This is the accessible text file for GAO report number GAO-11-115 
entitled 'Information Technology: Veterans Affairs Can Further Improve 
Its Development Process for Its New Education Benefits System' which 
was released on December 1, 2010. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

United States Government Accountability Office:
GAO: 

Report to the Committee on Veterans' Affairs, House of Representatives: 

December 2010: 

Information Technology: 

Veterans Affairs Can Further Improve Its Development Process for Its 
New Education Benefits System: 

GAO-11-115: 

GAO Highlights: 

Highlights of GAO-11-115, a report to the Committee on Veterans' 
Affairs, House of Representatives. 

Why GAO Did This Study: 

The Post-9/11 GI Bill was signed into law in June 2008 and provides 
educational assistance for veterans and members of the armed forces 
who served on or after September 11, 2001. The Department of Veterans 
Affairs (VA) is responsible for processing claims for these new 
education benefits. VA concluded that its legacy systems and manual 
processes were insufficient to support the new benefits and, 
therefore, began an initiative to modernize its benefits processing 
capabilities. The long-term solution was to provide a fully automated 
end-to-end information technology (IT) system to support the delivery 
of benefits by December 2010. VA chose an incremental development 
approach, called Agile software development, which is intended to 
deliver functionality in short increments before the system is fully 
deployed. 

GAO was asked to (1) determine the status of VA’s development and 
implementation of its IT system to support the implementation of 
education benefits identified in the Post-9/11 GI Bill and (2) 
evaluate the department’s effectiveness in managing its IT project for 
this initiative. 

What GAO Found: 

VA has made important progress in delivering key automated 
capabilities to process the new education benefits. Specifically, it 
deployed the first two of four releases of its long-term system 
solution by its planned dates, thereby providing regional processing 
offices with key automated capabilities to prepare original and 
amended benefit claims. In addition, the Agile process allowed the 
department the flexibility to accommodate legislative changes and 
provide functionality according to business priorities. While progress 
has been made, VA did not ensure that certain critical tasks were 
completed that were initially expected to be included in the second 
release by June 30, 2010. For example, the conversion of data from 
systems in the interim solution to systems developed for the long-term 
solution was not completed until August 23, 2010. Because of the 
delay, VA planned to reprioritize the functionality that was to be 
included in the third release. Further, while VA plans to include full 
self-service capabilities to veterans, it will not do so in the fourth 
release as scheduled; instead it intends to provide this capability 
after the release or in a separate initiative. VA reported obligations 
and expenditures for these releases, through July 2010, to be 
approximately $84.6 million, with additional planned obligations of 
$122.5 million through fiscal year 2011. 

VA has taken important steps by demonstrating a key Agile practice 
essential to effectively managing its system development—establishing 
a cross-functional team that involves senior management, governance 
boards, key stakeholders, and distinct Agile roles. In addition, VA 
made progress toward demonstrating three other Agile practices—
focusing on business priorities, delivering functionality in short 
increments, and inspecting and adapting the project as appropriate. 
Specifically, to ensure business priorities are a focus, VA 
established a vision that captures the project purpose and goals and 
established a plan to maintain requirements traceability. To aid in 
delivering functionality, the department established an incremental 
testing approach. It also used an oversight tool, which was intended 
to allow the project to be inspected and adapted by management. 
However, VA could make further improvements to these practices. In 
this regard, it did not (1) establish metrics for the goals or 
prioritize project constraints; (2) always maintain traceability 
between legislation, policy, business rules, and test cases; (3) 
establish criteria for work that was considered “done” at all levels 
of the project; (4) provide for quality unit and functional testing 
during the second release, as GAO found that 10 of the 20 segments of 
system functionality were inadequate; and (5) implement an oversight 
tool that depicted the rate of the work completed and the changes to 
project scope over time. Until VA improves these areas, management 
will lack the visibility it needs to clearly communicate progress and 
unresolved issues in its development processes may not allow VA to 
maximize the benefits of the system. 

What GAO Recommends: 

To help guide the full development and implementation of the long-term 
solution, GAO is recommending that VA take five actions to improve its 
development process for its new education benefits system. VA 
concurred with three of GAO’s five recommendations and provided 
details on planned actions, but did not concur with the remaining two. 

View [hyperlink, http://www.gao.gov/products/GAO-11-115] or key 
components. For more information, contact Valerie C. Melvin at (202) 
512-6304 or melvinv@gao.gov. 

[End of section] 

Contents: 

Letter: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Briefing for Staff Members of the Subcommittee on Economic 
Opportunity, Committee on Veterans' Affairs, House of Representatives: 

Appendix II: Comments from the Department of Veterans Affairs: 

Appendix III: Comments from the Veterans Affairs' Assistant Secretary 
for Information and Technology: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Abbreviations: 

IT: information technology: 

OI&T: Office of Information and Technology: 

PMAS: Project Management Accountability System: 

SPAWAR: Space and Naval Warfare Systems Center--Atlantic: 

VA: Department of Veterans Affairs: 

VBA: Veterans Benefits Administration: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

December 1, 2010: 

The Honorable Bob Filner: 
Chairman: 
The Honorable Steve Buyer: 
Ranking Member: 
Committee on Veterans' Affairs: 
House of Representatives: 

In June 2008, Congress passed the Post-9/11 Veterans Educational 
Assistance Act of 2008[Footnote 1] (commonly referred to as the Post-
9/11 GI Bill or Chapter 33). This act amended Title 38 United States 
Code to include Chapter 33, which provides educational assistance for 
veterans and members of the armed forces who served on or after 
September 11, 2001. The Department of Veterans Affairs (VA) is 
responsible for processing claims for the Chapter 33 education 
benefit, which is a three-part benefit--tuition and fee payments, 
housing allowance, and book stipend. 

In considering its implementation of the legislation, the department 
concluded that it did not have a system capable of calculating the new 
benefit. As a result, the department undertook an initiative to 
modernize its education benefits processing capabilities. This 
initiative involved an interim solution that augmented existing 
processes by providing temporary applications to manually collect data 
and a long-term solution to deliver automated processing capabilities. 
The department intended to complete enough of the system functionality 
in the long-term solution to replace the interim solution by June 
2010, and to include additional capabilities, such as interfaces to 
legacy systems,[Footnote 2] to provide a fully automated end-to-end 
system to support the delivery of education benefits by December 2010. 

To develop the system for its long-term solution, VA is relying on 
contractor assistance and is using an incremental development 
approach, called Agile software development,[Footnote 3] which is to 
deliver software functionality in short increments before the system 
is fully deployed. Agile software development stresses the use of key 
practices such as working as one team to define business priorities 
and, based on those priorities, delivering work in short increments. 
Each increment of work is inspected by the team and the project's 
plans and priorities are adapted accordingly. 

Given the importance of delivering education benefits to veterans and 
their families, we were asked to review the long-term solution to: 

* determine the status of VA's development and implementation of its 
information technology (IT) system to support the implementation of 
education benefits identified in the Post-9/11 GI Bill, and: 

* evaluate the department's effectiveness in managing its IT project 
for this initiative. 

As agreed with your offices, on September 13, 2010, we provided 
briefing slides that outlined the results of our study to staff of 
your Subcommittee on Economic Opportunity. The purpose of this report 
is to provide the published briefing slides to you and to officially 
transmit our recommendations to the Secretary of Veterans Affairs. The 
slides, which discuss our scope and methodology, are included in 
appendix I. 

We conducted our work in support of this performance audit at the 
Department of Veterans Affairs headquarters in Washington, D.C., and 
at a contractor's facility in Chantilly, Virginia, from November 2009 
to December 2010 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

In summary, our study highlighted the following: 

* VA has made important progress in developing and implementing the 
first two of four releases of software planned for its new education 
benefits processing system as scheduled, with these deployments 
occurring on March 31, 2010, and June 30, 2010. In doing so, the 
department provided its regional processing offices with key automated 
capabilities to prepare original and amended benefit claims. It also 
responded to legislative changes and provided for housing rate 
adjustments. While VA did not previously estimate cost for these 
releases and, as such, could not track estimated to actual costs, it 
reported that about $84.6 million had been obligated through July 
2010. The department noted that its Agile process allowed the 
flexibility to adapt to legislative changes and provide functionality 
according to business priorities. 

However, VA did not ensure that certain critical tasks were completed 
that were initially expected to be included in the second release by 
June 30, 2010. Specifically, the department did not complete the 
conversion of data from systems in the interim solution to the systems 
developed for the long-term solution because it was found to be more 
complex than the department had anticipated. The department also did 
not complete the development of interfaces between the new system and 
legacy systems. Program officials stated that data conversion was 
included along with housing rate adjustments in a sub-release that was 
later deployed on August 23, 2010. Because of these delays, VA planned 
to reprioritize what functionality would be developed in its third 
release by September 30, 2010. For its fourth release, it intends to 
reduce its planned functionality of providing full self-service 
capabilities to veterans by December 31, 2010. The department intends 
to provide this capability after its fourth release or under a 
separate initiative. As such, VA estimates that the total system 
development actual and planned obligations through 2011 will be about 
$207.1 million.[Footnote 4] 

* VA has demonstrated key Agile practices that are essential to 
effectively managing its system development, but certain practices can 
be improved. Specifically, the department ensured that teams 
represented key stakeholders and that distinct Agile roles were 
fulfilled. For example, the teams consisted of subject matter experts, 
programmers, testers, analysts, engineers, architects, and designers. 
The department also made progress toward demonstrating the three other 
Agile practices--focusing on business priorities, delivering 
functionality in short increments, and inspecting and adapting the 
project as appropriate. However, VA can improve its effectiveness in 
these areas. 

* Business priorities. To ensure business priorities are a focus, a 
project starts with a vision that contains, among other things, a 
purpose, goals, metrics, and constraints. In addition, it should be 
traceable to requirements. VA established a vision that captured the 
project purpose and goals; however, it had not established metrics for 
the project's goals or prioritized project constraints. Department 
officials stated that project documentation is evolving and they 
intend to improve their processes based on lessons learned; however, 
until it identifies metrics and constraints, the department will not 
have the means to compare the projected performance and actual results 
of this goal. VA had also established a plan that identified how to 
maintain requirements traceability within an Agile environment; 
however, the traceability between legislation, policy, business rules, 
and test cases was not always maintained. VA stated that its 
requirements tool did not previously have the capability to perform 
this function but now provides this traceability to test cases. 
Nonetheless, if the department does not ensure that requirements are 
traceable to legislation, policies, and business rules, it has limited 
assurance that the requirements will be fully met. 

* Deliver functionality in short increments. To aid in delivering 
functionality in short increments, defining what constitutes completed 
work (work that is "done") and testing functionality is critical. 
[Footnote 5] However, VA had not established criteria for work that 
was considered "done" at all levels of the project. Program officials 
stated that each development team had its own definition of "done" and 
agreed that they needed to provide a standard definition across all 
teams. If VA does not mutually agree upon a definition of "done" at 
each level, confusion about what constitutes completed work can lead 
to inconsistent quality and it may not be able to clearly communicate 
how much work remains. In addition, while the department had 
established an incremental testing approach, the quality of unit and 
functional testing performed during Release 2 was inadequate in 10 of 
the 20 segments of system functionality we reviewed. Program officials 
stated that they placed higher priority on user acceptance testing at 
the end of a release and relied on users to identify defects that were 
not detected during unit and functional testing. Until the department 
improves testing quality, it risks deploying future releases that 
contain defects which may require rework. 

* Inspect and adapt. In order for projects to be effectively inspected 
and adapted, management must have tools to provide effective 
oversight. For Agile development, progress and the amount of work 
remaining can be reflected in a burn-down chart, which depicts how 
factors such as the rate at which work is completed (velocity) and 
changes in overall product scope affect the project over time. While 
VA had an oversight tool that showed the percentage of work completed 
to reflect project status at the end of each iteration, it did not 
depict the velocity of the work completed and the changes to scope 
over time. Program officials stated that their current reporting did 
not show the changes in project scope because their focus was on 
metrics that are forward looking rather than showing past statistics 
for historical comparison. However, without this level of visibility 
in its reporting, management may not have all the information it needs 
to fully understand project status. 

Conclusions: 

VA deployed the first two of four releases of its long-term system 
solution by its planned dates, therefore providing improved claims- 
processing functionality to all regional processing offices, such as 
the ability to calculate original and amended benefit claims. In 
addition, the Agile process allowed the department the flexibility to 
accommodate legislative changes and provide functionality according to 
business priorities, such as housing rate adjustments. However, key 
features of the solution were not completed as intended in the second 
release because the department found some functionality to be more 
complex than anticipated. Specifically, interfaces to legacy systems 
and the conversion of data from systems in the interim solution were 
not completed as intended in the second release. Due to these delays, 
VA planned to reprioritize what functionality would be included in its 
third release. Also, for its fourth release, the department had 
reduced a significant planned functionality--veteran self-service 
capability. While VA intends to provide this capability after the 
fourth release within the long-term system solution or under a 
separate initiative, it is unclear what functionality will be 
delivered in the remaining two releases when it deploys the system in 
December 2010. 

In using an Agile approach for this initiative, VA is applying lessons 
learned and has taken important first steps to effectively manage the 
IT project by establishing a cross-functional team that involves 
senior management, governance boards, and key stakeholders. However, 
the department had not ensured that several key Agile practices were 
performed. Measurable goals were not developed and the project 
progressed without bidirectional traceability in its requirements. 
Additionally, in developing the system, VA did not establish a common 
standard and consistent definition for work to be considered "done" or 
develop oversight tools to clearly communicate velocity and the 
changes to project scope over time. Testing deficiencies further 
hindered VA's assurances that all critical system defects would be 
identified. Until VA improves these areas, management does not have 
the visibility it needs to clearly communicate progress to 
stakeholders and estimate when future system capabilities will be 
delivered. Additionally, reduced visibility and unresolved issues in 
its development processes may result in the department continuing to 
remove functionality that was expected in future releases, thus 
delivering a system that does not fully and effectively support the 
implementation of education benefits as identified in the Post-9/11 GI 
Bill. 

Recommendations for Executive Action: 

To help guide the full development and implementation of the Chapter 
33 long-term solution, we recommend that the Secretary of Veterans 
Affairs direct the Under Secretary for Benefits to take the following 
five actions: 

* establish performance measures for goals and identify constraints to 
provide better clarity in the vision and expectations of the project; 

* establish bidirectional traceability between requirements and 
legislation, policies, and business rules to provide assurance that 
the system will be developed as expected; 

* define the conditions that must be present to consider work "done" 
in adherence with agency policy and guidance; 

* implement an oversight tool to clearly communicate velocity and the 
changes to project scope over time; and: 

* improve the adequacy of the unit and functional testing processes to 
reduce the amount of system rework. 

Agency Comments and Our Evaluation: 

We received written comments on a draft of this report from the 
Secretary of Veterans Affairs and VA's Assistant Secretary for 
Information and Technology. In the Secretary's comments, reproduced in 
appendix II, VA concurred with three of our recommendations and did 
not concur with two recommendations. Specifically, the department 
concurred with our recommendation to establish performance measures 
for goals and identify constraints to provide better clarity in the 
vision and expectations of the project. VA noted that it plans to 
develop performance measures consistent with automating the Post-9/11 
GI Bill by March 2011. While this is a positive step, as we noted, it 
is also important that the department identify any project or business 
constraints to better clarify the vision and expectations of the 
system. VA also concurred with our recommendation that it establish 
bidirectional traceability between requirements and legislation, 
policies, and business rules to provide assurance that the system will 
be developed as expected. The department stated that it plans to 
establish traceability between its business rules for the long-term 
solution and the legislation by June 2011. Additionally, VA concurred 
with our recommendation to define the conditions that must be present 
to consider work "done" in adherence with department policy and 
guidance. VA noted that the initiative's fiscal year 2011 operating 
plan outlines these conditions at the project level and that it 
intends to clarify the definition at the working group level by 
December 2010. 

VA did not concur with our recommendation that it implement an 
oversight tool to clearly communicate velocity and the changes to 
project scope over time. The department indicated that development 
metrics and models had already been established and implemented to 
forecast and measure development velocity. In this regard, as our 
briefing noted, department officials stated that they previously 
reported project-level metrics during the first release, and based on 
lessons learned, decided to shift to reporting metrics at the 
development team level. While it is important that VA established the 
capability to track team-level metrics, it is also important to track 
and clearly report how changes to the system development at the team 
level affect the overall project-level scope over time. Specifically, 
without the overall velocity--a key mechanism under the Agile 
methodology--VA does not have the information to understand the 
expected effort to complete the total scope of work and the associated 
length of time to do so. The overall velocity provides an 
understanding of the complexity and difficulty in accomplishing tasks 
and provides VA management with information to better understand 
project risks. This visibility is a key concept of the Agile 
methodology that VA has chosen to implement for this project. Without 
this level of visibility in its reporting, management and the 
development teams may not have all the information they need to fully 
understand project status and generate the discussion and feedback 
necessary for continuous process improvement. Therefore, we continue 
to believe that our recommendation for VA to clearly communicate 
velocity and project scope changes can only strengthen the 
department's development process to be more in line with Agile system 
development practices. 

VA also did not concur with our recommendation to improve the adequacy 
of the unit and functional testing processes to reduce the amount of 
system rework. While the department noted that its testing approach is 
compatible with Agile development, it also acknowledged in other 
technical comments the department provided that there were instances 
of inconsistencies of user stories for capabilities being marked 
"done" and the user stories we reviewed during the second release 
showed significant weaknesses in the quality of testing performed. 
While we agree that VA's testing approach is consistent with Agile 
methodology, these weaknesses we identified demonstrate ineffective 
testing and the need for a consistent and agreed-upon definition of 
"done." Further, the program officials noted that their approach 
focused on users identifying defects at the end of the release, which, 
as we have noted, can be problematic because it is difficult for users 
to remember all the items and parameters needed for 
functionality.[Footnote 6] Without increased focus on the quality of 
testing early in the development process, VA risks delaying 
functionality and/or deploying functionality with unknown defects that 
could require future rework that may be costly and ultimately impede 
the claims examiners' ability to process claims efficiently. 
Therefore, we continue to believe that our recommendation to improve 
the adequacy of unit and functional testing is needed to improve the 
effectiveness of VA's process called for in the Agile methodology. 
This would provide stakeholders greater assurance that functionality 
developed during each iteration is of releasable quality before it is 
presented to users as completed work in accordance with Agile system 
development practices. 

In addition, VA provided other technical comments on a draft of this 
report. In the comments, the department provided additional 
clarification on why there were delays to functionality and how they 
affected the release schedule. Specifically, the department stated 
that the governance structure it established for the initiative 
provided the necessary management, support, and prioritization of 
development efforts to balance desired functionality within the 
development challenges and constraints. The department noted that, 
among other things, delays in the first two releases were a result of 
additional functionality prioritized and developed, such as housing 
rate adjustments and the ability to automatically generate letters for 
veterans as well as unanticipated challenges, such as the complexity 
of data conversion tasks. Further, it noted that decisions and 
prioritizations were primarily made to minimize impact on field 
offices and to support fall enrollment and that they impacted the 
development capacity to support the capabilities that could be 
developed in the third release. VA also offered other technical 
comments which were incorporated as appropriate. 

Beyond the department's comments on our recommendations, the Assistant 
Secretary for Information and Technology provided additional written 
comments, reproduced in appendix III, which noted concerns with our 
draft report. In these comments, the Assistant Secretary stated that 
the department believes we fell short of meeting the objectives for 
this report by omitting key facts and presenting an unnecessarily 
negative view of VA's status and effectiveness to Congress. In 
particular, the Assistant Secretary stated that VA had successfully 
converted all processing of new Post-9/11 GI Bill claims to the long- 
term solution prior to the commencement of the fall 2010 enrollment 
process and that processing with the new system has been nearly 
flawless. He added that Veterans Business Administration claims 
processors like the new system and find it easy and effective to use. 
We are encouraged to hear that the department is experiencing positive 
results from the system development efforts that have been 
accomplished. However, as noted in our briefing, system functionality 
that was envisioned to (1) provide self-service capabilities to 
veterans and (2) end-to-end processing of benefits by December 2010 
was deferred. Further, as the vision for its new education benefits 
system evolves, it is essential that the department documents these 
changes to ensure that its expectations and goals for the system are 
measurable and aligned at all levels. 

In addition, the Assistant Secretary stated that limited exposure to 
the Agile methodology possibly caused us to present incorrect 
assumptions as facts, such as our evaluation of the department's 
testing. Our audit team, which included a trained ScrumMaster, 
examined the department's use of Agile Scrum practices against 
documented and accepted methodologies and consulted with an expert in 
the field that is not only a ScrumMaster, but also an Agile Scrum 
trainer that has extensive experience in evaluating Agile system 
development projects. At the initiation of our study, we discussed our 
evaluation approach with program officials and throughout the study, 
held meetings with them to ensure our full understanding of the 
department's requirements and testing processes. We did not take issue 
with the Agile testing approach used by VA. However, we found 
deficiencies in testing. Further, we presented the results of our 
observations to program officials in June 2010, at which time they did 
not express any such concerns, or otherwise comment on our evaluation 
of the testing. Further, given the evolving nature of Agile system 
development, it is important to ensure that work that is presented as 
"done" and demonstrated to the users at the end of an iteration has 
undergone adequate testing to prevent inaccurate information from 
being provided. In addition to weaknesses we identified in the testing 
of select user stories, the department identified a number of defects 
during the development of the second release. In our view, VA has an 
opportunity to improve the adequacy of its unit and functional testing 
which occurs during each iteration to help identify and resolve any 
defects before any related functionality is presented to users as 
completed work at the end of the iteration. As we noted, the 
department agreed that they needed to clarify their definition of 
"done" and ensure it is being applied consistently. As such, the 
definition often includes fully tested functionality that has no 
defects. During our review, we observed on multiple occasions work 
being presented as "done" without having completed all testing. 
Improved testing up front can reduce the amount of defects found later 
in user acceptance testing and production that would require more 
costly rework. 

Further, the Assistant Secretary stated that the department believes 
that we missed a substantial opportunity to positively influence real 
change by not focusing on the fact that VA had adopted the Agile 
methodology after many failings with other IT systems development 
efforts that used waterfall development methodologies. We agree that 
VA has taken an important step toward improving its development 
capability and that it has developed significant segments of its new 
education benefits system with its new methodology. However, as we 
noted in our briefing, the department had not fully established 
metrics for its goals, which are essential to fully gauge its progress 
beyond past initiatives. 

While we believe that VA has made substantial progress in implementing 
a new process to develop its system, we stand by our position that 
there is still an opportunity for the department to improve its new 
development process in accordance with our recommendations. Doing so 
would further increase the likelihood that VA fully develops and 
delivers the end-to-end benefits processing capabilities envisioned to 
support the Post-9/11 GI Bill and the needs of veterans. 

We are sending copies of this report to appropriate congressional 
committees, the Secretary of Veterans Affairs, and other interested 
parties. In addition, the report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have questions about this report, please contact 
me at (202) 512-6304 or melvinv@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix IV. 

Signed by: 

Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 

[End of section] 

Appendix I: Briefing for Staff Members of the Subcommittee on Economic 
Opportunity, Committee on Veterans' Affairs, House of Representatives: 

Information Technology: Veterans Affairs Can Improve Its Development 
Process for Its New Education Benefits System: 

Briefing for Staff Members of the Subcommittee on Economic Opportunity 
Committee on Veterans' Affairs: 
House of Representatives: 

September 13, 2010: 

Table of Contents: 
Introduction; 
Objectives; 
Scope and Methodology; 
Results in Brief; 
Background; 
Status of Development Efforts; 
VA's Effectiveness in Managing Its New System; 
Conclusions; 
Recommendations for Executive Action; 
Agency Comments and Our Evaluation; 
Attachment I; 
Attachment II; 
Attachment III. 

Introduction: 

In June 2008, Congress passed the Post-9/11 Veterans Educational 
Assistance Act of 2008[Footnote 7] (commonly referred to as the Post-
9/11 GI Bill or Chapter 33). This act amended Title 38 United States 
Code to include Chapter 33, which provides educational assistance for 
veterans and members of the armed forces who served on or after 
September 11, 2001. 

The Department of Veterans Affairs (VA) is responsible for processing 
claims for the Chapter 33 education benefit, which is a three-part 
benefit—tuition and fee payments, housing allowance, and book stipend. 
The benefit is determined based upon an individual's aggregate 
qualifying active duty service. 

A key milestone in the Chapter 33 legislation was the requirement that 
VA provide the new educational assistance benefits to service members 
and veterans beginning on August 1, 2009. In considering its 
implementation of the legislation, the department concluded that it 
did not have a system capable of calculating the new benefit. As a 
result, the department undertook an initiative to modernize its 
education benefits processing capabilities. 

VA's initiative to modernize its education benefits processing 
involved interim and longterm solutions to deliver new processing 
capabilities. According to the department, the interim solution was 
intended to augment existing processes by providing temporary 
applications and tools, such as a spreadsheet that aided claims 
examiners in manually collecting data from VA legacy systems and to 
calculate the new benefits.[Footnote 8] 

At the same time that it began the interim solution, the department 
also initiated a longterm solution that was intended to fully automate 
the manual processes for calculating education benefits for service 
members and veterans. Specifically, the long-term solution was 
intended to provide a system to replace the interim solution as well 
as provide automated interfaces with existing legacy systems. The 
department intended to complete enough of the functionality in the 
long-term solution to replace the interim solution by June 2010, and 
to include additional capabilities for full deployment of the new 
education benefits system by December 2010. 

To develop the system for its long-term solution, VA is relying on 
contractor assistance and is using an incremental development 
approach, called Agile software development,[Footnote 9] which is to 
deliver software functionality in short increments before the system 
is fully deployed. Agile software development has key practices such 
as working as one team. This one team is to define business priorities 
and, based on those priorities, deliver work in short increments. Each 
increment of work is inspected by the team and the project's plans and 
priorities are adapted accordingly. 

Historically, VA has experienced significant IT development and 
delivery difficulties. In the spring of 2009, the department reviewed 
its inventory of IT projects and identified ones that exhibited 
serious problems with schedule slippages and cost overruns. The 
department noted that an incremental approach, such as Agile software 
development, was considered to be an effective way to support the long-
term system solution development. 

Given the importance of delivering education benefits to veterans and 
their families, we were asked to review the long-term solution to: 

* determine the status of VA's development and implementation of its 
information technology (IT) system to support the implementation of 
education benefits identified in the Post-9/11 GI Bill and; 

* evaluate the agency's effectiveness in managing its IT project for 
this initiative. 

[End of section] 

Scope and Methodology: 

To determine the status of VA's development and implementation of IT 
system to support the implementation of education benefits identified 
in the Post-9/11 GI Bill, we: 

* reviewed VA and contractor plans for system development, observed 
project status meetings, and compared the actual status of development 
and implementation to the planned status, and; 

* discussed the department's plans and implementation with VA and 
contractor officials to determine the functionality completed and 
demonstrated. 

To evaluate VA's effectiveness in managing its IT project for this 
initiative, we: 

* reviewed current Agile literature and interviewed experts in the 
field to identify key Agile practices applicable to the department's 
project; 

* evaluated and compared the department's IT project management 
practices to industry standards, best practices, and disciplined 
processes, such as Agile software development, and applicable federal 
laws,[Footnote 10] policies, and guidance;[Footnote 11] 

* analyzed requirements and testing artifacts for 20 segments of 
system features developed to determine the traceability of 
requirements and testing coverage; 

* observed key agency and contractor development meetings such as 
daily discussions, bi-weekly software reviews and planning meetings, 
where management decisions were made and Agile practices were 
demonstrated; and; 

* interviewed department and contractor officials about the management 
and oversight of requirements, testing, and transition plans. 

The information on cost estimates and costs that were incurred for 
long-term solution development were provided by VA officials. We did 
not audit the reported costs and thus cannot attest to their accuracy 
or completeness. 

We conducted this performance audit at the Department of Veterans 
Affairs headquarters in Washington, D.C., and at a contractor facility 
in Chantilly, Virginia, from November 2009 to September 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Results in Brief: 

VA has developed and implemented the first two of four releases of 
software planned for its new education benefits processing system as 
scheduled, with these deployments occurring on March 31, 2010, and 
June 30, 2010. In doing so, VA provided its regional processing 
offices with key automated capabilities to prepare original and 
amended benefit claims. In addition, VA responded to legislative 
changes and provided for housing rate adjustments. While VA did not 
previously estimate costs for these releases and, as such, could not 
track estimated to actual costs, it has reported that about $84.6 
million has been obligated through July 2010. The department noted 
that its Agile process allowed the flexibility to adapt to legislative 
changes and provide functionality according to business priorities. 
However, VA did not ensure that certain critical tasks were performed 
that were expected to be part of the second release. Specifically, it 
did not complete the conversion of data from systems in the interim 
solution to the systems developed for the long-term solution and did 
not complete the development of interfaces between the new system and 
legacy systems.[Footnote 12] 

Further, because of these delays, VA is in the process of determining 
and prioritizing what functionality will be developed in its third 
release by September 30, 2010. For its fourth release, it intends to 
reduce its planned functionality of providing full self-service 
capabilities to veterans by December 31, 2010. However, VA intends to 
provide this capability after its fourth release or under a separate 
initiative. As such, VA estimates that the total system development 
actual and planned obligations through 2011 will be about $207.1 
million.[Footnote 13] 

VA has demonstrated key Agile practices that are essential to 
effectively managing its system development, but certain practices can 
be improved. Specifically, the department has ensured that teams 
represent key stakeholders and that specific Agile roles were 
fulfilled. For example, the teams consist of subject matter experts, 
programmers, testers, analysts, engineers, architects, and designers. 
The department has also made progress toward demonstrating the three 
other Agile practices—focusing on business priorities, delivering 
functionality in short increments, and inspecting and adapting the 
project as appropriate. However, VA can improve its effectiveness in 
these areas. Specifically: 

* To ensure business priorities are a focus, a project starts with a 
vision that contains, among other things, purpose, goals, metrics, and 
constraints. In addition, it should be traceable to requirements. VA 
has established a vision that captures the project purpose and goals; 
however, it has not established metrics for the project's goals or 
prioritized project constraints. VA officials stated that project 
documentation is evolving and they intend to improve their processes 
based on lessons learned; however, until it identifies metrics and 
constraints, the department will not have the means to compare the 
projected performance and actual results of this goal. VA has
also established a plan that identifies how to maintain requirements 
traceability within an Agile environment; however, the traceability 
between legislation, policy, business rules, and test cases was not 
always maintained. VA stated its requirements tool did not previously 
have the capability to perform this function and now provides this 
traceability to test cases. Nonetheless, if VA does not ensure that 
requirements are traceable to legislation, policies, and business 
rules, it has limited assurance that the requirements will be fully 
met. 

* To aid in delivering functionality in short increments, defining 
what constitutes completed work (work that is "done") and testing 
functionality is critical.[Footnote 14] However, VA has not yet 
established criteria for work that is considered "done" at all levels 
of the project. Program officials stated that each development team 
has its own definition of "done" and agreed that they need to provide 
a standard definition across all teams. If VA does not mutually agree 
upon a definition of "done" at each level, confusion about what 
constitutes completed work can lead to inconsistent quality and it may 
not be able to clearly communicate how much work remains. In addition, 
while the department has established an incremental testing approach, 
the quality of unit and functional testing performed during Release 2 
was inadequate in 10 of the 20 segments of system functionality we 
reviewed. Program officials stated that they placed higher priority on 
user acceptance testing at the end of a release and relied on users to 
identify defects that were not detected during unit and functional 
testing. Until the department improves testing quality, it risks 
deploying future releases that contain defects which may require 
rework. 

* In order for projects to be effectively inspected and adapted, 
management must have tools to provide effective oversight. For Agile 
development, progress and the amount of work remaining can be 
reflected in a burn-down chart, which depicts how factors such as the 
rate at which work is completed (velocity) and changes in overall 
product scope affect the project over time. While VA has an oversight 
tool that shows the percentage of work completed to reflect project 
status at the end of each iteration, it does not depict the velocity 
of the work completed and the changes to scope over time. Program 
officials stated that their current reporting does not show
the changes in project scope because their focus is on metrics that 
are forward looking rather than showing past statistics for historical 
comparison. However, without this level of visibility in its 
reporting, management may not have all the information it needs to 
fully understand project status. 

To help ensure successful implementation of the Chapter 33 initiative, 
we are recommending that VA establish performance measures for goals 
and identify constraints; establish traceability between requirements 
and legislation, policies, and business rules; define the conditions 
that must be present to consider work "done;" review and improve the 
unit and functional testing processes; and implement an oversight tool 
to clearly communicate velocity and the changes to project scope over 
time. 

We received oral comments on a draft of this briefing from VA 
officials, including the Deputy Assistant Secretary for Congressional 
and Legislative Affairs and the Assistant Secretary for Information 
and Technology. In their comments, the officials stated that the 
department was not in a position to concur or not concur with our 
recommendations, but planned to provide formal comments on our final 
report. The officials also provided technical comments, which we have 
incorporated in the briefing as appropriate. 

[End of section] 

Background: 

In recognition of their service to our country, VA provides medical 
care, benefits, social support, and lasting memorials to veterans, 
service members, and their families. VA is the second largest federal 
department with more than 270,000 employees. In fiscal year 2009, the 
department reported incurring more than $100 billion in obligations 
for its overall operations. 

The Veterans Benefits Administration (VBA), one of VA's three line 
administrations,[Footnote 15] provides assistance and benefits, such 
as educational assistance, through four veterans' regional processing 
offices.[Footnote 16] In 2009, the department reported that it 
provided more than $3.5 billion in educational assistance benefits to 
approximately 560,000 individuals. In 2011, it expects the number of 
all education claims to grow by 32 percent over 2009, increasing from 
1.7 million to 2.25 million. 

Prior to the passage of the Post-9/11 GI Bill, VA delivered education 
benefits by relying on a combination of manual processes and legacy IT 
systems. However, the department concluded that the educational 
assistance required by the statute would be complex to calculate and 
would involve a multitude of factors, such as the beneficiary's length 
of service, the type of education being pursued, and the geographic 
location of the academic institution. Accordingly, the department 
determined its legacy systems were insufficient to support the demands 
for processing the new benefit. 

In October 2008, VA established its Chapter 33 initiative to develop 
the capability to process the new education benefit. The initiative 
involved both an interim and long-term solution: 

* The interim solution, deployed in November 2009, provided 
applications and tools, such as a spreadsheet that aided claims 
examiners in manually collecting data from VA legacy systems to 
calculate the new education benefit. 

* The long-term solution was expected to be complete enough to replace 
the interim solution by June 2010 and to include additional 
capabilities to provide a fully automated end-to-end system to support 
the delivery of education benefits by December 2010. 

Among other features, by December 2010, the new education benefits 
system was to: 

* modernize processing of new Chapter 33 awards and amended existing 
Chapter 33 claims, to include automated calculations of benefits, such 
as tuition and fee payments, housing allowance, and book stipends; 

* increase claims processing efficiency to all regional offices, such 
as providing capability to automatically access veteran demographic 
and service data; 

* interface with VA's existing legacy systems that contain information 
required to calculate benefits, such as a financial payment system; 
and; 

* create veteran self-service capabilities such as the capability to 
estimate and apply for benefits online. 

To oversee the development and implementation of the new education 
benefits system, VA has formed a governance structure that includes 
executive level management from VBA and the department's Office of 
Information and Technology (OI&T). The VBA Under Secretary of Benefits 
has primary responsibility for coordinating the Chapter 33 initiative. 
For example, the Under Secretary ensures collaboration for the 
effective management and coordination of VA resources in support of 
the Chapter 33 implementation. 

To develop and implement the long-term solution, VA's OI&T entered 
into an interagency agreement with the Department of Defense's Space 
and Naval Warfare Systems Center—Atlantic (SPAWAR) to develop the long-
term solution. SPAWAR is managing multiple contractors[Footnote 17] to 
develop the system and is providing technical, information assurance, 
and program management services. SPAWAR is also providing operational 
services and engineering, planning, and analysis to support 
application development. VA and SPAWAR work together to manage and 
develop the system. Specifically, VBA subject matter experts and OI&T 
technical representatives are part of the system development teams. 

Chapter 33 Implementation Approach: 
		
To develop and implement the new system, VA also is following its 
Project Management Accountability System (PMAS)[Footnote 18] framework 
which was established in June 2009. PMAS requires that the 
department's IT projects adopt an iterative release schedule in which 
system features are delivered within firm, 6-month (or less) cycles. 
Consistent with the framework, the department established four release 
dates for the Chapter 33 long-term solution. Each release was to 
deploy incremental capabilities that would expand upon previously 
developed functionality. 

The following table shows VA's planned schedule for deploying the four 
releases and the associated functionality. 

Release: 1; 
Planned deployment date: March 31, 2010; 
Planned functionality: Provide improved claims-processing 
functionality, such as the ability to calculate new original awards, 
amend awards, and convert beneficiary data from systems supporting the 
interim solution to the new system. To be deployed to a limited number 
of claims examiners in the regional processing offices. 

Release: 2; 
Planned deployment date: June 30, 2010; 
Planned functionality: Increase automation and efficiency to all 
regional processing offices, as well as develop interlaces to legacy 
systems (excluding the financial system). 

Release: 3; 
Planned deployment date: September 30, 2010; 
Planned functionality: Develop an interlace between the new system and 
the department's legacy
financial system. 

Release: 4; 
Planned deployment date: December 31, 2010; 
Planned functionality: Provide other end user features to further 
improve processing efficiencies, such as self-service functionality 
aimed at improving the veteran's experience. 

Source: VA. 

[End of table] 

While VA did not originally estimate the total cost to implement the 
long-term solution, nor estimate its cost by release, as of July 2010, 
program officials reported actual and planned obligations of 
approximately $207.1 million through fiscal year 2011.[Footnote 19] 
	
To develop and implement the long-term solution according to the 
planned release schedule, VA is using an Agile software development 
approach, which places an emphasis on collaboration between developers 
and stakeholders and produces a system in an iterative and incremental 
fashion. Agile software development is recognized as having 
fundamental differences from traditional methods.[Footnote 20] For 
example, it is an iterative process in which each output (which can 
range between 1 and 8 weeks in duration) provides a segment of system 
functionality that is developed, tested, and demonstrated to users so 
that early feedback can be considered. A segment of functionality 
could be a computer screen to display the amount a beneficiary would 
be entitled to. However, with a traditional approach, the complete 
product is often delivered at the end of the development phase of the 
system lifecycle and is not performed in short iterative segments. 

Although iterative and incremental development approaches have been 
used for many years,[Footnote 21] the Agile movement officially began 
in February 2001 with the creation of the Agile Manifesto.[Footnote 
22] According to current Agile literature,[Footnote 23] an Agile 
approach emphasizes the following four key practices: 

Work as one team. In Agile development, project participants view 
themselves as one team aimed at a common goal. However, while the 
participants should work together as one whole team, there are 
specific roles on the team. 

* Product owner. The product owner's primary duties include making 
sure that all team members are pursuing a common vision for the 
project, establishing priorities so the highest-valued functionality 
is always being worked on, and making decisions that lead to a good 
return on investment. 

* Team member. The team member's role often includes programmers, 
testers, analysts, database engineers, usability experts, technical 
writers, architects, and designers. The team members are responsible 
for developing high-quality functionality as prioritized by the 
product owner. 

* Project manager. The project manager focuses more on leadership than 
on management and is a facilitator for the team working together. In 
addition, he or she is responsible for removing project obstacles that 
may impede the team's performance. 

Additionally, best practices state that it is essential for a systems 
development team to have involvement from other stakeholders, such as 
executive level management and senior management.[Footnote 24] Such 
involvement helps to minimize project risk by ensuring that key 
requirements are identified and developed, problems or issues are 
resolved, and decisions and commitments are made in a timely manner. 

Focus on business priorities. Agile teams demonstrate customer 
collaboration and commitment to business priorities in two ways. 
First, the product owner prioritizes and determines the order in which 
features will be developed. A release plan is then created that states 
how much work the team can accomplish by a certain date. Second, Agile 
teams focus on completing and delivering user-valued features, usually 
in the form of user stories, which are a way of expressing software 
requirements. A user story is a brief description of functionality as 
viewed by a user or customer of the system. User stories are gathered 
and documented throughout the development process. 

Work to deliver functionality in short iterations. Agile practices 
focus on delivering functionality in short increments as opposed to 
delivering at the end of the development phase of the system 
lifecycle; however, the functionality is based on a product vision, 
which is important for motivating a team and creating a long-term 
connection between those developing the product and those using it. 
Most Agile teams work in iterations of 2 to 4 weeks long, during which 
time a team transforms one or more user stories into coded and tested 
software. All work (for example, analysis, design, coding, and 
testing) is performed concurrently within each iteration. 

During the iteration, each piece of functionality or feature worked on 
should be determined to be of releasable quality, before it is 
presented as completed work. The criteria for making the determination 
is the definition of done. Only work that is completed should be 
presented during a review meeting that takes place at the end of an 
iteration. Because a single iteration does not usually provide 
sufficient time to complete enough new functionality to satisfy user 
or customer desires, a release, which is typically 2 to 6 months and 
is comprised of one or more iterations, identifies a desired set of 
functionality and the projected time frame it will be ready for users 
and customers. 

Inspect and adapt. Agile teams demonstrate the value of responding to 
change by incorporating knowledge gained in the preceding iteration 
and adapting plans accordingly at the start of the next iteration. 
This is intended to facilitate continuous process improvement. For 
example, the accuracy of the release plan may be affected by the 
team's discovery that it has overestimated or underestimated its rate 
of progress in that software development is more time consuming; 
therefore, the release plan should be revisited and updated regularly. 
Further, it may be the case that based on seeing the software from an 
earlier iteration, the product owner learns that users would like to 
see more of one type of feature and that they do not value another 
feature as much as originally planned. The value of the plan could be 
increased in this case by moving more of the desired features into the 
release and postponing some of the lesser-valued features. This 
recognizes that planning is an ongoing process that takes place during 
the entire project in order to deliver a valuable solution to the 
users. 
	
These practices are important to any Agile framework, including the 
one VA has chosen to implement called Scrum.[Footnote 25] Scrum 
emphasizes developing software in increments and producing segments of 
functionality that are tested and demonstrated to users. In addition, 
Scrum teams are interactive and cross-functional in developing these 
segments throughout each iteration. See attachment I for a discussion 
of the specific practices and predefined roles within the Scrum 
framework for managing software development. 

[End of section] 

Objective 1: Status of Development Efforts: 
		
VA Has Delivered Key Automated Capabilities in Its Long-Term Solution, 
but Has Reduced Its Planned Functionality to Accommodate Recent 
Development Delays: 

While VA deployed Release 1 and 2 as scheduled and plans to meet 
Release 3 and 4 scheduled deployment dates of September 30, 2010, and 
December 31, 2010, system functionality was reduced and delayed to 
meet its scheduled release dates. VA reported obligations and 
expenditures for these releases, through July 2010, to be 
approximately $84.6 million—$59.8 million for SPAWAR and contractor 
support and $24.8 million for VA program operations. (For a breakout 
of SPAWAR and VA obligations and expenditures by release, see 
attachment II.) 

VA deployed Release 1 of the long-term solution on March 31, 2010, as 
scheduled, providing a limited set of claims examiners at the four 
regional processing offices the ability to calculate tuition, housing 
allowance, books, stipends, and fees for processing original awards of 
education benefits. However, the release did not provide planned 
functionality to process claims for amended awards or to convert and 
transfer beneficiary data from systems that were part of the interim 
solution to systems for the long-term solution. VA officials stated 
that the processing of amended awards and the data conversion task 
were found to be more complex than they had originally anticipated and 
therefore, the functionality was delayed for completion in Release 2. 

The department subsequently deployed Release 2 on June 30, 2010, as 
scheduled. This release extended the basic award capability to all 
claims examiners at each of the four regional processing offices. 
Department officials noted that the Agile process allowed them the 
flexibility to reprioritize the functionality that would be included 
in the release. As such, the release provided key automated 
capabilities including the ability to generate three different types 
of letters to veterans, to process amended awards, and the capability 
to process benefits for legislative changes, such as Fry 
Scholarships.[Footnote 26] However, the planned development of an 
interface to the legacy systems was not fully completed. For example, 
VA did not fully develop the interface that was intended to automate 
the verification of student enrollment data. 

In addition, despite having delayed the conversion of data from the 
interim solution to the long-term solution until Release 2, this task 
was not completed. As a result, VA created a sub-release, Release 2.1, 
with the intent of completing data conversion and adding selected 
functionality, such as the 2010 housing rate adjustments, by July 26, 
2010; however, program officials stated that Release 2.1 was actually 
deployed on August 23, 2010. With this release, program officials 
stated that approximately 30,000 out of 550,00 records were not 
converted. The officials added that they intend to make a decision in 
mid-September on when and how the remaining records will be converted. 

Further, program officials stated that the department has not yet 
decided how the delay of Release 2.1 will affect the interfaces that 
were to be developed in Release 3, which is still planned to be 
deployed by September 30, 2010. As such, program officials stated that 
they would decide in September how much of the Release 3 functionality 
could be completed by the scheduled date. In addition, they also 
stated that they have reduced functionality of the system and the self-
service capability will not be included as planned in Release 4 when 
it is deployed in December 31, 2010. However, the department plans to 
provide this self-service capability after Release 4 within the long-
term system solution or under a separate initiative. The department is 
in the process of defining what the self-service capability will 
include. 

[End of section] 

Objective 2: VA's Effectiveness in Managing Its New System: 
		
VA Has Established a Team to Support System Development, but 
Management Can Improve Other Key Agile Practices: 

To provide effective management for an Agile project, such as the 
development of the Chapter 33 long-term solution, a key component for 
success is demonstrating effective use of the Agile practices: working 
as one team, focusing on business priorities, delivering functionality 
in short increments, and inspecting and adapting the project as 
appropriate. While VA has taken an important step to effectively 
manage its development of the system for processing Chapter 33 
educational benefits by establishing a cross-functional team, it has 
not yet fully ensured business priorities are a focus, demonstrated 
that it is delivering quality functionality in short increments, or 
provided mechanisms to enable inspection and adaptation of the 
project. As a result, VA does not have the visibility it needs to 
clearly communicate progress to stakeholders and may not be able to 
generate feedback necessary for effectively establishing project 
priorities and continuous process improvements. 
		
VA Has Established a Cross-Functional Team: 

As discussed earlier, Agile practices value the importance of 
organizations developing a cross-functional team that includes all key 
stakeholders. Specific Agile roles such as product owner, team member, 
and project manager should be included in the development. In 
addition, there needs to be involvement from executive level 
management, senior management, and users. Such involvement helps to 
minimize project risk by ensuring that key requirements are identified 
and developed.[Footnote 27] 

VA has established a team of executive level management that fulfills 
the role of the product owner. For example, the team consists 
primarily of executives and senior managers from VBA and the 
department's OI&T, who are members of two decision-making bodies for 
the initiative: the Joint Executive Board and Executive Steering 
Committee. They meet weekly to discuss the vision and make decisions 
on functionality, schedule, and cost issues. VA has also established 
additional workgroups that provide daily leadership, oversight, and 
operations management for the systems development effort and serve as 
extensions of the product owner to identify and prioritize 
requirements. (For detailed information about the responsibilities and 
leadership of the decision-making bodies in the governance structure, 
see attachment III.) 

The department has also established multiple, cross-functional teams 
to develop the system. These teams consist of VA subject matter 
experts as well as contractors that are programmers, testers, 
analysts, database engineers, architects, and designers. These teams 
hold daily Scrum meetings to discuss work that has been planned and 
accomplished, and any impediments to completing the work. At the 
completion of each iteration, which in VA's case is every 2 weeks, a 
review meeting occurs between the cross-functional teams and VA 
stakeholders to review and demonstrate completed system functionality. 
Following this meeting, planning sessions are held to discuss the work 
to be accomplished in the next iteration based on the next highest-
prioritized requirements contained in user stories. 

In addition, VA has identified project managers from both VA and 
SPAWAR that focus on leadership of the initiative. These project 
managers monitor and facilitate meetings and provide clarification to 
contractors, subject matter experts, and other developers. They are 
also responsible for addressing impediments discussed at the review 
meetings. 

With this involvement from key stakeholders, VA has established a team 
structure that fulfills the key roles within an Agile team and has 
better positioned itself to effectively manage the initiative. 

Although VA Has a Vision for Its Business Priorities, Key Elements Are 
Missing: 

Under an Agile methodology, to ensure business priorities are a focus, 
a project starts with a vision of the system that is communicated to 
the team by the product owner. This vision should clearly state the 
purpose and goals of the project; the goals should be measurable; and 
constraints should be identified and prioritized to establish project 
parameters related to scope, cost, and schedule. In addition, well-
defined and managed requirements are a cornerstone of effective system 
development. According to recognized guidance, disciplined processes 
for developing and managing requirements can help reduce the risks of 
developing a system that does not meet user and operational needs. 
[Footnote 28] Such processes include establishing policies and plans 
for managing changes to requirements and maintaining bidirectional 
requirements traceability.[Footnote 29] As such, the project vision 
should be traceable to requirements and functionality developed, which 
is contained in user stories. 
		
VA has established a vision document that captures the project purpose 
and goals. Specifically, the stated purpose of the department's long-
term solution is to develop a system that ensures timely and accurate 
benefit payments to beneficiaries and achieves the following goals: 
maximizes the user experience, provides a flexible architecture to 
support benefit changes, provides an efficient workflow, and provides 
a model and framework that supports code reuse across future VA 
projects. 

However, the department has not established metrics for the project's 
goals, prioritized project constraints, or ensured that requirements 
were fully traceable to legislation, policies, and business rules. 
Specifically, the goals that VA has established do not have metrics 
for determining the progress towards achieving the goals. For example, 
for VA's goal to maximize the user experience, the department has not 
established a quantifiable, numerical target or other measurable value 
to facilitate future assessments of whether the goal was achieved. As 
a result, the department does not have the means to compare the 
projected performance and actual results of this goal. 

Further, the department has not clearly identified and prioritized 
constraints for the project that would impact how decisions affecting 
the scope, cost, and schedule for the system should be made. Although 
its vision document states that VA will identify constraints, it has 
not yet documented them. Without having clearly identified and 
prioritized constraints, stakeholders may not agree or understand what 
factors should drive the decisions and adjustments made in system 
development to achieve the project's goals. 

VA also did not always ensure that requirements for Release 2 were 
traceable. While the department has established a plan that identifies 
the process that the team is to follow to transform requirements into 
user stories and the tools it is to utilize to maintain traceability, 
our review of selected user stories in Release 2 found that 
traceability between legislation, policy, business rules, and test 
cases was not always maintained and, therefore, could not be verified. 
For example, requirements in the 20 user stories we reviewed in 
Release 2 were not traceable to legislation, nor were we able to 
observe how requirements were traceable to all the test cases that 
covered the complete requirement. 
		
With regard to these deficiencies, VA officials stated that project 
documentation is evolving and they intend to improve their processes 
based on lessons learned. However, until the department fully 
establishes goals that are measurable and identifies and prioritizes 
constraints, it may not have the ability to clearly communicate 
progress to stakeholders. 

Further, officials acknowledged that the department's requirement tool 
did not have the capability to fully establish software traceability 
for Release 2, but that VA has since upgraded its tool.[Footnote 30] 
The officials stated the department will be able to provide this level 
of traceability to test cases in future releases. While program 
officials acknowledged the importance of traceability and the need to 
improve their process, they have not identified how the department 
will effectively establish bidirectional traceability between system 
requirements and legislation, policy, and business rules. Until the 
department can effectively ensure that requirements are fully 
traceable to legislation, policies, business rules, and test cases it 
will continue to have a limited ability to reasonably assure that the 
Chapter 33 requirements will be completely met. 

VA Delivers Functionality in Short Iterations, but Needs to Ensure 
Standards Are Defined and Met: 

To ensure that the product is potentially shippable at the end of 
every increment, work should adhere to an agreed-upon definition of 
"done." If the definition is not agreed upon, the quality of work may 
vary and teams may inappropriately consider work as completed, thus 
unreliably reporting progress. Stakeholders should agree to a 
definition of completed work that conforms to an organization's 
standards, conventions, and guidelines. These standards often include 
fully tested functionality that has no defects. Furthermore, we have 
highlighted in our prior work that effective testing is an essential 
component of any system development effort.[Footnote 31] 

While the department has defined some criteria for work that is 
considered "done" at the release level, VA has not defined what it 
means at the user story, iteration, or project level. We observed 
multiple cases during Release 2 development in which user stories were 
presented as "done," but had varying amounts of work completed. For 
example, at three iteration review meetings, we observed at least one 
development team that presented user stories as "done" without having 
completed all testing. 

Program officials stated that each development team has their own 
definition of "done" and agreed that they need to provide a standard 
definition across all teams. If VA does not mutually agree upon and 
document this definition at each level and ensure it conforms to the 
department's standards, conventions, and guidelines, confusion about 
what constitutes completed work could lead to inconsistent quality and 
unreliable performance and progress reporting. Further, in the absence 
of an agreed-upon definition, VA is not able to clearly communicate 
how much work remains for completing the system. 

With regard to testing, VA has established an incremental testing 
approach that calls for automated unit and functional testing to be 
conducted on work completed during iterations.[Footnote 32] In 
addition, it has also established user acceptance testing that is 
performed before a release is delivered. Nonetheless, we found that 
the unit and functional testing performed during Release 2 was 
inadequate. Specifically, in reviewing the testing conducted for 20 
user stories, we identified the testing to be inadequate for 10 of 
them. For these 10 user stories, we identified a total of 19 
deficiencies covering a range of issues. 

For example, 7 user stories were not fully tested for expected values 
or boundary conditions specified in their associated requirements 
documents. These testing deficiencies may hinder VA's ability to 
identify critical defects. VA and contractor system development and 
testing teams subsequently identified a number of defects during 
Release 2. Specifically, program officials stated that 218 of the 423 
defects that were to be corrected in Release 2 were classified as high 
priority.[Footnote 33] For example, user acceptance testing found that 
an award letter included the incorrect date for a student's enrollment 
period. Program officials stated that all of the high-priority defects 
were corrected or closed as invalid and that they are working toward 
correcting the remaining defects in future iterations. 
	
Program officials also stated that they placed higher priority on user 
acceptance testing at the end of a release and relied on users to 
identify defects that were not detected during unit and functional 
testing. However, as we have noted, relying on subject matter experts 
to perform user acceptance testing is not a realistic solution because 
it is difficult for them to remember all the items needed for 
functionality.[Footnote 34] Further, while program officials stated 
that many of the defects were closed before Release 2 was fully 
deployed, due to the inadequate testing the potential exists for a 
significant number of additional defects to be found after deployment, 
thus requiring system rework which can increase costs and affect 
schedule.[Footnote 35] Until the department improves testing quality, 
it risks deploying future releases that contain defects which may 
require rework and extend the completion date for the project. 
Ultimately, this could increase the risk of delayed functionality that 
would impede the ability for claims examiners to process claims 
efficiently. 
	
VA Has Not Fully Implemented Tools to Inspect and Adapt the Project: 

In order for projects to be effectively inspected and adapted, 
management must have tools to provide visibility to communicate 
progress to stakeholders. Under the Scrum framework, project 
visibility is achieved through the use of specific tools. For example, 
progress and the amount of work remaining across the release is 
demonstrated by a burn-down chart. Specifically, a burn-down chart can 
depict how factors such as the rate at which work is completed 
(velocity) and changes in overall product scope affect the project 
over time. This information can be forecasted to estimate how long a 
release will take to complete. Further, when compared to the project 
rate of work completion, the chart can provide visibility into the 
actual project status and can be used for continuous process 
improvement such as increasing the accuracy of estimating story points 
for future user stories. 
	
VA's burn-down chart did not include elements that aided in 
communicating progress. While the department used a burn-down chart in 
Release 2 that showed the percentage of work completed to reflect 
project status at the end of each iteration, this chart did not depict 
the velocity of the work completed and the changes to scope over time. 
[Footnote 36] Program officials stated that their current reporting 
did not show the changes in project scope because their focus was on 
metrics that are forward looking rather than showing past statistics 
for historical comparison. However, such a chart is essential to team 
members' understanding of progress made and provides a continuous 
feedback loop. In addition, it can also provide management visibility 
into the project and changes over time. 

Since the department did not use a burn-down chart to report 
performance over time, management and stakeholders cannot clearly 
discern the actual amount of work completed relative to the amount of 
work that was expected to be completed. Without this level of 
visibility in its reporting, management and the development teams may 
not have all the information they need to fully understand project 
status and generate the discussion and feedback necessary for 
continuous process improvement. 

[End of section] 

Conclusions: 

VA deployed the first two releases of its long-term system solution by 
its planned dates, therefore providing improved claims-processing 
functionality, such as the ability to calculate new original awards in 
Release 1. Additionally, it increased automation to all regional 
processing offices with automated capability to process amended awards 
in Release 2. Critical long-term system solution features were not 
completed because VA reprioritized its work to accommodate for 
legislative changes and because the department found some major 
functions more complex than anticipated. As such, interfaces to legacy 
systems and the conversion of data from systems in the interim 
solution were not completed in Release 2. VA added an additional sub-
release to address this incomplete functionality, but it has not yet 
concluded how these delays will affect the functionality that will be 
developed in Release 3. Also, for Release 4, VA has reduced a 
significant planned functionality—veteran self-service capability. 
While VA intends to provide this capability after Release 4 within the 
long-term system solution or under a separate initiative, it is 
unclear what functionality will be delivered in the remaining 2 
releases when it deploys the system in December 2010. 

In using an Agile approach for this initiative, VA is applying lessons 
learned and has taken important first steps to effectively manage the 
IT project by establishing a cross-functional team that involves 
senior management, governance boards, and key stakeholders. However, 
the department has not yet ensured that several key Agile practices 
were performed. Measurable goals were not developed and the project 
progressed without bidirectional traceability in its requirements. 
Additionally, in developing the system, VA did not establish a common 
standard and consistent definition for work to be considered "done" or 
develop oversight tools to clearly communicate velocity and the 
changes to project scope over time. Testing deficiencies further 
hinder VA's assurances that all critical system defects will be 
identified. Until VA improves these areas, management does not have 
the visibility it needs to clearly communicate progress to 
stakeholders and estimate when future system capabilities will be 
delivered. Additionally, reduced visibility and unresolved issues in 
its development processes may result in the department continuing to 
remove functionality that was expected in future releases, thus 
delivering a system that does not fully and effectively support the 
implementation of education benefits as identified in the Post-9/11 GI 
Bill. 

[End of section] 

Recommendations for Executive Action: 
	
To help guide the development and implementation of the Chapter 33 
long-term solution, we recommend that the Secretary of Veterans 
Affairs direct the Under Secretary for Benefits to take the following 
five actions: 

* establish performance measures for goals and identify constraints to 
provide better clarity in the vision and expectations of the project; 

* establish bidirectional traceability between requirements and 
legislation, policies, and business rules to provide assurance that 
the system will be developed as expected; 

* define the conditions that must be present to consider work "done" 
in adherence with agency policy and guidance; 

* improve the adequacy of the unit and functional testing processes to 
reduce the amount of system rework; and; 

* implement an oversight tool to clearly communicate velocity and the 
changes to project scope over time. 

[End of section] 

Agency Comments and Our Evaluation: 

We received oral comments on a draft of this briefing from VA 
officials, including the Deputy Assistant Secretary for Congressional 
and Legislative Affairs and the Assistant Secretary for Information 
and Technology. In the comments, the Deputy Assistant Secretary stated 
that the department was not in a position to concur or not concur with 
our recommendations but planned to provide formal comments on our 
final report. The officials provided additional clarification on why 
the department experienced delays in data conversion. Specifically, 
they noted that, consistent with Agile practices, the department 
reprioritized work and adapted the system to add selected 
functionality, such as the 2010 housing rate adjustments. They added 
that the Joint Executive Board had made this decision to ensure that 
claims examiners would have the most recent rate to process benefits 
for the fall 2010 enrollment season. Additionally, the department 
recognized lessons learned with the Agile approach, and it intends to 
incorporate them in future development work. The officials provided 
other technical comments, which we have incorporated as appropriate. 

In further comments, the Assistant Secretary for Information and 
Technology emphasized that using Agile system development for this 
initiative allowed the department to provide significant system 
functionality incrementally that had far exceeded its past IT 
initiatives. Specifically, he noted that the project had delivered 
working software close to schedule and had been more successful than 
past system development efforts. 

[End of section] 

Attachment I: Description of the Scrum Framework Being Used by VA: 
		
The Scrum framework is an Agile method that contains sets of practices 
and predefined roles. The following describes the key terminology used 
within the framework being utilized by VA for the Chapter 33 long-term 
solution system development: 

Scrum teams. These teams are to be cross-functional groups of about 
seven individuals that are developers, subject matter experts, and 
managers that perform analysis, design, implementation, and testing of 
specific pieces of functionality. The product owner acts as an 
interface between stakeholders and Scrum teams and is also responsible 
for translating requirements into work lists, maintains the work list, 
and maintains a backlog of requirements (i.e. user stories), called a 
product backlog. 

Sprint. Each team works in iterations that typically last 2 to 4 
weeks; these blocks of time are known as sprints. During a sprint, 
each Scrum team creates a potentially shippable product (for example, 
working and tested software). These products are developed based on 
the user stories in the product backlog that are prioritized by the 
product owner and team. Each user story is assigned a level of effort, 
called story points. Story points are used as a relative unit of 
measure to communicate complexity and progress between the business 
and development sides of the project. Each sprint builds on the 
previous sprint to generate a working system. After a predetermined 
number of sprints, a release of the system goes into production. 
		
Sprint planning meeting. Held prior to each sprint, this meeting is 
where user stories are communicated to the team and the team then 
commits to an amount of work it will complete for the next sprint. 
After the product owner agrees, user stories are then finalized for 
that sprint. 

Daily Scrum meeting. During each sprint, Scrum teams meet every day 
and hold a daily Scrum meeting. This meeting is short and concise and 
its purpose is to ensure that team members understand the work that 
has been completed since the last stand up meeting, what work is 
planned for the current day, and any problems that would prevent the 
team from achieving that work. Each team has a ScrumMaster, who is 
responsible for facilitating the meetings by maintaining the process 
and promoting resolution of problems identified by the team. 

Sprint review. After each sprint, teams demonstrate completed work and 
discuss work that was not finished with stakeholders. They also 
identify any problems that were encountered in completing the work. 
Feedback and priority is solicited from stakeholders so that it can be 
incorporated into future sprints. 

[End of section] 

Attachment II: VA and SPAWAR Costs for Chapter 33 System Development: 
		
Table: VA and SPAWAR Chapter 33 Costs by Release as of July 31, 2010: 

Type of Cost[A]: SPAWAR expenditures; 
Release 1[B]: $39.8 million; 
Release 2: $14.4 million; 
Release 2.1: $3.3 million; 
Release 3: $2.3 million; 
Release 4: $0.0; 
Post-Release 4: [Empty]; 
Total: $59.8 million. 

Type of Cost[A]: VA program obligations; 
Release 1[B]: $20.7 million; 
Release 2: $3.8 million; 
Release 2.1: $0.0; 
Release 3: $0.3 million; 
Release 4: $0.0; 
Post-Release 4: [Empty]; 	
Total: $24.8 million. 

Type of Cost[A]: Total; 
Release 1[B]: $60.5 million; 
Release 2: $18.2 million; 
Release 2.1: $3.3 million; 
Release 3: $2.6 million; 
Release 4: $0.0; 
Post-Release 4: [Empty]; 	
Total: $84.6 million. 

Type of Cost[A]: Funds obligated and transferred to SPAWAR but not yet 
expended; 
Release 3/Release 4: $45.5 million [C]. 

Type of Cost[A]: Planned and obligated costs to complete Release 3 (VA 
and SPAWAR program costs; 
Release 3: $24.0 million. 

Type of Cost[A]: Planned but not obligated FY2011 cost to complete 
Release 4 (VA and SPAWAR program costs); 
Release 4: $1.3 million. 

Type of Cost[A]: Planned but not obligated FY2011 cost for post-
Release 4 systems development activities (VA and SPAWAR program costs); 
Post-Release 4: $51.7 million[D]. 

Type of Cost[A]: Total funds expended, obligated, and planned 
obligations for Chapter 33 interim and long-term solution development; 
Total: $207.1 million. 

Source: VA. 

[A] These costs represent actual expenditures, obligated funds, and 
planned obligated funds. VA could not provide estimated project costs 
to compare to these costs. 

[B] Release 1 costs include both interim and long-term solution costs. 
VA did not provide the cost accounting to account for these separately. 

[C] As of September 4, 2010, VA could not provide a breakout between 
Release 3 and 4. 

[D] While VA has estimated this funding, it could not describe what 
these costs will represent. 

[End of table] 

[End of section] 

Attachment III: VA's Governance and Oversight for the Chapter 33 
Initiative: 
		
VA established a governance structure for the Chapter 33 initiative in 
October 2008. The table below shows the decision-making bodies and 
their responsibilities for the initiative. 

Title: Joint Executive Board; 
Description: Co-chaired by the Under Secretary for Benefits and the 
Assistant Secretary for Information and Technology, this senior 
governing body provides executive-level oversight and strategic 
guidance for implementation of the initiative. It is responsible for 
ensuring that communications, strategies, planning, and deliverables 
enable the initiative to meet its mission, goals, and objectives. 

Title: Executive Steering Committee; 
Description: Co-chaired by the Director of Education Service and the 
Program Manager, the Steering Committee advises the Joint Executive 
Board on requirements, policies, and standards. It is responsible for 
the oversight of program planning and execution to ensure that the 
strategic vision is incorporated into the business operations. 

Title: Working Group; 
Description: Co-chaired by the Leader of the Veterans Benefits 
Administration (VBA) Education Service Program Executive Office and 
the Dependency Lead, Office of Information and Technology, Chapter 33 
Program Management Office, the Working Group provides oversight and 
governance to workgroups leading programmatic and technical interests 
of the initiative. It defines and prioritizes business requirements, 
identifies and escalates issues and risks, and makes recommendations 
to the Executive Steering Committee on which requests to approve and 
resource. 

Title: Workgroups; 
Description: Eight workgroups, led by Education Service and Office of 
Information and Technology staff, provide daily operations management 
and ensure that requirements areas are identified and defined for each 
of the following areas: Benefits Delivery Network/Financial Accounting 
System, Business Requirements, Certification and 
Accreditation/Security, Infrastructure, Interlaces, Strategic 
Planning, Training, and the Security Review Board. 

Source: VA. 

[End of table] 

[End of section] 

[End of briefing slides] 

Appendix II: Comments from the Department of Veterans Affairs: 

The Secretary Of Veterans Affairs: 
Washington: 

November 12, 2010: 

The Honorable Gene Dodaro: 
Acting Comptroller General of the United States: 
Washington, DC 20548: 

Dear Mr. Dodaro: 

The Department of Veterans Affairs (VA) has reviewed the Government 
Accountability Office's (GAO) draft report, "Information Technology: 
Veterans Affairs Can Improve its Development Process for its New 
Education Benefits System" (GA0-11-115). 

Since this GI Bill's implementation in 2009, which gives veterans with 
active duty service on, or after, September 11, 2001, enhanced 
educational benefits that cover more educational expenses, provide a 
living allowance, money for books and the ability to transfer unused 
educational benefits to spouses or children, over 360,000 Veterans and 
family members have enrolled in college. When you include all other 
college education programs, that number exceeds 600,000. This new GI 
Bill is important—not only for the numbers who are accepted into 
schools—but for the numbers who will be graduating from them in the 
years ahead. That's the measure of success. 

Implementation of this program continues to be a high priority to the 
Department and we have made great progress in fulfilling its 
objectives. The enclosure contains comments on GAO's draft report and 
responds to your recommendations. 

Sincerely, 

Signed by: 
Eric K. Shinseki: 

Enclosure: 

[End of letter] 

Enclosure: 

Department of Veterans Affairs (VA) Comments to Government 
Accountability Office (GAO) Draft Report: Information Technology: 
Veterans Affairs Can Improve its Development Process for its New 
Education Benefits System (GAO-11-115). 

GAO Recommendation: To help guide the development and implementation 
of the Chapter 33 long-term solution, we recommend that the Secretary 
of Veterans Affairs direct the Under Secretary for Benefits to take 
the following five actions: 

Recommendation 1: Establish performance measures for goals and 
identify constraints to provide better clarity in the vision and 
expectations of the project. 

VA Response: Concur. The Office of Information and Technology (OIT) 
will develop performance measures consistent with automating the Post-
9/11 GI Bill in order to evaluate SPAWAR and hold them accountable for 
achieving these goals. Target Completion Date: March 1, 2011. 

Recommendation 2: Establish bidirectional traceability between 
requirements and legislation, policies, and business rules to provide 
assurance that the system will be developed as expected. 

VA Response: Concur. VA believes that GAO's statement incorrectly 
implies that requirements traceability was not occurring when it in 
fact was being carefully documented, missing only the legislation 
element, which will require the assistance of legal experts to be 
correctly accomplished. VBA and OIT will work together to trace the 
rules on the long-term solution back to the legislation. Target 
Completion Date: June 30, 2011. 

Recommendation 3: Define the conditions that must be present to 
consider work "done" in adherence with agency policy and guidance. 

VA Response: Concur. The fiscal year 2011 Automate GI Bill Operating 
Plan outlines the conditions that will allow the project to be 
declared a success. At the Chapter 33 (CH33) working group level (VBA 
and OIT), VA will clarify the definition of "done" and ensure that it 
is being applied consistently. Target Completion Date: December 1, 
2010. 

Recommendation 4: Implement an oversight tool to clearly communicate 
velocity and the changes to project scope over time. 

VA Response: Non-Concur. Development metrics and models were 
established and implemented to forecast and measure development 
velocity. Based on lessons learned, these models were expanded to 
forecast and measure velocity at each scrum team. 

Recommendation 5: Improve the adequacy of the unit and functional 
testing processes to reduce the amount of system rework. 

VA Response: Non-Concur. VA's testing approach is compatible with 
Agile development, where unit, functional, and end-user testing are 
collaboratively accomplished and all significant errors are identified 
and resolved prior to deployment. 

[End of section] 

Appendix III: Comments from the Veterans Affairs' Assistant Secretary 
for Information and Technology: 

Department Of Veterans Affairs: 
Assistant Secretary For Information And Technology: 
Washington Dc 20420: 

November 12, 2010: 

Ms. Valerie Melvin: 
Director, Information Management And Human Capital Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Melvin: 

The Department of Veterans Affairs (VA) has reviewed the Government 
Accountability Office's (GAO) draft report, "Information Technology: 
Veterans Affairs Can Improve its Development Process for its New 
Education Benefits System" (GAO-11-115) and has concurred on three 
recommendations and non-concurred on two recommendations. As we 
expressed during our phone call on September 11, 2010, VA has some 
concerns regarding GAO's draft report. 

Chairman Filner's request to GAO was to "determine the status of VA's 
development and implementation" and to "evaluate the agency's 
effectiveness in managing its information technology for this 
project". VA believes GAO fell short of meeting this charge by 
omitting key facts, and presenting an unnecessarily negative view of 
our status and effectiveness to Congress. 

Despite unanimous predictions to the contrary, VA successfully 
converted all processing of new Post-9/11 GI Bill claims to the Long 
Term Solution (LTS) prior to the commencement of the Fall 2010 
enrollment process. Since installation, processing with the new system 
has been nearly flawless, with no significant "bugs" encountered. The 
Veterans Benefits Administration claims processors like the new system 
and find it easy and efficient to use. By dramatically changing its 
development processes, adopting the Agile methodology for this 
project, VA also dramatically changed its system development results. 
Prior to GAOs initial presentation to Congress, VA officials provided 
GAO with this information and we believe that GAO should have included 
all of these facts in its report to accurately present "the status of 
VA's development and implementation" of the new GI Bill LTS. 

Additionally, because Agile methodologies are not broadly used in the 
federal sector, this may have been the first exposure the GAO team 
performing this audit had to this methodology. Limited exposure to 
Agile methodology possibly caused GAO to present incorrect assumptions 
as facts. A specific example is the statement that "...the quality of 
unit and functional testing performed during Release 2 was 
inadequate..." VA utilized a testing approach compatible with Agile 
development, where unit, functional, and end-user testing were 
collaboratively accomplished, which ensured that all significant 
errors were identified and resolved prior to deployment. While 
different from traditional Waterfall" development techniques used on 
large systems development programs throughout government, the results 
speak for themselves. All three releases deployed during the GAO audit 
were installed with no significant (defined as severity I or 2) errors. 

Finally, we believe that GAO missed a substantial opportunity to 
positively influence real change in the results of information 
technology (IT) systems development across the federal government As 
GAO noted as recently as May 2010, use of waterfall development 
methodologies within VA had caused continual, largescale systems 
development failures. An objective evaluation of VA's effectiveness in 
managing its IT for this project would focus on the fact that VA 
recognized its failings and adopted Agile methodologies, with the 
result being a stunning and unpredicted success. If VA, with one of 
the worst track records in systems development (as amply documented 
over many years by VA's Inspector General and GAO), has been able to 
achieve such positive results, what are the implications for failing 
IT programs across government? 

The enclosure provides specific comments to the draft report and 
discusses each of the recommendations. VA appreciates the opportunity 
to comment on your draft report. 

Sincerely, 

Signed by: 

Roger W. Baker: 

Enclosure: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Valerie C. Melvin, (202) 512-6304 or melvinv@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, key contributions to this 
report were made by Christie M. Motley, Assistant Director; Rebecca E. 
Eyler; David A. Hong; Ashley D. Houston; John C. Martin; and Charles 
E. Youman. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 110-252, Secs. 5001-5003, June 30, 2008. 

[2] VA's legacy systems, among others, include a financial payment 
system, an education information system, and a veteran demographic and 
service data system. These legacy systems contain essential 
information required for calculating the benefit, such as prior 
benefit payments, academic institution rates, and veterans' service 
dates. VA planned to complete interfaces to all legacy systems except 
for its financial payment system, which is planned for the third 
release. 

[3] Agile software development is not a set of tools or a single 
methodology, but a philosophy based on selected values, such as, the 
highest priority is to satisfy customers through early and continuous 
delivery of valuable software; delivering working software frequently, 
from a couple of weeks to a couple of months; and that working 
software is the primary measure of progress. For more information on 
Agile development, see [hyperlink, http://www.agilealliance.org]. 

[4] This number represents actual expenditures, obligated funds, and 
planned obligated funds through fiscal year 2011. 

[5] One of the key Agile principles is that the delivery of completed 
software be defined, commonly referred to as the definition of "done." 
This is critical to the development process to help ensure that, among 
other things, testing has been adequately performed and the required 
documentation has been developed. 

[6] GAO, Business Modernization: Improvements Needed in Management of 
NASA's Integrated Financial Management Program, [hyperlink, 
http://www.gao.gov/products/GAO-03-507] (Washington, D.C.: April 30, 
2003). 

[7] Pub. L. No. 110-252, Secs. 5001-5003, June 30, 2008. 

[8] VA's legacy systems, among others, include a financial payment 
system, an education information system, and a veteran demographic and 
service data system. These legacy systems contain essential 
information required for calculating the benefit, such as prior 
benefit payments, academic institution rates, and veterans' service 
dates. 

[9] Agile software development is not a set of tools or a single 
methodology, but a philosophy based on selected values such as, the 
highest priority is to satisfy customers through early and continuous 
delivery of valuable software, delivering working software frequently, 
from a couple of weeks to a couple of months, and that working 
software is the primary measure of progress. For more information on 
Agile development, see [hyperlink, http://www.agilealliance.org]. 

[10] Pub. L. No. 110-252, Secs. 5001-5003 and Pub. L. No. 111-32, Sec. 
1002. 

[11] VA Project Management Accountability System (PMAS) Guide 1.0, 
March 2010. 

[12] VA planned to complete interfaces to all legacy systems except 
for its financial payment system, which is planned for the third 
release. 

[13] This number represents actual expenditures, obligated funds, and 
planned obligated funds through fiscal year 2011. 

[14] One of the key Agile principles is that the delivery of completed 
software be defined, commonly referred to as the definition of "done." 
This is critical to the development process to help ensure that, among 
other things, testing has been adequately performed and the required 
documentation has been developed. 

[15] VA's two other line administrations are the Veterans Health 
Administration and the National Cemetery Administration. 

[16] The regional processing offices are located in Atlanta, Georgia; 
Buffalo, New York; Muskogee, Oklahoma; and St. Louis, Missouri. 

[17] Among others, contractors such as Agilex Technologies, Inc., Booz 
Allen Hamilton, GeoLogics, and Lockheed Martin, support the Chapter 33 
system development. 

[18] VA Project Management Accountability System (PMAS) Guide 1.0, 
March 2010. 

[19] This estimate does not include maintenance costs past the end of 
fiscal year 2011 because program officials stated this will be 
budgeted under a different VBA initiative. 

[20] Carnegie Mellon Software Engineering Institute, Mary Ann Lapham, 
et al., Considerations for Using Agile in DOD Acquisition (Pittsburgh, 
Penn., April 2010). 

[21] For a brief history on iterative and incremental development and 
the origins of Agile methods, see Carnegie Mellon Software Engineering 
Institute, Hillel Glazer, et al., CMMIO or Agile: Why Not Embrace 
Both! (Pittsburgh, Penn., November 2008). 

[22] The Agile Manifesto was written and signed by a group of 
methodologists, who called themselves the Agile Alliance. Basic 
principles are set forth in this document and include, for example, 
that business people and developers must work together daily and 
throughout the project. For more information on the creation of the 
Agile Manifesto, see [hyperlink, 
http://agilemanfesto.org/history.html]. 

[23] Mike Cohn, Succeeding with Agile: Software Development Using 
Scrum (Boston, Mass.: Pearson Education, Inc., 2010); Agile Estimating 
and Planning (Upper Saddle River, N.J.: Pearson Education, Inc., 
2006); User Stories Applied (Boston, Mass.: Pearson Education, Inc., 
2004); and Ken Schwaber, Agile Project Management with Scrum (Redmond, 
Wash.: Microsoft Press, 2004). 

[24] Institute of Electrical and Electronics Engineers (IEEE), Systems 
and software engineering — software life cycle processes, IEEE Std. 
12207-2008, (Piscataway, N.J., January 2008) and Carnegie Mellon 
Software Engineering Institute, CMMI for Development, Version 1.2, 
CMU/SEI-2006-TR-008 (Pittsburgh, Penn., August 2006). 

[25] One of the widely used methodologies of implementing Agile values 
is Scrum. For more information on the Scrum approach see [hyperlink, 
http://www.scrumalliance.org/]. 

[26] Pub. L. No. 111-32, Sec. 1002, June 24, 2009, amended the Post-
9/11 Educational Assistance Act of 2008 by adding the Marine Gunnery 
Sergeant John David Fry Scholarship (see 38 U.S.C. § 3311), which 
includes in the act benefits for the children of service members who 
died in the line of duty on or after Sept. 11, 2001. Eligible children 
attending school may receive up to the highest public, in-state 
undergraduate tuition and fees, plus a monthly living stipend and book 
allowance under the program. 

[27] Institute of Electrical and Electronics Engineers (IEEE), Systems 
and software engineering — software life cycle processes, IEEE Std. 
12207-2008, (Piscataway, N.J., January 2008) and Carnegie Mellon 
Software Engineering Institute, CMMI for Development, Version 1.2, 
CMU/SEI-2006-TR-008 (Pittsburgh, Penn., August 2006). 

[28] Carnegie Mellon Software Engineering Institute, Capability 
Maturity Model® Integration for Development, Version 1.2 (Pittsburgh, 
Penn., August 2006), and Software Acquisition Capability Maturity 
Model® (SA-CMM®) version 1.03, CMU/SEI-2002-TR-010 (Penn., March 
2002); and the Institute of Electrical and Electronic Engineers 
(IEEE), 1362-1998, IEEE Guide for Information Technology—System 
Definition—Concept of Operations Document (New York, N.Y.,1998). 

[29] Maintaining bidirectional requirement traceability means that 
system-level requirements can be traced both backward to higher-level 
business or operational requirements, and forward to system design 
specifications and test plans. 

[30] Department officials noted that prior to this upgrade, they were 
able to establish traceability to test cases manually. 

[31] GAO, Year 2000 Computing Crisis: A Testing Guide, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-10.1.21] (Washington, D.C.: 
November 1998); Information Technology: Customs Automated Commercial 
Environment Progressing, but Need for Management Improvements 
Continues, [hyperlink, http://www.gao.gov/products/GAO-05-267] 
(Washington, D.C.: Mar. 14, 2005); and Homeland Security: Visitor and 
Immigrant Status Program Operating, but Management Improvements Are 
Still Needed, [hyperlink, http://www.gao.gov/products/GAO-06-318T] 
(Washington, D.C.: Jan. 25, 2006). 

[32] For further information on unit and functional testing, see GAO, 
Indian Trust Funds: Challenges Facing Interior's Implementation of New 
Trust Asset and Accounting Management System, [hyperlink, 
http://www.gao.gov/products/GAOIT-AIMD-99-238] (Washington, D.C.: Jul. 
14, 1999) and GAO, Financial Management Systems: Additional Efforts 
Needed to Address Key Causes of Modernization Failures, [hyperlink, 
http://www.gao.gov/products/GA0-06-184] (Washington, D.C.: March 27, 
2006). 

[33] Defect numbers were reported as of June 29, 2010. Program 
officials described high-priority defects as defects that could 
"break" the system and must be fixed. 

[34] GAO, Business Modernization: Improvements Needed in Management of 
NASA's Integrated Financial Management Program, [hyperlink, 
http://www.gao.gov/products/GAO-03-507] (Washington, D.C.: April 2003). 

[35] For more information on how defects result in unplanned rework 
and increased costs, see [hyperlink, 
http://www.gao.gov/products/GAO-06-184]. 

[36] Program officials stated that they had previously used a burn-
down chart that showed velocity for all teams in Release 1. However, 
in Release 2, they decided that they would provide burn-down charts at 
the team level, but not at the overall project level. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: