United States Government Accountability Office

GAO Testimony before the Subcommittee on 

Federal Workforce, U.S. Postal Service, 

and Labor Policy, Committee on Oversight 

and Government Reform, 

House of Representatives 

OPM RETIREMENT 

MODERNIZATION 

Longstanding Information 

Technology Management 

Weaknesses Need to Be 

Addressed 

Statement of Valerie C. Melvin, Director 

Information Management 

 and Technology Resources Issues 

For Release on Delivery 

Expected at 9:30 a.m. EST 

November 15, 2011 

GAO-12-226T 
 United States Government Accountability Office 

Highlights of GAO-12-226T, a testimony 

before the Subcommittee on Federal 

Workforce, U.S. Postal Service and Labor 

Policy, Committee on Oversight and 

Government Reform, House of 

Representatives 

November 2011 

OPM RETIREMENT MODERNIZATION 

Longstanding Information Technology Management 

Weaknesses Need to Be Addressed 

Why GAO Did This Study 

The Office of Personnel Management 

(OPM) is the central human resources 

agency for the federal government 

and, as such, is tasked with ensuring 

the government has an effective 

civilian workforce. As part of its 

mission, OPM defines recruiting and 

hiring processes and procedures; 

provides federal employees with 

various benefits, such as health 

benefits; and administers the 

retirement program for federal 

employees. The use of information 

technology (IT) is crucial in helping 

OPM to carry out its responsibilities, 

and in fiscal year 2011 the agency 

invested $79 million in IT systems and 

services. For over 2 decades, OPM 

has been attempting to modernize its 

federal employee retirement process 

by automating paper-based processes 

and replacing antiquated information 

systems. However, these efforts have 

been unsuccessful, and OPM canceled 

its most recent retirement 

modernization effort in February 2011. 

GAO was asked to provide a statement 

summarizing its work on challenges 

OPM has faced in managing its efforts 

to modernize federal employee 

retirement processing. To do this, GAO 

relied on previously published work as 

well as a limited review of more recent 

documentation on OPM’s retirement 

modernization activities. 

What GAO Recommends 

GAO is not making new 

recommendations at this time. As 

noted, GAO has previously made 

numerous recommendations to 

address the challenges OPM has 

faced in carrying out its retirement 

modernization efforts. 

What GAO Found 

In a series of reviews, GAO found that OPM’s efforts to modernize its retirement 

system have been hindered by weaknesses in several important management 

disciplines that are essential to successful IT modernization efforts. For example, 

in 2005, GAO made recommendations to address weaknesses in the following 

areas: 

• Project management. While OPM had defined major retirement 

modernization components, it had not identified the dependencies among 

them, increasing the risk that delays in one activity could hinder progress in 

others. 

• Risk management. OPM did not have a process for identifying and tracking 

project risks and mitigation strategies on a regular basis. This meant that 

OPM lacked a mechanism to address potential problems that could 

adversely impact the retirement modernization effort’s cost, schedule, and 

quality. 

• Organizational change management. OPM had not developed a detailed 

plan to help users transition to different job responsibilities in response to the 

deployment of the new system, which could lead to confusion about roles 

and responsibilities, hindering effective system implementation. 

In 2008, as OPM was on the verge of deploying its automated retirement 

processing system, GAO reported deficiencies and made recommendations to 

improve key management capabilities in additional areas: 

• Testing. Test results 1 month prior to the deployment of a major system 

component showed that it had not performed as intended. The defects, along 

with a compressed testing schedule, increased the risk that the deployed 

system would not work as intended. 

• Cost estimating. The cost estimate OPM had developed was not supported 

by documentation necessary to its reliability. This meant that OPM did not 

have a sound basis for formulating budgets or developing a cost baseline for 

the program. 

• Earned value management, which is a tool for measuring program 

progress. The baseline against which OPM was measuring program 

progress did not reflect the full scope of the project, meaning that variances 

from planned performance would not be identified. 

In 2009, GAO reported that OPM continued to face challenges in cost estimating, 

earned value management, and testing and made recommendations to address 

these deficiencies as well as additional weaknesses in planning and overseeing 

the retirement modernization effort. Although OPM agreed with GAO’s 

recommendations and had begun to address them, the agency terminated the 

retirement modernization effort in February 2011. The agency has since stated 

that it does not plan to undertake another large-scale retirement modernization, 

but instead plans targeted steps to improve retirement processing, such as hiring 

new staff and working to improve data quality. Nonetheless, the development 

and institutionalization of the capabilities GAO recommended to address these 

weaknesses remains key to the success of any future IT initiatives that OPM 

undertakes. 

View GAO-12-226T. For more information, 

contact Valerie C.Melvin at (202) 512-6304 or 

melvinv@gao.gov. 
 

Page 1 GAO-12-226T 

Chairman Ross, Ranking Member Lynch, and Members of the 

Subcommittee: 

I am pleased to participate in today’s hearing on the Office of Personnel 

Management’s (OPM) efforts to modernize the federal government’s 

hiring and retirement systems. As you are aware, these systems are 

crucial to helping OPM achieve its mission of recruiting, retaining, and 

providing services to the federal workforce, with the agency reportedly 

investing $79 million for its IT systems and services in fiscal year 2011. 

OPM has, however, experienced challenges in managing its 

modernization initiatives. Reports that we issued in 2005, 2008, and 2009 

on the agency’s efforts toward planning and implementing a modernized 

retirement system highlighted its long history of undertaking retirement 

modernization projects that have not yielded the intended outcomes. At 

your request, my testimony today summarizes the findings from reports 

that we have issued on challenges the agency has faced in managing its 

efforts to modernize federal employee retirement processing.1

The information in my testimony is based primarily on our previous work 

at OPM. We also obtained and conducted a limited review of more recent 

documentation pertaining to the agency’s current retirement system 

modernization activities. We conducted our work in support of this 

testimony during November 2011 at OPM headquarters in Washington, 

D.C. All work on which this testimony is based was conducted in 

accordance with generally accepted government auditing standards. 

As the central human resources agency for the federal government, OPM 

is tasked with ensuring that the government has an effective civilian 

workforce. To carry out this mission, OPM delivers human resources 

products and services including policies and procedures for recruiting and 

Background 

 1

GAO, Office of Personnel Management: Retirement Modernization Planning and 

Management Shortcomings Need to Be Addressed, GAO-09-529 (Washington, D.C.: Apr 

21, 2009); Office of Personnel Management: Improvements Needed to Ensure Successful 

Retirement Systems Modernization, GAO-08-345 (Washington, D.C.: Jan 31, 2008); 

Comments on the Office of Personnel Management’s February 20, 2008 Report to 

Congress Regarding the Retirement Systems Modernization, GAO-08-576R (Washington, 

D.C.: Mar 28, 2008); and Office of Personnel Management: Retirement Systems 

Modernization Program Faces Numerous Challenges, GAO-05-237 (Washington, D.C.: 

Feb 28, 2005). 
 

hiring, provides health and training benefit programs, and administers the 

retirement program for federal employees. According to the agency, 

approximately 2.7 million active federal employees and nearly 2.5 million 

retired federal employees rely on its services.2 The agency’s March 2008 

analysis of federal employment retirement data estimates that nearly 1 

million active federal employees will be eligible to retire and almost 

600,000 will most likely retire by 2016.3

According to OPM, the retirement program serves current and former 

federal employees by providing (1) tools and options for retirement 

planning and (2) retirement compensation. Two defined-benefit retirement 

plans that provide retirement, disability, and survivor benefits to federal 

employees are administered by the agency. The first plan, the Civil 

Service Retirement System (CSRS), provides retirement benefits for most 

federal employees hired before 1984. The second plan, the Federal 

Employees Retirement System (FERS), covers most employees hired in 

or after 1984 and provides benefits that include Social Security and a 

defined contribution system.4

OPM and employing agencies’ human resources and payroll offices are 

responsible for processing federal employees’ retirement applications. 

The process begins when an employee submits a paper retirement 

application to his or her employer’s human resources office and is 

completed when the individual begins receiving regular monthly benefit 

payments as calculated by OPM. 

Processing retirement claims includes functions such as determining 

retirement eligibility, inputting data into benefit calculators, and providing 

customer service. To do so, the agency uses over 500 different 

procedures, laws, and regulations, which are documented on its internal 

website. For example, the site contains memorandums that outline new 

 2

OPM, Fiscal Year 2010 Annual Performance Report (January 2011). 

3

OPM, An Analysis of Federal Employee Retirement Data: Predicting Future Retirements 

and Examining Factors Relevant to Retiring from the Federal Service (March 2008). 

4

The Social Security Administration is responsible for administering Social Security, and 

the Federal Retirement Thrift Investment Board administers the defined-contribution 

system known as the Thrift Savings Plan. Defined-benefit plans calculate benefit amounts 

in advance of retirement based on factors such as salary level and years of service, and 

defined-contribution plans calculate benefit amounts based on how the amount is invested 

by the employee and employer. 

Page 2 GAO-12-226T 
 

procedures for handling special retirement applications, such as those for 

disability or court orders. In addition, OPM’s retirement processing 

involves the use of over 80 information systems that have approximately 

400 interfaces with other internal and external systems. 

OPM has stated that the federal employee retirement process does not 

provide prompt and complete benefit payments upon retirement, and that 

customer service expectations for more timely payments are increasing. 

The agency also reports that a greater workload is expected due to an 

anticipated increase in the number of retirement applications over the 

next decade, although current retirement processing operations are at full 

capacity. Further, the agency has identified several factors that limit its 

ability to process retirement benefits in an efficient and timely manner. 

Specifically, OPM noted that: 

• current processes are paper-based and manually intensive, resulting 

in a higher number of errors and delays in providing benefit payments; 

• the high costs, limited capabilities, and other problems with the 

existing information systems and processes pose increasing risks to 

the accuracy of benefit payments; 

• current manual capabilities restrict customer service; 

• federal employees have limited access to retirement records, making 

planning for retirement difficult; and 

• attracting qualified personnel to operate and maintain the antiquated 

retirement systems, which have about 3 million lines of custom 

programming, is challenging.5

OPM Has a Long History of 

Unsuccessful Retirement 

Modernization Initiatives 

Recognizing the need to modernize its retirement processing, in the late 

1980s OPM began initiatives that have called for automating its 

antiquated paper-based processes. Initial modernization visions called for 

developing an integrated system and automated processes to provide 

prompt and complete benefit payments. However, following attempts over 

 5

GAO-09-529. 

Page 3 GAO-12-226T 
 

more than two decades, the agency has not yet been successful in 

achieving the modernized retirement system that it envisioned. 

• In early 1987, OPM began a program called the FERS Automated 

Processing System (FAPS). However, after 8 years of planning, the 

agency decided to reevaluate the program and the Office of 

Management and Budget requested an independent review of the 

program that identified various management weaknesses. The 

independent review suggested areas for improvement and 

recommended terminating the program if immediate action was not 

taken. In mid-1996, OPM terminated the program. 

• In 1997, OPM began planning a second modernization initiative, 

called the Retirement Systems Modernization (RSM) program. The 

agency originally intended to structure the program as an acquisition 

of commercially available hardware and software that would be 

modified in-house to meet its needs. From 1997 to 2001, OPM 

developed plans and analyses and began developing business and 

security requirements for the program. However, in June 2001, it 

decided to change the direction of the retirement modernization 

initiative. 

• In late 2001, retaining the name RSM, the agency embarked upon its 

third initiative to modernize the retirement process and examined the 

possibility of privately sourced technologies and tools. Toward this 

end, the agency determined that contracting was a viable alternative 

and, in 2006, awarded three contracts for the automation of the 

retirement process, to include the conversion of paper records to 

electronic files and consulting services to redesign its retirement 

operations. 

• In February 2008, OPM renamed the program RetireEZ and deployed 

an automated retirement processing system. However, by May 2008 

the agency determined that the system was not working as expected 

and suspended system operation. In October 2008, after 5 months of 

attempting to address quality issues, the agency terminated the 

contract for the system. In November 2008, OPM began restructuring 

the program and reported that its efforts to modernize retirement 

processing would continue. However, after several years of trying to 

revitalize the program, the agency terminated retirement system 

modernization in February 2011. 

Page 4 GAO-12-226T 
 

OPM’s efforts to modernize its retirement system have been hindered by 

weaknesses in several key project management disciplines. Our 

experience with major modernization initiatives has shown that having 

sound IT management capabilities is essential to achieving successful 

outcomes. Among others, these capabilities include project management, 

risk management, organizational change management, system testing, 

cost estimating, progress reporting, planning, and oversight. However, we 

found that many of the capabilities in these areas were not sufficiently 

developed. For example, in reporting on RSM in February 2005, we noted 

weaknesses in key management capabilities, such as project 

management, risk management, and organizational change 

management.6

IT Management 

Weaknesses Have 

Repeatedly Hindered 

OPM’s Retirement 

Modernization Efforts 

• Project management is the process for planning and managing all 

project-related activities, including defining how project components 

are interrelated. Effective project management allows the 

performance, cost, and schedule of the overall project to be measured 

and controlled in comparison to planned objectives. Although OPM 

had defined major retirement modernization project components, it 

had not defined the dependencies among them. Specifically, the 

agency had not identified critical tasks and their impact on the 

completion of other tasks. By not identifying critical dependencies 

among retirement modernization components, OPM increased the risk 

that unforeseen delays in one activity could hinder progress in other 

activities. 

• Risk management is the process for identifying potential problems 

before they occur. Risks should be identified as early as possible, 

analyzed, mitigated, and tracked to closure. OPM officials 

acknowledged that they did not have a process for identifying and 

tracking retirement modernization project risks and mitigation 

strategies on a regular basis but stated that the agency’s project 

management consultant would assist it in implementing a risk 

management process. Without such a process, OPM did not have a 

mechanism to address potential problems that could adversely impact 

the cost, schedule, and quality of the retirement modernization 

project. 

 6

GAO-05-237. 

Page 5 GAO-12-226T 
 

• Organizational change management is the process of preparing users 

for the changes to how their work will be performed as a result of a 

new system implementation. Effective organizational change 

management includes plans to prepare users for impacts the new 

system might have on their roles and responsibilities, and a process 

to manage those changes. Although OPM officials stated that change 

management posed a substantial challenge to the success of 

retirement modernization, they had not developed a detailed plan to 

help users transition to different job responsibilities. Without having 

and implementing such a plan, confusion about user roles and 

responsibilities could have hindered effective implementation of new 

retirement systems. 

We recommended that the Director of OPM ensure that the retirement 

modernization program office expeditiously establish processes for 

effective project management, risk management, and organizational 

change management. In response, the agency initiated steps toward 

establishing management processes for retirement modernization and 

demonstrated activities to address our recommendations. 

We again reported on OPM’s retirement modernization in January 2008, 

as the agency was on the verge of deploying a new automated retirement 

processing system.7 We noted weaknesses in additional key 

management capabilities, including system testing, cost estimating, and 

progress reporting. 

• Effective testing is an essential activity of any project that includes 

system development. Generally, the purpose of testing is to identify 

defects or problems in meeting defined system requirements or 

satisfying system user needs. At the time of our review, 1 month 

before OPM planned to deploy a major system component, test 

results showed that the component had not performed as intended. 

We warned that until actual test results indicated improvement in the 

system, OPM risked deploying technology that would not accurately 

calculate retirement benefits. Although the agency planned to perform 

additional tests to verify that the system would work as intended, the 

schedule for conducting these tests became compressed from 5 

months to 2-1/2 months, with several tests to be performed 

concurrently rather than in sequence. The agency identified a lack of 

 7

GAO-08-345. 

Page 6 GAO-12-226T 
 

testing resources, including the availability of subject matter experts, 

and the need for further system development as contributing to the 

delay of planned tests and the need for concurrent testing. The high 

degree of concurrent testing that OPM planned to meet its February 

2008 deployment schedule increased the risk that the agency would 

not have the resources or time to verify that the planned system 

worked as expected. 

• Cost estimating represents the identification of individual project cost 

elements, using established methods and valid data to estimate future 

costs. The establishment of a reliable cost estimate is important for 

developing a project budget and having a sound basis for measuring 

performance, including comparing the actual and planned costs of 

project activities. Although OPM developed a retirement 

modernization cost estimate, the estimate was not supported by the 

documentation that is fundamental to a reliable cost estimate. Without 

a reliable cost estimate, OPM did not have a sound basis for 

formulating retirement modernization budgets or for developing the 

cost baseline that is necessary for measuring and predicting project 

performance. 

• Earned value management (EVM) is a tool for measuring program 

progress by comparing the value of work accomplished with the 

amount of work expected to be accomplished. Fundamental to reliable 

EVM is the development of a baseline against which variances are 

calculated. OPM used EVM to measure and report monthly 

performance of the retirement modernization system. The reported 

results provided a favorable view of project performance over time 

because the variances indicated the project was progressing almost 

exactly as planned. However, this view of project performance was 

not reliable because the baseline on which it was based did not reflect 

the full scope of the project, had not been validated, and was unstable 

(i.e., subject to frequent changes). This EVM approach in effect 

ensured that material variances from planned project performance 

would not be identified and that the state of the project would not be 

reliably reported. 

We recommended that the Director of OPM address these deficiencies 

by, among other things, conducting effective system tests prior to system 

deployment, in addition to improving program cost estimation and 

progress reporting. In response to our report, OPM stated that it 

concurred with our recommendations and stated that it would take steps 

to address the weakness we identified. Nevertheless, OPM deployed a 

limited initial version of the modernized retirement system in February 

Page 7 GAO-12-226T 
 

2008. After unsuccessful efforts to address system quality issues, the 

agency suspended system operation, terminated the system contract, 

and began restructuring the modernization effort. 

In April 2009, we again reported on OPM’s retirement modernization, 

noting that the agency still remained far from achieving the modernized 

retirement processing capabilities that it had planned.8 Specifically, we 

noted that significant weaknesses continued to exist in three key 

management areas that we had previously identified—cost estimating, 

progress reporting, and testing—while also noting two additional 

weaknesses related to planning and oversight. 

• Despite agreeing with our January 2008 recommendation that OPM 

develop a revised retirement modernization cost estimate, the agency 

had not completed initial steps for developing a new cost estimate by 

the time we reported again in April 2009. At that time, we reported that 

the agency had not yet fully defined the estimate’s purpose, 

developed an estimating plan, or defined the project’s characteristics. 

By not completing these steps, OPM increased the risk that it would 

produce an unreliable estimate and not have a sound basis for 

measuring project performance and formulating retirement 

modernization budgets. 

• Although it agreed with our January 2008 recommendation to 

establish a basis for effective EVM, OPM had not completed key 

steps as of the time of our April 2009 report. Specifically, despite 

planning to begin reporting on the retirement project’s progress using 

EVM, the agency was not prepared to do so because initial steps, 

including the development of a reliable cost estimate and the 

validation of a baseline, had not been completed. Engaging in EVM 

reporting without first performing these fundamental steps could have 

again rendered the agency’s assessments unreliable. 

• As previously discussed, effective testing is an essential component 

of any project that includes developing systems. To be effectively 

managed, testing should be planned and conducted in a structured 

and disciplined fashion. Beginning the test planning process in the 

early stages of a project life cycle can reduce rework later. Early test 

planning in coordination with requirements development can provide 

 8

GAO-09-529. 

Page 8 GAO-12-226T 
 

major benefits. For example, planning for test activities during the 

development of requirements may reduce the number of defects 

identified later and the costs related to requirements rework or change 

requests. OPM’s need to compress its testing schedule and conduct 

tests concurrently, as we reported in January 2008, illustrates the 

importance of planning test activities early in a project’s life cycle. 

However, at the time of our April 2009 report, the agency had not 

begun to plan test activities in coordination with developing its 

requirements for the system it was planning at that time. 

Consequently, OPM increased the risk that it would again deploy a 

system that did not satisfy user expectations and meet requirements. 

• Project management principles and effective practices emphasize the 

importance of having a plan that, among other things, incorporates all 

the critical areas of system development and is to be used as a 

means of determining what needs to be done, by whom, and when. 

Although OPM had developed a variety of informal documents and 

briefing slides that described retirement modernization activities, the 

agency did not have a complete plan that described how the program 

would proceed in the wake of its decision to terminate the system 

contract. As a result, we concluded that until the agency completed 

and used a plan that could guide its efforts, it would not be properly 

positioned to move forward with its restructured retirement 

modernization initiative. 

• Office of Management and Budget and GAO guidance calls for 

agencies to ensure effective oversight of IT projects throughout all lifecycle phases. Critical to effective oversight are investment 

management boards made up of key executives who regularly track 

the progress of IT projects such as system acquisitions or 

modernizations. OPM’s Investment Review Board was established to 

ensure that major investments are on track by reviewing their 

progress and determining appropriate actions when investments 

encounter challenges. Despite meeting regularly and being provided 

with information that indicated problems with the retirement 

modernization, the board did not ensure that retirement modernization 

investments were on track, nor did it determine appropriate actions for 

course correction when needed. For example, from January 2007 to 

August 2008, the board met and was presented with reports that 

described problems the retirement modernization program was facing, 

such as the lack of an integrated master schedule and earned value 

data that did not reflect the “reality or current status” of the program. 

However, meeting minutes indicated that no discussion or action was 

taken to address these problems. According to a member of the 

Page 9 GAO-12-226T 
 

board, OPM guidance regarding how the board is to communicate 

recommendations and needed corrective actions for investments it is 

responsible for overseeing had not been established. Without a fully 

functioning oversight body, OPM could not monitor the retirement 

modernization and make the course corrections that effective boards 

are intended to provide. 

Our April 2009 report made new recommendations that OPM address the 

weaknesses in the retirement modernization project that we identified. 

Although the agency began taking steps to address them, the 

recommendations were overtaken by the agency’s decision in February 

2011 to terminate the retirement modernization project. 

In November 2011, agency officials, including the Chief Information 

Officer, Chief Operating Officer, and Associate Director for Retirement 

Services, told us that OPM does not plan to initiate another large-scale 

effort to modernize the retirement process. Rather, the officials said the 

agency intends to take targeted steps to improve retirement processing 

that will include 

• hiring and training approximately 100 new staff to help improve the 

timeliness of processing retirement applications and responding to 

retirement claims; 

• demonstrating the capability to automate retirement applications; 

• working with other agencies to improve the quality of electronic data 

they transmit to OPM for use in retirement processing; and 

• improving OPM’s retirement services website to allow enhanced 

communication. 

Under this approach, OPM does not currently have plans to modernize 

the existing, antiquated retirement systems that the agency has long 

identified as necessary to accomplishing retirement modernization and 

improving the timeliness and accuracy of benefit payments. 

In summary, despite OPM’s recognition of the need to improve the 

timeliness and accuracy of retirement processing, the agency has thus far 

been unsuccessful in several attempts to develop the capabilities it has 

long sought. For over two decades, the agency’s retirement 

modernization efforts have been plagued by weaknesses in management 

Page 10 GAO-12-226T 
 

capabilities that are critical to the success of such endeavors. Among the 

management disciplines the agency has struggled with are project 

management, risk management, organizational change management, 

cost estimating, system testing, progress reporting, planning, and 

oversight. Even though the agency is now considering only modest efforts 

to improve retirement processing, the development and institutionalization 

of these management capabilities is key to the success of any future 

retirement modernization or other IT initiative that OPM undertakes. 

Mr. Chairman, this concludes my statement today. I would be pleased to 

answer any questions that you or other members of the Subcommittee 

may have at this time. 

If you have any questions concerning this statement, please contact 

Valerie C. Melvin, Director, Information Management and Technology 

Resources Issues, at (202) 512-6304 or melvinv@gao.gov. Other 

individuals who made key contributions include Mark T. Bird, Assistant 

Director; Larry E. Crosland; Lee A. McCracken; Teresa M. Neven; and 

Charles E. Youman. 

Page 11 GAO-12-226T 

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