or 
performance shortfalls in meeting commitments made in the fourth plan. 
In those cases where the fifth plan cited a reason for the shortfall, 
our analysis of the reasons showed that weak management controls were 
a contributor--either via (1) proactive prudent IRS decision making 
not to start or continue projects because of immature controls (for 
example, see Reporting Compliance on p. 51 of this briefing) or (2) 
immature controls allowed project shortfalls to occur. 

Figure: Current Timeline Depicting Escalating Program Execution Risk 
as of December 2001: 

[Refer to PDF for image: illustration] 

Program Management Capability: Program Management Office; 
Start: 11/99; 
Management capability fully established: 2/02. 

Program Management Capability: Selected Management Capabilities (e.g. 
Configuration Mgmt, Quality Assurance, Risk Mgmt); 
Start: 11/99; 
Management capability fully established: 12/01; 2/02; 3/02. 

Program Management Capability: Enterprise Architecture	1.0	1.1
Start: 11/99; 
Management capability fully established: 1.0: 1/01; 1.1: 6/01; 2.0: 
4/02. 

Selected Key Projects[A]: STIR; 
Start: Prior to 11/99; 
Milestone 3: beginning of detailed design and development: 1/01; 
Milestone 4: completion of detailed design and development/beginning 
of deployment: 2/02; 
Ongoing: through 10/02. 

Selected Key Projects[A]: IRFoF; 
Start: Prior to 11/99; 
Milestone 3: beginning of detailed design and development: 10/01; 
Milestone 4: completion of detailed design and development/beginning 
of deployment: 5/02; 
Ongoing: through 10/02. 

Selected Key Projects[A]: CADE; 
Start: Prior to 11/99; 
Milestone 3: beginning of detailed design and development: 7/01; 
Milestone 4: completion of detailed design and development/beginning 
of deployment: 7/02; 
Ongoing: through 10/02. 

Selected Key Projects[A]: e-Services; 
Start: Prior to 11/99; 
Milestone 3: beginning of detailed design and development: 1/01; 
Milestone 4: completion of detailed design and development/beginning 
of deployment: 10/02; 
Ongoing: through 10/02. 

Selected Key Projects[A]: Other projects[A]; 
Start: Prior to 11/99; 
Ongoing: through 10/02. 

[A] 4 of 22 total acquisition projects. 

[End of figure] 

IRS acknowledges these risks. According to the CIO, until the
weaknesses are fully addressed, IRS is mitigating them by: 

* relying on existing immature processes, 

* leveraging the knowledge, skills, and abilities of experienced 
senior executives to make sure project issues are proactively managed, 
and, 

* hiring additional experienced executives. 

In our view, reliance on a combination of immature processes and 
individual capabilities and heroic efforts is not a recipe for 
success. Past government and industry experience shows the probability 
of repeating successes on projects using this approach is low. 

Objective 3: Other observations about IRS' fifth plan and its BSM 
program: 

Observation 1: Plan Discloses and Explains Project Cost and Schedule 
Changes, But Continues to Omit Changes to System Capabilities and 
Expected Benefits: 

In our June 1999 report on IRS' first plan,[Footnote 21] we 
recommended that IRS, in future expenditure plans, report progress 
against incremental project commitments. Since then, we have reported 
with each plan that IRS has improved its reporting but has not 
included progress on all incremental project commitments, such as 
promised system capabilities and expected system benefits. 

In the fifth plan, IRS disclosed that 18 projects have experienced 
cost and/or schedule shortfalls against commitments made in its fourth 
and other prior plans. 

Of the 18: 

* 7 were program management initiatives that had cost increases 
ranging from 1% to 84% ($150,000 to $1.9 million), and, 

* 11 were system acquisition projects, of which: 

- 10 experienced schedule delays ranging from 1.5 months to 14 months; 
6 of the 10 experienced delays of 4 months or more; and 1 project had 
its schedule shortened by 4 months. 

- 8 experienced cost increases ranging from 4% to 66% ($500,000 to 
$6.1 million); 3 had cost decreases ranging from 4% to 23% ($365,000 
to $4.1 million). 

Table: Examples include:[A] 
			
Program/Project	Management Initiative: Reporting Compliance--
Individual Milestone 2; 
Commitment Date and Funding as of 3/2001 ($000): 11/30/01; $6,022	
Revised Commitment Date and Funding ($000): 11/30/02; $10,000
Change (%): +12 months; +$3,978 (66%). 
			
Program/Project	Management Initiative: Customer Account Data Engine 
(CADE) Milestone 4; 
Commitment Date and Funding as of 3/2001 ($000): 12/31/01; $40,038; 
Revised Commitment Date and Funding ($000): 6/30/02; $45,338
Change (%): +6 months; +$5,300 (13%). 
			
Program/Project	Management Initiative: Security and Technology 
Infrastructure Releases (STIR) 
Milestone 4; 
Commitment Date and Funding as of 3/2001 ($000): 9/30/01; $25,178
Revised Commitment Date and Funding ($000): 1/31/02; $31,287
Change (%): +4 months; +$6,109 (24%). 

[A] A list of 18 is in appendix III. 

[End of table] 
		
However, the fifth plan does not provide the level of specificity 
needed to identify changes, if any, to projects' scope. For example, 
while the plan discusses the impact of the schedule and cost variances 
on each project, it does not specify (1) changes to project scope and 
related benefit expectations or (2) effects on interdependent projects 
and their benefits. 

In addition, since the plan was completed, other slippages have 
occurred. For example, on October 23, 2001, IRS moved STIR's Milestone 
4 from October 2001 to January 2002, increasing its reported schedule 
slippage from 1 months to 4 months. 

According to IRS officials, the omission of such scope and benefit 
information was an oversight, and they plan to correct it in the next 
expenditure plan. 

By not fully providing scope and benefit change information, 
congressional oversight of IRS modernization management performance 
and accountability is constrained. 

Observation 2: IRS Beginning to Develop BSM Human Capital Strategy: 
	
As we have previously reported,[Footnote 22] strategic human capital 
centers on viewing people as assets whose value to an organization can 
be enhanced through investment. As the value of people increases, so 
does the performance capacity of the organization. To maintain and 
enhance the capabilities of IT staff, organizations should, among 
other things, 

* assess knowledge and skills needed to effectively perform IT 
operations to support agency mission and goals,	 

* inventory the knowledge and skills of current IT staff, 

* identify gaps between requirements and current staffing, and, 

* develop and implement plans to fill the gaps. 

IRS has begun to address this issue. For example, it has hired a human 
capital specialist to develop a plan by January 2002, for defining and 
implementing an IT human capital strategy. 

Until IRS develops and implements this strategy, it will not know 
whether it has the right IT knowledge and skills to effectively manage 
the BSM program. Without this, IRS increases the risk of BSM program 
and project cost, schedule, and performance shortfalls. 

Observation 3: IRS' Integrated Master Schedule Has Yet to be Finalized: 

The Integrated Master Schedule is an important tool for managing IRS' 
acquisition of modernized systems. According to IRS, it is to: 

* specify about 20,000 major tasks and associated schedules, involving 
a dozen organizations, for acquiring and implementing the portfolio of 
BSM projects, and, 

* identify the numerous and complex dependencies across these projects. 

IRS officials recognize the importance of having such an integrated 
schedule and committed to completing one before they begin 
implementing FY 2002 system releases (scheduled to begin in January 
2002). However, despite important progress, IRS has not yet completed 
the schedule because: 

* implementation plans (through milestone 5) have not yet been 
developed for all BSM projects to be implemented in FY 2002, 

* all change requests that impact BSM projects baselines have not been 
analyzed, approved, and incorporated into the schedule, and, 

* 33 of 61 changes that need to be made to existing (legacy) systems 
have not yet been analyzed, approved, and incorporated into the 
schedule. 

IRS officials stated that they plan to have the Integrated Master 
Schedule completed by late December 2001. 

They attributed the delay in finalizing the schedule to this being the 
first time IRS has attempted to develop a management tool of this size 
and complexity, and it has taken longer than anticipated. 

Until these steps are completed, IRS does not have the means to 
adequately manage the interdependencies within and among projects, 
thus increasing the risk of project delays, overruns, and rework. 

Observation 4: IRS Has Not Yet Implemented Effective Project Cost and 
Schedule Estimating Practices: 

Producing reliable estimates of expected costs for program-level 
activities and projects is essential to determining a project's cost-
effectiveness. Without this information, the likelihood of poor 
investment decisions is increased. 

As part of our ongoing constructive engagement with IRS, we have 
orally recommended to the former and current IRS CIOs that IRS adopt 
effective cost and schedule estimating practices. SEI defines such 
practices in its model for evaluating organizational cost and schedule 
estimating capabilities.[Footnote 23] The practices include having: 

* a historical database, 

* structured processes for estimating product size and reuse, 

* extrapolation mechanisms, 

* audit trails, 

* integrity in dealing with dictated costs and schedules, and, 

* data collection and feedback processes. 

IRS officials recognize the importance of each of these practices. 
However, IRS is not currently performing them. 

Consequently and as has been the case in the prior plans, the cost and 
schedule estimates in IRS' fifth plan are contractor-provided, "rough 
order of magnitude" estimates, that have not been subjected to 
meaningful, reliable validation by IRS. 

IRS officials stated that heretofore they have not been able to 
dedicate time to implementing effective estimating practices because 
of other competing program and project priorities. 

However, IRS has tasked the PRIME to develop a plan to implement an 
estimating capability, that is to include: 

* Selection of an estimating method, 

* Development of a plan for implementing the method by mid-January 
2002, and, 

* Implementation of the plan beginning by the end of February 2002. 

IRS then plans to develop and implement an approach to oversee PRIME 
estimating efforts by February 2002. 

IRS officials acknowledge that IRS' lack of an effective estimating 
process has contributed to project delays and cost overruns. Without 
improved estimation practices, these project shortfalls are likely to 
continue. 

[End of section] 

Conclusions: 

IRS' fifth plan satisfies the legislative conditions. However, what 
has and continues to challenge IRS is implementing the planned 
management controls and capabilities. Since our last report, IRS has 
made important progress in implementing pockets of modernization 
management capability. However, this capability is still not where it 
should be because it has not received the same level of priority and 
attention as BSM system projects. In our view, these modernization 
control weaknesses will continue to put IRS at risk of building 
systems that may not perform as intended, and/or cost more and take 
longer than necessary to complete. 

Moreover, the risks facing IRS have and will continue to become more 
severe as projects begin to be built and implemented (ELC Milestones 3 
and 4). Consequently, we are particularly concerned about those 
projects that have or are going to proceed beyond these milestones. 
This concern is heightened because (1) several of these projects are 
to provide the foundational infrastructure upon which later projects 
depend, and (2) these projects are already beginning to experience 
cost and schedule delays. Exacerbating this situation are IRS' plans 
to simultaneously start more projects while confronting these other 
challenges. 

IRS' risk mitigation strategy of relying on experienced executives 
until control weaknesses are corrected is at best a stop gap measure 
and is not sufficient given that IRS' timeline for addressing software 
acquisition weaknesses extends 2 years. Until IRS addresses its 
management control weaknesses, it will expose BSM to unnecessary risk. 

IRS' fifth plan also does not fully provide whether projects' scope 
and expected benefit commitments have changed. Such information is 
critical to congressional oversight of IRS modernization management 
performance and accountability. 

[End of section] 

Recommendations for Executive Action: 

To address the escalating risks facing IRS on its BSM program, we 
recommend that the Commissioner of Internal Revenue: 

* reconsider the planned scope and pace of the BSM program as defined 
in the fifth expenditure plan with the goal of better balancing the 
number of system acquisition projects underway and planned with IRS' 
capacity to manage this workload. At a minimum, the Commissioner's 
reconsideration should include: 

- slowing ongoing projects and/or delaying new project starts to 
reduce BSMO resource demands, 

- making correcting modernization management weaknesses a top priority 
and a matter of top management attention, and, 

- reapplying resources (financial and human capital) available from 
slowed and delayed projects toward correction of control weaknesses. 

To that end, we further recommend that the Commissioner do the 
following with respect to each of modernization management weaknesses 
that we identified. 

* First, for software acquisition management, 

- immediately assess CADE, STIR, and e-Services against SEI SA-CMM 
level 2 requirements, 

- based on this assessment, develop a plan for correcting identified 
weaknesses for these projects, including having an independent CMM 
evaluation performed on these projects before submission of the next 
BSM expenditure plan, 

- submit with the next expenditure plan, the results of this 
independent evaluation, along with a plan for ensuring that all BSM 
projects that have passed milestone 3 will meet CMM level 2 
requirements, and, 

- require all projects that have not passed milestone 3 as of December 
31, 2001, to be assessed as CMM level 2 and have a plan for correcting 
any project weaknesses found as a condition of milestone 3 approval. 

* Second, for configuration management, risk management, EA 
implementation, human capital strategic management, integrated program 
scheduling, and cost and schedule estimating, ensure that commitments 
discussed in this briefing for addressing residual weaknesses are 
implemented as planned, and report any deviations, from these planned 
commitments to IRS' appropriations subcommittees. 

* Third, until PRIME quality assurance weaknesses are corrected, 
increase the level of IRS oversight, scrutiny, and quality assurance 
of PRIME activities. 

In addition, to allow for effective congressional oversight of the 
program, we reiterate our prior recommendation that the Commissioner 
report to IRS' appropriations subcommittees on any changes to 
expenditure plan commitments concerning system 
requirements/capabilities to be delivered and the associated benefits 
to be realized, and continue to report such performance measures in 
future expenditure plans. 

[End of section] 

Agency Comments: 

In commenting on a draft of this briefing, BSM executives stated that 
they generally agreed with our findings, conclusions, and 
recommendations. 

[End of section] 

Appendix I: IRS' Expenditure Plan: 

Table: BSM Spending Plan, Fiscal Year 2002 ($000): 

Proposed Modernization Initiatives: 

Program Level Activities[A]: Program Management (formerly Prime 
Program Management Office); 	
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $7,918. 
			
Program Level Activities[A]: Business Integration; 
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $10,461. 

Program Level Activities[A]: Architecture & Integration; 
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $32,539. 

Program Level Activities[A]: Management Processes; 
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $10,082. 

Program Level Activities[A]: FFRDC (MITRE); 
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $18,070. 

Program Level Activities[A]: Subtotal: $79,070. 

Core Infrastructure Support Projects[A]: Security and Technology 
Infrastructure Releases; 
Milestone: FY; 
Milestone Date: May 02; 
Amount Requested: $43,973. 

Core Infrastructure Support Projects[A]: Infrastructure Shared 
Services; 
Milestone: FY; 
Milestone Date: Nov. 02; 
Amount Requested: $39,747. 

Core Infrastructure Support Projects[A]: Enterprise Systems Management; 
Milestone: FY; 
Milestone Date: July 02; 
Amount Requested: $11,323. 

Core Infrastructure Support Projects[A]: Development Integration & 
Testing Environment; 
Milestone: FY; 
Milestone Date: May 02; 
Amount Requested: $12,916. 

Core Infrastructure Support Projects[A]: Subtotal: $107,959. 

Data Projects: Customer Account Data Engine - MF R1; 
Milestone: MS5; 
Milestone Date: Dec. 02; 
Amount Requested: $5,795. 

Data Projects: Customer Account Data Engine - IMF R2; 
Milestone: MS4; 
Milestone Date: Dec. 02; 
Amount Requested: $38,400. 

Data Projects: Customer Account Data Engine - IMF R3; 
Milestone: MS3; 
Milestone Date: June 03; 
Amount Requested: $9,779. 

Data Projects: Enterprise Data Warehouse R3; 
Milestone: MS4,5; 
Milestone Date: May 04; 
Amount Requested: $4,500. 

Data Projects: Custodial Accounting Project TASL B1 B2; 
Milestone: MS4,5; 
Milestone Date: Feb. 04; 
Amount Requested: $36,500. 

Data Projects: Integrated Financial Services/Core Financial Systems; 
Milestone: MS4; 
Milestone Date: Nov. 02; 
Amount Requested: $17,250. 

Subtotal: $112,224. 

Business Projects: IR/FoF R1; 
Milestone: MS5; 
Milestone Date: July 02; 
Amount Requested: $5,000. 

Business Projects: e-Services 2002; 
Milestone: MS4,5; 
Milestone Date: Oct. 03; 
Amount Requested: $26,092. 

Business Projects: Customer Account Management; 
Milestone: MS3; 
Milestone Date: Oct. 02; 
Amount Requested: $24,494. 

Business Projects: Filing & Payment Compliance; 
Milestone: MS2,3; 
Milestone Date: Jan. 03; 
Amount Requested: $14,100. 

Business Projects: Reporting Compliance - Individual; 
Milestone: MS2,3; 
Milestone Date: Nov. 02; 
Amount Requested: $10,000. 

Business Projects: HR Connect; 
Milestone: MS4,5; 
Milestone Date: Dec. 02; 
Amount Requested: $10,000. 

Subtotal: $89,686. 
			
Addition to Management Reserve: $2,061. 
			
Total Business Systems Modernization Program: $391,000. 

[A] Program Level and Core Infrastructure Support Projects are funded 
on a fiscal year (FY) basis rather than by milestone. 

[End of table] 

[End of section] 

Appendix II: Results of Past GAO Reviews: 

Spending Plan: 1st Spending Plan (May 1999) ($35 million request); 
Results of GAO Review: 
* The plan satisfied the legislative conditions for the use of MA 
funds and was consistent with our open recommendations.
* The plan was an appropriate first step, but the key to success would 
be effective implementation of the plan.
* Future plans should specify progress against prior plan commitments, 
and the next plan should clarify IRS/contractor roles and 
responsibilities. (See Tax Systems Modernization: Results of Review of 
IRS' Initial Expenditure Plan, GAO/AIMD/GGD-99-206, June 15, 1999) 

Spending Plan: 1st Interim Spending Plan (Dec. 1999) ($33 million 
request); 
Results of GAO Review: 
*The plan raised concerns about projects that were scheduled to begin 
detailed design and software development before, among other things, 
the enterprise architecture was completed and the ELC was defined and 
implemented.
* IRS should expedite completion of the architecture and 
implementation of the ELC.
* Future plans should explain how IRS plans to manage the risk of 
performing detailed design or development work if the architecture is 
not sufficiently completed or the ELC is not sufficiently implemented. 

Spending Plan: 2nd Spending Plan (Mar 2000) ($176 million request); 
Results of GAO Review: 
* IRS met relatively few commitments in its $35 million first ITIA 
spending plan, even though the Service later received an additional 
$33 million and nearly 5 months of extra time to accomplish the goals 
set forth in the first plan. 
* The plan satisfied the legislative conditions for the use of ITIA 
funds, and was generally consistent with recommendations contained in 
our earlier reports. 
* The key to success would be whether IRS effectively implements the 
plan. 
* Until IRS completes its initiated actions to redirect and 
restructure its modernization effort, it would continue to lack key 
modernization and technical controls. (See Tax Systems Modernization: 
Results of Review of IRS' March 7, 2000, Expenditure Plan, GAO/AMID-00-
175, May 24, 2000). 

Spending Plan: 2nd Interim Spending Plan (Aug 2000) ($33 million 
request); 
Results of GAO Review: 
* IRS had not adhered to the approved and funded March 7, 2000, 
spending plan. 
* On selected initiatives, IRS had not met cost and schedule 
commitments made in its March 7, 2000 spending plan. 
* Most modernization initiatives had nevertheless made important 
progress since March 2000. IRS fully addressed two of its 
modernization management capability weaknesses, and it was making 
progress in addressing others. 
* One project, Custodial Accounting Project (CAP), had been approved 
for product development without sufficient definition and without a 
compelling business case. Further investment in CAP should be limited 
until IRS demonstrates sufficient business value and reports to the 
House and Senate committees on risk mitigation. 
* Another project, Security and Technology Infrastructure Release 
(STIR), was being preliminarily designed without sufficient 
requirements definition and economic justification. The STIR project 
should be directed to complete a security risk assessment as soon as 
possible, and ensure that STIR requirements and the proposed design 
solution are economically justified through a business case. (See Tax 
Systems Modernization: Results of Review of IRS' August 2000 Interim 
Spending Plan, GAO-01-91, November 8, 2000). 

Spending Plan: 3rd Spending Plan (Oct 2000) ($200 million request); 
Results of GAO Review: 
* IRS' plan satisfied the legislative conditions for the use of MA 
funds, and was making important progress towards satisfying the 
congressional direction on two projects - CAP and STIR. 
* IRS was making important progress in establishing effective 
modernization management capability, but important and challenging 
work remained. Until IRS completed its initiated actions to fully 
implement its system life cycle methodology and business systems 
modernization office, and resolve issues concerning the completeness 
and accuracy of enterprise architecture, it continued to lack key 
modernization and technical controls. 
* Five modernization initiatives experienced schedule delays and/or 
cost increases. However, the third plan did not address whether 
projects' prior commitments for delivery of promised systems 
capabilities (requirements) and benefit/business value were being met. 
* IRS used contractor-provided "rough order-of-magnitude" estimates in 
preparing the third expenditure plan. IRS planned to validate the 
third plan's estimates as part of its process to negotiate and 
definitize contract task orders. Previously, this process resulted in 
finalized contract costs below the estimates, totaling $9 million. 
(See Tax Systems Modernization: Results of Review of IRS' Third 
Expenditure Plan, GAO-01-227, January 22, 2001). 

Spending Plan: 4th Spending Plan (March 2001) ($128 million request); 
Results of GAO Review: 
* IRS' plan satisfied the conditions specified in the appropriations 
acts. 
* IRS continued to make important progress in implementing 
modernization management controls and capabilities. Nevertheless, IRS' 
modernization management capacity is still not where it should be, 
given (1) the number of systems acquisition projects that the March 
2001 plan identifies as underway and planned and (2) the fact that 
several of the ongoing projects are entering critical stages in their 
life cycles. For example, IRS did not have a sufficiently defined 
version of the enterprise architecture to guide and constrain 
projects, and employing rigorous configuration management practices. 
* Due to missing management capacity, key IRS projects were beginning 
to experience cost, schedule, and performance shortfalls against the 
commitments the agency made in its third expenditure plan. For 
example, deployment of the Customer Communications 2001 project was 
three months behind schedule, and promised system capabilities and 
associated benefits had been deferred. Also, a critical infrastructure 
project, STIR, was reported to be 1.5 months late in trying to 
complete its preliminary design phase 	(Milestone 3); and the agency 
was still working to finalize 6 of 19 work products needed to complete 
the phase. Thus, the project was actually almost five months late. 
* IRS officials recognized the need to address its modernization 
management capacity before key ongoing projects moved into critical 
life-cycle phases, and before additional projects were started. 
Accordingly, IRS planned or had initiated steps to address these 
weaknesses. In particular the Commissioner had decided to slow ongoing 
and new projects, giving priority to putting in place missing 
management capacity. We believed this decision was prudent and 
appropriate and made recommendations to ensure IRS followed through on 
this decision. (See Business Systems Modernization: Results of Review 
of IRS' March 2001 Expenditure Plan, GAO-01-716, June 29, 2001). 

[End of section] 

Appendix III: IRS Reported Cost Increases/Schedule Delays: 

Program/Project Management Initiative: Customer Communications 
Milestone 3 (release 2002); 
Commitment Date and Funding as of 3/2001 ($000): 07/31/01; $17,787; 
Revised Commitment Date and Funding ($000): 09/30/01; $13,696; 
Change (%): +2 months; -$4,091 (-23%). 
			
Program/Project Management Initiative: Customer Communications 
Milestone 4, 5 (release	2001); 
Commitment Date and Funding as of 3/2001 ($000): 5/31/01; $43,386; 
Revised Commitment Date and Funding ($000): 10/31/01: $45,174; 
Change (%): +5 months; +$1,788 (4%). 
			
Program/Project Management Initiative: e-Services Milestone 2,3; 
Commitment Date and Funding as of 3/2001 ($000): 6/30/01; $17,879; 
Revised Commitment Date and Funding ($000): 8/14/01; $16,819; 
Change (%): +1.5 months; -$1,060 (-6%). 

Program/Project Management Initiative: Customer Account Management 
Milestone 2; 
Commitment Date and Funding as of 3/2001 ($000): 11/30/01; $12,135; 
Revised Commitment Date and Funding ($000): 03/31/02; $13,100; 
Change (%): +4 months; +$965 (8%). 
			
Program/Project Management Initiative: Filing and Payment Compliance 
Milestone 2,3; 
Commitment Date and Funding as of 3/2001 ($000): 11/30/01; $2,517; 
Revised Commitment Date and Funding ($000): 01/31/03; $3,017; 
Change (%): +14 months; +500 (20%). 
			
Program/Project Management Initiative: Reporting Compliance--
Individual Milestone 2; 
Commitment Date and Funding as of 3/2001 ($000): 11/30/01; $6,022; 
Revised Commitment Date and Funding ($000): 11/30/02; $10,000; 
Change (%): +12 months; +3,978 (66%). 
			
Program/Project Management Initiative: Customer Account Data Engine 
(CADE) Milestone 2,3; 
Commitment Date and Funding as of 3/2001 ($000): 4/30/01; $16,567; 
Revised Commitment Date and Funding ($000): 6/30/01; $19,267; 
Change (%): +2 months; +$2,700 (16%). 
			
Program/Project Management Initiative: Customer Account Data Engine 
(CADE) Milestone 4; 
Commitment Date and Funding as of 3/2001 ($000): 12/31/01; $40,038; 
Revised Commitment Date and Funding ($000): 6/30/02; $45,338; 
Change (%): +6 months; +$5,300 (13%). 
			
Program/Project Management Initiative: Custodial Accounting Project 
(CAP) TASL B1 B2 Milestone 4,5; 
Commitment Date and Funding as of 3/2001 ($000): 7/31/03; $44,130
Revised Commitment Date and Funding ($000): 03/31/03; $51,430
Change (%): -4 months; +$7,300 (17%). 

Program/Project Management Initiative: Integrated Financial 
Services/Core Financial Systems Milestone 2,3; 
Commitment Date and Funding as of 3/2001 ($000): 3/31/02; $8,565; 
Revised Commitment Date and Funding ($000): 5/31/02; $8,200; 
Change (%): +2 months; -$365 (-4%). 
			
Program/Project Management Initiative: Security and Technology 
Infrastructure Releases (STIR) Milestone 4; 
Commitment Date and Funding as of 3/2001 ($000): 9/30/01; $25,178; 
Revised Commitment Date and Funding ($000): 1/31/02; $31,287; 
Change (%): +4 months; +$6,109 (24%). 

Program/Project Management Initiative: Virtual Development Environment 
(VDE); 
Commitment Date and Funding as of 3/2001 ($000): (thru end of FY01); 
$6,340; 
Revised Commitment Date and Funding ($000): $7,693; 
Change (%): +$1,353 (21%). 
			
Program/Project Management Initiative: Program Management Office 
(formally PPMO); 
Commitment Date and Funding as of 3/2001 ($000): (thru end of FY01); 
$21,716; 
Revised Commitment Date and Funding ($000): $22,448; 
Change (%): +$732 (3%). 
		
Program/Project Management Initiative: Program Management Office 
(formally PPMO); 
Commitment Date and Funding as of 3/2001 ($000): (1st 6 weeks of 
FY02); $2,236; 
Revised Commitment Date and Funding ($000): $4,124; 
Change (%): +$1,888 (84%). 
			
Program/Project Management Initiative: Vision and Strategy--Tax 
Administration (TAVS) Milestone 1; 
Commitment Date and Funding as of 3/2001 ($000): $8,376; 
Revised Commitment Date and Funding ($000): $8,996; 
Change (%): +$620 (7%). 

Program/Project Management Initiative: Internal Management Vision and 
Strategy (IMVS) Milestone 1; 
Commitment Date and Funding as of 3/2001 ($000): $4,227; 
Revised Commitment Date and Funding ($000): $4,377; 
Change (%): +$150 (4%). 
			
Program/Project Management Initiative: Configuration Management; 
(thru end of FY01); 
Commitment Date and Funding as of 3/2001 ($000): $1,687; 
Revised Commitment Date and Funding ($000): $1,885; 
Change (%): +$198 (12%). 
			
Program/Project Management Initiative: Architectural Engineering 
Office (AEO); 
Commitment Date and Funding as of 3/2001 ($000): (thru end of FY01); 
$19,670; 
Revised Commitment Date and Funding ($000): $19,906; 
Change (%): +$236 (1%). 

[End of table] 

[End of Appendix I] 

Appendix II: Comments from the Internal Revenue Service: 

Department Of The Treasury: 
Commissioner: 
Internal Revenue Service: 
Washington, D.C. 20224: 

February 15, 2002: 

Mr. Randolph C. Hite: 
Director, Information Technology Systems Issues: 
U.S. General Accounting Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Hite: 

I appreciate the GAO's review of the IRS's Business Systems 
Modernization (BSM) Plan for FY 2002. The release of the appropriated 
$391 million based on the GAO's review will make it possible for us to 
enhance services to the American taxpayer and improve the efficiency 
of the IRS operations. I welcome the opportunity to respond to the 
review and address the issues you raised. 

Modernization of the IRS's information systems and business processes 
is one of the largest and most complex business systems modernization 
programs ever undertaken. Consequently, we have no clear precedent for 
charting our course. We continue to mature as an organization while we 
undergo enormous change and simultaneously support the operations of 
the agency. We have learned that in any such complex undertaking, 
continuous changes will occur, and, therefore, we must adjust our 
plans as we learn. Nevertheless, we are committed to developing a 
program that employs sound management practices and uses our resources 
wisely. 

We made significant progress in FY 2001 in our BSM program. The IRS 
implemented its first two modernized systems, Customer Communications 
2001 and Customer Relationship Management Examination. Both are 
delivering business benefits to taxpayers and the IRS. In addition, we 
made significant advancements on many other projects slated for FY 
2002 delivery including: 

1. Internet Refund/Fact of Filing (which will allow taxpayers to use 
the Internet to check on the status of their refunds), 

2. Customer Account Data Engine Release 1 (a pilot of the first part 
of the modernized individual taxpayer data base), 

3. A production pilot of HR connect (a human resources management 
system being implemented Department-wide by Treasury), and, 

4. E-services (electronic problem resolution and relationship 
management for third party practitioners). 

Further, the first release of the Enterprise Architecture was 
delivered last January, as well as a major upgrade in May. The 
Enterprise Architecture includes a technical architecture, high-level 
business processes and an enterprise transition plan based on Tax 
Administration and Internal Management Visions and Strategies. An 
updated release is in progress for completion later this year. 

We have made important progress in implementing key infrastructure 
components needed to support future development and operation of BSM 
systems, such as new hardware and systems software, a robust testing 
environment, Internet portals, security infrastructure, and systems 
and network management capabilities. We have leveraged other resources 
within the Modernization, Information Technology and Security (MITS) 
Services organization, such as security, product assurance, and 
production operations. 

We have also made progress in Program management over the past year. A 
network of Executive Steering Committees, chaired by senior IRS 
executives and with broad business participation, are key elements of 
our BSM Program management structure. Project advisory councils, 
business process owners, our Enterprise Life Cycle Methodology, and a 
network of systems engineering and change control boards are all 
operating effectively. In addition, we redesigned our management 
meetings to increase communications, control, and address critical 
management and integration issues on a more timely basis. 

The combination of improvement management processes and a stronger 
executive management team has kept the Program under control. Further, 
as noted in the GAO Report, we made important progress in implementing 
key management processes, such as Configuration Management and Risk 
Management, though we acknowledge that further improvements are needed 
before these management processes are implemented fully. We will 
review with the GAO our commitment to achieving full implementation as 
soon as practical. 

We have addressed many of your recommendations, such as prudently 
slowing existing projects and deferring new projects when management 
capacity is inadequate to proceed with acceptable risk. 

GAO's Report cites 18 projects that "have experienced cost and/or 
schedule shortfalls against commitments made in the fourth and other 
prior plans." Many of the variances from plan are minor (less than 10 
percent), and several were cases where actual costs were less than 
estimated (the total variance across all 18 projects is under 10 
percent). Also, in many cases, these variations were the result of 
prudent management actions (formally approved by either the Core 
Business Systems Executive Steering Committee or the appropriate Sub-
ESC, and reviewed with GAO and OMB). Examples include deferring the 
Enterprise Systems Management project to align its testing schedule 
with other products to reduce overall cost, and deferring the start of 
Reporting Compliance due to lack of management capacity. 

Many of these commitments were simply planning estimates made early 
(prior to Milestone 3 exit) in the project life cycle (ELC). Our track 
record demonstrates effective control of BSM projects. However, we 
agree with the GAO that all management processes must be implemented 
fully since the complexity of the Program will increase dramatically 
as we go forward. We are neither complacent nor satisfied with our
present capabilities. We will provide a full explanation of the root 
causes of each of the cost or schedule differences in a separate 
communication. 

In addition to the internal management controls that are in place, 
those we are adding, and the legal controls that we operate under, the 
BSM Program performs in an exceptionally open environment, under 
special legislative controls, and with a rigorous and effective 
governance process. These controls, as well as our own management
judgment, ensure that we have adequate management capacity and an 
acceptable risk before starting future work. The GAO has indicated 
that we need to do a better job of explaining all unmet commitments in 
prior Plans in the current expenditure Plan, and we will do so. BSM 
executives will continue to hold weekly meetings, as we have done 
throughout FY 2001, with the GAO to inform you of events as they occur. 

I agree with your recommendations and have set target plans and 
schedules to fully implement Configuration Management, Risk 
Management, and cost and schedule estimating processes, as well as 
your recommendations in human capital management and other areas. We 
have reviewed these target dates with your office. In addition to the 
dedicated staff assigned to these improvements, both the IRS and PRIME 
have appointed senior executives to coordinate within and across our 
respective organizations to ensure we give top priority to completing 
their implementation. 

Regarding your recommendation to achieve the Software Engineering 
Institute's Software Acquisition Capability Maturity Model (SA-CMM) 
Level 2 certification, we have made progress. We acknowledge that this 
has taken longer than we expected, and our past commitment to achieve 
this by September 2001 was unrealistic, based on how long other 
organizations are taking to achieve this level of 
certification.[Footnote 1] I believe our plan is now reasonable, we 
have developed these plans working closely with MITRE, the Systems 
Engineering Institute of Carnegie Mellon University, and the PRIME
contractor, who has already achieved this certification level in their 
Civilian Government Group.[Footnote 2] This thorough preparation and 
planning ensures that we have a realistic approach to achieving SA-CMM 
Level 2 certification as targeted. 

Regarding your recommendation to align the pace of the program with 
the maturity of the BSM Organization's management controls and 
management capacity, we agree and are committed to comply. To 
illustrate, we are conducting a Portfolio Reassessment for the FY 2002 
plan, with participation from IRS's business units, MITRE and PRIME. 
Our Core Business Systems Executive Steering Committee will approve 
this reassessment. 

We recently completed a major effort to "refresh" the Tax 
Administration Vision and Strategy (TAVS), which looks ahead to FY 
2003 and beyond, and will "institutionalize" the value of this vital 
program asset. In all these reviews, we look for opportunities to make 
prudent adjustments to the program plan to lower execution risk. We 
are proactively keeping all of our stakeholders informed of any 
changes we make as a result of the Portfolio Reassessment process, and 
we plan to conduct regular Portfolio Reassessments in the future. 

We must maintain the momentum created in FY 2001 as we move into FY 
2002 and beyond, both to deliver benefits to taxpayers and IRS 
employees to maintain strong buy-in from IRS executives and other key 
stakeholders. Hence, we need to strike a proper balance between 
delivering business value, building critical infrastructure, and 
implementing the management processes necessary to ensure control and 
effectiveness. We believe our FY 2002 Expenditure Plan strikes this 
balance, but will continue to reexamine our commitments as per the 
GAO's recommendations. 

IRS leadership understands the importance of correcting the issues you 
identified and is moving aggressively to resolve them. I appreciate 
your acknowledgment of the important progress we made. I also 
appreciate your hard work in preparing your comprehensive report, your 
support of the BSM Program, and your ongoing counsel. 

Sincerely, 

Signed by: 

Charles O. Rossotti: 

Appendix II Footnotes: 

[1] Only one other government organization, the Abrams Battle Tank 
Program in the Department of Defense, has achieved SA-CMM Level 2 
certification, and they just did so last November. 

[2] CSC's Civilian Group was the first organization to achieve SA-CMM 
Level 2, and expects to receive their SA-CMM Level 3 certification 
soon. 

[End of Appendix II] 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

Gary N. Mountjoy, (202) 512-6367. 

Acknowledgments: 

In addition to the individual named above, other key contributors were 
Bernard R. Anderson, William G. Barrick, Timothy D. Hopkins, Ona M. 
Noble, Pietro L. Salatti, Aaron W. Thorne, and William F. Wadsworth. 

[End of section] 

Footnotes: 

[1] The Treasury and General Government Appropriations Act, 2002 (P. 
L. 107-67). 

[2] The act specifies that BSM funds are unavailable until IRS submits 
to congressional appropriations committees for approval a 
modernization expenditure plan that (1) meets the Office of Management 
and Budget's (OMB) capital planning and information technology 
investment control review requirements; (2) complies with IRS's 
enterprise architecture; (3) meets IRS's life-cycle management 
requirements; (4) is approved by IRS, Treasury, and OMB; (5) is 
reviewed by GAO; and (6) complies with federal acquisition 
requirements and management practices. 

[3] U.S. General Accounting Office, Business Systems Modernization: 
Results of Review of IRS's March 2001 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-01-716] (Washington, D.C.: June 29, 
2001). 

[4] Carnegie Mellon University's Software Engineering Institute has 
developed criteria, known as the Software Acquisition Capability 
Maturity Model® (SA-CMM®), for determining organizations' software 
acquisition management effectiveness or maturity. Capability Maturity 
Model and CMM are registered in the U.S. Patent and Trademark Office. 

[5] Configuration management is the means for ensuring the integrity 
and consistency of systems modernization programs and project products 
throughout their life cycles. Through effective configuration 
management, for example, integration among related projects and 
alignment between projects and the enterprise architecture can be 
achieved. 

[6] An enterprise architecture is an institutional blueprint defining 
how an enterprise operates today, in both business and technological 
terms, and how it wants to operate in the future. It also includes a 
roadmap for transitioning between these environments. 

[7] An Enterprise Architecture (EA) is an institutional blueprint 
defining how an enterprise operates today, in both business and 
technology terms, and how it wants to operate at some point in the 
future. An EA also includes a roadmap for transitioning between these 
environments. 

[8] IRS refers to its life cycle management program as the Enterprise 
Life Cycle (ELC), which is graphically depicted in the Background 
Section. 

[9] See appendix I for a more detailed summary of the plan. 

[10] The 3 categories under this heading include 16 separate projects. 

[11] Internal Revenue Service: Results of Review of IRS Spending for 
Business Systems Modernization [hyperlink, 
http://www.gao.gov/products/GA0-01-920], August 17, 2001. 

[12] For details on our past review results, see appendix II. 

[13] For example, see Business Systems Modernization: Results of 
Review of IRS' March 2001 Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-716], June 29, 2001, and Internal 
Revenue Service: Progress Continues But Serious Management Challenges 
Remain [hyperlink, http://www.gao.gov/products/GAO-01-562T], April 2, 
2001. 

[14] For example, see Tax Systems Modernization: Results of Review of 
IRS' Third Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-227, January 22, 2001). 

[15] Business Systems Modernization: Results of Review of IRS' March 
2001 Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-716], June 29, 2001. 

[16] Business Systems Modernization: Results of Review of IRS' March 
2001 Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-716], June 29, 2001. 

[14] Tax Systems Modernization: Management and Technical Weaknesses 
Must Be Corrected If Modernization Is to Succeed [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-95-156], July 26, 1995. 

[18] Business Systems Modernization: Results of Review of IRS' March 
2001 Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-716], June 29, 2001. 

[19] For example, Tax Systems Modernization: Management and Technical 
Weaknesses Must Be Corrected If Modernization Is to Succeed 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-95-156], July 26, 
1995.	 

[20] Business Systems Modernization: Results of Review of IRS' March 
2001 Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GA0-01-716], June 29, 2001. 

[21] Tax Systems Modernization: Results of Review of IRS' Initial 
Expenditure Plan [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-99-206], June 15, 1999. 

[22] Human Capital: Attracting and Retaining a High-Quality 
Information Technology Workforce [hyperlink, 
http://www.gao.gov/products/GAO-02-113T], October 4, 2001. 

[23] Software Engineering Institute Checklists and Criteria for 
Evaluating the Cost and Schedule Estimating Capabilities of Software 
Organizations (CMU/SEI-95-SR-005). 

[End of section] 

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