Compliance with Legislative Conditions

The expenditure plan, including related documentation and program  officials’ statements, satisfied four legislative conditions, partially satisfied  four legislative conditions, and did not satisfy one legislative condition.  The nine legislative conditions and the level of satisfaction are  summarized below.
Legislative condition 1: Define activities, milestones, and costs for  implementing the program (partially satisfied).
The SBInet expenditure plan included general cost information for  proposed activities and some associated milestone information, such as  beginning and ending dates. DHS estimates that the total cost for  completing the acquisition phase for the southwest border is $7.6 billion  for fiscal years 2007 through 2011. However, the plan and related  documentation did not include sufficient details about the activities,  milestones, or costs for implementing the program. Although the plan  stated that about $790 million will be spent in the Tucson sector in Arizona  for such elements as fencing, ground sensors, radars, cameras, and fixed  and mobile towers, the plan did not specify how the funds will be  allocated by element and did not provide specific dates for   implementation. In addition, the plan did not include activities, milestones,  or costs for the northern border. According to DHS, work on the northern  border is not to begin before fiscal year 2009.
Legislative condition 2: Demonstrate how activities will further the  goals and objectives of the SBI, as defined in the SBI multiyear  strategic plan (not satisfied).
The SBInet expenditure plan included a section that describes SBI and  SBInet goals; however, the expenditure plan and related documentation  did not link individual activities with SBI’s goals, as called for by the  legislative condition. Further, the December 2006 SBI strategic plan  contained three strategic goals, one of which addresses border control.  SBI and SBInet senior officials told us all SBInet activities link back to the  overall goal of controlling the border and that the linkage between  program goals and activities is intuitive. However, the SBInet expenditure  plan did not link specific activities to more detailed SBI strategic plan  goals, such as the annual performance goals.
Legislative condition 3: Identify funding and organization staffing  (including full-time equivalents, contractors, and detailees)  requirements by activity (satisfied).
The SBInet program is managed by the SBInet Program Management  Office (PMO). The PMO plans to execute SBInet activities through a series  of concurrent task orders and to rely on a mix of government and  contractor staff. The PMO plans to nearly triple its current workforce,  from approximately 100 to 270 personnel, by September 2007 in order to  support and oversee this series of concurrent task orders. As of December  2006, SBInet officials told us that they have assigned lead staff for the task  orders that have been awarded.
Legislative condition 4: Report on costs incurred, the activities  completed, and the progress made by the program in terms of obtaining  operational control of the entire border of the United States (partially  satisfied).
The SBInet expenditure plan and related documentation discussed how  approximately $1.5 billion will be allocated to SBInet activities. For  example, about $790 million is allocated for the Tucson Border Patrol  sector and $260 million for the Yuma sector in Arizona. However, the plan  did not include costs incurred to date mainly because SBInet activities are  in the early stages of implementation and costs had not yet been captured  by DHS’s accounting system (e.g., the SBInet systems integration contract  was awarded in September 2006 and the first two task orders were  awarded in September and October 2006). Moreover, the expenditure plan  did not include a baseline measure of miles under control of the border.  While the plan did not discuss progress made to date by the program to  obtain control of the border, related program documents, such as the  bimonthly SBI reports to Congress, included information on the number of  miles under control in the southwest border. According to the November  2006 bimonthly report, as of August 2006, 284 miles of the southwest  border are under control.
Legislative condition 5: Include a certification by DHS’s Chief  Procurement Officer (CPO) that procedures to prevent conflicts of  interest between the prime integrator and major subcontractors are  established and a certification by DHS’s Chief Information Officer  (CIO) that an independent verification and validation agent is currently  under contract for the project (satisfied).
On November 30, 2006, DHS’s CPO certified that the prime integrator had  established procedures to prevent conflicts of interest between it and its  major subcontractors and that DHS is developing a process to monitor and  oversee implementation of the prime integrator’s procedures. Also, on  November 30, 2006, DHS’s Deputy CIO certified that the SBInet program  had contracted with a private company as the interim independent  verification and validation (IV&V) agent. However, this company is also  responsible for performing program activities, including requirements  management and test and evaluation activities and thus is not independent  of all the program’s products and processes that it could review. The  Deputy CIO certified that a permanent IV&V agent is to be selected by  February 28, 2007, and that CBP is to provide information sufficient to  determine that this independence issue has been resolved.
Legislative condition 6: Comply with all applicable acquisition rules,  requirements, guidelines, and best systems acquisition management  practices of the federal government (partially satisfied).
SBInet is using, at least to some extent, several acquisition best practices.  The extent to which these practices are in use varies, and outcomes are  dependent on successful implementation. However, one acquisition  requirement not followed was that the SBInet systems integration contract  did not contain a specific number of units that may be ordered or a  maximum dollar value. According to the Federal Acquisition Regulation  (FAR), indefinite quantity contracts must specify the maximum quantity  of supplies or services the agency will acquire. This may be stated as a  number of units or as a dollar value. SBI and SBInet officials told us that  the contract already contains a maximum quantity of “6,000 miles of  secure U.S. border” and that this was sufficient to satisfy the FAR  requirement. We disagree because the statement in the contract about the  6,000 miles of secure border merely reflects the agency’s overall outcome  to be achieved with the supplies or services provided but does not specify  the maximum quantity of supplies or services the agency may acquire. We  believe that a maximum quantity or dollar value limit should be included  in the contract in order to ensure that it is consistent with the FAR  requirement.
SBInet’s acquisition approach calls for considerable concurrency among  related planned tasks and activities. The greater the degree of concurrency  among related and dependent program tasks and activities, the greater a  program’s exposure to cost, schedule, and performance risks. SBI and  SBInet officials told us that they understand the risks inherent in  concurrency and are addressing these risks. However, they have yet to  provide evidence that shows they have identified the dependencies among  their concurrent activities and that they are proactively managing the  associated risk.
Further, the program office did not fully define and implement key  acquisition management processes, such as project planning, requirements  management, and risk management. According to the SBInet Program  Manager, this is due to the priority being given to meeting an accelerated  program implementation schedule. However, the program office has  begun implementing a risk management process and, according to the  Program Manager, plans to develop a plan for defining and implementing  the remaining processes by the spring of 2007.
Legislative condition 7: Comply with the capital planning and  investment control review requirements established by the Office of  Management and Budget (OMB), including Circular A-11, part 7  (partially satisfied).
As required by OMB, the plan and related documentation provided a brief  description of SBInet and addressed the program’s management structure  and responsibilities for most of the program office’s directorates. In  addition, the program office developed a draft privacy impact assessment  and established an earned value management (EVM) system to manage  the prime integrator’s progress against cost and schedule goals. However,  an OMB-required EVM system had not been fully implemented because the  baselines against which progress can be measured for the two task orders  that had been issued, as of December 4, 2006, were not yet established.  Further, the program office had not yet developed a system security plan  or determined SBInet’s compliance with the DHS enterprise architecture.
Legislative condition 8: Include reviews and approvals by DHS’s  Investment Review Board (IRB), the Secretary of Homeland Security,  and OMB (satisfied).
DHS’s IRB approved the plan on November 22, 2006; the Secretary of  Homeland Security approved the expenditure plan on November 22, 2006;  and OMB approved the plan on December 4, 2006.
Legislative condition 9: Include a review by GAO (satisfied).
On December 7, 2006, we briefed the House of Representatives Committee  on Appropriations staff and on December 13, 2006, we briefed the Senate  Committee on Appropriations staff regarding the results of our review.

	Conclusions

The legislatively mandated expenditure plan for SBInet is a congressional  oversight mechanism aimed at ensuring that planned expenditures are  justified, performance against plans is measured, and accountability for  results is ensured. Because the SBInet expenditure plan lacked sufficient  details on such things as planned activities and milestones, anticipated  costs and staffing levels, and expected mission outcomes, Congress and  DHS are not in the best position to use the plan as a basis for measuring  program success, accounting for the use of current and future  appropriations, and holding program managers accountable for achieving  effective control of the southwest border.
Under the FAR, indefinite quantity contracts such as the SBInet contract  must contain the specific number of units that may be ordered or a  maximum dollar value. However, the SBInet contract merely contains the  maximum number of miles to be secured. While SBInet officials consider  this sufficient to satisfy the FAR requirement, a maximum quantity  expressed in units other than the overall outcome to be achieved or  expressed as a dollar value limit would help ensure that the contract is  consistent with this requirement.
DHS’s approach to SBInet introduces additional risk because the  program’s schedule entails a high level of concurrency. With multiple  related and dependent projects being undertaken simultaneously, SBInet  is exposed to possible cost and schedule overruns and performance  problems. Without assessing this level of concurrency and how it affects  project implementation, SBInet runs the risk of not delivering promised  capabilities and benefits on time and within budget.

	Recommendations for Executive Action

To help ensure that Congress has the information necessary to effectively  oversee SBInet and hold DHS accountable for program results, and to help  DHS manage the SBInet program and ensure that future SBInet  expenditure plans meet the legislative requirements, we recommend that  the Secretary of Homeland Security direct the U.S. Customs and Border   Protection Secure Border Initiative Program Management Office  Executive Director to take the following three actions:    ensure that future expenditure plans include explicit and measurable  commitments relative to the capabilities, schedule, costs, and benefits  associated with individual SBInet program activities;    modify the SBInet systems integration contract to include a maximum  quantity or dollar value; and  re-examine the level of concurrency and appropriately adjust the  acquisition strategy.

	Agency Comments

In written comments on a draft of this report, DHS generally agreed with  our findings and conclusions, but did not agree with our assessment that  the SBInet contract does not contain specific numbers of units that may be  ordered or a maximum dollar value. In addition, DHS stated that CBP  intends to fully satisfy each of the legislative conditions in the near future  to help minimize the program’s exposure to cost, schedule, and  performance risks. DHS’s written comments are reproduced in   appendix II.
With respect to our recommendations, DHS concurred with two of our  recommendations and disagreed with one. Specifically, DHS concurred  with our recommendation for future expenditure plans to include explicit  and measurable commitments relative to capabilities, schedule, costs, and  benefits associated with individual SBInet program activities.  According  to DHS, future SBInet expenditure plans will include actual and planned  progress, report against commitments contained in prior expenditure  plans, and include a section that addresses and tracks milestones.  DHS  also concurred with our recommendation to re-examine the level of  concurrency and appropriately adjust the acquisition strategy. In its  written comments, DHS stated that CBP is constantly assessing the overall  program as it unfolds, and adjusting it to reflect progress, resource  constraints, refinements and changes in requirements, and insight gained  from ongoing system engineering activities. DHS also stated that CBP  recognizes the risk inherent in concurrency and has added this to the  program’s risk management database.
DHS did not agree with our recommendation to modify the SBInet  integration contract to include a maximum quantity or dollar value.   According to DHS, the quantity stated in the contract, “6,000 miles of   secure U.S. border,” is measurable and is therefore the most appropriate  approach to defining the contract ceiling.  We do not agree. Under the  FAR, an agency may use an indefinite delivery/indefinite quantity contract,  such as that used for SBInet, when it is not possible to determine in  advance the precise quantities of goods or services that may be required  during performance of the contract.  Though these types of contracts are  indefinite, they are not open-ended.  The FAR requires that indefinite  quantity contracts contain a limit on the supplies or services that may be  ordered, stated in terms of either units or dollars.  This limit serves a  variety of purposes, including establishing the maximum financial  obligation of the parties.  In our view, the purported maximum used in the  SBInet contract, “the full panoply of supplies and services to provide 6,000  miles of secure U.S. border,” does not allow anyone to calculate with any  degree of certainty what the maximum financial obligation of the parties  might turn out to be since the contract does not make clear the total  amount of supplies or services that would be required to secure even 1  mile of U.S. border.  In order to ensure that the SBInet contract is  consistent with the FAR, we continue to believe that it should be modified  to include a maximum quantity, either units or a dollar value, rather than  the total amount of miles to be secured.
We are sending copies of this report to the Chairman and Ranking  Minority Members of other Senate and House committees that have  authorization and oversight responsibilities for homeland security. We are  also sending copies to the Secretary of Homeland Security, the  Commissioner of Customs and Border Protection, and the Director of the  Office of Management and Budget. Copies of this report will also be  available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any further questions about this report, please  contact Richard Stana at (202) 512-8816 or StanaR@gao.gov. Contact   points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. Key contributors to this report are  listed in appendix III.

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

	Briefing on the Secure Border Initiative’s

		Briefing Overview

• Objective, Scope, and Methodology Results in Brief Background Findings Conclusions Recommendations for Executive Action Agency Comments and Our Evaluation Attachment 1: Scope and Methodology

	To accomplish our objective, we analyzed the SBInet December 2006 expenditure plan and supporting documentation. We also interviewed cognizant program officials and contractors. We did not review the justification for cost estimates included in the expenditure plan. We conducted our work at Department of Homeland Security’s (DHS) U.S. Customs and Border Protection (CBP) headquarters in the Washington, D.C., metropolitan area from October 2006 to December 2006, in accordance with generally accepted government auditing standards. Details of our scope and methodology are provided in attachment 1.

Pub. L. No. 109-295, 120 Stat. 1355, 1359-60. The Appropriations Act required an expenditure plan to establish a security barrier along  the border of the United States of fencing and vehicle barriers and other forms of tactical infrastructure and technology.  In response to this  requirement, DHS submitted a plan on December 4, 2006, titled “SBInet Expenditure Plan,” that defines SBInet as “the component of SBI  charged with developing and installing the technology and tactical infrastructure solution for border control.”  The Appropriations Act also  required GAO to review the expenditure plan.

Results in Brief: Satisfaction of legislative conditions

	Legislative conditions

	3. Identifies funding and the organization staffing (including full-time equivalents, contractors, and detailees) requirements by activity. 4. Reports on costs incurred, the activities completed, and the progress made by the program in terms of obtaining operational control of the entire border of the United States. 5. Includes a certification by DHS’s Chief Procurement Officer (CPO) that procedures to prevent conflicts of interest between the prime integrator and major subcontractors are established and a certification by DHS’s Chief Information Officer (CIO) that an independent verification and validation agent is currently under contract for the project.

Results in Brief: Satisfaction of legislative conditions

	DHS defines control of U.S. borders as the ability to:

1. detect illegal entries into the United States;  2. identify and classify these entries to determine the level of  threat involved;  3. efficiently and effectively respond to these entries; and  4. bring events to a satisfactory law enforcement resolution.
The initial focus of SBInet will be on southwest border investments  and areas between the ports of entry that CBP has designated as  having the highest need for enhanced border security due to  serious vulnerabilities.  Figure 2 shows the topography, interstate  highways, and some major secondary roads along the southwest  border.

Background

	DHS’s acquisition process for major investments consists of 5 decision milestones and requires Investment Review Board approval at key decision points (see fig. 4).

DHS estimates that the total cost for completing the acquisition phase for  the southwest border is $7.6 billion from FY2007 through FY2011.  $5.1 billion is for the design, development, integration and  deployment of fencing, roads, vehicle barriers, sensors, radar units,  and command, control, and communications and other equipment.   $2.5 billion is for integrated logistics and operations support during  the acquisition phase for the southwest border.
DHS expects to have control of the southwest border by October 2011.
DHS officials have yet to provide draft implementation plans by southwest  border sectors and years for FY2007-FY2011.
The expenditure plan does not include activities, milestones, or costs for  the northern border. According to DHS, work on the northern border is not  projected to begin before FY2009.

Legislative condition #1 continued

	The expenditure plan provides a general breakdown of how funds will be allocated to SBInet’s activities.1 (See table 1.)

	A-11 Requirement

Provide a brief description of the investment and its status in the CPIC review,  including major assumptions made about the investment.

Legislative Condition #7 continued

	A-11 Requirement Describes the management structures, responsibilities, and qualifications that

contribute to achievement of cost, schedule, and performance goals.
The expenditure plan and other documentation address the management structures  and responsibilities. Specifically, the program office includes six line and four staff  directorates reporting to the SBInet Program Manager. The management structure  also includes the use of integrated project teams that consist of subject matter  experts from a variety of disciplines required to effectively manage an acquisition  project.  The draft Program Management Plan, dated September 18, 2006, identified  responsibilities for five of the six program office line directorates, and for two of the  four staff directorates. The plan also identified responsibilities for some, but not all,  divisions within each of the directorates. For example, the plan describes the  responsibilities of the Mission Engineering Directorate, but it does not describe the  responsibilities for the five divisions within the Directorate.
We have not yet seen any documentation that describes the qualifications of the  program office staff.

Legislative Condition #7 continued

	A-11 Requirement

Provide a summary of the investment’s risk assessment, including how 19 OMB- identified risk elements are being addressed.
The program office has defined and begun implementing a risk management  process, and developed a risk database that addresses 13 of the 19 OMB-identified  risk. The risk elements that are not addressed include privacy and technical  obsolescence.

Legislative Condition #7 continued

	A-11 Requirement

Provides a summary of the investment’s status in accomplishing baseline cost  and schedule goals through the use of an earned value management (EVM)  system or operational analysis, depending on the life-cycle stage.
The program office is currently relying on the prime integrator’s EVM system to  manage the prime contractor’s progress against cost and schedule goals. The  prime integrator’s EVM system has been independently certified as meeting  established standards.
However, the EVM system has not yet been fully implemented because the  baselines against which progress can be measured for the two task orders that  have been issued to date has not yet been established. According to program  officials, these baselines will be established for the program management task  order and the Project 28 task order in mid-December 2006 and mid-January  2007, respectively.

Legislative Condition #7 continued

	A-11 Requirement Demonstrates that the investment is included in the agency’s enterprise architecture

and CPIC process.
The expenditure plan did not include a discussion of the program office’s activities in  regard to the DHS enterprise architecture.
Moreover, according to program officials, the program office has not yet determined  if SBInet is aligned with the architecture. According to these officials, SBInet is to be  reviewed by the Enterprise Architecture Center of Excellence, which is the DHS  entity that determines enterprise architecture alignment, by the end of December  2006.

Legislative Condition #7 continued

	A-11 Requirement

Provides a description of an investment’s security and privacy issues. Summarizes  the agency’s ability to manage security at the system or application level.  Demonstrates compliance with the certification and accreditation process, as well as  the mitigation of IT security weaknesses.
The expenditure plan did not include a discussion of security and/or privacy.  According to a program office security specialist, the program office has not yet  developed a system security plan because it is too early in the system development  life cycle. A system security plan is to be developed as a part of the system  certification and accreditation process.
Regarding privacy, the program office developed a draft privacy impact assessment  dated October 2006. The assessment addresses several, but not all, of OMB’s  criteria.
Legislative Condition #8: Includes Approvals by IRB,  DHS Secretary and OMB (Satisfied)
The expenditure plan, including related documentation and program  officials’ statements, satisfied the condition that the plan be reviewed  and approved by DHS’s Investment Review Board, the Secretary of  Homeland Security, and OMB.
DHS’s Investment Review Board approved the plan on  November 22, 2006.
The Secretary of Homeland Security approved the expenditure  plan on November 22, 2006.
OMB approved the plan on December 4, 2006.

Legislative Condition #9: Is Reviewed by GAO (Satisfied)

	The expenditure plan, including related documentation and program officials statements, satisfies the condition that the plan be reviewed by GAO.

The SBInet PMO provided draft versions of the expenditure  plan and supporting documentation.
We conducted our review from October 11, 2006, to December  5, 2006.

Conclusions

	The SBInet December 2006 expenditure plan, including related documentation and

program officials’ statements, has satisfied four, partially satisfied four and not  satisfied one of the nine conditions legislated by the Congress. Satisfying the  legislative conditions is important because the expenditure plan is intended to  provide Congress with the information needed to effectively oversee the program  and hold DHS accountable for program results. Satisfying the legislative conditions  is also important to minimize the program’s exposure to cost, schedule, and  performance risks.
DHS’s approach to SBInet introduces additional risk because the program’s  structure entails a high level of concurrency and lacks a maximum quantity or dollar  value for the integration contract.
The current expenditure plan offers a high-level and partial outline of a large and  complex program that forms an integral component of a broader multi-year  initiative. However, Congress and DHS need additional details of planned  milestones, anticipated interim and final costs, and staffing to be reasonably  assured that the current risk to the project’s cost, schedule, and ultimate  effectiveness is minimized.

Recommendations

	To ensure that Congress has the information necessary to effectively oversee SBInet and hold DHS accountable for program results, and to help DHS manage the SBInet program and ensure that future SBInet expenditure plans meet the legislative requirements, we recommend that the Secretary of Homeland Security direct the U.S. Customs and Border Protection Secure Border Initiative Program Management Office Executive Director to take the following three actions:

ensure that future expenditure plans include explicit and  measurable commitments relative to the capabilities, schedule,  costs, and benefits associated with individual SBInet program  activities;  re-examine the level of concurrency and appropriately adjust the  acquisition strategy; and   modify the SBInet systems integration contract to include a  maximum quantity or dollar value.

Agency Comments and Our Evaluation

	With respect to our recommendations, DHS, SBI, and SBInet officials agreed with our first recommendation on the need for future expenditure plans to include explicit and measurable commitments relative to capabilities, schedule, costs and benefits associated with individual SBInet program activities. SBI and SBInet officials stated that more details will be available for future expenditure plans as subsequent task orders for the program are awarded.

Agency Comments and Our Evaluation continued

	DHS, SBI and SBInet officials also took issue with our third recommendation on modifying the SBInet integration contract to include a maximum quantity or dollar value. They stated that the contract already contains a maximum quantity of “6,000 miles of secure U.S. border” and that this was sufficient to satisfy the FAR requirement. We disagree and continue to believe that a maximum quantity or dollar value limit should be included in the integration contract in order to ensure that it is consistent with FAR requirements.

DHS, SBI and SBInet officials also provided clarifying information that we incorporated as  appropriate in this briefing.

Attachment 1: Scope and Methodology

	To accomplish our objective, we analyzed the SBInet fiscal year 2007

expenditure plan and supporting documentation, comparing them to relevant federal requirements and guidance, and applicable best practices.
We reviewed draft versions of the expenditure plan, including versions 1.0  (November 15, 2006); 2.0 (November 27, 2006); and 2.1 (November 29,  2006).  We also reviewed the final version of the plan submitted to  Congress on December 4, 2006.
We interviewed DHS, CBP, SBI, and SBInet program officials and  contractors.
We did not review the justification for cost estimates included in the  expenditure plan. In addition, we did not independently verify the source or  validity of the cost information.

Attachment 1: Scope and Methodology continued

	We compared available program documentation to capital planning

guidance (OMB-A-11) to determine whether the information complies with  the capital planning and investment controls.
We conducted our work at CBP headquarters in the Washington, D.C.,  metropolitan area from October 2006 to December 2006, in accordance  with generally accepted government auditing standards.

Appendix II: Comments from the Department of Homeland Security

Appendix III: GAO Contact and Staff Acknowledgments

	GAO Contact

	Staff Acknowledgments

In addition to the person named above, Robert E. White, Assistant  Director; Deborah Davis, Assistant Director; Richard Hung, Assistant  Director; E. Jeanette Espínola; Frances Cook; Katherine Davis; Gary  Delaney; Joseph K. Keener; Sandra Kerr; Raul Quintero; and Sushmita  Srikanth made key contributions to this report.

Summary:
Why GAO Did This Study

In November 2005, the Department of Homeland Security (DHS) established the Secure Border Initiative (SBI) program to secure U.S. borders and reduce illegal immigration. One element of SBI is SBInet, the program responsible for developing a comprehensive border protection system. By legislative mandate, DHS developed a fiscal year 2007 expenditure plan for SBInet to address nine legislative conditions, including a review by GAO. DHS submitted the plan to the Appropriations Committees on December 4, 2006. To address the mandate, GAO assessed the plan against federal guidelines and industry standards and interviewed appropriate DHS officials.

What GAO Found

The SBInet expenditure plan, including related documentation and program officials' statements, satisfied four legislative conditions, partially satisfied four legislative conditions, and did not satisfy one legislative condition. Satisfying the legislative conditions is important because the expenditure plan is intended to provide Congress with the information needed to effectively oversee the program and hold DHS accountable for program results. Satisfying the legislative conditions is also important to minimize the program's exposure to cost, schedule, and performance risks. SBInet's December 2006 expenditure plan offered a high-level and partial outline of a large and complex program that forms an integral component of a broader multiyear initiative. However, the plan and related documentation did not include explicit and measurable commitments relative to capabilities, schedule, costs, and benefits associated with individual SBInet program activities. In addition, the SBInet systems integration contract did not contain a specific number of units that may be ordered or a maximum dollar value as required by Federal Acquisition Regulation. Further, DHS's approach to SBInet introduces additional risk because the program's schedule entails a high level of concurrency among related planned tasks and activities.