a

GAO

United States General Accounting Office

Report to the Chairman, Subcommittee 

on Transportation, Treasury and 

Independent Agencies, Committee on 

Appropriations, House of 

Representatives

August 2003 RECORDS 

MANAGEMENT

National Archives and 

Records 

Administration’s 

Acquisition of Major 

System Faces Risks

GAO-03-880
The ERA program’s acquisition policies, plans, and practices do not 

consistently conform to industry standards. In developing the plans and 

policies to guide its acquisition of the ERA system, NARA elected to 

follow recognized industry standards set forth by the Institute of 

Electrical and Electronics Engineers (IEEE). However, key policy and 

planning documents are missing elements that are required by the 

standards. For example, one key document is the concept of operations, 

which should describe the characteristics of a proposed system from the 

users’ viewpoint. The ERA Concept of Operations does not include 

several key elements required by the IEEE standard, including a 

complete description of the proposed system. Because these policy and 

planning documents form the basis of the acquisition, such shortcomings 

could result in serious long-term risks to the cost, schedule, and 

performance of the ERA program. 

NARA cannot adequately track the cost and schedule of the ERA 

program. A comprehensive schedule with an appropriate work 

breakdown structure is a prerequisite to program tracking, as it allows 

managers to measure how well the program is achieving its cost and 

schedule goals. To achieve upcoming major milestones (some of which 

are shown in the figure), the program must successfully complete a 

complex series of tasks. However, the program schedule omits 

significant tasks and activities; for example, it does not include the 

process to reengineer the agency’s life cycle business processes, which 

will be crucial to defining requirements. In addition, the schedule lacks a 

work breakdown structure, which would allow accurate estimates of the 

resources and time required for each work activity. If NARA cannot track 

how well the program is meeting cost and schedule, the risk is increased 

that funds may not be used efficiently or effectively, quality problems 

may limit the usefulness of the resulting system, and the system may not 

be delivered according to established milestones. 

Major Milestones in ERA Acquisition 

Increasingly, government records 

involve documents that are 

electronically created and stored. 

In support of its mission to manage 

and archive these records and 

ensure access to the “essential 

evidence” that they contain, the 

National Archives and Records 

Administration (NARA) is acquiring 

an advanced Electronic Records 

Archives (ERA). GAO was asked to 

determine, among other things, 

how the ERA program’s system 

acquisition policies, plans, and 

practices conform to industry 

standards and how well NARA is 

meeting the ERA program’s cost 

and schedule. 

To reduce the risks associated with 

NARA’s efforts to design and 

acquire ERA, GAO recommends 

that the U.S. Archivist direct the 

NARA Chief Information Officer to 

take a range of actions, including 

revising key planning documents 

and developing a schedule that is 

based on a comprehensive work 

breakdown structure (including 

associated costs and other 

resources). 

In comments on the draft report, 

the Archivist of the United States 

accepted our recommendations 

and provided an update on NARA’s 

efforts to implement them. The 

Archivist also provided additional 

information on the ERA acquisition 

schedule. 

www.gao.gov/cgi-bin/getrpt?GAO-03-880.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at 

(202) 512-6240 or koontzl@gao.gov. 

Highlights of GAO-03-880, a report to the 

Chairman, Subcommittee on 

Transportation, Treasury and Independent 

Agencies, Committee on Appropriations, 

House of Representatives 

August 2003 

RECORDS MANAGEMENT

National Archives and Records 

Administration’s Acquisition of Major 

System Faces Risks 
Page i GAO-03-880 Electronic Archive Acquisition

Contents

Letter 1

Recommendations for Executive Action 4

Agency Comments 4

Appendixes

Appendix I: National Archives and Records Administration’s Acquisition 

of Electronic Records Archives 6

Appendix II: Comments from the National Archives and Records 

Administration 49

Abbreviations

ERA Electronic Records Archives

IEEE Institute of Electrical and Electronics Engineers

IT information technology

NARA National Archives and Records Administration

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-03-880 Electronic Archive Acquisition

United States General Accounting Office

Washington, D.C. 20548

A

August 22, 2003 Letr

The Honorable Ernest J. Istook, Jr.

Chairman

Subcommittee on Transportation, Treasury and Independent Agencies

Committee on Appropriations

House of Representatives

Dear Mr. Chairman:

The National Archives and Records Administration (NARA) has initiated 

the Electronic Records Archives (ERA), a project to acquire a major 

information system to maintain and provide access to permanent federal 

records independent of the technological state of the art and the varieties 

of record formats. NARA’s goal is for this system to preserve and provide 

access to any kind of electronic record, so that the agency can carry out its 

mission into the future. However, as we have reported previously,1

acquiring a major information technology (IT) system like ERA is a 

significant challenge for a relatively small organization such as NARA, 

which has no previous experience in acquiring major information systems.

Our objectives were to determine 

1. the status of NARA’s efforts to establish organizational capabilities for 

acquiring major information systems, 

2. how the ERA project’s system acquisition policies, plans, and practices 

conform to industry standards, and 

3. how well NARA is meeting the ERA project’s cost and schedule goals. 

To achieve these objectives, we reviewed agency information technology 

policies and practices, and we obtained and analyzed ERA program 

documents on system acquisition, project management, and cost and 

schedule. We evaluated ERA documents and practices by the standards 

selected by the program to guide the ERA acquisition, including specifically 

those of the Institute of Electrical and Electronics Engineers (IEEE). We 

also interviewed NARA information resources management and ERA 

1

U.S. General Accounting Office, Information Management: Challenges in Managing and 

Preserving Electronic Records, GAO-02-586 (Washington, D.C.: June 17, 2002).
Page 2 GAO-03-880 Electronic Archive Acquisition

program officials. We performed our work from July 2002 to May 2003 in 

accordance with generally accepted government auditing standards.

On May 15, 2003, we provided your staff with a briefing on the results of 

our study, which included procurement-sensitive information. The slides 

from that briefing—with procurement-sensitive information removed—are 

included as appendix I to this report. The purpose of this report is to 

provide the published briefing slides to you and to officially transmit our 

recommendations to the Archivist of the United States. 

In summary, our briefing made three points:

• To establish its capabilities for acquiring major information systems, 

NARA has made progress in implementing the key management areas of 

IT investment management, enterprise architecture, and IT security. 

However, these capabilities are not yet completely established, and 

NARA has more work to do to implement our prior recommendations in 

this area.2

 Specifically, while NARA continues to develop an enterprise 

architecture, it does not plan to complete its target architecture3 in time 

to influence the ERA system definition and requirements. Furthermore, 

while NARA has completed some elements of an information security 

program, several key areas have not yet been addressed, such as 

(1) individual system security plans and (2) security certification and 

accreditation of its information systems.4 Without strong IT 

management capabilities, NARA increases its risk of failing to achieve 

2

U.S. General Accounting Office, Information Management: Challenges in Managing and 

Preserving Electronic Records, GAO-02-586 (Washington, D.C.: June 17, 2002).

3

A target architecture is one aspect of an overall enterprise architecture. An enterprise 

architecture describes (in useful models, diagrams, and narrative) the mode of operation for 

an enterprise, such as an agency or mission area. It provides a perspective on enterprise 

operations both for the current (“as is”) operating environment and for the target (“to be”) 

environment. More specifically, the target environment is the business and technology 

environment that is planned to result from aligning technology investments with the 

strategic goals of the enterprise (including requisite changes to the operations, organization, 

and management of both the automated and manual processes of the enterprise). An 

enterprise architecture also includes a transition plan for sequencing from the current to the 

target environment. 

4

Under OMB policy, responsible federal officials are required to make a security 

determination (called accreditation) to authorize placing IT systems into operation. In order 

for these officials to make sound, risk-based decisions, a security evaluation (known as 

certification) of the IT system is needed. 
Page 3 GAO-03-880 Electronic Archive Acquisition

cost, schedule, and performance objectives for its information systems, 

including ERA. 

• The ERA program has developed policies, plans, and practices to guide 

and manage its acquisition of the ERA system. In many cases, however, 

these do not conform to the chosen standards or to applicable federal 

acquisition guidance. In developing its plans and policies, NARA elected 

to follow recognized industry standards set forth by IEEE. However, key 

policy and planning documents are missing elements that are required 

by the standards. For example, one key document is the concept of 

operations, which should describe the characteristics of a proposed 

system from the users’ viewpoint. The ERA Concept of Operations does 

not include several key elements required by the IEEE standard, 

including a complete description of the proposed systems. In addition, 

key ERA staff positions are unfilled, including positions that NARA 

determined are needed to carry out system acquisition tasks. Without 

adequate policy and planning documents—which form the basis of the 

acquisition—and adequate staff to carry out these policies and plans, 

NARA increases the long-term risks to the acquisition. 

• Finally, NARA cannot adequately track the cost and schedule of the ERA 

project because the schedule does not include all program tasks and 

lacks a work breakdown structure.5

 In addition, NARA has not used 

earned value management—a performance-based technique that allows 

managers to track the budget against the schedule—to track the ERA 

cost and schedule programwide. Without the ability to track cost and 

schedule effectively, NARA increases the risk that ERA funds will not be 

used efficiently or effectively, quality problems will limit the usefulness 

of the ERA system, and the ERA system will not be delivered according 

to established milestones.

In light of the challenges NARA faces in acquiring ERA, NARA will face 

significant difficulties unless it addresses the weaknesses described above.

5

A work breakdown structure provides descriptions of all work activities for a given project 

that are detailed enough to expose risk factors and allow accurate estimates of resource 

requirements and schedule duration for each work activity. Each major work activity should 

include standard elements such as assigned personnel, resource budgets, estimated task 

duration, and dependencies among work activities. An adequate work breakdown structure 

is a prerequisite to program tracking, allowing managers to measure how well a program is 

achieving its cost and schedule goals.
Page 4 GAO-03-880 Electronic Archive Acquisition

Recommendations for 

Executive Action

To reduce the risks associated with NARA’s efforts to design and acquire 

the Electronic Records Archives, we recommend that the U.S. Archivist 

direct the NARA Chief Information Officer to address weaknesses in the 

acquisition policies, plans, and practices by 

• revising the ERA Life Cycle document and associated procedures and 

practices to conform to IEEE standards; 

• revising the ERA Concept of Operations to conform to IEEE standards, 

including a complete description of the current and proposed systems; 

• revising the ERA Acquisition Strategy to conform to IEEE standards 

and the Federal Acquisition Regulation; 

• revising the ERA Risk Management Plan to provide processes and 

procedures specific to the ERA program; 

• revising the ERA Quality Assurance Plan to conform to appropriate 

industry standards, establishing a vigorous, independent ERA quality 

assessment process, and providing the staffing resources necessary to 

ensure that quality assessment duties are performed effectively; and 

• filling key vacant ERA positions. 

Further, we recommend that the U.S. Archivist direct the NARA Chief 

Information Officer to immediately address weaknesses in tracking cost 

and schedule by 

• developing an ERA schedule that is based on a comprehensive work 

breakdown structure (including associated costs and other resources) 

and establishes dependencies between successor and predecessor 

tasks; and 

• using earned value management to capture and monitor progress for the 

entire ERA program. 

Agency Comments In providing written comments on a draft of this report (which are 

reprinted in app. II), the Archivist of the United States indicated that NARA 

is acting to implement our recommendations and provided an update on 

the status of the agency’s efforts to do so. In addition, the Archivist 
Page 5 GAO-03-880 Electronic Archive Acquisition

provided a clarification regarding the ERA acquisition schedule, stating 

that there will be two to three releases for each of the increments in the 

schedule.

We are sending copies of this report to the Chairmen and Ranking Minority 

Members of the Subcommittee on Transportation, Treasury and 

Independent Agencies, House Committee on Appropriations; the 

Subcommittee on Transportation, Treasury and General Government, 

Senate Committee on Appropriations; the Subcommittee on Technology, 

Information Policy, Intergovernmental Relations and the Census, House 

Committee on Government Reform; and the Subcommittee on Oversight of 

Government Management, the Federal Workforce and the District of 

Columbia, the Senate Committee on Governmental Affairs. We are also 

sending copies to the Archivist of the United States. We will also make 

copies available to others upon request. In addition, the report will be 

available at no charge on the GAO Web site at www.gao.gov.

Should you have any question on matters contained in this report, please 

contact me at (202) 512-6240 or by E-mail at koontzl@gao.gov. Other key 

contributors to this report were Timothy Case, Barbara Collier, Mirko 

Dolak, and Elena Epps.

Sincerely yours,

Linda D. Koontz

Director, Information Management Issues
Page 6 GAO-03-880 Electronic Archive Acquisition

Appendix I

National Archives and Records Apendxies

Administration’s Acquisition of Electronic 

Records Archives ApendxiI

1

National Archives and Records Administration’s 

Acquisition of Electronic Records Archives

Briefing for the Staff of the 

Subcommittee on Transportation, 

Treasury and Independent Agencies 

House Appropriations Committee

May 15, 2003
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 7 GAO-03-880 Electronic Archive Acquisition

2

Outline of Briefing

Introduction

Objectives, Scope, and Methodology

Results in Brief

Background

Results

• IT Organizational Capabilities 

• Systems Acquisition Policies, Plans, and Practices

• Cost and Schedule

Conclusions

Recommendations

Agency Comments
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 8 GAO-03-880 Electronic Archive Acquisition

3

Introduction

The mission of the National Archives and Records Administration (NARA) is to ensure “ready

access to essential evidence” for the public, the President, the Congress, and the Courts.

NARA is responsible for oversight of records management and archiving, which increasingly 

involves dealing with documents that are electronically created and stored. Accordingly, 

NARA is acquiring an advanced Electronic Records Archives (ERA) system. 

• NARA’s goals are for this system to preserve and provide access to any kind of 

electronic record, free from dependency on any specific hardware or software, so that 

the agency can carry out its mission into the future. 

• According to NARA, the ERA system will be a distributed system, allowing storage and 

management of massive record collections at a variety of installations, with accessibility 

provided via the Internet. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 9 GAO-03-880 Electronic Archive Acquisition

4

Introduction

In June 2002, we issued a report that assessed the ERA program and NARA’s key 

organizational capabilities for acquiring a major information system.1 As we noted in that 

report, acquiring a major information technology (IT) system such as ERA is a significant

challenge for a relatively small organization like NARA, whose IT management capabilities 

are relatively limited. NARA has no previous experience in acquiring major information

systems.

In our 2002 report we recommended that the Archivist 

• revise the ERA project schedule so that it reflected estimates of the amount of work and 

resources required to complete each task, and schedule enough time for NARA to 

complete essential planning tasks, and

• strengthen IT management capabilities by 

(1) implementing an IT investment management process, 

(2) developing an enterprise architecture, and 

(3) improving information security. 

1 U.S. General Accounting Office, Information Management: Challenges in Managing and Preserving Electronic Records,

GAO-02-586 (Washington, D.C.: June 17, 2002).
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 10 GAO-03-880 Electronic Archive Acquisition

5

Objectives, Scope, and Methodology

Objectives

As agreed with the Subcommittee on Transportation, Treasury and Independent Agencies, 

House Appropriations Committee, our work focused on three objectives:

• What is the status of NARA’s efforts to establish organizational capabilities for acquiring 

major information systems?

• How do the ERA project’s system acquisition policies, plans, and practices conform to 

industry standards?

• How well is NARA meeting the ERA project’s cost and schedule goals? 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 11 GAO-03-880 Electronic Archive Acquisition

6

Objectives, Scope, and Methodology

Scope and Methodology

To accomplish our objectives, we

• obtained and evaluated policies and conducted interviews to determine the status of 

NARA’s efforts to establish organizational capabilities in IT investment management, 

enterprise architecture, and IT security;

• analyzed ERA system acquisition and project management documents, including the 

Acquisition Strategy, Life Cycle, and Concept of Operations.

• analyzed the project’s cost and schedule documents; 

• analyzed ERA risk management, program assessment, and verification and validation 

reports; and

• interviewed NARA information resource management and ERA program officials and 

contractor staff to understand the scope and contents of project documents and plans 

and to clarify information in supporting documentation.

In our review of the ERA program’s policies, plans, and practices, we evaluated the 

implementation of life cycle processes against the Institute of Electrical and Electronics 

Engineers (IEEE) standards selected by the program to guide the ERA acquisition, as well 

as applicable federal acquisition regulations and guidance.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 12 GAO-03-880 Electronic Archive Acquisition

7

Objectives, Scope, and Methodology 

We also reviewed NARA’s efforts to staff the ERA acquisition program.

We have requested the revised life cycle cost estimates for the ERA system, but these have 

not yet been provided. Consequently, we are currently unable to assess the current 

estimated life cycle costs and benefits of the proposed system.

We performed our work from July 2002 to May 2003 in accordance with generally accepted 

government auditing standards.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 13 GAO-03-880 Electronic Archive Acquisition

8

Results in Brief: Objective 1

Information Technology Management

NARA has made some progress in establishing capabilities for acquiring major information 

systems, but key IT organizational capabilities are not yet completely established. NARA is 

still working to establish its information technology investment management, enterprise 

architecture, and information security capabilities:

• NARA has strengthened its information technology investment management. 

• NARA is continuing to develop an enterprise architecture, but it does not plan to 

complete its target architecture in time to influence the ERA system definition and 

requirements.

• NARA completed some elements of an information security program, but several key 

areas have not yet been addressed, such as individual system security plans and 

certification and accreditation of its information systems.

Without strong IT organizational capabilities in place, the risk is increased that NARA will not 

be able to achieve cost, schedule, and performance objectives for information systems, 

including ERA.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 14 GAO-03-880 Electronic Archive Acquisition

9

Results in Brief: Objective 2 

Systems Acquisition

The ERA program has developed policies, plans, and practices to guide and manage its 

acquisition of the ERA system, and has elected to follow Institute of Electrical and 

Electronics Engineers (IEEE) standards in this effort. The ERA program intends to apply 

these standards to the development of the plans and policies that will guide the practices to 

be followed in acquiring the ERA system. However, in many cases, its policies, plans, and 

practices do not conform to the chosen standards or to applicable federal acquisition 

guidance. For example:

• Key policy and planning documents (such as the ERA Risk Management Plan, Quality

Assurance Plan, and Acquisition Strategy) are missing elements that are required by the 

standards and federal acquisition guidance. 

Such shortcomings in ERA policies, plans, and practices could result in serious long-term

risks to the cost, schedule, and performance of the ERA program.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 15 GAO-03-880 Electronic Archive Acquisition

10

Results in Brief: Objective 3 

Tracking Cost and Schedule

NARA is unable to objectively track the cost and schedule of the ERA project. The ERA 

schedule does not include all program tasks and lacks a work breakdown structure.

If NARA cannot track how well the ERA program is meeting cost and schedule, the likelihood 

is increased that ERA funds will not be used efficiently or effectively, quality problems will 

limit the usefulness of the ERA system, and the ERA system will not be delivered according 

to established milestones. 

To reduce the risks associated with NARA’s efforts to design and acquire the Electronic 

Records Archive, we are making several recommendations to the U.S. Archivist. 

In oral comments on a draft of this briefing, NARA generally agreed with our findings, 

conclusions, and recommendations.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 16 GAO-03-880 Electronic Archive Acquisition

11

Background

Acquisition Strategy

Developing the ERA Acquisition Strategy

NARA envisions ERA to be a major information system with the ability to authentically

preserve and provide access to massive volumes of all types and formats of electronic 

records, free from dependency on any specific hardware or software. The system may be 

based on persistent object preservation, a method of accommodating a variety of file formats 

that is the subject of research sponsored by NARA and other organizations. A leading 

candidate for capturing the necessary information is the Extensible Markup Language (XML),

which provides a means for “tagging” (annotating) information in a meaningful fashion that 

can be readily interpreted by disparate computer systems.3

3 For more information on XML, see our earlier report: U.S. General Accounting Office, Electronic Government: Challenges to 

Effective Adoption of the Extensible Markup Language, GAO-02-327 (Washington, D.C.: Apr. 5, 2002).
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 17 GAO-03-880 Electronic Archive Acquisition

12

Background

Acquisition Strategy

However, as pointed out in our earlier report,4 the solution to the electronic records archiving

challenge has yet to be developed. No electronic archive system exists that is comparable in 

complexity or scale to NARA’s vision.5 Further, some key technologies associated with 

electronic document archiving and storage are not yet available commercially. As a result, 

ERA is technically and managerially complex and challenging, requiring the development of 

an advanced architecture for the conversion and preservation of electronic records. 

To guide its acquisition of the ERA system, the ERA program has adopted IEEE standards

for software life cycle processes.6 The standards establish a common framework for the 

acquisition of software products and services, defines processes and tasks that are to be 

tailored and applied during the acquisition of a system, and identifies specific guidance 

applicable to the acquisition process. One standard identifies five primary processes: 

acquisition, supply, development, operations, and maintenance. 

4 U.S. General Accounting Office, Information Management: Challenges in Managing and Preserving Electronic Records,

GAO-02-586 (Washington, D.C.: June 17, 2002).

5 NARA officials believe that many relevant hardware and software components are available in the marketplace, and that

potential integrators have both an understanding of NARA’s needs and appropriate strategies for addressing them.

6 The Institute of Electrical and Electronics Engineers, 12207.0 Standard for Information Technology—Software Life Cycle

Processes; 12207.1 Standard for Information Technology—Software Life Cycle Processes—Life Cycle Data; and 12207.2

Standard for Information Technology—Software Life Cycle Processes—Implementation Considerations.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 18 GAO-03-880 Electronic Archive Acquisition

13

Background

Acquisition Strategy

The ERA program is currently in the acquisition life cycle process. It plans to take the 

following acquisition approach:

• define the ERA concept,

• develop ERA requirements,

• release a draft and final Request for Proposal,

• award two contracts for a design competition, and 

• based on the results of the competition, select a single contractor who will develop the 

ERA system in five increments, beginning in January 2005.

ERA also needs to follow applicable federal acquisition requirements for major information 

systems. Specifically, it was required to submit to OMB an evaluation of alternatives to be 

considered and to develop life cycle cost and benefit estimates of the proposed ERA system.

According to the acquisition schedule, shown on the following slide, development of the first

increment will take 2 years to complete and will encompass key ERA capabilities related to 

the records management process, while subsequent increments will add additional 

functionality and record types. 

The expected completion date for the development of the ERA system is December 2010.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 19 GAO-03-880 Electronic Archive Acquisition

14

Background

Acquisition Strategy

ERA Acquisition Schedule 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 20 GAO-03-880 Electronic Archive Acquisition

15

Background

Other NARA Initiatives

Other NARA Initiatives Related to Electronic Records

Besides the ERA acquisition, NARA’s strategy for archiving electronic records includes, 

among other things, three other initiatives:

• Expanding the capability of its current systems for archiving electronic records by 

accommodating additional electronic record formats and volumes.

• Through the Records Management Initiatives, revising NARA’s records disposition 

policies and processes, including reengineering of NARA’s life cycle management of 

records.

• Through the Electronic Records Management initiative, providing the guidance and 

tools that agencies need to manage their records in electronic form, including policy 

guidance on new electronic record formats accepted by NARA.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 21 GAO-03-880 Electronic Archive Acquisition

16

Background

Technical Assessments

National Academy of Sciences Assessment of ERA

NARA has funded two independent assessments of ERA by the National Academy of 

Sciences.

The first assessment, due in May 2003, is to assess the viability of an advanced architecture 

for file format conversion and encapsulation being researched by the National Partnership for

Advanced Computational Infrastructure. 

The second assessment is to 

• identify and evaluate alternative methods for digital preservation of records, 

• examine the operational use of the Internet for digital archiving,

• identify aspects of the preservation of electronic records that cannot be adequately 

addressed either by state-of-the art information technology or by technologies under 

development, and 

• determine the feasibility of commercializing new ideas from research. 

It is to be completed from 6 to 9 months after the first assessment.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 22 GAO-03-880 Electronic Archive Acquisition

17

Background

ERA Program Management

ERA Program Management

The ERA program management office is responsible for the development of ERA policies, 

plans, guidance, and procedures.

• NARA hired a contractor, Integrated Computer Engineering (ICE), Inc.,7 to assist in 

developing the capability to design, acquire, and manage the ERA system.

• ICE is responsible for developing many ERA acquisition documents and for validating 

and verifying that these documents conform to industry standards for content and 

structure.

The following slide shows the organizational chart for the program management office, 

showing government staff positions.8

7 On January 15, 2002, American Systems Corporation (ASC) announced its acquisition of ICE, Inc. According to the 

ERA project manager, this change does not affect the status of NARA’s contract with ICE, Inc.

8 According to NARA, it is considering organizational changes that are under review based on findings of its most recent 

assessment of the ERA program and other lessons learned. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 23 GAO-03-880 Electronic Archive Acquisition

18

Background

ERA Program Management

ERA Program Organization Chart
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 24 GAO-03-880 Electronic Archive Acquisition

19

Objective 1: IT Organizational Capabilities

In our earlier report, we recommended that the Archivist strengthen key IT organizational 

capabilities by 

(1) implementing an IT investment management process,

(2) developing an enterprise architecture, and 

(3) improving information security. 

NARA has made some progress in strengthening its capabilities in these areas, but they are

not yet completely established. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 25 GAO-03-880 Electronic Archive Acquisition

20

Objective 1: IT Organizational Capabilities 

IT Investment Management

IT Investment Management

An IT investment management process is an integrated approach to managing IT 

investments that provides for the continuous identification, selection, control, life cycle

management, and evaluation of IT investments. The Clinger-Cohen Act and OMB guidance 

emphasize the need to have investment management processes and information to help 

ensure that IT projects are being implemented at acceptable costs and within reasonable 

and expected time frames and that they are contributing to tangible, observable

improvements in mission performance (i.e., that projects are meeting the cost, schedule, and 

performance commitments upon which their approval was justified).

GAO’s Information Technology Investment Management (ITIM) maturity framework9 defines

critical processes pertaining to IT investment management and oversight. Among other

things these processes provide for establishing investment decision-making bodies 

responsible for selecting and controlling IT investments by (1) understanding, for example,

each project’s expected return on investment and associated costs, schedule, and 

performance commitments; (2) regularly determining each project’s progress toward these

expectations and commitments; and (3) taking corrective actions to address deviations. 

9 U.S. General Accounting Office, Information Technology Investment Management: A Framework for Assessing and

Improving Process Maturity (Exposure Draft), GAO/AIMD-10.1.23 (Washington, D.C.: May 2000).
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 26 GAO-03-880 Electronic Archive Acquisition

21

Objective 1: IT Organizational Capabilities 

IT Investment Management

NARA has taken steps to strengthen its IT investment management processes. Among the 

actions it has completed are the following:

• NARA has established an IT investment review board, which receives monthly briefings 

on strategic projects covering schedule and risks.

• NARA has updated its directive addressing IT investment management.

• Initial versions of policy documentation have been completed for two of the three phases 

of IT investment management: control and evaluation.

• NARA has completed interim guidance for analyzing the life cycle benefits, costs, and 

risks of IT.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 27 GAO-03-880 Electronic Archive Acquisition

22

Objective 1: IT Organizational Capabilities 

Enterprise Architecture

Enterprise Architecture

An enterprise architecture provides a description—in useful models, diagrams, and 

narrative—of the mode of operation for an agency. It describes the agency in both 

(1) logical terms, such as interrelated business locations and users; and 

(2) technical terms, such as hardware, software, data, communications, and security 

attributes and standards. 

An enterprise architecture provides these perspectives both for the “as is” environment 

(baseline) and for the “to be” environment (target). It also consists of technical reference 

model and technical standards used by the agency, as well as a plan to transition from the 

baseline to the target environment. 

NARA has ongoing efforts to complete an enterprise architecture, which are expected to 

continue over the next 2 years. It developed initial versions of its enterprise architecture, 

including a baseline and target architecture, a technical reference model, and standards 

profile. According to NARA’s Chief Technology Officer, while this initial effort provided a 

basis for an architecture, it was not complete and NARA is continuing to develop a more 

comprehensive version.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 28 GAO-03-880 Electronic Archive Acquisition

23

Objective 1: IT Organizational Capabilities 

Enterprise Architecture

Beginning in July 2003, NARA plans to address a number of activities associated with its

enterprise architecture, including 

• procuring and installing software tools to manage the development of its enterprise 

architecture,

• continuing to refine data management processes and definitions, and

• establishing an information security architecture. 

NARA has not completed the definition of its “to be” architecture, which will provide a 

framework for defining the ERA system’s requirements. The ERA program currently plans to 

complete the definition of requirements by the end of June 2003.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 29 GAO-03-880 Electronic Archive Acquisition

24

Objective 1: IT Organizational Capabilities 

Information Security

Information Security

Federal legislation and guidance for information security require organizations, among other

things, to establish an information security program, including the following activities:

• Develop information security policy and procedures.

• Develop system security plans for networks, facilities, and systems or groups of 

information systems.

• Perform risk assessments.

• Determine the sensitivity and criticality of systems.

• Establish certification and accreditation programs for information systems.

As a result of security assessments conducted by NARA and its Inspector General, the 

Archivist declared NARA’s information security a material weakness in fiscal year 2000; it 

remains a material weakness. 

In response to the recommendations in our earlier report, NARA has taken steps to establish 

an information security program. In fiscal year 2002, NARA 

• completed an information security policy and security control handbooks, 

• addressed several information security vulnerabilities, and 

• conducted a limited vulnerability assessment and risk analysis of NARA’s network. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 30 GAO-03-880 Electronic Archive Acquisition

25

Objective 1: IT Organizational Capabilities 

Information Security

However, NARA’s IT security program is incomplete in several areas, including the following:

• Security plans for all NARA systems have not been developed.

• NARA has not implemented a security risk assessment program. 

• It has not determined the sensitivity and criticality of systems.

NARA indicated that in fiscal year 2003, it plans to

• complete certification and accreditation of 41 IT systems, and

• address outstanding security risks and remove security as a material weakness. 

Nevertheless, without a fully established information security program, the risk to the planned 

ERA system and its archived data is increased. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 31 GAO-03-880 Electronic Archive Acquisition

26

Objective 2: Systems Acquisition

Policies, Plans, and Practices

To guide its acquisition of the ERA system, the program has adopted an IEEE standard for

software life cycle processes (IEEE 12207 and associated standards). These standards were 

expected to be used in developing the life cycle plan and processes that the program is 

following to acquire the ERA system: 

• developing the ERA Life Cycle document,

• defining a concept of operations,

• developing requirements,

• creating an acquisition strategy,

• performing risk management,

• performing configuration management, and

• conducting quality assurance.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 32 GAO-03-880 Electronic Archive Acquisition

27

Objective 2: Systems Acquisition 

ERA Life Cycle

ERA Life Cycle 

The ERA Life Cycle document describes the life cycle of the ERA system from 

conceptualization of ideas through retirement, as well as processes for acquiring and 

supplying software products and services for the ERA system. 

However, the ERA Life Cycle document does not meet all applicable IEEE standards:

• It states that it was tailored to the IEEE 12207 standards but fails to identify which 

elements were excluded or modified.

• It does not document key activities, such as the processes, activities, and tasks needed 

for contract preparation, including all tasks associated with development of the Request 

for Proposal.

• It does not show the proposed approach, including the design competition and the 

incremental approach. 

Without a complete, well-documented life cycle that meets applicable standards, NARA and 

the ERA program are impeded in their ability to manage and track key acquisition processes

and activities.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 33 GAO-03-880 Electronic Archive Acquisition

28

Objective 2: Systems Acquisition

Concept of Operations

Concept of Operations

According to IEEE standards, the Concept of Operations is a user-oriented document that 

describes the characteristics of a proposed system from the users' viewpoint. The document 

becomes the framework for all subsequent activities leading to system deployment. The 

IEEE standard describes key elements that should be included in this document, including 

major system components, interfaces to external systems, and performance characteristics 

such as speed, throughput, and volume.

The ERA Concept of Operations describes the high-level operational characteristics of the 

ERA system from the viewpoint of the users, developer, and other stakeholders. The 

Concept provides justification for the proposed system, identifies classes of ERA users, and 

describes operational scenarios. It does not include several key elements required by the 

IEEE standard, including

• a complete description of the proposed system, 

• the system’s modes of operation under different circumstances (for example, regular,

degraded, emergency, backup, etc).

The ERA program is planning to update its Concept of Operations to address these elements 

by August 18, 2003.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 34 GAO-03-880 Electronic Archive Acquisition

29

Objective 2: Systems Acquisition 

ERA Requirements

ERA Requirements 

Requirements provide the blueprint that system developers and program managers use to 

design, develop, and acquire a system. It is critical that requirements be carefully defined 

and that they flow directly from the organization’s concept of operations (how the 

organization’s day-to-day operations are or will be carried out to meet mission needs). 

ERA requirements are currently being defined; NARA expects them to be completed by June 

30, 2003. 

Accordingly, we did not review them for their conformance to industry standards.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 35 GAO-03-880 Electronic Archive Acquisition

30

Objective 2: Systems Acquisition

Acquisition Strategy

Acquisition Strategy

An acquisition strategy is a description of how an organization plans to acquire a system. It

establishes the framework by which detailed acquisition planning and program execution will 

be accomplished and communicated to key stakeholders. For ERA, the acquisition strategy

should conform to IEEE standards and must conform to the Federal Acquisition Regulation 

(FAR) for acquisition planning. 

The ERA Acquisition Strategy does not fully conform to applicable standards, according to 

an assessment by the ERA program:

• It does not satisfy all FAR requirements: 28 of 39 content requirements are not satisfied,

including the identification of acquisition risks, the description of the ERA cost model and 

life cycle costs, and the establishment of detailed milestones for the acquisition process.

• It does not meet all IEEE standards: 15 of 32 content requirements are not satisfied, 

including the establishment and implementation of an acquisition planning strategy, 

standards for the preparation of contract requirements, and criteria for the selection of a 

qualified supplier.

Unless it adheres to these standards and requirements, NARA increases the risk that its

strategy will not be clearly understood by key stakeholders.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 36 GAO-03-880 Electronic Archive Acquisition

31

Objective 2: Systems Acquisition 

Risk Management

Risk Management

In acquisition, risk management is a process for identifying potential problems before they 

occur and adjusting the acquisition to mitigate problems and to decrease the chance of their 

occurring. Risk management includes developing a project risk management plan; identifying 

and prioritizing potential problems; implementing risk mitigation strategies, as required; and 

tracking and reporting progress against the plans. 

NARA has developed an ERA Risk Management Plan. However, the ERA program has not 

fully established a risk management process to comply with IEEE requirements:

• In the ERA Risk Management Plan, the risk planning policy is incomplete. For example, 

the plan does not discuss how resources are to be made available to treat risks or how 

risks are to be communicated to and reviewed by stakeholders. 

• The plan is written at a high level of generality and has not been defined specifically for

the ERA program. For example, procedures for risk identification and risk analysis are 

not specific to the ERA program.

In the absence of a fully established risk management process, NARA may miss 

opportunities to avoid or mitigate predictable risks in its ERA acquisition. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 37 GAO-03-880 Electronic Archive Acquisition

32

Objective 2: Systems Acquisition 

Configuration Management

Configuration Management Plan

The ERA Configuration Management Plan, based on the IEEE standard, is intended to 

establish and maintain the integrity and control of the products of the ERA program through 

its life cycle. The IEEE standard for software configuration plans describes classes of 

information that should be included in the plan. These include identifying

• who is responsible for accomplishing planned activities,

• what configuration management project activities are to be performed,

• when, in relation to other project activities, the activities are to be scheduled, and 

• what tools and human resources are required for executing the plan.

A verification and validation assessment of the Configuration Management Plan by ERA 

contractors found that while the plan did not satisfy all of the above IEEE requirements, the 

amount of information included in the plan was appropriate for the point in the acquisition 

process at which it was written. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 38 GAO-03-880 Electronic Archive Acquisition

33

Objective 2: Systems Acquisition 

Quality Assurance

Quality Assurance

In IT acquisition, quality assurance describes processes for providing independent 

assessment of the requirements and processes for developing and producing a system or 

software. Quality assurance includes developing a quality assurance plan, determining

applicable processes and product standards to be followed, and conducting reviews to 

ensure that the product and process standards are followed. Quality assessments should 

take place throughout the life cycle of an acquisition.

The ERA program has developed the ERA Quality Assurance Plan, which references IEEE 

standards for software quality assurance. However, elements required by the standard are 

absent. For example, the plan

• does not include ERA documentation to be reviewed,

• lacks criteria by which to assess documentation,

• does not specify quality assurance tasks to be performed, and

• lacks estimates of resources to be expended.

Without a fully established quality assurance plan, the ERA program is at risk of generating 

products that do not meet requirements.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 39 GAO-03-880 Electronic Archive Acquisition

34

Objective 2: Systems Acquisition

Policies, Plans, and Practices

In addition to the life cycle processes described by IEEE standards, ERA is subject to federal 

acquisition requirements.10 Among other things, these call for

• an evaluation of alternatives to be considered and 

• the development of life cycle cost and benefit estimates of proposed systems.

Also associated with the ERA acquisition process are NARA’s efforts to staff the ERA

acquisition program.

10 Office of Management and Budget Circular A-109, Major System Acquisitions; OMB Circular A-11, Preparing and 

Submitting Budget Estimates.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 40 GAO-03-880 Electronic Archive Acquisition

35

Objective 2: Systems Acquisition 

ERA Staffing

ERA Staffing

NARA has made progress in staffing the ERA program, but staffing may pose a risk to ERA. 

NARA has determined that to carry out the acquisition tasks discussed earlier, it will need 46 

staff: 24 government staff and 22 contractor staff. According to program officials, funding 

shortfalls have prevented them from hiring the needed ERA staff. Currently, all 22 contractor

staff are onboard, but only 15 of the 24 projected ERA government staff have been hired. 

Although we have not evaluated the appropriate staffing level, some staffing shortages are

significant. Three key government positions—the business manager and contract and 

financial management specialists—are yet to be hired. In addition, staff for other key 

positions were only recently hired: the chief system engineer and the risk management and 

quality assurance specialists. All these positions are important to the quality and 

completeness of key program processes.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 41 GAO-03-880 Electronic Archive Acquisition

36

Objective 3: Tracking Cost and Schedule 

A project schedule with an appropriate work breakdown structure is a prerequisite to 

program tracking, allowing managers to measure how well the program is achieving its cost 

and schedule goals. The work breakdown structure should be detailed enough to expose all 

risk factors and allow accurate estimates of resource requirements and schedule duration for

each work activity. Each major work activity should include standard elements such as 

assigned personnel, resource budgets, estimated task duration, and dependencies among 

work activities. 

Work activities can be measured through performance-based techniques such as earned 

value management, which allows managers to track the budget against the schedule. 

“Earned value” may be used to determine if work is being done at a higher or lower 

cost/performance rate than was planned.

OMB requires the use of such techniques in the monitoring of the cost, schedule, and 

performance of system acquisition projects.14

14 Office of Management and Budget Circular A-11.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 42 GAO-03-880 Electronic Archive Acquisition

37

Objective 3: Tracking Cost and Schedule

In our 2002 report, we recommended that the ERA project schedule be revised to reflect 

estimates of the amount of work and resources required to complete each task, and that 

NARA schedule enough time to complete essential planning tasks.

While the ERA program has developed a more detailed project schedule that includes 

standard elements, NARA has not yet fully carried out our recommendation, as these 

elements are not yet complete:

• The project schedule omits significant tasks and activities, including

• the process to reengineer the agency’s life cycle business processes, upon which 

ERA requirements are being developed, and

• the activity by ERA contractors to verify and validate ERA project management and 

acquisition documentation for conformance to industry standards.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 43 GAO-03-880 Electronic Archive Acquisition

38

Objective 3: Tracking Cost and Schedule 

NARA has indicated that it plans to use earned value management to assess performance

programwide, but this plan has not yet been implemented.

• In the absence of a program schedule that includes all program tasks and a work 

breakdown structure with associated costs, the ERA program cannot use earned value 

management to track ERA cost and schedule. 

The lack of earned value management impairs NARA’s ability to track and meet future 

project milestones.

The ERA program is in an early phase of acquisition planning and has not yet been required 

to meet many significant milestones. To date, NARA has met a major ERA milestone—the 

definition of the ERA concept. 

Meeting major milestones will become more important and more challenging in later phases 

of the acquisition. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 44 GAO-03-880 Electronic Archive Acquisition

39

Conclusions

In acquiring ERA, NARA faces significant challenges. ERA will be a major information

system; NARA has no previous experience in acquiring major information systems. Further,

no comparable electronic archive system is now in existence, in terms of either complexity or

scale. Finally, technology necessary to address some key requirements of ERA is not 

commercially available and will have to be developed. 

In light of these challenges, NARA will face significant difficulties in its ERA acquisition 

unless it addresses 

• its IT organizational capabilities;

• ERA system acquisition policies, plans, and practices; and

• its ability to control ERA’s cost and schedule. 

NARA has made progress implementing the key management areas of IT investment 

management, enterprise architecture, and IT security, but NARA has more work to do to 

implement our prior recommendations in this area. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 45 GAO-03-880 Electronic Archive Acquisition

40

Conclusions

Without strong acquisition policies, plans, and practices, the risk is increased that the ERA 

system will fail to meet user expectations, will cost more than currently estimated, and will be

delivered later than currently planned. Specifically, NARA and the ERA program have not 

• followed the IEEE 12207 standards and associated guidance in defining and managing 

the ERA acquisition process, 

• developed ERA acquisition processes and associated documentation in sufficient detail 

to allow program managers and NARA executives to manage and oversee the program,

or

• implemented the defined acquisition processes and practices according to these 

documented policies and plans.

Further, NARA is unable to effectively track and assess the status of the ERA program 

because its program schedule does not include all program tasks and lacks a work 

breakdown structure. 
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 46 GAO-03-880 Electronic Archive Acquisition

41

Recommendations

To reduce the risks associated with NARA’s efforts to design and acquire the Electronic 

Records Archives, we recommend that the U.S. Archivist direct the NARA Chief Information 

Officer to do the following:

• Address weaknesses in the acquisition policies, plans, and practices by

• revising the ERA Life Cycle document and associated procedures and practices to 

conform to IEEE standards;

• revising the ERA Concept of Operations to conform to IEEE standards, including a 

complete description of the current and proposed systems;

• revising the ERA Acquisition Strategy to conform to IEEE standards and the Federal 

Acquisition Regulation;

• revising the ERA Risk Management Plan to provide processes and procedures

specific to the ERA program; 

• revising the ERA Quality Assurance Plan to conform to appropriate industry

standards, establishing a vigorous, independent ERA quality assessment process, 

and providing the staffing resources necessary to ensure that quality assessment 

duties are performed effectively; and

• filling key vacant ERA positions.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 47 GAO-03-880 Electronic Archive Acquisition

42

Recommendations

• Immediately address weaknesses in tracking cost and schedule by 

• developing an ERA schedule that is based on a comprehensive work breakdown

structure (including associated costs and other resources) and establishes 

dependencies between successor and predecessor tasks; and 

• Using earned value management to capture and monitor progress for the entire ERA 

program.
Appendix I

National Archives and Records 

Administration’s Acquisition of Electronic 

Records Archives

Page 48 GAO-03-880 Electronic Archive Acquisition

43

Agency Comments

NARA provided us with oral comments on a draft of this briefing during a meeting held on 

April 24, 2003, attended by the Deputy Archivist, the ERA program manager, and other

agency officials. These officials generally agreed with our findings, conclusions, and 

recommendations. They indicated that NARA is already addressing the weaknesses in 

ERA’s acquisition policies, plans, and practices identified through a verification and validation 

activity. NARA officials also provided clarifications and additional technical comments, which 

we have incorporated into the briefing as appropriate. 
Page 49 GAO-03-880 Electronic Archive Acquisition

Appendix II

Comments from the National Archives and 

Records Administration ApendxiI
Appendix II

Comments from the National Archives and 

Records Administration

(310371) Page 50 GAO-03-880 Electronic Archive Acquisition
GAO’s Mission The General Accounting Office, the audit, evaluation and investigative arm of 

Congress, exists to support Congress in meeting its constitutional responsibilities 

and to help improve the performance and accountability of the federal government 

for the American people. GAO examines the use of public funds; evaluates federal 

programs and policies; and provides analyses, recommendations, and other 

assistance to help Congress make informed oversight, policy, and funding 

decisions. GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

Obtaining Copies of 

GAO Reports and 

Testimony

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and fulltext files of current reports and testimony and an expanding archive of older 

products. The Web site features a search engine to help you locate documents 

using key words and phrases. You can print these documents in their entirety, 

including charts and other graphics.

Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its Web site 

daily. The list contains links to the full-text document files. To have GAO e-mail this 

list to you every afternoon, go to www.gao.gov and select “Subscribe to 

e-mail alerts” under the “Order GAO Products” heading.

Order by Mail or Phone The first copy of each printed report is free. Additional copies are $2 each. A check 

or money order should be made out to the Superintendent of Documents. GAO 

also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a single 

address are discounted 25 percent. Orders should be sent to:

U.S. General Accounting Office

441 G Street NW, Room LM

Washington, D.C. 20548

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Public Affairs Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Service Requested

Presorted Standard

Postage & Fees Paid

GAO

Permit No. GI00