Information Technology: Management Improvements Needed on	 
Immigration and Customs Enforcement's Infrastructure		 
Modernization Program (07-SEP-05, GAO-05-805).			 
                                                                 
The Department of Homeland Security's (DHS) Atlas program is	 
intended to modernize Immigration and Customs Enforcement's (ICE)
information technology (IT) infrastructure. By congressional	 
mandate, DHS is to develop and submit for approval an expenditure
plan for Atlas that satisfies certain legislative conditions,	 
including a review by GAO. GAO was asked to determine whether the
plan satisfied certain legislative conditions and to provide	 
observations on the plan and management of the program. 	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-805 					        
    ACCNO:   A35901						        
  TITLE:     Information Technology: Management Improvements Needed on
Immigration and Customs Enforcement's Infrastructure		 
Modernization Program						 
     DATE:   09/07/2005 
  SUBJECT:   Cost effectiveness analysis			 
	     Enterprise architecture				 
	     Homeland security					 
	     Information technology				 
	     Internal controls					 
	     Investment planning				 
	     Procurement planning				 
	     Program evaluation 				 
	     Program management 				 
	     Risk management					 
	     Strategic planning 				 
	     DHS Atlas Program					 

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GAO-05-805

                 United States Government Accountability Office

                     GAO Report to Congressional Committees

September 2005

                                  INFORMATION
                                   TECHNOLOGY

    Management Improvements Needed on Immigration and Customs Enforcement's
                      Infrastructure Modernization Program

                                       a

GAO-05-805

[IMG]

September 2005

INFORMATION TECHNOLOGY

Management Improvements Needed on Immigration and Customs Enforcement's
Infrastructure Modernization Program

                                 What GAO Found

DHS's fiscal year 2004 Atlas expenditure plan, related documentation, and
program officials' statements satisfied all conditions imposed by
Congress, including (1) meeting the capital planning and investment
control review requirements established by the Office of Management and
Budget (OMB); (2) complying with the DHS enterprise architecture; (3)
complying with the acquisition rules, requirements, guidelines, and
systems acquisition management practices of the federal government; and
(4) being reviewed and approved by ICE's Investment Review Board, DHS, and
OMB. However, this satisfaction is based more on plans and commitments
that provide for meeting these conditions than on completed actions. As
such, much remains to be accomplished for Atlas planning and management
efforts to be considered effective and thereby minimize the risks
associated with the program's capacity to deliver promised IT
infrastructure capabilities and benefits on time and within budget.

GAO developed a number of observations about the expenditure plan and
DHS's management of the program. The observations address the need for
economic justification of Atlas, rigorous and disciplined program
management practices, performance measurements that are linked to goals
and benefits, and an expenditure plan that provides sufficient information
on program commitments for it to be a useful accountability tool. For
example, Atlas's existing economic justification does not reflect recent
and planned changes in the program's scope and purpose, including plans to
expand the program beyond IT infrastructure upgrades. In addition, program
management controls and capabilities have yet to be established. While ICE
has begun to establish an Atlas program office, this office is not yet
operational and is not adequately staffed. For example, while ICE has
assigned a program manager and three contracting staff, it has not yet
determined how many staff will be needed on the Atlas projects. In
addition, while the program manager recently assessed staffing needs for
program support positions, and identified several, none have been filled
(see graphic).

                       Proposed Program Management Office

  Common    Enterprise                Information  Infrastructure  Transformation 
 Computing  Information  Integration   Assurance   Engineering     Planning       

Staffing in place

Staffing need assessed Source: GAO analysis of DHS data.

Staffing need not assessed

United States Government Accountability Office

Contents

    Letter                                                                  1 
                        Compliance with Legislative Conditions              2 
              Other Observations on the Expenditure Plan and Management of 
                                        Atlas                               3 
                                     Conclusions                            5 
                         Recommendations for Executive Action               6 
                                   Agency Comments                          7 

Appendixes

Appendix I:     Briefing to the Staffs of the Subcommittees on Homeland 
                   Security, Senate and House Committees on Appropriations  8 
Appendix II:              Comments from the U.S. Department of Homeland 
                                                                  Security 60 
    Appendix III:                    GAO Contact and Staff Acknowledgments 63 

Abbreviations

DHS Department of Homeland Security
ICE Immigration and Customs Enforcement
IT information technology
OMB Office of Management and Budget

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

A

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

September 7, 2005

The Honorable Judd Gregg
Chairman
The Honorable Robert C. Byrd
Ranking Member
Subcommittee on Homeland Security
Committee on Appropriations
United States Senate

The Honorable Harold Rogers
Chairman
The Honorable Martin Olav Sabo
Ranking Member
Subcommittee on Homeland Security
Committee on Appropriations
House of Representatives

The 2004 Department of Homeland Security Appropriations Act1 provided
$40 million for Immigration and Customs Enforcement's (ICE) program to
modernize its information technology (IT) infrastructure.2 The goals of
the
program-which ICE refers to as "Atlas"-are to, among other things,
improve information sharing, strengthen information security, and improve
workforce productivity. The act provided that the Department of Homeland
Security (DHS) was prohibited from obligating the $40 million until it
developed a plan for how the funds are to be spent that satisfied certain
legislative conditions, including having the plan reviewed by us. On March
16, 2005, DHS submitted its fiscal year 2004 expenditure plan to the
Senate
and House Appropriations Subcommittees on Homeland Security. Pursuant
to the act, we reviewed the plan; our objectives were to (1) determine
whether the plan satisfies legislative conditions specified in the act and
(2)
provide any other observations about the plan and management of the
program.

On May 10 and 24, 2005, we briefed the Senate and House Homeland
Security Subcommittee staffs, respectively, on the results of our review.

1Pub. L. No. 108-90 (Oct. 1, 2003).

2During fiscal year 2004, the Department of Homeland Security reprogrammed
about $30.2 million of the $40 million to address other ICE priorities,
thereby leaving $9.8 million for the program.

This report transmits the results of that work. The full briefing,
including our scope and methodology, is reprinted in appendix I.

  Compliance with Legislative Conditions

DHS satisfied each of the applicable legislative conditions specified in
the act. In particular, the plan, including related program documentation
and program officials' statements, satisfied or provided for satisfying
all key aspects of (1) meeting the capital planning and investment control
review requirements of the Office of Management and Budget (OMB);3 (2)
complying with the DHS enterprise architecture;4 (3) complying with
acquisition rules, requirements, guidelines, and systems acquisition
management practices of the federal government; and (4) having the plan
reviewed and approved by ICE's Investment Review Board, DHS, and OMB.

However, satisfaction of these legislative conditions is based in large
part on plans and oral commitments by program officials that provide for
meeting the conditions. To illustrate, OMB capital planning requirements
direct agencies planning to make a major IT investment, like Atlas, to
among other things (1) summarize the investment's life-cycle costs; (2)
analyze costs and benefits, including return on investment; (3) establish
performance goals and measures; and (4) develop security and privacy
plans. The Atlas program does not have a current life-cycle cost estimate
nor a current cost-benefit analysis showing return on investment. It also
does not have a complete set of performance measures. Further, the program
does not have an up-to-date security plan that includes Atlas, and
officials have yet to develop a privacy impact assessment for the program.
The program manager acknowledged these shortfalls and either planned or
orally committed to fully satisfy the requirements when expenditure plan
funds become available.

3OMB Circular A-11 establishes policy for planning, budgeting, acquiring,
and managing federal capital assets. Capital investment and control
requirements are now found in OMB Circular A-11, part 7, rather than in
part 3.

4An enterprise architecture provides a clear and comprehensive picture of
an organization's operations and its supporting systems and
infrastructure. It is an essential tool for effectively and efficiently
engineering business processes and for implementing and evolving
supporting systems in a manner that maximizes interoperability, minimizes
overlap and duplication, and optimizes performance.

  Other Observations on the Expenditure Plan and Management of Atlas

Our observations address the need for economic justification of Atlas,
rigorous and disciplined program management practices, performance
measurements that are linked to goals and benefits, and an expenditure
plan that provides sufficient information on program commitments to make
the plan a useful accountability tool. An overview of specific
observations follows:

o 	Economic justification (i.e., analysis of costs and benefits) does not
reflect recent and planned changes in the program's scope and purpose. The
existing cost-benefit analysis-which was developed in 2002-has not yet
been revised to reflect changes in the program's scope and purpose. Since
ICE became responsible for Atlas in 2003 (inherited from the Immigration
and Naturalization Service) it has materially changed the program's scope,
purpose, and priorities. Specifically, Atlas was expanded to (1) support
additional law enforcement units5 (and their business requirements) that
were merged into ICE and (2) provide the flexibility to support new ICE
priorities, such as integrating future antiterrorism programs and projects
and facilitating information sharing with domestic and international law
enforcement organizations. In addition, the program is also being expanded
beyond infrastructure upgrades to include efforts to streamline and
reengineer core business functions with the application of IT. According
to the fiscal year 2004 expenditure plan and program manager, revising the
analysis is a "next step" to be taken and the goal is to have a contractor
complete an updated cost-benefit analysis on or about September 30, 2005.

o 	Program management controls and capabilities have yet to be
established. ICE has begun to establish an Atlas program office; however,
the program office is not yet operational. Specifically, the bureau has
drafted a management structure and plan, which includes staff roles and
responsibilities. However, the structure and plan are currently being
reviewed by ICE management and have not been made final. Moreover, of the
$63.52 million that ICE reported was obligated for Atlas in fiscal years
2002 and 2003, only about $900,000 (or about 1.4 percent of the total
amount) was obligated for program management capabilities. In contrast,
our work on other IT modernization programs (including two in DHS) show
that 19 percent was invested in such

5The units include the Federal Air Marshals Service, Federal Protective
Service, Customs investigations, and Customs intelligence.

management capabilities. In addition, while key acquisition management
processes have been defined in ICE's System Development Life Cycle
methodology, the program office has yet to implement these processes.

Further, the program office is not adequately staffed.6 Currently, the
office has staffed the program manager position, and it has three
contracting staff performing functions such as developing staffing needs
assessments and other program management-related activities. While the
program manager recently assessed staffing needs for program support
positions (e.g., financial management, contracting, and enterprise
architecture), he has not yet performed a needs assessment to determine
the staffing needs for the five of the six projects that comprise the
Atlas program. Moreover, of the seven program support positions that the
program manager has determined are needed, none have been filled,
according to program officials. The program manager stated that ICE plans
to strengthen program management controls and capabilities once funds
provided for in the expenditure plan are available.

o 	Program goals, expected benefits, and reported achievements are not
fully aligned. The Atlas expenditure plan and documentation show that the
program has defined goals and expected benefits and has reported actual
achievements accomplished during fiscal years 2002 and 2003. However, the
relationships among goals, benefits, and achievements have not been
defined and are not apparent in all cases. Moreover, the reported
achievements are not expressed in terms of measurable outcomes or results,
but rather as activities completed. The program manager stated that the
2002 and 2003 achievements were not analyzed and aligned to program goals
and benefits, and that outcome-based measures were not developed in part
because the emphasis at the time was on buying and deploying long overdue
infrastructure upgrades as quickly as possible. He stated that in the
future, the program intends to define, ensure, and disclose the linkage
among program goals, benefits, and results.

6According to the program manager, Atlas staffs were transferred to the
US-Visitor and Immigrant Status Indicator Technology program in 2003,
which is managed by the DHS Under Secretary for Border and Transportation
Security.

o 	Fiscal year 2004 expenditure plan does not provide sufficient
information on program commitments to permit effective congressional
oversight. The Atlas expenditure plan does not show the level of detail
and scope of the program needed for Congress to understand its plans and
commitments relative to system capabilities, cost, benefits, and schedule.
Further, it does not sufficiently describe progress made against program
commitments (e.g., expected benefits). According to the program manager,
the state of the plan reflects the program's uncertainty about the
appropriate level of detail in expenditure plans. He stated that future
plans will include missing content.

Conclusions	The fiscal year 2004 Atlas expenditure plan, in combination
with related program documentation and program officials' statements,
satisfies the legislative conditions set forth by Congress. However, this
satisfaction is based more on plans and commitments that provide for
meeting these conditions than on completed actions. As such, much remains
to be accomplished for Atlas planning and management efforts to be
considered effective and thereby minimize the risks associated with the
program's capacity to deliver promised IT infrastructure capabilities and
benefits on time and within budget.

The current state of planning and management puts the program at risk.
While this is partially due to events beyond the program's control, such
as the department's decision to reprogram Atlas funding and to redeploy
Atlas staff to competing DHS priorities, as well as to change the
program's scope and purpose when it transitioned from the Immigration and
Naturalization Service to ICE, it is also due to the program's decision
not to use fiscal years 2002 and 2003 funds to invest in program
management capabilities.

Given that more than $60 million has reportedly been obligated to date on
the program, resources have been available to strengthen planning and
management capabilities in key areas, but investment in these areas has
been deferred. Deferral of establishing such program planning and
management controls and capabilities-such as having reliable and current
economic justification for the program; a capable program office; and
clearly aligned program goals, benefits, and performance measures-
introduce unnecessary risk to the program.

Moreover, not providing congressional decision makers with the information
that they need about program commitments to be met with the

expenditure plan funds-including the benefits to be produced, the
capabilities to be delivered, and the cost and schedule estimates to be
met-impedes congressional oversight.

  Recommendations for Executive Action

To minimize risks to the Atlas program, we recommend that the Secretary of
Homeland Security, through the Under Secretary for Border and
Transportation Security, direct the Assistant Secretary for Immigration
and Customs Enforcement to ensure that ICE follows through on commitments
to implement effective management controls and capabilities by taking the
following five steps:

o 	Revising and updating the cost-benefit analysis, to identify current
mission requirements; how they will be met; and an estimate of the
program's incremental and life-cycle costs, benefit, schedule, and return
on investment. This should also include establishing plans, associated
tasks, and milestones for accomplishing this effort.

o 	Making the Atlas program office operational by (1) developing a
staffing needs assessment to determine the positions and the level of
staffing needed for all projects to adequately manage the program,
including a human capital strategy and timetable for acquiring the staff
and bringing them on board; (2) finalizing the roles and responsibilities
for the positions identified in the staffing assessment and for the
projects; and (3) implementing and institutionalizing key acquisition
management controls, including risk management processes where relevant
responsibilities are assigned and key risks and their status are reported
to an executive body.

o 	Developing and implementing an updated Atlas security plan and privacy
impact assessment. This should also include establishing plans, associated
tasks, and milestones for accomplishing this effort.

o 	Developing and implementing rigorous performance management practices
for the Atlas program that include properly aligned goals, benefits,
achievements, and anticipated achievements that are defined in measurable
terms. This should also include establishing plans, associated tasks, and
milestones for accomplishing this effort.

o 	Ensuring that future expenditure plans fully disclose the system
capabilities, schedule, cost, and benefits to be delivered, as well as the
acquisition strategy for Atlas.

Agency Comments	In the department's written comments on a draft of this
report, which were contained in a letter signed by the director, DHS
Departmental GAO/Office of Inspector General Liaison, DHS concurred with
all of our recommendations and stated actions it was taking to implement
them. DHS's 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
authorization and oversight responsibilities for homeland security. We are
also sending copies to the Secretary of Homeland Security and the Director
of OMB. Copies of this report will also be available at no charge on our
Web site at www.gao.gov.

Should you or your offices have any questions on matters discussed in this
report, please contact me at (202) 512-3439 or at [email protected]. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. Key contributors to this report
are listed in appendix III.

Randolph C. Hite Director, Information Technology Architecture

and Systems Issues

Appendix I

Briefing to the Staffs of the Subcommittees on Homeland Security, Senate and
House Committees on Appropriations

  Information Technology: Management Improvements Needed on Immigration and
  Customs Enforcement's Infrastructure Modernization Program

Briefing to the Staffs of the
Subcommittees on Homeland Security,
Senate and House Committees on Appropriations

May 10 and May 24, 2005

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

o  Introduction

o  Objectives

o  Results in Brief

o  Background

o  Results

o  Legislative Conditions

o  Observations

o  Conclusions

o  Recommendations

o  Agency Comments

o  Attachment I: Scope and Methodology

                                       2

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

The Department of Homeland Security's (DHS) Bureau of Immigration and
Customs Enforcement (ICE)1 is responsible for enforcing border security,
trade, and other laws by, for example, investigating and collecting
intelligence on individuals and groups who act to violate these laws. ICE
is also responsible for detecting and deterring hostile acts on U.S.
commercial aviation and protecting federal facilities.

Atlas is an ICE program to modernize the bureau's information technology
(IT) infrastructure. IT infrastructure includes the hardware (e.g.,
servers, routers, storage devices, communication lines) and system
software (e.g., database management and operating systems and network
management) that provide an environment for operating and maintaining
software applications.

According to ICE, the goals of Atlas include improving information
sharing, strengthening information security, and improving workforce
productivity.

1ICE was formed from the former Immigration and Naturalization Service,
U.S. Customs Service, and other entities. Atlas began in 2002 under the
former INS.

                                       3

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

The fiscal year 2004 Department of Homeland Security Appropriations Act2
appropriated $40 million for Atlas and provided that DHS was prohibited
from obligating these funds until the department submitted a plan for how
the funds were to be spent that satisfied the following legislative
conditions:

o 	meets the capital planning and investment control review requirements
established by the Office of Management and Budget (OMB), including OMB
Circular A-11, part 3,3

o  complies with DHS's enterprise architecture,4

o 	complies with the acquisition rules, requirements, guidelines, and
systems acquisition management practices of the federal government,

2Pub.L. No. 108-90 (Oct. 1, 2003).

3OMB Circular A-11 establishes policy for planning, budgeting,
acquisition, and management of federal capital assets. Capital investment
and control requirements are now found in OMB Circular A-11, part 7,
rather than part 3.

4As agreed with the staffs of the appropriations subcommittees, we
assessed compliance with the DHS enterprise architecture in lieu of the
ICE enterprise architecture.

                                       4

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

                                  Introduction

o 	is reviewed and approved by ICE's Investment Review Board (IRB),5 DHS,
and OMB, and

o  is reviewed by GAO.

During fiscal year 2004, DHS reprogrammed about $30.2 million of the Atlas
funds to cover other ICE priorities, leaving $9.8 million for the program.

DHS submitted its fiscal year 2004 expenditure plan for $9.8 million on
March 16, 2005, to its Senate and House Appropriations Subcommittees on
Homeland Security.

5The purpose of the IRB is to integrate capital planning and investment
control, budgeting, and acquisition. It is also to ensure that spending on
investments directly supports and furthers the mission and that this
spending provides optimal benefits and capabilities to stakeholders and
customers.

                                       5

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

As agreed, our objectives were to

1. determine whether the Atlas fiscal year 2004 expenditure plan satisfies
the legislative conditions, and

2. provide any other observations about the expenditure plan and DHS's
management of the Atlas program.

We conducted our work at DHS and ICE headquarters in Washington, D.C. from
March 2005 through May 2005 in accordance with generally accepted
government auditing standards. Details of our scope and methodology are
provided in attachment I.

                                       6

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Objective 1: Satisfaction of Legislative Conditions

Legislative conditions Status

1.	Meets the capital planning and investment control review requirements
established by OMB, including OMB Circular A-11, Satisfied7 part 7.6

2. Complies with the DHS enterprise architecture. Satisfied

3.	Complies with the acquisition rules, requirements, guidelines, and
systems acquisition management practices of the federal Satisfied
government.

Satisfied

4. Is reviewed and approved by ICE IRB, DHS, and OMB.

5. Is reviewed by GAO. Satisfied

6Capital investment and control requirements are now found in OMB Circular
A-11, part 7, rather than part 3. 7Satisfied: Satisfied or provides for
satisfying every aspect of the condition that we reviewed.

                                       7

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

    Objective 2: Other Observations

o 	Economic justification does not reflect recent and planned changes in
the program's scope and purpose.

o  Program management controls and capabilities have yet to be
established.

o 	Program goals, expected benefits, and reported achievements are not
fully aligned.

o 	Fiscal year 2004 expenditure plan does not provide sufficient
information on program commitments to permit effective congressional
oversight.

                                       8

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Recommendations

We are making recommendations to the Secretary of DHS to improve Atlas
expenditure planning and program management.

In commenting on a draft of this briefing, ICE's chief information officer
and the Atlas program manager agreed with our findings and conclusions and
stated that our recommendations were reasonable.

                                       9

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

ICE was formed as a component agency of DHS in 2003 when the law
enforcement functions of the Justice Department's former Immigration and
Naturalization Service (INS) and the Treasury Department's former Customs
Service, among other agencies, were merged into DHS.

The ICE mission is to ensure the security of the American people and
homeland by investigating violators of, and thereby, enforcing the
nation's immigration and customs laws; protecting U.S. commercial air
carriers, airports, passengers, and crews; policing and securing federal
buildings and other facilities; and collecting, analyzing, and
disseminating intelligence to assist it in these endeavors.

Headed by the Assistant Secretary of Immigration and Customs Enforcement,
ICE has approximately 15,000 employees in over 400 offices domestically
and in other countries.

The Atlas program was started by INS in 2002. Responsibility for the
program was transferred to ICE in 2003 as part of the establishment of
DHS.

The figure on the following page shows ICE and Atlas organizational
placement within the department.

                                       10

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Simplified DHS organizational chart showing ICE and Atlas program

                                       11

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

According to ICE officials, Atlas was initiated to address information
sharing and security limitations within the former INS caused by, for
example,

o  obsolete hardware/software that needed refreshing;

o  incompatible, non-interoperable information systems; and

o  uneven system security capabilities.

These officials stated that these challenges were exacerbated by the
formation of ICE because the organizations that merged into ICE had
different hardware/software environments (e.g., multiple e-mail systems)
and different mission and customer needs.

                                       12

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

The stated goals of Atlas are, among other things, to:

o  enhance workforce productivity,

o  strengthen integrity, security, and privacy of information and data
assets, and

o  promote information sharing and collaboration.

                                       13

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

                                   Background

Continued.

Source: DHS data.

                                       16

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Since fiscal year 2002, Atlas has been provided $143.17 million in
appropriated funds.

o  $39.1 million from INS counterterrorism funding in fiscal year 2002.8

o 	$24.47 million from INS investment and operations and maintenance
funding in fiscal year 2003.

o 	$40 million from DHS appropriations in fiscal year 2004,9 of which
$30.2 million was reprogrammed by DHS to cover other ICE priorities,
leaving $9.8 million.

o  $39.6 million from DHS appropriations in fiscal year 2005.10

8Counterterrorism funding came from the Department of Defense and
Emergency Supplemental Appropriations for Recovery from and Response
to Terrorist Attacks on the United States Act, 2002. Pub. L. No. 107-117
(Jan. 10, 2002); H.R. Report 107-350 (Dec. 19, 2001).
9Pub.L. No. 108-90 (Oct. 1, 2003).
10Pub.L.. No. 108-334 (Oct. 18, 2004).

                                       17

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

The Atlas expenditure plan satisfies each of the legislative conditions.

Condition 1 Satisfied. The expenditure plan, including related program
documentation and statements from the program manager, either satisfies or
provides for satisfying the capital planning and investment control review
requirements established by OMB, including Circular A-11, part 3,13 which
establishes policy for planning, budgeting, acquisition, and management of
federal capital assets.

Examples of our analysis are in the following table. As the table shows,
not all OMB requirements have been satisfied, but oral commitments have
been made for doing so. Given that ICE has reportedly already invested
$63.52 million on Atlas projects and plans to invest another $9.8 million
this year, it is important for ICE to follow through on these commitments.

13Capital investment and control requirements are now found in OMB
Circular A-11, part 7, rather than part 3.

                                       20

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Condition 2 Satisfied. The plan, including related program documentation
and DHS officials' statements, either satisfies or provides for satisfying
the condition that the department ensure Atlas is compliant with DHS's
enterprise architecture (EA).

An EA provides a clear and comprehensive picture of an organization's
operations and its supporting systems and infrastructure. It is an
essential tool for effectively and efficiently engineering business
processes and for implementing and evolving supporting systems in a manner
that maximizes interoperability, minimizes overlap and duplication, and
optimizes performance. We have worked with the Congress, OMB, and the
federal Chief Information Officers Council to highlight the importance of
architectures for both organizational transformation and IT management. An
important element of EA management is ensuring that IT investments are
compliant with EA, including basing such assessments on documented
analysis.

On August 6, 2004, we reported on version 1.0 of DHS's EA, stating that
DHS's initial EA provides a partial foundation but was missing key
elements expected to be found in a well-defined architecture.15 DHS has
since developed version 2.0 of its EA. We have not reviewed this version
of DHS's EA.

15GAO, Homeland Security: Efforts Under Way to Develop Enterprise
Architecture, but Much Work Remains, GAO-04-777 (Washington, D.C.: August
6, 2004).

                                       23

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

DHS's Enterprise Architecture Board and Enterprise Architecture Center of

Excellence16 are responsible for determining whether programs comply with
the

EA. On December 8, 2004, Atlas's program manager requested the center to

assess the program's compliance with the EA. On January 10, 2005, the
center

reported the results of its assessment to the board, stating that Atlas
was in

compliance. On January 12, 2005, the board approved this compliance

determination.

The center based its determination on documentation submitted by the
program

manager and discussions among center staff, including officials from DHS's

Infrastructure Transformation Office and IT Security Office. However, the

determination was not based on documented analysis mapping Atlas's

infrastructure architecture to the EA. Such analysis is necessary to make

informed alignment determinations. According to the center's chair, who
also

serves as DHS's chief architect, because Atlas is in the early stages of
its life

cycle and therefore is not very well defined, such an analysis was not
required,

and when Atlas is more defined, a thorough and documented analysis will be

performed.

16A review group made of subject manner experts that recommends EA
compliance to the DHS Enterprise Architecture Board and ultimately to the
DHS IRB.

                                       24

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Given the critical role that Atlas is to play in contributing to DHS's
strategic information sharing and interoperability goals, it is important
for ICE and DHS to follow through on the stated provision to base future
Atlas compliance determinations on documented and verifiable analysis.

                                       25

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Condition 3 Satisfied. The plan, including related program documentation
and statements from the Atlas program manager, either satisfies or
provides for satisfying the condition to comply with the acquisition
rules, requirements, guidelines, and systems acquisition management
practices of the federal government. These practices provide a management
framework based on the use of rigorous and disciplined processes for
planning, managing, and controlling the acquisition of IT resources,
including:

o 	acquisition planning, which ensures, among other things, that
reasonable plans, milestones, and schedules are developed and that all
aspects of the acquisition effort are included in these plans;

o 	solicitation, which involves making sure that a request for proposal
that delineates a project's requirements is prepared and, consistent with
relevant solicitation laws and regulations, that a contractor is selected
that can most cost-effectively satisfy these requirements;

o 	requirements development and management, which includes establishing
and maintaining a common and unambiguous definition of requirements among
the acquisition team, the system users, and the development contractor;

                                       26

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

o 	project management, provides for management of the activities within
the project office and supporting contractors to ensure a timely,
efficient, and cost-effective acquisition;

o 	contract tracking and oversight, which ensures that the development
contractor performs according to the terms of the contract; needed
contract changes are identified, negotiated, and incorporated into the
contract; and contractor performance issues are identified early, when
they are easier to address; and

o 	evaluation, which determines whether the acquired products and services
satisfy contract requirements before acceptance.

                                       27

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

These acquisition management processes are also embodied in published best
practices models, such as the Software Engineering Institute (SEI)'s
Software Acquisition Capability Maturity Model(R).17 Examples of our
analysis of ICE performance of these processes and practices are shown on
the following table. They show that not all aspects of the processes and
practices have been implemented, but that oral commitments have been made
for doing so. Given that ICE has already invested $63.52 million on Atlas
projects and plans to invest another $9.8 million this year, it is
important for ICE to follow through on these commitments.

17Developed by Carnegie Mellon Software Engineering Institute (SEI),
Software Acquisition Capability Maturity Model (SA-CMM(R)), Version 1.03
(March 2002).

                                       28

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Condition 4 Satisfied. DHS and OMB satisfied the legislative condition
requiring that the plan be reviewed and approved by the ICE IRB, DHS, and
OMB.

o 	The ICE IRB chair approved the fiscal year 2004 expenditure plan on
November 16, 2004.

o 	The DHS chief information officer, who also chairs the Enterprise
Architecture Board, approved the plan on January 12, 2005.

o  OMB approved the plan on January 4, 2005.

Condition 5 Satisfied. GAO satisfied the condition that it review the
plan.

Our review was completed on May 5, 2005.

                                       30

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 1: Economic justification does not reflect recent and planned
changes in the program's scope and purpose.

Cost-benefit analyses are essential tools for making informed program
investment selection and control decisions and for establishing the return
on investment benchmark against which to measure whether investments are
delivering intended business value. Accordingly, the Clinger-Cohen Act,
OMB guidance,21 and investment management best practices recognize the
importance of having reliable and current cost-benefit analyses.

INS developed an analysis of Atlas's costs and benefits in 2002. The
analysis estimated that the program would cost about $800 million to
implement over a 6year period and would provide benefits of approximately
$1.1 billion dollars, primarily through better system response times and
reduced operations and maintenance costs, as shown in the following
figure.

21Clinger-Cohen Act of 1996, 40 U.S.C. 11101-11704; and Office of
Management and Budget (OMB) Circular A-130, Management of Federal
Information Resources (November 30, 2000).

                                       31

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Sources of Atlas program benefits

As we have previously reported,22 it is important for cost-benefit
analyses to be updated to reflect material changes to a program's scope,
purpose, cost, timeframes, etc., so that agency officials will have a
reliable basis for program investment decisions.

22For example, see GAO, Information Technology: Greater Use of Best
Practices Can Reduce Risks in Acquiring Defense Health Care System,
GAO-02-345 (Washington, D.C.: September 26, 2002).

                                       32

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 1: Cont.

Since ICE became responsible for Atlas in 2003, the bureau has materially
changed the program's scope, purpose, and priorities. Specifically, Atlas
was expanded to

o 	support additional law enforcement units (and their business
requirements) that were merged into ICE (e.g., Federal Air Marshals
Service, Federal Protective Service, Customs investigations, Customs
intelligence); and

o 	provide the flexibility to support new ICE priorities (e.g.,
integrating future anti-terrorism programs and projects, facilitating
information sharing with domestic and international law enforcement
organizations).

In addition, the program manager said that the program is to include
efforts to streamline and reengineer core business functions with the
application of information technology. According to this official, details
of these efforts are to be defined in the fiscal year 2005 Atlas
expenditure plan.

                                       33

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 1: Cont.

According to the Atlas program manager, the cost benefit analysis has not
yet been revised to reflect changes to the program's scope and purpose
because doing so has not been a priority. According to the fiscal year
2004 expenditure plan, revising the analysis is a "next step" to be taken.
However, existing plans do not identify a date for doing so. The program
manager stated that a current cost-benefit analysis will be developed once
funds provided for in the expenditure plan become available. He also
stated that the goal is to have a contractor complete an updated cost
benefit analysis on or about September 30, 2005.

Until the cost benefit analysis is revised to reflect recent and planned
changes to the program, DHS will not have a reliable basis for making
informed Atlas investment decisions.

                                       34

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Program management controls and capabilities have yet to be
established.

As we have previously reported,23 the success of major modernization
programs such as Atlas depends on having an operational program office
that has, among other things, effectively implemented rigorous and
disciplined program management process controls and adequately filled key
human capital positions. Two activities key to strategically managing
human capital are performing staffing needs assessments and defining staff
roles and responsibilities.

The SEI's Software Acquisition Capability Maturity Model (SA-CMM(R))24 has
defined a suite of key acquisition process areas that are necessary to
manage the system acquisition program in a rigorous and disciplined
fashion. As described earlier in the briefing, these process areas
include:

o  acquisition planning,

o  solicitation,

o  requirements development and management,

o  project management,

o  contract tracking and oversight, and

o  evaluation.

23 For example, see GAO, Information Technology: Homeland Security Needs
to Improve Entry Exit System Expenditure Planning, GAO-03-563 (Washington,
D.C.: June 9, 2003).

24 Carnegie Mellon Software Engineering Institute, Software Acquisition
Capability Maturity Model (SA-CMM(R)), Version 1.03 (March 2002). 35

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Cont.

ICE has begun to establish an Atlas program office. For example, the
bureau has drafted a management structure and plan, which includes staff
roles and responsibilities. However, the structure and plan are currently
being reviewed by ICE management and the program office is not yet
operational. Moreover, while key acquisition management processes have
been defined in the System Development Life Cycle methodology, which our
previous work25 has shown adequately defines the critical management
processes needed to successfully acquire systems, the program office has
yet to implement these processes.

25 For example, see GAO, Information Technology: Homeland Security Needs
to Improve Entry Exit System Expenditure Planning, GAO-03-563 (Washington,
D.C.: June 9, 2003).

                                       36

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Cont.

In addition, the program office is not adequately staffed.26 Currently,
the office has staffed the program manager position and it has three
contracting staff performing such functions as developing staffing needs
assessments and other program management related activities. Further,
while the program manager recently assessed staffing needs for program
support positions (e.g., financial management, contracting, EA), he has
not yet determined the staffing needs for five Atlas projects.
Specifically, the program manager recently asked, and the project managers
provided estimates of, staffing needed, but these estimates were not based
on an estimating methodology or staffing needs assessment. Instead, the
project managers provided estimates of the staff that could be obtained
given the funding provided in the plan. Moreover, of the seven program
support positions that the program has determined it needs, none have been
filled. (The figure on the next slide shows the proposed office structure,
along with the organizational areas where staffing needs have and have not
been assessed, and where staffing needs have and have not been filled.)

26According to the program manager, Atlas staff were transferred to the
US-Visitor and Immigrant Status Indicator Technology program in 2003,
which is managed by the DHS Under Secretary for Border and Transportation
Security.

                                       37

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Cont. Proposed Program Management Office

27Government full-time employees 38
28Contracting full-time employees
29According to the program manager, the staff for the Transformation
Planning project also serve as the staff for the program office.

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Cont.

The program manager attributes the state of the program office, including
controls and capabilities, to competing DHS priorities. He stated that ICE
plans to strengthen program management controls and capabilities once
funds provided for in the expenditure plan are available. In particular,
he cited two projects (Transformation Planning and Infrastructure
Engineering) in the expenditure plan that have this goal. However,
existing program documentation does not describe how and when these
projects are to achieve this goal. Moreover, it should be noted that of
the $63.52 million obligated for Atlas in fiscal years 2002 and 2003,
$900,000 (or about 1.4 percent of the total) was obligated for these two
projects. While the current expenditure plan proposes investing $2.17 of
the $9.8 million on these two projects, this still represents but 4
percent of the $73.37 million Atlas funding to date going to improving
program management. By contrast, our work on other IT modernization
programs, such as US-VISIT, shows that roughly 19 percent was invested in
program management.

                                       39

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 2: Cont.

Until the above program management controls and capabilities are in place
and functioning, ICE faces the increased likelihood that Atlas will not
meet its objectives on schedule and within budget.

                                       40

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 3: Program goals, expected benefits, and reported achievements
are not fully aligned.

The Clinger-Cohen Act30 requires the use of effective IT management
practices, including measuring the contributions of IT investments to
achieving agency mission outcomes. To this end, OMB states31 that agencies
should, among other things

o  establish program performance goals and expected benefits,

o 	develop outcome-based measures to assess actual program performance
(i.e., achievements) against expected benefits, and

o  ensure that goals, expected benefits, and achievements are properly
aligned.

30Clinger-Cohen Act of 1996, Public Law 104-106; and Office of Management
and Budget (OMB) Circular A-130, Management of Federal Information
Resources (November 30, 2000). 31OMB Circular No. A-11, Part 7 (revised
July 2004).

                                       41

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 3: Cont.

The Atlas expenditure plan and documentation show that the program has
defined goals and expected benefits and has reported actual achievements
accomplished during 2002 and 2003. The stated goals include:

o  enhancing productivity, and

o  assuring integrity, security, and privacy of information and data
assets, and

o  promoting information sharing and collaboration.

The stated benefits include:

o  better response time,

o  reduced operations/maintenance costs,

o  improved reliability, and

o  enhanced help desk operations.

                                       42

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 3: Cont.
In addition, examples of stated achievements are

o  purchased Active Directory hardware and software for the e-mail system,

o  initiated an interim Security Operations Center, and

o  developed a data encryption approach for the network.

However, the relationships among goals, benefits, and achievements have
not been defined, and are not otherwise apparent in all cases. For
example, it is not clear how the following reported achievements relate to
Atlas goals.

o  improving the capacity of the network,

o  implementing tools to monitor network performance, and

o  completing an Enterprise Information Concept of Operations document.

Moreover, the reported achievements are not expressed in terms of
measurable outcomes or results, but rather as activities completed.

                                       43

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 3: Cont.

The program manager stated that the 2002 and 2003 achievements were not
analyzed and aligned to program goals and benefits and outcome-based
measures were not developed because the emphasis at the time was on buying
and deploying long-overdue infrastructure upgrades as quickly as possible.
However, he also stated that the program intends to define, ensure, and
disclose the linkage among program goals, benefits, and results in the
future. To this end, the program manager stated that one performance
measure for each project has been defined as a starting point and that
other outcome-based performance measures will be defined and used to
assess program progress. However, existing program plans and documentation
do not specify how and when this will be done.

The program manager also told us that the state of Atlas's performance
practices are due to competing DHS priorities limiting the resources that
have been devoted to the program. Until the program aligns its goals,
benefits, and performance measures, it will not have the necessary means
for measuring progress, ensuring accountability, and making well-informed
investment decisions.

                                       44

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 4: Fiscal year 2004 expenditure plan does not provide
sufficient information on program commitments to permit effective
congressional oversight.

As we have previously reported,32 the legislative requirement to submit
expenditure plans for major IT modernization programs, like Atlas, to the
Appropriations Committees is intended to provide lawmakers with a
sufficient understanding of the programs to permit informed
decision-making about the use of the appropriated funds and provide a
mechanism for holding the agency accountable for results. Our prior
experience in working with Congress and other agencies on developing and
implementing expenditure plans shows that these plans need to disclose a
sufficient level and scope of information for Congress to understand what
the system capabilities and benefits are to be delivered, by when, at what
cost, and what progress is being made against the commitments.

The Atlas expenditure plan does not show the level of detail and scope of
the program for Congress to understand its plans and commitments relative
to system capabilities, cost, benefits, and schedule. Further, it does not
sufficiently describe progress made against program commitments (e.g.,
expected benefits).

32For example, see GAO, Information Technology: Homeland Security Needs to
Improve Entry Exit System Expenditure Planning, GAO-03-563 (Washington,
D.C.: June 9, 2003).

                                       45

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Observation 4: Cont.

Instead, the expenditure plan and supporting documentation describe, for
example, high-level system capabilities to be delivered under each
project, planned expenditure aggregated by project (not linked to system
capabilities). It does not link planned expenditures to system
capabilities, set milestones for delivery of system capabilities, or
discuss benefits to be realized as a result of planned system investments.

According to the Atlas program manager, the state of the plan reflects the
program's uncertainty about the appropriate level of detail in expenditure
plans. This official also stated that future plans will reflect GAO's
published work on the content of program expenditure plans. If it does
not, the Congress will not have essential information needed to make
informed decisions about expenditure plan approval and to oversee
progress.

                                       46

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

The fiscal year 2004 Atlas expenditure plan, in combination with related
program documentation and program officials' statements, satisfies the
legislative conditions set forth by Congress. However, this satisfaction
is based on plans and commitments that provide for meeting these
conditions, rather than on completed actions to satisfy the conditions. As
such, much remains to be accomplished before Atlas planning and management
efforts can be considered effective and thereby minimize the risks
associated with the program's capacity to deliver promised IT
infrastructure capabilities and benefits on time and within budget.

The current state of planning and management puts the program at risk.
While this is partially due to events beyond the program's control, such
as the department's decision to reprogram Atlas funding and to redeploy
Atlas staff to competing DHS priorities, as well as changes to the
program's scope and purpose when it transitioned from INS to ICE, it is
also due to the program's decision to not use fiscal year 2002 and 2003
funds to invest in program management capabilities.

                                       47

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

Given that more than $60 million has been reportedly obligated to date on
the program, resources have been available to strengthen planning and
management capabilities in key areas, but investment in these areas has
been deferred. Deferral of establishing such program planning and
management controls and capabilities, such as having reliable and current
economic justification for the program, a capable program office, and
clearly aligned program goals, benefits, and performance measures,
introduce unnecessary risk to the program.

Moreover, not providing congressional decision-makers with the information
that they need about program commitments to be met with the expenditure
plan funds, including the benefits to be produced, the capabilities to be
delivered, and the cost and schedule estimates to be met, impedes
congressional oversight.

                                       48

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

To minimize risks to the Atlas program, we recommend that the Secretary of
Homeland Security, through the Under Secretary for Border and
Transportation Security, direct the Assistant Secretary for Immigration
and Customs Enforcement to ensure that ICE follows through on commitments
to implement effective management controls and capabilities by

o 	Revising and updating the cost-benefit analysis to identify current
mission requirements, how they will be met, and an estimate of the
program's incremental and life-cycle costs, benefit, schedule, and return
on investment. This should also include establishing plans, associated
tasks, and milestones for accomplishing this effort.

o 	Making the Atlas program office operational by (1) developing a
staffing needs assessment to determine the positions and the level of
staffing needed for all projects to adequately manage the program,
including a human capital strategy for acquiring the staff and a timetable
for bringing them on board; (2) finalizing the roles and responsibilities
for the positions identified in the staffing assessment and for the
projects; and (3) implementing and institutionalizing key acquisition
management controls, including risk management processes where relevant
responsibilities are assigned and key risks and their status are reported
to an executive body.

                                       49

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

o 	Developing and implementing an updated Atlas security plan and privacy
impact assessment. This should also include establishing plans, associated
tasks, and milestones for accomplishing this effort.

o 	Developing and implementing rigorous performance management practices
for the Atlas program that include properly aligned goals, benefits, and
achievements, and anticipated achievements that are defined in measurable
terms. This should also include establishing plans, associated tasks, and
milestones for accomplishing this effort.

o 	Ensuring that future expenditure plans fully disclose the system
capabilities, schedule, cost-benefits to be delivered, as well as the
acquisition strategy for Atlas.

                                       50

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

In providing oral comments on a draft of this briefing, ICE's chief
information officer and the Atlas program manager agreed with our findings
and conclusions and stated that our recommendations were reasonable. They
also provided technical comments, which we incorporated in the briefing as
appropriate.

                                       51

Appendix I
Briefing to the Staffs of the Subcommittees
on Homeland Security, Senate and House
Committees on Appropriations

To accomplish our objectives, we

o 	analyzed the fiscal year 2004 Atlas expenditure plan and supporting
documents against legislative conditions and other relevant federal
requirements, guidance, and best practices to determine whether the
conditions were met, and in doing so, considered the conditions met when
the expenditure plan, including supporting program documentation and
program officials' representations, either satisfied or provided for
satisfying the conditions, and

o 	assessed supporting documentation and interviewed program and other
involved ICE and DHS officials to determine capabilities in key program
management areas, such as

o  acquisition planning,

o  enterprise architecture,

o  project management,

o  human capital planning, and

o  risk management.

For DHS data that we did not substantiate, we have made appropriate
attribution indicating that data's source.

We conducted our work at ICE and DHS headquarters in Washington, D.C. from
March 2005 through May 2005 in accordance with generally accepted
government auditing standards.

                                       52

Appendix II

Comments from the U.S. Department of Homeland Security

Appendix II
Comments from the U.S. Department of
Homeland Security

Appendix II
Comments from the U.S. Department of
Homeland Security

Appendix III

                     GAO Contact and Staff Acknowledgments

GAO Contact Randolph C. Hite, (202) 512-3439

Staff 	In addition to the individual named above, Gary Mountjoy, Assistant
Director; Nancy Glover; James Houtz; and Tammi Nguyen made key

  Acknowledgments contributions to this report.

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