Homeland Security: Transforming Departmentwide Financial	 
Management Systems Remains a Challenge (28-JUN-07, GAO-07-1041T).
                                                                 
Since 2003, when the Department of Homeland Security (DHS) began 
operations, it has faced the difficult challenge of bringing	 
together 22 diverse agencies and developing an integrated	 
financial management system to provide reliable, timely, and	 
useful financial information. GAO's 2007 report, Homeland	 
Security: Departmentwide Integrated Financial Management Systems 
Remain a Challenge, GAO-07-536, emphasized the key issues related
to DHS attempting to transform its financial management systems. 
For today's hearing, this testimony, based on GAO's recent	 
report, (1) summarizes DHS's financial system transformation	 
efforts, (2) points out key financial system transformation	 
challenges at DHS, and (3) highlights the building blocks that	 
DHS should consider to form the foundation for successful	 
financial management system transformation efforts.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-1041T					        
    ACCNO:   A71611						        
  TITLE:     Homeland Security: Transforming Departmentwide Financial 
Management Systems Remains a Challenge				 
     DATE:   06/28/2007 
  SUBJECT:   Best practices					 
	     Concept of operations				 
	     Federal agency reorganization			 
	     Financial management				 
	     Financial management systems			 
	     Homeland security					 
	     Human capital management				 
	     Internal controls					 
	     Requirements definition				 
	     Risk management					 
	     Standards						 
	     Strategic planning 				 
	     Systems conversions				 
	     Program implementation				 

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GAO-07-1041T

   

     * [1]Background
     * [2]eMerge2 Project Was Unsuccessful
     * [3]Financial Management Systems Transformation Efforts Are Inco
     * [4]Four Key Building Blocks and Effective Human Capital Managem
     * [5]Concluding Observations
     * [6]Contacts and Acknowledgments

          * [7]Order by Mail or Phone

Testimony

Before the Subcommittee on Federal Financial Management, Government
Information, Federal Services, and International Security, Committee on
Homeland Security and Governmental Affairs, U.S. Senate

United States Government Accountability Office

GAO

For Release on Delivery
Expected at 3:00 p.m. EDT
Thursday, June 28, 2007

HOMELAND SECURITY

Transforming Departmentwide Financial Management Systems Remains a
Challenge

Statement of McCoy Williams
Director, Financial Management and Assurance

Keith Rhodes
Chief Technologist, Applied Research and Methods
Center for Technology and Engineering

GAO-07-1041T

Mr. Chairman and Members of the Subcommittee:

It is a pleasure to be here today to participate in this hearing on the
Department of Homeland Security's (DHS) ongoing efforts to effectively
modernize its financial management systems. Modern financial management
systems are a critical component to instituting strong financial
management as called for by the Chief Financial Officers (CFO) Act of
1990,^1 the Federal Financial Management Improvement Act of 1996,^2 and
other legislation. Hearings such as this one today can be very useful to
foster meaningful financial management reform.

Over the years, we have reported on various agencies' financial management
system implementation failures. As we testified^3 in March 2006, agencies
continue to struggle with developing and implementing integrated financial
management systems that achieve expected functionality within cost and
timeliness goals. Our recent report,^4 which was prepared at the request
of this subcommittee, discusses in detail some of the most significant
problems and observations we identified with DHS's financial management
system modernization efforts. Since 2003, GAO has designated implementing
and transforming DHS as high risk^5 because the agency has yet to
implement a corrective action plan that includes a comprehensive
transformation strategy, and because its management systems--especially
related to financial, information, acquisition, and human capital
management--are not yet integrated and wholly operational. Today, we would
like to provide our perspectives on the importance of DHS following best
practices in developing and implementing its financial management systems.
Specifically, we would like to

^1Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990). The Department of
Homeland Security Financial Accountability Act of 2004, Pub. L. No.
108-330 S 3, 118 Stat. 1275, 1276 (Oct. 16, 2004), added DHS to the list
of CFO Act agencies.

^2Pub. L. No. 104-208, div. A., S 101(f), title VIII, 110- Stat. 3009,
3009-389 (Sept. 30, 1996).

^3GAO, Financial Management Systems: DHS Has an Opportunity to Incorporate
Best Practices in Modernization Efforts, [8]GAO-06-553T (Washington, D.C.:
Mar. 29, 2006).

^4GAO, Homeland Security: Departmentwide Integrated Financial Management
Systems Remain a Challenge, [9]GAO-07-536 (Washington, D.C.: June 21,
2007).

^5GAO, High-Risk Series: An Update, [10]GAO-07-310 (Washington, D.C.:
January 2007).

           o summarize DHS's financial management systems transformation
           efforts,
           o point out key financial management system transformation
           challenges at DHS, and
           o highlight the building blocks that form the foundation for
           successful financial management system transformation efforts.

Our statement is based upon our recently issued report,^6 as well as our
previous reports and testimonies, which were performed in accordance with
U.S. generally accepted government auditing standards.

Background

Since DHS began operations in March 2003, as mandated by the Homeland
Security Act of 2002,^7 it has faced the daunting task of bringing
together 22 diverse agencies and developing an integrated financial
management system. DHS inherited many financial management weaknesses and
vulnerabilities from the 22 agencies. Auditors had identified 30
reportable conditions,^8 18 of which were considered material internal
control weaknesses^9 in the components prior to the transfer to DHS. In
fiscal year 2003, the DHS financial statement auditors reported 14
reportable conditions, of which 7 were considered to be material
weaknesses. While incremental progress has been made, the material
internal control weaknesses and financial reporting problems continued in
fiscal year 2006. In fiscal year 2006, while the total number of
reportable conditions decreased to 12, the number of material weaknesses
increased to 10. Some of the more recent material weaknesses identified by
the auditors include problems with fund balance with treasury, budgetary
accounting, and intergovernmental balances.

^6 [11]GAO-07-536 .

^7Pub. L. No. 107-296, 116 Stat. 2135 (Nov. 25, 2002).

^8Under standards issued by the American Institute of Certified Public
Accountants (AICPA), reportable conditions are matters coming to the
auditors' attention relating to significant deficiencies in the design or
operation of internal controls that, in the auditors' judgment, could
adversely affect the department's ability to record, process, summarize,
and report financial data consistent with the assertions of management in
the financial statements. The AICPA recently revised its guidance for
audits of financial statements beginning on or after December 15, 2006, to
replace the term "reportable condition" with "significant deficiency."

^9A material weakness was previously defined as a reportable condition in
which the design or operation of one or more of the internal control
components does not reduce to a relatively low level the risk that
misstatements caused by error or fraud in amounts that would be material
in relation to the financial statements being audited may occur and not be
detected within a timely period by employees in the normal course of
performing their assigned functions. The new definition of a material
weakness is a significant deficiency, or combination of significant
deficiencies, that results in more than a remote likelihood that a
material misstatement of the financial statements will not be prevented or
detected. According to AICPA guidance, this change is effective for audits
of financial statements beginning on or after December 15, 2006.

In early March 2007, DHS officials issued the Internal Controls Over
Financial Reporting (ICOFR) Playbook, a high-level plan with a stated
purpose of addressing the existing internal control weaknesses. DHS
officials have reported that the ICOFR Playbook draws from internal
control best practices to establish a management control program that
measures performance and provides accountability for improvement. DHS
officials expect the ICOFR Playbook to guide DHS for the next several
years through fundamental financial management improvement across the
spectrum of financial activities supporting the agency's mission.

eMerge^2 Project Was Unsuccessful

DHS began implementation of the Electronically Managing Enterprise
Resources for Government Effectiveness and Efficiency (eMerge^2) program
in January 2004 to integrate financial management systems across the
entire department and to address the department's financial management
weaknesses. eMerge^2 was expected to establish the strategic direction for
migration, modernization, and integration of DHS financial, accounting,
procurement, personnel, asset management, and travel systems, processes,
and policies. In February 2005, the DHS CFO conducted a review of the
eMerge^2 effort. DHS chose not to exercise the next contract option, and
DHS's contract with Bearing Point, Inc. (Bearing Point), the systems
integrator, to acquire and implement eMerge^2 expired in December 2005.

In March 2006, DHS's Deputy CFO testified^10 that eMerge^2 was taking a
new direction in that the department was going to perform an assessment of
existing financial management systems at the component level to determine
whether internal resources could be leveraged. DHS officials also reported
that they were going to review the Office of Management and Budget's (OMB)
Financial Management Line of Business initiative to assess whether
migration to a shared service provider was a feasible option. In March
2006, we testified^11 that DHS was at an important crossroads in
implementing a financial management system, and we discussed the necessary
building blocks that form the foundation for successful financial
management system implementation efforts.

^10Department of Homeland Security, March 29, 2006, testimony before the
House Government Reform Subcommittee on Government Management, Finance,
and Accountability and the House Homeland Security Subcommittee on
Management, Integration, and Oversight.

Finally, in September 2006, the newly appointed CFO stated that eMerge^2
was officially "dead." See figure 1 for a summary of the eMerge^2
timeline. DHS officials have stated that approximately $52 million was
spent on the eMerge^2 project before it was halted in December 2005. DHS
could not provide any documentation to support these reported costs. DHS's
decision to end the project before spending an estimated $229 million on a
financial management system that would not provide the expected system
functionality and desired performance was prudent, and we support the
decision to cut its losses. However, the agency has made little progress
since that time and has missed an invaluable opportunity to address
existing financial management problems.

^11 [12]GAO-06-553T .

Figure 1: Timeline of Key eMerge^2 Events

Financial Management Systems Transformation Efforts Are Incomplete

While DHS officials have recognized the need for an integrated financial
management system, the department has not developed an overall financial
management transformation strategy that includes financial management
policies and procedures, standard business processes, a human capital
strategy, and effective internal controls. DHS officials have acknowledged
that the ICOFR Playbook has a policy and process focus and does not
comprise a strategy for financial systems modernization. DHS's high-level
financial management systems strategy, Transformation and Systems
Consolidation (TASC), focuses on leveraging existing systems investments
across DHS components, and is still in the early stages of development.
More detailed implementation strategies will be necessary to fully address
financial management system integration efforts.

DHS recently provided us with its high-level strategy--TASC--which calls
for DHS to consolidate its financial management systems into one of two
models: the Transportation Security Administration (TSA) systems model or
the U.S. Customs and Border Protection (CBP) systems model, which the
department refers to as shared baselines. Some of the main objectives of
this strategy are to realize cost savings and operational efficiencies,
reduce the number of financial systems, and ensure that internal controls
are embedded in these financial systems. DHS and OMB officials told us
that OMB approved DHS's decision to rely on its in-house core financial
management operations.

Our concern is that the components where the proposed shared baselines are
currently in use have numerous financial management weaknesses and
consequently do not appear to be good candidates to be the models for an
entity with an annual budget in excess of $40 billion. For example, the
financial statement auditors for TSA reported^12 that TSA--which is
serviced by the Coast Guard--was unable to provide sufficient evidential
matter or make knowledgeable representations to support fiscal year 2005
and 2006 transactions and account balances, particularly for budgetary
accounting and undelivered orders and property, plant, and equipment,
among others. While DHS officials have stated that TSA's audit
shortcomings were centered on policies and procedures and are not
systems-oriented problems, our analysis of the auditor's report indicated
that the problems were broad based. As DHS has recognized, success in
financial management rests upon a comprehensive framework of people,
policies, processes, systems, and assurance. Accordingly, it is imperative
that DHS fully understands the policy and procedures weaknesses at TSA in
order to prevent such weaknesses from affecting subsequent users.

^12Department of Homeland Security, Performance and Accountability Report
Fiscal Year 2006 (Washington, D.C.: November 2006).

In addition, the TASC strategy document and other draft documents DHS
recently provided to us are incomplete. The documents provide a high-level
perspective of the systems comprising the TSA shared baseline and broad
time frames for migrating various DHS components. Much more detailed
planning is needed to ensure that DHS has a solid foundation and road map
for this transformation effort. For example, it is not clear which DHS
component is expected to host^13 the TSA shared baseline and what other
services will be provided. Issues related to how this change will affect
DHS's human capital are not yet addressed. Further, the TASC strategy does
not address the CBP baseline nor, most importantly, how these various
systems will ultimately be unified for departmentwide information needs.
Much more detail is needed to provide a financial management strategy or
plan for integrating and modernizing DHS's financial management systems.

Moreover, we would like to highlight the need for a close
interrelationship between TASC and the ICOFR Playbook. The ICOFR Playbook
calls for policies and procedures to be developed in a variety of
financial management areas, such as intragovernmental transactions; legal
and other liabilities; budgetary accounting; property, plant, and
equipment; and operating materials and supplies. It is important that
these policies and procedures be embedded in the financial systems that
are discussed in TASC so that rework is minimized. While the ICOFR
Playbook in particular continues to focus primarily on getting a "clean"
audit opinion on DHS's annual financial statements, getting a "clean"
audit opinion, although important, is not the end goal. The end goal is to
establish a fully functioning CFO operation that includes (1) modern
financial systems that provide reliable, timely, and useful information to
support day-to-day decision making and oversight and for the systematic
measurement of performance; (2) a cadre of highly qualified senior-level
and supporting staff; and (3) sound internal controls that safeguard
assets and ensure proper accountability. Ultimately, DHS must be able to
provide reliable, useful, and timely financial management information so
that DHS leadership and the Congress are well positioned to make fully
informed decisions to secure America's homeland.

^13Information technology hosting involves providing secure facility
space, networks, and hardware to host software applications and providing
the necessary personnel to operate this secure environment.

Four Key Building Blocks and Effective Human Capital Management Must Drive DHS's
Financial Management Transformation Efforts

Mr. Chairman, at this time I would like to point out that based on
industry best practices, we have identified four key building blocks that
will be critical to DHS's ability to successfully complete its financial
transformation. Our March 2006 testimony^14 and, more recently, our report
for this subcommittee,^15 pointed out that careful consideration of these
four concepts, each one building upon the next, will be integral to the
success of DHS's strategy. The four concepts are (1) developing a concept
of operations, (2) defining standard business processes, (3) developing a
migration and/or implementation strategy for DHS components, and (4)
defining and effectively implementing disciplined processes necessary to
properly manage the specific projects. Fully embracing these four building
blocks and human capital best practices will be critical to the success of
any future financial management system plan or strategy for transforming
departmentwide financial management systems at DHS. We have continued to
refine these key issues to ensure they remain closely aligned with DHS's
stated approach--most recently, the department's TASC strategy.

DHS also has an opportunity to reap substantial benefits by reengineering
business processes and standardizing those processes to realize
productivity gains and staff portability across the various components. In
addition, identifying staff with the requisite skills to implement such
systems and identifying gaps in needed staff skills and filling them are
necessary to successfully implementing and operating a new financial
management system. Any DHS financial management system transformation plan
or strategy will be inherently complex and challenging, making the
adoption of best practices even more important for this undertaking. Table
1 highlights the key issues to be considered for each of the four areas.

^14 [13]GAO-06-553T .

^15 [14]GAO-07-536 .

Table 1: Key Issues for DHS to Consider Based on the Four Building Blocks

Building block                    Key issues                               
Concept of operations: Describe      o Define how DHS's day-to-day         
systems characteristics for a        financial management operations are   
proposed system from a user's        and will be carried out to meet       
perspective                          mission needs.                        
                                        o Clarify which component and         
                                        departmentwide systems are considered 
                                        financial management systems.         
                                        o Include a transition strategy that  
                                        is useful for developing an           
                                        understanding of how and when changes 
                                        will occur.                           
                                        o Develop an approach for obtaining   
                                        reliable information on the costs of  
                                        its financial management systems      
                                        investments.                          
                                        o Link DHS's concept of operations to 
                                        its enterprise architecture.          
Standard business process:           o Assign responsibility for           
Identify preferred business          developing departmentwide standard    
processes to standardize             business processes that meet the      
applications and training and        needs of its component agencies.      
portability of staff                 o Develop an approach to encourage    
                                        agencies to adopt new processes       
                                        rather than selecting other methods   
                                        that simply automate old ways of      
                                        doing business.                       
                                        o Provide a foundation for component  
                                        efforts to describe the business      
                                        processes needed for unique missions, 
                                        or develop subprocesses to support    
                                        those at the departmentwide level.    
Strategy for implementing the        o Develop specific criteria for       
shared baseline approach: Utilize    requiring component agencies to       
a detailed plan to consolidate       migrate to one of the shared          
financial management operations      baselines rather than attempting to   
                                        develop and implement their own       
                                        stovepiped business systems.          
                                        o Provide the necessary information   
                                        for a component agency to make a      
                                        selection of a shared baseline        
                                        system.                               
                                        o Define and instill new values,      
                                        norms, and behaviors within component 
                                        agencies that support new ways of     
                                        doing work and overcoming resistance  
                                        to change.                            
                                        o Build consensus among customers and 
                                        stakeholders on specific changes      
                                        designed to better meet their needs.  
                                        o Plan, test, and implement all       
                                        aspects of the transition from one    
                                        organizational structure and business 
                                        process to another.                   
Disciplined processes: Reduce        o Incorporate industry standards and  
development time and enhance         best practices into DHS-wide guidance 
effectiveness by adopting            related to financial management       
industry standards and best          systems implementation efforts.       
practices                            o Take actions to reduce risks and    
                                        costs associated with data conversion 
                                        and interface efforts.                
                                        o Adopt an oversight process to       
                                        ensure that modernization efforts     
                                        effectively implement the prescribed  
                                        policies and procedures.              

Source: GAO.

As we previously stated, effective human capital management is critical to
the success of any transformation effort. We reported in our Executive
Guide: Creating Value Through World-class Financial Management^16 that
having staff with the appropriate skills is key to achieving financial
management improvements, and managing an organization's employees is
essential to achieving results. Strategic human capital management for
financial management projects includes organizational planning, staff
acquisition, and team development. The independent public accountants who
conducted DHS's fiscal year 2006 audit have stated that many of the
department's difficulties in financial management and reporting can be
attributed to the original stand-up of a large, new, and complex executive
branch agency without adequate organizational expertise in financial
management and accounting. Moreover, DHS's Resource Management
Transformation Office officials have stated that because of staffing
shortages, outside contractors are currently performing some of the
financial management activities or duties that internal DHS staff would
normally perform. Some of the most pressing human capital challenges at
DHS include (1) successfully completing its ongoing transformation; (2)
forging a unified results-oriented culture across the department; (3)
obtaining, developing, providing incentives to, and retaining needed
talent; and (4) most importantly, maintaining leadership at the top, to
include a chief operating officer or chief management officer.

^16 [15]GAO/AIMD-00-134 .

Having adequate and sufficient human resources with the requisite training
and experience to successfully implement a financial management system is
a critical success factor. Strategic human capital planning is necessary
for all stages of a financial systems implementation. Agencies across the
federal government face the challenge of sustaining the momentum of
transformation because of the limited tenure of key administration
officials. Managing the transformation of financial management systems at
an organization the size and complexity of DHS requires comprehensive
coordinated planning and integration of key management functions across
all components of the department.

In our related report, released today, we made six recommendations focused
on the need for DHS to develop a financial management plan or strategy and
to fully adopt the building blocks and human capital practices that are
vital to minimizing the risk related to modernizing its financial
management systems. In written comments on a draft of this report, DHS
concurred with our recommendations and described the approach and steps
that are planned to improve DHS's financial management systems.

Concluding Observations

GAO and others have found that the key to implementing systems that meet
cost, schedule, and performance objectives is to have effectively
implemented the disciplined processes necessary to reduce risks to
acceptable levels. Ending eMerge^2 was a prudent decision; however, we are
concerned that DHS still lacks a clearly defined financial management
strategy or financial management system implementation effort to even
begin to address the integration and transformation issues highlighted in
our most recent high-risk report.

Given that DHS is one of the largest and most complex executive branch
agencies in the federal government, developing, operating, maintaining,
and transforming its financial management systems represent a monumental
challenge. This challenge is compounded by the relatively recent creation
of DHS and the poor condition of the range of legacy financial and related
business systems it inherited. Critical success factors for DHS's
transformation efforts will include using the four building blocks and
human capital best practices to provide reasonable assurance that the
risks associated with implementing a departmentwide integrated financial
management system are minimized. If properly implemented, the
recommendations included in our related report released today, which are
based on best practices, will help reduce the risk associated with a
project of this magnitude and importance to an acceptable level.
Otherwise, DHS runs the risk of repeating the failure of eMerge^2. At the
request of this subcommittee, this testimony summarizes the results of our
first review of DHS's financial management transformation efforts. We look
forward to continuing to work with you as we continue to monitor DHS's
efforts to transform its financial management systems. As DHS moves
forward, your subcommittee's continuing efforts to oversee the status of
this transformation will be critical to its success.

Mr. Chairman, this concludes our prepared statement. We will be happy to
respond to any questions you or other members of the subcommittee may have
at this time.

Contacts and Acknowledgments

For information about this statement, please contact McCoy Williams,
Director, Financial Management and Assurance, at (202) 512-9095 or
[16][email protected] , or Keith A. Rhodes, Chief Technologist, Applied
Research and Methods, Center for Engineering and Technology, at (202)
512-6412 or [17][email protected] . Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this testimony. Individuals who made key contributions to this
testimony include Kay Daly, Assistant Director; Chris Martin, Senior Level
Technologist; Felicia Brooks; Francine Delvecchio; and Chanetta Reed.

(195118)

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[24]www.gao.gov/cgi-bin/getrpt?GAO-07-1041T .

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Highlights of [25]GAO-07-1041T , a testimony before the Subcommittee on
Federal Financial Management, Government Information, Federal Services,
and International Security, Committee on Homeland Security and
Governmental Affairs, U.S. Senate

June 28, 2007

HOMELAND SECURITY

Transforming Departmentwide Financial Management Systems Remains a
Challenge

Since 2003, when the Department of Homeland Security (DHS) began
operations, it has faced the difficult challenge of bringing together 22
diverse agencies and developing an integrated financial management system
to provide reliable, timely, and useful financial information. GAO's 2007
report, Homeland Security: Departmentwide Integrated Financial Management
Systems Remain a Challenge, GAO-07-536, emphasized the key issues related
to DHS attempting to transform its financial management systems.

For today's hearing, this testimony, based on GAO's recent report, (1)
summarizes DHS's financial system transformation efforts, (2) points out
key financial system transformation challenges at DHS, and (3) highlights
the building blocks that DHS should consider to form the foundation for
successful financial management system transformation efforts.

[26]What GAO Recommends Though there are no recommendations in this
statement, in its related report (GAO-07-536), GAO made six
recommendations focused on the need for DHS to define a departmentwide
financial management strategy and embrace best practices, including human
capital practices, to foster its systems integration effort. DHS concurred
with GAO's recommendations.

DHS began implementation of the Electronically Managing Enterprise
Resources for Government Effectiveness and Efficiency (eMerge^2) program
in January 2004 to integrate financial management systems across the
entire department and to address the multitude of financial management
weaknesses DHS inherited. In December 2005, the DHS Chief Financial
Officer (CFO) decided not to exercise the next contract option with the
systems integrator, and by September 2006, DHS's new CFO stated that
eMerge^2 was officially "dead." DHS officials have stated that about $52
million was spent on this project before it was halted but could not
provide documentation to support this amount. DHS's decision to end the
project before spending an estimated $229 million was prudent; however,
the agency has made little progress since that time and as a result has
missed an invaluable opportunity to address existing financial management
problems.

While DHS officials have recognized the need for an integrated financial
management system, the department has not yet developed an overall
transformation strategy that includes financial management policies and
procedures, standard business processes, a human capital strategy, and
effective internal controls. DHS officials have acknowledged that the
Internal Controls Over Financial Reporting Playbook issued in March 2007
has a policy and process focus and does not comprise a strategy for
financial systems modernization. DHS's recently developed high-level
financial management systems strategy, the Transformation and Systems
Consolidation, focuses on leveraging existing systems investments across
DHS components and is still in the early stages of development. More
detailed implementation strategies will be necessary to fully address
financial management system integration efforts.

Consolidating financial management systems for an entity as large and
diverse as DHS poses significant management challenges. DHS also has an
opportunity to reap substantial benefits by reengineering business
processes and standardizing those processes in terms of both productivity
gains and staff portability across the various components. Based on
industry best practices, GAO has identified four key building blocks that
will be critical to DHS's ability to successfully complete its financial
management transformation:

           o developing a concept of operations,
           o defining standard business processes,
           o developing a migration and/or implementation strategy for DHS
           components, and
           o defining and effectively implementing disciplined processes
           necessary to properly manage the specific projects.

Fully embracing these four building blocks and human capital best
practices will be critical to the success of any future financial
management plan or strategy that addresses implementing and/or migrating
to an integrated departmentwide financial management system at DHS.

References

Visible links
8. http://www.gao.gov/cgi-bin/getrpt?GAO-06-553T
9. http://www.gao.gov/cgi-bin/getrpt?GAO-07-536
  10. http://www.gao.gov/cgi-bin/getrpt?GAO-07-310
  11. http://www.gao.gov/cgi-bin/getrpt?GAO-07-536
  12. http://www.gao.gov/cgi-bin/getrpt?GAO-06-553T
  13. http://www.gao.gov/cgi-bin/getrpt?GAO-06-553T
  14. http://www.gao.gov/cgi-bin/getrpt?GAO-07-536
  15. http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-134
  16. mailto:[email protected]
  17. mailto:[email protected]
  18. http://www.gao.gov/
  19. http://www.gao.gov/
  20. http://www.gao.gov/fraudnet/fraudnet.htm
  21. mailto:[email protected]
  22. mailto:[email protected]
  23. mailto:[email protected]
  24. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1041T
  25. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1041T
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