Customs Service Modernization: Actions Initiated to Correct ACE
Management and Technical Weaknesses (Testimony, 05/13/99,
GAO/T-AIMD-99-186).
Pursuant to a congressional request, GAO discussed the weaknesses of the
Customs Service's Automated Commercial Environment (ACE) project.
GAO noted that: (1) Customs is well over 2 years behind its original
National Customs Automation Program prototype schedule; (2) Customs was
not building ACE within the context of an enterprise systems
architecture, or blueprint of its agencywide future systems environment;
(3) Customs developed and published an architecture in July and August
1997; (4) GAO reviewed this architecture and reported in May 1998 that
it was not effective because it was neither complete nor enforced; (5)
in response, Customs agreed to develop a complete architecture and
establish a process to ensure compliance; (6) Customs reports that its
architecture will be completed in May 1999; (7) Customs did not identify
and evaluate a full range of alternatives to its defined ACE solution
before commencing development activities; (8) Customs did not develop a
reliable life cycle cost estimate for the approach it selected; (9)
Customs is not making investment decisions incrementally as required by
the Clinger-Cohen Act and the Office of Management and Budget; (10)
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; (11) Customs lacks the capability to effectively
develop or acquire ACE software; and (12) Customs lacked a software
process improvement program to effectively address these and other
software process weaknesses.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-AIMD-99-186
TITLE: Customs Service Modernization: Actions Initiated to
Correct ACE Management and Technical Weaknesses
DATE: 05/13/99
SUBJECT: Computer software verification and validation
Systems conversions
Schedule slippages
Internal controls
Information resources management
Cost effectiveness analysis
Systems design
Customs administration
IDENTIFIER: Customs Service Automated Commercial Environment System
Customs Service National Customs Automation Program
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AI99186t.book GAO United States General Accounting Office
Testimony Before the Committee on Finance, U. S. Senate
For Release on Delivery Expected at 10 a. m. Thursday, May 13,
1999
CUSTOMS SERVICE MODERNIZATION
Actions Initiated to Correct 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-99-186
GAO/T-AIMD-99-186
Page 1 GAO/T-AIMD-99-186
Mr. Chairman and Members of the Committee: 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 (IT) 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, 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 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 Clinger- Cohen, see Assessing
Risk and Returns: A Guide for Evaluating Federal Agencies' IT
Investment Decision- making (GAO/ AIMD10.1.13,
February 1997).
Page 2 GAO/T-AIMD-99-186
accepted industry system/ software engineering models, such as
those published by the Software Engineering Institute (SEI). 3
Unfortunately, Customs has not employed such practices on ACE over
the last 5 years. Our February 1999 report on ACE, 4 upon which my
testimony today is based, describes serious ACE management and
technical weaknesses. The weaknesses that we reported 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. To Customs' credit, its
leadership has agreed with our findings, has initiated actions to
implement our recommendations, and is committed to seeing that
these actions are completed before investing huge sums of money in
the system.
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 in3
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-99-186
house, the first NCAP release was not deployed until May 1998-- 16
months 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 1999 ACE business plan specifies a
$1.48 billion life cycle cost estimate.
Customs Has Been Developing ACE Without a Complete Enterprise
Systems Architecture
At the time of our review, Customs was 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 ClingerCohen
Act requires agency Chief Information Officers (CIO) to develop,
maintain, and implement an information technology 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,
information technology 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-99-186
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 reports that its architecture will be
completed in May 1999. Also, in January 1999, Customs 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-99-186
Customs Has Not Been 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 and GAO guidance together
provide an effective IT investment management framework for
answering this question. Among other things,
they describe the need 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-99-186
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 did not (1) use a cost model, (2) account for changes in
its approach to building different ACE increments, (3) account for
changes to ACE software and hardware architecture, or (4) 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,
and 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-99-186
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 Has Not Been 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-99-186
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-99-186
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 Initiated Actions to Implement 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 identified 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-99-186
In commenting on our February 1999 report, the Commissioner of
Customs agreed with our findings and committed to implementing our
recommendations. In April 13, 1999, testimony, the Commissioner
outlined several actions Customs has underway to improve ACE
project management and address our recommendations. 11 In brief,
Customs
plans to acquire the services of a prime contractor that is at
least SEI level 3 certified to help Customs implement mature
software processes and plan, implement, and manage its
modernization efforts, including ACE; plans to hire a Federally
Funded Research and Development Center (FFRDC) to support
solicitation, selection, contract award, contract
management, and ongoing oversight of the prime contractor; has
hired a contractor to update and improve the ACE life cycle cost
estimate;
has retained an audit firm to provide independent reviews of
Customs' methodology for estimating ACE costs and revised cost/
benefit analysis; has engaged a contractor to update and improve
the ACE cost/ benefit analysis by addressing our concerns,
including use of ITDS as the
interface for ACE; plans to perform additional cost/ benefit
analyses of ACE increments and analyze alternative approaches to
building ACE; and
plans to ensure that each ACE increment is compliant with
Customs' enterprise systems architecture.
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 11
Statement of Commissioner Raymond W. Kelly, Commissioner of the
Customs Service, Authorization
Hearing with the Customs Service Before the House Committee on
Ways and Means Trade Subcommittee, April 13, 1999.
Page 11 GAO/T-AIMD-99-186
causes of their not delivering promised system capabilities on
time and within budget. 12 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.
To Customs' credit, it fully recognizes the seriousness of the
situation, has
quickly initiated actions to begin correcting its ACE management
and technical weaknesses, and is committed to each of these
actions. 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 Committee may have at
this time.
12 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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