Tax Systems Modernization: Blueprint Is A Good Start but Not Yet
Sufficiently Complete To Build or Acquire Systems (Letter Report,
02/24/98, GAO/AIMD/GGD-98-54).

Pursuant to a congressional request, GAO reviewed the modernization
blueprint that the Internal Revenue Service (IRS) prepared pursuant to
the conference report accompanying the fiscal year 1997 Omnibus
Consolidated Appropriations Act.

GAO noted that: (1) IRS' May 15, 1997, modernization blueprint is a good
first step and provides a solid foundation from which to determine
precise business requirements, a complete target architecture, and a
discipline set of processes and detailed plans for validating,
implementing, and enforcing the architecture; (2) similarly, the
blueprint's business requirements specify needed improvements in such
areas as financial management, and the architecture and sequencing plan
include several positive attributes, including traceability between
business requirements and systems and high-level descriptions of data
and security subarchitectures; (3) however, the blueprint is not yet
complete and does not provide sufficient detail and precision for
building or acquiring new systems; (4) in particular, IRS' systems life
cycle (SLC) does not define in sufficient detail any of the SLC
processes needed to manage technology investments; (5) as a result, IRS
does not yet know how systems will actually be designed, developed,
tested, or acquired; how compliance with standards will be assessed and
ensured; how progress on projects will be determined; or how key SLC
products will be validated; (6) additionally, IRS plans for each of the
three remaining blueprint components--business requirements,
architecture, and sequencing plan--to include four levels of
progressively greater detail; (7) as of May 15, 1997, IRS had completed
the first two levels; (8) as a result, information that is critical to
effective and efficient systems modernization is not yet known,
essential decisions have not yet been made, and needed actions have not
yet been taken; (9) IRS' Chief Information Officer (CIO) has
acknowledged that essential elements are missing from the May 15, 1997,
blueprint, and stated that he has begun addressing these voids; (10)
however, even though IRS, has given the CIO increased responsibility and
accountability for managing and controlling systems development,
acquisition, and maintenance, neither the CIO nor any other IRS
organizational entity has budgetary and organizational authority over
all IRS systems activities; and (11) as a result, it is unlikely that
IRS will be able to institutionally implement and enforce its
modernization blueprint once it is completed.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD/GGD-98-54
     TITLE:  Tax Systems Modernization: Blueprint Is A Good Start but 
             Not Yet Sufficiently Complete To Build or Acquire
             Systems
      DATE:  02/24/98
   SUBJECT:  Strategic information systems planning
             Systems design
             Systems conversions
             Accountability
             Tax administration systems
             Systems development life cycle
             Information resources management
             ADP procurement
             Information technology
IDENTIFIER:  IRS Integrated Data Retrieval System
             IRS Electronic Audit Research Log System
             IRS Tax System Modernization Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

February 1998

TAX SYSTEMS MODERNIZATION -
BLUEPRINT IS A GOOD START BUT NOT
YET SUFFICIENTLY COMPLETE TO BUILD
OR ACQUIRE SYSTEMS

GAO/AIMD/GGD-98-54

Tax Systems Modernization

(511531)


Abbreviations
=============================================================== ABBREV

  CIO - chief information officer
  CMM - Capability Maturity Model
  IRS - Internal Revenue Service
  SEI - Software Engineering Institute
  SLC - systems life cycle
  TSM - Tax Systems Modernization

Letter
=============================================================== LETTER


B-278517

February 24, 1998

The Honorable Ben Nighthorse Campbell
Chairman
Subcommittee on Treasury
 and General Government
Committee on Appropriations
United States Senate

The Honorable Jim Kolbe
Chairman
Subcommittee on Treasury, Postal
 Service, and General Government
Committee on Appropriations
House of Representatives

This report provides the results of our assessment of the
modernization blueprint that the Internal Revenue Service (IRS)
prepared pursuant to the conference report accompanying the fiscal
year 1997 Omnibus Consolidated Appropriations Act (Public Law
104-208).  In the conference report, the Congress directed the
Department of the Treasury to, among other things, develop a
blueprint that would define, direct, and control future modernization
efforts. 

On May 15, 1997, IRS provided a modernization blueprint to the
Congress.  This blueprint consists of four principal components:  (1)
a systems life cycle\1 (SLC), (2) business requirements, (3)
functional and technical architectures,\2 and (4) a sequencing
plan.\3 We assessed each of these components to determine whether
they provided the foundation needed to develop or acquire modernized
systems.  In August and September 1997, we briefed IRS, Treasury, and
your respective offices on the results of our assessment.  In
response to those briefings, your offices asked that we report our
findings to you.  Our specific objectives were to determine whether

  -- IRS' SLC was complete and consistent with best industry and
     government practices;

  -- the business requirements were sufficiently precise and the
     functional and technical architectures were sufficiently
     complete to build or acquire systems, and the sequencing plan
     was sufficiently complete to understand the transition to the
     target systems environment;

  -- IRS' business requirements, functional and technical
     architectures, and sequencing plan had been validated using
     defined and implemented SLC processes; and

  -- the information technology management structure was conducive to
     effective implementation and enforcement of the blueprint. 

Appendix I provides details on our scope and methodology. 

We performed our work from May 1997 through September 1997 in
accordance with generally accepted government auditing standards.  We
requested comments on a draft of this report from the Commissioner of
Internal Revenue, who provided us with written comments.  These
comments are discussed in the "Agency Comments" section and are
reprinted in appendix II. 


--------------------
\1 A systems life cycle defines the policies, processes, and products
for managing information technology investments from conception,
development, and deployment through maintenance and support. 

\2 A system architecture defines the critical attributes of an
agency's collection of information systems in both
business/functional and technical/physical terms. 

\3 A sequencing plan defines the actions that must be taken, and
their schedules along with costs, to cost effectively evolve from the
current to the future systems operating environment. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

IRS' May 15, 1997, modernization blueprint is a good first step and
provides a solid foundation from which to define precise business
requirements, a complete target architecture, and a disciplined set
of processes and detailed plans for validating, implementing, and
enforcing the architecture.  For example, the blueprint's SLC
overview provides a high-level approach that is consistent with best
practices in both the public and private sectors for life cycle
management of information technology investments.  Similarly, the
blueprint's business requirements specify needed improvements in such
areas as financial management, and the architecture and sequencing
plan include several positive attributes, including traceability
between business requirements and systems and high-level descriptions
of data and security subarchitectures. 

However, the blueprint is not yet complete and does not provide
sufficient detail and precision for building or acquiring new
systems.  In particular, IRS' SLC does not define in sufficient
detail any of the SLC processes needed to manage technology
investments.  As a result, IRS does not yet know how systems will
actually be designed, developed, tested, or acquired; how compliance
with standards will be assessed and ensured; how progress on projects
will be determined; or how key SLC products will be validated.  In
short, IRS cannot yet implement disciplined life cycle management. 

Additionally, IRS plans for each of the three remaining blueprint
components-- business requirements, architecture, and sequencing
plan--to include four levels of progressively greater detail.  As of
May 15, 1997, IRS had completed the first two levels.  As a result,
information that is critical to effective and efficient systems
modernization is not yet known, essential decisions have not yet been
made, and needed actions have not yet been taken.  For example, the
architecture does not yet specify how requirements for data security,
availability, or reliability will actually be satisfied.  Similarly,
the sequencing plan does not specify projects, schedules, costs, or
interdependencies, and thus how, when, and at what cost IRS will move
from its current operating environment to its modernized environment. 

IRS' Chief Information Officer (CIO) has acknowledged that essential
elements are missing from the May 15, 1997, blueprint, and stated
that he has begun addressing these voids.  However, even though IRS,
acting on our past recommendations, has given the CIO increased
responsibility and accountability for managing and controlling
systems development, acquisition, and maintenance, the CIO does not
have budgetary and organizational authority over all IRS systems
activities.  As a result, it is unlikely that IRS will be able to
institutionally implement and enforce its modernization blueprint
once it is completed. 


   BACKGROUND
------------------------------------------------------------ Letter :2

IRS envisions a future in which its tax processing environment will
be virtually paper-free and taxpayer information will be readily
available to IRS employees to update taxpayer accounts and respond to
taxpayer inquiries.  To accomplish this, IRS embarked on an ambitious
systems modernization program, called Tax Systems Modernization
(TSM).  In 1995, we identified serious management and technical
weaknesses in TSM that jeopardized its successful completion,\4 made
more than a dozen recommendations to fix the problems, and designated
TSM as a high-risk information technology initiative in our biennial
report series on high-risk federal programs.  We again designated TSM
as high- risk in our 1997 report series.\5

To correct modernization weaknesses, we recommended in our 1995
report, among other things, that the Commissioner of Internal Revenue
ensure that IRS (1) implements disciplined processes for requirements
management, investment decision management, and system development
management, and (2) completes an integrated system architecture,
including data and security subarchitectures.  IRS agreed with all of
our recommendations. 

In June 1996, we reported\6 that while IRS had initiated a number of
actions to address our recommendations, many of these actions were
incomplete and none, either individually or collectively, responded
fully to any of our recommendations.  Accordingly, in the conference
report accompanying the fiscal year 1997 appropriations act (P.L. 
104-208, Sept.  30, 1996), the Congress took several actions,
including directing Treasury to develop a blueprint to define,
direct, and control future modernization efforts.  On May 15, 1997,
Treasury submitted its modernization blueprint to the Congress.  The
blueprint consisted of four documents:  (1) an SLC overview that
provides a high-level framework for defining a disciplined set of
processes for managing the modernization, (2) about 3,600 broad
business requirements, (3) high-level functional and technical
architectures that generally describe the target systems environment,
and (4) a general sequencing plan for transitioning from IRS' current
to its target systems environment. 


--------------------
\4 Tax Systems Modernization:  Management and Technical Weaknesses
Must Be Corrected If Modernization Is to Succeed (GAO/AIMD-95-156,
July 26, 1995). 

\5 High-Risk Series:  An Overview (GAO/HR-95-1, Feb.  1995);
High-Risk Series:  Information Management and Technology
(GAO/HR-97-9, Feb.  1997). 

\6 Tax Systems Modernization:  Actions Underway But IRS Has Not Yet
Corrected Management and Technical Weaknesses (GAO/AIMD-96-106, June
7, 1996). 


   IRS' SLC OVERVIEW IS
   CONCEPTUALLY CONSISTENT WITH
   BEST PRACTICES BUT LACKS
   ADEQUATE PROCESS AND PRODUCT
   DEFINITION
------------------------------------------------------------ Letter :3

IRS' SLC overview is consistent with general approaches used by
successful private and public sector organizations for managing large
information technology investments.  The macro-level practices
described in the overview provide the framework for planning,
controlling, developing, and deploying information systems based on
defined activities, events, milestones, reviews, and products. 

IRS' SLC overview, which is summarized in table 1, consists of
phases, processes, and products.  The phases, listed as columns in
table 1, are: 

  -- Requirements Management.  This phase addresses the questions of
     what is needed and how to satisfy the need(s).  It includes (1)
     identification and definition of information technology needs;
     (2) conduct of technical analyses (e.g., cost estimates,
     architectural impact assessments) for each defined need; (3)
     development of individual business cases (i.e., investment
     justifications) that include architectural impact and
     cost/benefit results; and (4) prioritization of competing
     business cases by type (new development, maintenance, and
     research and development). 

  -- Investment Decision Management.  This phase includes activities
     and documentation to determine how much should be spent and what
     should be developed and deployed.  During this phase, business
     cases are rank ordered by type on an agencywide basis,
     investment decisions are made (i.e., business cases are approved
     and funded on the basis of investment costs and benefits), and
     investment decisions are monitored over time to determine actual
     costs incurred and benefits realized. 

  -- System Development/Operations Management.  This phase defines,
     sequences, and documents activities necessary to develop,
     deploy, operate, and maintain systems.  It consists of (1)
     research and development, which includes prototype development
     and evaluation; (2) engineering, which includes system
     requirements analysis, systems design, release definition,
     release requirements analysis, and release system design; (3)
     design and development, which includes configuration item
     requirements analysis, preliminary design, detailed design, code
     and unit testing, and integration and testing; (4) integration,
     test, and deployment, which includes release integration and
     testing, release system acceptance testing, system piloting, and
     system rollout; and (5) maintenance, which includes release
     design, code and unit test, and integration and test. 

  -- Management Control and Oversight.  This phase spans each of the
     three aforementioned phases.  It includes change control
     management (i.e., determining what to change and when),
     configuration management (i.e., capturing and maintaining
     records of the changes), performance management (i.e., measuring
     progress against baselines), organizational management (i.e.,
     determining who is responsible for what), and audit and
     evaluation process management (i.e., determining whether SLC
     processes are effective and being followed). 

Associated with each phase, and shown as rows in table 1, are (1)
detailed process definitions, which describe the functions that are
performed and how they are performed, (2) key actions that need to be
taken to implement the processes, and (3) key products that are
prepared as a result of the processes' execution. 



                                     Table 1
                     
                                IRS' SLC Overview

                                        SLC phases
          ----------------------------------------------------------------------
                                              System
                            Investment        development/      Management
          Requirements      decision          operations        control and
          management        management        management        oversight
--------  ----------------  ----------------  ----------------  ----------------
SLC
processe
s
and
products

Detailed  Requirements:     Project:          System:           Organization
process    definition       selection        design          management
definiti   assessment       control          development/
on                          evaluation      acquisition       Evaluate
          prioritization                       operations      process
           validation      Required data     and               and product
                                              maintenance       compliance
                            Product
                            validation        Product           Enforce
                                              validation        standards
                                                                and architecture

Process   Responsible       Responsible       Responsible       Responsible
implemen  organizations     organizations     organizations     organizations
tation    designated        designated        designated        designated

          Handbooks         Handbooks         Handbooks         Handbooks
          prepared          prepared          prepared          prepared

          Training          Training          Training          Training
          conducted         conducted         conducted         conducted

Products  Concept of        Single            Sequencing plan   Documented
          Operations        investment                          decisions
                            portfolio         Architecture
          Business          (development,
          requirements      operations,       System:
                            research           design
          Business cases    and               
                            development)      specifications
          Architecture                         code
          impact            Documented         documentation
          analyses          data-driven
                            decisions         Test plans and
                                              reports
--------------------------------------------------------------------------------
Note:  The critical processes and products shown in this table are
some but not all of the processes and products that constitute each
SLC phase. 


   IRS' SLC IS INCOMPLETE
------------------------------------------------------------ Letter :4

While the SLC overview provides a framework that is consistent with
public and private sector best practices, IRS' SLC is incomplete and
does not yet provide the specificity needed for building or acquiring
systems.  As IRS recognizes, its SLC does not yet specify how
technology investment activities will be performed.  For example, it
does not specify (1) how work processes will be reengineered; (2) how
business requirements will be specified; (3) how engineering
solutions will be developed; (4) how business cases for technology
investments will be formulated and evaluated; (5) how systems
conforming to architectural standards will be developed; (6) how
operational systems conforming to architectural standards will be
maintained; and (7) how technology investments will be evaluated
using performance metrics.\7

The SLC shortcomings fall into three categories (see table 2). 
First, IRS does not yet have detailed process definitions for any of
the SLC phases.  For instance, IRS has not clearly defined how
requirements will be formulated and how they will be assessed and
prioritized; how projects will be controlled and evaluated; what data
will be required and what evaluation criteria will be used; how
system designs will be assessed and how system developments and
acquisitions will be managed; and how architectural compliance will
be determined and enforced.  Without these process definitions, IRS
cannot validate that the blueprint products published as of May 15,
1997, are correct and consistent.  Moreover, IRS cannot adequately
develop the level of detail and precision that, as discussed in the
following section of this report, these blueprint products currently
lack. 

Second, because it has not yet defined detailed SLC processes, IRS
has not yet implemented its SLC.  For example, handbooks have not
been prepared and training has not been conducted for any of the SLC
phases.  Further, organizational roles and authorities have not been
adequately specified, making it unclear who does what in each SLC
process and phase.  For instance, as described in the modernization
blueprint, the IRS chiefs will be responsible for reengineering
business processes and developing business requirements, but it is
unclear who has the responsibility and the authority to ensure that
the reengineered processes and specified requirements are prioritized
and optimized agencywide.  Similarly, although the CIO is responsible
for developing architecturally compliant engineering solutions to
satisfy business requirements, the CIO does not control all system
development resources.  Moreover, as discussed later in more detail,
neither the CIO nor any other organizational entity has sufficient
authority to implement SLC processes and enforce architectural
compliance agencywide. 

Third, many SLC products have not been defined or developed.  For
example, IRS does not have an agencywide, rank ordered, portfolio of
investment options.  Moreover, some investments are not supported by
business cases (i.e., business need documents, cost and schedule
estimates, analyses of the organizational and technical impact of the
proposed solution(s) on the phases and releases of the sequencing
plan and on the architecture, and analyses of the proposed
solution(s) expected return on investment). 



                                     Table 2
                     
                         IRS' Defined and Implemented SLC
                              Processes and Products

                                        SLC phases
          ----------------------------------------------------------------------
                                              System
                            Investment        development/      Management
          Requirements      decision          operations        control and
          management        management        management        oversight
--------  ----------------  ----------------  ----------------  ----------------
SLC
processe
s and
products

Detailed  None              None              None              None
process
definiti
on

Process   Some responsible  Some              Some              Some
implemen  organizations     responsible       responsible       responsible
tation    identified        organizations     organizations     organizations
                            identified        identified        identified

Products  Concept of        None              Sequencing plan   None
          Operations\a
                                              Architecture
          Business
          requirements
--------------------------------------------------------------------------------
\a IRS prepared a draft Concept of Operations dated July 31, 1997,
which postdated the May 15, 1997, submission to the Congress and was
not included with it. 


--------------------
\7 Performance metrics provide measures of how well the technical
development and design are evolving. 


   BLUEPRINT PRODUCTS ARE A GOOD
   START BUT ARE INCOMPLETE OR
   INSUFFICIENT
------------------------------------------------------------ Letter :5

While the products constituting IRS' May 15, 1997, modernization
blueprint represent a good first step and a foundation upon which to
build, none are complete.  In particular, the business requirements
are not precise enough and the architecture is not sufficiently
complete to build or acquire systems.  Additionally, the sequencing
plan does not provide sufficient detail to understand the transition
to the target systems environment. 


      BUSINESS REQUIREMENTS ARE
      INSUFFICIENTLY PRECISE
---------------------------------------------------------- Letter :5.1

IRS has divided its tax administration workflow into the following
six core functional areas. 

  -- Submissions processing, which is the primary source of data
     entering the workflow.  It provides for the collection and
     correction of data extracted from paper and electronic tax
     returns, payments, and information returns as well as forwarding
     of these data to the corporate processing function for storage
     and access control. 

  -- Corporate data processing, which includes receipt of data from
     the submissions processing function and storage of data in
     enterprisewide databases.  It provides for controlled access to
     a single, authoritative source of corporate data in support of
     the customer service, compliance, and financial reporting
     workflow functions. 

  -- Customer service, which provides the primary, non-face-to-face
     interface to taxpayers primarily through correspondence and
     telephone contacts. 

  -- Compliance, which provides the primary, face-to-face interface
     to taxpayers in resolving collection, exam, and other compliance
     cases. 

  -- Financial reporting, which is integrated with each of the
     workflow functions that update financial data and provides
     traceability to the source of all financial updates and summary
     financial reporting. 

  -- Information system infrastructure, which supports the other five
     functional areas by providing communication networks, computing
     platforms, workstations, and development facilities. 

For each of these core functional areas, the IRS business users
developed "guiding principles" that were intended to provide a
framework for developing modernization business requirements.  For
example, the submission processing guiding principles state that IRS
will (1) receive submissions from taxpayers and third parties on
approved media, (2) perform up-front manual processing for
nonelectronic submissions, (3) define interface protocols for
electronic submissions, (4) transform nonelectronic submissions into
electronic representations, and (5) perfect submissions.  Similarly,
some of the customer service guiding principles state that IRS will
(1) provide non-face-to-face communication with taxpayers via various
communication media, (2) provide access to taxpayer account and
non-account data without geographic restriction, and (3) accept
taxpayer data via various communication media. 

Using these guiding principles, IRS developed about 3,600 business
requirements that it believes represent IRS' mission needs.  To IRS'
credit, some of these requirements provide for significant
improvements in IRS' financial management capabilities.  For example,
they include

  -- a general ledger that is transaction-based and conforms to
     federal standards;

  -- automated capture of nonfinancial performance information, such
     as the number of transactions, calls, paper returns filed, and
     electronic returns filed;

  -- improvements in management information for receivables;

  -- the ability to trace significant transactions and documents; and

  -- prompt and accurate recording of seized asset transactions. 

However, some of the requirements are insufficiently precise to be
useful in building or acquiring systems.  For instance, our audits of
IRS' financial statements\8 have reported the need for IRS to correct
the serious problems that caused us to designate IRS' accounts
receivable as a high-risk area.\9 To help address these weaknesses,
we have recommended that IRS maintain a subsidiary ledger or similar
mechanism to routinely track the status of and to assist in managing
accounts receivable.  However, the business requirements do not
describe the subsidiary accounts receivable records in sufficient
detail to show that IRS plans to implement such a mechanism.  For
example, they do not specify whether the subsidiary records will
provide for tracking accounts receivable on a
receivable-by-receivable basis and include such information as (1)
the age of the receivable, (2) the status of any payments received,
(3) the accrual of any interest and penalties, (4) the status of the
taxpayer's ability to pay any remaining balances, and (5) the nature
of the receivable (i.e., a balance due, created by examination). 

In another case, a business requirement under the infrastructure
systems core functional area calls for "supporting all five levels"
of the Software Engineering Institute's (SEI) software development
Capability Maturity Model (CMM).\10 The model's five levels of
maturity provide users with a four-step, sequential approach for
incremental process improvement.  In 1995 and 1996, we reported that
IRS was a CMM level 1 organization, SEI's lowest level, meaning that
its software development processes were ad hoc and sometimes chaotic. 
Since a substantial process effort is required to move from CMM level
1 to level 2, and from there to each higher level, IRS' stated
business requirement of "supporting all five levels" is too vague and
imprecise to be meaningful.  Rather than calling for support of all
five CMM levels, IRS needs to require incremental attainment of CMM
levels, as SEI advocates, according to a specified schedule, such as
level 2 within 2 years and level 3 within 4 years.  Without precise
goals, IRS cannot implement an effective process improvement program. 

Also, some of IRS' guiding principles are not reflected by specific
business requirements.  For example, the guiding principles that (1)
45 percent of all taxpayer inquiries be resolved via automated
systems and (2) 95 percent of all inquiries be resolved in the
initial contact could not be reconciled with customer service
business requirements specifying the volume of calls that will be
resolved.  In addition, some key terms in the principles are not well
defined.  For example, the terms "initial contact" and "resolution"
are not defined.  IRS is currently reassessing its guiding principles
and its business requirements. 


--------------------
\8 See, for example, Financial Audit:  Examination of IRS' Fiscal
Year 1995 Financial Statements (GAO/AIMD-96-101, July 11, 1996). 

\9 High-Risk Series:  IRS Management (GAO/HR-97-8, Feb.  1997). 

\10 The Software Engineering Institute was established at Carnegie
Mellon University in 1984 primarily to address the Defense
Department's software development problems.  In 1991, the Institute
developed CMM for use by organizations to evaluate their capability
to consistently and predictably produce high-quality software. 


      ARCHITECTURE IS
      INSUFFICIENTLY DETAILED
---------------------------------------------------------- Letter :5.2

IRS' architecture consists of two components:  a functional
architecture and a technical architecture.  The functional
architecture defines in business terms the activities/subfunctions
that support the six core functional areas discussed earlier,\11 the
relationships among these activities/subfunctions, and the data
required to support these activities/subfunctions.  The technical
architecture defines subsystems, configuration items, data
allocations, interfaces, and common services that collectively
provide a physical view of the target systems environment. 

Consistent with best practices in both industry and government, the
architecture provides traceability among the business requirements,
functions and subfunctions, and subsystems.  That is, each of the
blueprint's approximately 3,600 business requirements can be mapped
to general points in the architecture where they are addressed. 
Traceability is critical to ensuring that systems meet users needs. 

The architecture has other positive attributes.  For example, it
specifies a data subarchitecture consisting of five primary databases
and 18 supporting databases characterized as (1) mission-critical,
such as a financial accounting database required to support revenue
accounting, tracking, and reporting; (2) submissions management
support, such as a state return database containing the data of
electronically filed state tax returns; (3) security requirements
support, such as a security audit database containing data used to
track and audit behaviors observed by technical mechanisms that
secure sensitive data; and (4) systems management and systems
development support, such as a configuration management database
containing information used to manage the development and operational
configuration of the modernization systems. 

Also, the architecture includes a security subarchitecture that
addresses data privacy and security.  It articulates the need to
provide user identification and authentication, to build security
profiles specifying transactions and patterns of transactions for
which a user is authorized, and to limit the transactions that users
can perform to those included in their profiles.  Information
transmitted over data communications networks like the Internet would
be protected through the use of encryption.  Security-relevant audit
data would also be collected, aggregated, and analyzed. 

Despite the architecture's positive attributes, it does not yet
include implementation details and therefore is insufficiently
complete to use in building or acquiring systems.  For example,
whereas the intention to ensure the confidentiality of taxpayer data
is clear, the method to be used is unspecified; and whereas the
intention to use data encryption is clear, encryption products and
approaches are unspecified.  Additionally, the architecture does not
sufficiently define the data administration function, and business
requirements have not been allocated to specific configuration items
(i.e., actual hardware or software components).  As a result, it is
not yet known which of the system components will satisfy which of
the requirements, or how it will do so. 


--------------------
\11 The six areas are (1) submissions processing, (2) corporate data
processing, (3) customer service, (4) compliance, (5) financial
reporting, and (6) information systems infrastructure. 


      SEQUENCING PLAN IS NOT
      SUFFICIENTLY COMPLETE
---------------------------------------------------------- Letter :5.3

To aid in implementing its target architecture, IRS developed a
sequencing plan for transitioning from its current to its target
systems environment.  To do so, IRS first analyzed existing system
platforms, applications, databases, and infrastructures to identify
system duplications and gaps as well as systems with "the best
functionality" that should be preserved.  According to IRS, it then
applied three criteria to define a cost effective, risk mitigated
sequence within which it would introduce new or modified systems and
retire existing systems.  The criteria are: 

  -- focus on systems to support IRS business priorities;

  -- limit the need for complex system interfaces, large-scale data
     conversions, and continuous disruption of business operations;
     and

  -- minimize the need to develop interim systems and interfaces and
     make centralization of duplicative, stand-alone applications and
     systems a priority. 

The result was a sequencing plan that divides the transition into six
incremental phases within which software, hardware, and supporting
infrastructure components will be developed, acquired, and deployed. 
Each phase in turn is segmented into multiple releases, which consist
of actual software/hardware upgrades, improvements/enhancements, and
replacements as well as existing system capability retirements or
deactivations.  According to IRS, the order of the phases is based on
criteria such as IRS' business priorities and a migration plan.  (See
table 3 for a summary of the six phases.)



                                Table 3
                
                   Summary of Sequencing Plan Phases

Phase     Description
--------  ------------------------------------------------------------
Phase 0   Intended to provide a bridge to a modernized systems
          environment through implementation of "stay in business"
          enhancements to existing systems (e.g., year 2000
          conversion).

Phase 1   Intended to provide an integrated data framework to support
          customer service and compliance activities as well as other
          business processes (e.g., tax law assistance, telephone
          operations); focuses on access to mission-critical data,
          nationwide workload distribution, and increased and more
          rapid workload servicing. Composed of five releases.

Phase 2   Intended to provide enhanced examination and collection
          capabilities, improved field compliance capability, and more
          efficient processing of mission-critical data. Composed of
          two releases.

Phase 3   Intended to provide consolidated and standardized corporate
          applications, accelerated issue detection, and enhanced
          automated self-service applications; focuses on reengineered
          processing of master taxpayer data files. Composed of five
          releases.

Phase 4   Intended to provide enhanced and integrated revenue
          accounting and general ledger capabilities to facilitate
          tracking and reporting of financial events and data (e.g.,
          compliance with Federal Accounting Standards Advisory Board
          and Treasury Financial Management System requirements).
          Composed of two releases.

Phase 5   Intended to provide greater control over the receipt and
          processing of paper and electronic returns and payment data
          as well as image-based data capture and retention
          capabilities; focuses on submissions processing activities.
          Composed of two releases.
----------------------------------------------------------------------
While the sequencing plan describes IRS' general intentions for
migrating from its current to its target systems environment, the
sequencing plan does not provide the fundamental and critical detail
needed to fully understand or execute this transition.  For example,
it does not specify (1) the schedule and cost estimates for any of
the phases or releases, (2) the projects that will constitute the
phases or releases, (3) the projects' cost and schedule estimates,
and (4) the projects' interdependencies. 

Additionally, the sequencing plan does not describe precisely what is
intended to occur as subfunctions evolve through the various phases
and releases.  For instance, a subfunction called Case Analysis and
Resolution is shown as new in phase 1/release 1.  It is then shown as
changed in 10 subsequent releases, but none of the planned changes
are explained. 

Further, the sequencing plan indicates that several legacy systems,
such as the Electronic Audit Research Log (an automated tool to
monitor and detect browsing) and the Integrated Data Retrieval System
(the primary system through which IRS employees access taxpayer
accounts), will be replaced.  However, the plan does not identify
what will replace them or how the replacement will be accomplished. 


      SLC PRODUCTS HAVE NOT BEEN
      VALIDATED USING DEFINED,
      IMPLEMENTED SLC PROCESSES
---------------------------------------------------------- Letter :5.4

The processes to validate SLC products, including the business
requirements, the architecture, and the sequencing plan, have not yet
been defined in detail nor have they been implemented.  As a result,
none of the products submitted as part of the IRS blueprint on May
15, 1997, have been validated using defined, implemented SLC
processes. 


   AGENCYWIDE RESPONSIBILITY AND
   AUTHORITY FOR IMPLEMENTING AND
   ENFORCING THE BLUEPRINT HAS NOT
   BEEN ESTABLISHED
------------------------------------------------------------ Letter :6

Information management reforms enacted in the Paperwork Reduction Act
of 1995 and the Clinger-Cohen Act of 1996 direct the heads of major
agencies to appoint CIOs.  The legislation assigns a wide range of
duties and responsibilities to CIOs, including (1) helping to
establish sound information technology investment management
processes, (2) implementing an integrated agencywide technology
architecture, and (3) strengthening the agency's capabilities to
effectively manage information resources and develop needed systems. 
Additionally, this legislation, Office of Management and Budget
guidance,\12 and our research into how leading public and private
sector organizations successfully manage information technology\13
define common tenets for the CIO position.  Among these tenets is the
need for the agencies to support the CIO position with an effective
CIO organization and management framework for implementing agencywide
information technology initiatives. 

The legislation establishes the CIO position at executive branch
agencies and sets forth special requirements for CIOS at the 24
agencies where the Chief Financial Officers Act of 1990, as amended,
established chief financial officer positions.  In addition, we have
supported the establishment of a CIO structure at the agency
subcomponent and bureau levels, such as IRS.\14 Such a management
structure is particularly important in situations where the
departmental subcomponents, like IRS, have large information
technology budgets or are engaged in major modernization efforts that
require the substantial attention and oversight of a CIO.  In the
Conference Report on the Clinger- Cohen Act, the conferees recognized
that agencies may wish to establish CIOs for major subcomponents and
bureaus.\15 These subcomponent-level CIOs should have
responsibilities, authority, and management structures that mirror
those of the departmental CIO. 

In 1995, we reported that IRS had not established an effective
organizational structure to manage systems modernization agencywide. 
Specifically, IRS' modernization management structure was fragmented
and did not provide for agencywide control over all new modernization
systems and all upgrades and replacements of operational systems.  As
a result, we recommended that the Commissioner assign the Associate
Commissioner/Modernization Executive management and control
responsibility for all systems development activities, including
those of IRS' research and development organization.\16 Since that
time, IRS has appointed a CIO and established an Investment Review
Board, and Treasury has taken a more active role in overseeing the
modernization.  However, organizational control over IRS' huge
information technology investment portfolio continues to be a
problem.  The CIO does not control all information systems activity
and thus cannot effectively enforce compliance with established
system process and product standards.  In particular, the CIO does
not have budgetary and organizational authority over all IRS systems
development, research and development, and maintenance activities. 


--------------------
\12 Memorandum for the President's Management Council, "What Makes a
Good CIO?" June 28, 1996. 

\13 Executive Guide:  Improving Mission Performance Through Strategic
Information Management and Technology (GAO/AIMD-94-115, May 1994). 

\14 Government Reform:  Legislation Would Strengthen Federal
Management of Information and Technology (GAO/T-AIMD-95-205, July 25,
1995). 

\15 H.R.  Conf.  Rep.  No.  104-450 at 977 (1996). 

\16 Tax Systems Modernization:  Management and Technical Weaknesses
Must Be Corrected If Modernization Is To Succeed (GAO/AIMD-95-156,
July 26, 1995). 


   CONGRESS HAS LIMITED IRS
   MODERNIZATION SPENDING UNTIL
   BLUEPRINT IS COMPLETED
------------------------------------------------------------ Letter :7

In June 1996, we reported\17 that while IRS had initiated a number of
actions to respond to our recommendations for correcting pervasive
management and technical weaknesses in TSM, many of these actions
were incomplete and none, either individually or collectively,
responded fully to any of our recommendations.  Accordingly, we
suggested that the Congress consider limiting TSM spending to only
cost effective efforts that (1) support ongoing operations and
maintenance; (2) support ongoing IRS efforts to instill requisite SLC
discipline, including completing and enforcing the architecture,
institutionalizing disciplined software development and acquisition
processes, and improving its information technology investment
management; (3) are small, represent low technical risk, and can be
delivered in a relatively short time frame; or (4) involve deploying
already developed systems, only if these systems have been fully
tested, are not premature given the lack of a completed architecture,
and produce a proven, verifiable business value.  The act (P.L. 
104-208, Sept.  30, 1996) and conference report providing IRS' fiscal
year 1997 appropriations limited IRS' information technology spending
to efforts that were consistent with these categories. 

In September 1997, we briefed IRS' appropriations and authorizing
committees on the results of our assessment of IRS' May 15, 1997,
blueprint.  In the conference report accompanying the IRS fiscal year
1998 appropriations act,\18 the conferees agreed with our findings. 
Accordingly, they limited IRS spending for fiscal year 1998 to
efforts that were consistent with the aforementioned spending
categories.  Additionally, IRS' fiscal year 1998 appropriations act
(P.L.  105-61, Oct.  10, 1997) states that fiscal year 1998 or prior
year "Information Systems" appropriations are not available to award
or otherwise initiate a prime contract to implement IRS'
modernization blueprint.  The act also states that fiscal year 1998
"Information Technology Investments" funds are not available for
obligation until IRS and Treasury submit to the Congress a plan for
expenditure that, among other things, implements the blueprint.  The
conference report on the act adds that details of the blueprint need
to be completed before IRS commits to build or acquire new systems. 


--------------------
\17 Tax Systems Modernization:  Actions Underway But IRS Has Not Yet
Corrected Management and Technical Weaknesses (GAO/AIMD-96-106, June
7, 1996). 

\18 H.R.  Conf.  Rep.  No.  105-284 (1997). 


   CONCLUSIONS
------------------------------------------------------------ Letter :8

IRS' May 15, 1997, modernization blueprint provides the foundation
for specifying IRS' future systems environment and a disciplined
approach for delivering this environment.  However, none of the
blueprint components are detailed or complete.  As a result, the
components do not yet provide an adequate basis for effectively and
efficiently developing or acquiring systems.  In addition, the
business requirements, architecture, and sequencing plan have not
been validated using defined and implemented SLC processes.  As a
result, IRS cannot assure itself that these SLC products constitute
the correct course of action for the agency to follow in modernizing
its information systems. 

IRS' CIO recognizes these shortcomings and has committed to
completing, implementing, and enforcing all SLC processes and
completing, validating, and enforcing compliance with all SLC
products before acquiring or developing systems.  However, the CIO
does not have the authority needed to enforce the modernization
blueprint (once it is completed) agencywide.  Until such authority is
assigned, it is uncertain that even a completed blueprint could be
used to overcome existing system incompatibilities and correct
inefficient and ineffective IRS operations. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :9

To ensure that IRS develops a complete blueprint for modernizing its
information systems, we recommend that the Commissioner of Internal
Revenue require the IRS CIO to: 

  -- complete the definition and implementation of all SLC processes,
     including processes for ensuring disciplined software
     development and acquisition and for validating SLC products;

  -- for each phase of the modernization, define business
     requirements and complete the architecture with sufficient
     detail and precision to build or acquire systems;

  -- formulate a sequencing plan that specifies (1) phase and release
     cost and schedule estimates, (2) projects that constitute the
     phases and releases, (3) project cost and schedule estimates,
     (4) project interdependencies, (5) the evolution of
     architectural subfunctions, and (6) the projects that replace
     legacy systems that are eliminated; and

  -- validate the business requirements, architecture, and sequencing
     plan using the completed and implemented SLC processes. 

To ensure that the modernization blueprint is implemented and
enforced agencywide, we recommend that the Commissioner give the CIO: 

  -- responsibility for developing, implementing, and enforcing SLC
     processes and products across IRS and

  -- requisite budgetary and organizational authority over all IRS
     systems development, research and development, and maintenance
     activities. 

Further, until mature SLC processes for developing and acquiring
systems have been implemented across IRS, we recommend that the
Commissioner limit requests for future appropriations for information
technology to only cost- effective efforts that

  -- support ongoing operations and maintenance, including all
     efforts to make IRS systems Year 2000 compliant;

  -- support ongoing IRS efforts to instill requisite SLC discipline,
     including completing and enforcing the architecture,
     institutionalizing disciplined software development and
     acquisition processes, and improving its information technology
     investment management;

  -- are small, represent low technical risk, and can be delivered in
     a relatively short time frame; or

  -- involve deploying already developed systems, only if these
     systems have been fully tested, are not premature given the lack
     of a completed architecture, and produce a proven, verifiable
     business value. 


   AGENCY COMMENTS
----------------------------------------------------------- Letter :10

In its comments, IRS characterized this report as complete,
thoughtful, and balanced.  IRS also agreed that (1) the blueprint is
not yet complete and does not provide sufficient detail and precision
for building or acquiring new systems and (2) the SLC needs to be
completed and implemented as a precondition to completing and
validating the blueprint as well as proceeding with the
modernization.  Additionally, IRS agreed with our concern about
assignment of agency responsibility and authority for managing
information technology and committed itself to addressing each of
these findings in the coming months.  IRS added that the report
provided important insight and perspective in shaping these plans and
moving IRS forward in a responsive and responsible manner. 


--------------------------------------------------------- Letter :10.1

We are sending copies of this report to the Ranking Minority Members
of the Subcommittee on Treasury and General Government, Senate
Committee on Appropriations and Subcommittee on Treasury, Postal
Service, and General Government, House Committee on Appropriations;
the Chairmen and the Ranking Minority Members of the Subcommittee on
Taxation and IRS Oversight, Senate Committee on Finance, the
Subcommittee on Oversight, House Committee on Ways and Means, the
Senate Committee on Governmental Affairs, the House Committee on
Government Reform and Oversight, and the Senate and House Committees
on the Budget.  We are also sending copies to the Secretary of the
Treasury, the Commissioner of Internal Revenue Service, and the
Director of the Office of Management and Budget.  Copies will be
available to others upon request. 

This work was performed under the direction of Dr.  Rona B. 
Stillman, Chief Scientist for Computers and Telecommunications, who
can be reached at (202) 512-6412.  Other contributors to this report
are listed in appendix III. 

Gene L.  Dodaro
Assistant Comptroller General


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

Pursuant to congressional direction in the conference report
accompanying the fiscal year 1997 Omnibus Consolidated Appropriations
Act (P.L.  104-208), on May 15, 1997, IRS issued a blueprint for
defining, directing, and controlling its modernization.  We assessed
the blueprint's four principal components (SLC, business
requirements, architecture, and sequencing plan) to determine whether
the blueprint provided the foundation needed to develop or acquire
modernized systems.  Our specific objectives were to determine
whether

  -- IRS' SLC was complete and consistent with best industry and
     government practices;

  -- the business requirements were sufficiently precise and the
     functional and technical architectures were sufficiently
     complete to build or acquire systems and the sequencing plan was
     sufficiently complete to understand the transition to the target
     systems environment;

  -- the business requirements, functional and technical
     architectures, and sequencing plan had been validated using
     defined and implemented SLC processes; and

  -- the information technology management structure was conducive to
     effective implementation and enforcement of the blueprint. 

To accomplish our objectives, we interviewed senior IRS officials
responsible for developing the modernization blueprint to determine
how the blueprint was derived, including the processes followed, the
participants involved, and the bases for and analyses supporting
decisions made in developing it.  We then reviewed and analyzed each
component of the blueprint and its related documentation for
completeness and sufficiency. 

With respect to IRS' SLC, we analyzed the overview document in
relation to generally accepted government and industry standards for
life cycle management of information technology investments.\1 In the
case of business requirements, we focused on two functional
areas--customer service and financial reporting--because of their
criticality to IRS' tax administration mission and because we have
completed a significant amount of audit work in these areas.  For
customer service, we determined whether the business requirements
were consistent with IRS' stated guiding principles.  For financial
reporting, we examined whether IRS' requirements addressed Federal
Accounting Standards Advisory Board standards as well as concerns
that we have raised about IRS' financial management capabilities in
prior GAO reports.\2 We also reviewed business requirements in IRS'
other core functional areas to determine whether they were generally
clear and unambiguous. 

Concerning the architecture and sequencing plan, we compared both
documents to published architectural guidance\3 to determine their
completeness and specificity.  For each of the blueprint components,
we also questioned senior IRS officials about the documents'
completeness and specificity, as well as IRS' plans for evolving,
validating, implementing, and enforcing them. 

With respect to IRS' information technology management structure, we
interviewed IRS officials about assignment of organizational and
budgetary authority over IRS information technology investments as
well as other formal mechanisms in place or planned to enforce IRS
information technology investment (research and development, new
systems development or acquisition, and system maintenance)
conformance to the modernization blueprint. 

In August and September 1997, we briefed senior IRS and Treasury
officials, including the Acting Commissioner of Internal Revenue, the
IRS CIO, the Treasury CIO, and the Treasury Acting Chief Financial
Officer, on our assessment results, including our conclusions and
recommendations. 

We performed our work at IRS headquarters in Washington, D.C.,
between May 1997 and September 1997 in accordance with generally
accepted government auditing standards. 



(See figure in printed edition.)Appendix II

--------------------
\1 Examples include DOD Directive 5000.1, Defense Acquisition, May
1996; DOD 5000.2-R, Mandatory Procedures for Major Defense
Acquisition Programs and Major Automated Information Systems, 1996;
IEEE/EIA 12207.1, Guide for Information Technology--Software Life
Cycle Processes:  Life Cycle Data, Dec.  1996; USAF Software
Technology Support Center, Guidelines for Successful Acquisition and
Management of Software-Intensive Systems, Version 2.0, June 1996; and
A Systems Engineering Capability Maturity Model, Version 1.1,
Carnegie Mellon University, Software Engineering Institute,
(SECMM-95-01, CMU/SEI-95-003, Nov.  1995). 

\2 See, for example, Financial Audit:  Examination of IRS' Fiscal
Year 1995 Financial Statements (GAO/AIMD-96-101, July 11, 1996). 

\3 Examples include Strategic Information Planning:  Framework for
Designing and Developing System Architectures (GAO/IMTEC-92-51, June
1992); Design Specification for IEEE Standard 1471--Recommended
Practice for Architectural Description, Aug.  21, 1997; Defense
Information Systems Agency, Center for Standards, Technical
Architecture Framework for Information Management, Version 3.0, April
1996; Office of Management and Budget, Memorandum for the Heads of
Executive Departments and Agencies, "Information Technology
Architectures," June 18, 1997. 


COMMENTS FROM THE INTERNAL REVENUE
SERVICE
=========================================================== Appendix I



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Keith Rhodes, Technical Director
Gregory Kutz, Associate Director
Randy Hite, Senior Assistant Director
Gary Mountjoy, Assistant Director
Nabajyoti Barkakati, Technical Assistant Director
John Martin, Technical Assistant Director
Madhav Panwar, Technical Assistant Director
Robert Pewanick, Assistant Director
Steve Sebastian, Assistant Director
Hai Tran, Technical Assistant Director
Suzanne Burns, Senior Information Systems Analyst
Agnes Spruill, Senior Information Systems Analyst

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

Lynda Willis, Director
David Attianese, Assistant Director
Sherrie Russ, Senior Evaluator
Nilsa Perez, Senior Evaluator
Monika Gomez, Evaluator

ATLANTA FIELD OFFICE

Carl Higginbotham, Senior Information Systems Analyst
Tonia Brown, Senior Information Systems Analyst
James Douglas, Auditor

SEATTLE FIELD OFFICE

Karlin Richardson, Senior Evaluator
Elizabeth Naftchi, Auditor

*** End of document. ***