GAO

United States General Accounting Office

Report to Congressional Committees

June 2001 CUSTOMS SERVICE 

MODERNIZATION

Results of Review of 

First Automated 

Commercial 

Environment 

Expenditure Plan

GAO-01-696

Page 1 GAO-01-696 Customs’ ACE Expenditure Plan

United States General Accounting Office

Washington, D.C. 20548

June 5, 2001

The Honorable Ben Nighthorse Campbell

Chairman

The Honorable Byron L. Dorgan

Ranking Member

Subcommittee on Treasury and General Government

Committee on Appropriations

United States Senate

The Honorable Ernest J. Istook

Chairman

The Honorable Steny H. Hoyer

Ranking Minority Member

Subcommittee on Treasury, Postal Service,

 and General Government 

Committee on Appropriations

House of Representatives

Pursuant to the U.S. Customs Service’s fiscal year 2001 appropriation,1

Customs submitted to the Congress in March 2001 its first expenditure 

plan, requesting $45 million for its Automated Commercial Environment 

(ACE). ACE is intended to be Customs’ new import processing system and 

the first project under the Customs Modernization Program. As required by 

the act, we reviewed the expenditure plan. Our objectives were to 

(1) determine whether the plan satisfied the legislative conditions specified 

in the act, (2) determine whether the plan is consistent with our open 

recommendations, and (3) provide any other observations about the 

expenditure plan and Customs’ modernization. 

On April 23, 2001, we briefed your offices on the results of this review. This 

report officially transmits the results of our work and our 

recommendations to the Commissioner of Customs. The full briefing, 

including our scope and methodology, is reprinted as appendix I. In 

summary, we made three major points:

• First, Customs’ expenditure plan satisfies the legislative conditions 

specified in the appropriations act, including (1) meeting the Office of 

1

 The Consolidated Appropriations Act, 2001 (Public Law 106-554, dated December 21, 

2000).
Page 2 GAO-01-696 Customs’ ACE Expenditure Plan

Management and Budget’s (OMB) capital planning and investment 

control review requirements; (2) complying with Customs’ enterprise 

architecture;2

 (3) complying with federal acquisition rules, 

requirements, guidelines, and systems acquisition management 

practices; and (4) being reviewed by the Customs Investment Review 

Board,3

 Treasury, and OMB.

• Second, activities described in the plan are consistent with our two open 

recommendations regarding the need for Customs to (1) justify and 

make ACE investment decisions incrementally and (2) strengthen ACE 

software acquisition management.

• Third, we observed two areas needing improvement. One, Customs has 

not adequately justified investing in the International Trade Data System 

(ITDS)4

 pilot project in parallel with, and separate from, planned ITDS 

efforts under the ACE modernization. Two, Customs has defined 

conflicting roles and responsibilities for its independent verification and 

validation (IV&V)5

 contractor. 

Recommendations for 

Executive Action 

To improve Customs’ ACE modernization management, we recommend 

that the Commissioner of the U.S. Customs Service direct the Chief 

Information Officer, as the modernization executive, to

• immediately transfer responsibility and accountability for the ITDS pilot 

to the ACE modernization program manager;

• include any plans for further investing in the ITDS pilot, including cost, 

benefit, and risk justification, in the next ACE expenditure plan; and

• clarify the ACE modernization IV&V agent’s roles and responsibilities to 

ensure that independence is not compromised.

2

 An enterprise architecture establishes the roadmap to achieving an agency’s mission 

through optimal performance of its core business processes within an efficient information 

technology environment. 

3

 Customs’ Investment Review Board makes information technology funding decisions on 

the basis of comparisons and trade-offs among competing project proposals.

4

 ITDS is a system that Customs is acquiring for the governmentwide collection, use, and 

dissemination of trade data.

5

 The purpose of independent verification and validation (IV&V) is to provide an 

independent review of system processes and products. The use of IV&V is a recognized best 

practice for large and complex systems development and acquisition projects. To be 

effective, IV&V must be performed by an entity that is independent of the processes and 

products that are being reviewed. 
Page 3 GAO-01-696 Customs’ ACE Expenditure Plan

Agency Comments In commenting on a draft of this report, the Director, Office of Planning, 

U.S. Customs Service agreed with our findings and recommendations. The 

Director’s written comments are reprinted in appendix II.

We are sending copies of this report to Senator Charles E. Grassley, 

Chairman, and Senator Max Baucus, Ranking Member, Senate Committee 

on Finance; and Representative William M. Thomas, Chairman, and 

Representative Charles B. Rangel, Ranking Minority Member, House 

Committee on Ways and Means. We are also sending copies of this report to 

the Honorable Paul H. O’Neill, Secretary of the Treasury; the Honorable 

Charles W. Winwood, Acting Commissioner of the U.S. Customs Service; 

and the Honorable Mitchell E. Daniels Jr., Director of OMB. 

Should you or your staff have any questions on matters discussed in this 

report, please contact me at (202) 512-3439. I can also be reached by e-mail 

at HiteR@gao.gov. Key contributors to this report were Mark Bird, Madhav 

Panwar, Jamelyn Smith, and Aaron Thorne. 

Randolph C. Hite

Director, Information Technology 

 Systems Issues
Page 4 GAO-01-696 Customs’ ACE Expenditure Plan

Appendix I

Results of Review of Customs’ First Apendxies

Automated Commercial Environment (ACE) 

Expenditure Plan ApendxiI

1

Results of Review of Customs’ First Automated

Commercial Environment (ACE) Expenditure Plan

Briefing to Staffs of the

Subcommittee on Treasury and General Government

Senate Committee on Appropriations

and

Subcommittee on Treasury, Postal Service,

and General Government

House Committee on Appropriations

April 23, 2001
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 5 GAO-01-696 Customs’ ACE Expenditure Plan

2

• Introduction

• Objectives

• Scope and Methodology

• Background

• Results in Brief

• Results

• Conclusions

• Recommendations for Executive Action

• Appendix I

Briefing Overview
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 6 GAO-01-696 Customs’ ACE Expenditure Plan

3

• The Automated Commercial Environment (ACE) is intended to be

Customs’ new import processing system.

• In February 1999 we reported1 that ACE suffered from serious

management weaknesses, such as inadequate economic

justification for investing in the proposed system solution and

ineffective software management processes, and we

recommended that Customs

• rigorously analyze alternative approaches to building ACE,

including satisfying some ACE requirements through

Treasury’s International Trade Data System (ITDS);2

• justify and make ACE investment decisions incrementally;

and

• strengthen ACE software acquisition management.

Introduction

1Customs Service Modernization: Serious Management and Technical Weaknesses Must Be Corrected (GAO/AIMD-99-41, February 26, 1999). 2At the time of our report, ITDS was a system that Treasury was acquiring for the governmentwide collection, use and dissemination of trade data.

Since then, responsibility for ITDS was transferred to Customs.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 7 GAO-01-696 Customs’ ACE Expenditure Plan

4

• In response, Customs’ FY 2001 appropriations act (Public Law

106-554) provided $130 million for ACE, but stated that these

funds may not be obligated until Customs submits to the

Congress for approval an ACE expenditure plan that

• meets OMB capital planning and investment control review

requirements;

• complies with the Customs Service’s enterprise architecture;

• complies with federal acquisition rules, requirements,

guidelines, and systems acquisition management practices;

• is reviewed and approved by the Customs Investment

Review Board (IRB), Treasury, and OMB; and

• is reviewed by GAO.

• Consistent with our open recommendation for incrementally

investing in ACE, Customs plans to submit a series of

expenditure plans seeking release of funds to acquire ACE.

Introduction

(cont’d.)
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 8 GAO-01-696 Customs’ ACE Expenditure Plan

5

• On March 5 and 6, 2001, the House and Senate subcommittees,

respectively, released to Customs $5 million in stopgap funding

to sustain program activities until Customs submitted its first

expenditure plan.

• On March 26, 2001, Customs submitted its first expenditure plan

to its House and Senate appropriations subcommittees seeking

release of $45 million from the ACE appropriation.

Introduction

(cont’d.)
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 9 GAO-01-696 Customs’ ACE Expenditure Plan

6

Introduction

(cont’d.)

Customs Fiscal Year 2001 ACE Appropriation - $130 Million

	







	







 

	
 





Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 10 GAO-01-696 Customs’ ACE Expenditure Plan

7

• As agreed, our objectives were to

• determine whether Customs’ first ACE expenditure plan dated

March 26, 2001, satisfies the legislative conditions,

• determine whether the plan is consistent with our open

recommendations, and

• provide any other observations about the expenditure plan

and Customs modernization.

• We agreed to provide our results to the subcommittees on April

23, 2001.

Objectives
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 11 GAO-01-696 Customs’ ACE Expenditure Plan

8

• To accomplish our objectives, we

• reviewed the expenditure plan and met with Customs

program officials to understand the scope and content of the

plan;

• analyzed the plan against the legislative conditions;

• assessed Customs’ actions for responding to our open

recommendations to determine consistency and progress;

• reviewed ACE program management plans, reports, and

briefings to clarify and ensure consistency with information in

the expenditure plan;

• reviewed ITDS pilot management plans, reports, and

briefings to understand its scope, approach, management

structure, justification, status, and relationship to the ACE

modernization; and

Scope and Methodology
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 12 GAO-01-696 Customs’ ACE Expenditure Plan

9

Scope and Methodology

(cont’d.)

• interviewed ACE and ITDS program management officials to

clarify information in plans, reports, and briefings.

• As agreed, to meet our reporting deadline we did not

independently validate planned initiatives’ cost estimates or

confirm the validity of Customs’ information on the initiatives’

content and progress.

• We provided a draft of this briefing on April 20, 2001, to Customs’

Chief Information Officer and incorporated his comments where

appropriate.

• We performed our work from February through April 2001 in

accordance with generally accepted government auditing

standards.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 13 GAO-01-696 Customs’ ACE Expenditure Plan

10

Need to Modernize

• Customs forecasts a burgeoning trade workload without a

commensurate increase in human capital resources.

• Customs relies on antiquated information systems and manual

processes to document, inspect, and account for the movement

and disposition of imported goods while collecting and accounting

for the related revenues.

• We have testified that the need for Customs to modernize its

import processing is undeniable because the existing import

processing system (Automated Commercial System or ACS) is

paper-intensive, error-prone, transaction-based, and out of step

with the just-in-time inventory practices of the trade community.3

Background

3U.S. Customs Service: Observations on Selected Operations and Program Issues (GAO/T-GGD/AIMD-00-150,

 April 20, 2000).
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 14 GAO-01-696 Customs’ ACE Expenditure Plan

11

	



	
	
	
	






















	 	

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Background

(cont’d.)

Source: U. S. Customs Service
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 15 GAO-01-696 Customs’ ACE Expenditure Plan

12

Background

(cont’d.)

Proposed ACE Versus Existing ACS Functionality

 Source: U. S. Customs Service

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Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 16 GAO-01-696 Customs’ ACE Expenditure Plan

13

• Customs strategy for replacing ACS and modernizing import

processing is to employ a world-class systems integration PRIME

contractor to deliver and deploy a system solution that meets

Customs business needs.

• Customs plans to announce the PRIME contractor on April 25,

2001.

Background

(cont’d.)
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 17 GAO-01-696 Customs’ ACE Expenditure Plan

14

Background

(cont’d.)

ITDS

• As part of the ACE modernization program, Customs plans to

acquire ITDS, which is to provide importers a single interface to

the many federal agencies that collect, use, and disseminate

trade data, including Customs.

Importer Importer

Without ITDS With ITDS

ITDS

Customs FDA DOT INS USDA Others Customs FDA DOT INS USDA Others
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 18 GAO-01-696 Customs’ ACE Expenditure Plan

15

March 26, 2001, $45 Million Expenditure Plan Summary4

Background

(cont’d.)

4Additional information on Customs’ expenditure plan is provided in appendix I.

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Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 19 GAO-01-696 Customs’ ACE Expenditure Plan

16

Results in Brief

• Objective 1: Customs’ expenditure plan satisfies the legislative 

conditions.

• Objective 2: The expenditure plan is consistent with open GAO 

 recommendations.5

Legislative Conditions Satisfies Does Not Satisfy

Meets OMB capital planning and investment control review

requirements ✔

Complies with the Customs Service’s enterprise architecture ✔

Complies with federal acquisition rules, requirements, guidelines,

and systems acquisition management practices ✔

Is reviewed and approved by the Customs investment review board

(IRB), Treasury, and OMB

✔

Is reviewed by GAO ✔

Recommendation Summary Consistent Inconsistent

Justify and make investment decisions incrementally ✔

Strengthen ACE software acquisition management ✔

5GAO closed its recommendation that Customs analyze alternative approaches to building ACE, including ITDS,

when responsibility for ITDS was transferred from Treasury to Customs.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 20 GAO-01-696 Customs’ ACE Expenditure Plan

17

Results in Brief

(cont’d.)

• Objective 3: Other observations

• Observation 1: Customs is investing in an ITDS pilot project

in parallel with, and separate from, planned ITDS efforts

under the ACE modernization.

• Supporting ACE program management documents provide

for acquiring and implementing ITDS as part of ACE.

• Nevertheless, Customs has underway, separate from the

ACE modernization program, an ITDS pilot system

acquisition and implementation effort.

• Customs has not adequately justified its ongoing efforts

and plans for its ITDS pilot effort.

• Observation 2: Customs has defined conflicting roles and

responsibilities for its independent verification and validation

(IV&V) contractor.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 21 GAO-01-696 Customs’ ACE Expenditure Plan

18

Objective 1: The expenditure plan satisfies the

legislative conditions.

Results

Legislative Conditions Satisfies Conditions Expenditure Plan Provisions

1. Meets OMB capital planning and investment

control review requirements.

✔

The expenditure plan was reviewed and approved

by the Customs IRB, the executive management

team that makes capital funding decisions. The

framework for these funding decisions is Customs’

investment management process, which we

determined meets OMB’s capital planning and

investment control review requirements as

outlined in OMB Circular A-130, “Management of

Federal Information Resources.”

2. Complies with the Customs Service’s

enterprise architecture. ✔

The expenditure plan seeks initial funding for

ACE, which we verified that Customs determined

to be in compliance with its enterprise

architecture.

3. Complies with federal acquisition rules,

requirements, guidelines, and systems

acquisitions management practices.

✔

Customs has formulated plans and assigned

responsibilities for implementing Software

Engineering Institute Software Acquisition

Capability Maturity Modell6 key process areas. If

implemented effectively, these processes should

meet federal acquisition rules, regulations, and

practices.

6Capability Maturity ModelSM is a service mark of Carnegie Mellon University, and CMM® is registered in the

U.S. Patent and Trademark Office.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 22 GAO-01-696 Customs’ ACE Expenditure Plan

19

Objective 1 (cont’d)

Results

(cont’d.)

Legislative Conditions Satisfies Conditions Expenditure Plan Provisions

4. Is reviewed and approved by the Customs IRB,

Treasury, and OMB.

✔

Customs’ IRB approval was given on January 19,

2001. Treasury approval was given on February

6 (for everything but the three initial ACE tasks)

and on March 9, 2001 (for the three initial ACE

tasks). OMB approval was given on February 23

(for everything but the three initial ACE tasks) and

on March 22, 2001 (for the three initial ACE tasks)

5. Is reviewed by GAO. ✔ Our review was completed on April 23, 2001
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 23 GAO-01-696 Customs’ ACE Expenditure Plan

20

Results

(cont’d.)

Objective 2: The plan is consistent with our open ACE

recommendations.

GAO Recommendation Consistent Actions Planned or Taken

Justify and make investment decisions

incrementally, and for each increment:

use disciplined investment processes;

prepare realistic and supportable benefit

expectations;

require a favorable return on investment and

compliance with Customs’ architecture before

making an investment decision;

and validate actual costs and benefits once an

increment is piloted.

✔

Customs ACE expenditure plan and supporting documents

describe an incremental approach to investing in ACE that

entails

compliance with Customs’ investment management

process;

preparation of cost/benefit analyses and independent

validation of the estimated costs and benefits for each

ACE increment;

requirements for a positive return on investment and

compliance with Customs’ enterprise architecture, as

required by Customs’ investment management process;

and

validation of actual costs and benefits as determined in

post-implementation reviews.

Strengthen ACE software acquisition management

by:

establishing an effective process improvement

program and correcting the weaknesses in

ACE software acquisition processes identified

in this report thereby bringing ACE processes

to at least Software Engineering Institute CMM

level 27

; and

requiring at least CMM level 2 processes of all

ACE software contractors.

✔

Customs ACE expenditure plan includes funds to continue

software acquisition process improvement efforts including

establishment of a software process improvement

program and

correction of weaknesses in ACE software acquisition

processes and demonstration of progress toward

bringing ACE processes to at least Software

Engineering Institute CMM level 2.

Customs instituted a policy requiring CMM level 2 processes

of all software contractors, and is requiring that its prime

modernization contractor maintain level 3 processes.

7CMM level 2 is the second level on the Software Engineering Institute’s five-level scale and means that an

organization has the software acquisition rigor and discipline to repeat project successes.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 24 GAO-01-696 Customs’ ACE Expenditure Plan

21

Results

(cont’d.)

Objective 3: Other observations about the expenditure

plan and the modernization program.

Observation 1: Customs is investing in an ITDS pilot project in

parallel with, and separate from, ITDS efforts under the ACE

modernization program.

• Supporting ACE program management documents include

acquisition of ITDS as an integral part of the PRIME contractor’s

activities. For example, one of the initial contractor tasks includes

defining ITDS requirements as part of defining ACE requirements.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 25 GAO-01-696 Customs’ ACE Expenditure Plan

22

Results

(cont’d.)

• In addition, however, Customs is in the process of acquiring and

implementing an ITDS pilot system. This pilot is being pursued

concurrent with the ACE modernization program, but separate

from the first expenditure plan, the ACE modernization program

office, and the first PRIME contractor task orders.

• The ITDS pilot is being managed by the Customs’ Software

Development Division, is scheduled to be fielded at Buffalo, NY in

June 2001, and is to be integrated with the existing ACE

prototype system.

• Fiscal year 2001 funding for ITDS is $5.4 million.

• According to Customs officials, the ITDS pilot is intended to help:

• demonstrate the ITDS/ACE integration feasibility,

• facilitate understanding of ITDS requirements,

• build credibility with federal agencies and importers, and

• maintain momentum toward implementing an operational

version of ITDS as part of the ACE modernization.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 26 GAO-01-696 Customs’ ACE Expenditure Plan

23

Results

(cont’d.)

• Beyond these stated reasons, Customs officials did not provide

any analysis of the ITDS pilot’s costs, benefits, and risks that

justify separately investing in it, notwithstanding the fact that its

strategy is to hire a PRIME contractor to deliver a system solution

to its ACE/ITDS requirements. Moreover, the reasons that

Customs cited are not compelling because

• the pilot is to be integrated with the ACE prototype system

and this prototype’s physical architecture includes dated

technology (e.g., COBOL-based mainframe applications) and

thus is not likely to be the architecture used by the PRIME

contractor in engineering the operational ACE system

solution;

• understanding and identifying ACE, including ITDS,

requirements is a task the PRIME contractor will be asked to

perform; and
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 27 GAO-01-696 Customs’ ACE Expenditure Plan

24

Results

(cont’d.)

• building credibility and maintaining momentum are vague and

ambiguous bases for justifying additional investment in ITDS

beyond already executed task orders.

• Without a more compelling analytical basis for investing in the

ITDS pilot, further spending on it beyond Customs’ current

contractual obligation risks unwise use of funds.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 28 GAO-01-696 Customs’ ACE Expenditure Plan

25

Results

(cont’d.)

Observation 2: Customs has defined conflicting roles and

responsibilities for its independent verification and validation

(IV&V) contractor.

• The purpose of IV&V is to provide an independent review of

system processes and products. The use of IV&V is a

recognized best practice for large and complex system

development and acquisition projects, like ACE.

• To be effective, the IV&V function must be performed by an entity

that is independent of the processes and products that are being

reviewed.

• However, Customs plans to use its IV&V agent (MITRE) to also

perform some of the activities that the IV&V agent is to be

responsible for reviewing.

• Thus, Customs will not have an independent review of critical

modernization activities, such as program management.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 29 GAO-01-696 Customs’ ACE Expenditure Plan

26

Results

(cont’d.)

Roles and Responsiblities for MITRE

Program

Responsibility

IV&V

Responsibility

Strategic Planning ✔

Budgeting ✔

Research ✔

Program Management ✔ ✔

Project Management ✔ ✔

Requirements Definition ✔ ✔

Requirements Management ✔

Investment Management Decisions ✔ ✔

Engineering ✔ ✔

Design ✔

Development ✔

Integration ✔ ✔

Acceptance Testing ✔

Deployment ✔

Training ✔

Documentation ✔

Transition Management ✔

Performance Management ✔

Audit and Evaluation ✔
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 30 GAO-01-696 Customs’ ACE Expenditure Plan

27

Conclusions

• Customs’ first ACE expenditure plan satisfies the legislative

conditions and is consistent with our open recommendations. In

our view, it constitutes a reasonable first step to a complex, longterm modernization program.

• Nevertheless, opportunities for improvement exist because the

plan

• excludes relevant system investment activities pertaining to

ITDS and allows these activities to proceed outside of the

scope of the modernization program without an analytically

justified basis for doing so, and

• provides for conflicting roles and responsibilities for the

modernization program’s IV&V agent.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 31 GAO-01-696 Customs’ ACE Expenditure Plan

28

Recommendations for

Executive Action

 To improve Customs ACE modernization management, we

recommend that the Commissioner direct the Chief Information

Officer, as the Modernization Executive, to:

• Immediately transfer responsibility and accountability for the

ITDS pilot to the ACE modernization program manager.

• Include any plans for further investing in the ITDS pilot,

including cost, benefit, and risk justification, in the next ACE

expenditure plan.

• Clarify the ACE modernization IV&V agent’s roles and

responsibilities to ensure independence is not compromised.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 32 GAO-01-696 Customs’ ACE Expenditure Plan

29

Agency Comments

• In commenting on a draft of this briefing, the Customs Chief

Information Officer agreed with our findings, conclusions, and

recommendations.
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 33 GAO-01-696 Customs’ ACE Expenditure Plan

30

Appendix I

Additional Information on Expenditure Plan

Program Management

Field staff travel Relocation of field personnel to the Washington area

to aid in setting ACE requirements

Software development /

acquisition process

improvement

Enhancing enterprise-wide management processes

ACE prototype operations and

maintenance

Sustaining contractors to support the ACE pilot in

Detroit and Port Huron, Michigan; and Laredo, Texas

Program management support

contractor (Robbins-Gioia)

Robbins-Gioia provides support in management

process development, budgeting, expenditures

tracking, requirements and configuration management,

communications, and contractor administration

Program management support

contractor (MITRE)

MITRE provides support in planning and analysis,

systems architecture and engineering, management

capability maturity, and IV&V of prime work products

Support systems Analysis, acquisition, and development of systems to

interface with prime contractor to manage the

modernization program

Program office Collocation of Customs and contractor staffs, as well

as office systems and training
Appendix I

Results of Review of Customs’ First 

Automated Commercial Environment (ACE) 

Expenditure Plan

Page 34 GAO-01-696 Customs’ ACE Expenditure Plan

31

Appendix I

(cont’d.)

8Cost details for contractor tasks are procurement sensitive and are therefore not provided in this briefing.

Initial Modernization Contractor Tasks8

Establish and maintain a management office with all of the necessary policies,

procedures, and support structure to manage the modernization initiative. This includes

planning, implementing, and managing at both the program and project levels.

Establish and maintain the logical and conceptual design of the infrastructure and

services required for implementing ACE. This includes updating and maintaining

various systems engineering documents such as the Customs Enterprise Life Cycle

Model, the Customs Enterprise Architecture, and the Technical Reference Model.

Develop a set of top-level ACE functional requirements, including all ITDS

requirements, based on the knowledge and experience provided by subject matter

experts from various offices within Customs. These requirements will be translated by

the prime contractor into a comprehensive ACE project plan that outlines the transition

from the current ACS to the target ACE system. The transition will occur through a

series of projects that will incrementally build on ACE functionality.

(310208)

Letr
Page 35 GAO-01-696 Customs’ ACE Expenditure Plan

Appendix II

Comments From the U.S. Customs Service ApendxiI
Appendix II

Comments From the U.S. Customs Service

Page 36 GAO-01-696 Customs’ ACE Expenditure Plan
Appendix II

Comments From the U.S. Customs Service

(310214) Letr Page 37 GAO-01-696 Customs’ ACE Expenditure Plan
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