Customs Service Modernization: Actions Needed to Correct Serious ACE
Management and Technical Weaknesses (Testimony, 04/13/99,
GAO/T-AIMD-99-141).

Pursuant to a congressional request, GAO discussed the Customs Service's
management of its Automated Commercial Environment (ACE) system.

GAO noted that: (1) the need to leverage information technology to
improve the way that Customs does business in the import arena is
undeniable; (2) Customs' existing import processes and supporting
systems are simply not responsive to the business needs of either
Customs or the trade community, whose members collectively import about
$1 trillion in goods annually; (3) these existing processes and systems
are paper-intensive, error-prone, and transaction-based, and they are
out of step with the just-in-time inventory practices used by the trade;
(4) recognizing this, Congress enacted the Customs Modernization and
Informed Compliance Act to define legislative requirements for improving
import processing through an automated system; (5) Customs fully
recognizes the severity of the problems with its approach to managing
import trade and is modernizing its import processes and undertaking ACE
as its import system solution; (6) begun in 1994, Customs' estimate of
the system's 15-year life cycle cost is about $1.05 billion, although
this estimate is being increased; (7) in light of ACE's enormous mission
importance and price tag, Customs' approach to investing in and
engineering ACE demands disciplined and rigorous management practices;
(8) such practices are embodied in the Clinger-Cohen Act of 1996 and
other legislative and regulatory requirements, as well as accepted
industry system/software engineering models, such as those published by
the Software Engineering Institute; (9) unfortunately, Customs has not
employed such practices to date on ACE; (10) GAO's February 1999 report
on ACE describes serious management and technical weaknesses in Customs'
management of ACE; and (11) the ACE weaknesses are: (a) building ACE
without a complete and enforced enterprise systems architecture; (b)
investing in ACE without a firm basis for knowing that it is a cost
effective system solution; and (c) building ACE without employing
engineering rigor and discipline.

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

 REPORTNUM:  T-AIMD-99-141
     TITLE:  Customs Service Modernization: Actions Needed to Correct
	     Serious ACE Management and Technical Weaknesses
      DATE:  04/13/99
   SUBJECT:  Customs administration
	     Systems conversions
	     Strategic information systems planning
	     Systems design
	     ADP procurement
	     International trade regulation
	     Information resources management
	     Computer software verification and validation
	     Life cycle costs
	     Cost effectiveness analysis
IDENTIFIER:  Customs Service National Customs Automation Program
	     Customs Service Automated Commercial Environment System
	     Treasury International Trade Data System
	     Customs Service Automated Commercial System

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AI99141T.book GAO United States General Accounting Office

Testimony Before the Subcommittee on Trade, Committee on Ways and
Means, House of Representatives

For Release on Delivery Expected at 11 a. m. Tuesday, April 13,
1999

CUSTOMS SERVICE MODERNIZATION

Actions Needed to Correct Serious ACE Management and Technical
Weaknesses

Statement of Randolph C. Hite Associate Director, Governmentwide
and Defense Information Systems Accounting and Information
Management Division

GAO/T-AIMD-99-141

  GAO/T-AIMD-99-141

Page 1 GAO/T-AIMD-99-141

Mr. Chairman and Members of the Subcommittee: Thank you for
inviting me to participate in today's Customs Service oversight
hearing. My statement will focus on Customs' Automated Commercial
Environment, better known as ACE. Through ACE, Customs intends to
implement much needed improvements in the way it currently
enforces import trade laws and regulations and assesses and
collects import duties, taxes, and fees, which total $22 billion
annually.

The need to leverage information technology to improve the way
that Customs does business in the import arena is undeniable.
Customs' existing import processes and supporting systems are
simply not responsive to the business needs of either Customs or
the trade community, whose members collectively import about $1
trillion in goods annually. These existing processes and systems
are paper- intensive, errorprone, and transaction- based, and they
are out of step with the just- in- time inventory practices used
by the trade. Recognizing this, the Congress enacted the Customs
Modernization and Informed Compliance Act, or Mod Act, to define
legislative requirements for improving import

processing through an automated system. 1 Customs fully recognizes
the severity of the problems with its approach to managing import
trade and is modernizing its import processes and undertaking ACE
as its import system solution. Begun in 1994, Customs' estimate of
the system's 15- year life cycle cost is about $1.05 billion,
although this estimate is being revised upwards. In light of ACE's
enormous mission importance and price tag, Customs' approach to
investing in and engineering ACE demands disciplined and rigorous
management practices. Such practices are embodied in the Clinger-
Cohen Act of 1996 2 and other legislative and regulatory
requirements, as well as

1 Customs refers to Title VI of the North American Free Trade
Agreement Implementation Act (Public Law 103- 182, 19 U. S. C.
1411 et seq) as the Customs Modernization and Informed Compliance
Act or Mod Act. 2 Although the Clinger- Cohen Act (Public Law 104-
106) was passed after Customs began developing ACE, its principles
are based on practices that are widely considered to be integral
to successful information technology (IT) investments. For an
analysis of the management practices of several leading private
and public sector organizations on which the Clinger- Cohen Act is
based, see Executive

Guide: Improving Mission Performance Through Strategic Information
Management and Technology (GAO/AIMD-94-115, May 1994). For an
overview of the IT management process envisioned by ClingerCohen,
see Assessing Risk and Returns: A Guide for Evaluating Federal
Agencies' IT Investment Decision- making (GAO/ AIMD- 10. 1. 13,
February 1997).

Page 2 GAO/T-AIMD-99-141

accepted industry system/ software engineering models, such as
those published by the Software Engineering Institute (SEI). 3
Unfortunately, Customs has not employed such practices to date on
ACE. Our February 1999 report on ACE, 4 upon which my testimony
today is based, describes serious management and technical
weaknesses in Customs' management of ACE. The ACE weaknesses are
(1) building ACE without a complete and enforced enterprise
systems architecture, (2) investing in ACE without a firm basis
for knowing that it is a costeffective system solution, and (3)
building ACE without employing engineering rigor and discipline.
My testimony will address each of these points as well as our
recommendations for correcting them. Customs agrees with our
findings, and it is committed to implementing our recommendations.

ACE: A Brief History Customs began ACE in 1994, and its early
estimate of the cost and time to develop the system was $150
million over 10 years. At this time, Customs also decided to first
develop a prototype of ACE, referred to as NCAP

(National Customs Automation Program prototype), and then to
complete the system. In May 1997, 5 we testified that Customs'
original schedule for completing the prototype was January 1997,
and that Customs did not have a schedule for completing ACE. At
that time, Customs agreed to develop a comprehensive project plan
for ACE. In November 1997, Customs estimated that the system would
cost $1. 05 billion to develop, operate, and maintain throughout
its life cycle. Customs plans to develop and deploy the system in
21 increments from 1998 through 2005, the first four of which
would constitute NCAP.

Currently, Customs is well over 2 years behind its original NCAP
schedule. Because Customs experienced problems in developing NCAP
software inhouse, the first NCAP release was not deployed until
May 1998 16 months 3 Software Development Capability Maturity
Model SM (SW- CMM  ) and Software Acquisition Capability Maturity
Model SM (SA- CMM  ). Capability Maturity Model SM is a service
mark of Carnegie Mellon

University, and CMM  is registered in the U. S. Patent and
Trademark Office. 4 Customs Service Modernization: Serious
Management and Technical Weaknesses Must Be Corrected (GAO/AIMD-
99-41, February 26, 1999).

5 Customs Service Modernization: ACE Poses Risks and Challenges
(GAO/T-AIMD-97-96, May 15, 1997).

Page 3 GAO/T-AIMD-99-141

late. In view of the problems it experienced with the first
release, Customs contracted out for the second NCAP release and
deployed this release in October 1998 21 months later than
originally planned. Customs' most

recent dates for deploying the final two NCAP releases (0.3 and 0.
4) are March 1999 and September 1999, which are 26 and 32 months
later than the original deployment estimates, respectively.
According to Customs, these dates will slip farther because of
funding delays.

Additionally, Customs officials told us that a new ACE life cycle
cost estimate is being developed, but that it was not ready to be
shared with us. At the time of our review, Customs' $1. 05 billion
estimate developed in 1997 was the official ACE life cycle cost
estimate. However, a January 1998 ACE business plan specifies a
$1.48 billion life cycle cost estimate.

Customs Is Developing ACE Without a Complete Enterprise Systems
Architecture

Customs is not building ACE within the context of an enterprise
systems architecture, or blueprint of its agencywide future
systems environment. Such an architecture is a fundamental
component of any rationale and

logical strategic plan for modernizing an organization's systems
environment. As such, the Clinger- Cohen Act requires agency chief
information officers (CIO) to develop, maintain, and implement an
information technology (IT) architecture. Also, the Office of
Management and Budget (OMB) issued guidance in 1996 that requires
agency IT investments to be architecturally compliant. These
requirements are

consistent with, and in fact based on, IT management practices of
leading private and public sector organizations. Simply stated, an
enterprise systems architecture specifies the system (e. g.,

software, hardware, communications, security, and data)
characteristics that the organization's target systems environment
is to possess. Its purpose is to define, through careful analysis
of the organization's strategic

business needs and operations, the future systems configuration
that supports not only the strategic business vision and concept
of operations, but also defines the optimal set of technical
standards that should be met to produce homogeneous systems that
can interoperate effectively and be maintained efficiently. Our
work has shown that in the absence of an enterprise systems
architecture, incompatible systems are produced that

Page 4 GAO/T-AIMD-99-141

require additional time and resources to interconnect and to
maintain and that suboptimize the organization's ability to
perform its mission. 6 We first reported on Customs' need for a
systems architecture in May 1996 and testified on this subject in
May 1997. 7 In response, Customs developed

and published an architecture in July and August 1997. We reviewed
this architecture and reported in May 1998 that it was not
effective because it was neither complete nor enforced. 8 For
example, the architecture did not 1. fully describe Customs'
business functions and their relationships, 2. define the
information needs and flows among these functions, and 3.
establish the technical standards, products, and services that
would be characteristic of its target systems environment on the
basis of these business specifications.

Accordingly, we recommended that Customs complete its enterprise
information systems architecture and establish compliance with the
architecture as a requirement of Customs' information technology
investment management process. In response, Customs agreed to
develop a complete architecture and establish a process to ensure
compliance. Customs is in the process of developing the
architecture and reports that it will be completed in May 1999.
Also, in January 1999, Customs reported

that it changed its internal procedures to provide for effective
enforcement of its architecture, once it is completed. Until the
architecture is completed and enforced, Customs risks spending
millions of dollars to develop, acquire, and maintain information
systems, including ACE, that do not effectively and efficiently
support the agency's mission needs.

6 Air Traffic Control: Complete and Enforced Architecture Needed
for FAA Systems Modernization (GAO/AIMD-97-30, February 3, 1997).
7 Customs Service Modernization: Strategic Information Management
Must Be Improved for National Automation Program To Succeed
(GAO/AIMD-96-57, May 9, 1996) and Customs Service Modernization:
ACE Poses Risks and Challenges (GAO/T-AIMD-97-96, May 15, 1997). 8
Customs Service Modernization: Architecture Must Be Complete and
Enforced to Effectively Build and Maintain Systems (GAO/AIMD-98-
70, May 5, 1998).

Page 5 GAO/T-AIMD-99-141

Customs Is Not Managing Its Investment in ACE Effectively

Effective IT investment management is predicated on answering one
basic question: Is the organization doing the right thing by
investing specified time and resources in a given project or
system? The Clinger- Cohen Act and OMB guidance together provide
an effective IT investment

management framework for answering this question. Among other
things, they set requirements for 1. identifying and analyzing
alternative system solutions,

2. developing reliable estimates of the alternatives' respective
costs and benefits and investing in the most cost beneficial
alternative, and 3. to the maximum extent practical, structuring
major projects into a series of increments to ensure that each
increment constitutes a wise investment. Customs did not satisfy
any of these requirements for ACE. First, Customs did not identify
and evaluate a full range of alternatives to its defined ACE
solution before commencing development activities. For example,
Customs did not consider how ACE would relate to another
Treasuryproposed system for processing import trade data, known as
the International Trade Data System (ITDS), including considering
the extent to which ITDS should be used to satisfy needed import
processing functionality. Initiated in 1995 as a project to
develop a coordinated,

governmentwide system for the collection, use, and dissemination
of trade data, the ITDS project is headed by the Treasury Deputy
Assistant Secretary for Regulatory, Tariff and Trade Enforcement.
The system is

expected to reduce the burden federal agencies place on
organizations by requiring that they respond to duplicative data
requests. Treasury intends for the system to serve as the single
point for collecting, editing, and validating trade data as well
as collecting and accounting for trade revenue.

At the time of our review of ACE, these functions were also
planned for ACE.

Similarly, Customs did not evaluate different ACE architectural
designs, such as the use of a mainframe- based versus client/
server- based hardware architecture. Also, Customs did not
evaluate alternative development approaches, such as acquisition
versus in- house development. In short, Customs committed to and
began building ACE without knowing whether it had chosen the most
cost- effective alternative and approach.

Page 6 GAO/T-AIMD-99-141

Second, Customs did not develop a reliable life cycle cost
estimate for the approach it selected. SEI has developed a method
for project managers to use to determine the reliability of
project cost estimates. Using SEI's

method, we found that Customs' $1.05 billion ACE life cycle cost
estimate was not reliable, and that it did not provide a sound
basis for Customs' decision to invest in ACE. For example, in
developing the cost estimate,

Customs (1) did not use a cost model, (2) did not account for
changes in its approach to building different ACE increments, (3)
did not account for changes to ACE software and hardware
architecture, and (4) did not have

historical project cost data upon which to compare its ACE
estimate. Moreover, the $1.05 billion cost estimate used to
economically justify ACE omitted relevant costs. For instance, the
costs of technology refreshment and system requirements definition
were not included (see table 1). Exacerbating this problem,
Customs represented its ACE cost estimate as a precise point
estimate rather than explicitly disclosing to investment
decisionmakers in Treasury, OMB, and Congress the estimate's
inherent uncertainty.

Table 1: Estimated Costs Omitted From Customs' ACE Cost- Benefit
Analysis

Customs' projections of ACE benefits were also unreliable because
they were either overstated or unsupported. For example, the
analysis includes $203.5 million in savings attributable to 10
years of avoided maintenance

and support costs on the Automated Commercial System (ACS) the
system ACE is to replace. However, Customs would not have avoided
maintenance and support costs for 10 years. At the time of
Customs' analysis, it planned to run both systems in parallel for
4 years, and thus

planned to spend about $53 million on ACS maintenance and support
during this period. As another example, $650 million in savings
was not supported by verifiable data or analysis, and $644 million
was based on

Excluded cost description Excluded cost estimate

Hardware and software upgrades at each port office (e. g., desktop
workstations and operating systems, application and data servers,
database management systems). $73 to $172 million Security
analysis, project planning and management, and independent
verification and validation. $23 million Requirements definition,
component integration, regression testing, and training. No
estimate

available

Page 7 GAO/T-AIMD-99-141

assumptions that were analytically sensitive to slight changes,
making this $644 million a best case scenario. Third, Customs is
not making its investment decisions incrementally as required by
the Clinger- Cohen Act and OMB. Although Customs has decided to
implement ACE as a series of 21 increments, it is not justifying
investing in each increment on the basis of defined costs and
benefits and a positive return on investment for each increment.
Further, once it has deployed an increment at a pilot site for
evaluation, it is not validating the benefits that the increment
actually provides, and it is not accounting for

costs on each increment so that it can demonstrate that a positive
return on investment was actually achieved. Instead, Customs
estimated the costs and benefits for the entire system-- all 21
increments, and used this as economic justification for ACE. Mr.
Chairman, our work has shown that such estimates of many system
increments to be delivered over many years are impossible to make
accurately because later increments are not well understood or
defined. Also, these estimates are subject to change in light of
experiences on nearer term increments and changing business needs.
By using an inaccurate, aggregated estimate that is not refined as
increments are developed, Customs is committing enormous resources
with no assurance

that it will achieve a reasonable return on its investment. This
grand design approach to managing large system modernization
projects has repeatedly proven to be ineffective across the
federal government, resulting in huge sums invested in systems
that do not provide expected benefits. Failure of the grand design
approach was a major impetus for the IT management reforms
contained in the Clinger- Cohen Act.

Customs Is Not Managing ACE Software Development/ Acquisition
Effectively

Software process maturity is one important and recognized measure
of determining whether an organization is managing a system or
project the right way, and thus whether or not the system will be
completed on time and within budget and will deliver promised
capabilities. The ClingerCohen Act requires agencies to implement
effective IT management processes, such as processes for managing
software development and acquisition. SEI has developed criteria
for determining an organization's software development and
acquisition effectiveness or maturity.

Customs lacks the capability to effectively develop or acquire ACE
software. Using SEI criteria for process maturity at the
repeatable level, which is the second level on SEI's five- level
scale and means that an

Page 8 GAO/T-AIMD-99-141

organization has the software development/ acquisition rigor and
discipline to repeat project successes, we evaluated ACE software
processes. In February 1999, 9 we reported that the software
development processes that Customs was employing on NCAP 0.1, the
first release of ACE, were not

effective. For example, we reported that Customs lacked effective
software configuration management, which is important for
establishing and maintaining the integrity of the software
products during development.

Also, we reported that Customs lacked a software quality assurance
program, which greatly increased the risk of ACE software not
meeting process and product standards. Further, we reported that
Customs lacked a software process improvement program to
effectively address these and other software process weaknesses.
Our findings concerning ACE software development maturity are
summarized in table 2.

Table 2: Summary of ACE Software Development Maturity

Note: These represent five of six level 2 key process areas in
SEI's Software Development Capability Maturity Model. We did not
evaluate ACE in the sixth level 2 key process area-- software
subcontract management-- because Customs did not use
subcontractors on ACE.

As discussed in our brief history of ACE, after Customs developed
NCAP 0.1 in- house, it decided to contract out for the development
of NCAP 0.2, thus changing its role on ACE from being a software
developer to being a software acquirer. According to SEI, the
capabilities needed to effectively acquire software are different
than the capabilities needed to effectively develop software.
Regardless, we reported later in February 1999 10 that the
software acquisition processes that Customs was employing on NCAP

0.2 were not effective. For example, Customs did not have an
effective software acquisition planning process and, as such,
could not effectively

9 Customs Service Modernization: Ineffective Software Development
Processes Increase Customs System Development Risks (GAO/AIMD-99-
35, February 11, 1999).

Key process areas Satisfied Not satisfied

Requirements management X Software project planning X Software
project tracking and oversight X Software quality assurance X
Software configuration management X

10 GAO/AIMD-99-41, February 26, 1999.

Page 9 GAO/T-AIMD-99-141

establish reasonable plans for performing software engineering and
for managing the software project. Also, Customs did not have an
effective evaluation process, meaning that it lacked the
capability for ensuring that contractor- developed software
satisfied defined requirements. Our findings

concerning ACE software acquisition maturity are summarized in
table 3.

Table 3: Summary of ACE Software Acquisition Maturity

Note: These represent seven level 2 key process areas in SEI's
Software Acquisition Capability Maturity Model. We also evaluated
one key process area associated with the defined level of process
maturity (level 3)-- acquisition risk management.

Customs Has Committed to Implementing Our Recommendations for
Strengthening ACE Management

To address ACE management weaknesses, we recommended that Customs
analyze alternative approaches to satisfying its import automation
needs, including addressing the ITDS/ ACE relationship;  invest in
its defined ACE solution incrementally, meaning for each

system increment (1) rigorously estimate and analyze costs and
benefits, (2) require a favorable return- on- investment and
compliance with Customs' enterprise systems architecture, and (3)
validate actual costs and benefits once an increment is piloted,
compare actuals to estimates, use the results in deciding on
future increments, and report

the results to congressional authorizers and appropriators;
establish an effective software process improvement program and
correct the software process weaknesses in our report, thereby
bringing

ACE software process maturity to a least an SEI level 2; and
require at least SEI level 2 processes of all ACE software
contractors. Key process areas Satisfied Not satisfied

Software acquisition planning X Solicitation X Requirements
development and management X Project office management X Contract
tracking and oversight X Evaluation X Transition and support X
Acquisition risk management X

Page 10 GAO/T-AIMD-99-141

In his February 16, 1999, comments on a draft of our report, the
Commissioner of Customs agreed with our findings and committed to
implementing our recommendations. On April 1, 1999, the
Commissioner provided us a status report on Customs efforts to do
so. In brief, the

Commissioner stated that Customs  is conducting and will conduct
additional analyses to consider

alternative approaches to ACE, and will base these analyses on the
assumption that Customs will use and not duplicate ITDS
functionality;  is developing the capability to perform cost-
benefit analyses of ACE

increments, and is and will conduct postimplementation reviews of
ACE increments;  has retained an audit firm to independently
validate cost- benefit analyses;  is developing software process
improvement plans to achieve software process maturity of level 2
and then level 3; and

 is preparing a directive to require at least level 2 processes of
all Customs software contractors.

Additionally, the Commissioner stated that Customs is developing a
plan for engaging a prime integration contractor that is at least
SEI level 3 certified. Under this approach, the prime contractor
would assist Customs in implementing effective system/ software
engineering processes and

would engage subcontractors to meet specified system development
and maintenance needs.

Conclusions Successful systems modernization is absolutely
critical to Customs' ability to perform its trade import mission
efficiently and effectively in the 21 st century. Systems
modernization success, however, depends on doing the right thing,
the right way. To be right, organizations must (1) invest in and
build systems within the context of a complete and enforced
enterprise systems architecture, (2) make informed, data- driven
decisions about investment options based on expected and actual
return- on- investment for system increments, and (3) build system
increments using mature software engineering practices. Our
reviews of agency system modernization efforts over the last 5
years point to weaknesses in these three areas as the root

Page 11 GAO/T-AIMD-99-141

causes of their not delivering promised system capabilities on
time andwithin budget. 11

Until Customs corrects its ACE management and technical
weaknesses, the federal government's troubled experience on other
modernization efforts is a good indicator for ACE. In fact,
although Customs does not collect data to know whether the first
two ACE releases are already falling short of cost and performance
expectations, the data it does collect on meeting milestones show
that the first two releases have taken about 2 years longer than
originally planned. This is precisely the type of unaffordable
outcome that can be avoided by making the management and technical
improvements we recommended. Fortunately, Customs fully recognizes
the seriousness of the situation and

has committed to correcting its ACE management and technical
weaknesses. We are equally committed to working with Customs as it
strives to do so and with Congress as it oversees this important
initiative. This concludes my statement. I would be glad to
respond to any questions

that you or other Members of the Subcommittee may have at this
time. 11 Tax System Modernization: Management and Technical
Weaknesses Must Be Corrected If Modernization Is to Succeed
(GAO/AIMD-95-156, July 26, 1995); Tax Systems Modernization:
Actions Underway but IRS Has Not Yet Corrected Management and
Technical Weaknesses (GAO/AIMD-96-106, June 7, 1996); Tax Systems
Modernization: Blueprint Is a Good Start but Not Yet Sufficiently
Complete to Build or Acquire Systems (GAO/ AIMD/ GGD- 98- 54,
February 24, 1998); Air Traffic Control: Immature Software
Acquisition Processes Increase FAA System Acquisition Risks
(GAO/AIMD-97-47, March 21, 1997; Air Traffic Control: Complete and
Enforced Architecture Needed for FAA Systems Modernization
(GAO/AIMD-97-30, February 3, 1997); and Air Traffic Control:
Improved Cost Information Needed to

Make Billion Dollar Modernization Investment Decisions (GAO/AIMD-
97-20, January 22, 1997).

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