INFORMATION 

TECHNOLOGY

SBA Needs to 

Strengthen Oversight 

of Its Loan 

Management and 

Accounting System 

Modernization

Report to the Chairman, Committee on 

Small Business, House of 

Representatives

January 2012

GAO-12-295

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-295, a report to the 

Chairman, Committee on Small Business, 

House of Representatives

January 2012

INFORMATION TECHNOLOGY 

SBA Needs to Strengthen Oversight of Its Loan 

Management and Accounting System Modernization

Why GAO Did This Study

The Small Business Administration 

(SBA) performs a range of significant 

activities intended to strengthen small 

businesses and relies extensively on 

information technology (IT) systems to 

do so. These systems are used to 

support loan accounting and track 

loans through origination, servicing, 

and liquidation. SBA has been 

attempting to modernize these systems 

for several years through its Loan 

Management and Accounting System 

(LMAS) modernization effort. The most 

recent iteration of this effort is a series 

of more focused development efforts, 

known as the LMAS-Incremental 

Improvement Projects (IIP). 

GAO was asked to describe the status 

of SBA’s LMAS modernization effort 

and determine whether SBA has 

adequate processes and procedures in 

place to manage and oversee its 

LMAS modernization effort. In 

performing this work, GAO reviewed 

cost and schedule reports to Congress 

and assessed SBA’s current 

management of the projects against 

best practices and relevant guidance. 

What GAO Recommends

GAO is recommending that the 

Administrator of SBA ensure that 

appropriate IT management practices

are applied to the projects as 

described in this report and clarify the 

responsibilities of the executive bodies 

with purview over the LMAS-IIPs and 

ensure they provide the appropriate 

oversight of the projects’ progress. 

What GAO Found

As of October 2011, SBA had completed one of the seven projects and awarded 

contracts for work on three others. However, the projects are experiencing 

increasing costs and schedule delays. Specifically, according to the most recent 

project schedule, SBA completed one project in May 2011, 2 months later than 

planned, and SBA expects five of the remaining six projects to finish between 4 

and 11 months later than the dates reported to Congress. Further, according to 

the agency’s most recent report to Congress, dated March 2011, the total cost of 

the projects increased approximately $5 million since October 2010. SBA plans 

to complete the seven IIPs at a total cost of approximately $28 million by July 

2013.

SBA has inconsistently implemented key information technology management 

practices for successfully managing and overseeing its LMAS modernization 

efforts; these practices include software requirements management, risk 

management, IT human capital management, enterprise architecture, and 

investment management (see table below). For example, SBA appropriately 

managed changes to IIP requirements, identified risks for three of four active 

projects, inventoried existing human capital capabilities, drafted target segment 

architectures, and had the overall direction of the IIP effort approved by an 

executive review committee. However, it has not fully implemented other key 

aspects of these practices and policies. For example, it did not validate the 

requirements for one of the ongoing IIPs. Also, the agency did not fully prioritize 

risks related to one IIP or plan to mitigate them. In addition, it did not fully identify 

gaps in project workforce skills, and did not fully implement basic enterprise 

architecture practices, including maintaining and prioritizing its segment 

architectures, which provide the modernization details needed to develop and 

implement portions, or segments, of an agency’s IT portfolio. In addition, the cost 

baselines approved by SBA’s executive oversight body differ from the projected 

costs reported to Congress 2 months later. Further, there is no evidence that the 

projects have approved schedule baselines. These weaknesses in basic 

management practices make it less likely that SBA will be able to complete the 

projects within the time, budget, and scope parameters originally planned. 

Summary of SBA Implementation of Key IT Management Controls

IT management control Rating

Software requirements management Partially implemented

IT risk management Partially implemented

IT human capital management Partially implemented

Enterprise architecture Partially implemented

IT investment management Partially implemented

Source: GAO analysis of SBA data.

Inconsistencies in SBA’s application of IT management practices occurred, in 

part, because it did not provide adequate executive oversight through its 

investment management process, even though it is using two executive boards

to oversee the IIPs. While these boards have overlapping responsibilities and 

lines of authority, several basic oversight responsibilities, including executive 

approval of the project’s schedule, were left unaddressed by either body. 

View GAO-12-295. For more information, 

contact David A.Powner at (202) 512-9286 or 

pownerd@gao.gov. 
Page i GAO-12-295 Information Technology

Letter 1 

Summary 2

Conclusions 5

Recommendations for Executive Action 6

Agency Comments 7

Appendix I Briefing to the Staff of the House Committee on Small Business 9

Appendix II Comments from the Small Business Administration 60

Appendix III GAO Contact and Staff Acknowledgments 63

Table

Table 1: IIP Initial and Current Expected Completion Dates and 

Projected Costs 4

Contents
Page ii GAO-12-295 Information Technology

Abbreviations

BTIC Business Technology Investment Council

CMMI Capability Maturity Model—Integration

COBOL Common Business Oriented Language

EA enterprise architecture

EAMMF Enterprise Architecture Management Maturity Framework

FSAB Financial Systems Advisory Board

IIP Incremental Improvement Project

IT information technology

ITIM information technology investment management

LAS Loan Accounting System

L/LMS Loan and Lending Monitoring System

LMAS Loan Management and Accounting System

OIG Office of Inspector General

OMB Office of Management and Budget

SBA Small Business Administration

SEI Software Engineering Institute

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United States. The published product may be reproduced and distributed in its entirety 

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Page 1 GAO-12-295 Information Technology

United States Government Accountability Office

Washington, DC 20548

January 25, 2012

The Honorable Sam Graves

Chairman

Committee on Small Business

House of Representatives

Dear Mr. Chairman:

The Small Business Administration (SBA) performs a range of significant 

activities intended to strengthen small businesses. To accomplish these 

activities, SBA relies extensively on information technology (IT) systems. 

Among these are financial systems used to support loan accounting and 

track loans through origination, servicing, and liquidation. The loan 

systems, collectively called the Loan Accounting System, were 

implemented in the 1970s and outsourced to be run on a contractor’s 

mainframe hardware. SBA has been pursuing efforts to upgrade and 

modernize its financial systems for several years. 

The current effort, referred to as the Loan Management and Accounting 

System (LMAS) program, dates from 2005 and was a response to 

concerns about the age and information security risks of the legacy 

system. The effort was intended to result in a single, integrated loan 

management and loan accounting solution. However, after an 

independent study and two reviews by the Office of Management and 

Budget (OMB) raised concerns about SBA’s management of the program, 

it was restructured into a series of seven more focused projects with 

shorter time frames, referred to as LMAS-Incremental Improvement 

Projects (IIP). 

As agreed, our objectives were to: (1) describe the status of SBA’s LMAS 

modernization effort; and (2) determine whether SBA has adequate 

processes and procedures in place to manage and oversee its LMAS 

modernization effort.

To describe the status of SBA’s LMAS modernization effort, we analyzed 

pertinent LMAS documentation—such as program schedules, plans, 

budget justifications, cost and schedule data, reports provided to 

congressional committees, and documents provided to OMB—and we 

interviewed agency officials. We then compared cost and schedule 

information to recently published reports to Congress to determine the 

progress to date of the program.

 
 

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To determine whether SBA has adequate processes and procedures in 

place to manage and oversee its LMAS modernization effort, we 

evaluated its capabilities to employ the following IT management controls, 

which are critical to the success of a systems modernization effort:

software requirements management, IT risk management, IT human 

capital management, enterprise architecture, and information technology 

investment management. For each of these controls, we determined how 

SBA applied the practices to the four IIPs for which development efforts 

are complete or in progress or for which contracts had been awarded by 

analyzing pertinent documentation—such as policies, procedures, plans, 

meeting minutes, risk logs, and software requirements, and by 

interviewing agency officials. We then compared the information collected 

to key aspects of federal guidance, best practices, and SBA policies.

We conducted this performance audit from February 2011 to January

2012 in Washington, D.C., in accordance with generally accepted 

government auditing standards. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

On November 18, 2011, we transmitted the results of our review to the 

staff of the House Committee on Small Business. This report transmits 

the briefing materials we provided and the recommendations we made to 

the Administrator of SBA. The full briefing materials, including the full 

details on our scope and methodology, are reprinted in appendix I.1

In summary, we made the following points:

 

As of October 2011, SBA had completed one of the seven LMASIncremental Improvement Projects, and awarded contracts for three 

others. Specifically, it completed the first project, an upgrade of its internal 

administrative accounting and management system, in May 2011. A 

contract has been awarded for another project—to migrate user 

interfaces from a legacy mainframe platform to SBA’s current web-based 

 

1

In comments on the original briefing reprinted in appendix I, officials cited concerns with 

publicly releasing estimates for contracts not yet awarded by SBA. Accordingly, we 

redacted this information from the attached briefing.

Summary
 

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infrastructure—which is being deployed incrementally. In addition, SBA 

has awarded contracts to conduct assessments of work to be done for 

two other IIPs—addressing the conversion of code in a legacy mainframe 

environment to a nonproprietary platform and a migration of legacy 

database systems at its Denver office to its current database 

infrastructure. For the three remaining projects, the agency intends to 

build off of the work completed as a result of the first four projects 

identified earlier in this report. SBA has begun planning for one of these, 

and work has yet to begin for the remaining two IIPs.

Even though the agency only received approval to pursue the IIPs in 

January 2011, the projects are already experiencing increased costs and 

schedule delays. Specifically, according to the most recent project 

schedule, dated August 2011, it completed one IIP in May 2011, 2 

months later than planned. In addition, the agency expects five of the 

remaining six projects to finish between 4 and 11 months later than the 

dates reported to Congress in October 2010. Further, according to its

most recent report to Congress, dated March 2011, the total cost of the 

IIPs increased approximately $5 million since October 2010, while the 

projected individual project cost for each of the seven projects had risen 

between approximately 3 and 53 percent. SBA plans to complete the 

seven projects at a total cost of approximately $28 million by July 2013, 

which is an overall increase of about 22 percent. Table 1 provides details 

on the status of the individual projects with contracts awarded.
 

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Table 1: IIP Initial and Current Expected Completion Dates and Projected Costs

LMAS-IIP Current status

Expected 

completion date 

as of October 

2010

Expected 

completion date 

as of August 

2011

Projected cost 

as of October 

2010 (in 

millions)

Projected cost 

as of March 

2011 (in 

millions)

Percentage 

increase in 

projected costs

Oracle Upgrade Completed in May 

2011

March 2011 Completed in May 

2011

$8.45 $8.66 2.5%

Migration of 

User Interfaces

Contract awarded 

and work in 

progress

December 2011 May 2012 3.32 3.76 13.3

Migrate to New 

Version of 

COBOL

Contract awarded 

to conduct 

assessment

May 2012 April 2013 6.05 8.72 44.1

Sybase to 

Oracle Migration

Contract awarded 

to conduct 

assessment

October 2011 September 2012 2.51 3.11 23.9

Source: GAO analysis of SBA data.

SBA has inconsistently implemented key practices for successfully 

managing and overseeing its LMAS modernization efforts; these practices 

include software requirements management, IT risk management, IT 

human capital management, enterprise architecture, and IT investment 

management: 

• Requirements management. SBA appropriately managed changes to 

requirements for the two projects for which this process would be 

appropriate; however, it did not validate the requirements for one of 

the ongoing IIPs. In addition, requirements were not documented for 

two of the ongoing projects. 

• Risk management. Risks were identified for three of four active 

projects; however, it did not fully prioritize risks related to one IIP or 

develop plans to mitigate them.

• IT human capital management. SBA inventoried existing human 

capital capabilities; however, it did not fully identify gaps in project 

workforce skills and did not develop strategies to close them. 

• Enterprise architecture. SBA drafted target segment architectures for 

the IIPs; however, they have not been approved by the appropriate 

officials. In addition, the agency did not fully implement other basic 

enterprise architecture practices, including maintaining and prioritizing 

its segment architectures.
 

Page 5 GAO-12-295 Information Technology

• IT investment management. The agency had the overall direction of 

the IIP effort approved by an executive review committee. However, 

SBA did not address other capital planning requirements for the 

program, including approving a schedule baseline or reviewing its risk 

management plan, or provide evidence that it approved the 

subsequent changes to the budget estimates reported to Congress.

Inconsistencies in SBA’s application of IT management practices 

occurred, in part, because it did not provide adequate executive oversight 

through its investment management process, even though it is using two 

executive bodies to oversee the projects. While these bodies have 

overlapping responsibilities and lines of authority, several basic oversight 

responsibilities, including executive approval of the project’s schedule, 

were left unaddressed by either body. In addition, the cost baselines 

approved by SBA’s executive oversight body differ greatly from the 

projected costs reported to Congress 2 months later. According to SBA 

officials, additional oversight was provided through undocumented 

meetings and reviews of reports to Congress. These weaknesses in the 

use of basic management practices make it less likely that SBA will be 

able to complete the IIPs within the time, budget, and scope parameters 

originally planned.

SBA has completed one of the seven IIPs, work is underway on one 

other, and contracts have been awarded for two more. However, most of 

the projects are already experiencing individual schedule delays of 4 to 

11 months and an overall cost increase of about 22 percent, which 

increases the risk that SBA will not be able to deliver the projects as 

planned. 

SBA’s likelihood of successfully completing the projects would improve if 

it more consistently applied basic IT management practices. SBA has 

taken a number of steps that are consistent with sound IT management. 

For example, it has identified and validated system requirements and has 

identified system development risks as well as plans to mitigate them, but 

it has not done so consistently for each of its ongoing projects. Also, it 

has taken several actions consistent with sound enterprise architecture 

and human capital management practices, including developing segment 

architectures and identifying staff positions needed to complete the IIPs. It 

has not, however, fully applied other sound practices in these areas, 

including maintaining and prioritizing the segment architectures and 

developing a strategy to meet outstanding human capital needs. Given 

Conclusions 
 

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that SBA has been unable to successfully complete prior efforts to 

modernize its loan systems, the consistent use of sound IT management 

practices will be critical to reducing the risk of its new approach 

encountering similar difficulties.

Weaknesses in executive oversight of the IIPs have contributed to SBA’s 

inconsistent use of sound IT management practices and increase the 

likelihood that the projects will experience delays or cost overruns. In 

particular, its use of two oversight bodies with overlapping responsibilities 

and lines of authority is likely to lead to continued duplication or gaps in 

oversight, such as the lack of documented schedule and cost baselines 

for the projects. The gaps, in particular, make it difficult for SBA to 

conduct the necessary oversight of project progress. In addition, 

addressing these weaknesses in executive oversight should result in 

more effective management of program progress and more timely 

decisions about adjustments needed to arrest or reverse the schedule 

delays and cost overruns that have already occurred.

To better ensure that the loan management incremental improvement 

projects are completed as planned and provide anticipated capabilities, 

we are recommending that the Administrator of SBA direct the Chief 

Information Officer to ensure that SBA is applying the appropriate 

information technology management practices to the IIPs. Specifically, 

SBA should ensure that

• IIP requirements are managed appropriately, including elicitation, 

documentation, and verification and validation; 

• IT risks to the IIPs are adequately managed, including preparing for 

risk management, identifying and analyzing risks, mitigating risks, and 

providing executive oversight of risk management activities; 

• the human capital necessary for the IIPs is managed appropriately, 

including the determination of human capital needs, the identification 

of gaps between current capabilities and needs, the development of a 

strategy to close those gaps, and the documentation of these 

activities; and

• the enterprise architecture segments related to the IIPs are managed 

appropriately, including the development, prioritization, and 

maintenance of the segments.

Recommendations for 

Executive Action
 

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In addition, we recommend that the Administrator of SBA clarify the 

responsibilities of the executive bodies responsible for the IIPs and 

ensure they provide the appropriate oversight of the project’s progress. 

Specifically, these executive bodies should conduct and document 

executive review and approval of the LMAS modernization’s

• risk management approach;

• target segment architectures; and

• cost and schedule baselines, including ongoing oversight of progress 

against those baselines.

In written comments on the draft of this report, the Small Business 

Administration’s Assistant Administrator, Office of Congressional and 

Legislative Affairs, stated that SBA generally agreed with our 

recommendations (see Appendix II). The Assistant Administrator also 

asked that we clarify two points. First, he stated that the costs of the 

LMAS modernization had not increased, and that the figures we included 

from an October 2010 report to Congress included only contractor costs 

while the figures from a March 2011 report included both contractor and 

government costs. However, the documents provided by SBA do not 

specify that the two reports describe different costs. Specifically, while the 

Congressional letter that requested the October 2010 report asked for 

“contract costs to date,” it also asked for “future obligations and expected 

future costs.” Also, the report itself does not state that the future costs 

include only contractor costs. We used these two reports as sources of 

cost data for the modernization because they were the only sources 

available at the time of our initial review. Further, this disagreement on 

the projected cost of the modernization reinforces the need for an

approved cost and schedule baseline that can be used to evaluate 

program progress, as discussed in our briefing. 

Second, the Assistant Administrator stated that SBA’s executive oversight 

bodies reviewed the LMAS modernization’s overall schedule and cost 

estimates through both formal and informal discussions, including 

executive-level meetings in August and September 2010. We considered 

this information in our initial assessment, but do not believe that the 

records he cites demonstrate that SBA is maintaining current cost or 

schedule baselines. Our briefing notes the inclusion of initial cost 

estimates for each of the improvement projects in the August executive 

discussion. However, we also note that even though SBA reported 

Agency Comments
 

Page 8 GAO-12-295 Information Technology

different cost estimates in subsequent reports to Congress, we did not 

find evidence of executive approval of changes to the budget after August 

2010. In addition, while the minutes of the August 2010 discussion 

include a single estimated completion date for the IIP effort, they do not 

specify the estimated completion dates for each project. The minutes of 

the September meeting did not include any specific information on the 

improvement projects’ costs or schedule. The Assistant Administrator 

stated that SBA is considering formalizing the currently-undocumented 

reviews. We agree that fully-documenting decisions about the projects’ 

costs and schedules would improve its ability to manage the improvement 

projects. A copy of the Assistant Administrator’s comments are included 

as Appendix II.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send a copy of this report to the 

Administrator of SBA. The report will also be available at no charge on 

the GAO website at http://www.gao.gov. 

If you or your staffs have any questions concerning this report, please 

contact me at (202) 512-9286 or by e-mail at pownerd@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in appendix II.

Sincerely yours,

David A. Powner

Director, Information Technology

 Management Issues
Appendix I: Briefing to the Staff of the House 

Committee on Small Business

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Appendix I: Briefing to the Staff of the House 

Committee on Small Business
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Appendix II: Comments from the Small 

Business Administration

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Appendix II: Comments from the Small 

Business Administration
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Business Administration

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Appendix II: Comments from the Small 

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Appendix III: GAO Contact and Staff 

Acknowledgments

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David A. Powner, (202) 512-9286 or pownerd@gao.gov

In addition to the individual named above, James R. Sweetman, Jr., 

Assistant Director; Eric Costello; Franklin Jackson; Lee McCracken; 

Meredith Raymond; Karl Seifert; and Dan Wexler made key contributions 

to this report. 

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(311271)
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