Indian Trust Funds: Challenges Facing Interior's Implementation of New
Trust Asset and Accounting Management System (Testimony, 07/14/1999,
GAO/T-AIMD-99-238).
Pursuant to a congressional request, GAO discussed the: (1) Department
of the Interior's efforts to acquire the Trust Asset and Accounting
Management System (TAAMS); (2) results of GAO's evaluation and
recommendations to Interior to address its findings; (3) status of
TAAMS; and (4) challenges still confronting Interior's implementation of
this important system.
GAO noted that: (1) GAO's April 1999 report found that Interior was not
following sound practices that would: (a) help ensure that TAAMS
cost-effectively met trust management needs; and (b) reduce development
risks; (2) until Interior defines the logical characteristics of its
business environment and uses them to establish technical standards and
approaches, it runs the risk that TAAMS and other information technology
investments will be redundant and incompatible and out-of-sync with
Indian trust management requirements; (3) in undertaking its efforts to
acquire TAAMS, Interior did not follow a sound process for: (a) ensuring
that the most cost-effective technical alternative was selected; and (b)
reducing acquisition risks; (4) by not following accepted best practices
for technology service acquisitions, Interior was not necessarily
dooming TAAMS to failure; (5) rather, it was further elevating the risk
of encountering problems in the development stages that could delay
implementation or unnecessarily increase costs; (6) according to the
TAAMS project manager, the TAAMS contractor has already modified its
commercial-off-the-shelf product to provide the functionality called for
in the TAAMS contract; (7) the contractor is in the process of testing
this product; (8) it expects to complete testing by mid September; (9)
during the week of June 14, 1999 the contractor performed integration
testing of the initial version of TAAMS, and the following week,
Interior initiated a TAAMS pilot at the Billings, Montana, area office;
(10) the purpose of software integration testing is to verify that units
of software, when combined, work together as intended; (11) on July 7
and July 8, the contractor conducted preliminary user acceptance tests
at the contractor's facility in Dallas, Texas; (12) Interior has also
engaged an independent verification and validation (IV&V) agent who will
verify that system testing is performed in accordance with generally
accepted guidelines; (13) when the IV&V assessment is done in September
1999, Interior will decide whether or not to proceed with implementing
TAAMS; and (14) it is critical for Interior to follow sound practices
during the testing phase for TAAMS.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-AIMD-99-238
TITLE: Indian Trust Funds: Challenges Facing Interior's
Implementation of New Trust Asset and Accounting
Management
System
DATE: 07/14/1999
SUBJECT: Information resources management
Trust funds
Strategic information systems planning
Federal agency accounting systems
Systems compatibility
Systems design
Computer software verification and validation
Cost control
ADP procurement
Federal procurement
IDENTIFIER: Dept. of the Interior Trust Asset and Accounting
Management System
BIA Land Records Information System
Indian Trust Fund
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ai99238t GAO United States General Accounting Office
Testimony Before the Committee on Indian Affairs and the Committee
on Energy and Natural Resources, U. S. Senate
For Release on Delivery Expected at 9: 30 a. m. Wednesday, July
14, 1999
INDIAN TRUST FUNDS Challenges Facing Interior's Implementation of
New
Trust Asset and Accounting Management System
Statement of Keith A. Rhodes Director, Office of Computer and Information Technology Assessment Accounting and Information Management Division
GAO/T-AIMD-99-238
Statement of Keith A. Rhodes Director, Office of Computer and
Information Technology Assessment Accounting and Information
Management Division GAO/T-AIMD-99-238
Page 1 GAO/T-AIMD-99-238
Messrs. Chairmen and Members of the Committees: Thank you for
inviting me to participate in today's hearing on the Department of
the Interior's effort to improve its management of a reported $3
billion in Indian trust funds and about 54 million acres of Indian
land. As
you know, this effort is focused on correcting long- standing
trust fund management weaknesses, which include inadequate
accounting and information systems; untrained and inexperienced
staff; backlogs in appraisals, ownership determinations, and
recordkeeping; the lack of a
master lease file and an accounts receivable system; inadequate
written policies and procedures; and poor internal controls.
Earlier this year, at the request of the Senate Committee on
Indian Affairs, we reported on Interior's improvement plan to
assess whether it provided an effective solution to addressing
these long- standing problems. 1 In particular, we
assessed whether one of the most critical improvement projects the
acquisition of a new service for managing Indian assets and land
records known as the Trust Asset and Accounting Management System
or TAAMS would cost effectively meet trust management needs.
Today, I will discuss how we conducted our assessment of the TAAMS
acquisition efforts, the results of our evaluation and our
recommendations to Interior to address our findings, the current
status of TAAMS, and the challenges still confronting Interior's
implementation of this important
system. What Is TAAMS? The Department of the Interior has the
responsibility for managing Indian trust lands as well as
accounting for income derived from those lands. The purpose of the
TAAMS project part of the overall Interior effort to improve the
management of Indian trust funds and assets is to obtain a
modern, integrated information system for managing these income
producing activities, distributing income to owners, and
maintaining title and ownership records. The other projects that
make up this effort, which were defined in Interior's July 1998
High Level Implementation Plan, are described in appendix I to
this testimony.
Interior intended to acquire TAAMS as a commercial- off- the-
shelf (COTS) system. With this goal in mind, in May 1998, Interior
issued a Request for 1 Indian Trust Funds: Interior Lacks
Assurance That Trust Improvement Plan Will Be Effective (GAO/AIMD-
99-53, April 28, 1999).
Lett er
Page 2 GAO/T-AIMD-99-238
Information. The responses from vendors were evaluated using a
standardized form assessing data in 15 categories. After this
survey was completed, Interior decided to combine the TAAMS
project with another improvement project aimed at enhancing
Interior's Land Records Information System (LRIS) and to obtain
the needed functionality of these combined projects by acquiring a
trust asset information management service using a COTS system.
Under this approach, a contractor would
manage Interior- provided land and trust account data in a
contractor- owned and maintained data center while Interior would
perform its trust management functions by accessing contractor-
provided applications that run in the data center.
On December 1, 1998, Interior awarded the TAAMS contract. As part
of its improvement effort, Interior expects to spend about $60
million on developing and improving information systems, including
TAAMS.
Our Assessment of TAAMS
We began our assessment of TAAMS in July 1998 while Interior was
in the process of specifying the system's functional requirements.
Figure 1 illustrates where our review began in the acquisition and
development process.
Lett er
Page 3 GAO/T-AIMD-99-238
Figure 1: Key System Development Processes and GAO's Review
When we review systems at this point in development, we normally
assess whether agencies are following sound software development
and acquisition practices. In this regard, the critical questions
are the following. Before embarking on its development effort,
did the agency define an
integrated architecture for its business operations to ensure that
the system it is building and acquiring will not be duplicative or
User Acceptance Testing Functional Requirements
Specifies the high- level functions of the system
System Acceptance Testing
Design Requirements
Specifies the tasks each software component must perform
Integration Testing Detailed Design and Coding
Specifies the detailed steps for each software component and
implements those steps
Unit Testing
Stages of system development Stages of testing
Concept of Operations
Specifies how system is used in operation Beginning of
GAO review
Page 4 GAO/T-AIMD-99-238
incompatible with other agency systems and, therefore,
unnecessarily costly to maintain and interface? Before choosing a
certain system or service, did the agency assess the
value and risks of a sufficient range of alternatives for solving
its business problem? After selecting a system or service, did
the agency take prudent steps to
minimize acquisition and development risks? The processes and
controls we expect agencies to adopt that will help them to answer
these and other questions are called for in best practice
literature 2 or in legislative requirements, such as the Clinger-
Cohen Act of 1996, and federal policy governing acquisition
efforts, including Office of Management and Budget guidance and
National Institute of Standards and
Technology Federal Information Processing Standards. To assess
whether Interior was following sound development and acquisition
practices, we reviewed Interior's documents relating to the
acquisition, including the Request for Information, vendor
responses, and the Request for Proposals. We also met with senior
Interior officials responsible for acquiring the service,
including Interior's Chief Information
Officer; Assistant Secretary for Policy, Management and Budget
(Interior's Chief Financial Officer); Special Trustee; and the
Interior contractor who assisted in the acquisition of the new
service.
Subsequent to our report, we continued to monitor the status of
the TAAMS project by attending status meetings, interviewing the
TAAMS project manager, reviewing TAAMS project documentation, and
observing a TAAMS test on July 7 and 8, 1999, at the contractor's
Dallas, Texas, facility. This work has been performed in
accordance with generally accepted government auditing standards.
2 For example, the Software Engineering Institute's Software
Acquisition Capability Maturity Model SM (Capability Maturity
Model SM is a service mark of Carnegie Mellon University, and CMM
is a registered trademark) that provides a logical and widely
accepted framework for baselining an organization's current
process capabilities (i. e., strengths and weaknesses) and
assessing whether an organization has the necessary process
discipline in place to repeat earlier successes on similar
projects. The Institute of Electrical and Electronics Engineers,
Inc., also issues guidance on practices to reduce system
development and acquisition risks.
Page 5 GAO/T-AIMD-99-238
Results of Our Evaluation of the TAAMS Acquisition
Efforts With regard to Interior's initial systems acquisition
efforts, our April 1999
report found that Interior was not following sound practices that
would (1) help ensure that TAAMS cost effectively met trust
management needs and (2) reduce development risks. First, although
Interior planned for its components, such as the TAAMS and Trust
Funds Accounting System, to independently improve information
systems or acquire information
services, at a cost of about $60 million, it had not defined an
integrated architecture for Indian trust operations. Architectures
are comprehensive construction plans that systematically and
completely describe an organization's target business environment,
both in logical (e. g., missions, business functions, and
information flows) terms and technical (e. g., software, hardware,
and communications) terms. The Clinger- Cohen Act requires the
Chief Information Officer to develop and maintain an information
systems architecture. Without one, agencies are at risk of
building and buying systems that are duplicative, incompatible,
and
unnecessarily costly to maintain and interface. Our previous
reviews at the Federal Aviation Administration (FAA), Customs
Service, Department of Education, Internal Revenue Service, and
National Oceanic and Atmospheric Administration 3 have shown that,
while the absence of a complete architecture does not guarantee
the failure of system modernization efforts, it does greatly
increase the risk that agencies will spend more money and time
than necessary to ensure that systems are
compatible and in line with business needs. For example, in
February 1997, we found that the FAA's lack of a complete
architecture resulted in incompatibilities among air traffic
control systems that (1) required higher- than- need- be system
development, integration, and maintenance costs and (2) reduced
overall system performance. Further, without having
architecturally defined requirements and standards governing
information and data structures and communications, FAA was forced
to spend an additional $38 million to acquire a system dedicated
to overcoming incompatibilities among systems.
3 See Air Traffic Control: Complete and Enforced Architecture
Needed for FAA Systems Modernization (GAO/AIMD-97-30, February 3,
1997); Customs Service Modernization: Architecture Must Be
Complete and Enforced to Effectively Build and Maintain Systems
(GAO/AIMD-98-70, May 5, 1998); Student Financial Aid Information:
Systems Architecture Needed to Improve Program's Efficiency
(GAO/AIMD-97-122, July 29, 1997); Tax Systems Modernization:
Management and Technical Weaknesses Must Be Corrected If
Modernization Is To Succeed (GAO/AIMD-95-156, July 26, 1995); and
Weather Forecasting: Systems Architecture Needed for National
Weather Service Modernization (GAO/AIMD-94-28 March 11, 1994).
Page 6 GAO/T-AIMD-99-238
Similarly, in July 1997, we reported that because it lacked a
system architecture, the Department of Education had made limited
progress in integrating its National Student Loan Data System with
other student financial aid databases. Moreover, without an
architecture, the department
could not correct long- standing problems resulting from a lack of
integration across its student financial aid systems. We concluded
that until Interior defines the logical characteristics of its
business environment and uses them to establish technical
standards and approaches, it runs the risk that TAAMS and other
information technology investments will be redundant and
incompatible and out- of- sync with Indian trust management
requirements. We therefore recommended that Interior develop an
information systems architecture for Indian trust operations
before making major investments in information technology systems.
Second, in undertaking its effort to acquire TAAMS, Interior did
not follow a sound process for (1) ensuring that the most cost-
effective technical alternative was selected and (2) reducing
acquisition risks. Specifically, Interior did not do the
following.
Assess the desirability of satisfying its requirements by (1)
modifying existing legacy systems, (2) acquiring a COTS product
and using existing Interior infrastructure resources, (3) building
a system that would provide the necessary capability, or (4)
acquiring a service. The Clinger- Cohen Act of 1996 requires
agencies to establish a process to assess the value and risks of
information technology investments,
including the prioritizing of alternative projects. Perform a gap
analysis in surveying the availability of COTS products.
This analysis would systematically and quantitatively compare and
contrast COTS products against Interior's requirements based on
functional, technical, and cost differences.
Require the contractor to demonstrate that the COTS system could
work with Interior- provided data or that the system could
interface with other Interior systems.
Develop a risk management plan to address the possibility that
the new service would not meet performance or business
requirements, be able to work with Interior systems, and/ or be
delivered on schedule and within budget.
Again, by not following these accepted best practices for
technology service acquisitions, Interior was not necessarily
dooming TAAMS to
Page 7 GAO/T-AIMD-99-238
failure. Rather, it was further elevating the risk of encountering
problems in the development stages that could delay implementation
or unnecessarily increase costs. Thus, we recommended that
Interior develop and implement an effective risk management plan
and ensure that all project decisions are based on objective data
and demonstrated project accomplishments, and are not schedule
driven.
In commenting on a draft of our April 1999 report, Interior's
Assistant Secretary for Policy, Management and Budget recognized
that there were still problems to overcome with TAAMS, but
expressed concern about
some of our conclusions. However, in a subsequent letter to the
Congress describing actions taken in response to our
recommendations, Interior stated in July 1999 that the report has
been helpful in causing the department to intensify its efforts to
complete a systems architecture and identify the complete
functional requirements for TAAMS. Interior further stated that it
was in the process of developing a departmentwide enterprise
target architecture that would contain the items recommended in
our report (which included a high- level description of Interior's
mission and target concept of operations, the business functions
to be performed and the relationships among functions, the
improvement projects to be undertaken and how they are
interrelated, and the specific standards and approaches that will
be used to build or acquire systems). However, Interior stated
that this effort has been slowed by the need to address the Year
2000 computing problem. Interior said that it plans to include a
request for additional funding in its fiscal year 2001 budget
request to complete the architecture.
Also, Interior officials are working on revising Interior's High
Level Implementation Plan to add more details about each of the
projects and to include realistic project time frames. The revised
plan is expected to be provided to the Secretary of the Interior
for his approval by July 31, 1999.
The Current Status of TAAMS
According to the TAAMS project manager, the TAAMS contractor has
already modified its COTS product to provide the functionality
called for in the TAAMS contract. Currently, the contractor is in
the process of testing this product. It expects to complete
testing by mid- September. During the week of June 14, the
contractor performed integration testing of the initial version of
TAAMS, and, the following week, Interior initiated a
Page 8 GAO/T-AIMD-99-238
TAAMS pilot at the Billings, Montana, area office. The purpose of
software integration testing is to verify that units of software,
when combined, work together as intended. On July 7 and July 8,
the contractor conducted
preliminary user acceptance tests at the contractor's facility in
Dallas, Texas. We attended and observed these tests.
Interior has also engaged an independent verification and
validation (IV& V) agent who will verify that system testing is
performed in accordance with generally accepted guidelines. When
the IV& V assessment is done in September 1999, Interior will
decide whether or not to proceed with implementing TAAMS. Upcoming
Expectations and Challenges for TAAMS
It is critical for Interior to follow sound practices during the
testing phase for TAAMS. Along these lines, I would like to
highlight our expectations for the next few months beginning first
with an illustration (figure 2) of the stages of system testing
that we would expect Interior and its contractor to follow.
Page 9 GAO/T-AIMD-99-238
Figure 2: Major Stages of System Development and Testing
In considering this illustration, it is important to keep in mind
that complete and thorough testing is essential to provide
reasonable assurance that new or modified systems process
information correctly and will meet an organization's business
needs. To ensure that tests are thorough, organizations should
perform tests in incremental steps. That is, they should first
verify that each component of the software faithfully
implements the detailed design. Once this is done, they should
verify that combined units of software work together as intended.
From there, they should verify that a complete system satisfies
functional requirements using quantitative tests. Finally, they
should verify that the system addresses the users' needs. To
ensure tests are complete, organizations should have well- defined
functional and detailed requirements. If a requirement has not
been defined, it is unlikely that a test will uncover a defect.
User Acceptance Testing
Verifies that system operates correctly with operational hardware
and meets users needs
Functional Requirements
Specifies the high- level functions of the system
System Acceptance Testing
Verifies that complete system satisfies functional requirements
Design Requirements
Specifies the tasks each software component must perform
Integration Testing
Verifies that units of software, when combined, work together as
intended
Detailed Design and Coding
Specifies the detailed steps for each software component and
implements those steps
Unit Testing
Verifies that each component of the software faithfully implements
the detailed design
Stages of system development Stages of testing Concept of
Operations
Specifies how system is used in operation
Page 10 GAO/T-AIMD-99-238
We would also expect Interior and its contractor to establish an
effective management framework for testing. At a minimum, roles,
responsibilities, and expectations for testing should be defined;
a test and evaluation plan should be written; and guidance
defining policies, principles, strategies, standards, and
processes relevant to planning, executing, and reporting on each
level of testing should be issued. We would further expect the IV&
V contractor to ensure that test standards and guidance are being
met.
As we review TAAMS, we will evaluate whether an effective
management framework has been established for tests and whether
the tests themselves are planned and conducted in a structured,
disciplined, and incremental fashion. However, evaluating TAAMS
based solely on testing will not
ensure that Interior's trust needs will be met. First, it is
likely that the system testing phase will not uncover all errors
in the modified COTS system. In fact, testing performed through
the system test phase often catches less than 60 percent of a
program's defects. 4 The remaining errors are found through other
quality assurance practices, such as code
inspections, or by end- users after the software has been put into
production. Thus, it will be important for Interior to implement a
quality assurance program that is both rigorous and well-
structured. Second, even if TAAMS works as intended, Interior will
still need to ensure the integrity of the data that are loaded
into the system; establish adequate policies, procedures, and
controls for operation of the system; and provide
timely training and equipment to system users. Without any one of
these essential ingredients, the success of the TAAMS project
could be undermined. Third, in going forward, it will still be
vital for Interior to define a systems architecture. Without
blueprints to guide and constrain TAAMS and future information
system development efforts, Interior will not have a systematic
way to preclude either inconsistent systems design or development
decisions or the resulting suboptimal performance and added costs
associated with incompatible systems. Messrs. Chairmen, this
concludes my statement. I will be pleased to respond to any
questions that you or other members of the Committees may have at
this time. 4 Rapid Development: Taming Wild Software Schedules,
Bruce McConnell (Microsoft Press 1996).
Page 11 GAO/T-AIMD-99-238
Contact and Acknowledgements
For information about this testimony, please contact Keith Rhodes
at (202) 512- 6415. Individuals making key contributions to this
testimony included Naba Barkakati, Cristina Chaplain, Michael
Koury, and Chris Martin.
Page 12 GAO/T-AIMD-99-238
Appendix I Thirteen Projects for Improving Indian Trust Management
Appendi x I
To address long- standing problems with its management of Indian
trust funds and assets, Interior established a Trust Management
Improvement Project (TMIP) and issued a High Level Implementation
Plan for the TMIP on July 31, 1998. The 13 projects identified in
the High Level Plan are directed at improving systems; enhancing
the accuracy and completeness of Interior's data regarding the
ownership and lease of Indian lands; and correcting deficiencies
with respect to records management, training, policies and
procedures, and internal controls within 3 years. For each
project, the plan assigns management responsibility and identifies
some supporting tasks, critical milestones, and resource
estimates.
Interior estimates that it will spend $147.4 million from fiscal
years 1997 through 2000 on this effort. About $60 million of this
amount is to be spent on developing and improving information
systems, $54 million on data cleanup, $17 million on records
management, $8 million on training, and
$8 million on all other activities. Table I. 1 describes the 13
separate projects included in Interior's High Level Implementation
Plan.
Appendix I Thirteen Projects for Improving Indian Trust Management
Page 13 GAO/T-AIMD-99-238
Table I. 1: Thirteen Projects for Improving Indian Trust
Management Project Description
1. Office of the Special Trustee for American Indians (OST) Trust
Financial Records Cleanup
OST will standardize and verify Individual Indian Monies (IIM)
system data for trust resource records and correct and establish
an inventory of hard copy records for each trust fund account.
2. Bureau of Indian Affairs (BIA) Trust Resource Records Cleanup
BIA trust resource records will be cleaned up to ensure timely
ownership and land status data. Processing backlogs will be worked
off to update existing and future trust resource management
systems data essential to ensure that income distribution and
resource management functions can operate
from timely data. 3. BIA Probate Backlog BIA will inventory,
identify, and develop action plans and
procedures to eliminate probate backlog. 4. Office of Hearings and
Appeals (OHA) Probate Backlog
OHA will inventory, identify, and develop action plans and
procedures to eliminate OHA probate backlog.
5. BIA Appraisal Program This project includes an assessment of
the present BIA
appraisal program, policies, and procedures; reviews of staff
qualifications; determination of the adherence to uniform
Standards of Professional Appraisal Practices; and
development of corrective action plans, as appropriate. 6. Trust
Funds Accounting System A proven COTS trust accounting system will
be acquired, using a service bureau approach, to replace the
present BIA
IIM accounting module. 7. TAAMS The department will evaluate,
acquire, and pilot standardized, proven COTS general trust
management system technology (Master Lease, Billings and Accounts
Receivable, and
Collection subsystems) to the extent practicable. Following
successful testing and piloting, theTAAMS system will proceed to
full implementation across BIA, replacing the present BIA
Integrated Records Management System. 8. BIA LRIS Enhancements
This project contemplates the modernization of BIA's official
title system to provide on- line and up- to- date legal and
beneficial title ownership and encumbrance for all Indian lands
and resources, including automated calculation of data
storage of fractional interests and automated chain- of- title
processes and information. 9. Minerals Management Service (MMS)
System Reengineering
MMS will design, develop, and implement new core business
processes for its royalty management functions, with supporting
systems.
Appendix I Thirteen Projects for Improving Indian Trust Management
Page 14 GAO/T-AIMD-99-238
Source: Department of the Interior July 1998 High Level
Implementation Plan. 10. Records
Management A joint records management solution for Interior trust
records will be developed and implemented, involving OST, BIA,
MMS, Bureau of Land Management (BLM), OHA, and other relevant
Interior offices. The project scope includes Indian trust records
management, storage, access, control, and disposition and
contemplates electronic recordkeeping, including imaging
technology. 11. Policy and Procedures Interior trust policies and
procedures will be inventoried, reviewed, and, where appropriate,
revised or established. This project specifically involves and
includes representatives of OST, BIA, MMS, BLM, OHA, and other
departmental offices
involved in Indian trust management. 12. Training This project
will plan and deliver both trust management and employee skills
training relevant to delivery of Interior's trust
fiduciary responsibilities to American Indians. Training will be
provided across the Interior trust workforce and include tribes
and participating contractors. 13. Internal Controls This project
will systematically address documented internal
control deficiencies in Indian trust management, item by item,
that have been identified through internal and external audit,
congressional oversight, and outside reviews. Corrective
actions will be validated and/ or designed to assure resolution of
all internal control weaknesses.
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