OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

January 25, 2008 

MEMORANDUM FOR DIRECTOR OF U.S. FOREIGN ASSISTANCE/ADMINISTRATOR, 

U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT 

U.S. AMBASSADOR TO IRAQ 

ECONOMIC MINISTER/COORDINATOR FOR ECONOMIC 

TRANSITION IN IRAQ 

MISSION DIRECTOR-IRAQ, U.S. AGENCY FOR 

INTERNATIONAL DEVELOPMENT 

DIRECTOR, IRAQ TRANSITION ASSISTANCE OFFICE 

SUBJECT: Efforts to Implement a Financial-Management Information System in Iraq 

(SIGIR 08-007) 

We are providing this audit report for your information and use. We performed this audit in 

accordance with our statutory responsibilities contained in Public Law 108-106, as amended, 

which requires the independent and objective conduct of audits relating to programs and 

operations funded with amounts appropriated or otherwise made available to the Iraq Relief and 

Reconstruction Fund. The law also requires that we provide for the independent and objective 

leadership and coordination of and recommendations on policies designed to promote economy, 

efficiency, and effectiveness in the administration of such programs and operations and to 

prevent and detect fraud, waste, and abuse. This review was conducted as Project 8005. 

We considered comments from the U.S. Agency for International Development when preparing 

the final report. The comments are addressed in the report, where applicable, and a copy is 

included in Management Comments section of this report. 

We appreciate the courtesies extended to our staff. For additional information on this report, 

please contact Robert Pelletier at 703-428-0739 or robert.pelletier@sigir.mil. 

 

 

Stuart W. Bowen, Jr. 

Inspector General 
Table of Contents 

Executive Summary i 

Introduction 1 

U.S. Funding for IFMIS Cannot Be Fully Calculated 4

Reconstruction Policy Decisions and Guidance, Rather Than User Needs, 

Drove IFMIS Development 7

Operational Issues Impacting IFMIS 12

Conclusions and Lessons Learned 15

Appendices 

A. Scope and Methodology 17 

B. Acronyms 18

C. Audit Team Members 19

Management Comments 20
Efforts to Implement a FinancialManagement Information System in Iraq 

SIGIR-08-007 January 25, 2008

Executive Summary 

Introduction 

In early summer 2003, the Coalition Provisional Authority (CPA) and the International Monetary 

Fund conducted assessments that identified a need for improvements in the Government of Iraq’s 

(GoI) budget and financial control system. These assessments found that the GoI financial 

structure provided limited ability to monitor Iraqi ministerial budgets and expenditures, leaving 

the ministries vulnerable to fraud, waste, and misappropriation of funds. According to a senior 

advisor with the CPA, “the Iraqi Ministry of Finance had been completely looted and 

burned...There were no computers...Everything was paper intensive.” The CPA, which then 

managed the budget, conceived the Iraqi Financial Management Information System (IFMIS) as 

a solution to manage and oversee the GoI budget. 

According to the U.S. Agency for International Development (USAID), when instructed by the 

CPA to implement an Iraqi financial management information system, it entered into a broadbased contract with BearingPoint, Inc. for that purpose. That contract had numerous other tasks 

related to economic and financial reforms. IFMIS represented only a small part of the total effort 

and estimated cost under the contract, which was known as Economic Governance I (EG-I). In 

September 2004, USAID awarded to BearingPoint a follow-on contract for the continuation of 

the economic and financial reforms. That contract, known as Economic Governance II (EG-II), 

continued to fund IFMIS, which again was only a small part of the total effort and cost. Both 

contracts were cost-plus-fixed-fee level of effort. 

In September 2006, the Joint Contracting Command Iraq/Afghanistan issued to BearingPoint two 

concurrent contracts for the Iraq Reconstruction Management Office—now the Iraq Transition 

Assistance Office (ITAO). The first had three components: two related to IFMIS and a third to 

fiscal policy reforms. The second contract was to integrate a procurement module into IFMIS. 

In July 2007, the U.S. Embassy in Iraq ordered the suspension of the IFMIS project because the 

BearingPoint project leader and his security detail had been kidnapped and the GoI lacked 

support for the system. To provide timely information on economy and efficiency issues and 

respond to a request for assistance from the U.S. Embassy, the Special Inspector General for Iraq 

Reconstruction (SIGIR) issued an interim report concerning the IFMIS contracts.1 In sum, 

SIGIR recommended that the embassy establish a working group to evaluate a number of factors 

impacting the way forward and that further work on a financial management system be 

 

1 Interim Report on Efforts and Further Actions Needed to Implement a Financial Management Information System 

in Iraq (SIGIR-08-001, October 24, 2007). 

i
contingent on the GoI’s commitment to such a system and an independent assessment of GoI 

needs. This report presents SIGIR’s overall review results of the IFMIS project. 

SIGIR’s overall objective for this report was to assess the U.S. government efforts to improve 

GoI budgeting and financial management through IFMIS. Specifically, SIGIR looked at: 

1. U.S. funding for IFMIS development and implementation. 

2. The extent to which IFMIS development and implementation objectives and schedule were 

achieved. 

3. Operational issues that impacted the success and acceptability of IFMIS. 

4. USAID’s actions with regard to the recommendations in SIGIR’s interim report. 

Results in Brief 

IFMIS had achieved limited functionalities before it was shut down in June 2007. Its costs at 

that time were estimated at $26 million. Lack of support for the system within the GoI and 

security issues were the key contributing factors to the shut-down. In November 2007, USAID 

began initiatives to ensure GoI support for the system in the future. In mid-January 2008, the 

Iraqi Minister of Finance and Acting Mission Director of USAID signed a Memorandum of 

Understanding to restart the system. These initiatives are in line with SIGIR’s prior 

recommendations to secure the GoI’s commitment to a financial management information 

system, and that USAID undertake an independent, third-party assessment of GoI managementsystem requirements and capabilities. 

Although deteriorating security conditions and competing demands no doubt adversely impacted 

IFMIS development, there was also a lack of clear direction based on user requirements. Neither 

the USAID EG-I and EG-II contracts nor BearingPoint’s work plans provided that direction. 

Information was not available to clearly assess progress on the system in relation to available 

benchmarks, making it difficult for USAID to assess BearingPoint’s performance. 

Cost is an important factor in managing any system’s development, and the USAID contracts did 

not require the identification of IFMIS costs. SIGIR considers that a weakness in the contract 

requirements. SIGIR also believes that the use of the cost-plus-fixed-fee level of effort contracts 

was not the best choice for a system development and implementation effort because it placed 

greater cost risk on the U.S. government. 

SIGIR recognizes that Iraq was and still is a complex and difficult environment in which to 

operate and that policy considerations drove many of the early decisions on how to help improve 

the GoI’s financial management information. Because IFMIS development and implementation 

had ceased and SIGIR previously provided recommendations for improving the system, SIGIR 

makes no further recommendations. However, SIGIR believes that valuable lessons—with 

broader applicability—can be gleaned from the course followed by the IFMIS development 

project. 

ii
U.S. Funding for IFMIS Cannot Be Fully Calculated 

Although we could not fully calculate from agency official accounting records the total U.S. 

funds expended for IFMIS, available information indicates it is about $26 million.2 The two 

ITAO contracts identify IFMIS-related costs, but the USAID contracts do not differentiate 

IFMIS related costs from others. According to the Corps of Engineers, which is responsible for 

maintaining the financial data for ITAO contracts, ITAO had spent $4,060,723 for IFMIS-related 

modules as of October 2007. When asked for its IFMIS cost estimates, USAID provided 

BearingPoint’s estimates. According to BearingPoint, which is responsible for reporting its costs 

to USAID, $22,093,386 million of the EG-I and EG-II contract costs relate to IFMIS. Based on 

the ITAO cost data and the BearingPoint estimate, IFMIS-related costs therefore appear to be 

about $26 million. 

The cost-plus-fixed-fee level of effort type contracts USAID utilized for the IFMIS project are 

more suitable for research or a preliminary exploration study than for a system development and 

implementation effort. According to USAID, it made the right choice in choosing these type 

contracts because they provided maximum flexibility needed for the Iraqi environment.

Reconstruction Policy Decisions and Guidance, Rather Than User 

Needs, Drove IFMIS Development 

According to International Monetary Fund and World Bank studies, a sound informationtechnology project design is predicated on the identification of user requirements. However, the 

GoI requirements were never identified. According to USAID, that resulted from a policy 

decision made initially by the CPA and maintained by other U.S. government organizations. 

Without Iraqi user requirements to guide the system development, IFMIS development appears 

to have been driven by U.S. reconstruction policy decisions, CPA guidance, and BearingPoint 

work plans. 

The USAID EG-I and EG-II cost-plus-fixed-fee level of effort contracts do not provide clear 

objectives, tasks, and timeframes for IFMIS development. According to USAID, the 

BearingPoint work plans it approved rather than the EG-I and EG-II contracts delineated 

requirements and deliverables. SIGIR found the work plans lacking content and clear direction, 

specific deliverables, and set timelines. Given their absence, it would have been difficult for 

USAID to measure BearingPoint’s progress on the system. SIGIR also found that USAID 

personnel in Baghdad lacked specific knowledge about deliverables and their status. All our 

questions in this regard were directed to BearingPoint. 

Despite these issues and a difficult security environment, BearingPoint had developed and 

implemented a system that captured most of the GoI budget, allowed vouchers to be processed, 

payments to be made, and reports to be generated. However, SIGIR identified a number of 

issues adversely impacting IFMIS operations. 

 

2

 We reported a cost estimate of $38 million in our October 2007 interim report on IFMIS. On the basis of morecurrent cost data, we have revised that estimate to $26 million. 

iii
Operational Issues Impacting IFMIS 

A number of issues remain to be resolved before IFMIS can be relied upon to generate reports 

that address Iraqi needs. SIGIR’s review identified IFMIS operational issues that affected the 

system’s acceptance by GoI ministries. For example, SIGIR found that ministries had problems 

with spending units,3 the reports produced by the system, and data reliability. SIGIR also found 

that as alternatives to IFMIS, the Ministry of Finance continued to use legacy systems, while 

other ministries, such as Defense and Interior, had developed their own financial management 

systems. 

At the time SIGIR completed its review in December 2007, USAID was preparing to undertake 

an independent assessment of GoI needs, and had initiated discussions with the Ministry of 

Finance to secure GoI commitment to IFMIS. Those actions were consistent with SIGIR’s prior 

recommendations. 

Lessons Learned 

Because IFMIS development and implementation has ceased and SIGIR previously provided 

recommendations on the system, SIGIR makes no further recommendations. However, SIGIR 

believes that valuable lessons—with broader applicability—can be gleaned from the course 

followed by the IFMIS development project: 

• User commitment and requirements identification are critical to the success of any 

management-information system development and implementation effort and should be 

prerequisites for any system development. 

• Clear objectives and a schedule to achieve them are needed to effectively manage the 

work of contractors involved in developing systems and should be clearly articulated in 

contract documents. 

• Management needs accurate and complete expenditure information to effectively manage 

project or program costs, and contracts should be written to require that information. 

Management Comments and Audit Response 

USAID strongly disagreed with our positions and information on the status and cost of the 

system and the type of contract used. SIGIR believes its positions are sound and the information 

in the report accurate. SIGIR addresses these differences in this report, where applicable. 

Further, SIGIR added recent information pertaining to the GoI’s commitment to IFMIS. A copy 

of USAID’s detailed comments is included in the Management Comments section of this report. 

 

3

 Spending units are workstations used to transmit payment and revenue transactions from the ministries/agencies to 

the IFMIS central database and receive trial balances in return. 

iv
Introduction 

In early summer 2003, the Coalition Provisional Authority (CPA) and the International Monetary 

Fund (IMF) conducted assessments that identified a need for improvements in the Government 

of Iraq’s (GoI) budget and financial control system. These assessments found that the GoI 

financial structure provided limited ability to monitor Iraqi ministerial budgets and expenditures, 

leaving the ministries vulnerable to fraud, waste, and misappropriation of funds. According to a 

senior advisor with the CPA, “the Iraqi Ministry of Finance had been completely looted and 

burned ...There were no computers...Everything was paper intensive.” As a result, the Iraqi 

Financial Management Information System (IFMIS) was conceived by the CPA as a needed 

solution to manage and oversee the GoI budget, which was then managed by the CPA. 

According to the U.S. Agency for International Development (USAID), when instructed by the 

CPA to implement an Iraqi financial management information system, it contracted with 

BearingPoint, Inc. to develop and implement that system. 

In July 2007, the U.S. Embassy in Iraq ordered the suspension of the IFMIS project because the 

BearingPoint project leader and his security detail had been kidnapped and the GOI lacked 

support for the system. To provide timely information on economy and efficiency issues and 

respond to a request for assistance from the U.S. Embassy in Iraq, we provided, in October 2007, 

recommendations and interim results concerning the IFMIS contracts.4 In sum, we 

recommended that the U.S. Embassy establish a working group to evaluate a number of factors 

impacting the way forward and that further work on a financial-management system be 

contingent on the GoI’s commitment to such a system and an independent assessment of GoI 

needs. This report presents our overall review results on the IFMIS project. 

IFMIS-Related Contracts 

IFMIS development and implementation efforts were primarily performed under contracts 

between USAID and BearingPoint. In addition, the Iraq Reconstruction Management Office—

now the Iraq Transition Assistance Office (ITAO)—had two contracts with BearingPoint to 

incorporate IFMIS modules. 

In accordance with CPA directions to develop an Iraqi financial-management information 

system, USAID contracted for that system in 2003 under a broad-based contract with 

BearingPoint. IFMIS represented only a small part of the total effort and estimated cost under 

the contract known as Economic Governance I (EG-I).5

 The contract included numerous other 

tasks related to economic and financial reforms for Iraq. The initial performance period of the 

contract was from July 18, 2003, to July 17, 2004. It also provided for two option years. They 

were not exercised, but the performance period was extended to September 30, 2004. The total 

estimated cost of the contract, for the initial period and extension, was $79,583,885. 

 

4 Interim Report on Efforts and Further Actions Needed to Implement a Financial Management Information System 

in Iraq (SIGIR-08-001, October 24, 2007). 5

 Contract number RAN-C-00-03-00043-00. 

1
In September 2004, USAID awarded a follow-on contract to BearingPoint for the continuation of 

the economic and financial reforms.6

 Known as Economic Governance II (EG-II), it continued 

to fund IFMIS. As with the EG-I contract, IFMIS represented only a small part of the total effort 

and estimated cost of EG-II. The contract specified an initial performance period from 

September 3, 2004, to September 2, 2007, had a total estimated cost of $184,637,237, and 

provided for two option years. The options, exercised in June 2007, extended the performance 

period to September 2, 2009, and increased the contract’s total estimated cost to $224,999,967. 

In September 2006, the Joint Contracting Command-Iraq/Afghanistan issued two concurrent 

contracts for the Iraq Reconstruction Management Office—now ITAO—to BearingPoint. The 

first contract had three components:7 two related to IFMIS and a third to fiscal policy reforms. 

The contract performance period was October 1, 2006, to September 30, 2007, and the total 

estimated cost was $4,525,718. The second contract was to integrate a procurement module into 

IFMIS;8 the contract performance period was October 1, 2006, to September 30, 2007, and the 

total estimated cost $4,196,884. 

IFMIS Operations Had Been Suspended 

Following the kidnapping of the BearingPoint project leader and his security detail in May 2007, 

according to USAID, the Ministry of Finance did not encourage GoI staff to return to work at the 

IFMIS data center, and the ministry effectively shut down IFMIS operations. In late June 2007, 

therefore, USAID suspended IFMIS implementation activities under the EG-II contract. 

Activities under the ITAO contracts were subsequently cancelled. IFMIS was dormant at the 

time we completed our review in December 2007. 

IFMIS had its core system at the Ministry of Finance and spending units in the ministries and 

agencies. At the core are a central database and general ledger, accounts payable, and cash 

management functions. At the time the system was shut down, work had been underway to 

incorporate budget and procurement modules. In addition, there were plans to incorporate 

accounts-receivables and assets-management modules, as well as to install 182 spending units. 

(Only 112 were installed as of October 2007.) The spending units are used to transmit payment 

and revenue transactions from the ministries/agencies to the Ministry of Finance for recording in 

the IFMIS central database. In return, that ministry provided one trial balance financial report 

for each ministry/agency. The spending units are linked to the Ministry of Finance database via 

the Internet. The following figure depicts the IFMIS components. 

 

6

 Contract number 267-C-00-04-00405-00. 

7

 Contract number W916GXQ-06-C-0009. 

8

 Contract number W916GXQ-06-C-0010. 

2
Figure 1: IFMIS Components 

Central Data Base

Maintains transaction details and structural data 

e.g., Chart of Account 

General Ledger

Manages storage, access, 

and reporting of financial 

data

Accounts Payable

Manages payments 

Cash Management 

Monitors cash position and 

analyzes cash flows

Budget 

Manages budget 

preparation

Accounts Receivable 

Manages revenue

Asset Management

Maintains records of major 

government assets

Procurement

Manages purchases of 

goods and services 

Legend

Installed 

 Not installed

Partially Installed 

Workstation

112 

spending 

units

 70 

spending 

units

Internet

Workstation

IFMIS CORE SYSTEM Modules 

Note: 

Spending units are designed to transmit payment and revenue transactions from the ministries/agencies to the IFMIS central database and receive 

trial balances in return. 

Source: Developed by SIGIR from USAID and BearingPoint documents. 

Objectives 

Our overall objective in this review was to assess the U.S. government’s efforts to improve GoI 

budgeting and financial management through IFMIS. Specifically, we assessed: 

1. U.S. funding for IFMIS development and implementation. 

2. The extent to which IFMIS development and implementation objectives and schedule were 

achieved. 

3. Operational issues that impacted the success and acceptability of IFMIS. 

4. USAID’s actions with regard to the recommendations in our interim report. 

3
U.S. Funding for IFMIS Cannot Be Fully Calculated 

Although we could not fully calculate from agency official accounting records the total U.S. 

funds expended for IFMIS, available information indicates it is about $26 million.9

 The two 

ITAO contracts identify IFMIS-related costs, but the USAID contracts do not differentiate 

IFMIS related costs from others. According to the Corps of Engineers, which is responsible for 

maintaining the financial data for ITAO contracts, ITAO had spent $4,060,723 for IFMIS-related 

modules as of October 2007. When asked for its IFMIS cost estimates, USAID provided 

BearingPoint’s estimates. According to BearingPoint, which is responsible for reporting its costs 

to USAID, $22,093,386 million of the EG-I and EG-II contract costs relate to IFMIS. Based on 

the ITAO cost data and the BearingPoint estimate, IFMIS-related costs therefore appear to be 

about $26 million. 

The cost-plus-fixed-fee level of effort type contracts USAID utilized for the IFMIS project are 

more suitable to research or a preliminary exploration study than for a system development and 

implementation effort. According to USAID, it made the right choice in choosing these type 

contracts because they provided maximum flexibility needed for the Iraqi environment.

ITAO Expenditures Related to IFMIS Can Be Calculated 

ITAO had two contracts that supported IFMIS. The first contained three components: the 

integration of a budget-preparation system module into IFMIS, intergovernmental fiscal policy 

reforms, and extension of IFMIS to the provinces. The second contract involved one task; to 

integrate a procurement module into IFMIS. The following table shows the funds allocated to 

and expended for the two contracts: 

Table 1: Funds Allocated and Expended for ITAO Contracts, as of October 2007 

CONTRACT/COMPONENT FUNDS ALLOCATED FUNDS EXPENDED

Contract W91GXQ-06-C-0009 

 IFMIS budget module $2,359,174 $1,996,805

 Fiscal reforms 1,279,200 0

 Extension of IFMIS 890,200 0

 Subtotals 4,528,574 1,996,805

Contract W91GXQ-06-C-0010 4,196,884 2,063,918

Totals $8,725,458 $4,060,723

Source: Corps of Engineers

 

9

 We reported a cost estimate of $38 million in our October 2007 interim report on IFMIS. On the basis of morecurrent cost data, we have revised that estimate to $26 million. 

4
USAID Contracts Did Not Require IFMIS Costs To Be Identified 

According to the USAID EG-I contract with BearingPoint, the purpose of the project was to 

“provide economic rehabilitation and reform for Iraq to stimulate the country’s international 

trade engagement, employment and broad-based prosperity.” Fulfillment of the contract would: 

“facilitate a rapid and responsible economic integration of Iraq with its regional 

and international partners in order to create sustainable job generation, adopt 

international standards of production, harmonize economic policy, reinforce 

traditional trade linkages and develop new trade partnerships, and will develop 

and implement a roadmap for managing the economic and technical work to 

assure the food policy safety net is available for those who may be unable to 

function on the private market after cessation of the UN food program.” 

The EG-I project had five components: 

1. Economic Governance: Policy, Regulatory, and Legal Climate for Growth 

2. Microeconomic Foundations for Growth: Competitiveness Initiative 

3. Privatization: Assessment and Support 

4. Credit Activities: Lending to Micro Enterprises, Small- and Medium-Size Businesses 

5. Food for Oil: Develop and implement a road map to assure an adequate social safety net 

after phase-out of the United Nations Food for Oil program. 

Each of the components involved multiple tasks and benchmarks. All IFMIS-related tasks are 

included in the Economic Governance component. Because EG-I was a cost-plus-fixed-fee level 

of effort contract, BearingPoint was required to report its costs to USAID. However, the contract 

required that BearingPoint report all of them as a single contract-line item and not by 

components, tasks, or other work-breakdown structure. Therefore, all costs for work performed 

under the five components listed above were reported as one line item. 

According to the EG-II contract, the work would “establish a legal and institutional framework 

that enables Iraqis to pursue their economic and societal objectives—individually and 

collectively.” The contract also contained multiple components and tasks, including those 

specifically related to IFMIS development and implementation. The work was organized under 

the following six components: 

1. Tax, Fiscal, and Customs Reform 

2. Monetary Policy Through Building the Capacity of the Central Bank of Iraq 

3. Development of the Banking Sector 

4. Commercial Law and Institutional Reform 

5. Capacity Building of the Iraqi Electricity and Communications Industries 

6. Social Services 

5
All IFMIS-related tasks are included in the first component—Tax, Fiscal, and Customs Reform. 

For example, one of those tasks was to oversee the completion of the roll-out of IFMIS within 

the Ministry of Finance, 18 Governorates, and 28 related Ministries. 

The EG-II contract is also a cost-plus-fixed-fee level of effort contract. The cost-reporting 

requirements for EG-II were the same as for EG-I; all costs for the six components were to be 

reported as a single contract-line item and not by a more finite work-breakdown structure, such 

as IFMIS. Consequently, the official accounting records do not provide a basis for calculating 

IFMIS costs. 

We asked USAID for its IFMIS cost estimate and were provided with BearingPoint estimates as 

of May 2007. They specified costs of $2,361,679 million under EG-I and $19,731,707 under 

EG-II, for a total of $22,093,386 million related to IFMIS. The largest cost item was for 

security, which totaled $11,641,281, or 53% of total costs. BearingPoint also estimated a total of 

16,256 person-days had been used for IFMIS under the EG-I and EG-II contracts, as follows: 

• 2,251 person-days for the period July 2003 to September 2004 for EG-I 

• 14,005 person-days for the period September 2004 through September 2007 for EG-II 

USAID’s Contract Type Was Not Well Suited to a System Development Project 

Both USAID EG-I and EG-II contracts were cost-plus-fixed-fee level of effort contracts, a type 

that provides less cost risk to the contractor. Under it, according to the Federal Acquisition 

Regulation, Subpart 15.404-4, the contractor assumes the least cost risk in that the contractor is 

reimbursed costs determined to be allocable and allowable, plus the fixed fee. According to the 

Federal Acquisition Regulation, Subpart 16.306, the cost-plus-fixed-fee contract also gives the 

contractor only a minimum incentive to control costs and is more suitable for “the performance 

of research or preliminary exploration or study, and [where] the level of effort required is 

unknown.” IFMIS, in our view, was more than a research or preliminary study effort; it was a 

system development and implementation effort. 

According to USAID, it made the right choice in choosing cost-plus-fixed-fee level of effort 

contracts for EG-I and EG-II because these contracts provided the maximum flexibility needed 

for the Iraqi environment. USAID said it required a type of contract that would be able to adapt 

and change to evolving needs in a dynamic environment. Both EG-I and II were written well 

before they would be implemented. (Work on developing the EG-I contract began prior to the 

fall of Baghdad.) According to USAID, both contracts allowed for USAID to support the CPA 

and later the U.S. Embassy by providing the ability to meet new needs and adjust to changes in 

priorities. 

6
Reconstruction Policy Decisions and Guidance, Rather 

Than User Needs, Drove IFMIS Development 

According to IMF and World Bank studies, a sound information-technology project design is 

predicated on the identification of user requirements. However, the GoI requirements were 

never identified. According to USAID, that resulted from a policy decision made initially by the 

CPA and maintained by other U.S. government organizations. Without Iraqi user requirements 

to guide the system development, IFMIS development appears to have been driven by U.S. 

reconstruction policy decisions, CPA guidance, and BearingPoint work plans. 

The USAID EG-I and EG-II cost-plus-fixed-fee level of effort contracts did not provide clear 

objectives, tasks, and time-frames for IFMIS development. According to USAID, the 

BearingPoint work plans it approved, rather than the EG contracts, delineated requirements and 

deliverables. We found the work plans also lacking content and clear direction, specific 

deliverables, and set timelines. Given their absence, it would be difficult for USAID to measure 

BearingPoint’s progress on the system. We also found that USAID personnel in Baghdad lacked 

specific knowledge about contract deliverables and their status. All of our questions in this 

regard were directed to BearingPoint. 

Despite these issues and a difficult security environment, BearingPoint had developed and 

implemented a system that captured most of the GoI budget, allowed vouchers to be processed, 

payments to be made, and reports to be generated. However, we identified a number of issues 

adversely impacting IFMIS operations. For example, significant efforts would be required 

before IFMIS could be relied upon to generate reports that address Iraqi needs. Also, we found 

that other ministries, such as Defense and Interior, had developed their own financial 

management systems that could not transfer data to IFMIS. As a result, ministry personnel had 

to manually input data through spending units at the ministries. According to USAID officials, 

the data transfer problem can be fixed through a long term process of system improvements and 

those improvements would be a GoI responsibility. 

User Needs Were Not Considered 

According to IMF and World Bank studies,10 financial-management information system projects 

in developing countries achieve limited success because they are not designed to meet either 

users’ needs or functional requirements. The functional-requirements documents should serve as 

the blueprint for the system development and, if they are wrong, it is difficult to rectify the 

situation later. In 2003, a team from the IMF advised the CPA and USAID against implementing 

an automated financial-management system before a formal requirements analysis was 

conducted. The CPA and USAID nonetheless proceeded with IFMIS without undertaking the 

necessary analysis. That, according to USAID, was done at the initial direction of the CPA and 

the subsequent direction of the Iraq Reconstruction Management Office and the Office of the 

Treasury attaché. 

 

10 The IMF and World Bank provide technical assistance to help countries effectively mange their economic policies 

and financial affairs. 

7
BearingPoint prepared a conceptual and functional design in 2005. However, that document was 

reviewed by IMF and World Bank representatives, as well as others, and the consensus was that 

it lacked three necessary components: adequate information about the existing Iraqi business 

processes, the manner in which IFMIS would support these processes, and the nature and extent 

of any changes to the processes that may be required for effective and efficient operation of the 

system. 

Broad Guidance Appears to Have Driven the IFMIS Development 

Approach 

According to USAID, the end goal for IFMIS remained “surprisingly consistent” throughout the 

design and implementation effort. That goal was an automated, nation-wide financialmanagement information system. USAID stated that, in trying to achieve such a system, it 

operated in “an environment with a wide array of U.S. and international donors simultaneously 

conducting reform efforts and in which USAID regularly adapted system requirements to support 

external policy decisions.” USAID also stated that a CPA task order (Task 8—Financial 

Management Information System)11 and USAID-approved BearingPoint work plans, rather than 

the EG-I and EG-II contracts, delineated requirements and deliverables. This ensured that 

USAID activities would be highly adaptive and responsive to changing needs on the ground. 

Moreover, USAID stated the EG-I contract provided for that needed flexibility, as follows: 

“The selection of tasks and indicative benchmarks to be achieved in the first year 

of the contract is subject to the policy approval process of the US government 

regarding this activity, a process to be established by USAID to assure that 

economic governance activities carried out by the Contractor support the policy 

objectives of the United States government.” 

USAID stated that the initial scope of work for IFMIS was not articulated in the EG-I contract 

but in CPA Task 8, which was developed by USAID and approved by the CPA in August 2003. 

The scope of work shown below describes an overall goal for the system and two phases of 

development. 

• Procure and implement a comprehensive financial management-information system to 

enable the Ministry of Finance to effectively execute the national budget. The 

functionalities of the system being proposed will satisfy the IMF recommendations for 

rebuilding public-expenditure management in Iraq. 

• The immediate objective is to implement the core foundation components of the system, 

which includes expenditures and cash management, in the Ministry of Finance, line 

agencies, and regional government entities. 

• Once that is accomplished, the other applications necessary for managing assets and 

public revenue receipts, regulating public procurement, managing government debt, and 

financial reporting will be developed and implemented to complete the comprehensive 

system. 

 

11 CPA Task 8 was one of 12 CPA-approved tasks that defined the scope of work for the EG-I contract. 

8
CPA Task 8 also identified tasks and deliverables for IFMIS. However, the tasks are very broad 

and not relatable to the two development phases articulated in the scope of work above. For 

example, Task 8 required the following: 

• Identify, procure, and install all hardware, software and/or communication infrastructure 

necessary for IFMIS to become fully operational. Ensure that all system documentation 

and long-term, sustainable maintenance contracts are in place. 

• Install IFMIS, and make it operational, by January 1, 2004. 

The initial BearingPoint work plan, dated October 27, 2003, provided no additional specifics in 

terms of tasks or deliverables. The document projects that the IFMIS project would be planned 

and managed, and the core accounting system for expenditures and basic cash management at the 

Ministry of Finance implemented, during the period September 15, 2003 through April 3, 2004. 

According to USAID, the second BearingPoint work plan, dated January 28, 2004, identified 

three phases of implementation: 

• Phase I (January 1, 2004—March 7, 2004) entails initial design work and installation of 

130 computers in the Ministry of Finance. 

• Phase II (March 8, 2004—mid-July 2004) includes the rollout of the system to all of that 

ministry’s offices in Baghdad. More than with Phase I, Phase II relied on a number of 

externalities, including completion of the communications network in Baghdad and 

computer centers in the Ministry of Finance and other ministries, and delivery of all 

necessary equipment as well as continued support from the Ministry of Finance and a 

permissive security environment. 

• Phase III (mid-July 2004—end of 2004) is the national rollout of the IFMIS throughout 

all Treasury Governorates in Iraq. 

The work in Phases I and II was to be accomplished during the performance period of the EG-I 

contract, which was in force through July 17, 2004. However, as USAID stated, that work did 

not correspond to the tasks described in the EG-I contract but to the BearingPoint work plans 

developed later. The contract specified that, during the period March 2004—July 2004, “A fully 

automated budget, reporting, and tracking system (including the installation and application of 

appropriate budget planning and execution software) is implemented in at least 50% of line 

agencies and one-third of all provinces and localities (municipalities and districts).” 

In July 2004, the EG-I contract was extended for 2 1⁄2 months to continue such tasks as 

implementing and testing IFMIS in Ministry of Finance treasury operations and beginning to 

implement the system in other key ministries. USAID stated that the extension maintained 

several technical activities, including support to IFMIS. 

Although USAID said the EG-I contract requirements were met satisfactorily, USAID officials 

and BearingPoint advisors nonetheless identified a number of organizational, leadership, and 

security-related challenges. Organizationally, the Ministry of Finance lacked the technical, 

professional, and managerial capacity, while staff members worked with a low level of computer 

literacy—problems that required significant training and technical assistance to overcome. 

9
Progress toward goals significantly depended on ministry leadership, both in implementing 

supporting policy and in providing such basic tools as reliable electricity and as Internet 

connections. In addition, the EG-I project operated at a time of deteriorating security, which 

increasingly limited access to the Ministry of Finance. Moreover, according to USAID, IFMIS 

components of the EG-I contract faced competing priorities. For example, the CPA requested 

more money for capital expenditures, drawing resources away from other components. 

The EG-II contract, awarded in September 2004, was for overseeing completion of Phase III—

the national rollout of IFMIS in all Treasury Governorates in Iraq. As such, the contract required 

BearingPoint to perform such tasks as overseeing the entire rollout within the Ministry of 

Finance, the 18 Governorates, and 28 related ministries; and assuring a completed system 

installation within the first year. According to USAID, it approved on October 25, 2004, the EGII initial work plan, covering the period between November 2004 and the following January. 

That work included completing the implementation of IFMIS within the ministry, the 

Governorates, and the related ministries. Implementation included all hardware, software, and 

networking requirements, all required training, and development of financial reports. 

According to USAID, Phase III had two sub-phases. The first had as its goal full activation of 56 

spending units. USAID stated this was completed by August 15, 2005, and covered 85% of the 

Iraqi budget. The second sub phase, which was underway by September 1, 2005, had two 

components: 

• Installation of 65 spending units—40 in Baghdad and 25 outside of Baghdad. (The total 

was increased to 81 by April 2006.) These sites represented 10% of the Iraqi budget. 

• Installation of 61 additional spending units. According to USAID, the Ministry of 

Finance, as a sign of commitment, had agreed to roll IFMIS out to these final 61 spending 

units. (The number was later reduced to 45 by April 2006.) 

According to USAID, contract requirements were met. “Key components” were completed prior 

to late May of this year, and IFMIS was fully functional. A total of 112 spending units were 

connected to the system and capable of entering data. Deteriorating security conditions slowed 

connection of the less-central, relatively small budget sites. They generally lie outside of 

Baghdad, and have limited access to electricity and the Internet. 

We found it exceedingly difficult to understand the various deliverables and their time frames in 

the USAID contracts and approved work plans. Our attempts to understand specific objectives 

and time frames by means of discussions with USAID’s Baghdad staff proved equally difficult. 

Those staff members, we found, lacked sufficient knowledge about contract deliverables and 

their status. USAID personnel in Baghdad referred all of our questions about the IFMIS 

system’s status to BearingPoint. 

As discussed in SIGIR’s October 2007 interim report, and the next section, a number of issues 

adversely impacted IFMIS operations. For example, we found that other ministries, such as 

Defense and Interior, had developed financial management systems for their own needs but 

unable to transfer data to IFMIS. As a result, these ministry personnel had to manually input 

data through their own spending units. According to USAID officials, the data transfer problem 

10
can be fixed through a long term process of system improvements and those improvements 

would be a GoI responsibility. 

11
Operational Issues Impacting IFMIS 

A number of issues remained to be resolved before IFMIS could be relied upon to generate 

reports that address Iraqi needs. Our review identified IFMIS operational issues that impacted 

the system’s acceptance by GoI ministries. For example, we found that ministries had problems 

with spending units, the reports produced by the system, and data reliability. We also found that 

as alternatives to IFMIS, the Ministry of Finance continued to use legacy systems, and other 

ministries, such as Defense and Interior, had developed their own financial management systems. 

At the time we completed this audit USAID was preparing to undertake an independent 

assessment of GoI needs, and had initiated discussions with the Ministry of Finance to secure 

GoI commitment to IFMIS. These planned actions are consistent with our prior 

recommendations. 

IFMIS Operational Issues 

During our review, we learned of a number of problems that impacted the use of spending units. 

According to senior U.S. advisors to Iraqi ministries and Iraqi officials, the ministries had 

difficulty using their spending units because: 

• Electricity, which was required for unit operations and Internet connections, had limited 

and uncertain availability. 

• Internet transmission via satellite—required to transmit ministry data to the Ministry of 

Finance—was periodically terminated because the GoI did not pay transmission fees. 

• Trained personnel to input financial data were in short supply. Many ministry personnel, 

who were initially trained by BearingPoint to use spending units, had left the country due 

to the difficult working environment and persistent security risks. In March 2007, 

BearingPoint turned over to the Ministry of Finance responsibility for training individuals 

on the use of spending units; however, according to a senior advisor to the ministry, the 

latter did not have the capability to deliver such training. 

• Access to IFMIS was restricted to one or two people in other ministries, because the 

Ministry of Finance was slow to approve access rights to individuals there. This proved 

to be a problem because many people who were given access rights to the system had left 

the ministries and sometimes the country. 

• Spending units were not user friendly. Data had to be entered one record at a time, and 

some ministries were obligated to enter thousands of records. This process was 

burdensome and subject to data errors. 

The issues cited above contributed to data-accuracy problems and incomplete financial data, 

which in turn adversely impacted the usefulness of IFMIS. Another factor limiting the system’s 

utility was the ministries’ inability to obtain the types of financial reports they needed to manage. 

According to U.S. advisors and Iraqi officials, the reports received from the Ministry of Finance 

12
provided only aggregate information, and not the detailed breakdowns required to oversee a 

ministry’s operations. The ministries requested more detailed reports, but the Ministry of 

Finance did not provided them. According to USAID officials, they wanted to provide more 

detailed data and requested authority to do so but were denied that authority. 

As alternatives to IFMIS, some agencies implemented their own financial management systems 

or continued to use legacy systems or manual processes. We learned that the Ministries of 

Defense and Interior implemented their own Oracle-based systems to manage the Iraqi military 

and civilian police workforce located throughout the country. Both the Oracle-based systems 

and the legacy systems were incompatible with IFMIS and could not transfer financial data from 

one system to the other. As a result, ministry personnel had to enter data into IFMIS as well as 

into their own ministry’s systems, which contributed to frustrations, additional work, and data 

entry errors. According to USAID officials, the CPA specifically directed USAID and 

BearingPoint not to incorporate the Ministries of Defense and Interior into IFMIS because these 

ministries provide funding for defense related functions; their financial management systems 

were to be implemented as an initiative of the U.S. Department of Defense. 

We were told by U.S. Embassy officials that the Ministry of Finance continued to operate and 

use legacy systems in parallel with IFMIS and reverted to them when IFMIS was shut down. 

According to USAID and BearingPoint personnel, it is not unusual to operate legacy systems in 

parallel with new systems until the new systems are fully tested and proven to be operationally 

ready. 

Status of Actions on Recommendations in SIGIR’s Interim Report 

USAID is taking or planning to take actions that are consistent with the recommendations in our 

interim report. In our October 2007 interim report, we recommended that (1) the U.S. Embassy 

establish a working group and draw on outside experts as necessary to evaluate several factors, 

including GoI financial-management system requirements and capabilities as well as how best to 

meet those requirements; (2) the Department of State make conditional future work and funding 

for such a system on securing GoI’s commitment to it and on the results of a GoI-sponsored 

independent assessment of financial management needs; and (3) the Department of State help the 

GoI determine interim solutions that will improve financial data management, especially in the 

provinces, until a new operational system is developed. 

With regard to evaluating GoI management-system requirements and capabilities, USAID is 

preparing to undertake an independent, third-party assessment. And according to USAID, with 

regard to securing the GoI’s commitment to IFMIS, USAID and U.S. Embassy officials met on 

November 10 with the Special Advisor to the Minister of Finance and three Directors General to 

discuss the future of IFMIS. Over the course of the conversation, the Special Advisor noted his 

commitment to the continuing development and implementation of IFMIS. On November 20, 

the USAID Mission Director sent a letter to the Special Advisor proposing a series of joint steps 

with the Ministry of Finance to ensure GoI support for and leadership in reaching that goal. The 

GoI has requested follow-up meetings. In addition, at the request of the Iraqi Ministry of 

Finance, a Memorandum of Understanding was signed in mid-January 2008 by the Minister of 

Finance and Acting Mission Director of USAID to restart the system. According to USAID, 

under the Memorandum of Understanding, the Minister of Finance makes a substantial 

13
commitment of effort and resources to the restart of the system with USAID assistance. A copy 

of the Memorandum is included with the USAID Management Comments. 

14
Conclusions and Lessons Learned 

Conclusions 

IFMIS had achieved limited functionalities before it was shut down in June 2007. Its costs at 

that time were estimated at $26 million. Lack of support for the system within the GoI and 

security concerns were the key contributing factors to the shut-down. In November 2007, 

USAID began initiatives to ensure GoI support for the system in the future. In mid-January 

2008, the Iraqi Minister of Finance and Acting Mission Director at USAID signed a 

Memorandum of Understanding to restart the system. The initiatives now underway are in line 

with our prior recommendations about securing GoI’s commitment and about ensuring USAID’s 

effort to undertake an independent, third-party assessment of GoI management-system 

requirements and capabilities. 

Although deteriorating security conditions and competing demands no doubt adversely impacted 

IFMIS development, there was also a lack of clear direction based on user requirements. The 

USAID contracts and BearingPoint work plans did not provide that direction. Information was 

not available to clearly assess progress on the system in relation to available benchmarks, 

making it difficult for USAID to asses BearingPoint’s performance. 

Cost is an important factor in managing any system’s development, and the USAID contracts did 

not provide for the identification of IFMIS costs. We believe this was a weakness in the contract 

requirements. We also believe the use of the cost-plus-fixed-fee level of effort contracts was not 

the best contract choice for a system development and implementation effort because it placed 

greater cost risk on the U.S. government. 

We recognize that Iraq was and still is a complex and difficult environment in which to operate 

and that policy factors drove many of the early decisions on how to improve the GoI’s financial 

management information. However, in retrospect, we believe that valuable lessons—with 

broader applicability—can be gleaned from the course followed by the IFMIS development 

project. 

Lessons Learned 

• User commitment and requirements identification are critical to the success of any 

management-information system development and implementation effort and should be 

prerequisites for any system development. 

• Clear objectives and a schedule to achieve them are needed to effectively manage the 

work of contractors involved in developing systems and should be clearly articulated in 

contract documents. 

• Management needs accurate and complete expenditure information to effectively manage 

project or program costs, and contracts should be written to require that information. 

15
Recommendation 

Our interim report provided recommendations and USAID is taking or planning actions that are 

consistent with those recommendations. Consequently, we make no new ones at this time, but 

will continue to assess the actions USAID is taking. We encourage USAID to continue to devote 

management attention to completing these actions to gain the greatest possible return for the 

substantial investment the United States has made in IFMIS. We will follow-up on USAID’s 

progress later this year. 

Management Comments and Audit Response 

USAID strongly disagreed with some of our positions and some of the information in the report. 

It states we inappropriately describe IFMIS as achieving “limited functionalities” and that the 

system achieved a “high degree of functionality” prior to being shut down in 2007. It also states 

that a fully operational IFMIS will require continued support and, more importantly, GoI efforts 

to tailor the system to meet their needs in order to reach its full potential. Further, it takes issue 

with our position that U.S. funding for IFMIS cannot be fully calculated stating that USAID has 

provided a clear total expenditure for IFMIS. Moreover, USAID states that it is greatly 

concerned with our position that the cost-plus-fixed-fee type contract for IFMIS was a less than 

optimal contract mechanism and that this type contract, “suitable for research, or preliminary 

exploration or study and [where] the level of effort is unknown,” was the exact mechanism 

required. USAID refers to information in our draft report that was from a March 2007 IMF 

report. We have deleted that information because the IMF report was for Iraqi use only. 

We had discussed these matters with USAID officials during the course of our audit and had 

incorporated their views, where appropriate. We believe our positions are sound and the 

information in our report accurate. In summary, with regards to USAID’s specific concerns 

mentioned above, we offer the following information. 

• The description of IFMIS as “limited” is based on our analysis and the analysis of others. 

• USAID states that a fully operational IFMIS will require GoI efforts to tailor the system 

to meet their needs. We agree, but as stated in this report, those needs should have been 

incorporated in the project design and not after 3 years of development effort. 

• USAID did provide cost information on IFMIS, however, as we state in this report, the 

information was BearingPoint’s estimates and not from the agency’s official accounting 

records. Moreover, the BearingPoint estimates state the EG-I estimates “are illustrative 

only—Iraq I project did not track these costs separately.” 

• As we state in this report, the cost-plus-fixed-fee contract gives the contractor only a 

minimum incentive to control costs. Moreover, because it is more suitable to a research 

or preliminary exploration or study, in our view, it was not well suited to a specific 

system development and implementation effort. 

USAID provided recent information on the GoI’s support for IFMIS. We have incorporated that 

information in this report. 

16
Appendix A—Scope and Methodology 

We performed our initial work in the International Zone in Baghdad from March through 

September 2007 and our follow-up work in the Washington, D.C., area from October through 

December 2007, all in accordance with generally accepted government auditing standards. 

To determine the U.S. cost and funding for the Iraq Financial Management Information System 

(IFMIS) we reviewed contract documents provided by the U.S. Agency for International 

Development (USAID) and the Iraq Transition Assistance Office (ITAO). We requested cost 

information from USAID and were provided BearingPoint, Inc. estimates as of May 2007. We 

did not validate the BearingPoint cost estimates. We also requested cost information from ITAO 

and were referred to the U.S. Corps of Engineers, which is responsible for maintaining the 

financial data for ITAO contracts. We received financial data as of October 2007 on the ITAO 

contracts from the U.S. Army Corps of Engineers Financial Management System. We did not 

validate the data.12

To determine the extent to which IFMIS development and implementation objectives and 

schedule were achieved, we reviewed and analyzed contract files, USAID memorandums and 

correspondence, BearingPoint monthly performance reports, Coalition Provisional Authority task 

orders, and International Monetary Fund (IMF) reports. Our attempts to understand specific 

objectives and time frames by means of discussions with USAID’s Baghdad staff proved 

difficult because the staff members lacked detailed knowledge about contract deliverables and 

their status. USAID personnel in Baghdad referred all of our questions about the IFMIS 

system’s status to BearingPoint. We also developed detailed questions for USAID concerning 

the contract objectives, deliverables, and time frames and were provided answers and documents 

in response to those questions. 

To determine operational issues that impacted the success and acceptability of IFMIS, we 

reviewed IMF reports and memorandums and correspondence from U.S. advisors to Iraqi 

ministries and Iraqi officials. We held discussions with some of these individuals. We attended 

weekly meetings of the IFMIS steering committee, chaired by the Department of State Treasury 

attaché. 

To determine the status of USAID’s response to the recommendations in our October 2007 

interim report, we requested and received that information from USAID. 

 

12 For more information on the reliability of data drawn from the U.S. Corps of Engineers Financial Management 

System, see GAO report 02-589, “Corps of Engineers Making Improvements but Weaknesses Continue,” June, 

2002. 

17
Appendix B—Acronyms 

CPA Coalition Provisional Authority 

EG Economic Governance 

GoI Government of Iraq 

IFMIS Iraqi Financial Management Information System 

IMF International Monetary Fund 

ITAO Iraq Transition Assistance Office 

USAID U.S. Agency for International Development 

18
Appendix C—Audit Team Members 

This report was prepared and the review was conducted under the direction of David R. Warren, 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction. The staff members who contributed to this report include: 

Ziad Buhaissi 

Robert Pelletier 

Diane Recio 

Roger M. Williams 

19
Management Comments 

USAID 

20
21
22
23
24
25
26
27
28
29
30
31
32
33
SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, 

and operations in Iraq, the Special Inspector General 

for Iraq Reconstruction provides independent and 

objective: 

• oversight and review through comprehensive 

audits, inspections, and investigations 

• advice and recommendations on policies to 

promote economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention 

and detection of fraud, waste, and abuse 

• information and analysis to the Secretary of 

State, the Secretary of Defense, the Congress, 

and the American people through Quarterly 

Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go 

to SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, 

and Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Kristine R. Belisle 

Director for Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

Email: PublicAffairs@sigir.mil 

34