[Senate Prints 106-64]
[From the U.S. Government Publishing Office]
106th Congress S. Prt.
2d Session COMMITTEE PRINT 106-64
_______________________________________________________________________
INVESTIGATIVE REPORT
of
SENATOR FRED THOMPSON
Chairman of the
COMMITTEE ON GOVERNMENTAL AFFAIRS UNITED STATES SENATE
regarding the
FEDERAL AGENCY COMPLIANCE WITH THE CLINGER-COHEN ACT
[GRAPHIC] [TIFF OMITTED] TONGRESS.#13
OCTOBER 2000
__________
U.S. GOVERNMENT PRINTING OFFICE
68-009 WASHINGTON : 2000
C O N T E N T S
Page
Executive Summary................................................ 1
Introduction and Scope of Investigation.......................... 4
Findings......................................................... 5
Recommendations.................................................. 11
Appendix A: Letter to departments and agencies from Senate
Governmental Affairs Committee Chairman Fred Thompson and
Ranking Minority Member Joseph Lieberman regarding compliance
with the Clinger-Cohen Act of 1996............................. 13
Appendix B: GAO Audits and Reports on Federal Agency Information
Technology Management Since Enactment of the CCA............... 19
Appendix C: Individual Agency Responses to the Thompson/Lieberman
letter:
Department of Agriculture (USDA)............................... 21
Department of Defense (DOD).................................... 24
Department of Education........................................ 27
Department of Energy (DOE)..................................... 31
Department of Health and Human Services (HHS).................. 34
Department of Housing and Urban Development (HUD).............. 39
Department of the Interior..................................... 44
Department of Justice (DOJ).................................... 49
Department of Labor (DOL)...................................... 54
Department of State............................................ 62
Department of Transportation (DOT)............................. 71
Department of the Treasury..................................... 75
Department of Veterans Affairs (VA)............................ 78
Agency for International Development (USAID)................... 81
Environmental Protection Agency (EPA).......................... 83
Federal Emergency Management Agency (FEMA)..................... 87
General Services Administration (GSA).......................... 90
National Aeronautics and Space Administration (NASA)........... 95
National Science Foundation (NSF).............................. 99
Nuclear Regulatory Commission (NRC)............................ 104
Office of Personnel Management (OPM)........................... 109
Small Business Administration (SBA)............................ 111
Social Security Administration (SSA)........................... 112
(iii)
INVESTIGATIVE REPORT ON
FEDERAL AGENCY COMPLIANCE WITH THE
CLINGER-COHEN ACT
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EXECUTIVE SUMMARY
Senator Fred Thompson (R-TN), Chairman of the Senate
Governmental Affairs Committee, recently completed a
comprehensive investigation of agencies and departments subject
to the Clinger-Cohen Act of 1996 (CCA).\1\ The review was
initiated as part of the Committee's oversight agenda and is
the result of a series of questions posed to agencies to
ascertain the status of their efforts to comply with the 1996
law.
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\1\ Public Law 104-106 (Division D & Division E).
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The rapid pace of technological change and innovation has
offered unprecedented opportunities for the Federal Government
to use information technology (IT) to improve operational
performance, reduce costs, and enhance service responsiveness
to the public. Because of the Federal Government's increased
reliance on information technology, in 1994 Congress increased
its attention and oversight on agencies' acquisition,
management and use of information technology. Congress'
investigation of agency information technology use raised a
range of thorny issues surrounding managing and integrating
complex information management processes; computer hardware and
software; telecommunications networks; and, most importantly,
aligning information technology with business needs.
Consequently, Congress found that Federal agencies must have
effective leadership and must enforce management controls over
the government's $38 billion in annual spending on information
management and technology.
In response to concerns about how the Federal Government
was managing and acquiring information technology, Congress
passed the CCA in 1996. The CCA mandates, among other things,
that executive agencies design and implement capital planning
and investment controls, implement specified information
technology-related actions to enhance performance and results-
based management, and establish Chief Information Officers
(CIOs) with certain defined duties and responsibilities. In
addition, the CCA requires agencies to identify information
technology acquisition programs that have significantly
deviated from cost, performance, or schedule goals.
The Senate Committee on Governmental Affairs played a large
role in the passage of the CCA and maintains a high level of
interest in compliance with its provisions. As a part of the
Committee's oversight agenda, Chairman Thompson, along with the
Committee's Ranking Minority Member, Senator Joseph I.
Lieberman (D-CT), developed a series of questions to better
understand the status of CCA compliance in the agencies and
departments subject to its mandates.
Major Findings
Information Technology Management: Chief Information Officer Turnover
High
The CCA established CIOs in 24 agencies in order to ensure
that sound IT investment decisions are made and that cost-
effective return-on-investment--focus on results and
contributions to mission effectiveness--is achieved. The CCA
vested the CIO with specific responsibilities to help him or
her accomplish their goals.
While all of the 24 agencies have CIOs, the Federal
Government has been experiencing relatively high turnover.
While this should be expected in CIO positions because similar
turnover rates are not uncommon in the private sector, it
presents a management challenge to agencies that are trying to
maintain sustained focus in and momentum for ongoing IT
projects. In addition, various levels of CIOs within an agency
do not always coordinate with one central CIO thus causing
reporting and policy inconsistencies within a single agency.
Agencies Aren't Complying with Capital Investment and Planning and
Performance Measures
One of the most important aspects of the CCA is the
requirement that agencies make sound information technology
investment decisions based upon the business needs of an
executive agency or department. Under the CCA, each agency is
required to design and develop a process for assessing and
managing the risk of its information technology purchases in
order to ensure effective program performance results.
However, the findings reveal that 17 of the 24 agencies
covered by the CCA are not implementing fully the CCA's IT
capital planning and investment control requirements. For
example, the Small Business Administration responded that
because of its work on the Year 2000 computer problem, it did
not have time to develop formal information technology capital
planning procedures.
And while 21 agencies reported that their capital
investment and planning work processes were being improved or
reengineered, half of the agencies reported requiring process
reengineering or mission-related processes before making
significant investments in IT in support of those missions.
In order to make sound business decisions, agencies need
reliable information upon which to base those decisions.
However, the quality of the data for the assessments of major
IT investments needed for decisionmaking and for measuring
progress is questionable at most agencies. For example, the
Department of Agriculture noted that, while it has improved the
quality of the data used for decisionmaking, it is unclear
whether the data it uses to measure program performance is
accurate, reliable, or even current.
While it is important to have clear and accurate data
before making investment decisions, it is equally important for
agencies to link IT performance to agency program performance.
In fact, agencies are required to incorporate these performance
goals in annual agency reports required under the Government
Performance and Results Act (GPRA).\2\ Unfortunately, the
findings revealed that most agency links to these reports were
often too broad to provide sufficiently robust measures of the
impact information technology makes on an agency's overall
performance. Additionally, Chairman Thompson found that 16
agencies neither developed nor submitted IT management reports
that included accomplishments, progress, and identification of
areas requiring attention. And, finally, one fourth of agencies
reported significant deviations of projects from cost or
schedule goals. Because agencies are not using sound business
procedures before investing in information technology, they are
unable to improve program performance and meet their mission
goals.
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\2\ Public Law 103-62.
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Agencies Aren't Applying Modular Contracting For Major IT Investments
In 1994, Congress found that Federal regulations governing
information technology acquisitions were outdated, focused on
paperwork and process rather than results, and prevented the
government from taking timely advantage of rapid advances
taking place in the competitive and fast changing global
information technology marketplace. The CCA authorizes agencies
to purchase IT on an incremental or modular basis to prevent
the mismanagement of IT spending. This authority still hasn't
been applied consistently in major IT investments
governmentwide, In fact, the findings revealed that eight
agencies reported still being in the process of implementing
modular contracting.
Recommendations
The report includes a dozen recommendations for executive
departments and agencies to implement in order to fully comply
with the CCA. The recommendations provide that departments and
agencies should:
review the mechanisms in place for assuring that
they are fully implementing the CCA through their policies,
procedures, and practices;
articulate the roles, reporting relationships and
boundaries of authority among all CIOs within an agency in ways
that enhance the effective implementation of the CCA;
provide the appropriate authority to the CIO to
ensure the CIO's control over IT capital planning and
investment processes;
increase quality control of their capital
planning and investment control practices, including ensuring
that any cost/benefit data used in investment decisionmaking is
accurate and complete;
provide clear procedures on how CIOs and program
managers communicate to senior management the status and
progress of major IT projects;
develop and incorporate the use of decision
milestones in IT project management;
develop an effective means of identifying IT
projects that deviate significantly from cost, schedule and
performance expectations;
increase project management and capital planning
skills within their IT workforce;
provide better data on how IT investments will
benefit Federal programs;
develop IT management plans that include
accomplishments, progress, and the identification of areas
requiring attention;
clarify the requirements for process
reengineering in their overall capital planning and investment
control procedures; and
increase their use of modular contracting for
building and acquiring information systems.
INTRODUCTION AND SCOPE OF INVESTIGATION
At the beginning of the second session of the 106th
Congress, Senate Governmental Affairs Committee Chairman Fred
Thompson began an investigation of how Federal agencies were
complying with the requirements of the Clinger-Cohen Act. This
review was undertaken as part of the Committee's oversight of
Federal agency information technology procurement and
management.
As part of the investigation, Chairman Thompson reviewed
responses to certain questions posed to the agencies \3\ as
well as 31 reports on information technology management
conducted by the General Accounting Office (GAO) since
enactment of the CCA.\4\
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\3\ By letter dated April 6, 2000 from Chairman Thompson and
Ranking Minority Member Lieberman (see Appendix A).
\4\ See Appendix B.
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Background
During the 104th Congress, the Senate Governmental Affairs
Committee reviewed the way information was being managed by
Federal agencies. Realizing that information technology,
particularly network computers, were changing the way Federal
managers compiled, distributed, and maintained information, as
well managed Federal programs, the Committee developed
legislation (which became the CCA) to remedy some of the
central problems underlying the way the government does
business. For example, the Committee's Subcommittee on
Oversight of Government Management and the District of Columbia
found that the government was falling further behind the
private sector in its ability to successfully use information
technology. According to a 1995 statement by then Senator
William Cohen:
``The Federal Government rarely if ever examines how
it does business before it automates. I recently held
hearings which examined how the Pentagon could save
more than $4 billion over 5 years simply by changing
the way it processed travel vouchers. Automating the
current voucher processing system will neither achieve
the projected savings nor the efficiencies that are
accomplished through reengineering. Second, the Federal
Government has wasted billions of dollars by
maintaining and updating so-called legacy or antiquated
computers from the 1960's and 1970's which are ill-
suited for the government's needs and by today's
standards will never be efficient or reliable.''\5\
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\5\ Statement of Senator William Cohen, Vol. 141, No. 101
Congressional Record, p. S8686, June 20, 1995.
These findings and others led to the development of
legislation intended to make it easier for the government to
buy and manage information technology. Most importantly, the
CCA was designed to make sure that, before the government
invests in technology, agencies will have carefully planned and
justified their expenditures.
Since enactment of the CCA, GAO has conducted a number of
audits at specific agencies to review the status of compliance
with various provisions, including progress in implementing
information technology investment controls, information
security, and the status and role of the agency CIOs.
Approximately 31 reports detailing agency strengths and
weaknesses have been completed. However, this report details,
for the first time, a governmentwide outline of agency
compliance efforts with the CCA.
FINDINGS
Strong Executive Leadership: How to Retain Federal Chief Information
Officers \6\
Background: Obtaining and retaining qualified personnel to
manage Federal information technology systems is a challenge
for the Federal Government. A number of senior government
officials have recommended changing the current salary
structure and providing agencies with the authority to provide
greater flexibility to workers, especially information
technology workers, in order to maintain highly skilled
employees and to be able to lure workers from the private
sector to serve in the public sector.
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\6\ Section 5125 of the CCA (40 U.S.C. 1425(b)).
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Finding 1: CIO positions in the Federal Government have been
experiencing relatively high turnover.\7\
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\7\ Turnover should be expected in CIO positions, and these rates
of turnover are not uncommon in the private sector. The challenge it
presents is one of maintaining sustained focus and momentum to ongoing
IT priority projects as well as to strategic IT direction.
Ten of the 24 major agencies/departments have had
three or four CIOs since enactment of the CCA in February 1996.
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One department, Department of Education, has had five.
The remaining 13 agencies and departments have
had one or two CIOs since February 1996.
Since 1996, several departments and agencies have
named ``acting'' CIOs, some for extended periods of time, due
to lengthy recruitment searches.
Finding 2: Roles, reporting relationships, and boundaries of authority
among CIOs within large executive agencies and departments are
not clearly established.
Decentralized executive agencies/departments have
several component-level organizations that have designated
CIOs. The staff of the component-level organizations report to
the component-level head. A majority of agencies reported not
having direct reporting relationships to the agency-wide
CIO.\8\ This reporting arrangement may reduce the agency-wide
CIO's ability to institutionalize department-wide IT management
practices and technical standards.
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\8\ The Department of Commerce is planning to have component agency
CIOs (NOAA, PTO, etc.) report to both their agency heads and to the
department CIO.
For example, the Department of Health and Human
Services (HHS) has 13 operating divisions that have designated
CIOs. According to HHS, four CIOs report to the head of the
operating division (top level), four CIOs report to a top
deputy (second level), and five report to lower levels of
management. None of the CIOs have a direct reporting
relationship to the department-level CIO.
Achieving Benefits From Capital Planning and Investment Control \9\
Background: A strong and comprehensive IT capital planning
process is necessary to assure that agency IT expenditures
receive the executive-level oversight required for confidence
that the agency head is executing his or her responsibility in
IT investment management as specified in the CCA. In addition,
the IT capital planning process provides the mechanism for
selecting IT investments as part of the overall IT portfolio
that support the agency mission.
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\9\ Section 5122 of the CCA (40 U.S.C. 1422).
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Finding 3: IT capital planning and investment control processes have
not been fully implemented governmentwide.
Seventeen of the 24 agencies and departments have
not established a complete and comprehensive IT capital
planning and investment control process (CPIC). The agencies'
and departments' efforts range from needing improvements in
their established processes to developing a process as
specified by the CCA.
Seven agencies and departments--the Department of
Defense, the Environmental Protection Agency, the General
Services Administration, the National Aeronautics and Space
Administration, the Nuclear Regulatory Commission, the National
Science Foundation, and the Department of Veterans Affairs--
reported that they had implemented a complete and comprehensive
IT CPIC process, with only one--GSA--saying its process needed
to be refined and enhanced.
For example, Agriculture reported that while it
has established processes for three phases of capital
planning--select, control, and evaluate--efforts are under way
to improve inconsistent component-level capital planning.
Additionally, Agriculture reported that its CIO office has
engaged contract support to help review the major investments
to determine where improvements need to be made.
The Department of Interior reported that the
Y2K problem became that agency's top priority and, as a result,
the CCA took a back seat. According to Interior, its CIO Office
was not organized until March 2000. However, Interior reported
that it has made significant progress in implementing its IT
CPIC process.
SBA also reported Y2K as a problem which forced
it to use all of its IT resources to sustain routine operations
and maintenance. This effort, according to SBA, reduced its
resources in other areas including the development of formal IT
capital planning procedures.
Finding 4: CIO authority and control in IT investment and capital
planning is limited.
Not all agencies require their IT initiatives to
come under agency-wide CIO review or control unless the
initiative fits specific threshold requirements which may be
based on financial or functional criteria. In addition, agency-
wide CIOs often only have direct responsibility for systems
that cut across department units. Moreover, those system
projects that are under the CIO's control may not line up with
those classified as ``major'' by OMB for those agencies that
use this criteria.\10\
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\10\ Memo (M-97-02) sent on October 25, 1996, by then OMB Director
Franklin D. Raines to heads of executive departments and agencies
providing direction regarding investments in major information
technology systems defines ``major information system'' as a system
``that requires special management attention because of its importance
to an agency mission; its high development operating, or maintenance
costs; or its significant role in the administration of agency
programs, finances, property, or other resources.''
Not all department initiatives are reviewed
within a department-wide portfolio. Moreover, not all
initiatives come under CIO technical review at some level of
the review process, although for most agencies, ``major'' IT
initiatives do. This may impact the effectiveness of the
capital planning and investment process as well as the impact
of IT on the agency's ability to achieve its mission
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successfully and efficiently.
Several agencies reported they are initiating
efforts to coordinate component and agency-wide practices or to
ensure the implementation of sound capital planning and
investment processes within their component levels.
In many cases, major department CIOs do not have
control over IT expenditures which do not meet the department-
wide threshold requirements for capital planning.
Some agencies reported inconsistencies in their
capital planning and investing processes across their
organizational components.
For example, in the Department of
Transportation, the two largest organizations--the Federal
Aviation Administration and the U.S. Coast Guard--use their own
agency capital planning and investment control processes which
DOT asserts account for about 90 percent of DOT's total IT
expenditures.
Finding 5: The quality of data for the assessments of major IT
investments and initiatives for decisionmaking and for
measuring progress is questionable.
A majority of the agencies and departments
reported that the quality of the data for making investment
decisions and measuring progress needs improvement.
Many of these agencies reported that they had
begun using, or plan to use, the Information Technology
Investment Portfolio System (ITIPS) to better manage their IT
investments. Agencies reported that ITIPS helps them to collect
and track investment data needed to effectively select and
control IT investments.
For example, Agriculture reported that it
believes it has improved the quality of the data used for
decisionmaking, but more improvement is needed before there
will be consistency across the whole agency. As for the quality
of the data for measuring progress, Agriculture also reported
that it is unsure of its accuracy, reliability, or currency,
but will use a contractor to aid in this evaluation effort.
In another example, Interior reported that a
major obstacle to instilling confidence in cost data is that
its Federal budgeting and accounting systems do not adequately
support cost accounting information related to IT costs.
Managing IT for Overall Performance and Results \11\
Background: Federal CIOs are responsible for managing IT
investments to demonstrate cost effectiveness and efficiencies.
In addition, IT investment strategies and spending should be
tightly aligned with expected improvements in mission
performance and results. The inability to track IT development
and implementation effectively can result in a failure to
identify cost and schedule overruns and the failure of IT
initiatives to meet performance expectations. Management plans
and reporting are critical to providing continuity in planning
from year to year and in measuring the contribution of IT to
mission performance across the agency.
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\11\ Section 5123 of the CCA (40 U.S.C. 1423).
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Finding 6: Although most agencies reported the linking of IT system
performance to mission performance through annual GPIRA plans
and reports, these links were often too broad to provide
sufficiently robust measures of IT impact on overall strategic
performance.
Processes necessary for effective tracking of IT
development and implementation are weak.
Five agencies reported needing great
improvement in the quality of data necessary for tracking IT
development and implementation.
Fourteen agencies reported the use of
milestones in monitoring the progress of IT projects and four
agencies reported not using milestones.
Finding 7: Most agencies reported that they have not developed IT
management plans that include accomplishments, progress, and
identification of areas requiring attention.\12\
Sixteen agencies and departments neither
developed nor submitted IT management reports that included
accomplishments, progress, and identification of areas
requiring attention.
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\12\ Section 5127 of the CCA (40 U.S.C. 1427).
One fourth of the agencies reported significant
deviations of projects from cost or schedule goals laid out in
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agency strategic information resource management plans.
For example, Agriculture reported that, while
its CIO had not developed agency-wide IT management reports for
its agency head, the CIO plans to submit a separate IT report.
In another example, the Department of Justice
has produced an Annual Accountability Report for the last 2
years in which it describes the progress toward goals laid out
in its Strategic Plan. However, Justice agrees that an annual
assessment of progress will be useful and intends to modify its
IT investment management program to conduct and document annual
evaluations of agency progress.
Using IT to Improve Work Processes \13\
Background: The CCA requires reengineering analyses of
administrative and business processes either prior to or as
part of major systems investment decision-making. Investments
made in updating systems without reconsidering the underlying
processes risk producing less than optimal returns on
investment.
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\13\ Section 5123 of the CCA (40 U.S.C. 1423).
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Finding 8: Fewer than half of the agencies reported requiring process
reengineering of mission-related processes before making
significant IT investment in support of those missions.
Twenty-one of the 24 agencies reported that work
processes are being improved or reengineered.
Eighteen of the agencies claimed that some or all
of its top 10 IT investments included work process improvement
or reengineering.
A few agencies reported that they are in the
process of analyzing their mission or are just starting to
perform business process reengineering.
Some departments and agencies have initiated
major IT efforts to overhaul services and citizen access.
Agencies reporting such efforts include Agriculture, Education,
EPA, Federal Emergency Management Agency, NRC, and the
Department of Treasury.
For example, Agriculture reported that business
process reengineering remains a cornerstone of its
implementation of the CCA and its IT capital planning process.
Prior to design and deployment of major IT investments
throughout Agriculture in compliance with the CCA and with
Raines Rules,\14\ its CIO conducts business reviews as a
necessary management tool.
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\14\ Raines Rules refers to OMB Memo (M-97-02) sent on October 25,
1996, by then OMB Director Franklin D. Raines.
However, fewer than half of the agencies reported
requiring process reengineering of mission-related processes
before making significant IT investment in support of those
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missions.
Although 21 agencies reported that work
processes were being improved or reengineered, only about half
of these noted that this was a required activity and few
specifically noted that these activities occurred prior to
funding IT investments as required by the CCA.
Many agencies provided weak support for the
premise that they are engaging in work process improvement or
reengineering.
Examples of IT investments often noted that work
process improvements resulted from IT investments rather than
as a precursor to funding the investment. For example, Justice,
the Department of Labor, GSA, and NRC provided IT investment
examples that appeared to show reengineered processes as a
result of the IT investment.
Other IT investment examples cited by some
agencies included automation efforts with no mention of work
process redesign.
Several agencies pointed to their compliance with
Raines Rules as evidence that they have performed mission
analysis and work process redesign. However, compliance with
Raines Rules only requires that the agency answer whether work
redesign has begun--not whether the work redesign has been
completed.
For example, Education reported that it has
analyzed some of its missions and has begun to revise its
mission-related and administrative processes. Interior reported
that business process reengineering efforts are in various
stages of development in several of its bureaus.
Building Large IT Systems Incrementally Through Modular Contracting
\15\
Background: The CCA authorizes Federal agencies to adopt
modular approaches to building and acquiring information
systems. This is expected to produce smaller, more manageable
projects that can be examined in shorter time frames for
expected cost and benefit results. It also encourages the use
of pilots and prototyping before full scale development and
implementation.
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\15\ Section 5202 of the CCA (see section 38 of the Office of
Federal Procurement Policy Act (41 U.S.C. 434)).
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Finding 9: Modular contracting is still not applied consistently in
major IT investments government-wide.
Eight agencies reported still being in the
process of implementing modular contracting.
RECOMMENDATIONS
In order for executive departments and agencies to fully
comply with the CCA, the following recommendations should be
implemented:
1. Departments and agencies should review the mechanisms
in place for assuring that they are fully implementing the CCA
through their policies, procedures, and practices.
2. Departments and agencies should articulate the roles,
reporting relationships and boundaries of authority among all
CIOs within an agency in ways that enhance the effective
implementation of the CCA.
3. Departments and agencies must provide the appropriate
authority to the CIO to ensure the CIO's control over IT
capital planning and investment processes.
4. Departments and agencies need to increase quality
control of their capital planning and investment control
practices, including ensuring that any cost/benefit data used
in investment decisionmaking is accurate and complete.
5. Departments and agencies need to provide clear
procedures on how CIOs and program managers communicate to
senior management the status and progress of major IT projects.
6. In order to avoid schedule slips and cost overruns on
major IT investments, departments and agencies should develop
and incorporate the use of decision milestones in IT project
management.
7. Departments and agencies must develop an effective
means of identifying IT projects that deviate significantly
from cost, schedule and performance expectations.
8. Departments and agencies need to increase project
management and capital planning skills within their IT
workforce.
9. Departments and agencies must provide better data on
how IT investments will benefit Federal programs.
10. Departments and agencies should develop IT management
plans that include accomplishments, progress, and the
identification of areas requiring attention.
11. Departments and agencies should clarify the
requirements for process reengineering in their overall capital
planning and investment control procedures.
12. Departments and agencies should increase their use of
modular contracting for building and acquiring information
systems.
A P P E N D I X
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