Information Technology: Potentially Duplicative Investments Exist at the Departments of Defense and Energy
Published: 2012-02-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This testimony discusses the potentially duplicative information technology (IT) investments at selected agencies and actions these agencies are taking to address them. With at least $79 billion spent in fiscal year 2011 by the United States government on IT investments, it is important that federal agencies avoid investing in duplicative investments, whenever possible, to ensure the most efficient use of resources.
Last year, we issued a comprehensive report that identified federal programs or functional areas where unnecessary duplication, overlap, or fragmentation exists; the actions needed to address such conditions; and the potential financial and other benefits of doing so. More recently, we reported on the Office of Management and Budgets (OMB) and federal agencies oversight of IT investments and the initiatives under way to address potentially duplicative IT investments. Specifically, we recently reported that there are hundreds of IT investments providing similar functions across the federal government. For example, agencies reported about 1,500 investments that perform general information and technology functions, about 775 supply chain management investments, and about 620 human resource management investments.
Congress asked us to testify on our report being released today that describes the extent to which potentially duplicative IT investments exist within these three categories, including the actions agencies are taking to address them. In this regard, this testimony specifically covers potentially duplicative investments we identified at three of the largest agencies with respect to number of investmentsthe Departments of Defense (DOD), Energy (DOE), and Homeland Security (DHS).
section_title: What GAO Found
paragraphs: Although the Departments of Defense, Energy, and Homeland Security utilize various processes to prevent and reduce investment in duplicative programs and systems, potentially duplicative IT investments exist. Further complicating agencies ability to identify and address duplicative investments is miscategorization of investments within agencies. Each of the agencies has recently initiated plans to address many of these investments. DHSs efforts have resulted in the identification and elimination of duplication, but DODs and DOEs initiatives have not yet led to the elimination or consolidation of duplicative investments or functionality. Until DOD and DOE demonstrate progress on their efforts to identify and eliminate duplicative investments, and correctly categorize investments, it will remain unclear whether they are avoiding investment in unnecessary systems. Each of the agencies we reviewed has IT investment management processes in place that are, in part, intended to prevent, identify, and eliminate unnecessary duplicative investments. Even with such investment review processes, of the 810 investments we reviewed,we identified 37 potentially duplicative investments at DOD and DOE within three FEA categories (Human Resource Management, Information and Technology Management, and Supply Chain Management).
31 potentially duplicative investments totaling approximately $1.2 billion at DOD, and
6 potentially duplicative investments totaling approximately $8 million at DOE.
We did not identify any potentially duplicative investments at DHS within our sample; however, DHS has independently identified several duplicative investments and systems. Specifically, DHS officials have identified and, more importantly, reduced duplicative functionality in four investments by consolidating or eliminating certain systems within each of these investments, including a personnel security investment, time and attendance investment, human resources investment, and an information network investment. DHS officials have also identified 38 additional systems that they have determined to be duplicative.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the potentially duplicative  information technology (IT) investments at selected agencies and actions  these agencies are taking to address them. With at least $79 billion spent  in fiscal year 2011 by the United States government on IT investments, it  is important that federal agencies avoid investing in duplicative  investments, whenever possible, to ensure the most efficient use of  resources.
Last year, we issued a comprehensive report that identified federal  programs or functional areas where unnecessary duplication, overlap, or  fragmentation exists; the actions needed to address such conditions; and  the potential financial and other benefits of doing so. More recently, we  reported on the Office of Management and Budget’s (OMB) and federal  agencies’ oversight of IT investments and the initiatives under way to  address potentially duplicative IT investments. Specifically, we recently  reported that there are hundreds of IT investments providing similar  functions across the federal government. For example, agencies reported  about 1,500 investments that perform general information and technology  functions, about 775 supply chain management investments, and about  620 human resource management investments.
You asked us to testify on our report being released today that describes  the extent to which potentially duplicative IT investments exist within  these three categories, including the actions agencies are taking to  address them.  In this regard, my testimony specifically covers potentially  duplicative investments we identified at three of the largest agencies with  respect to number of investments–the Departments of Defense (DOD),  Energy (DOE), and Homeland Security (DHS). In preparing this  testimony, we relied on the GAO report being released at today’s hearing.
GAO, Information Technology: Departments of Defense and Energy Need to Address  Potentially Duplicative Investments, GAO-12-241 (Washington, D.C.: Feb. 17, 2012).
In that report, to identify potentially duplicative IT investments within each  of the selected agencies, we analyzed a subset of investment data from  OMB’s exhibit 53 to identify investments with similar functionality.   Specifically, we reviewed 810, or 11 percent, of the approximately 7,200  IT investments federal agencies report to OMB through the exhibit 53.  Our review represents approximately 24 percent of DOD’s IT portfolio in  terms of the number of investments that they report to OMB, 19 percent  of DOE’s, and 16 percent of DHS’s. We then reviewed the name and  narrative description of each investment’s purpose to identify similarities  among related investments within each agency (we did not review  investments across agencies). This formed the basis of establishing  groupings of similar investments. We discussed the groupings with each  of the selected agencies, and we obtained further information from  agency officials and reviewed and assessed agencies’ rationales for  having multiple systems that perform similar functions. Additionally, when  analyzing each investment’s description, we compared the investment’s  designated Federal Enterprise Architecture (FEA) primary category and  sub-category with OMB’s definitions for each FEA primary category and  sub-category and determined whether the investment was placed in the  correct FEA category. We obtained additional information from agency  officials about these discrepancies. We also interviewed officials to  discuss actions agencies have taken to address the potentially duplicative  investments and reviewed supporting documentation.
All work on which this testimony is based was performed 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 objective.
subsections: section_title: Background
paragraphs: Information technology should enable government to better serve the  American people. However, according to OMB, despite spending more  than $600 billion on IT over the past decade, the federal government has  achieved little of the productivity improvements that private industry has  realized from IT. Too often, federal IT projects run over budget, behind  schedule, or fail to deliver promised functionality. In combating this  problem, proper oversight is critical. Both OMB and federal agencies have  key roles and responsibilities for overseeing IT investment management.  OMB is responsible for working with agencies to ensure investments are  appropriately planned and justified. Additionally, each year, OMB and  federal agencies work together to determine how much the government  plans to spend on IT projects and how these funds are to be allocated.
subsections: section_title: OMB’s IT Oversight Mechanisms
paragraphs: OMB uses the following mechanisms to help it fulfill oversight  responsibilities of federal IT spending during the annual budget  formulation process.
OMB requires 27 federal departments and agencies to provide  information related to their IT investments, including agency IT  investment portfolios (called exhibit 53s) and capital asset plans and  business cases (called exhibit 300s).
In June 2009, OMB publicly deployed the IT Dashboard, which is  intended to display near real-time information on the cost, schedule,  and performance of all major IT investments. For each major  investment, the Dashboard provides performance ratings on cost and  schedule, a chief information officer (CIO) evaluation, and an overall  rating. The CIO evaluation is based on his or her evaluation of the  performance of each investment and takes into consideration multiple  variables. The CIO also has the ability to provide written comments  regarding the status of each investment.
According to OMB, the public display of investment data on the IT  Dashboard is intended to allow OMB, other oversight bodies, and the  general public to hold government agencies accountable for results and  progress. In addition, the Dashboard allows users to download exhibit 53  data, which provide details on the more than 7,200 federal IT investments  (totaling $78.8 billion in planned spending for fiscal year 2011).
As we have previously reported, while the IT Dashboard provides IT  investment information for 27 federal agencies, it does not include any  information about 61 other agencies’ investments. Specifically, it does  not include information from 58 independent executive branch agencies  and 3 other agencies. It also does not include information from the  legislative or judicial branch agencies. Accordingly, we recommended that  OMB specify which executive branch agencies are included when  discussing the annual federal IT investment portfolio. OMB disagreed with  this recommendation, stating that the agencies included in the federal IT  portfolio are already identified in OMB guidance and on the IT Dashboard.  However, we maintained that the recommendation had not been fully  addressed because OMB officials frequently refer to the federal IT  portfolio without clarifying that it does not include all agencies.
section_title: Agencies Spend Billions on Poorly Performing IT Investments
paragraphs: Despite OMB’s oversight mechanisms, the federal government spends  billions of dollars on poorly performing IT investments, as the following  examples illustrate:   In February 2010, the Defense Integrated Military Human Resources  System was canceled after 10 years of development and  approximately $850 million spent, due, in part, to a lack of strategic  alignment, governance, and requirements management, as well as  the overall size and scope of the effort.  In January 2011, the Secretary of Homeland Security ended the  Secure Border Initiative Network program after spending about $1.5  billion because it did not meet cost-effectiveness and viability  standards. In February 2011, the Office of Personnel Management canceled its  Retirement Systems Modernization program, after several years of  trying to improve the implementation of this investment. the Office of Personnel Management, it spent approximately $231  million on this investment.
Additionally, as of August 2011, according to the IT Dashboard, 261 of  the federal government’s approximately 800 major IT investments— totaling almost $18 billion—are in need of management attention (rated  “yellow” to indicate the need for attention or “red” to indicate significant  concerns).  (See fig. 1.)
GAO, Border Security: Preliminary Observations on the Status of Key Southwest Border  Technology Programs, GAO-11-448T (Washington, D.C.: Mar. 15, 2011).
GAO, OPM Retirement Modernization: Longstanding Information Technology  Management Weaknesses Need to Be Addressed, GAO-12-226T (Washington, D.C.:  Nov. 15, 2011).
The approximately 800 major IT investments total about $40.6 billion for fiscal year  2011. reviews—known as “TechStat” sessions—of selected IT investments  involving OMB and agency leadership to increase accountability and  transparency and improve performance. OMB officials stated that, as  of December 2010, 58 sessions had been held and resulted in  improvements to or termination of IT investments with performance  problems. In addition, OMB has identified 26 additional high-priority IT  projects and plans to develop corrective action plans with agencies at  future TechStat sessions. According to the former Federal CIO,  OMB’s efforts to improve management and oversight of IT  investments have resulted in $3 billion in savings.  IT reform. In December 2010, the Federal CIO issued a 25 Point  Implementation Plan to Reform Federal Information Technology  Management. This 18-month plan specified five major goals:  strengthening program management, streamlining governance and  improving accountability, increasing engagement with industry,  aligning the acquisition and budget processes with the technology  cycle, and applying “light technology” and shared solutions. As part of  this plan, OMB outlined actions to, among other things, strengthen  agencies’ investment review boards and consolidate federal data  centers. The plan stated that OMB will work with Congress to  consolidate commodity IT spending (e.g., e-mail, data centers,  content management systems, and web infrastructure) under agency  CIOs. Further, the plan called for the role of federal agency CIOs to  focus more on IT portfolio management.
section_title: Categorization of IT Investments Is Intended to Facilitate Identification of Similar IT Investments
paragraphs: In addition to these efforts to improve government spending on IT,  avoiding unnecessary duplicative investments is critically important. In  February 2002, OMB established the FEA initiative. According to OMB,  the FEA is intended to facilitate governmentwide improvement through  cross-agency analysis and identification of duplicative investments, gaps,  and opportunities for collaboration, interoperability, and integration within  and across agency programs. Since the fiscal year 2004 budget cycle,  OMB has required agencies to categorize their IT investments in their  annual exhibit 53s according to primary function and sub-function.
In their fiscal year 2011 submissions, agencies reported the greatest  number of IT investments in Information and Technology Management  (1,536 investments), followed by Supply Chain Management (777  investments), and Human Resource Management (622 investments).  Similarly, planned expenditures on investments were greatest in  Information and Technology Management, at about $35.5 billion. Figure 2  depicts, by primary function, the total number of investments within the 27  federal agencies that report to the IT Dashboard.
Additionally, agencies were required to choose a sub-function for each  investment related to the primary function.
section_title: GAO Has Previously Reported on Potential Duplication and the Challenges of Identifying Duplicative Investments
paragraphs: During the past several years, we have issued multiple reports and  testimonies and made numerous recommendations to OMB and federal  agencies to identify and reduce duplication within the federal  government’s portfolio of IT investments.
In March 2011, we reported an overview of federal programs and  functional areas where unnecessary duplication, overlap, or  fragmentation existed. agencies, offices, or initiatives had similar or overlapping objectives or  provided similar services to the same populations, or where government  missions were fragmented across multiple agencies or programs. The  report touched on hundreds of federal programs, including IT programs,  affecting virtually all major federal departments and agencies.
GAO-11-318SP.
Consolidation Initiative to guide federal agencies in consolidating data  centers. Specifically, OMB and agencies plan to close more than 950 of  the over 2,100 federal data centers by 2015. As of November 2011,  agencies reported that a total of 149 data centers have been closed  across the federal government. For example, 16 DOD data centers, 3  DOE centers, and 7 DHS centers have been closed.
In September 2011, we reported that limitations in OMB’s guidance  hindered efforts to identify IT duplication. Specifically, OMB guidance  stated that each IT investment needs to be mapped to a single functional  category within the FEA to allow for the identification and analysis of  potentially duplicative investments across agencies. We noted that this  limits OMB’s ability to identify potentially duplicative investments both  within and across agencies because similar investments may be  organized under different functions. Accordingly, we recommended that  OMB revise guidance to federal agencies on categorizing IT investments  to ensure that the categorizations are clear and that it allow agencies to  choose secondary categories, where applicable. OMB officials generally  agreed with this recommendation and stated that they plan to update the  FEA reference models to provide additional clarity on how agencies  should characterize investments in order to enhance the identification of  potentially duplicative investments.
We also reported that results of OMB initiatives to identify potentially  duplicative investments were mixed and that several federal agencies did  not routinely assess their entire IT portfolios to identify and remove or  consolidate duplicative systems. Specifically, we said that most of OMB’s  recent initiatives have not yet demonstrated results, and several agencies  did not routinely assess legacy systems to determine if they are  duplicative. As a result, we recommended that OMB require federal  agencies to report the steps they take to ensure that their IT investments  are not duplicative as part of their annual budget and IT investment  submissions. OMB generally agreed with this recommendation.
section_title: Selected Agencies Have Potentially Duplicative Investments; DOD and DOE Need to Do More to Address Them
paragraphs: Although the Departments of Defense, Energy, and Homeland Security  utilize various processes to prevent and reduce investment in duplicative  programs and systems, potentially duplicative IT investments exist.  Further complicating agencies’ ability to identify and address duplicative  investments is miscategorization of investments within agencies. Each of  the agencies has recently initiated plans to address many of these  investments. DHS’s efforts have resulted in the identification and  elimination of duplication, but DOD’s and DOE’s initiatives have not yet  led to the elimination or consolidation of duplicative investments or  functionality. Until DOD and DOE demonstrate progress on their efforts to  identify and eliminate duplicative investments, and correctly categorize  investments, it will remain unclear whether they are avoiding investment  in unnecessary systems.
subsections: section_title: Potentially Duplicative IT Investments Exist at Selected Agencies
paragraphs: Each of the agencies we reviewed has IT investment management  processes in place that are, in part, intended to prevent, identify, and  eliminate unnecessary duplicative investments. For example, DOD’s  Information Technology Portfolio Management Implementation guide  requires the evaluation of existing systems to identify duplication and  determine whether to maintain, upgrade, delete, or replace identified  systems. Similarly, DOE’s Guide to IT Capital Planning and Investment  Control specifies that investment business case summaries should be  reviewed for redundancies and opportunities for collaboration.  Additionally, according to DHS’s Capital Planning and Investment Control  Guide, proposed investments must be reviewed at the department level to  determine if the proposed need is, among other things, being fulfilled by  another DHS program, or already fulfilled by an existing capability.
Even with such investment review processes, of the 810 investments we  reviewed, we identified 37 potentially duplicative investments at DOD  and DOE within three FEA categories (Human Resource Management,  Information and Technology Management, and Supply Chain  Management). These investments account for about $1.2 billion in total  IT spending for fiscal years 2007 through 2012. Specifically, we identified
31 potentially duplicative investments totaling approximately $1.2  billion at DOD, and
6 potentially duplicative investments totaling approximately $8 million  at DOE.
The 37 investments comprise 12 groups of investments that appear to  have duplicative purposes based on our analysis of each investment’s  description, budget information, and other supporting documentation from  agency officials (see table 1). For example, we identified three  investments at DOE that were each responsible for managing the back- end infrastructure at three different locations. We also identified four DOD  Navy personnel assignment investments—one system for officers, one for  enlisted personnel, one for reservists, and a general assignment  system—each of which is responsible for managing similar assignment  functions. Additionally, the Air Force has five investments that are each  responsible for contract management, and within the Navy there are  another five contract management investments. Table 1 summarizes the  12 groups of potentially duplicative investments we identified by purpose  and agency.
We did not identify any potentially duplicative investments at DHS within  our sample; however, DHS has independently identified several  duplicative investments and systems. Specifically, DHS officials have  identified and, more importantly, reduced duplicative functionality in four  investments by consolidating or eliminating certain systems within each of  these investments, including a personnel security investment, time and  attendance investment, human resources investment, and an information  network investment. DHS officials have also identified 38 additional  systems that they have determined to be duplicative. For example,  officials identified multiple personnel action processing systems that could  be consolidated.
Officials from the three agencies reported that duplicative investments  exist for a number of reasons, including decentralized governance within  the departments and a lack of control over contractor facilities. For  example, DOE investments for the management of back-end  infrastructure are for facilities which DOE oversees but does not control.  In addition, DOD officials indicated that a key reason for potential  duplication at the Department of the Navy is that it had traditionally used a  decentralized IT management approach, which allowed offices to develop  systems independent of any other office’s IT needs or acquisitions.
Further complicating the agencies’ ability to prevent investment in  duplicative systems or programs is the miscategorization of investments.  Among the 810 investments we reviewed, we identified 22 investments  where the selected agencies assigned incorrect FEA primary functions or  sub-functions. Specifically, we identified 13 miscategorized investments  at DOD, 4 at DOE, and 5 at DHS.  For example, DHS’s Federal  Emergency Management Agency—Minor Personnel/Training Systems  investment was initially categorized within the Employee Performance  Management sub-function, but DHS agreed that this investment should  be assigned to the Human Resources Development sub-function.
Agency officials agreed that they had inadvertently miscategorized 15 of  the 22 investments we identified. However, proper categorization is  necessary in order to analyze and identify duplicative investments, both  within and across agencies. Each improper categorization represents a  possible missed opportunity to identify and eliminate an unjustified  duplicative investment. Until agencies correctly categorize their  investments, they cannot be confident that their investments are not  duplicative and are justified, and they may continue expending valuable  resources developing and maintaining unnecessarily duplicative systems.
Therefore, we recommended in our report that the agencies correct the  miscategorizations for the investments we identified and ensure that  investments are correctly categorized in agency submissions. In  response, DOD stated that it agreed, and will attempt to make the  categorization changes for certain investments in its fiscal year 2013  submission. DHS also agreed with the recommendation, and provided  documentation showing that the department had recently corrected the  miscategorizations for each of the investments we identified. DOE agreed  that two of the four investments we identified could be recategorized, and  reported that the department has made those changes. However, DOE  disagreed that the other two investments we identified were  miscategorized, explaining that its categorizations reflect funding  considerations. However, OMB guidance indicates that investments  should be classified according to their intended purpose. Consequently,  we believe the recommendation is warranted.
section_title: Agencies Have Recently Initiated Plans to Address Potential Duplication in Many Investments, but Results Have Yet to Be Realized at DOD and DOE
paragraphs: DHS has taken action to improve its processes for identifying and  eliminating duplicative investments, which has produced tangible results.  Specifically, in 2010 and 2011, the DHS CIO conducted program and  portfolio reviews of hundreds of IT investments and systems. DHS  evaluated portfolios of investments within its components to avoid  investing in systems that are duplicative or overlapping, and to identify  and leverage investments across the department. Among other things,  this effort contributed to the identification and consolidation of duplicative  functionality within four investments. DHS also has plans to further  consolidate systems within these investments by 2014, which is expected  to produce approximately $41 million in cost savings. The portfolio  reviews also contributed to the identification of 38 additional systems that  are duplicative. For example, officials identified multiple personnel action  processing systems that could be consolidated.
DOD has begun taking action to address 29 of the 31 duplicative  investments we identified. For example, according to DOD officials, four  of the DOD Navy acquisition management investments—two for Naval  Sea Systems Command and two for Space and Naval Warfare Systems  Command—will be reviewed to determine whether these multiple support  systems are necessary. In addition, DOD reported that the Air Force is in  the process of developing a single contract writing system to replace the  five potentially duplicative investments we have identified. Moreover, the  Department of the Navy has implemented an executive oversight board  that is chaired by the Navy CIO, and it is now the Navy’s single senior  information management and technology policy and governance forum.  The Department of the Navy also required all IT expenditures greater  than $100,000 to be centrally reviewed and approved by the Navy CIO to  ensure that they are not duplicative. Officials reported that these initiatives  will include the review of Navy’s 22 potentially duplicative investments  that we identified.
Similarly, DOE has plans under way to address each of the 6 investments  we identified as potentially duplicative. Specifically, DOE officials  established working groups that are addressing the two groups of  duplicative investments we identified. These working groups are to  address records management and back-end infrastructure, and are  looking across the department to minimize redundancy in each of these  areas. In addition, the CIO stated that DOE has developed a  departmental strategy for electronic records management whereby a  small number of approved records management applications will be  identified for departmentwide use. Moreover, in a broader effort to reduce  duplication across the department, in September and October 2011, DOE  held technical strategic reviews, known as “TechStrat” sessions, which  are aimed at exploring opportunities to consolidate DOE’s commodity IT  services, such as e-mail and help desk support, among the various DOE  offices. The first two sessions provided opportunities for DOE bureaus to  identify and share lessons learned, and established action items to  improve DOE’s IT investment portfolio.
While these efforts could eventually yield results, DOD’s and DOE’s  initiatives have not yet led to the consolidation or elimination of  duplication. For example, while DOD provided us with documented  milestones—several of which have passed—for improving the  Department of the Navy’s IT investment review processes, officials did  not provide us with any examples of duplicative investments that they had  consolidated or eliminated. Similarly, while DOE officials have  documented time frames for consolidating DOE’s commodity IT services,  electronic records management investments, and identity management  investments, officials were unable to demonstrate that they have  consolidated or eliminated unjustified duplicative investments.
Additionally, DOD does not have plans under way to address the  remaining 2 of the 31 potentially duplicative investments, which are two  civilian personnel management investments. Specifically, DOD officials  stated that they do not have plans to address these two investments  because they do not agree that they are potentially duplicative. However,  agency officials were unable to demonstrate that investing in these  systems and programs was justified.
Until DOD and DOE demonstrate, through existing transparency  mechanisms, such as OMB’s IT Dashboard, that they are making  progress in identifying and eliminating duplicative investments, it will  remain unclear whether they are avoiding investment in unnecessary  systems. Therefore, we recommended that these two agencies utilize  existing transparency mechanisms, such as the IT Dashboard, to report  on the results of their departments’ efforts to identify and eliminate, where  appropriate, each potentially duplicative investment we identified, as well  as any other duplicative investments. In response to our report, DOD and  DOE stated that they agreed with the recommendation. Additionally, DOE  added that for the non-major investments that we identified as being  potentially duplicative, it will update GAO on its progress through means  other than the IT Dashboard, since non-major investments are not  individually tracked on the Dashboard.
In summary, while agencies have various investment review processes in  place that are partially designed to avoid investing in systems that are  duplicative, we have identified 37 potentially duplicative investments at  DOD and DOE that account for about $1.2 billion in total IT spending for  fiscal years 2007 through 2012. Given that our review covered 11 percent  (810 investments) of the total number of IT investments that agencies  report to OMB, it raises questions about how much more potential  duplication exists.
DHS’s recent efforts have resulted in the identification and consolidation  of duplicative functionality in several investments and related systems.  DOD and DOE have also recently initiated plans to address many  investments that we identified, but these recent initiatives have not yet  resulted in the consolidation or elimination of duplicative investments or  functionality. Further complicating agencies’ ability to prevent, identify,  and eliminate duplicative investments is miscategorization of investments  within agencies. Implementation of our recommendations should provide  better assurance that agencies are avoiding investment in unnecessary  systems.
Chairman Lankford, Ranking Member Connolly, and Members of the  Subcommittee, this concludes my statement. I would be happy to answer  any questions at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: If you should have any questions about this testimony, please contact me  at (202) 512-9286 or by e-mail at pownerd@gao.gov. Individuals who  made key contributions to this testimony are Shannin O’Neill, Assistant  Director; Javier Irizarry; Lee McCracken; and Kevin Walsh.
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