Records Management: National Archives and Records		 
Administration's Acquisition of Major System Faces Risks	 
(22-AUG-03, GAO-03-880).					 
                                                                 
Increasingly, government records involve documents that are	 
electronically created and stored. In support of its mission to  
manage and archive these records and ensure access to the	 
"essential evidence" that they contain, the National Archives and
Records Administration (NARA) is acquiring an advanced Electronic
Records Archives (ERA). GAO was asked to determine, among other  
things, how the ERA program's system acquisition policies, plans,
and practices conform to industry standards and how well NARA is 
meeting the ERA program's cost and schedule.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-880 					        
    ACCNO:   A08059						        
  TITLE:     Records Management: National Archives and Records	      
Administration's Acquisition of Major System Faces Risks	 
     DATE:   08/22/2003 
  SUBJECT:   Archives						 
	     Internal controls					 
	     Records management 				 
	     Performance measures				 
	     Federal records management 			 
	     Information technology				 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-03-880

                                       A

Letter

August 22, 2003 The Honorable Ernest J. Istook, Jr. Chairman Subcommittee
on Transportation, Treasury and Independent Agencies Committee on
Appropriations House of Representatives Dear Mr. Chairman: The National
Archives and Records Administration (NARA) has initiated the Electronic
Records Archives (ERA), a project to acquire a major information system to
maintain and provide access to permanent federal

records independent of the technological state of the art and the
varieties of record formats. NARA*s goal is for this system to preserve
and provide access to any kind of electronic record, so that the agency
can carry out its mission into the future. However, as we have reported
previously, 1 acquiring a major information technology (IT) system like
ERA is a

significant challenge for a relatively small organization such as NARA,
which has no previous experience in acquiring major information systems.

Our objectives were to determine 1. the status of NARA*s efforts to
establish organizational capabilities for

acquiring major information systems, 2. how the ERA project*s system
acquisition policies, plans, and practices

conform to industry standards, and 3. how well NARA is meeting the ERA
project*s cost and schedule goals. To achieve these objectives, we
reviewed agency information technology policies and practices, and we
obtained and analyzed ERA program documents on system acquisition, project
management, and cost and schedule. We evaluated ERA documents and
practices by the standards selected by the program to guide the ERA
acquisition, including specifically those of the Institute of Electrical
and Electronics Engineers (IEEE). We also interviewed NARA information
resources management and ERA 1 U. S. General Accounting Office,
Information Management: Challenges in Managing and

Preserving Electronic Records, GAO- 02- 586 (Washington, D. C.: June 17,
2002).

program officials. We performed our work from July 2002 to May 2003 in
accordance with generally accepted government auditing standards.

On May 15, 2003, we provided your staff with a briefing on the results of
our study, which included procurement- sensitive information. The slides
from that briefing* with procurement- sensitive information removed* are
included as appendix I to this report. The purpose of this report is to
provide the published briefing slides to you and to officially transmit
our recommendations to the Archivist of the United States.

In summary, our briefing made three points:  To establish its
capabilities for acquiring major information systems,

NARA has made progress in implementing the key management areas of IT
investment management, enterprise architecture, and IT security. However,
these capabilities are not yet completely established, and NARA has more
work to do to implement our prior recommendations in this area. 2
Specifically, while NARA continues to develop an enterprise architecture,
it does not plan to complete its target architecture 3 in time to
influence the ERA system definition and requirements. Furthermore, while
NARA has completed some elements of an information security program,
several key areas have not yet been addressed, such as (1) individual
system security plans and (2) security certification and accreditation of
its information systems. 4 Without strong IT management capabilities, NARA
increases its risk of failing to achieve

2 U. S. General Accounting Office, Information Management: Challenges in
Managing and Preserving Electronic Records, GAO- 02- 586 (Washington, D.
C.: June 17, 2002). 3 A target architecture is one aspect of an overall
enterprise architecture. An enterprise architecture describes (in useful
models, diagrams, and narrative) the mode of operation for an enterprise,
such as an agency or mission area. It provides a perspective on enterprise

operations both for the current (* as is*) operating environment and for
the target (* to be*) environment. More specifically, the target
environment is the business and technology environment that is planned to
result from aligning technology investments with the strategic goals of
the enterprise (including requisite changes to the operations,
organization, and management of both the automated and manual processes of
the enterprise). An enterprise architecture also includes a transition
plan for sequencing from the current to the target environment. 4 Under
OMB policy, responsible federal officials are required to make a security

determination (called accreditation) to authorize placing IT systems into
operation. In order for these officials to make sound, risk- based
decisions, a security evaluation (known as certification) of the IT system
is needed.

cost, schedule, and performance objectives for its information systems,
including ERA.

 The ERA program has developed policies, plans, and practices to guide
and manage its acquisition of the ERA system. In many cases, however,
these do not conform to the chosen standards or to applicable federal

acquisition guidance. In developing its plans and policies, NARA elected
to follow recognized industry standards set forth by IEEE. However, key
policy and planning documents are missing elements that are required by
the standards. For example, one key document is the concept of operations,
which should describe the characteristics of a proposed system from the
users* viewpoint. The ERA Concept of Operations does not include several
key elements required by the IEEE standard, including a complete
description of the proposed systems. In addition, key ERA staff positions
are unfilled, including positions that NARA determined are needed to carry
out system acquisition tasks. Without adequate policy and planning
documents* which form the basis of the acquisition* and adequate staff to
carry out these policies and plans, NARA increases the long- term risks to
the acquisition.

 Finally, NARA cannot adequately track the cost and schedule of the ERA
project because the schedule does not include all program tasks and lacks
a work breakdown structure. 5 In addition, NARA has not used earned value
management* a performance- based technique that allows managers to track
the budget against the schedule* to track the ERA cost and schedule
programwide. Without the ability to track cost and schedule effectively,
NARA increases the risk that ERA funds will not be used efficiently or
effectively, quality problems will limit the usefulness of the ERA system,
and the ERA system will not be delivered according to established
milestones.

In light of the challenges NARA faces in acquiring ERA, NARA will face
significant difficulties unless it addresses the weaknesses described
above.

5 A work breakdown structure provides descriptions of all work activities
for a given project that are detailed enough to expose risk factors and
allow accurate estimates of resource requirements and schedule duration
for each work activity. Each major work activity should include standard
elements such as assigned personnel, resource budgets, estimated task
duration, and dependencies among work activities. An adequate work
breakdown structure is a prerequisite to program tracking, allowing
managers to measure how well a program is achieving its cost and schedule
goals.

Recommendations for To reduce the risks associated with NARA*s efforts to
design and acquire

Executive Action the Electronic Records Archives, we recommend that the U.
S. Archivist

direct the NARA Chief Information Officer to address weaknesses in the
acquisition policies, plans, and practices by

 revising the ERA Life Cycle document and associated procedures and
practices to conform to IEEE standards;

 revising the ERA Concept of Operations to conform to IEEE standards,
including a complete description of the current and proposed systems;

 revising the ERA Acquisition Strategy to conform to IEEE standards and
the Federal Acquisition Regulation;

 revising the ERA Risk Management Plan to provide processes and
procedures specific to the ERA program;  revising the ERA Quality
Assurance Plan to conform to appropriate industry standards, establishing
a vigorous, independent ERA quality assessment process, and providing the
staffing resources necessary to ensure that quality assessment duties are
performed effectively; and  filling key vacant ERA positions.

Further, we recommend that the U. S. Archivist direct the NARA Chief
Information Officer to immediately address weaknesses in tracking cost and
schedule by

 developing an ERA schedule that is based on a comprehensive work
breakdown structure (including associated costs and other resources) and
establishes dependencies between successor and predecessor tasks; and

 using earned value management to capture and monitor progress for the
entire ERA program.

Agency Comments In providing written comments on a draft of this report
(which are reprinted in app. II), the Archivist of the United States
indicated that NARA

is acting to implement our recommendations and provided an update on the
status of the agency*s efforts to do so. In addition, the Archivist

provided a clarification regarding the ERA acquisition schedule, stating
that there will be two to three releases for each of the increments in the
schedule.

We are sending copies of this report to the Chairmen and Ranking Minority
Members of the Subcommittee on Transportation, Treasury and Independent
Agencies, House Committee on Appropriations; the Subcommittee on
Transportation, Treasury and General Government, Senate Committee on
Appropriations; the Subcommittee on Technology, Information Policy,
Intergovernmental Relations and the Census, House

Committee on Government Reform; and the Subcommittee on Oversight of
Government Management, the Federal Workforce and the District of Columbia,
the Senate Committee on Governmental Affairs. We are also

sending copies to the Archivist of the United States. We will also make
copies available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at www. gao. gov.

Should you have any question on matters contained in this report, please
contact me at (202) 512- 6240 or by E- mail at koontzl@ gao. gov. Other
key contributors to this report were Timothy Case, Barbara Collier, Mirko
Dolak, and Elena Epps.

Sincerely yours, Linda D. Koontz Director, Information Management Issues

Appendi xes National Archives and Records Administration*s Acquisition of
Electronic

Appendi x I

Records Archives National Archives and Records Administration*s
Acquisition of Electronic Records Archives Briefing for the Staff of the
Subcommittee on Transportation, Treasury and Independent Agencies

House Appropriations Committee May 15, 2003

1

Outline of Briefing Introduction Objectives, Scope, and Methodology
Results in Brief Background Results

 IT Organizational Capabilities  Systems Acquisition Policies, Plans,
and Practices  Cost and Schedule Conclusions Recommendations Agency
Comments

2

Introduction The mission of the National Archives and Records
Administration (NARA) is to ensure *ready access to essential evidence*
for the public, the President, the Congress, and the Courts. NARA is
responsible for oversight of records management and archiving, which
increasingly involves dealing with documents that are electronically
created and stored. Accordingly, NARA is acquiring an advanced Electronic
Records Archives (ERA) system.

 NARA*s goals are for this system to preserve and provide access to any
kind of electronic record, free from dependency on any specific hardware
or software, so that the agency can carry out its mission into the future.

 According to NARA, the ERA system will be a distributed system, allowing
storage and management of massive record collections at a variety of
installations, with accessibility provided via the Internet.

3

Introduction In June 2002, we issued a report that assessed the ERA
program and NARA*s key organizational capabilities for acquiring a major
information system. 1 As we noted in that report, acquiring a major
information technology (IT) system such as ERA is a significant challenge
for a relatively small organization like NARA, whose IT management
capabilities are relatively limited. NARA has no previous experience in
acquiring major information systems.

In our 2002 report we recommended that the Archivist  revise the ERA
project schedule so that it reflected estimates of the amount of work and

resources required to complete each task, and schedule enough time for
NARA to complete essential planning tasks, and

 strengthen IT management capabilities by (1) implementing an IT
investment management process, (2) developing an enterprise architecture,
and (3) improving information security.

1 U. S. General Accounting Office, Information Management: Challenges in
Managing and Preserving Electronic Records , GAO- 02- 586 (Washington, D.
C.: June 17, 2002).

4

Objectives, Scope, and Methodology

Objectives

As agreed with the Subcommittee on Transportation, Treasury and
Independent Agencies, House Appropriations Committee, our work focused on
three objectives:

 What is the status of NARA*s efforts to establish organizational
capabilities for acquiring major information systems?

 How do the ERA project*s system acquisition policies, plans, and
practices conform to industry standards?

 How well is NARA meeting the ERA project*s cost and schedule goals? 5

Objectives, Scope, and Methodology

Scope and Methodology

To accomplish our objectives, we  obtained and evaluated policies and
conducted interviews to determine the status of

NARA*s efforts to establish organizational capabilities in IT investment
management, enterprise architecture, and IT security;

 analyzed ERA system acquisition and project management documents,
including the

Acquisition Strategy, Life Cycle, and Concept of Operations .  analyzed
the project*s cost and schedule documents;  analyzed ERA risk management,
program assessment, and verification and validation

reports; and  interviewed NARA information resource management and ERA
program officials and

contractor staff to understand the scope and contents of project documents
and plans and to clarify information in supporting documentation.

In our review of the ERA program*s policies, plans, and practices, we
evaluated the implementation of life cycle processes against the Institute
of Electrical and Electronics Engineers (IEEE) standards selected by the
program to guide the ERA acquisition, as well as applicable federal
acquisition regulations and guidance.

6

Objectives, Scope, and Methodology We also reviewed NARA*s efforts to
staff the ERA acquisition program. We have requested the revised life
cycle cost estimates for the ERA system, but these have not yet been
provided. Consequently, we are currently unable to assess the current
estimated life cycle costs and benefits of the proposed system.

We performed our work from July 2002 to May 2003 in accordance with
generally accepted government auditing standards.

7

Results in Brief: Objective 1

Information Technology Management

NARA has made some progress in establishing capabilities for acquiring
major information systems, but key IT organizational capabilities are not
yet completely established. NARA is still working to establish its
information technology investment management, enterprise architecture, and
information security capabilities:

 NARA has strengthened its information technology investment management.
 NARA is continuing to develop an enterprise architecture, but it does
not plan to

complete its target architecture in time to influence the ERA system
definition and requirements.

 NARA completed some elements of an information security program, but
several key areas have not yet been addressed, such as individual system
security plans and certification and accreditation of its information
systems.

Without strong IT organizational capabilities in place, the risk is
increased that NARA will not be able to achieve cost, schedule, and
performance objectives for information systems, including ERA.

8

Results in Brief: Objective 2

Systems Acquisition

The ERA program has developed policies, plans, and practices to guide and
manage its acquisition of the ERA system, and has elected to follow
Institute of Electrical and Electronics Engineers (IEEE) standards in this
effort. The ERA program intends to apply these standards to the
development of the plans and policies that will guide the practices to be
followed in acquiring the ERA system. However, in many cases, its
policies, plans, and practices do not conform to the chosen standards or
to applicable federal acquisition guidance. For example:

 Key policy and planning documents (such as the ERA Risk Management Plan,
Quality Assurance Plan, and Acquisition Strategy ) are missing elements
that are required by the standards and federal acquisition guidance.

Such shortcomings in ERA policies, plans, and practices could result in
serious long- term risks to the cost, schedule, and performance of the ERA
program.

9

Results in Brief: Objective 3

Tracking Cost and Schedule

NARA is unable to objectively track the cost and schedule of the ERA
project. The ERA schedule does not include all program tasks and lacks a
work breakdown structure.

If NARA cannot track how well the ERA program is meeting cost and
schedule, the likelihood is increased that ERA funds will not be used
efficiently or effectively, quality problems will limit the usefulness of
the ERA system, and the ERA system will not be delivered according to
established milestones.

To reduce the risks associated with NARA*s efforts to design and acquire
the Electronic Records Archive, we are making several recommendations to
the U. S. Archivist.

In oral comments on a draft of this briefing, NARA generally agreed with
our findings, conclusions, and recommendations.

10

Background

Acquisition Strategy Developing the ERA Acquisition Strategy

NARA envisions ERA to be a major information system with the ability to
authentically preserve and provide access to massive volumes of all types
and formats of electronic records, free from dependency on any specific
hardware or software. The system may be based on persistent object
preservation, a method of accommodating a variety of file formats that is
the subject of research sponsored by NARA and other organizations. A
leading candidate for capturing the necessary information is the
Extensible Markup Language (XML), which provides a means for *tagging*
(annotating) information in a meaningful fashion that can be readily
interpreted by disparate computer systems. 3

3 For more information on XML, see our earlier report: U. S. General
Accounting Office, Electronic Government: Challenges to Effective Adoption
of the Extensible Markup Language , GAO- 02- 327 (Washington, D. C.: Apr.
5, 2002).

11

Background

Acquisition Strategy

However, as pointed out in our earlier report, 4 the solution to the
electronic records archiving challenge has yet to be developed. No
electronic archive system exists that is comparable in complexity or scale
to NARA*s vision. 5 Further, some key technologies associated with
electronic document archiving and storage are not yet available
commercially. As a result, ERA is technically and managerially complex and
challenging, requiring the development of an advanced architecture for the
conversion and preservation of electronic records.

To guide its acquisition of the ERA system, the ERA program has adopted
IEEE standards for software life cycle processes. 6 The standards
establish a common framework for the acquisition of software products and
services, defines processes and tasks that are to be tailored and applied
during the acquisition of a system, and identifies specific guidance
applicable to the acquisition process. One standard identifies five
primary processes: acquisition, supply, development, operations, and
maintenance.

4 U. S. General Accounting Office, Information Management: Challenges in
Managing and Preserving Electronic Records , GAO- 02- 586 (Washington, D.
C.: June 17, 2002). 5 NARA officials believe that many relevant hardware
and software components are available in the marketplace, and that
potential integrators have both an understanding of NARA*s needs and
appropriate strategies for addressing them. 6 The Institute of Electrical
and Electronics Engineers, 12207.0 Standard for Information Technology
Software Life Cycle Processes; 12207. 1 Standard for Information
Technology Software Life Cycle Processes Life Cycle Data; and 12207.2
Standard for Information Technology Software Life Cycle Processes
Implementation Considerations.

12

Background

Acquisition Strategy

The ERA program is currently in the acquisition life cycle process. It
plans to take the following acquisition approach:

 define the ERA concept,  develop ERA requirements,  release a draft
and final Request for Proposal,  award two contracts for a design
competition, and  based on the results of the competition, select a
single contractor who will develop the

ERA system in five increments, beginning in January 2005. ERA also needs
to follow applicable federal acquisition requirements for major
information systems. Specifically, it was required to submit to OMB an
evaluation of alternatives to be considered and to develop life cycle cost
and benefit estimates of the proposed ERA system.

According to the acquisition schedule, shown on the following slide,
development of the first increment will take 2 years to complete and will
encompass key ERA capabilities related to the records management process,
while subsequent increments will add additional functionality and record
types.

The expected completion date for the development of the ERA system is
December 2010. 13

Background

Acquisition Strategy ERA Acquisition Schedule

14

Background

Other NARA Initiatives Other NARA Initiatives Related to Electronic
Records

Besides the ERA acquisition, NARA*s strategy for archiving electronic
records includes, among other things, three other initiatives:

 Expanding the capability of its current systems for archiving electronic
records by accommodating additional electronic record formats and volumes.

 Through the Records Management Initiatives, revising NARA*s records
disposition policies and processes, including reengineering of NARA*s life
cycle management of records.

 Through the Electronic Records Management initiative, providing the
guidance and tools that agencies need to manage their records in
electronic form, including policy guidance on new electronic record
formats accepted by NARA.

15

Background

Technical Assessments National Academy of Sciences Assessment of ERA

NARA has funded two independent assessments of ERA by the National Academy
of Sciences.

The first assessment, due in May 2003, is to assess the viability of an
advanced architecture for file format conversion and encapsulation being
researched by the National Partnership for Advanced Computational
Infrastructure.

The second assessment is to  identify and evaluate alternative methods
for digital preservation of records,  examine the operational use of the
Internet for digital archiving,  identify aspects of the preservation of
electronic records that cannot be adequately

addressed either by state- of- the art information technology or by
technologies under development, and

 determine the feasibility of commercializing new ideas from research. It
is to be completed from 6 to 9 months after the first assessment.

16

Background

ERA Program Management ERA Program Management

The ERA program management office is responsible for the development of
ERA policies, plans, guidance, and procedures.

 NARA hired a contractor, Integrated Computer Engineering (ICE), Inc., 7
to assist in developing the capability to design, acquire, and manage the
ERA system.

 ICE is responsible for developing many ERA acquisition documents and for
validating and verifying that these documents conform to industry
standards for content and structure.

The following slide shows the organizational chart for the program
management office, showing government staff positions. 8

7 On January 15, 2002, American Systems Corporation (ASC) announced its
acquisition of ICE, Inc. According to the ERA project manager, this change
does not affect the status of NARA*s contract with ICE, Inc. 8 According
to NARA, it is considering organizational changes that are under review
based on findings of its most recent assessment of the ERA program and
other lessons learned.

17

Background

ERA Program Management ERA Program Organization Chart

18

Objective 1: IT Organizational Capabilities In our earlier report, we
recommended that the Archivist strengthen key IT organizational
capabilities by

(1) implementing an IT investment management process, (2) developing an
enterprise architecture, and (3) improving information security. NARA has
made some progress in strengthening its capabilities in these areas, but
they are not yet completely established.

19

Objective 1: IT Organizational Capabilities

IT Investment Management IT Investment Management

An IT investment management process is an integrated approach to managing
IT investments that provides for the continuous identification, selection,
control, life cycle management, and evaluation of IT investments. The
Clinger- Cohen Act and OMB guidance emphasize the need to have investment
management processes and information to help ensure that IT projects are
being implemented at acceptable costs and within reasonable and expected
time frames and that they are contributing to tangible, observable
improvements in mission performance (i. e., that projects are meeting the
cost, schedule, and performance commitments upon which their approval was
justified).

GAO*s Information Technology Investment Management (ITIM) maturity
framework 9 defines critical processes pertaining to IT investment
management and oversight. Among other things these processes provide for
establishing investment decision- making bodies responsible for selecting
and controlling IT investments by (1) understanding, for example, each
project*s expected return on investment and associated costs, schedule,
and performance commitments; (2) regularly determining each project*s
progress toward these expectations and commitments; and (3) taking
corrective actions to address deviations.

9 U. S. General Accounting Office, Information Technology Investment
Management: A Framework for Assessing and Improving Process Maturity
(Exposure Draft), GAO/ AIMD- 10.1.23 (Washington, D. C.: May 2000).

20

Objective 1: IT Organizational Capabilities

IT Investment Management

NARA has taken steps to strengthen its IT investment management processes.
Among the actions it has completed are the following:

 NARA has established an IT investment review board, which receives
monthly briefings on strategic projects covering schedule and risks.

 NARA has updated its directive addressing IT investment management. 
Initial versions of policy documentation have been completed for two of
the three phases

of IT investment management: control and evaluation.  NARA has completed
interim guidance for analyzing the life cycle benefits, costs, and

risks of IT. 21

Objective 1: IT Organizational Capabilities

Enterprise Architecture Enterprise Architecture

An enterprise architecture provides a description* in useful models,
diagrams, and narrative* of the mode of operation for an agency. It
describes the agency in both

(1) logical terms, such as interrelated business locations and users; and
(2) technical terms, such as hardware, software, data, communications, and
security

attributes and standards. An enterprise architecture provides these
perspectives both for the *as is* environment (baseline) and for the *to
be* environment (target). It also consists of technical reference model
and technical standards used by the agency, as well as a plan to
transition from the baseline to the target environment.

NARA has ongoing efforts to complete an enterprise architecture, which are
expected to continue over the next 2 years. It developed initial versions
of its enterprise architecture, including a baseline and target
architecture, a technical reference model, and standards profile.
According to NARA*s Chief Technology Officer, while this initial effort
provided a basis for an architecture, it was not complete and NARA is
continuing to develop a more comprehensive version.

22

Objective 1: IT Organizational Capabilities

Enterprise Architecture

Beginning in July 2003, NARA plans to address a number of activities
associated with its enterprise architecture, including

 procuring and installing software tools to manage the development of its
enterprise architecture,

 continuing to refine data management processes and definitions, and 
establishing an information security architecture. NARA has not completed
the definition of its *to be* architecture, which will provide a framework
for defining the ERA system*s requirements. The ERA program currently
plans to complete the definition of requirements by the end of June 2003.

23

Objective 1: IT Organizational Capabilities

Information Security Information Security

Federal legislation and guidance for information security require
organizations, among other things, to establish an information security
program, including the following activities:

 Develop information security policy and procedures.  Develop system
security plans for networks, facilities, and systems or groups of

information systems.  Perform risk assessments.  Determine the
sensitivity and criticality of systems.  Establish certification and
accreditation programs for information systems. As a result of security
assessments conducted by NARA and its Inspector General, the Archivist
declared NARA*s information security a material weakness in fiscal year
2000; it remains a material weakness.

In response to the recommendations in our earlier report, NARA has taken
steps to establish an information security program. In fiscal year 2002,
NARA

 completed an information security policy and security control handbooks,
 addressed several information security vulnerabilities, and  conducted
a limited vulnerability assessment and risk analysis of NARA*s network.

24

Objective 1: IT Organizational Capabilities

Information Security

However, NARA*s IT security program is incomplete in several areas,
including the following:  Security plans for all NARA systems have not
been developed.  NARA has not implemented a security risk assessment
program.  It has not determined the sensitivity and criticality of
systems. NARA indicated that in fiscal year 2003, it plans to

 complete certification and accreditation of 41 IT systems, and  address
outstanding security risks and remove security as a material weakness.
Nevertheless, without a fully established information security program,
the risk to the planned ERA system and its archived data is increased.

25

Objective 2: Systems Acquisition

Policies, Plans, and Practices

To guide its acquisition of the ERA system, the program has adopted an
IEEE standard for software life cycle processes (IEEE 12207 and associated
standards). These standards were expected to be used in developing the
life cycle plan and processes that the program is following to acquire the
ERA system:

 developing the ERA Life Cycle document,  defining a concept of
operations,  developing requirements,  creating an acquisition strategy,
 performing risk management,  performing configuration management, and 
conducting quality assurance.

26

Objective 2: Systems Acquisition

ERA Life Cycle ERA Life Cycle

The ERA Life Cycle document describes the life cycle of the ERA system
from conceptualization of ideas through retirement, as well as processes
for acquiring and supplying software products and services for the ERA
system.

However, the ERA Life Cycle document does not meet all applicable IEEE
standards:  It states that it was tailored to the IEEE 12207 standards
but fails to identify which

elements were excluded or modified.  It does not document key activities,
such as the processes, activities, and tasks needed

for contract preparation, including all tasks associated with development
of the Request for Proposal.

 It does not show the proposed approach, including the design competition
and the incremental approach.

Without a complete, well- documented life cycle that meets applicable
standards, NARA and the ERA program are impeded in their ability to manage
and track key acquisition processes and activities.

27

Objective 2: Systems Acquisition

Concept of Operations Concept of Operations

According to IEEE standards, the Concept of Operations is a user- oriented
document that describes the characteristics of a proposed system from the
users' viewpoint. The document becomes the framework for all subsequent
activities leading to system deployment. The IEEE standard describes key
elements that should be included in this document, including major system
components, interfaces to external systems, and performance
characteristics such as speed, throughput, and volume.

The ERA Concept of Operations describes the high- level operational
characteristics of the ERA system from the viewpoint of the users,
developer, and other stakeholders. The

Concept provides justification for the proposed system, identifies classes
of ERA users, and describes operational scenarios. It does not include
several key elements required by the IEEE standard, including

 a complete description of the proposed system,  the system*s modes of
operation under different circumstances (for example, regular,

degraded, emergency, backup, etc). The ERA program is planning to update
its Concept of Operations to address these elements by August 18, 2003.

28

Objective 2: Systems Acquisition

ERA Requirements ERA Requirements

Requirements provide the blueprint that system developers and program
managers use to design, develop, and acquire a system. It is critical that
requirements be carefully defined and that they flow directly from the
organization*s concept of operations (how the organization*s day- to- day
operations are or will be carried out to meet mission needs).

ERA requirements are currently being defined; NARA expects them to be
completed by June 30, 2003.

Accordingly, we did not review them for their conformance to industry
standards. 29

Objective 2: Systems Acquisition

Acquisition Strategy Acquisition Strategy

An acquisition strategy is a description of how an organization plans to
acquire a system. It establishes the framework by which detailed
acquisition planning and program execution will be accomplished and
communicated to key stakeholders. For ERA, the acquisition strategy should
conform to IEEE standards and must conform to the Federal Acquisition
Regulation (FAR) for acquisition planning.

The ERA Acquisition Strategy does not fully conform to applicable
standards, according to an assessment by the ERA program:

 It does not satisfy all FAR requirements: 28 of 39 content requirements
are not satisfied, including the identification of acquisition risks, the
description of the ERA cost model and life cycle costs, and the
establishment of detailed milestones for the acquisition process.

 It does not meet all IEEE standards: 15 of 32 content requirements are
not satisfied, including the establishment and implementation of an
acquisition planning strategy, standards for the preparation of contract
requirements, and criteria for the selection of a qualified supplier.

Unless it adheres to these standards and requirements, NARA increases the
risk that its strategy will not be clearly understood by key stakeholders.

30

Objective 2: Systems Acquisition

Risk Management Risk Management

In acquisition, risk management is a process for identifying potential
problems before they occur and adjusting the acquisition to mitigate
problems and to decrease the chance of their occurring. Risk management
includes developing a project risk management plan; identifying and
prioritizing potential problems; implementing risk mitigation strategies,
as required; and tracking and reporting progress against the plans.

NARA has developed an ERA Risk Management Plan . However, the ERA program
has not fully established a risk management process to comply with IEEE
requirements:

 In the ERA Risk Management Plan, the risk planning policy is incomplete.
For example, the plan does not discuss how resources are to be made
available to treat risks or how risks are to be communicated to and
reviewed by stakeholders.

 The plan is written at a high level of generality and has not been
defined specifically for the ERA program. For example, procedures for risk
identification and risk analysis are not specific to the ERA program.

In the absence of a fully established risk management process, NARA may
miss opportunities to avoid or mitigate predictable risks in its ERA
acquisition.

31

Objective 2: Systems Acquisition

Configuration Management Configuration Management Plan

The ERA Configuration Management Plan , based on the IEEE standard, is
intended to establish and maintain the integrity and control of the
products of the ERA program through its life cycle. The IEEE standard for
software configuration plans describes classes of information that should
be included in the plan. These include identifying

 who is responsible for accomplishing planned activities,  what
configuration management project activities are to be performed,  when,
in relation to other project activities, the activities are to be
scheduled, and  what tools and human resources are required for executing
the plan. A verification and validation assessment of the Configuration
Management Plan by ERA contractors found that while the plan did not
satisfy all of the above IEEE requirements, the amount of information
included in the plan was appropriate for the point in the acquisition
process at which it was written.

32

Objective 2: Systems Acquisition

Quality Assurance Quality Assurance

In IT acquisition, quality assurance describes processes for providing
independent assessment of the requirements and processes for developing
and producing a system or software. Quality assurance includes developing
a quality assurance plan, determining applicable processes and product
standards to be followed, and conducting reviews to ensure that the
product and process standards are followed. Quality assessments should
take place throughout the life cycle of an acquisition.

The ERA program has developed the ERA Quality Assurance Plan , which
references IEEE standards for software quality assurance. However,
elements required by the standard are absent. For example, the plan

 does not include ERA documentation to be reviewed,  lacks criteria by
which to assess documentation,  does not specify quality assurance tasks
to be performed, and  lacks estimates of resources to be expended.
Without a fully established quality assurance plan, the ERA program is at
risk of generating products that do not meet requirements.

33

Objective 2: Systems Acquisition

Policies, Plans, and Practices

In addition to the life cycle processes described by IEEE standards, ERA
is subject to federal acquisition requirements. 10 Among other things,
these call for

 an evaluation of alternatives to be considered and  the development of
life cycle cost and benefit estimates of proposed systems Also associated
with the ERA acquisition process are NARA*s efforts to staff the ERA
acquisition program.

10 Office of Management and Budget Circular A- 109, Major System
Acquisitions ; OMB Circular A- 11, Preparing and Submitting Budget
Estimates .

34

Objective 2: Systems Acquisition

ERA Staffing ERA Staffing

NARA has made progress in staffing the ERA program, but staffing may pose
a risk to ERA. NARA has determined that to carry out the acquisition tasks
discussed earlier, it will need 46 staff: 24 government staff and 22
contractor staff. According to program officials, funding shortfalls have
prevented them from hiring the needed ERA staff. Currently, all 22
contractor staff are onboard, but only 15 of the 24 projected ERA
government staff have been hired.

Although we have not evaluated the appropriate staffing level, some
staffing shortages are significant. Three key government positions* the
business manager and contract and financial management specialists* are
yet to be hired. In addition, staff for other key positions were only
recently hired: the chief system engineer and the risk management and
quality assurance specialists. All these positions are important to the
quality and completeness of key program processes.

35

Objective 3: Tracking Cost and Schedule A project schedule with an
appropriate work breakdown structure is a prerequisite to program
tracking, allowing managers to measure how well the program is achieving
its cost and schedule goals. The work breakdown structure should be
detailed enough to expose all risk factors and allow accurate estimates of
resource requirements and schedule duration for each work activity. Each
major work activity should include standard elements such as assigned
personnel, resource budgets, estimated task duration, and dependencies
among work activities.

Work activities can be measured through performance- based techniques such
as earned value management, which allows managers to track the budget
against the schedule. *Earned value* may be used to determine if work is
being done at a higher or lower cost/ performance rate than was planned.

OMB requires the use of such techniques in the monitoring of the cost,
schedule, and performance of system acquisition projects. 14

14 Office of Management and Budget Circular A- 11. 36

Objective 3: Tracking Cost and Schedule In our 2002 report, we recommended
that the ERA project schedule be revised to reflect estimates of the
amount of work and resources required to complete each task, and that NARA
schedule enough time to complete essential planning tasks.

While the ERA program has developed a more detailed project schedule that
includes standard elements, NARA has not yet fully carried out our
recommendation, as these elements are not yet complete:

 The project schedule omits significant tasks and activities, including 
the process to reengineer the agency*s life cycle business processes, upon
which

ERA requirements are being developed, and  the activity by ERA
contractors to verify and validate ERA project management and

acquisition documentation for conformance to industry standards. 37

Objective 3: Tracking Cost and Schedule NARA has indicated that it plans
to use earned value management to assess performance programwide, but this
plan has not yet been implemented.

 In the absence of a program schedule that includes all program tasks and
a work breakdown structure with associated costs, the ERA program cannot
use earned value management to track ERA cost and schedule.

The lack of earned value management impairs NARA*s ability to track and
meet future project milestones.

The ERA program is in an early phase of acquisition planning and has not
yet been required to meet many significant milestones. To date, NARA has
met a major ERA milestone* the definition of the ERA concept.

Meeting major milestones will become more important and more challenging
in later phases of the acquisition.

38

Conclusions In acquiring ERA, NARA faces significant challenges. ERA will
be a major information system; NARA has no previous experience in
acquiring major information systems. Further, no comparable electronic
archive system is now in existence, in terms of either complexity or
scale. Finally, technology necessary to address some key requirements of
ERA is not commercially available and will have to be developed.

In light of these challenges, NARA will face significant difficulties in
its ERA acquisition unless it addresses

 its IT organizational capabilities;  ERA system acquisition policies,
plans, and practices; and  its ability to control ERA*s cost and
schedule. NARA has made progress implementing the key management areas of
IT investment management, enterprise architecture, and IT security, but
NARA has more work to do to implement our prior recommendations in this
area.

39

Conclusions Without strong acquisition policies, plans, and practices, the
risk is increased that the ERA system will fail to meet user expectations,
will cost more than currently estimated, and will be delivered later than
currently planned. Specifically, NARA and the ERA program have not

 followed the IEEE 12207 standards and associated guidance in defining
and managing the ERA acquisition process,

 developed ERA acquisition processes and associated documentation in
sufficient detail to allow program managers and NARA executives to manage
and oversee the program, or

 implemented the defined acquisition processes and practices according to
these documented policies and plans.

Further, NARA is unable to effectively track and assess the status of the
ERA program because its program schedule does not include all program
tasks and lacks a work breakdown structure.

40

Recommendations To reduce the risks associated with NARA*s efforts to
design and acquire the Electronic Records Archives, we recommend that the
U. S. Archivist direct the NARA Chief Information Officer to do the
following:

 Address weaknesses in the acquisition policies, plans, and practices by
 revising the ERA Life Cycle document and associated procedures and
practices to

conform to IEEE standards;  revising the ERA Concept of Operations to
conform to IEEE standards, including a

complete description of the current and proposed systems;  revising the
ERA Acquisition Strategy to conform to IEEE standards and the Federal

Acquisition Regulation;  revising the ERA Risk Management Plan to provide
processes and procedures

specific to the ERA program;  revising the ERA Quality Assurance Plan to
conform to appropriate industry

standards, establishing a vigorous, independent ERA quality assessment
process, and providing the staffing resources necessary to ensure that
quality assessment duties are performed effectively; and

 filling key vacant ERA positions. 41

Recommendations  Immediately address weaknesses in tracking cost and
schedule by

 developing an ERA schedule that is based on a comprehensive work
breakdown structure (including associated costs and other resources) and
establishes dependencies between successor and predecessor tasks; and

 Using earned value management to capture and monitor progress for the
entire ERA program.

42

Agency Comments NARA provided us with oral comments on a draft of this
briefing during a meeting held on April 24, 2003, attended by the Deputy
Archivist, the ERA program manager, and other agency officials. These
officials generally agreed with our findings, conclusions, and
recommendations. They indicated that NARA is already addressing the
weaknesses in ERA*s acquisition policies, plans, and practices identified
through a verification and validation activity. NARA officials also
provided clarifications and additional technical comments, which we have
incorporated into the briefing as appropriate.

43

Comments from the National Archives and

Appendi x II Records Administration

(310371)

Report to the Chairman, Subcommittee on Transportation, Treasury and
Independent Agencies, Committee on Appropriations, House of
Representatives

August 2003 RECORDS MANAGEMENT National Archives and Records
Administration*s Acquisition of Major System Faces Risks

GAO- 03- 880

Contents Letter 1

Recommendations for Executive Action 4 Agency Comments 4

Appendixes

Appendix I: National Archives and Records Administration*s Acquisition of
Electronic Records Archives 6

Appendix II: Comments from the National Archives and Records
Administration 49

Abbreviations

ERA Electronic Records Archives IEEE Institute of Electrical and
Electronics Engineers IT information technology NARA National Archives and
Records Administration

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

a

GAO United States General Accounting Office

The ERA program*s acquisition policies, plans, and practices do not
consistently conform to industry standards. In developing the plans and
policies to guide its acquisition of the ERA system, NARA elected to
follow recognized industry standards set forth by the Institute of
Electrical and Electronics Engineers (IEEE). However, key policy and
planning documents are missing elements that are required by the

standards. For example, one key document is the concept of operations,
which should describe the characteristics of a proposed system from the
users* viewpoint. The ERA Concept of Operations does not include several
key elements required by the IEEE standard, including a complete
description of the proposed system. Because these policy and planning
documents form the basis of the acquisition, such shortcomings could
result in serious long- term risks to the cost, schedule, and performance
of the ERA program.

NARA cannot adequately track the cost and schedule of the ERA program. A
comprehensive schedule with an appropriate work breakdown structure is a
prerequisite to program tracking, as it allows managers to measure how
well the program is achieving its cost and schedule goals. To achieve
upcoming major milestones (some of which are shown in the figure), the
program must successfully complete a complex series of tasks. However, the
program schedule omits significant tasks and activities; for example, it
does not include the process to reengineer the agency*s life cycle
business processes, which will be crucial to defining requirements. In
addition, the schedule lacks a work breakdown structure, which would allow
accurate estimates of the resources and time required for each work
activity. If NARA cannot track how well the program is meeting cost and
schedule, the risk is increased that funds may not be used efficiently or
effectively, quality problems may limit the usefulness of the resulting
system, and the system may not be delivered according to established
milestones.

Major Milestones in ERA Acquisition

Increasingly, government records involve documents that are electronically
created and stored. In support of its mission to manage and archive these
records and ensure access to the *essential evidence* that they contain,
the National Archives and Records

Administration (NARA) is acquiring an advanced Electronic Records Archives
(ERA). GAO was asked to determine, among other things, how the ERA
program*s system acquisition policies, plans, and

practices conform to industry standards and how well NARA is meeting the
ERA program*s cost and schedule. To reduce the risks associated with

NARA*s efforts to design and acquire ERA, GAO recommends that the U. S.
Archivist direct the NARA Chief Information Officer to take a range of
actions, including revising key planning documents and developing a
schedule that is based on a comprehensive work breakdown structure
(including

associated costs and other resources).

In comments on the draft report, the Archivist of the United States
accepted our recommendations and provided an update on NARA*s efforts to
implement them. The Archivist also provided additional

information on the ERA acquisition schedule.

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 880. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Linda Koontz at (202) 512- 6240 or koontzl@ gao. gov.
Highlights of GAO- 03- 880, a report to the

Chairman, Subcommittee on Transportation, Treasury and Independent
Agencies, Committee on Appropriations, House of Representatives August
2003

RECORDS MANAGEMENT

National Archives and Records Administration*s Acquisition of Major System
Faces Risks

Page i GAO- 03- 880 Electronic Archive Acquisition

Page 1 GAO- 03- 880 Electronic Archive Acquisition United States General
Accounting Office Washington, D. C. 20548

Page 1 GAO- 03- 880 Electronic Archive Acquisition

A

Page 2 GAO- 03- 880 Electronic Archive Acquisition

Page 3 GAO- 03- 880 Electronic Archive Acquisition

Page 4 GAO- 03- 880 Electronic Archive Acquisition

Page 5 GAO- 03- 880 Electronic Archive Acquisition

Page 6 GAO- 03- 880 Electronic Archive Acquisition

Appendix I

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 7 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 8 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 9 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 10 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 11 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 12 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 13 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 14 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 15 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 16 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 17 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 18 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 19 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 20 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 21 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 22 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 23 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 24 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 25 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 26 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 27 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 28 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 29 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 30 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 31 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 32 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 33 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 34 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 35 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 36 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 37 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 38 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 39 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 40 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 41 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 42 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 43 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 44 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 45 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 46 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 47 GAO- 03- 880 Electronic Archive Acquisition

Appendix I National Archives and Records Administration*s Acquisition of
Electronic Records Archives

Page 48 GAO- 03- 880 Electronic Archive Acquisition

Page 49 GAO- 03- 880 Electronic Archive Acquisition

Appendix II

Appendix II Comments from the National Archives and Records Administration

Page 50 GAO- 03- 880 Electronic Archive Acquisition

GAO*s Mission The General Accounting Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting its
constitutional responsibilities

and to help improve the performance and accountability of the federal
government for the American people. GAO examines the use of public funds;
evaluates federal programs and policies; and provides analyses,
recommendations, and other assistance to help Congress make informed
oversight, policy, and funding decisions. GAO*s commitment to good
government is reflected in its core values of accountability, integrity,
and reliability.

Obtaining Copies of GAO Reports and Testimony

The fastest and easiest way to obtain copies of GAO documents at no cost
is through the Internet. GAO*s Web site (www. gao. gov) contains abstracts
and fulltext files of current reports and testimony and an expanding
archive of older products. The Web site features a search engine to help
you locate documents using key words and phrases. You can print these
documents in their entirety, including charts and other graphics.

Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as *Today*s Reports,* on its
Web site daily. The list contains links to the full- text document files.
To have GAO e- mail this

list to you every afternoon, go to www. gao. gov and select *Subscribe to
e- mail alerts* under the *Order GAO Products* heading. Order by Mail or
Phone The first copy of each printed report is free. Additional copies are
$2 each. A check

or money order should be made out to the Superintendent of Documents. GAO
also accepts VISA and Mastercard. Orders for 100 or more copies mailed to
a single address are discounted 25 percent. Orders should be sent to:

U. S. General Accounting Office 441 G Street NW, Room LM Washington, D. C.
20548 To order by Phone: Voice: (202) 512- 6000 TDD: (202) 512- 2537 Fax:
(202) 512- 6061

To Report Fraud, Waste, and Abuse in Federal Programs

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

Public Affairs Jeff Nelligan, Managing Director, NelliganJ@ gao. gov (202)
512- 4800 U. S. General Accounting Office, 441 G Street NW, Room 7149
Washington, D. C. 20548

United States General Accounting Office Washington, D. C. 20548- 0001
Official Business Penalty for Private Use $300 Address Service Requested

Presorted Standard Postage & Fees Paid

GAO Permit No. GI00
*** End of document. ***