U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1

68–009

" ! COMMITTEE PRINT 106TH CONGRESS

2d Session

S. PRT.

2000

106–64

INVESTIGATIVE REPORT

OF

SENATOR FRED THOMPSON

Chairman of the

COMMITTEE ON GOVERNMENTAL AFFAIRS

UNITED STATES SENATE

regarding the

FEDERAL AGENCY COMPLIANCE WITH THE

CLINGER-COHEN ACT

OCTOBER 2000

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3

C O N T E N T S

Page

Executive Summary ................................................................................................. 1

Introduction and Scope of Investigation ................................................................ 4

Findings .................................................................................................................... 5

Recommendations .................................................................................................... 11

Appendix A: Letter to departments and agencies from Senate Governmental

Affairs Committee Chairman Fred Thompson and Ranking Minority Member Joseph Lieberman regarding compliance with the Clinger-Cohen Act

of 1996 ................................................................................................................... 13

Appendix B: GAO Audits and Reports on Federal Agency Information Technology Management Since Enactment of the CCA ............................................ 19

Appendix C: Individual Agency Responses to the Thompson/Lieberman letter:

Department of Agriculture (USDA) .................................................................... 21

Department of Defense (DOD) ............................................................................ 24

Department of Education .................................................................................... 27

Department of Energy (DOE) ............................................................................. 31

Department of Health and Human Services (HHS) .......................................... 34

Department of Housing and Urban Development (HUD) ................................. 39

Department of the Interior .................................................................................. 44

Department of Justice (DOJ) .............................................................................. 49

Department of Labor (DOL) ................................................................................ 54

Department of State ............................................................................................ 62

Department of Transportation (DOT) ................................................................ 71

Department of the Treasury ................................................................................ 75

Department of Veterans Affairs (VA) ................................................................. 78

Agency for International Development (USAID) ............................................... 81

Environmental Protection Agency (EPA) ........................................................... 83

Federal Emergency Management Agency (FEMA) ........................................... 87

General Services Administration (GSA) ............................................................. 90

National Aeronautics and Space Administration (NASA) ................................ 95

National Science Foundation (NSF) ................................................................... 99

Nuclear Regulatory Commission (NRC) ............................................................. 104

Office of Personnel Management (OPM) ............................................................ 109

Small Business Administration (SBA) ............................................................... 111

Social Security Administration (SSA) ................................................................ 112

(III)

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1Public Law 104–106 (Division D & Division E).

INVESTIGATIVE REPORT ON

FEDERAL AGENCY COMPLIANCE WITH THE

CLINGER-COHEN ACT

EXECUTIVE SUMMARY

Senator Fred Thompson (R–TN), Chairman of the Senate Governmental Affairs Committee, recently completed a comprehensive

investigation of agencies and departments subject to the ClingerCohen Act of 1996 (CCA).1 The review was initiated as part of the

Committee’s oversight agenda and is the result of a series of questions posed to agencies to ascertain the status of their efforts to

comply with the 1996 law.

The rapid pace of technological change and innovation has offered unprecedented opportunities for the Federal Government to

use information technology (IT) to improve operational performance, reduce costs, and enhance service responsiveness to the public. Because of the Federal Government’s increased reliance on information technology, in 1994 Congress increased its attention and

oversight on agencies’ acquisition, management and use of information technology. Congress’ investigation of agency information technology use raised a range of thorny issues surrounding managing

and integrating complex information management processes; computer hardware and software; telecommunications networks; and,

most importantly, aligning information technology with business

needs. Consequently, Congress found that Federal agencies must

have effective leadership and must enforce management controls

over the government’s $38 billion in annual spending on information management and technology.

In response to concerns about how the Federal Government was

managing and acquiring information technology, Congress passed

the CCA in 1996. The CCA mandates, among other things, that executive agencies design and implement capital planning and investment controls, implement specified information technology-related

actions to enhance performance and results-based management,

and establish Chief Information Officers (CIOs) with certain defined duties and responsibilities. In addition, the CCA requires

agencies to identify information technology acquisition programs

that have significantly deviated from cost, performance, or schedule

goals.

The Senate Committee on Governmental Affairs played a large

role in the passage of the CCA and maintains a high level of interest in compliance with its provisions. As a part of the Committee’s

oversight agenda, Chairman Thompson, along with the CommitVerDate 11-MAY-2000 15:41 Dec 07, 2000 Jkt 000000 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 68009.TXT SAFFAIRS PsN: SAFFAIRS
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tee’s Ranking Minority Member, Senator Joseph I. Lieberman (D–

CT), developed a series of questions to better understand the status

of CCA compliance in the agencies and departments subject to its

mandates.

MAJOR FINDINGS

Information Technology Management: Chief Information Officer

Turnover High

The CCA established CIOs in 24 agencies in order to ensure that

sound IT investment decisions are made and that cost-effective return-on-investment—focus on results and contributions to mission

effectiveness—is achieved. The CCA vested the CIO with specific

responsibilities to help him or her accomplish their goals.

While all of the 24 agencies have CIOs, the Federal Government

has been experiencing relatively high turnover. While this should

be expected in CIO positions because similar turnover rates are not

uncommon in the private sector, it presents a management challenge to agencies that are trying to maintain sustained focus in

and momentum for ongoing IT projects. In addition, various levels

of CIOs within an agency do not always coordinate with one central

CIO thus causing reporting and policy inconsistencies within a single agency.

Agencies Aren’t Complying with Capital Investment and Planning

and Performance Measures

One of the most important aspects of the CCA is the requirement

that agencies make sound information technology investment decisions based upon the business needs of an executive agency or department. Under the CCA, each agency is required to design and

develop a process for assessing and managing the risk of its information technology purchases in order to ensure effective program

performance results.

However, the findings reveal that 17 of the 24 agencies covered

by the CCA are not implementing fully the CCA’s IT capital planning and investment control requirements. For example, the Small

Business Administration responded that because of its work on the

Year 2000 computer problem, it did not have time to develop formal information technology capital planning procedures.

And while 21 agencies reported that their capital investment and

planning work processes were being improved or reengineered, half

of the agencies reported requiring process reengineering or missionrelated processes before making significant investments in IT in

support of those missions.

In order to make sound business decisions, agencies need reliable

information upon which to base those decisions. However, the quality of the data for the assessments of major IT investments needed

for decisionmaking and for measuring progress is questionable at

most agencies. For example, the Department of Agriculture noted

that, while it has improved the quality of the data used for decisionmaking, it is unclear whether the data it uses to measure program performance is accurate, reliable, or even current.

While it is important to have clear and accurate data before

making investment decisions, it is equally important for agencies

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2Public Law 103–62.

to link IT performance to agency program performance. In fact,

agencies are required to incorporate these performance goals in annual agency reports required under the Government Performance

and Results Act (GPRA).2 Unfortunately, the findings revealed that

most agency links to these reports were often too broad to provide

sufficiently robust measures of the impact information technology

makes on an agency’s overall performance. Additionally, Chairman

Thompson found that 16 agencies neither developed nor submitted

IT management reports that included accomplishments, progress,

and identification of areas requiring attention. And, finally, one

fourth of agencies reported significant deviations of projects from

cost or schedule goals. Because agencies are not using sound business procedures before investing in information technology, they

are unable to improve program performance and meet their mission goals.

Agencies Aren’t Applying Modular Contracting For Major IT Investments

In 1994, Congress found that Federal regulations governing information technology acquisitions were outdated, focused on paperwork and process rather than results, and prevented the government from taking timely advantage of rapid advances taking place

in the competitive and fast changing global information technology

marketplace. The CCA authorizes agencies to purchase IT on an incremental or modular basis to prevent the mismanagement of IT

spending. This authority still hasn’t been applied consistently in

major IT investments governmentwide, In fact, the findings revealed that eight agencies reported still being in the process of implementing modular contracting.

RECOMMENDATIONS

The report includes a dozen recommendations for executive departments and agencies to implement in order to fully comply with

the CCA. The recommendations provide that departments and

agencies should:

• review the mechanisms in place for assuring that they are

fully implementing the CCA through their policies, procedures,

and practices;

• articulate the roles, reporting relationships and boundaries of

authority among all CIOs within an agency in ways that enhance the effective implementation of the CCA;

• provide the appropriate authority to the CIO to ensure the

CIO’s control over IT capital planning and investment processes;

• increase quality control of their capital planning and investment control practices, including ensuring that any cost/benefit

data used in investment decisionmaking is accurate and complete;

4

3 By letter dated April 6, 2000 from Chairman Thompson and Ranking Minority Member

Lieberman (see Appendix A). 4See Appendix B.

• provide clear procedures on how CIOs and program managers

communicate to senior management the status and progress of

major IT projects;

• develop and incorporate the use of decision milestones in IT

project management;

• develop an effective means of identifying IT projects that deviate significantly from cost, schedule and performance expectations;

• increase project management and capital planning skills within their IT workforce;

• provide better data on how IT investments will benefit Federal

programs;

• develop IT management plans that include accomplishments,

progress, and the identification of areas requiring attention;

• clarify the requirements for process reengineering in their

overall capital planning and investment control procedures;

and

• increase their use of modular contracting for building and acquiring information systems.

INTRODUCTION AND SCOPE OF INVESTIGATION

At the beginning of the second session of the 106th Congress,

Senate Governmental Affairs Committee Chairman Fred Thompson

began an investigation of how Federal agencies were complying

with the requirements of the Clinger-Cohen Act. This review was

undertaken as part of the Committee’s oversight of Federal agency

information technology procurement and management.

As part of the investigation, Chairman Thompson reviewed responses to certain questions posed to the agencies 3 as well as 31

reports on information technology management conducted by the

General Accounting Office (GAO) since enactment of the CCA.4

BACKGROUND

During the 104th Congress, the Senate Governmental Affairs

Committee reviewed the way information was being managed by

Federal agencies. Realizing that information technology, particularly network computers, were changing the way Federal managers

compiled, distributed, and maintained information, as well managed Federal programs, the Committee developed legislation (which

became the CCA) to remedy some of the central problems underlying the way the government does business. For example, the

Committee’s Subcommittee on Oversight of Government Management and the District of Columbia found that the government was

falling further behind the private sector in its ability to successfully

use information technology. According to a 1995 statement by then

Senator William Cohen:

5

5Statement of Senator William Cohen, Vol. 141, No. 101 Congressional Record, p. S8686, June

20, 1995. 6Section 5125 of the CCA (40 U.S.C. 1425(b)).

7Turnover should be expected in CIO positions, and these rates of turnover are not uncommon

in the private sector. The challenge it presents is one of maintaining sustained focus and momentum to ongoing IT priority projects as well as to strategic IT direction.

‘‘The Federal Government rarely if ever examines how it

does business before it automates. I recently held hearings

which examined how the Pentagon could save more than

$4 billion over 5 years simply by changing the way it processed travel vouchers. Automating the current voucher

processing system will neither achieve the projected savings nor the efficiencies that are accomplished through reengineering. Second, the Federal Government has wasted

billions of dollars by maintaining and updating so-called

legacy or antiquated computers from the 1960’s and 1970’s

which are ill-suited for the government’s needs and by today’s standards will never be efficient or reliable.’’5

These findings and others led to the development of legislation

intended to make it easier for the government to buy and manage

information technology. Most importantly, the CCA was designed

to make sure that, before the government invests in technology,

agencies will have carefully planned and justified their expenditures.

Since enactment of the CCA, GAO has conducted a number of

audits at specific agencies to review the status of compliance with

various provisions, including progress in implementing information

technology investment controls, information security, and the

status and role of the agency CIOs. Approximately 31 reports detailing agency strengths and weaknesses have been completed.

However, this report details, for the first time, a governmentwide

outline of agency compliance efforts with the CCA.

FINDINGS

STRONG EXECUTIVE LEADERSHIP: HOW TO RETAIN FEDERAL CHIEF

INFORMATION OFFICERS 6

Background: Obtaining and retaining qualified personnel to manage Federal information technology systems is a challenge for the

Federal Government. A number of senior government officials have

recommended changing the current salary structure and providing

agencies with the authority to provide greater flexibility to workers, especially information technology workers, in order to maintain

highly skilled employees and to be able to lure workers from the

private sector to serve in the public sector.

Finding 1: CIO positions in the Federal Government have been experiencing relatively high turnover.7

• Ten of the 24 major agencies/departments have had three or

four CIOs since enactment of the CCA in February 1996. One

department, Department of Education, has had five.

• The remaining 13 agencies and departments have had one or

two CIOs since February 1996.

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8The Department of Commerce is planning to have component agency CIOs (NOAA, PTO,

etc.) report to both their agency heads and to the department CIO. 9Section 5122 of the CCA (40 U.S.C. 1422).

• Since 1996, several departments and agencies have named

‘‘acting’’ CIOs, some for extended periods of time, due to

lengthy recruitment searches.

Finding 2: Roles, reporting relationships, and boundaries of authority among CIOs within large executive agencies and departments are not clearly established.

• Decentralized executive agencies/departments have several

component-level organizations that have designated CIOs. The

staff of the component-level organizations report to the component-level head. A majority of agencies reported not having direct reporting relationships to the agency-wide CIO.8 This reporting arrangement may reduce the agency-wide CIO’s ability

to institutionalize department-wide IT management practices

and technical standards.

• For example, the Department of Health and Human Services

(HHS) has 13 operating divisions that have designated CIOs.

According to HHS, four CIOs report to the head of the operating division (top level), four CIOs report to a top deputy

(second level), and five report to lower levels of management.

None of the CIOs have a direct reporting relationship to the

department-level CIO.

ACHIEVING BENEFITS FROM CAPITAL PLANNING AND INVESTMENT

CONTROL 9

Background: A strong and comprehensive IT capital planning

process is necessary to assure that agency IT expenditures receive

the executive-level oversight required for confidence that the agency head is executing his or her responsibility in IT investment

management as specified in the CCA. In addition, the IT capital

planning process provides the mechanism for selecting IT investments as part of the overall IT portfolio that support the agency

mission.

Finding 3: IT capital planning and investment control processes

have not been fully implemented governmentwide.

• Seventeen of the 24 agencies and departments have not established a complete and comprehensive IT capital planning and

investment control process (CPIC). The agencies’ and departments’ efforts range from needing improvements in their established processes to developing a process as specified by the

CCA.

• Seven agencies and departments—the Department of Defense,

the Environmental Protection Agency, the General Services

Administration, the National Aeronautics and Space Administration, the Nuclear Regulatory Commission, the National

Science Foundation, and the Department of Veterans Affairs—

reported that they had implemented a complete and comprehensive IT CPIC process, with only one—GSA—saying its

process needed to be refined and enhanced.

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10Memo (M–97–02) sent on October 25, 1996, by then OMB Director Franklin D. Raines to

heads of executive departments and agencies providing direction regarding investments in major

information technology systems defines ‘‘major information system’’ as a system ‘‘that requires

special management attention because of its importance to an agency mission; its high development operating, or maintenance costs; or its significant role in the administration of agency programs, finances, property, or other resources.’’

• For example, Agriculture reported that while it has established processes for three phases of capital planning—select,

control, and evaluate—efforts are under way to improve inconsistent component-level capital planning. Additionally,

Agriculture reported that its CIO office has engaged contract

support to help review the major investments to determine

where improvements need to be made.

• The Department of Interior reported that the Y2K problem

became that agency’s top priority and, as a result, the CCA

took a back seat. According to Interior, its CIO Office was

not organized until March 2000. However, Interior reported

that it has made significant progress in implementing its IT

CPIC process.

• SBA also reported Y2K as a problem which forced it to use

all of its IT resources to sustain routine operations and

maintenance. This effort, according to SBA, reduced its resources in other areas including the development of formal

IT capital planning procedures.

Finding 4: CIO authority and control in IT investment and capital

planning is limited.

• Not all agencies require their IT initiatives to come under

agency-wide CIO review or control unless the initiative fits

specific threshold requirements which may be based on financial or functional criteria. In addition, agency-wide CIOs often

only have direct responsibility for systems that cut across department units. Moreover, those system projects that are

under the CIO’s control may not line up with those classified

as ‘‘major’’ by OMB for those agencies that use this criteria.10

• Not all department initiatives are reviewed within a department-wide portfolio. Moreover, not all initiatives come under

CIO technical review at some level of the review process, although for most agencies, ‘‘major’’ IT initiatives do. This may

impact the effectiveness of the capital planning and investment

process as well as the impact of IT on the agency’s ability to

achieve its mission successfully and efficiently.

• Several agencies reported they are initiating efforts to coordinate component and agency-wide practices or to ensure the implementation of sound capital planning and investment processes within their component levels.

• In many cases, major department CIOs do not have control

over IT expenditures which do not meet the department-wide

threshold requirements for capital planning.

• Some agencies reported inconsistencies in their capital planning and investing processes across their organizational components.

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11Section 5123 of the CCA (40 U.S.C. 1423).

• For example, in the Department of Transportation, the two

largest organizations—the Federal Aviation Administration

and the U.S. Coast Guard—use their own agency capital

planning and investment control processes which DOT asserts account for about 90 percent of DOT’s total IT expenditures.

Finding 5: The quality of data for the assessments of major IT investments and initiatives for decisionmaking and for measuring

progress is questionable.

• A majority of the agencies and departments reported that the

quality of the data for making investment decisions and measuring progress needs improvement.

• Many of these agencies reported that they had begun using, or

plan to use, the Information Technology Investment Portfolio

System (ITIPS) to better manage their IT investments. Agencies reported that ITIPS helps them to collect and track investment data needed to effectively select and control IT investments.

• For example, Agriculture reported that it believes it has improved the quality of the data used for decisionmaking, but

more improvement is needed before there will be consistency

across the whole agency. As for the quality of the data for

measuring progress, Agriculture also reported that it is unsure of its accuracy, reliability, or currency, but will use a

contractor to aid in this evaluation effort.

• In another example, Interior reported that a major obstacle

to instilling confidence in cost data is that its Federal budgeting and accounting systems do not adequately support cost

accounting information related to IT costs.

MANAGING IT FOR OVERALL PERFORMANCE AND RESULTS 11

Background: Federal CIOs are responsible for managing IT investments to demonstrate cost effectiveness and efficiencies. In addition, IT investment strategies and spending should be tightly

aligned with expected improvements in mission performance and

results. The inability to track IT development and implementation

effectively can result in a failure to identify cost and schedule overruns and the failure of IT initiatives to meet performance expectations. Management plans and reporting are critical to providing

continuity in planning from year to year and in measuring the contribution of IT to mission performance across the agency.

Finding 6: Although most agencies reported the linking of IT system

performance to mission performance through annual GPIRA

plans and reports, these links were often too broad to provide

sufficiently robust measures of IT impact on overall strategic

performance.

• Processes necessary for effective tracking of IT development

and implementation are weak.

9

12Section 5127 of the CCA (40 U.S.C. 1427). 13Section 5123 of the CCA (40 U.S.C. 1423).

• Five agencies reported needing great improvement in the

quality of data necessary for tracking IT development and

implementation.

• Fourteen agencies reported the use of milestones in monitoring the progress of IT projects and four agencies reported

not using milestones.

Finding 7: Most agencies reported that they have not developed IT

management plans that include accomplishments, progress, and

identification of areas requiring attention.12

• Sixteen agencies and departments neither developed nor submitted IT management reports that included accomplishments,

progress, and identification of areas requiring attention.

• One fourth of the agencies reported significant deviations of

projects from cost or schedule goals laid out in agency strategic

information resource management plans.

• For example, Agriculture reported that, while its CIO had

not developed agency-wide IT management reports for its

agency head, the CIO plans to submit a separate IT report.

• In another example, the Department of Justice has produced

an Annual Accountability Report for the last 2 years in

which it describes the progress toward goals laid out in its

Strategic Plan. However, Justice agrees that an annual assessment of progress will be useful and intends to modify its

IT investment management program to conduct and document annual evaluations of agency progress.

USING IT TO IMPROVE WORK PROCESSES 13

Background: The CCA requires reengineering analyses of administrative and business processes either prior to or as part of major

systems investment decision-making. Investments made in updating systems without reconsidering the underlying processes risk

producing less than optimal returns on investment.

Finding 8: Fewer than half of the agencies reported requiring process reengineering of mission-related processes before making

significant IT investment in support of those missions.

• Twenty-one of the 24 agencies reported that work processes

are being improved or reengineered.

• Eighteen of the agencies claimed that some or all of its top 10

IT investments included work process improvement or reengineering.

• A few agencies reported that they are in the process of analyzing their mission or are just starting to perform business

process reengineering.

• Some departments and agencies have initiated major IT efforts

to overhaul services and citizen access. Agencies reporting such

10

14 Raines Rules refers to OMB Memo (M–97–02) sent on October 25, 1996, by then OMB Director Franklin D. Raines. 15Section 5202 of the CCA (see section 38 of the Office of Federal Procurement Policy Act

(41 U.S.C. 434)).

efforts include Agriculture, Education, EPA, Federal Emergency Management Agency, NRC, and the Department of

Treasury.

• For example, Agriculture reported that business process reengineering remains a cornerstone of its implementation of

the CCA and its IT capital planning process. Prior to design

and deployment of major IT investments throughout Agriculture in compliance with the CCA and with Raines

Rules,14 its CIO conducts business reviews as a necessary

management tool.

• However, fewer than half of the agencies reported requiring

process reengineering of mission-related processes before making significant IT investment in support of those missions.

• Although 21 agencies reported that work processes were

being improved or reengineered, only about half of these

noted that this was a required activity and few specifically

noted that these activities occurred prior to funding IT investments as required by the CCA.

• Many agencies provided weak support for the premise that

they are engaging in work process improvement or reengineering.

• Examples of IT investments often noted that work process

improvements resulted from IT investments rather than as a

precursor to funding the investment. For example, Justice, the

Department of Labor, GSA, and NRC provided IT investment

examples that appeared to show reengineered processes as a

result of the IT investment.

• Other IT investment examples cited by some agencies included

automation efforts with no mention of work process redesign.

• Several agencies pointed to their compliance with Raines Rules

as evidence that they have performed mission analysis and

work process redesign. However, compliance with Raines Rules

only requires that the agency answer whether work redesign

has begun—not whether the work redesign has been completed.

• For example, Education reported that it has analyzed some

of its missions and has begun to revise its mission-related

and administrative processes. Interior reported that business

process reengineering efforts are in various stages of development in several of its bureaus.

BUILDING LARGE IT SYSTEMS INCREMENTALLY THROUGH MODULAR

CONTRACTING 15

Background: The CCA authorizes Federal agencies to adopt modular approaches to building and acquiring information systems.

This is expected to produce smaller, more manageable projects that

11

can be examined in shorter time frames for expected cost and benefit results. It also encourages the use of pilots and prototyping before full scale development and implementation.

Finding 9: Modular contracting is still not applied consistently in

major IT investments government-wide.

• Eight agencies reported still being in the process of implementing modular contracting.

RECOMMENDATIONS

In order for executive departments and agencies to fully comply

with the CCA, the following recommendations should be implemented:

1. Departments and agencies should review the mechanisms in

place for assuring that they are fully implementing the CCA

through their policies, procedures, and practices.

2. Departments and agencies should articulate the roles, reporting relationships and boundaries of authority among all CIOs within an agency in ways that enhance the effective implementation of

the CCA.

3. Departments and agencies must provide the appropriate authority to the CIO to ensure the CIO’s control over IT capital planning and investment processes.

4. Departments and agencies need to increase quality control of

their capital planning and investment control practices, including

ensuring that any cost/benefit data used in investment decisionmaking is accurate and complete.

5. Departments and agencies need to provide clear procedures

on how CIOs and program managers communicate to senior management the status and progress of major IT projects.

6. In order to avoid schedule slips and cost overruns on major

IT investments, departments and agencies should develop and incorporate the use of decision milestones in IT project management.

7. Departments and agencies must develop an effective means

of identifying IT projects that deviate significantly from cost, schedule and performance expectations.

8. Departments and agencies need to increase project management and capital planning skills within their IT workforce.

9. Departments and agencies must provide better data on how

IT investments will benefit Federal programs.

10. Departments and agencies should develop IT management

plans that include accomplishments, progress, and the identification of areas requiring attention.

11. Departments and agencies should clarify the requirements

for process reengineering in their overall capital planning and investment control procedures.

12. Departments and agencies should increase their use of modular contracting for building and acquiring information systems.

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