Business Systems Modernization: Internal Revenue Service's Fiscal
Year 2005 Expenditure Plan (22-JUL-05, GAO-05-774).		 
                                                                 
The Internal Revenue Service's (IRS) Business Systems		 
Modernization (BSM) program is a multibillion-dollar, high-risk, 
highly complex effort that involves the development and delivery 
of a number of modernized information systems intended to replace
the agency's aging business and tax processing systems. As	 
required by law, IRS submitted its fiscal year 2005 expenditure  
plan in April 2005 to congressional appropriations committees,	 
requesting about $203 million from the BSM account. GAO's	 
objectives in reviewing the plan were to (1) determine whether it
satisfied the conditions specified in the law, (2) determine what
progress IRS had made in implementing our prior recommendations, 
and (3) provide any other observations about the plan and IRS's  
BSM program.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-774 					        
    ACCNO:   A30860						        
  TITLE:     Business Systems Modernization: Internal Revenue	      
Service's Fiscal Year 2005 Expenditure Plan			 
     DATE:   07/22/2005 
  SUBJECT:   Cost analysis					 
	     Cost overruns					 
	     Human capital management				 
	     Internal controls					 
	     Program evaluation 				 
	     Risk management					 
	     Schedule slippages 				 
	     Strategic planning 				 
	     Tax administration 				 
	     IRS Business Systems Modernization 		 
	     Program						 
                                                                 

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GAO-05-774

     

     * Report to Congressional Committees
          * July 2005
     * BUSINESS SYSTEMS MODERNIZATION
          * Internal Revenue Service's Fiscal Year 2005 Expenditure Plan
     * Contents
          * Recommendation for Executive Action
          * Agency Comments
     * Briefing Slides from the May 20, 2005, Briefing to the Senate and
       House Appropriations Subcommittee Staffs
     * Comments from the Internal Revenue Service
     * GAO Contact and Staff Acknowledgments

                 United States Government Accountability Office

Report to Congressional Committees

GAO

July 2005

BUSINESS SYSTEMS MODERNIZATION

          Internal Revenue Service's Fiscal Year 2005 Expenditure Plan

                                       a

GAO-05-774

BUSINESS SYSTEMS MODERNIZATION

Internal Revenue Service's Fiscal Year 2005 Expenditure Plan

  What GAO Found

IRS's fiscal year 2005 expenditure plan, which requested about $203
million for the BSM program, satisfies the conditions specified in the
law. These conditions include meeting the Office of Management and
Budget's capital planning and investment control review requirements and
complying with federal systems acquisition requirements and management
practices.

IRS has made progress in implementing GAO's recommendations to improve its
modernization management controls and capabilities. However, certain
controls and capabilities related to configuration management, human
capital management, cost and schedule estimating, contract management, and
post-implementation reviews have not yet been fully implemented or
institutionalized. Weaknesses in these controls and capabilities have
contributed, at least in part, to project cost and schedule shortfalls.

GAO's observations on the expenditure plan and BSM program include the
following:

     o During the past year, IRS has made progress implementing BSM, but much
       work remains. While IRS has deployed initial versions of several
       modernized tax processing and business systems, these deliveries only
       represent the initial steps toward modernization. For example, initial
       deliveries of the Customer Account Data Engine (CADE) project will
       process less than 1 percent of all tax returns filed this year.
     o IRS has not met long-term cost and schedule estimates, but its new
       incremental approach contributed to short-term improvements. In the
       second quarter of fiscal year 2004, systems modernization projects
       were rebaselined, and IRS adopted a new strategy to develop and deploy
       more manageable project segments. Since that time, IRS has met its
       short-term cost estimates and delivery dates for the initial releases
       of CADE and the Custodial Accounting Project. However, concerns remain
       about IRS's ability to continue meeting cost and schedule targets.
     o IRS has made progress toward addressing issues raised in independent
       BSM assessments and implementing program improvement initiatives, but
       high-priority issues and challenges remain in areas such as quality
       assurance, the change request process, and integrated schedule and
       baseline management.
     o The BSM vision and strategy need revision in order to clearly show
       what the modernization program will consist of, when it will be
       completed, and at what cost. For example, the latest modernization
       strategy referenced in an expenditure plan dates back to fiscal year
       2002, and its planned delivery dates no longer reflect reality.

                 United States Government Accountability Office

Contents

Letter                                                                   1 
                            Recommendation for Executive Action             4 
                            Agency Comments                                 4 
Appendixes                                                              
                Appendix I: Briefing Slides from the May 20, 2005,         
                            Briefing to the Senate                         
                            and House Appropriations Subcommittee Staffs    6 
              Appendix II:  Comments from the Internal Revenue Service     54 
              Appendix III: GAO Contact and Staff Acknowledgments          56 

                                 Abbreviations

BSM                      Business Systems Modernization                    
CIO                      Chief Information Officer                         
IRS                      Internal Revenue Service                          
OMB                                        Office of Management and Budget 
PRIME                                    Prime Systems Integration Support 

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separately.

A

United States Government Accountability Office Washington, D.C. 20548

July 22, 2005

The Honorable Christopher S. Bond Chairman The Honorable Patty Murray
Ranking Member Subcommittee on Transportation, Treasury,

the Judiciary, Housing and Urban Development,

and Related Agencies Committee on Appropriations United States Senate

The Honorable Joe Knollenberg Chairman The Honorable John W. Olver Ranking
Member Subcommittee on the Departments of Transportation,

Treasury, and Housing and Urban Development, the Judiciary, District of
Columbia, and Independent Agencies

Committee on Appropriations House of Representatives

As required by law, the Internal Revenue Service (IRS) submitted its
fiscal year 2005 expenditure plan in April 2005 to the congressional
appropriations committees, requesting about $203 million from the Business
Systems Modernization (BSM) account. Our objectives in reviewing the plan
were to (1) determine whether the plan satisfied the conditions specified
in the law,1 (2) determine what progress IRS had made in implementing our
prior recommendations, and (3) provide any other observations about the
plan and IRS's BSM program.

1BSM funds are unavailable until the IRS submits to congressional
appropriations committees for approval a modernization expenditure plan
that (1) meets the Office of Management and Budget's (OMB) capital
planning and investment control review requirements; (2) complies with
IRS's enterprise architecture; (3) conforms with IRS's enterprise life
cycle methodology; (4) complies with federal acquisition rules,
requirements, guidelines, and systems acquisition management practices;
(5) is approved by IRS, the Department of the Treasury, and OMB; and (6)
is reviewed by GAO. See P.L. 108-447, Div. H, Title II, Dec. 8, 2004, for
fiscal year 2005 funding.

On May 20, 2005, we briefed your respective offices on the results of our
review. This report transmits the materials we used at the briefing and
provides the recommendation that we made to the Commissioner of Internal
Revenue. The full briefing materials, including our scope and methodology,
are reprinted as appendix I.

In summary, we made the following major points:

     o IRS's fiscal year 2005 plan satisfies each of the six legislative
       conditions.
     o Although IRS has made progress in implementing our recommendations and
       improving its modernization management controls and capabilities,
       certain controls and capabilities related to configuration management,
       human capital management, cost and schedule estimating, contract
       management, and post-implementation reviews have not yet been fully
       implemented or institutionalized. Weaknesses in these controls and
       capabilities have contributed, at least in part, to BSM project cost
       and schedule shortfalls.
     o IRS has made progress in implementing BSM, but much work remains. IRS
       has deployed initial phases of several modernized systems during the
       past year, including the Customer Account Data Engine (the new
       taxpayer information database), Modernized e-File (a new electronic
       filing system), and e-Services (a new Web portal and electronic
       services for tax practitioners). The deployment of these systems
       provides several benefits to the taxpayer, including faster processing
       of tax refunds and more timely response to customer inquiries.
       However, these deliveries represent only a beginning, and much more
       remains to be done by IRS before the BSM program is complete. For
       example, the Customer Account Data Engine will process less than 1
       percent of all tax returns filed this year.
          * IRS has not met long-term cost and schedule estimates, but its
            new incremental approach contributed to short-term improvements.
            Historically, BSM has experienced significant cost overruns and
            schedule slippages. In the second quarter of fiscal year 2004,
            IRS rebaselined its projects and decided to change its BSM
            project strategy to enable it to develop and deploy more
            manageable project segments. Since making this change, IRS has
            met its short-term cost estimates and scheduled delivery dates
            for initial releases of the Customer Account Data Engine and the
            Custodial Accounting Project. However, concerns remain about
            IRS's ability to continue meeting its cost and schedule
          * targets because of persistent weaknesses in the agency's
            capabilities to deliver modernization initiatives on time and
            within budget.
     o IRS has made progress toward addressing issues raised in independent
       BSM assessments and implementing program improvement initiatives, but
       significant issues and challenges remain. IRS has made further
       progress in addressing the items in its BSM Challenges Plan,
       completing 44 of the 48 action items. In addition, the current IRS
       Associate Chief Information Officer (CIO) for BSM developed a new BSM
       program improvement framework, which covers all identified issues and
       allows the agency to regularly identify, prioritize, and resolve these
       issues. Currently, there are 17 high-priority initiatives. These
       initiatives address key areas, including quality assurance, cost and
       schedule estimation, the change request process, and integrated
       schedule management and baseline management. If it is effectively
       implemented, this program improvement process should help IRS manage
       program risk. However, until the agency has addressed its
       high-priority initiatives, BSM remains at risk of further cost
       overruns and delays in its delivery of critical functionality.
     o IRS is adjusting the BSM program in response to its assessment of the
       prime systems integration support (PRIME) contractor's performance and
       budget reductions. As a result of its assessment of the PRIME
       contractor's performance in 2004, IRS began to transfer program
       management operations from the contractor to the agency. Subsequent
       budget reductions resulted in further shifting of responsibilities
       away from the contractor. IRS has taken over significant
       responsibilities for program management, systems engineering, and
       business integration. Also, IRS has made adjustments to project
       funding allocations and future delivery schedules. Because IRS does
       not have all the expertise and processes needed to discharge these
       responsibilities effectively, these changes could impact future
       modernization budgets and cause further delays in implementing
       functionality that is intended to provide benefits to IRS and to
       taxpayers.
     o The BSM vision and strategy need revision. The BSM program is based on
       visions and strategies developed several years ago. The significant
       delays experienced by the program over the past few years and the
       changes brought about by the shift of significant program
       responsibilities from the PRIME contractor to IRS, indicate a need for
       IRS to revisit its long-term goals, strategies, and plans for BSM,

  Recommendation for Executive Action

including an assessment of when significant future BSM functionality would
be delivered and at what cost.

To address the many changes associated with the BSM and to clearly
describe what the modernization program is intended to accomplish, when it
will be completed, and at what cost, we recommend that the Commissioner of
Internal Revenue direct the CIO to take the following action:

o  fully revisit the vision and strategy for the BSM program and develop a
new set of long-term goals, strategies, and plans that are consistent with
the budgetary outlook and IRS's management capabilities.

In providing written comments on a draft of this report, the Commissioner

  Agency Comments

of Internal Revenue agreed with our findings and described the actions
that IRS is taking to implement our recommendation. The Commissioner also
provided additional information on various improvement efforts that IRS
has undertaken. The Commissioner's written comments are reprinted in
appendix II.

We are sending copies of this report to the Chairmen and Ranking Members
of other Senate and House committees and subcommittees that have
appropriation, authorization, and oversight responsibilities for the
Internal Revenue Service. We are also sending copies to the Commissioner
of Internal Revenue, the Secretary of the Treasury, the Chairman of the
IRS Oversight Board, and the Director of the Office of Management and
Budget. Copies are also available at no charge on the GAO Web site at

http://www.gao.gov.

Should you or your offices have questions on matters discussed in this
report, please contact me at (202) 512-9286 or [email protected]. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix III.

David A. Powner

Director, Information Technology Management Issues

Appendix I

Briefing Slides from the May 20, 2005, Briefing to the Senate and House
Appropriations Subcommittee Staffs

Review of IRS's Fiscal Year 2005 Business Systems Modernization Expenditure Plan

  Briefing for the staffs of the Subcommittee on Transportation, Treasury, the
Judiciary, Housing and Urban Development, and Related Agencies Senate Committee
    on Appropriations and Subcommittee on the Departments of Transportation,
    Treasury, and Housing and Urban Development, the Judiciary, District of
      Columbia, and Independent Agencies House Committee on Appropriations

                                  May 20, 2005

                                  Page 1 of 48

x Introduction and Objectives x Results in Brief x Background x Scope
and Methodology x Results x Conclusions x Recommendation for Executive
Action x Agency Comments x Appendixes

x I - Description of Business Systems Modernization (BSM) Projects and
Program-Level Initiatives x II - Additional Detail on IRS's Fiscal Year
2005 BSM Expenditure Plan x III - IRS Reported Project Cost/Schedule
Changes

Page 2 of 48

The Internal Revenue Service (IRS) has long relied on obsolete automated
systems for key operational and financial management functions, and its
attempts to modernize these computer systems span several decades. IRS's
multibillion-dollar Business Systems Modernization (BSM) program,
initiated in fiscal year 1999, is the agency's latest attempt to modernize
its systems. IRS contracted with Computer Sciences Corporation (CSC) as
the prime systems integration support (PRIME) contractor to assist with
designing, developing, and integrating a new set of information systems
that are intended to replace IRS's aging business and tax processing
systems. BSM is a high-risk, highly complex program that involves the
development and delivery of a number of modernized tax administration,
internal management, and core infrastructure projects that are intended to
provide improved and expanded service to taxpayers as well as IRS internal
business efficiencies.

As mandated by IRS's fiscal year 2005 appropriations act,1 BSM funds are
not available until IRS submits a modernization expenditure plan for
approval to the congressional appropriations committees. This plan must

x meet the capital planning and investment control review requirements
      established by the Office of
      Management and Budget (OMB);
x comply with IRS's enterprise architecture;2
x conform with IRS's enterprise life cycle methodology;3
x comply with     acquisition rules, requirements, guidelines, and        
      federal         systems acquisition management                          
      practices;      
x be approved by IRS, Treasury, and OMB; and
x be reviewed by GAO.

1

P.L. 108-447, Div. H, Title II, Dec. 8, 2004.

2

An enterprise architecture (EA) is an institutional blueprint defining how
an enterprise operates today, in both business and technology terms, and
intends to operate in the future. An EA also includes a roadmap for
transitioning between these environments. 3IRS refers to its life cycle
management program as the enterprise life cycle (ELC).

Page 3 of 48

Since mid-1999, IRS has submitted a series of expenditure or "spending"
plans requesting release of BSM appropriated funds. To date, about $1.9
billion has been appropriated for BSM, including about $203 million for
fiscal year 2005.4 Of the $1.9 billion appropriated, about $1.7 billion
has been released.

On April 4, 2005, IRS submitted its fiscal year 2005 expenditure plan to
the relevant House and Senate appropriations subcommittees, seeking
release of $203 million from the BSM account.

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

x determine whether IRS's fiscal year 2005 expenditure plan satisfies the
legislative conditions specified in IRS's appropriations act,

x determine IRS's progress in implementing our prior recommendations, and

x provide any other observations about the plan and IRS's BSM program.

P.L. 108-447, Div. H, Title II, Dec. 8, 2004. IRS uses the appropriated
totals to cover contractor costs related to the BSM program. IRS funds
internal costs for managing BSM with another appropriation. These costs
are not tracked separately for BSM-related activities.

Page 4 of 48

IRS's fiscal year 2005 plan satisfies each of the six legislative
conditions.

Although IRS has made progress in implementing our recommendations and
improving its modernization management controls and capabilities, certain
controls and capabilities related to configuration management, human
capital management, cost and schedule estimating, contract management, and
post-implementation reviews have not yet been fully implemented or
institutionalized. Weaknesses in these controls and capabilities have
contributed, at least in part, to BSM project cost and schedule
shortfalls.

We have five observations related to the BSM program and fiscal year 2005
expenditure plan:

x IRS Has Made Progress in Implementing BSM, but Much Work Remains. IRS
has deployed initial phases of several modernized systems during the past
year, including the Customer Account Data Engine (the new taxpayer
information database), Modernized e-File (a new electronic filing system),
and e-Services (a new Web portal and electronic services for tax
practitioners). The deployment of these systems provided several benefits
to the taxpayer, including faster processing of tax refunds and more
timely response to customer inquiries. However, these deliveries represent
only a beginning, and much more remains to be done by IRS before the BSM
program is complete. For example, the Customer Account Data Engine will
process less than 1 percent of all tax returns filed this year.

x IRS Has Not Met Long-Term Cost and Schedule Estimates, but Incremental
Approach Contributed to Short-Term Improvements. Historically, BSM has
experienced significant cost overruns and schedule slippages. In the
second quarter of fiscal year 2004, IRS rebaselined its projects and
decided to change its BSM project strategy to develop and deploy more
manageable project segments. Since making this change, IRS has met its
short-term cost estimates and scheduled delivery dates for initial
releases of the Customer Account Data Engine and the Custodial Accounting
Project. However, concerns remain about IRS's ability to continue meeting
its cost and schedule targets due to its history of poor cost and schedule
management.

Page 5 of 48

x IRS Has Made Progress Toward Addressing Issues Raised in Independent
BSM Assessments and Implementing Program Improvement Initiatives, but
Significant Issues and Challenges Remain. IRS has made further progress in
addressing the items in its BSM Challenges Plan, completing 44 of the 48
action items. In addition, the current IRS Associate Chief Information
Officer (CIO) for BSM developed a new BSM program improvement framework,
which covers all identified issues and allows the agency to regularly
identify, prioritize, and resolve these issues. Currently, there are 17
high-priority initiatives. These initiatives address key areas, including
quality assurance, cost and schedule estimation, the change request
process, and integrated schedule management and baseline management. If
effectively implemented, this program improvement process should help IRS
manage program risk. However, until the agency has addressed its
high-priority initiatives, BSM remains at risk of further cost overruns
and delays in delivery of critical functionality.

x IRS is Adjusting the BSM Program in Response to its Assessment of the
PRIME Contractor's Performance and Budget Reductions. As a result of its
assessment of the PRIME contractor's performance in 2004, IRS began to
move program management operations from the contractor to the agency.
Subsequent budget reductions resulted in further shifting of
responsibilities from the contractor. IRS has taken over significant
responsibilities for program management, systems engineering, and business
integration. Also, IRS has made adjustments to project funding allocations
and future delivery schedules. While it is too early to tell what effect
these changes will ultimately have on the BSM program, IRS's adjustments
are not without risk, could impact future modernization budgets, and will
cause further delays in implementing functionality that is intended to
provide benefits to IRS and to taxpayers.

x The BSM Vision and Strategy Need Revision. The BSM program is based on
visions and strategies developed several years ago. The significant delays
experienced by the program over the past few years and the changes brought
about by the shift of significant program responsibilities from the PRIME
contractor to IRS, indicate a need for IRS to revisit its long-term goals,
strategies, and plans for BSM, including an assessment of when significant
future BSM functionality would be delivered and at what cost.

Page 6 of 48

To address the many changes associated with the BSM and clearly describe
what the modernization program is intended to accomplish, when it will be
completed, and at what cost, we are recommending that the Commissioner of
Internal Revenue direct the CIO to fully revisit the vision and strategy
for the BSM program and develop a new set of long-term goals, strategies,
and plans that are consistent with the budgetary outlook and IRS's
management capabilities.

In commenting on a draft of this briefing, the Associate CIO for BSM
generally agreed with it and provided technical comments.

Page 7 of 48

To date, we have reviewed and reported on 11 requests for BSM funding releases:

x Since mid-1999, we have reported5  on the risks associated with IRS's
                                         approach of building systems while
      concurrently developing and implementing program management
      capabilities-for example, having a fully
      operational program management office and implementing its enterprise
      life cycle (ELC). IRS's ELC is a
      structured method for managing system         investments throughout    
      modernization program and project             their                     
      life cycles. We reported that attempting to acquire modernized systems
      before having the requisite
      management capability increases the risk that systems will experience
      cost, schedule, and performance
      shortfalls.         
      We have also        that the risk of cost increases and schedule delays
x reported6           associated with building
      systems without the requisite management controls is not as severe
      early in projects' life cycles when they
      are being planned (project definition and preliminary system design),
      but escalates as projects are built
      (detailed design and development) and implemented (enterprise
      deployment).        
      In the case of IRS and its ELC, a key point of risk escalation is
x milestone 3, at the end of the system
      architecture phase. From this point through design and development
      (milestone 4) to system deployment
      (milestone 5), risk will increase significantly if requisite controls
      are not in place. In our June 2003 report,7
      we identified key IRS projects that were approaching or had passed
      milestone 4 that were experiencing
      cost, schedule, and performance shortfalls, and concluded that program
      risks were heightened. In our
      November 2004 report,8     we stated that key IRS projects were
                                 continuing to incur significant cost
                                 increases

5

For example, see GAO, Business Systems Modernization: Results of Review of
IRS' March 2001 Expenditure Plan, GAO-01-716 (Washington, D.C.: June 29,
2001) and Internal Revenue Service: Progress Continues But Serious
Management Challenges Remain, GAO-01-562T (Washington, D.C.: April 2,
2001).

6

For example, see GAO, Tax Systems Modernization: Results of Review of IRS'
Third Expenditure Plan, GAO-01-227 (Washington, D.C.: January 22, 2001)
and Business Systems Modernization: IRS Needs to Better Balance Management
Capacity with Systems Acquisition Workload, GAO-02-356 (Washington, D.C.:
February 28, 2002).

7

GAO, Business Systems Modernization: IRS Has Made Significant Progress in
Improving Its Management Controls, but Risks Remain, GAO-03-768
(Washington, D.C.: June 27, 2003).

8

GAO, Business Systems Modernization: IRS's Fiscal Year 2004 Expenditure
Plan, GAO-05-46 (Washington, D.C.: November 17, 2004).

Page 8 of 48

and schedule delays, and that independent assessments of the BSM program
had identified significant weaknesses and risks, consistent with our prior
reviews.

x We also reported, in November 2004, that IRS had begun to implement a
risk-adjusted cost estimating methodology. Prior to the fiscal year 2004
expenditure plan, IRS's project cost estimates consisted of "point
estimates" that did not include adjustments for project risk. In the
fiscal year 2004 plan, IRS added a "risk adjustment" amount to the cost
estimate for each BSM project, in order to allow for variance and
uncertainty. These risk-adjusted cost estimates incorporated ranges based
on the uncertainty in the point estimates and adjusted those estimates to
provide a specified level of confidence, given the inherent variability.

IRS's fiscal year 2005 expenditure plan describes the agency's efforts to

x continue ongoing program-level initiatives through the first week of
November 2005 and core infrastructure projects through the end of November
2005,

x continue four ongoing tax administration projects (e-Services,
Modernized e-File Releases 3.1 and 3.2, and Customer Account Data Engine -
Individual Master File Release 1) to their next milestones,

x begin two new releases of tax administration projects (Modernized
e-File Release 4 and Customer Account Data Engine Release 2),

x establish a consolidated program management/transition management
activity for all Customer Account Data Engine project releases, and

x continue its ongoing work on the Filing and Payment Compliance/Private
Debt Collection Release 1 project (formerly known as Collection Contract
Support and allowing the selection of cases that can be handled by private
collection agencies) as well as the Customer Account Data Engine
Requirements Management/Engineering initiative (formerly known as the
Business Rules Management Solution), using funding provided in fiscal year
2004.

Page 9 of 48

However, as a result of current budget constraints, IRS will not be
pursuing any internal management support projects during fiscal year 2005.
Specifically, IRS has decided to terminate the Custodial Accounting
Project and postpone the next release of the Integrated Financial System
indefinitely.

Table 1 shows a financial summary of the plan.

Page 10 of 48

                                   Background

Table 1: Summary of IRS's Fiscal Year 2005 BSM Expenditure Plan (in thousands of
                                   dollars)a

                                                                  Amount      
                                                                 requested    
Project category b                                         
Tax administration projects                                        $90,587 
Core infrastructure projects                                        62,000 
Subtotal                                                           152,587 
Architecture, integration & management                     
Architecture & integration                                          18,506 
Business integration                                                 5,909 
Management processes                                                 4,763 
Federally funded research and development center-MITRE               9,719 
Program management                                                   5,199 
Architecture, integration & management risk adjustment                 904 
Subtotal                                                            45,000 
Management reserve                                                   5,773 
Total                                                             $203,360 

Source: IRS.

a

See appendix I for a description of each BSM project and program-level
initiative. See appendix II for additional detail on the plan.

b

The two categories under this heading include nine separate projects or
project releases.

Page 11 of 48

To accomplish our objectives, we x reviewed the fiscal year 2005
expenditure plan submitted by IRS in April 2005; x analyzed the plan
against the legislative conditions to identify any variances; x
interviewed IRS program and project management officials to corroborate
our understanding of the plan

and of other BSM activities;

x analyzed available evidence on recent efforts to implement
modernization management controls and capabilities-specifically, progress
on and/or plans for x configuration management,

x human capital management, x cost and schedule estimation, x contract
management, and x post-implementation reviews;

x reviewed program management reports, briefings, and related
documentation to assess the progress IRS has made in completing actions
and implementing program management improvements related to the BSM
Challenges Plan and Highest Priority Initiatives; and

x coordinated with the Treasury Inspector General for Tax Administration
(TIGTA) to avoid duplication of effort in reviewing BSM initiatives.

To assess the reliability of the cost and schedule information contained
in this expenditure plan, we interviewed IRS officials in order to gain an
understanding of the data and discuss our use of the data. In addition, we
checked that information in the plan was consistent with information
contained in IRS internal

Page 12 of 48

briefings. Accordingly, we determined that the data in the plan were
sufficiently reliable for purposes of this briefing.

We performed our work from April through May 2005, in Washington, D.C., in
accordance with generally accepted government auditing standards.

Page 13 of 48

Appendix I Briefing Slides from the May 20, 2005, Briefing to the Senate
and House Appropriations Subcommittee Staffs

    Results

    Objective 1: The plan satisfies the conditions in IRS's Fiscal Year 2005
                              appropriations act.

Table 2: Fiscal Year 2005 Expenditure Plan Provisions for Satisfying Legislative
                                   Conditions

2. Complies with     The plan identifies funding required to continue      
IRS's enterprise     definition and implementation of the enterprise       
architecture         architecture (EA). For example, it identifies funding 
Legislative          needed for lan identifies funding required for        
conditions           managing information technology (IT) ngle portfolio   
Expenditure plan     through its capital planning and investment control   
provisions 1. Meets  process. This ews to select, control, and evaluate IT 
OMB capital planning investments.                                          
and investment       
control review       
requirements IRS's   
fiscal year 2005     
expenditure          
pinvestments as part 
of a siincludes      
conducting periodic  
revix finalizing    
and publishing       
updates to the EA    
based on change      
requests, performing 
EA compliance        
certification        
activities, and      
updating the         
2005/2006 release    
architecture.        
maintaining and      
enhancing the ELC.   
3. Conforms with     The plan identifies funding required for meeting the  
IRS's enterprise     requirements in IRS's enterprise life cycle (ELC)     
life cycle x x     management program. For example, the plan calls for   
methodology onl5.    x maintaining responsibility for coordinating,       
Approved by IRS,     tracking, and integrating all programwide costs,      
Treasury, and OMB x schedules, releases, issues, and risks and            
x x 6. Reviewed by 
GAO x               
4. Complies with the As part of the ELC, IRS has defined processes, roles, 
acquisition rules,   and responsibilities for implementing Carnegie Mellon 
x requirements,     University's Software Engineering Institute (SEI)     
guidelines, and      Software Acquisition Capability Maturity ModelTM      
systems acquisition  practices ithin the repeatable level (level 2) of the 
management practices 5-stage model.a These practices are                   
of the federal       
government for the   
key process areas    
wconsistent with     
federal acquisition  
requirements and     
management           
practices, and the   
plan calls for       
implementation of    
the ELC on all       
projects. Further,   
all PRIME contractor 
cost reimbursement   
task orders are      
subject to a final   
independent audit by 
the Defense Contract 
Audit Agency to      
ensure that costs    
are incurred y for   
tasks actually       
completed on the     
contract. IRS -      
February 18, 2005    
Treasury - March 10, 
2005 OMB - March 18, 
2005 GAO - May 20,   
2005, briefing to    
IRS's appropriations 
subcommittees        

Source: IRS's fiscal year 2005 appropriations act and GAO analysis.

a

These are acquisition planning, solicitation, requirements development and
management, project management, contract tracking and oversight,
evaluation, and transition to support.

Page 14 of 48

                                    Results

Objective 2: IRS has made further progress in implementing our prior
recommendations to improve its modernization controls and capabilities,
although more remains to be done to fully address them.

Since we reported on IRS's last plan,9 it has made further progress in
addressing our prior recommendations to improve its modernization controls
and capabilities, as the following table illustrates:

Table 3: Status of IRS Progress in Implementing Prior GAO Recommendations

Prior recommendations to improve                          Status as of     
IRS's modernization controls and                In        fiscal year 2005 
capabilities                        Implemented progress  plan             
Configuration management                                  
Institutionalize Business Systems                   -     (See pp. 16-17)  
Modernization Office (BSMO)                               
configuration management procedures                       
Human capital management                                  
Implement plans for obtaining,                      -     (See pp. 18-19)  
developing, and retaining requisite                       
human capital resources                                   
Cost and schedule estimation                              
practices                                                 
Implement effective procedures for                  -     (See pp. 20-21)  
validating contractor-developed                           
cost and schedule estimates                               
Contract management                                       
Establish and implement a process                   -     (See pp. 22-23)  
for determining the type of task                          
order to be awarded                                       
Post-implementation reviews                               
Perform analyses of investment data                 -     (See pp. 24-25)  
to determine whether completed                            
projects have achieved expected                           
benefits                                                  

Source: GAO analysis of agency data.

9GAO-05-46.

Page 15 of 48

      Configuration Management

Effective configuration management (CM) is an essential control for
ensuring the integrity and consistency of program and project products
created by the system modernization program throughout their life
cycles.10

In June 2001, we reported11 that BSM's CM was ineffective, and we made
recommendations to address this weakness.

In June 2003, we reported12 that IRS had implemented most of our
recommendations and strengthened its CM processes but that it had not yet
fully institutionalized these processes across the BSM program.

In December 2003, TIGTA reported13 that, although IRS had made progress in
defining and establishing an enterprisewide CM process throughout the
Modernization and Information Technology Services organization,14 the
functions (i.e., identification, control, status accounting, and audit)
had not been uniformly implemented within the organization because IRS had
not established executive-level responsibility to ensure that processes
were properly implemented and that deficiencies identified in internal
assessments were appropriately addressed.

10CM is a discipline that applies technical and administrative direction
and surveillance to identify and document the functional and physical
characteristics of hardware or software, control changes to those
characteristics and their related documentation, record and report change
processing and implementation status, and verify compliance with specified
requirements. The purpose of CM is to systematically identify and baseline
the items that make up a system (identification), formally control any
modifications to those items (control), report on the status of the CM
process (status accounting), and ensure that baseline configurations are
implemented (audit). 11GAO-01-716. 12GAO-03-768.

13

Treasury Inspector General for Tax Administration, Additional Actions Are
Needed to Establish and Maintain Controls Over Computer Hardware and
Software Changes, Reference Number 2004-20-026 (Washington, D.C.: December
16, 2003). 14The Modernization and Information Technology Services
organization consists of (1) BSMO, which acquires and delivers new
computer hardware and software for IRS's modernized business processes and
(2) the Information Technology Services organization, which develops,
operates, and maintains computer hardware and software that support the
current production environment.

Page 16 of 48

During fiscal year 2004, IRS reported that it had made further progress
toward establishing mature configuration management processes. Among its
activities were developing and delivering training modules on CM processes
and configuration control boards (CCB) and completing internal compliance
assessments on four BSM projects to evaluate each project's practices to
determine whether they are being followed and support the project's goals.

However, the results of these assessments demonstrated the need for
additional improvements. Several discrepancies were identified in three of
the projects evaluated (Customer Account Data Engine, e-Services, and
Modernized e-File), including processes or documentation that were found
to be noncompliant with Modernization and Information Technology Services
CM processes and procedures and/or were inadequate to perform the intended
function. The assessment reports cited significant deficiencies and areas
of concern related to requirements management, requirements traceability,
and configuration audits. In addition, the Customer Account Data Engine
and e-Services assessment reports noted that many of the discrepancies
identified during prior assessments of these two projects still remained
unresolved or only partially resolved.

In September 2004, the IRS CIO issued a revised Modernization and
Information Technology Services CM Directive to establish organizational
responsibilities for implementing these processes enterprisewide and
addressing deficiencies. The charters for the associated CCBs were
approved by the CIO in December 2004. In January 2005, a new Associate CIO
was hired to head the new Enterprise Services organization within the
enterprise, which includes a new enterprisewide CM policy office. This
office, under the leadership of the Associate CIO for Enterprise Services,
is responsible for implementing the CM Directive and institutionalizing
these processes.

Until IRS fully institutionalizes effective CM processes, it cannot ensure
that systems are being developed in accordance with enterprisewide needs
and requirements and will not require expensive rework resulting in
additional costs and/or schedule delays.

Page 17 of 48

      Human Capital Management

To maintain and enhance the capabilities of IT staff, organizations should
develop and implement a human capital strategy that, among other things,

x assesses the knowledge and skills needed to effectively perform IT      
      operations to support agency mission                                    
      and goals,                                                              
x inventories the knowledge and skills of current IT staff,               
x identifies gaps between requirements and current staffing, and          
x develops and implements plans to fill the gaps.                         

In February 2002, we reported15 that IRS had not yet defined or
implemented an IT human capital strategy, and recommended that IRS address
this weakness.

In June 2003, we reported16 that IRS had made important progress in
addressing our recommendation, but had yet to

x develop a comprehensive multiyear workforce plan to replace the current
annual plan, which did not encompass all phases of multiyear projects, and

x hire, develop, or retain sufficient human capital resources with the
required competencies, including technical skills, in specific mission
areas.

15GAO-02-356. 16GAO-03-768.

Page 18 of 48

In September 2003, TIGTA reported17 that IRS's Modernization and
Information Technology Services organization had made significant progress
in developing its human capital strategy,18 including the development of a
5-year human capital plan; however, the strategy was not complete.
Specifically, IRS had not yet (1) identified and incorporated human
capital asset demands for the modernized organization,

(2) developed detailed hiring and retention plans, or (3) established a
process for reviewing the development of a human capital strategy and
monitoring its implementation.

In August 2004, the current Associate CIO for BSM identified the
completion of a human capital strategy as a high priority. Since then, IRS
has reported that it has developed and utilized a human resources capacity
management model to identify asset demands and determine where skills gaps
exist in the current BSMO organization. IRS is currently in the process of
prioritizing its BSM staffing needs within functional divisions, designing
and establishing a revised organizational structure and staffing
profile/level that meets the needs of the current BSM program, and
developing a detailed recruiting plan to bring necessary personnel on
board. For example, IRS is focusing on hiring additional staff in the
systems engineering area, to provide these skills to various modernization
projects. In providing comments on this briefing, IRS stated that it had
hired 9 of 10 engineers for the new Modernization Program Engineering
Office.

IRS has taken some steps in the right direction. However, until IRS fully
implements its strategy, it will not have all of the necessary IT
knowledge and skills to effectively manage the BSM program or to operate
modernized systems. Consequently, the risk of BSM program and project cost
increases, schedule slippages, and performance problems is increased.

17

Treasury Inspector General for Tax Administration, The Modernization,
Information Technology and Security Services Organization Needs to Take
Further Action to Complete Its Human Capital Strategy, Reference Number
2003-20-209 (Washington, D.C.: September 22, 2003).

18

The BSM human capital strategy is an integral part of the overall strategy
for the Modernization and Information Technology Services organization.

Page 19 of 48

      Cost and Schedule Estimation Practices

Producing reliable estimates of expected costs and time frames for the
completion of systems modernization initiatives is essential to
determining a program's cost-effectiveness. Without such information, the
likelihood of making poor investment decisions is increased.

The BSM program has had a history of cost overruns and schedule delays,
and has been criticized for its ineffective cost and schedule estimation
practices and inability to deliver projects within budget and on time.

In February 2002, we reported19 that BSM project cost and schedule
estimates were contractor-provided, "rough order of magnitude" estimates
that had not been validated by IRS, and recommended that IRS adopt
effective cost and schedule estimating practices.

Since that time, IRS directed the PRIME contractor to build a programwide
cost and schedule estimation system that is compliant with best practices
in the IT industry. To improve project cost and schedule estimates, IRS
and the PRIME contractor

x developed a guidebook to provide assistance in developing cost and      
      schedule estimates,                                                     
      issued procedures to (1) help IRS staff in validating the PRIME         
x contractor's cost and schedule estimating                               
      capabilities and (2) provide guidance for the independent review of     
      contractor-provided cost and schedule                                   
      estimates,                                                              
      established a database containing historical data from PRIME projects   
x to be used to prepare future                                            
      estimates, and                                                          
      developed a methodology for preparing risk-adjusted cost and schedule   
x estimates.                                                              

19GAO-02-356.

Page 20 of 48

Despite these steps, a September 2004 internal review of the PRIME
contractor's cost and schedule estimation capability concluded that
estimation processes and compliance were still inadequate in some
respects. The report stated that (1) the primary area of weakness was in
the PRIME contractor's execution, since there was little evidence that the
cost and schedule estimating guidance was being followed, and

(2) future efforts will focus on the institutionalization of established
guidance.

As a result of IRS's assessment of the PRIME contractor's performance, IRS
decided to shift primary responsibility for cost and schedule estimation
from the PRIME contractor to IRS staff. Despite the contractor's poor
performance in cost and schedule estimating, there are risks associated
with this change. For example, IRS has indicated that, as a part of this
transition, it must redefine BSM cost and schedule estimation processes
consistent with the current scope of the program and strengthen its
capabilities in this area. However, although the agency hired additional
technical expertise for cost and schedule estimating during fiscal year
2004, it acknowledges that it does not yet have all the expertise
necessary to estimate cost and schedule effectively.

Page 21 of 48

      Contract Management

The Federal Acquisition Regulation indicates that performance-based
contracting20 is the preferred method for acquiring services, should be
used to the maximum extent practicable, and that fixed-price task orders21
are the preferred type of performance-based task order.

In September 2002, TIGTA recommended22 that BSMO require the use of
fixed-price task orders whenever possible and appropriate for projects in
development and deployment and for any other task orders where
requirements can be clearly identified at the outset.

OMB has also encouraged IRS to use performance-based, fixed-price task
orders to the maximum extent practicable.

In June 2003, we reported23 that IRS did not have a clearly documented
process for determining the type of task order to be awarded for BSM
projects. We recommended that IRS establish and implement a process for
determining the type of task order to be awarded.

During fiscal year 2003, IRS issued BSMO guidance,24 a CIO memorandum,25
and a BSMO directive26 outlining

(1)
           IRS's intent to utilize more fixed-price task orders where
           appropriate, (2) the new IRS policy stipulating that all contracts
           and task orders for BSM development projects in milestones 4 and 5
           will be fixed-price, and

(3)
           implementation guidance and a strategy to facilitate the use of
           performance-based contracting in the

20

 The use of performance-based contracting means establishing clear and specific
     contract requirements where satisfaction can be objectively measured.

21

A fixed-price task order is one in which the price is agreed upon at the
outset and is not adjusted unless the requirements are changed.

22

Treasury Inspector General for Tax Administration, Additional Improvements
Are Needed in the Application of Performance-Based Contracting to Business
Systems Modernization Projects, Reference Number 2002-20-170 (Washington,
D.C.: September 13, 2002). 23GAO-03-768.

24

Internal Revenue Service, Enabling the Selection of Appropriate Contract
Types for BSM Task Orders, BSMO-Guidance-Contract Types (Washington, D.C.:
August 11, 2003).

25

Internal Revenue Service, Business Systems Modernization Fixed-Price
Policy, CIO Memorandum (Washington, D.C.: September 29, 2003).

26

Internal Revenue Service, Performance-Based Contracting for BSM Task
Orders, BSMO-DIR-PBC (Washington, D.C.: September 30, 2003).

Page 22 of 48

development of BSM task orders. IRS also provided training for more than
100 IRS and contractor staff in the use of newly developed templates and
instructions to facilitate the implementation of performance-based
contracting and compliance monitoring.

During fiscal year 2004, IRS's efforts focused on monitoring compliance
with BSMO directives and templates for implementing performance-based
contracting. IRS developed performance measures for assessing the extent
to which certain performance-based contracting practices were introduced
into the modernization environment. These measures were used to perform an
initial assessment of task orders for modernization projects. Results
indicated that IRS staff is applying the new guidelines for
performance-based contracting, but a larger number of task orders must be
assessed to provide a more reliable basis for evaluating compliance.

In August 2004, IRS issued a revised ELC directive that separated ELC
Milestone 4 into Milestone 4a (system design) and Milestone 4b (system
development). IRS considered this revision to be a necessary condition for
moving toward a firm fixed-price contracting environment for the later
stages of systems development. This established Milestone 4a as a
checkpoint at the end of the design phase where fixed-price task orders
can be negotiated for business system development and deployment.

During fiscal year 2005, IRS plans to improve implementation of
performance-based contracting by revising existing guidance, providing
needed training for new or improved guidance, and performing semiannual
assessments of compliance.

Until IRS fully implements performance-based contracting practices for
managing BSM task orders, it cannot ensure that contractor costs are being
adequately controlled or that the contractor is delivering products that
fully satisfy the requirements and contract specifications.

Page 23 of 48

      Post-Implementation Reviews

Conducting post-implementation reviews (PIR) is a process for reviewing IT
projects to identify lessons learned from investments and determine
whether the benefits anticipated in the business case for the investment
have been realized.

OMB Guidance,27 GAO's Information Technology Investment Framework,28 and
IRS's ELC require that post implementation reviews be performed on
deployed information systems. According to our framework, the reviews
should include (1) the collection, evaluation, and analysis of both
quantitative and qualitative investment data and (2) documentation of
lessons learned and recommendations for improving the information
technology investment process.

In November 2004, we reported29 that IRS had performed PIRs on deployed
projects; however, these reviews were incomplete and did not follow IRS's
procedure. Although the PIRs documented lessons learned in implementing
the projects and provided recommendations for future improvements, the
reviews did not

(1) compare and analyze actual versus planned benefits and systems
performance, (2) determine the validity of original business assumptions,
or (3) compare and analyze actual versus planned cost and schedule
estimates. We recommended that future post-implementation reviews of
deployed BSM projects include an analysis of quantitative and qualitative
investment data to determine whether expected benefits were achieved.

IRS has developed a new procedure for conducting post-milestone reviews
and PIRs on BSM projects. The post-milestone reviews are to focus on the
processes used in systems development, while the PIRs are to focus on
outcomes related to expected business benefits, user expectations, and
technical performance

27

Executive Office of the President, Office of Management and Budget,
Evaluating Information Technology Investments: A Practical Guide,
(November 1995) and Circular A-130, Transmittal Memorandum #4, Management
of Federal Information Resources, (November 2000).

28

GAO, Information Technology Investment Management: A Framework for
Assessing and Improving Process Maturity, GAO-04-394G (Washington, D.C.:
March 2004). 29GAO-05-46.

Page 24 of 48

requirements. We have reviewed the procedure and found that it is
compliant with established federal guidance. However, this new procedure
will not prove beneficial unless IRS ensures that it is followed for
conducting all future PIRs. The next BSM project PIR is scheduled for
early 2006.

Page 25 of 48

Objective 3: Observations about IRS's BSM Program and Expenditure Plan

Observation 1: IRS Has Made Progress in Implementing BSM, but Much Work
Remains.

During the past 12 months, IRS's BSM program has deployed initial phases
of several modernized systems and reported benefits to taxpayers and the
agency, including the following:

x Customer Account Data Engine (CADE) - Individual   CADE is intended to  
      Master File30 Release 1. 31                        
      replace IRS's antiquated system that contains the repository of
      taxpayer information and, therefore, is the        
      BSM program's linchpin and highest priority project. In July 2004 and
      January 2005, IRS implemented the                  
      initial releases of CADE, which have been used to process filing year
      2004 and year 2005 1040EZ returns,                 
      respectively, for single taxpayers with refund or even-balance tax
      returns. According to IRS, as of March             
      31, 2005, CADE had processed over 1 million tax returns so far this
      filing season.                                     
      e-Services. This project created a Web portal and provided other
x electronic services to promote the goal of         
      conducting most IRS transactions with taxpayers and tax practitioners
      electronically. IRS implemented                    
      e-Services in May 2004, and reported that, as of late March 2005, over
      84,000 users have registered with                  
      this Web portal.                                   
      Modernized e-File (MeF). This project is intended to provide electronic
x filing for large corporations, small               
      businesses, and tax-exempt organizations. The initial releases of this
      project were implemented in June                   

and December 2004, and allowed for the electronic filing of forms and
schedules for the Form 1120

30CADE will include the modernized database foundation to replace the
current master files processing systems, which are the agency's repository
of taxpayer information. There are master files for individuals,
businesses, and employer retirement plans. CADE is expected to facilitate
faster refund processing and more timely response to taxpayer inquiries.
31Release 1 includes five segments. Release 1.0, the base release of1040
EZ functionality, was deployed in July 2004. Release 1.1, also deployed in
July 2004 (concurrent with Release 1.0), contained filing season 2003 and
2004 tax law changes. Release 1.2, deployed in January 2005, included
filing season 2005 changes. Release 1.3.1, scheduled to be deployed in
July 2005, will include new functionality to improve performance and allow
address changes on tax returns as well as some filing season 2006 tax law
changes. Release 1.3.2, scheduled to be deployed in January 2006, will
include the remaining filing season 2006 tax law changes and some
additional functionality.

Page 26 of 48

(corporate tax return) and Form 990 (tax-exempt organizations' tax
return). IRS reported that, during the

2004 filing season, over 53,000 of these forms and schedules were accepted
using MeF.

x Integrated Financial System (IFS). This system replaces aspects of
IRS's core financial systems and is ultimately intended to operate as its
new accounting system of record. The first release of this system became
fully operational in January 2005.

Although IRS has delivered important functionality, the BSM program is far
from complete. Future deliveries of additional functionality of deployed
systems and the implementation of other projects are expected to have a
significant impact on IRS's taxpayer services and enforcement capability.
For example,

x IRS has projected that CADE will process about 2 million tax returns in
the 2005 filing season. However, the returns being processed in CADE are
the most basic of all tax returns and constitute less than 1 percent of
the total tax returns expected to be processed during the current filing
season. There is much work to be done before a significant number of
taxpayer returns are processed through the CADE system.

x The Filing and Payment Compliance (F&PC) project is expected to improve
processes and technologies that support IRS's compliance activities,
increase the agency's capacity to treat and resolve the backlog of
delinquent taxpayer cases, and improve voluntary taxpayer compliance.
Furthermore, it is expected to increase the closure of collection cases by
10 million annually by 2014. IRS intends to deliver an initial limited
private debt collection capability in January 2006, with full
implementation of this aspect of the F&PC project to be delivered by
January 2008, and additional functionality to follow in later years.

Page 27 of 48

Observation 2: IRS Has Not Met Long-Term Cost and Schedule Estimates, but
Incremental Approach Contributed to Short-Term Improvements.

The BSM program has a long history of significant cost increases and
schedule delays, which, in part, has led us to report the program as high
risk since 1995.32 Among the reasons for IRS's poor performance are the
inability to resolve key system design, integration, and performance
issues in a timely manner, unanticipated testing difficulties, and
insufficient requirements development.

In addition, IRS has overstated its cost and schedule estimating
performance in fiscal year 2004. IRS claims to have delivered all projects
(with the exception of IFS) on time and within budget and that the
variance between estimated and actual costs had been reduced from 33
percent in fiscal year 2002 to 4 percent in fiscal year 2004. However, we
do not agree with the methodology used in the analysis supporting this
claim. Specifically,

(1) the analysis did not reflect actual costs, instead it reflected
changes in cost estimates (i.e., budget allocations) for various BSM
projects; (2) IRS aggregated all of the changes in the estimates
associated with the major activities for some projects, such as CADE,
which masked that monies were shifted from future activities to cover
increased costs of current activities (e.g., $39.8 million in fiscal year
2004 funding originally allocated for the CADE Release 2 project was moved
to cover cost overruns in the CADE Release 1 and Business Rules
initiatives, but was not included in the 4 percent variance indicated
above); and (3) the calculations were based on a percentage of specific
fiscal year appropriations, which does not reflect that these are
multiyear projects.

A new strategy to develop and deploy more manageable program segments
contributed to recent improvements in meeting some short-term cost and
schedule estimates. In the second quarter of fiscal year 2004, IRS
rebaselined its projects and decided to change its BSM program strategy to
develop and deploy more manageable project segments. Our comparison of
IRS's reported project costs and ELC milestone completion dates presented
in the July 2004 and April 2005 expenditure plans shows that two BSM
projects, CADE Releases 1.1 and 1.2, were delivered at the estimated cost
and on or before the scheduled completion

32For our latest high-risk report, please see GAO, High-Risk Series: An
Update, GAO-05-207 (Washington, D.C., January 2005).

Page 28 of 48

dates projected in the July 2004 plan. In addition, it shows that Release
1 of the Custodial Accounting Project was delivered on time and within its
risk-adjusted cost estimate.

Concerns remain about IRS's ability to consistently deliver on time and
within budget in the future. As mentioned earlier, IRS has had a history
of cost increases and schedule delays. In addition, our comparison of the
July 2004 and April 2005 plans shows that 12 BSM project segments have
experienced cost increases and/or schedule delays against short-term and
long-term commitments shown in the July 2004 plan. Five of the 12
initiatives reported cost increases (4 were within the allocated project
risk adjustments and 1 was not). Also, 9 of the 12 initiatives reported
schedule delays. See appendix III for details. Based on our analysis, it
remains to be seen whether the IRS can continue to deliver modernization
initiatives on time and within budget through the life cycle of current
projects and into the future.

Page 29 of 48

Observation 3: IRS Has Made Progress Toward Addressing Issues Raised in
Independent BSM Assessments and Implementing Program Improvement
Initiatives, but Significant Issues and Challenges Remain.

As a result of continued cost overruns and schedule delays in the BSM
program, during the summer of 2003, IRS and the PRIME contractor, CSC,
initiated three external independent studies and one IRS internal analysis
to assess the effectiveness of the BSM program and to review the CADE
project.

These assessments and a subsequent report by the IRS Oversight Board33
resulted in 48 action issues to address weaknesses in and reduce risks to
the BSM program. In October 2003, IRS established a BSM Challenges Plan to
address the 48 action issues and assigned a senior executive to coordinate
the development of goals, management plans, and closure criteria.

In May 2004, IRS reported34 that 44 of the 48 action issues were closed
and that the plan had accomplished its mission to help put the necessary
policies and procedures in place to improve the delivery of modernized
systems. However, our review of this report found examples of important
issues that were closed even though required activities were incomplete.35

Subsequent to the May 2004 report, the current IRS Associate CIO for BSM
determined that many of the action issues had been prematurely closed in
the BSM Challenges Plan report. As a result, he began internally tracking
the progress of the original action issues, including those that had been
closed. Also, after interviewing a number of individuals associated with
the BSM program and reviewing the four BSM studies as well as various GAO
and TIGTA reports, the Associate CIO determined what he believed to be the
key barriers to success in the BSM program and created a plan to address
these barriers.

33IRS Oversight Board, Independent Analysis of IRS Business Systems
Modernization, Special Report (December 2003). Internal Revenue Service,
BSM Challenges Plan Close-Out Report (May 2004). 35See GAO-05-46 for
additional details.

Page 30 of 48

The Associate CIO established the following seven key focus areas for
improving IRS's capability to design, develop, and deliver modernized IT
systems:

x Staffing and Skill Sets,

x Contractor Management,

x Requirements and Demand Management,

x Systems Engineering,

x Project Management Disciplines,

x Communication and Collaboration, and

x Empowerment/Accountability.

He then mapped (1) the BSM Challenges Plan action issues, (2) GAO/TIGTA
recommended corrective actions for improving modernization management
controls and processes, and (3) several additional IRS-defined improvement
initiatives to these key focus areas to form a BSM program improvement
framework.

In August 2004, the Associate CIO identified 16 "highest priority
initiatives" from the program improvement framework that were to be
completed by the end of January 2005. This initial set of initiatives
contained improvement efforts linked to six of the seven key focus areas,
and consisted of three action issues from the BSM Challenges Plan, four
corrective actions recommended by GAO and TIGTA, and nine additional
improvement efforts identified by the Associate CIO.

Page 31 of 48

As of late April 2005, IRS reported that 44 of the 48 BSM Challenges Plan
action issues have been closed, including 10 which were merged with other
action issues. Of the remaining 4 open action issues, 2 of these issues
(related to hiring additional systems engineering staff and conducting key
technical reviews throughout the system life cycle) are nearing
completion, while the other 2 issues, (implementing recommendations from
an external study of the BSM contracting process and testing a business
rules engine36 in the CADE environment), require significant additional
work.

Also, IRS reported that 12 of the 16 initial highest priority initiatives
had been completed and closed, including efforts to fill four key critical
pay project manager positions, assess and modify the PRIME contractor's
role on the program, create a requirements management office, begin
revalidation of the CADE project approach and architecture, and
institutionalize monthly program reviews. The remaining 4 ongoing
initiatives, related to

(1) strengthening IRS's systems engineering capability, (2) completing the
BSM human capital strategy and recruiting plan, (3) hiring a leader and
establishing a requirements management office operation, and (4) hiring a
technical lead for the BSM program, have been carried over to the next
6-month cycle.

In addition to the 4 initiatives carried forward from the initial list,
IRS is focusing on 13 newly selected highest priority improvement
initiatives for a total of 17, which are planned to be completed by early
September 2005. Several of these initiatives relate to challenges from the
recent switch in responsibility for systems integration from the
contractor to IRS, and involve the transition of primary responsibility
for critical BSM program management operations to IRS, including

x contract management,                                                    
x quality assurance,                                                      
x cost and schedule estimation,                                           
x the change request process,                                             

36A business rules engine translates business rules, or processing
criteria (e.g., income tax refunds of $x or more are held for
administrative review) into executable computer code that processes
transactions related to a tax form, and selects and executes correct rules
based on the tax year and tax form.

Page 32 of 48

x integrated schedule management and baseline management, and

x project deployment transition support.

Other initiatives currently being implemented by IRS include ensuring BSM
staff are trained in required project management skills (e.g., schedule
analysis, earned value management, and testing monitoring) and
establishing a business rules management operation to establish and
support business rules harvesting37 as a method to define
modernization-related business requirements for projects such as CADE.

When effectively implemented, this program improvement process will allow
IRS to regularly assess and prioritize its issues and challenges. However,
until the agency has addressed its high priority initiatives, BSM remains
at risk of further cost overruns and delays in delivery of critical
functionality.

Business rules harvesting refers to the process of extracting, defining,
and documenting tax processing criteria from a variety of sources,
including IRS subject matter experts, legacy system source code, the tax
code, and various other paper documents.

Page 33 of 48

Observation 4: IRS is Adjusting the BSM Program in Response to Its
Assessment of the PRIME Contractor's Performance and Budget Reductions.

The BSM program is undergoing significant changes as it adjusts to the
recent change in the PRIME contractor's role as well as reductions in its
budget. As noted previously, IRS completed an assessment of the PRIME
contractor's performance during fiscal year 2004. As a result, IRS began
to transition program management responsibilities from the contractor to
the agency in the fall of 2004. Subsequent funding reductions increased
the shifting of areas of responsibility from the contractor. For fiscal
year 2005, IRS received about 29 percent less funding than it requested
(from $285 million to $203.4 million). According to the Senate report for
the fiscal year 2005 Transportation, Treasury, and General Government
appropriations bill, in making its recommendation to reduce BSM funding,
the Senate Appropriations Committee was concerned about the program's cost
overruns and schedule delays and wanted IRS to focus on its highest
priority projects, particularly CADE.38 In addition, IRS's fiscal year
2006 budget request reflects an additional reduction of about 2 percent,
or about $4.4 million, from the fiscal year 2005 appropriation. In
response, IRS has made adjustments to project funding allocations and
future delivery schedules.

It is too early to tell what effect these changes will ultimately have on
the BSM program. However, the adjustments IRS is making are not without
risk, could potentially impact future budget requests, and will delay the
implementation of certain functionality that was intended to provide
benefit to IRS operations and the taxpayer. For example,

x Shifts of BSM management responsibility from the PRIME contractor to
IRS. Due to IRS's assessment of the PRIME contractor's performance and
budget reductions, IRS decided to shift significant BSM responsibilities
for program management, systems engineering, and business integration from
the contractor to IRS staff. For example, IRS is assuming responsibility
for cost and schedule estimation and measurement, risk management,
integration test and deployment, and transition management. There are
risks associated with this decision. It is important to recognize that in
the late 1990's, IRS moved

U.S. Senate, Senate Report 108-342.

Page 34 of 48

management functions to contractors because of the agency's management
weaknesses and past difficulties managing large IT projects. To
successfully accomplish this transfer, IRS must have the management
capability to perform this role. Although the BSM program office has been
attempting to improve this capability through, for example, implementation
of a new governance structure and hiring staff with specific technical and
management expertise, IRS has had significant problems in the past
managing large development projects, and acknowledges that it currently
does not have all the expertise and processes needed to discharge these
additional responsibilities effectively.

x Reductions in management reserve/project risk adjustments. In response
to the fiscal year 2005 budget reduction, IRS reduced the amount that it
had allotted to program management reserve and project risk adjustments by
about 62 percent (from about $49.1 million to about $18.6 million).39 If
BSM projects have future cost overruns that cannot be covered by the
depleted reserve, this reduction could result in

(1) increased budget requests in future years or (2) delays in planned
future activities (e.g., delays in delivering promised functionality) to
use those allocated funds to cover the overruns. During fiscal year 2004,
IRS expended about 46 percent of its BSM management reserve/project risk
adjustments.

x Suspension of the Custodial Accounting Project (CAP). Although the
initial release of CAP went into production in September 2004, IRS has
decided not to use this system and to stop work on planned improvements
due to budget constraints. According to IRS, it made this decision after
it evaluated the business benefits and costs to develop and maintain CAP
versus the benefits expected to be provided by other projects, such as
CADE. Among the functionality that the initial releases of CAP were
expected to provide were (1) critical control and reporting capabilities
mandated by federal financial management laws;

(2) a traceable audit trail to support financial reporting; and (3) a
subsidiary ledger to accurately and promptly identify, classify, track,
and report custodial revenue transactions and unpaid assessments. With the
suspension of CAP, it is now unclear how IRS plans to replace the
functionality this system was expected to provide, which was intended to
allow the agency to make meaningful progress toward

39We did not include in our calculations, reductions to specific project
risk adjustment amounts that were made for reasons other than the fiscal
year 2005 budget reduction.

Page 35 of 48

addressing long-standing financial management weaknesses. IRS is currently
evaluating alternative

approaches to addressing these weaknesses.

x Reductions in planned functionality. According to IRS, planned
functionality for some of its BSM projects will be delayed. For example,
IRS no longer plans to include Form 1041 (the income tax return for
estates and trusts) in the fourth release of Modernized e-File, which is
expected to be implemented in fiscal year 2007. In addition, future
releases of the Integrated Financial System, planned to provide additional
functionality necessary to fully address financial management weaknesses,
have been postponed indefinitely.

Page 36 of 48

Observation 5: The BSM Vision and Strategy Need Revision.

The BSM program is based on visions and strategies developed in 2000 and
2001. The significant delays experienced by the program and the
substantive changes brought on by recent events such as IRS's assessment
of its contractor and budget reductions, indicate a need for IRS to
revisit its long-term goals, strategies, and plans for BSM. For example,
the latest modernization roadmap referenced in an expenditure plan dates
back to fiscal year 2002 and showed the first five releases of CADE were
to be completed by 2006-currently CADE Release 2 is not scheduled to be
delivered until 2007.

Such an assessment would include an evaluation of when significant future
BSM functionality would be delivered and at what cost. For example, CADE
is currently scheduled to complete Release 2 and be able to process an
estimated 33 million tax returns by 2007, but no detailed plans or
schedules are available for the remaining phases of this project. Although
the ability to process 33 million tax returns will be a significant
accomplishment, it is a long way from handling the over 200 million tax
returns received by IRS each filing season. For CADE, IRS still needs to
determine (1) what additional functionality needs to be developed to cover
the remaining tax returns, (2) how much it will cost IRS to develop this
functionality, and (3) when this functionality will be made available. A
similar analysis should be made for each of its major modernization
projects.

IRS's Associate CIO for BSM has recognized that it is time to recast the
agency's BSM strategy because of changes that have occurred subsequent to
the development of the program's initial plans. According to this
official, IRS is in the process of redefining and refocusing the BSM
program, and he expects this effort to be completed by the end of this
fiscal year; however, definite milestones for completing an updated
strategy do not exist.

It is important for IRS to fully revisit its vision and strategy for the
BSM program and develop a new set of long-term goals, strategies, and
plans that are consistent with the budgetary outlook and IRS's management
capabilities.

Page 37 of 48

IRS's fiscal year 2005 plan satisfies the legislative conditions.

IRS has made progress in implementing our recommendations to improve its
modernization management controls and capabilities. However, our reviews
and those of the Treasury inspector general clearly demonstrate that
significant challenges and serious risks remain. IRS acknowledges this and
is acting to address them.

IRS has deployed initial phases of several modernized systems recently and
has met short-term cost and schedule estimates. However, much more work
remains to be done to complete the modernization, and challenges confront
the IRS in meeting its longer-term cost and schedule estimates. In
addition, many high priority risks confront the BSM, including contract
management, program management, and bolstering its human capital, as
greater responsibility and accountability is transitioned from the
contractor to the IRS. Finally, the BSM long-term vision and strategy is
no longer current given project delays, and requires a major revision that
is consistent with the budgetary outlook and its management capabilities.

Page 38 of 48

To address the many changes associated with the BSM and clearly describe
what the modernization program is intended to accomplish, when it will be
completed, and at what cost, we recommend that the Commissioner of
Internal Revenue direct the CIO to take the following action:

x fully revisit the vision and strategy for the BSM program and develop a
new set of long-term goals, strategies, and plans that are consistent with
the budgetary outlook and IRS's management capabilities.

Page 39 of 48

In providing oral comments on a draft of this briefing, the Associate CIO
for BSM concurred with our findings and conclusions, and stated that it is
a fair representation of the BSM program. He also provided specific
technical comments that we have incorporated into the briefing, as
appropriate.

Page 40 of 48

Appendix I: Description of Business Systems Modernization (BSM) Projects
and Program-Level Initiatives

Proposed modernization         Description                                 
initiative                     
Tax administration projects    
                                  Is to create a Web portal and other         
e-Services                     e-Services to promote the goal of           
                                  conducting                                  
                                  most IRS transactions with taxpayers and    
                                  tax practitioners electronically.           
Filing and Payment             Is a series of projects providing support   
Compliance(F&PC)/ Private      for detecting, scoring, and working         
Data Collection (formerly      nonfiler (filing compliance) and            
referred to as Collection      delinquency (payment compliance) cases. The 
Contract Support (CCS))        first phase of F&PC is Private Debt         
                                  Collection, which will use advanced         
                                  software to analyze tax collection cases    
                                  and divide them into the complex cases      
                                  requiring                                   
                                  IRS involvement from the simpler ("balance  
                                  due") cases that can be handled by private  
                                  collection agencies.                        
                                  Is to provide a single standard for filing  
Modernized e-File              electronic tax returns. Initial releases    
                                  will                                        
                                  address large corporations, small           
                                  businesses, and tax-exempt organizations.   
                                  Its                                         
                                  ultimate goal is the conversion of IRS's    
                                  1040 e-file program.                        
Customer Account Data Engine - Is to build the modernized database         
Individual                     foundation to replace the existing master   
Master File (CADE IMF)         file processing systems that contain a      
                                  repository of information on individual     
                                  taxpayers.                                  
Internal management projects   
Custodial Accounting Project   Is to provide integrated tax operations and 
(CAP)                          internal management information to          
                                  support evolving decision analytics,        
                                  performance measurement, and                
                                  management information needs.               
Integrated Financial System    Is to provide a single ledger for custodial 
(IFS)                          and financial data and a platform to        
                                  integrate core financial data with budget,  
                                  performance, and cost accounting            
                                  data.                                       

                                 Page 41 of 48

                         (continued from previous page)

Appendix I: Description of Business Systems Modernization (BSM) Projects
and Program-Level Initiatives

Proposed modernization         Description                                 
initiative                     
Core infrastructure projects   
Development, Integration, &    Is to provide oversight for laboratory      
Testing Environment            environments that support evaluation,       
                                  development, and testing of components from 
                                  multiple projects: (1) Virtual              
                                  Development Environment provides a          
                                  development environment and a standardized  
                                  set of tools; (2) Enterprise Integration    
                                  Testing Environment provides an integration 
                                  testing environment for all projects.       
Infrastructure Shared Services Is to establish a program to build and      
                                  deliver an infrastructure that is scalable, 
                                  interoperable, flexible, manageable, and    
                                  features standardized operations and a      
                                  single                                      
                                  security and enterprise systems management  
                                  framework.                                  
Architecture, integration &    
management                     
Architecture & Integration     Is to ensure that systems solutions meet    
                                  IRS business needs and that the projects    
                                  are                                         
                                  effectively integrated.                     
Business Integration           Is to ensure that IRS's BSM program is      
                                  aligned with the business units' vision and 
                                  delivers the desired business results. It   
                                  provides support to the business owners     
                                  with key activities such as transition      
                                  management, business rules enterprise       
                                  management,                                 
                                  and business transformation.                
                                  Is to provide sustaining support for        
Management Processes           program-level management processes,         
                                  including                                   
                                  quality assurance, process improvement,     
                                  training, program control, and ELC          
                                  maintenance and enhancements.               
Federally Funded Research and  Is to provide program management and        
                                  systems engineering support to BSMO.        
Development Center-MITRE       
Program Management             Is to ensure that projects achieve their    
                                  objectives; provide the management          
                                  information and IT infrastructure that      
                                  supports risk management, project cost and  
                                  schedule estimating, and financial          
                                  management; and provide procurement         
                                  management for the                          
                                  CSC contract and associated task orders.    

Source: IRS.

Page 42 of 48

Appendix II: Additional Detail on IRS's Fiscal Year 2005 BSM Expenditure
Plan (in thousands of dollars)

Proposed modernization          Release a    Milestone Milestone Amount    
initiative                                   b         date      requested 
Tax administration projects                                      
e-Services                    R1.1, 1.2, 2.0     5      Aug. 05     $8,000 
e-Services                    PeopleSoft        N/A     Aug. 05        600 
                                 Upgrade                            
e-Services Risk Adjustment                                           1,000 
Subtotal - e-Services project                                        9,600 
Modernized e-File (MeF)            R3.1          4     March 05      2,400 
MeF                                R3.2          4     March 06     13,700 
MeF                                 R4           3      Oct. 05      8,000 
MeF Risk Adjustment                                                  2,650 
Subtotal - MeF project                                              26,750 
Customer Account Data Engine                                               
- Individual Master File            R1           5      Dec. 05      7,000
(CADE IMF)                                                       
                                                Filing                        
CADE IMF                            R1       Season 06  Dec. 05     27,000
CADE IMF                            R2          4a      June 06      7,000 
                                 Program Mgmt.                                
                                 and Transition                     
CADE IMF                      Mgmt.             N/A     Dec. 05      8,000
CADE IMF Risk Adjustment                                             5,237 
Subtotal - CADE IMF project                                         54,237 
Subtotal - tax administration                                       90,587 
projects                                                         
Core infrastructure projects                                     
Development, Integration &                    FY 05c    Nov. 05     15,574 
Testing Environment (DITE)                                       
Infrastructure Shared                         FY 05c    Nov. 05     42,426 
Services (ISS)                                                   
DITE/ISS Risk Adjustment                                             4,000 
Subtotal - core                                                     62,000 
infrastructure projects                                          

                                 Page 43 of 48

Appendix II: Additional Detail on IRS's Fiscal Year 2005 BSM Expenditure
Plan (in thousands of dollars)

                         (continued from previous page)

Proposed modernization initiative  Releasea Milestoneb Milestone Amount    
                                                          date      requested 
Architecture, integration, &                                     
management                                                       
Architecture & Integration                   FY 05 c    Nov. 05    $18,506 
Business Integration                         FY 05 c    Nov. 05      5,909 
Management Processes                         FY 05 c    Nov. 05      4,763 
FFRDC - MITRE                                FY 05 c    Nov. 05      9,719 
Program Management                           FY 05 c    Nov. 05      5,199 
Architecture, Integration &                                            904 
Management Risk Adjustment                                       
Subtotal - architecture,                                            45,000 
integration, & management                                        
Management reserve                                                   5,773 
Total fiscal year 2005 BSM program                                $203,360 

Source: IRS.

a

Releases are software versions that provide a subset of the total planned
project functionality.

b

Milestones correspond to phases within IRS's ELC (1 - Enterprise
Architecture, 2 - Domain Architecture, 3 - System Architecture, 4a -
System Design, 4b - System Development, 5 - System Deployment). Core
infrastructure projects and management initiatives are funded on a fiscal
year (FY) basis rather than by milestone.

Page 44 of 48

                                 Page 45 of 48

                  Commitment date Revised                   
                                  commitment                
                  and funding as     date and                                 
      Project     of 7/2004       funding as of             IRS explanation   
      segment     ($000)          4/2005 ($000)    Change   of change
     e-Services       4/30/05        8/31/05     +4 months  Significant scope 
                                                            was added to the  
    Milestone 5       $32,500        $32,500                project that      
                                                            resulted in       
                                                            additional time   
                                                            to the project    
                                                            schedule.         
                                                            Significant       
                                                            additions were a  
                                                            PeopleSoft        
                                                            upgrade,          
                                                            the expansion of  
                                                            the application   
                                                            process to        
                                                            include           
                                                            Modernized e-File 
                                                            (MeF) roles to    
                                                            grant             
                                                            accessibility to  
                                                            those users, and  
                                                            the Electronic    
                                                            Data              
                                                            Accessing         
                                                            Solution (EDAS).  
                                                            The government    
                                                            and contractor    
                                                            executed a        
                                                            replan to address 
                                                            schedule          
                                                            increases.        
     e-Services   4/30/05 $7,400  8/31/05        +4 months  $600K transferred 
     PeopleSoft                   $12,100        +$4,700    from FY 2005      
Upgrade (LOE)                                            project Risk      
                                                            Adjustment to     
                                                            cover estimated   
                                                            cost to complete  
                                                            the PeopleSoft    
                                                            upgrade prior to  
                                                            e-Services'       
                                                            transition to IRS 
                                                            operations and    
                                                            maintenance. In   
                                                            addition, $4.1    
                                                            million           
                                                            transferred from  
                                                            FY 2004           
                                                            project Risk      
                                                            Adjustment to     
                                                            cover increased   
                                                            cost of the       
                                                            PeopleSoft        
                                                            upgrade. Thus,    
                                                            the Total Segment 
                                                            Cost is $12,100K  
                                                            (7,400 + 4,100 +  
                                                            600).             

                                 Page 46 of 48

                  Commitment date Revised                   
                                  commitment                
                  and funding as     date and                                 
      Project     of 7/2004       funding as of             IRS explanation   
      segment     ($000)          4/2005 ($000)    Change   of change
Filing &                                                 Congress passed   
Payment            1/31/05        3/31/06     +14 months legislation       
                                                            allowing          
    Compliance/       $7,250         $13,250      +$6,000   the use of        
                                                            Private           
                                                            Collection        
                                                            Agencies          
Private Debt                                             (PCA) late in     
Collection                                               2004, forcing     
                                                            delay of most     
                                                            F&PC/PDC          
                                                            activities        
                                                            originally        
     (F&PC/PDC)                                             planned for FY    
                                                            2004. IRS is in   
                                                            the               
Release 1                                                process of        
Milestone 3,                                             developing a new  
4a                                                       schedule for      
                                                            Release 1 and     
                                                            will provide a    
                                                            full              
                                                            update in the     
                                                            upcoming FY 2005  
                                                            and               
                                                            2006 Expenditure  
                                                            Plan. $6 million  
                                                            transferred from  
                                                            FY 2004           
                                                            Management        
                                                            Reserve to fully  
                                                            fund original     
                                                            plan activities,  
                                                            including         
                                                            validation and    
                                                            planning of the   
                                                            long-             
                                                            term business     
                                                            strategy (which   
                                                            may               
                                                            include           
                                                            subreleases).     
Modernized                                    +2.5       Milestone 4 exit  
e-File             9/30/04        12/16/04    months     delayed to        
                                                            complete          
     Release 2        $15,325        $15,325                noncritical, post 
                                                            Initial Operating 
    Milestone 4                                             Capability (IOC)  
                                                            testing.          
Modernized     3/31/05 $7,539  3/24/05        -0.25      $2.4 million      
e-File Release                 $10,139        month      transferred from  
3.1 Milestone                                 +$2,600    the FY 2005 Risk  
4                                                        Adjustment to     
                                                            fund $2+ million  
                                                            in Tax Year       
                                                            changes and       
                                                            associated        
                                                            testing costs. An 
                                                            additional $.200  
                                                            million           
                                                            transferred from  
                                                            the FY            
                                                            2004 Risk         
                                                            Adjustment to     
                                                            test and          
                                                            implement tax law 
                                                            changes. Total    
                                                            Segment Cost is   
                                                            $10,139K (7,539 + 
                                                            200 + 2,400).     

                                 Page 47 of 48

                   Commitment   Revised                   
                      date      commitment                
                 and funding as    date and                                   
      Project    of 7/2004      funding as of             IRS explanation of  
      segment    ($000)         4/2005 ($000)    Change   change
Modernized                                  +3.5       Release 3.2         
e-File           10/15/04       2/04/05     months     Milestone 3         
                                                          completion          
    Release 3.2      $3,633         $3,633                delayed by          
                                                          negotiations        
                                                          required to         
    Milestone 3                                           obtain additional   
                                                          funding for         
                                                          Fed/State           
                                                          component. This in  
                                                          turn delayed the    
                                                          start date for      
                                                          Milestone 4.        
Modernized                                             Start date for      
e-File           6/30/05        10/31/05    +4 months  Release 4 Milestone 
                                                          3                   
     Release 4       $8,000         $8,000                delayed until FY    
                                                          2005 funding is     
    Milestone 3                                           approved and        
                                                          received. Release 4 
                                                          Milestone 3 will    
                                                          now begin after     
                                                          Release 3.1 exits   
                                                          Milestone 4.        
Customer                                               Milestone 5 was     
Account          6/30/05        12/31/05    +6 months  extended to the end 
                                                          of                  
    Data Engine     $17,450        $17,450                December 2005 to    
                                                          include changes for 
      (CADE)                                              Filing Seasons 2005 
                                                          (Release 1.2) and   
     Release 1                                            2006 (Release 1.3). 
    Milestone 5                                           
     Customer    12/31/05       12/31/05        +$1,300   Funding covers      
Account Data  $27,000        $28,300                   software            
Engine (CADE)                                          development, a      
    Release 1.3                                           suite of testing,   
                                                          and implementation  
                                                          of the July 2005    
                                                          Release (R1.3.1)    
                                                          and the January     
                                                          2006 Release        
                                                          (R1.3.2). $1.3      
                                                          million transferred 
                                                          from FY 2004        
                                                          Risk Adjustment to  
                                                          fund start-up work  
                                                          on the filing       
                                                          season 2006 changes 
                                                          and ensure the      
                                                          effort stayed on    
                                                          schedule. Total     
                                                          Segment Cost is now 
                                                          $28,300K (27,000 +  
                                                          1,300).             

                                 Page 48 of 48

                  Commitment date Revised                   
                                  commitment                
                  and funding as     date and                                 
      Project     of 7/2004       funding as of             IRS explanation   
      segment     ($000)          4/2005 ($000)    Change   of change
Customer       11/30/05        6/30/06 $7,000 +7 months  The project will  
Account Data   $15,000                        -$8,000    not formally exit 
Engine (CADE)                                            Milestone 4a      
Release 2                                                until June 2006   
Milestone 4a                                             so the logical    
                                                            and physical      
                                                            design may        
                                                            include filing    
                                                            season 2007 tax   
                                                            law changes. This 
                                                            activity is being 
                                                            subdivided into   
                                                            two pieces for FY 
                                                            2005. IRS will    
                                                            use $7 million of 
                                                            the $15 million   
                                                            in FY 2005 to     
                                                            fund traditional  
                                                            Milestone 4a      
                                                            activities,       
                                                            and $8 million to 
                                                            fund Program      
                                                            Management and    
                                                            Transition        
                                                            Management        
                                                            activities. The   
                                                            net increase to   
                                                            the overall CADE  
                                                            fiscal            
                                                            year 2005 budget  
                                                            is zero.          
     Custodial       10/29/04        9/30/04      -1 month  Milestone 4 exit  
                                                            accelerated by    
     Accounting      $105,318        $107,118     +$1,800   changes to        
                                                            initial load      
                                                            approach. $1.8    
Project (CAP)                                            million was       
                                                            transferred from  
                                                            FY 2004           
     Release 1                                              risk adjustment   
                                                            to cover costs of 
    Milestone 4                                             additional        
                                                            testing and       
                                                            resolving data    
                                                            quality issues.   
     Integrated       6/30/05        11/30/05    +5 months  BSMO recognized   
                                                            the need for      
Financial          $15,000        $15,000                Milestone 5 to    
System                                                   include a full    
                                                            accounting        
       (IFS)                                                cycle (year-end   
                                                            close) as part of 
                                                            the               
     Release 1                                              measurement and   
                                                            acceptance of the 
    Milestone 5                                             system, based on  
                                                            rationale         
                                                            provided by       
                                                            the Chief         
                                                            Financial         
                                                            Officer.          

Source: IRS.

                                  Appendix II

                   Comments from the Internal Revenue Service

Appendix II Comments from the Internal Revenue Service

Appendix III

                     GAO Contact and Staff Acknowledgments

David A. Powner, (202) 512-9286

  GAO Contact

In addition to the contact named above, Bernard R. Anderson, John L. Dale,

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Joanne L. Fiorino, Timothy D. Hopkins, and Tonia L. Johnson made key
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