Telecommunications: Agencies Need to Apply Transition Planning Practices to Reduce Potential Delays and Added Costs
Published: 2017-09-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: GSA is responsible for contracts providing telecommunications services for federal agencies. Transitions involving previous contracts faced significant delays resulting in increased costs. Because GSA's current telecommunications program, Networx, expires in May 2020, planning for the next transition has begun.
GAO was asked to review preparations for the transition. This report addresses the extent to which (1) GSA's plans and guidance to agencies incorporate lessons learned from prior transitions, and (2) agencies are following established planning practices in their transitions. In performing this work, GAO analyzed GSA lessons learned and transition guidance. GAO also selected five agencies—USDA, DOL, DOT, SEC, and SSA—based on size, structure, and Networx spending. GAO then reviewed the agencies' documentation to determine how they followed five planning practices identified in previous GAO reports.
section_title: What GAO Found
paragraphs: The General Services Administration's (GSA's) transition guidance to agencies addressed roughly half of its previously identified lessons learned. GSA identified 35 lessons learned from previous telecommunications contract transitions that identify actions that agencies should take. In transition guidance released to agencies, GSA fully addressed 17 of the 35 lessons. Two lessons from previous transitions were not appropriate for the current transition. GSA partially addressed an additional nine lessons. Seven lessons were not addressed at all (see figure). For example, GSA's guidance did not address the previous lesson that agencies should not assume that a transition to a new contract with the same vendor will be easier than a change in vendors. By not including all lessons learned in its plans and guidance to agencies, GSA limits agencies' ability to plan for actions that will need to be taken later in the transition. As a result, agencies face an increased risk that they could repeat prior mistakes, including those that could result in schedule delays or unnecessary costs.
Selected agencies—the Departments of Agriculture (USDA), Labor (DOL), and Transportation (DOT); the Securities and Exchange Commission (SEC), and the Social Security Administration (SSA)—have yet to fully apply most of the five planning practices previously identified by GAO as key to a successful telecommunications transition. The practices encompass: (1) developing inventories, incorporating strategic needs into transition planning, (2) incorporating strategic needs into transition planning, (3) developing a structured transition-management approach, (4) identifying resources necessary for the transition, and (5) establishing transition processes and measures of success. SEC fully implemented one practice, partially implemented three practices, and did not implement another. The other four agencies partially implemented each of the five practices. Agencies provided various reasons for not following planning practices, including uncertainty due to delays in GSA awarding the new contracts, plans to implement practices later as part of established agency procedures for managing IT projects, and a lack of direction and contractor assistance from GSA. If agencies do not fully implement the practices in the next transition, they will be more likely to experience the kinds of delays and increased costs that occurred in previous transitions.
section_title: What GAO Recommends
paragraphs: GAO recommends that GSA disseminate guidance that includes all agency-directed lessons learned. In addition, GAO recommends that USDA, DOL, DOT, SEC, and SSA complete adoption of the planning practices to avoid schedule delays and unnecessary costs. Five agencies agreed with all of our recommendations. SSA agreed with two recommendations, partially disagreed with one, disagreed with two, and provided updated information. GAO stands by the recommendations, as discussed in the report, and revised the report based on SSA's new information.

section_title: Letter
paragraphs: The General Services Administration (GSA) is responsible for ensuring  that federal agencies have access to the telecommunications services  and solutions that they need to meet mission requirements. As federal  agencies have evolved in their use of telecommunications, so too have  GSA’s contracts to help support their needs. Currently, these  telecommunications contracts not only support agencies’ basic telephone  needs, but also provide an acquisition vehicle for wireless and satellite  services, as well as managed network services and information  technology (IT) security services. In fiscal year 2015 alone, federal  agencies spent about $1.6 billion on services acquired through the  contracts under GSA’s current telecommunications program, known as  Networx.
In preparation for the end of its current telecommunications contracts in  2020, GSA developed a successor program, known as Enterprise  Infrastructure Solutions (EIS). It plans to award telecommunications  contracts under this program later in the summer of 2017. As such,  agencies will have to undertake the difficult task of transitioning their  telecommunications services to the EIS contracts. This transition is  expected to involve more than 135 agencies, about 32 types of services,  and thousands of voice and data circuits. GSA’s role in the transition  includes providing guidance and technical assistance to agencies.
The last two GSA government-wide telecommunications contract  transitions experienced significant delays that led to hundreds of millions  of dollars in increased costs and missed savings. The transition that  began in 1998 experienced delays that hindered the timely achievement  of program goals and resulted in an estimated $74 million in missed  savings. The most recent transition, which began in 2007, took 33  months longer than planned. The delays led to an increase of $66.4  million in costs to GSA and an estimated $329 million in lost savings.
After these transitions, GSA compiled lessons learned as a resource for  future transitions. Specifically, the agency identified 96 lessons learned  from the previous two transitions, related to topics such as transition  planning, execution, and monitoring; regional services, reporting, and risk  management, among others. Of the 96 lessons, GSA identified 35 that  specifically relate to actions that agencies should take during a  telecommunications transition.
This report responds to your request that we examine preparations for the  EIS transition. Specifically, our objectives were to determine the extent to  which (1) GSA’s plans and guidance to federal agencies for transitioning  to EIS incorporate lessons learned from prior transitions and (2) selected  agencies are following established planning practices for their transitions.
To address the first objective, we reviewed published GSA documents to  identify EIS transition guidance and lessons learned directed to agencies.  We then compared the published guidance sources to GSA’s agency- directed lessons learned. We also interviewed knowledgeable officials in  the Federal Acquisition Service (FAS), the organization within GSA that is  responsible for the transition.
To address the second objective, we selected a nongeneralizable sample  of federal agencies to review. Using contract billing data provided by  GSA, we identified agencies with total charges of more than $500,000 for  fiscal year 2015 for the most-purchased telecommunications services— voice, toll free, private line, and combined (local and long distance)  services. From this group of agencies, we selected agencies that  exhibited a variety of (1) sizes, (e.g., large agencies, medium agencies,  and small agencies); and (2) structures (e.g., agencies with and without  component organizations). Based on these criteria, we selected five  agencies—the Departments of Agriculture (USDA), Labor (DOL), and  Transportation (DOT), as well as the Securities and Exchange  Commission (SEC) and the Social Security Administration (SSA).
We then obtained and reviewed documentation (including strategic plans,  telecommunications inventories, and transition-related plans) and  interviewed relevant officials from each of the selected agencies. We  assessed each agency’s information against telecommunications  transition planning practices identified in our prior work.
Based on our assessment, we classified the status of agency efforts to  address each sound planning practice as “fully implemented” if the  agency had implemented all of the aspects of the practice activities or  “not implemented” if the agency did not demonstrate that it had taken any  steps consistent with the practice. We assigned a status of “partially  implemented” if the agency had addressed some, but not all of the  practice; or had approved plans to fully implement the practice at a later  time.
As part of this analysis, we gathered copies of the selected agencies’  telecommunications inventories and assessed their reliability. To do so,  we asked agencies for documentation of their quality control procedures  and practices related to ensuring the accuracy of the inventories. In  addition, we interviewed knowledgeable agency officials about the  systems and processes in place to collect and verify the data. We  determined that the inventory information provided by one agency, the  Securities and Exchange Commission, was sufficient for our purposes;  however, the information provided by the other four agencies was not  sufficient, due to the lack of documented policies to ensure the data’s  accuracy and completeness. This conclusion was considered during our  assessment of the selected agencies’ efforts to apply the planning  practice related to inventories. A detailed discussion of our objectives,  scope, and methodology can be found in appendix I.
We conducted this performance audit from January 2016 through  September 2017, 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.
subsections: section_title: Background
paragraphs: GSA’s existing government-wide telecommunications program is the  successor to a series of programs that have provided data services and  long-distance telecommunications to the federal government. In 1998 and  1999, GSA awarded two sets of contracts under the FTS2001 program,  which was designed to meet agency needs for various telecommunication  services, including long distance voice, video, and data services.
In 2007, GSA awarded successor contracts through an effort called  Networx. These contracts, which had an estimated combined value of  $20 billion, included a wider array of services provided through two sets  of contracts with differing characteristics:
GSA awarded Networx Universal contracts to AT&T, Verizon  Business Services, and Qwest Government Services. Networx  Universal offers voice and data services, wireless services, and  management and application services, including video and audio  conferencing, as well as mobile and fixed satellite services, with  national and international coverage.
Networx Universal contracts were set to expire in March 2017;  however, each participating vendor received a contract extension  through March 2020.
GSA awarded Networx Enterprise contracts to AT&T, Verizon  Business Services, Qwest Government Services, Level 3  Communications, and Sprint Nextel. Networx Enterprise offers  services similar to those of Networx Universal, with a focus on those  that are Internet-based, and does not require coverage of as large a  geographic area as does Networx Universal.
Networx Enterprise contracts were set to expire in May 2017;  however, each participating vendor, except one, received a contract  extension through May 2020.
subsections: section_title: Enterprise Infrastructure Solutions Will Provide Contracts for Agencies to Acquire Telecommunications Services
paragraphs: EIS is the replacement for Networx and all of GSA’s local and regional  telecommunications contracts. GSA intends for EIS to address federal  agencies’ global telecommunications and information technology  infrastructure requirements. It is the first set of contracts to be developed  under GSA’s Network Services 2020 (NS2020) strategy.
GSA plans for EIS to provide agencies with traditional and emerging  services to meet current and future requirements, by:  simplifying the government’s process of acquiring information  technology and telecommunications products and services; providing cost savings to each agency through aggregated volume  buying and pricing and spending visibility; enabling the procurement of integrated solutions; promoting participation by small businesses and fostering competition; offering a flexible and agile suite of services supporting a range of  government purchasing patterns into the future; and providing updated and expanded security services to meet current  and future government cybersecurity requirements.
In addition, GSA has identified several benefits that EIS is expected to  provide to the agencies that participate in its telecommunications  programs. These projected benefits include:  streamlined contract administration, including catalog-based offerings;  future-proof contracts (price management mechanism, 15-year period  of performance);  simplified pricing, including simplified contract line item number  structure; and enhanced management and operations support.
GSA issued its request for proposals (RFP) for EIS in October 2015.  Vendors’ responses to the RFP were received by February 2016.  According to FAS officials, GSA held discussions with offerors in 2016  and received proposals in December of that year. However, GSA  determined that none of the proposals met the defined requirements.  After another round of discussions, GSA received updated proposals on  March 31, 2017. While GSA determined that these revised proposals met  the requirements, a pre-award protest was filed on April 17, 2017. The  protest was then withdrawn in May 2017. On August 1, 2017, GSA  announced that it had awarded EIS contracts to ten vendors. GSA  expects agencies to issue notices to vendors providing a fair opportunity  to be considered for a task order within 2 months of contract awards.  According to GSA’s plans, the transition to EIS is expected to be  completed by March and May 2020, when the current Networx contracts  expire. A timeline of the transition to EIS is provided in figure 1.
section_title: GSA, Its Customer Agencies, and Contractors All Have Transition Responsibilities
paragraphs: Central to the successful transition from Networx to EIS are transition  planning and execution activities that involve GSA, federal agencies, and  Networx and EIS contractors. GSA serves as the facilitator for all  transition management activities and is using contract support to assist in  tracking transition activities in order to avoid delays and other problems  that can arise throughout the process.
To assist agencies with their transitions from the Networx contracts, GSA  is working with representatives of the federal agencies, both directly and  through an Infrastructure Advisory Group. This group is a collaborative  body for aligning government-wide and agency missions with GSA  strategies for acquiring and providing the future technology infrastructure  services that will enable them.
GSA’s primary responsibility is to provide program management for both  Networx and EIS. As part of this, it is responsible for   conducting government-wide strategy and project management;  collecting and validating an inventory of active services on all expiring  contracts; providing tailored assistance to agencies for transition planning and  help with contractor selection and ordering;  tracking and reporting the use of metrics that convey the relative  complexity and transition progress; and providing customer support, training, and self-help tools and  templates.
According to FAS officials, GSA’s approach to the current transition  includes providing direct assistance to agencies, with GSA performing  some transition tasks for small agencies and offering contractor  assistance to larger agencies. GSA developed two contracting vehicles to  support its efforts: (1) a Transition Coordination Center vehicle that  includes assistance with inventory validation, transition planning, and  solicitation development; and (2) a Transition Ordering Assistance vehicle  that addresses tasks including requirements development and source  selection assistance, and proposal evaluation. The Coordination Center  vehicle was put in place in January 2016, while the Ordering Assistance  vehicle was initially awarded in September 2016, but was not finalized  until March 2017, due to a bid protest.
GSA’s customer agencies—those federal agencies acquiring services  through the Networx program—have principal responsibility for the  transition. These agencies are responsible for coordinating transition  efforts with the incumbent and EIS contractors to ensure that existing  services under Networx are disconnected and that new services are  ordered. According to GSA, customer agencies’ responsibilities under EIS  include:  identifying key personnel, chiefly a Senior Transition Sponsor, Lead  Transition Manager, and Transition Ordering Contracting Officer; engaging expertise from Chief Information Officers, Chief Acquisition  Officers, and Chief Financial Officers to build an integrated transition  team of telecommunications managers, acquisition experts, and  financial staff; developing a financial strategy and budget for transition costs  beginning in fiscal year 2017; analyzing and confirming the accuracy of the inventory of active  services that must be transitioned; developing an agency transition plan by October 2016 that describes  the agency’s technological goals, transition schedule, strategy for  awarding task orders on EIS for transitioning services, and any  constraints or risks; and preparing solicitations for task orders to be released immediately upon  award of EIS contracts.
At the agencies we selected, the staff responsible for the transition were  part of their agency’s Office of the Chief Information Officer (OCIO).
section_title: Our Prior Work Has Addressed Telecommunications Transition Planning
paragraphs: We have previously reported on efforts by GSA and agencies to transition  from one telecommunications program to another. In a June 2006 report,  we identified a range of transition planning practices that can help  agencies reduce the risk of experiencing adverse effects of moving from  one broad telecommunications contract to another. We developed these  practices through an analysis of available literature on  telecommunications transitions and interviews with those having  experience in telecommunications transitions, including industry experts,  telecommunications vendors, and private sector companies. These  planning practices are to:
Establish an accurate telecommunications inventory and an inventory  maintenance process.
Identify strategic telecommunications requirements and use the  requirements to shape the agency’s management approach and guide  efforts when identifying resources and developing a transition plan.
Establish a structured management approach that includes a  dedicated transition management team, key management processes  (project management, configuration management, and change  management), and clear lines of communication.
Identify the funding and human capital resources that the transition  effort will require.
Develop a transition plan that includes objectives, measures of  success, a risk assessment, and a detailed timeline.
Each of these transition planning practices consists of various activities.  For example, developing a transition plan consists of (1) identifying and  documenting objectives and measures of success; (2) determining risks  that could affect success; and (3) defining transition preparation tasks and  developing a timeline for these tasks.
That same June 2006 report evaluated the progress of six selected  agencies in preparing for the transition from FTS2001 to Networx and  found that the agencies generally had not implemented the practices, but  were planning to do so. We recommended, among other things, that  GSA develop and distribute guidance to its customer agencies to ensure  that the identified transition planning practices were used. GSA agreed  with our recommendations and subsequently issued guidance related to  several of the identified practices.
Further, in 2008, we reported on the extent to which six selected agencies  were following the transition planning practices during the Networx  transition. We noted that the agencies were generally implementing the  practices, but three of them had not fully implemented some of the key  activities of the practices and were not planning to do so. For example,  one agency was using key project management processes in its transition  planning efforts, and five had plans to use them. Regarding identifying  human capital needs, two agencies had identified their resource needs,  and three had plans to identify them. Also, one of the agencies did not  plan to identify its human capital needs. We made recommendations to  those agencies that had not implemented key practice activities and did  not plan to do so, focused on addressing the gaps in transition planning.  One agency implemented the recommendation we made to it, one  implemented one of the two recommendations directed to it, and one  agency implemented one of the seven recommendations we made to it.
In 2013, we reported on factors that had contributed to the delay in the  Networx transition and the consequences of the delay. We pointed out  that weak project planning and complex acquisition processes were  factors that had contributed to the delay. We also reported on the extent  to which GSA was documenting and applying lessons learned to prepare  for the current EIS transition. In comparing GSA’s lessons-learned  process with six key practices necessary for a robust lessons-learned  process, we noted that GSA had fully satisfied three of the six key  practices. Specifically, it had collected, analyzed, and validated lessons  learned from the previous Networx transition.
However, GSA had not fully satisfied the remaining three practices: (1)  sharing lessons with its customer agencies, (2) archiving the lessons  learned, or (3) prioritizing them to ensure that resources are applied to  areas with the greatest return on investment. For example, GSA shared  briefings of lessons learned with agencies and OMB; however, it did not  make the information in its 2012 lessons-learned report readily available  to agencies and other transition stakeholders.
As a result, we recommended that GSA coordinate with the Office of  Personnel Management (OPM) for future transitions to examine potential  government-wide expertise shortfalls. We also recommended that it  provide agencies with guidance on project planning and fully archive,  prioritize, and share lessons learned. As of June 2017, GSA had  implemented three of the five recommendations we made. Specifically, in  accordance with our recommendations, GSA had provided project  planning guidance to agencies, updated its transition lessons-learned  database, and prioritized its lessons learned. In addition, GSA had begun  but not completed implementation of the recommendation applying  lessons based on priority and available resources. GSA agreed with the  recommendation regarding expertise shortfalls but had not yet  implemented it.
section_title: GSA Did Not Consistently Address Lessons Learned in Its Transition Plans and Guidance to Agencies
paragraphs: The use of lessons learned ensures that beneficial information is factored  into planning, work processes, and activities. Lessons learned can  provide a powerful method of sharing good ideas for improving work  processes, quality, and cost-effectiveness. Key lessons-learned practices,  as described in our earlier work, include disseminating lessons-learned  information to all involved parties. This practice emphasizes that  lessons learned should be disseminated through a variety of  communication media, such as briefings, bulletins, reports, e-mails,  websites, database entries, revised work processes or procedures, and  personnel training.
In addition, according to the Project Management Institute’s Guide to the  Project Management Body of Knowledge (PMBOK® Guide), distributing  lessons learned is important because they can provide insights on both  the decisions made regarding communications issues and the results of  those decisions in previous similar projects. The knowledge can be  used to plan the communication activities for the current project.
GSA compiled lessons learned from previous telecommunications  transitions, including 35 lessons that described actions that agencies  should take during future transitions. Two of these lessons address  issues that are not appropriate for the current transition, leaving 33  lessons for agencies.
GSA subsequently disseminated a number of these lessons learned to  agencies via various sources, including transition plans and guidance. For  example, to prepare for the current transition from Networx to EIS, GSA  developed plans, documents, presentations, and other transition-related  guidance sources in which it discussed lessons learned resulting from the  prior transitions.
Table 1 describes the transition guidance for EIS that GSA provided to  agencies at two intervals: by December 2016, when GSA had initially  planned to issue the EIS contracts, and between January and April 2017,  to account for new guidance issued after contract awards were delayed.
However, while the transition plans and guidance that GSA issued to  agencies included discussions of lessons learned, they did not do so  comprehensively or consistently. First, none of these sources addressed  all 33 of the agency-focused lessons that GSA had identified. For  example, the 2012 Lessons-Learned Report addressed 19 lessons (the  most of any source), but did not address the remaining 14. The EIS  Acquisition and Transition presentation to small agencies addressed 6 of  the 33 lessons. Second, even when GSA guidance addressed a previous  lesson, it did not always include all aspects of the lesson. Overall, when  GSA’s guidance addressed a lesson, it more frequently addressed the  lesson partially rather than fully. For example, one lesson called for  agencies to recognize the possibility that they might change vendors and  to develop plans to mitigate the risks from such a change. However,  although one guidance source (the 2012 Lessons-Learned report) told  agencies to plan for a change in vendors, it did not specify that they plan  to mitigate associated risks. In addition, another lesson stressed that the  coordination of service disconnects and activations by different vendors  was essential. One guidance source (GSA White Paper: NS2020  Transition Strategy) discussed the need for coordinated disconnects, but  did not discuss activations by different vendors. Figure 2 lists the number  of lessons that were fully, partially, or not addressed within each of GSA’s  various transition guidance documents.
When the information provided in GSA’s guidance is considered  collectively, significant gaps in communicating previous lessons learned  are evident. In the initial guidance released by December 2016, 15  lessons were fully addressed in the body of the guidance, 9 lessons were  partially addressed, and 9 lessons were not addressed at all. Additional  guidance that GSA released between January and April 2017 addressed  more lessons learned, but did not include all of the lessons learned that  were not previously disseminated. In total, the 12 guidance sources  released by April 2017 fully addressed 17 of the 33 lessons learned and  partially addressed another 9. The guidance sources did not address 7  lessons, including those related to agencies (1) bearing the costs  associated with contract extensions resulting from delays in their contract  selections, transition planning, or ordering; and (2) not assuming that a  transition to a new contract with the same vendor will be easier than a  change in vendors. Figure 3 shows the collective number of lessons that  were fully, partially, and not addressed in the GSA guidance. In addition,  appendix II describes each lesson learned and the extent to which it was  addressed in the guidance.
FAS officials responsible for the transition cited several reasons for not  fully addressing lessons learned from the prior telecommunication  transitions in the planning and guidance documents for the EIS transition.  These reasons included:
Lessons were originally developed to encourage agencies to consider  the actions; however, GSA has since changed its thinking on a  number of these lessons learned and believes they are no longer  applicable or relevant during the transition to EIS.
Several lessons are not specifically addressed in current guidance  because the agencies are not at the point in the transition where that  level of detail would be useful.
We agree that two of the 35 lessons—those addressing the ordering of  wide area network and trusted Internet connection services—are not  appropriate to the current transition due to changes in the proposed  contracts. However, we do not agree with many of GSA’s assessments of  the lessons that were not addressed. For example, one lesson that GSA  said was not applicable in December 2016 addressed being prepared for  the possibility that the agency’s current vendor will not be chosen for the  new contract. Because the EIS contracts had not been awarded, this was  still a possibility which agencies should consider. Another lesson that was  not addressed is the need to allow service changes during the  transition—an issue we maintain is still relevant due to the length of time  needed to complete a transition.
In addition, one lesson that GSA said was more appropriate for later in  the transition states that agency contracting officers should meet with  GSA contracting officers for advice. In our view, however, this lesson is  appropriate for all phases of transition planning efforts.
By not including all lessons learned in its plans and guidance to agencies,  GSA limits agencies’ ability to plan for actions that will need to be taken  later in the transition. As a result, the risk is increased that agencies could  repeat prior mistakes, including those that could result in schedule delays  or unnecessary costs.
section_title: Selected Agencies Have Begun Instituting Transition Planning Practices, but None Has Fully Implemented Them All
paragraphs: As discussed earlier, we previously identified a set of planning practices  that can mitigate the risks associated with a complex telecommunications  transition. These practices, which we reported on in 2006 and 2008, call  for agencies to:  1.  Develop asset and service inventories.  2.  Incorporate strategic needs into transition planning.  3.  Develop a structured transition-management approach.  4.  Identify resources necessary for the transition.  5.  Establish transition objectives, risks, and measures of success.
However, as of May 2017, none of the five agencies selected for our  review had fully implemented all five of the practices. These agencies  (DOL. DOT, SEC, SSA, and USDA) had generally addressed parts of all  five practices and one agency had fully implemented one practice.
The selected agencies provided various reasons for not fully adopting the  practices, ranging from their uncertainty due to delays in awarding the  EIS contracts and the lack of specific direction and planned contractor  assistance from GSA to implement the practices, to having plans to  implement practices later as part of established agency procedures for  managing IT projects. However, going forward, if the agencies do not fully  implement the practices, they will be more likely to experience the kinds  of delays and increased costs that occurred in previous transitions.
subsections: section_title: One Selected Agency Has Completed Its Asset and Service Inventory, and Four Others Have Begun Developing Theirs
paragraphs: To accomplish Practice 1—developing an accurate inventory of current  telecommunications assets and services—the transition planning  practices we previously identified state that agencies should complete two  activities. First, agencies should have a detailed and complete transition  inventory that reflects all of their facilities, components, field offices, and  any other managed sites. The inventory should include information such  as telecommunications services, traffic volumes, equipment, and  applications being used. In addition, agencies should use their transition  inventories to identify opportunities for optimizing their current technology  during strategic planning.
Second, agencies should have a documented inventory-maintenance  process that can be used to ensure that inventories remain current and  reflect changes leading up to, during, and after the transition. An  inventory-maintenance process can ensure that changes are captured  and allow agencies to verify vendor bills against their inventories  throughout the life of the contract.
Consistent with the first activity in this practice, all five selected agencies  had begun to develop service inventories. However, only one of the  agencies had completed its inventory. Specifically, SEC had identified an  inventory that included all agency components receiving  telecommunications services, validated the inventory with data provided  by GSA, and demonstrated that it had adequate procedures for ensuring  the completeness of the inventory. The four other agencies had  developed telecommunications inventories, but had not verified that the  inventories were complete.
SEC was also the only agency to complete the second activity related to  having a documented inventory maintenance process. In this regard, it  had documented procedures for updating its inventory. A second agency,  SSA, had established procedures for the reconciliation and maintenance  of local and long distance telecommunications services, but not for other  contracted services. The remaining three agencies did not have  documented procedures requiring inventory updates.
Table 2 summarizes the extent to which transition planners at the five  agencies had implemented the practice to establish telecommunications  inventories.
The four agencies that did not have complete inventories or procedures to  update their inventories cited several reasons for their status. Officials  responsible for the transitions at the three agencies with components  (Labor, DOT, and USDA) said that they have decentralized inventory  maintenance among their components. However, none of these agencies  has written policies that require components to develop a complete  inventory and keep them updated. As a result, some of the agencies’  components could demonstrate that their inventories were complete,  while other components could not.
In addition, SSA’s Division Director for Integrated Telecommunications  Management (who is within the agency’s Office of the Chief information  Officer (OCIO)) attributed that agency’s delay in developing a complete  inventory and a maintenance process to GSA not providing promised  contractor assistance with validating its inventory. However, while the  contracting vehicle for supporting later planning tasks was delayed due to  the bid protest, the vehicle that GSA provided for agency assistance with  inventory validation had been in place since January 2016.
Two of the four agencies identified several actions they plan to take to  address these gaps. USDA and DOT officials responsible for their  agencies’ transitions (who are within their departments’ OCIOs) said they  plan to develop a department-wide process that components will be  expected to use. DOT officials also discussed the possibility that the  Department would centralize the inventory maintenance process in the  future. The two agencies, however, did not have established deadlines for  completing these actions. Further, with regard to Labor, officials  responsible for its transition said they did not plan to develop a policy or  procedures governing how components should maintain an inventory of  telecommunications assets and believed such an approach to be  unnecessary.
Without complete and accurate telecommunications inventories, the  selected agencies are less likely to be prepared to address strategic  considerations and may be unable to avoid unnecessary transition delays  associated with inventory identification. Additionally, without a  documented inventory-maintenance process, the agencies may not  consistently and accurately capture the changes to their  telecommunications inventories during and after transition, thus, hindering  their ability to ensure that they are billed appropriately by the vendor or to  determine areas for optimization and sharing of telecommunications and  IT resources across the agency.
section_title: Selected Agencies Have Begun Performing Strategic Analyses of Their Telecommunications Requirements
paragraphs: To accomplish Practice 2—performing a strategic analysis of  telecommunications requirements— the transition planning practices we  previously identified state that agencies should complete four activities.  First, agencies should use their inventories of existing services to  determine current and future telecommunications needs. Next, they  should use the transition as an opportunity to identify areas for  optimization or sharing of telecommunications and IT resources across  the agency. Agencies should also evaluate the costs and benefits of  introducing new technology and alternatives for meeting the agency’s  telecommunications needs. Finally, they should align the identified needs  and opportunities with the agency’s mission, long-term IT plans, and  enterprise architecture plans  Two of the selected agencies (SSA and USDA) had partially addressed  the first activity, related to determining future telecommunications needs.  Specifically, SSA documented future requirements based on interviews  with stakeholders. However, SSA did not document that it based the  identified needs on its existing inventory. In addition, USDA created a  preliminary set of future telecommunications needs. However, these  needs had not been finalized. According to officials responsible for  USDA’s transition, finalization is expected in October 2017, which will  allow time for USDA components and vendors to provide feedback that  will be integrated into the preliminary set of future telecommunications  needs. The remaining three agencies (DOL, DOT, and SEC) had not  begun to identify future needs based on their current inventories.
With regard to the second activity of the practice, two agencies (DOL and  SSA) had completed efforts to identify areas for the optimization and  sharing of telecommunications and IT resources. In addition, one agency  had partially implemented this activity. Specifically, USDA had identified  options for optimization, but as of July 2017, it was still working with its  components and vendors to evaluate the options. According to agency  officials, they expect to reach a decision on options in October 2017, but  this schedule is not documented.
With regard to the two other agencies, DOT’s future plans were unclear  because it was awaiting IT investment management approval. Further,  officials with SEC stated that the commission would address this practice  later in 2017. None of these agencies had documented plans or  timeframes for completing this activity.
Consistent with the third activity of this practice, USDA had evaluated the  costs and benefits of new technology and alternative options for meeting  its telecommunications needs. SSA had partially addressed this activity in  that it had begun to evaluate the cost and benefits of upgrading agency  bandwidth, but had not yet evaluated costs and benefits for introducing  other new technology and alternatives for meeting the agency’s  telecommunications needs. SSA officials said they planned to conduct  such an analysis at a later time but had not documented plans to do so.  The other three agencies had not yet addressed this activity.
Finally, in addressing the fourth activity, three of the five agencies had  begun to determine whether their needs and opportunities were aligned  with their mission, long-term IT plans, and enterprise architecture plans,  although they had not yet completed these activities. Specifically, DOT  had demonstrated that its identified needs and opportunities aligned with  its mission. However, it did not demonstrate a similar alignment with its  long-term IT plans and enterprise architecture plans. In addition, SSA had  begun to align identified transition needs and opportunities with the  agency mission and long-term IT plans. However, it had not fully identified  its transition needs or evaluated those needs against its enterprise  architecture. SSA also had determined that its identified  telecommunications needs aligned with its long-term plans, as they  related to two ongoing modernization projects. However, the agency did  not show that the needs aligned with its enterprise architecture. USDA  also had aligned identified needs with its mission and enterprise  architecture plans. However, the agency had not aligned identified needs  and opportunities with its long-term IT plans. The remaining two agencies,  DOL and SEC, had not yet implemented this practice.
Table 3 summarizes the extent to which the five agencies performed a  strategic analysis of their telecommunications requirements. ● Practice activity has been fully implemented.  ◒ Agency has partially implemented practice activity.  ○ Agency has not implemented practice activity.
Three of the agencies attributed their limited progress on this practice to  their use of established agency IT management processes and their  related time frames. DOL transition officials (who are within the  department’s OCIO) stated that they had begun to manage the transition  within the agency’s systems development life cycle process, but it was  too early for most planning activities to be completed. DOT officials stated  that their agency was conducting a network assessment, causing a delay  in fulfilling this planning practice. The officials also said that their agency’s  specific management plans had not been finalized because the agency  intended to manage the transition as a project within its IT investment  management process; however, they had not yet gotten approval to do  so. Further, officials from SEC’s OCIO stated that they were following  internal agency best practices for managing a project and adherence to  the systems development life cycle.
Additionally, officials at three agencies described plans to address this  practice at a later time. DOL officials stated that they planned to issue a  request for information to ask vendors what new technologies are  available to meet the Department’s needs and to suggest changes to the  existing telecommunications infrastructure. When we discussed this issue  in December 2016, SEC officials stated that some actions could not be  completed until GSA awards the EIS contract because they do not yet  know what services will be available or their prices. In addition, SSA’s  telecommunications management division director stated that several  activities were initially delayed due to GSA not providing promised  contractor assistance, which required the agency to obtain assistance on  its own. However, the director added that SSA’s transition is now on  schedule, and it has begun addressing this practice using contractor  support.
While the selected agencies’ established IT management processes can  contribute to the fulfillment of the practice related to identifying strategic  needs, the limited time available for the transition leaves agencies with a  short window in which to make such determinations. As a result of the  delays in identifying their needs, agencies will have less time to  implement the resulting changes while meeting the deadlines for  transitioning off of the Networx contracts.
Also, agencies that do not fully assess the costs and benefits of  alternatives for meeting their telecommunications needs may not be  taking full advantage of the transition as an opportunity to optimize their  telecommunications services. Further, agencies that do not identify areas  for optimization and sharing miss opportunities to upgrade their  telecommunications services, or to shift service to more cost-effective  technology. If agencies do not incorporate strategic requirements into  their planning, they risk making decisions that are not aligned with their  long-term goals. Without aligning needs and opportunities with missions  and plans, agencies risk missing opportunities to use the new contract to  address their highest priorities.
section_title: Selected Agencies Have at Least Partially Developed a Structured Transition Management Approach
paragraphs: To accomplish Practice 3—establishing a structured transition  management approach— the previously identified transition planning  practices state that agencies should complete three activities. They  should establish a transition management team to be involved in all  phases of the transition, and in clearly defining the responsibilities for key  transition activities, such as project management, asset management,  contract and legal expertise, human capital management, and information  security management. Agencies should also ensure that all transition  team members are clear on who is involved and how transition plans and  objectives will be communicated. Finally, agencies should ensure that  they use established project management, configuration management,  and change management processes during the transition.
All five selected agencies established transition-management teams, as  outlined in the first activity of Practice 3. Transition plans written by the  agencies identified management teams and stakeholders responsible for  their transitions. However, of the five agencies, only SSA had defined all  of the roles and responsibilities identified in the practice. For example,  DOT and SEC defined roles for project and information security  management and contract expertise, but did not define roles for asset and  human-capital management and legal expertise. DOL and USDA defined  roles for project management and contract expertise, but did not define  roles for asset, human capital, and information security management, and  legal expertise.
The selected agencies generally had made more limited progress on the  second activity of Practice 3, regarding communicating their transition  plans. SSA had implemented this practice, while three other agencies had  not yet done so. One other agency, SEC, had partially implemented the  practice. Specifically, it had developed a plan that identified those who  are to be involved in the transition. However, the plan did not address  other key aspects of this practice, including identifying key local and  regional transition officials and points of contact responsible for  disseminating information to employees and working with the vendor to  facilitate transition activities.
Four of the five agencies had begun using the types of management  processes described in the third activity in Practice 3. Specifically, DOT,  SEC, SSA, and USDA had demonstrated the use of established project  management processes for their transitions, which included the use of  schedules, task lists, and risk assessments. However, none of these  agencies demonstrated that configuration or change management  processes, which reduce the risks associated with technical and  operational changes, were being applied to the transition. Further, the fifth  agency, DOL, had not addressed this practice.
Table 4 summarizes the extent to which the five selected agencies had  established a structured transition management approach.
The agencies cited several reasons for not fully implementing the  practice. Regarding the establishment of a management team with  defined roles, DOT officials stated that some stakeholders were not  involved in the early stages of the transition because the department  typically does not involve all stakeholders until later in the project  management life cycle. The officials also said that development of a  communications plan and implementation of change and configuration  management would be completed at a later time. However, DOT had not  documented a plan or schedule for doing so.
SEC officials stated that the agency had legal and human capital  expertise on the project; however, because SEC is a small agency,  individuals cannot always be dedicated to a project. The officials also  stated that the agency intended to handle communications through its  established practice of weekly calls between IT staff and regional  managers, although this process had not been documented. Additionally,  the officials stated that formal change and configuration management  practices apply to all of the agency’s IT projects, but did not demonstrate  that those practices applied to its telecommunications transition.
For SSA, the telecommunications management division director stated  that, the EIS transition is part of a modernization effort that is subject to  agency requirements to use established change and configuration  management processes. As a result such practices will also be used in  the transition. However, SSA did not document this approach.
In addition, DOL officials stated that once an integrated project team has  been formed, the transition effort is expected to proceed through the  traditional systems development life cycle, which will address the practice  activities related to project and change management. Similarly, USDA  officials stated that the department plans to assign human capital  resources later in the management process. Both departments’ officials  also described plans to use configuration and change management  processes during the transition to EIS, but those plans were not  documented. These officials did not identify specific dates by which their  planned actions are expected to be completed.
Agencies that do not use a sound management approach risk additional  financial costs, extended timelines, and disruptions to the continuity of  their telecommunications systems. Further, without establishing lines of  communication and identifying local and regional points of contact,  agencies may lack the quality of information that is necessary for  comprehensive understanding, accountability, and shared expectations  among all those with transition responsibilities. Finally, by not defining key  roles and responsibilities for the transition, the agencies risk extending  their transition period as they attempt to assign appropriate personnel and  update them on transition progress and issues. Due to the short time  available to complete the current transition, effectively employing these  practices will require expeditious action.
section_title: Selected Agencies Have Taken Initial Steps to Identify Resources Necessary for Transition Planning
paragraphs: To accomplish Practice 4—identifying the resources required to  successfully plan for the transition—the transition planning practices we  previously identified state that agencies should complete four activities.  First, they should identify the level of funding needed for their transition  planning efforts to ensure that needed resources are available. Next,  agencies should identify the organizational need for investments and  assess benefits versus costs to justify any resource requests. Agencies  should also determine staffing levels that may be required throughout the  transition effort, as well as ensure that personnel with the right skills are in  place to support the transition effort. Skills needed for this activity are  project management, asset management, contract and legal expertise,  human capital management, and information security expertise. Finally,  agencies should require training for those carrying out the transition or  operating and maintaining newly transitioned technology.
One selected agency (USDA) fully implemented the first activity in  Practice 4, having identified the level of funding needed to support its  transition planning. Three other agencies (DOT, DOL, and SSA) identified  funding for part of the transition effort but did not identify funding to  support other parts of the effort. Specifically, DOT developed a rough  estimate for transition planning support, but this estimate had not been  approved and it did not account for funds used for planning efforts  completed prior to fiscal year 2017. Further, cost projections that DOL  and SSA developed did not account for all years of transition support and  the agencies did not provide evidence that the costs accounted for the  transition management team. The fifth agency (SEC) had not identified its  funding needs for the transition.
For the second activity of Practice 4, DOL demonstrated that it had  identified the funding needed for transition project management, but not  for software and hardware upgrades, the establishment of a reliable  inventory, or the costs and benefits to justify any resource requests. In  addition, SSA and USDA identified the need for transition resources,  including staffing, but did not document cost-benefit justifications for those  resources. The remaining two agencies (DOT and SEC) had not  implemented this activity.
Three agencies also had partially implemented the third activity of the  practice. Specifically, DOL, SSA, and USDA had identified staffing levels  required for their near-term transition efforts. However, these agencies  had not substantiated that the staff identified will be sufficient to support  their entire transition efforts. DOT and SEC had not addressed this  practice.
With regard to the fourth activity of the practice, four agencies (DOL,  DOT, SEC, and USDA) demonstrated that their agencies had provided  training to transition support staff. However, none of these agencies  showed that they had conducted an analysis to identify all of the training  needed for the transition, including training on new equipment or services.  The fifth agency (SSA) had not implemented this practice. Table 5  summarizes the extent to which the five agencies identified resources for  their transitions.
Officials at the five agencies generally explained that they had not  developed specific resource estimates for their transition efforts because  they did not have an immediate need to do so. DOL officials explained  that, prior to fiscal year 2017, the department had not required additional  funding for the transition because it had leveraged resources from an  existing funded project. In addition, DOT officials stated that they had  conducted early transition planning using existing resources. SEC officials  stated that, based on past experience, the department did not require  additional funding or resources to support the transition because it was  considered to be a part of ongoing support funding from its operations  and maintenance budget. SEC officials added that, if something in the  new contracts required a change in current SEC telecommunications  services, they would follow the existing agency process for requesting  supplemental funding.
In addition, when we discussed these topics July 2017, officials at two  agencies generally expressed uncertainty about the scope of the  transition because they do not know what services would be available  under the new contracts. Once the contracts are awarded, according to  the officials, they expected to be better positioned to plan for needed  resources. SEC officials also said that they planned to take advantage of  transition-related training from GSA when it becomes available. Further,  SSA’s telecommunications management division director said that the  agency plans staffing annually and relies on current year resource usage  to plan staffing needs for future years. The director added that, if  additional staffing or other resources are needed, the request would be  justified to the agency’s oversight board. In addition, the director believed,  based on prior experience, that SSA’s staff are adequately trained, but  did not have any documented analysis to support this assertion.
While it may be premature to estimate all transition-related resource  needs, agencies that do not take steps to analyze their needs may be  underestimating the complexity and demands of the transition effort.  Additionally, without determining staffing needs for their transition efforts,  agencies risk experiencing gaps in staffing, which may lead to delays and  unexpected costs. Moreover, agencies that do not plan for required  training are likely to incur unnecessary costs and experience delays as  they try to quickly address gaps in staff competencies during the  transition’s short time frame.
section_title: Selected Agencies Have Begun to Establish Transition Objectives, Risks, and Measures of Success
paragraphs: To accomplish Practice 5—developing a plan that identifies objectives,  risks, and measures of success, and that approaches the process as a  critical project with a detailed timeline— the previously identified transition  planning practices state that agencies should complete three activities.  Agencies should first identify transition objectives and measures of  success. Transition objectives should be based on a strategic analysis of  telecommunications requirements and aligned with an overall mission and  business objectives. Agencies should also identify agency-specific risks  that could affect transition success. The importance of the risks should be  evaluated relative to the agency’s mission-critical systems and continuity  of operations plans. This risk assessment should include an analysis of  information security risks to determine what controls are required to  protect networks and what level of resources should be expended on  controls. Lastly, agencies should develop a transition plan that depicts a  management strategy with clearly defined transition preparation tasks and  includes a timeline that allows for periodic reporting and takes into  account mission-critical priorities, such as contingency plans and  identified risks. This timeline should take into account priorities relative to  the agency’s mission-critical systems, contingency plans, and identified  risks.
One selected agency (DOL) had fully implemented the first activity of this  practice by identifying objectives and measures of success linked to the  agency’s requirements and business needs. The remaining four agencies  partially implemented the activity. Specifically, DOT, SEC, and USDA  documented agency-specific transition objectives and measures of  success. However, these agencies did not demonstrate that their  transition objectives were based on a strategic analysis of  telecommunications requirements and were aligned with the agency’s  overall mission and business objectives. SSA had documented agency- specific transition objectives but had not documented measures of  success. According to officials responsible for SSA’s transition, the  agency plans to develop such objectives in the future, but had not  established a deadline for doing so.
All five selected agencies at least partially addressed the second activity  of Practice 5 by identifying agency-specific risks that could affect  transition success and by clearly defining transition preparation tasks.  Three agencies (SEC, SSA, and USDA) identified information security  risks, as called for in the practice activity. However, DOL and DOT risk  assessments did not include information security risks. Moreover, none of  the agencies considered continuity of operations in their risk assessments  nor took into account priorities relative to their mission-critical systems.
With respect to the third activity of the practice, each of the agencies at  least partially defined transition preparation tasks and developed a  timeline. However, the timelines did not take into account priorities  relative to the agencies’ mission-critical systems, contingency plans, and  identified risks. For example, in its transition plan, SEC identified multiple  risks that could delay the transition, if realized, such as compliance with  Office of Management and Budget security requirements. However, SEC  provided no evidence that such risks or associated mitigation activities  were accounted for in transition preparation tasks. Table 6 identifies the  extent to which the agencies had developed plans for the transition. ● Practice activity has been fully implemented.  ◒ Agency has partially implemented practice activity.  ○ Agency has not implemented practice activity.
Officials responsible for the transitions at the agencies we reviewed  generally described their intent to complete the practices related to  planning later in their transitions. DOL officials explained that the next  step in their planning process would be to form an Integrated Project  Team for the transition. The officials stated that, once formed, the  transition effort will proceed through the traditional systems development  life cycle and begin to document plans and decisions, which would  contribute to the last two practice activities.
With regard to DOT, an official stated that the agency was conducting a  network assessment, causing a delay in completing this practice. SEC  officials stated that the goal and primary measure of success for the  transition would be zero downtime, but that it did not expect to trace other  measures of success to business objectives.
Additionally, officials at the other two agencies explained that while they  had not fully implemented this practice, they plan to do so later, but did  not identify a deadline. SSA’s telecommunications management division  director stated that the agency could not complete a detailed transition  timeline because such a timeline would have to be based on the winning  contractor bids. In addition, USDA officials stated that the agency was still  working on a Statement of Objectives for transition services and expected  to tie transition objectives to strategic analysis of telecommunications  requirements and overall business and mission objectives as part of that  effort.
Three agencies (DOL, DOT, and SSA) also cited GSA requirements, in  part, as the reason for not completing the second and third practice  activities. DOL officials stated that the agency had not completed these  activities, in part, because GSA set no such expectations. A DOT official  stated that tasks to include mission-critical systems and contingency  plans were still being developed and that the agency had not provided  detailed tasks within its transition plan because GSA did not require them.  SSA’s telecommunications management division director offered a similar  explanation.
However, while the lack of awarded contracts constrained agencies’  ability to plan the transition in detail prior to August 2017, the limited time  available to conduct the transition makes it critical that agencies conduct  early planning with the information available, including information on  previous transitions. In addition, agencies that do not document  measurable objectives and clearly define transition tasks that take into  account agency priorities and risks may find it difficult to provide those  involved in the transition with clear expectations. Specifically, without  measurable objectives, managers will lack information that could be used  to track progress toward transition objectives and inform management  decisions. Further, agencies that do not analyze risks relevant to the  transition may encounter problems and delays during the process  because they are not adequately prepared to mitigate such risks.
section_title: Conclusions
paragraphs: GSA has identified lessons learned from previous telecommunications  contract transitions, and has communicated a number of lessons to  agencies through a series of plans and guidance. However, GSA did not  address all of its lessons in its guidance, and several of the lessons were  not communicated comprehensively. As a result, GSA made it more  difficult for agencies to take advantage of the lessons. Comprehensive  dissemination of lessons learned and agency planning guidance that  aligns with those lessons would provide agencies with information needed  to successfully plan for the complex transition effort that has already  begun.
The five agencies we reviewed had begun preparations for the transition  to a new government-wide telecommunications contract. However, none  had fully adopted the transition planning practices we previously identified  that can reduce the risk of unplanned delays. Several agencies stated  that they are planning to apply many of the management processes  outlined in the practices to their transition efforts later this year, often in  conjunction with existing IT management processes. While agencies’ use  of existing IT management processes can align with a number of the  identified practices, delaying the implementation of the established  planning practices to follow standard IT management timeframes can also  reduce agencies’ ability to fully apply the practices within the limited time  available to complete their transitions.
section_title: Recommendations and Executive Action
paragraphs: We are making a total of 25 recommendations to six agencies, including  one to GSA, five to USDA, five to DOL, four to SEC, five to SSA, and five  to DOT.
The Administrator of General Services should disseminate the 16 agency- focused lessons learned that have not been fully incorporated in GSA  guidance to the agencies involved in the current transition.  (Recommendation 1)
The Secretary of Agriculture should ensure that the Department’s Chief  Information Officer verifies the completeness of its inventory of current  telecommunications assets and services and establishes a process for  ongoing maintenance of the inventory. (Recommendation 2)
The Secretary of Agriculture should ensure that the Department’s Chief  Information Officer completes efforts to identify future telecommunications  needs and areas for optimization, identifies the costs and benefits of new  technology, and aligns USDA’s approach with its long-term plans.  (Recommendation 3)
The Secretary of Agriculture should ensure that the Department’s Chief  Information Officer identifies transition-related roles and responsibilities  related to the management of assets, human capital, and information  security, and legal expertise; develops a transition communications plan;  and uses configuration and change-management processes in USDA’s  transition. (Recommendation 4)
The Secretary of Agriculture should ensure that the Department’s Chief  Information Officer documents the costs and benefits of transition  investments, identifies staff resources needed for the remainder of the  transition, and analyzes training needs for staff assisting with the  transition. (Recommendation 5)
The Secretary of Agriculture should ensure that the Department’s Chief  Information Officer demonstrates that the Department’s transition goals  and measures align with its mission, identifies transition risks related to  critical systems and continuity of operations, and identifies mission-critical  priorities in USDA’s transition timeline. (Recommendation 6)
The Secretary of Labor should ensure that the Department’s Chief  Information Officer verifies the completeness of DOL’s inventory of  current telecommunications assets and services and establishes a  process for ongoing maintenance of the inventory. (Recommendation 7)
The Secretary of Labor should ensure that the Department’s Chief  Information Officer identifies the agency’s future telecommunications  needs, completes a strategic analysis of the agency’s  telecommunications requirements, and incorporates the requirements into  transition planning. (Recommendation 8)
The Secretary of Labor should ensure that the Department’s Chief  Information Officer identifies transition-related roles and responsibilities  related to the management of assets, human capital, and information  security, and legal expertise; develops a transition communications plan;  and uses project, configuration, and change-management processes in  DOL’s transition (Recommendation 9)
The Secretary of Labor should ensure that the Department’s Chief  Information Officer identifies the resources needed for the full transition,  develops justifications for the costs of changes to hardware and software,  identifies staff resources needed for the remainder of the transition, and  analyzes training needs for staff assisting with the transition.  (Recommendation 10)
The Secretary of Labor should ensure that the Department’s Chief  Information Officer identifies transition risks related to information  security, critical systems, and continuity of operations, and identifies  mission-critical priorities in DOL’s transition timeline. (Recommendation  11)
The Chairman of the Securities and Exchange Commission should  ensure that the Commission’s Chief Information Officer identifies the  agency’s future telecommunications needs, areas for optimization, and  the costs and benefits of new technology; completes a strategic analysis  of the commission’s telecommunications requirements; and incorporates  the identified requirements into transition planning. (Recommendation 12)
The Chairman of the Securities and Exchange Commission should  ensure that the Commission’s Chief Information Officer identifies roles  and responsibilities related to the management of assets and human  capital and legal expertise for the transition; includes key local and  regional officials in SEC’s transition communications plan; and completes  efforts to use configuration and change management processes in the  transition. (Recommendation 13)
The Chairman of the Securities and Exchange Commission should  ensure that the Commission’s Chief Information Officer identifies the  resources needed for the full transition, justifies requests for transition  resources, identifies staff resources needed for the full transition, and  completes efforts to analyze training needs for staff assisting with the  transition. (Recommendation 14)
The Chairman of the Securities and Exchange Commission should  ensure that the Commission’s Chief Information Officer completes efforts  to demonstrate that the commission’s transition goals and measures align  with its mission, identifies transition risks related to critical systems and  continuity of operations, and identifies mission-critical priorities in SEC’s  transition timeline. (Recommendation 15)
The Commissioner of the Social Security Administration should ensure  that the Administration’s Chief Information Officer verifies the  completeness of SSA’s inventory of current telecommunications assets  and services and establishes a process for ongoing maintenance of the  inventory regarding services other than local and long-distance  telecommunications. (Recommendation 16)
The Commissioner of the Social Security Administration should ensure  that the Administration’s Chief Information Officer completes identification  of the agency’s future telecommunications needs and aligns its approach  with the agency’s enterprise architecture. (Recommendation 17)
The Commissioner of the Social Security Administration should ensure  that the Administration’s Chief Information Officer uses configuration and  change-management processes in its transition. (Recommendation 18)
The Commissioner of the Social Security Administration should ensure  that the Administration’s Chief Information Officer identifies the resources  needed for the full transition, documents the costs and benefits of  transition investments, identifies staff resources needed for the remainder  of the transition, and analyzes training needs for all staff working on the  transition. (Recommendation 19)
The Commissioner of the Social Security Administration should ensure  that the Administration’s Chief Information Officer completes efforts to  identify measures of success for the transition, identifies transition risks  related to critical systems and continuity of operations, and identifies  mission-critical priorities in SSA’s transition timeline. (Recommendation  20)
The Secretary of Transportation should ensure that the Department’s  Chief Information Officer verifies the completeness of DOT’s inventory of  current telecommunications assets and services and establishes a  process for ongoing maintenance of the inventory. (Recommendation 21)
The Secretary of Transportation should ensure that the Department’s  Chief Information Officer identifies the agency’s future  telecommunications needs, areas for optimization, and costs and benefits  of new technology; and completes efforts to align DOT’s approach with its  long-term plans and enterprise architecture. (Recommendation 22)
The Secretary of Transportation should ensure that the Department’s  Chief Information Officer identifies roles and responsibilities related to the  management of assets and human capital and legal expertise for the  transition; develops a transition communications plan; and fully uses  configuration and change-management processes in DOT’s transition.  (Recommendation 23)
The Secretary of Transportation should ensure that the Department’s  Chief Information Officer fully identifies the resources needed for the full  transition, justifies requests for transition resources, identifies staff  resources needed for the full transition, and fully analyzes training needs  for staff assisting with the transition. (Recommendation 24)
The Secretary of Transportation should ensure that the Department’s  Chief Information Officer fully demonstrates that DOT’s transition goals  and measures align with its mission; completely identifies transition risks  related to information security, critical systems, and continuity of  operations; and fully identifies mission-critical priorities in the transition  timeline. (Recommendation 25)
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to GSA, USDA, DOL, SEC, DOT, and  SSA for comment. Four of the agencies (GSA, DOL, SEC, and SSA)  provided written comments on the draft report, while two agencies (USDA  and DOT) provided comments via email. In total, five agencies concurred  with our recommendations directed to them. One agency agreed with two  recommendations and disagreed wholly or in part with three other  recommendations.
In written comments, GSA agreed with our recommendation that it  disseminate the 16 agency-focused lessons learned that had not been  incorporated in GSA guidance. The agency stated that it plans to  revise its guidance to include all of its agency-focused lessons  learned. The agency also stated that it believes it has fully  implemented a recommendation we made in 2013 regarding applying  lessons based on priority and available resources. We intend to follow  up with GSA and seek supporting evidence to determine whether the  recommendation has been fully implemented. GSA’s comments are  reprinted in appendix III.
In written comments, DOL agreed with our five recommendations,  noting that the department plans to develop policies governing how its  components should maintain telecommunications inventories. The  Department also stated that it plans to have in place a documented  inventory process prior to services being awarded under the EIS  contracts. DOL’s comments are reprinted in appendix IV.
In written comments, SEC concurred with our four recommendations.  The agency stated that it plans to take several actions to address the  recommendations, including ensuring that all requirements are  reflected in its plans, as well as managing the transition according to  project and configuration management practices. SEC’s comments  are reprinted in appendix V.
In written comments, SSA agreed with two of our five  recommendations to the agency. Specifically, SSA agreed with our  recommendation on strategic analysis of telecommunications  requirements, reporting that the agency intends to conduct an  analysis of technologies and alternatives once a winning contractor  bid is in place. Regarding a second recommendation—to identify  transition resources—SSA agreed, but also stated that cost-benefit  justifications would prove extremely difficult and that no further  training is immediately necessary. We continue to believe that  justifying funding requests is key to identifying the appropriate level of  resources needed to conduct a transition. Also, with regard to training,  SSA did not provide any evidence to show that it had analyzed its  training needs. Without such information, the agency risks transition  delays if it later identifies a need for training that cannot be provided  quickly.
SSA partially disagreed with one recommendation—to identify  measures of success and risks related to continuity of operations and  critical systems. Specifically, SSA agreed to use several critical  milestones to monitor performance, but disagreed with the need to  identify the specified risks. The agency believes those risks were  already identified in one of its planning documents. However, we  reviewed the planning documents and did not find any specific  discussions of continuity of operations or critical systems, which are  essential to assuring that the transition does not have a negative  impact on the agency’s ability to complete its mission. We, therefore,  believe that the recommendation is appropriate and disagree with  SSA’s position.
SSA disagreed with our remaining two recommendations. Specifically,  it disagreed with the recommendation to implement  telecommunications inventory practices. SSA indicated that its  inventory was complete and that the inventory described its process  for maintaining services procured through GSA’s contracts. However,  we reviewed the information SSA provided and concluded that it did  not include complete information on the sites where each service was  provided, limiting the agency’s ability to plan for transition tasks  requiring the physical presence of staff. Further, while the agency had  procedures to update inventory information on local and long distance  services, it did not have similar procedures to update information on  other services ordered from the GSA contracts, such as wireless  (cellular), satellite, fixed data, and collaboration services. We,  therefore, continue to believe that it is important for SSA to complete  these steps.
Additionally, SSA disagreed with our recommendation to identify legal  expertise and utilize a structured transition management approach.  The agency indicated that it had previously identified legal expertise in  its transition plan. Although legal expertise was not discussed in the  plan that the agency initially provided for our review, SSA provided an  updated plan subsequent to its comments that included this  information. Thus, we revised our report to reflect that the agency had  completed this activity. We also deleted the reference to this activity in  our recommendation.
Further, in commenting on the second activity discussed in this  recommendation, SSA stated that the telecommunications transition  was part of a broader modernization effort which was subject to  agency guidance that includes the use of configuration and change  management. However, the agency did not provide evidence to  substantiate this position. As a result, we stand by this aspect of our  recommendation. SSA’s comments are reprinted in appendix VI.
In e-mail comments, USDA’s Senior Advisor stated that the  Department agreed with our five recommendations.
In e-mail comments, an official in DOT’s Office of the Secretary stated  that the Department concurred with our five recommendations.
Finally, we received technical comments from GSA and USDA, which we  incorporated, as appropriate.
We are sending copies of this report to the appropriate congressional  committees, the Administrator of GSA, Chairman of the SEC,  Commissioner of SSA, Secretary of Agriculture, Secretary of Labor,  Secretary of Transportation and other interested parties. In addition, this  report is available at no charge on the GAO website at  http://www.gao.gov.
Should you or your staffs have any questions on information discussed in  this report, please contact Carol Harris at (202) 512-4456 or  Harriscc@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 VII.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to determine to what extent: (1) GSA’s plans and  guidance to agencies for transitioning to EIS incorporate lessons learned  from prior transitions, and (2) selected agencies are following established  planning practices for their transitions.
To determine the extent to which GSA’s plans and guidance to agencies  for transitioning to EIS incorporate lessons learned from prior transitions,  we first obtained and reviewed GSA’s documented lessons learned for  the FTS2000 to FTS2001 and FTS2001 to Networx transitions. Second,  we identified (with input from GSA) those lessons learned that were  specific to agencies. Third, we reviewed transition plans, guidance, and  other EIS documentation developed by GSA, including presentations,  meeting minutes, and projected timelines provided to agencies. Fourth,  we evaluated each of the planning and guidance sources that GSA  disseminated to agencies to evaluate how completely the lessons learned  were addressed in the guidance. We did this by comparing the key  concepts identified in each lesson learned to the concepts described in  the guidance.
Based on our assessment, we classified the status of a lesson learned as  “fully addressed” if the lesson learned appeared in at least one planning  and guidance source or if all of the concepts described in a practice were  found collectively in multiple guidance sources; “partially addressed,” if  part of the lesson learned appeared in at least one document; or “not  addressed,” if the lesson learned did not appear in any of the planning  and guidance sources.
To determine the extent to which federal agencies are following  established transition planning practices, we selected five agencies for  review. Using Networx billing data provided by GSA, we identified total  charges for each service and each of 96 agencies for fiscal year 2015.  We first identified the four services with the most fiscal year 2015  spending. We then selected agencies representing a variety of (1) agency  sizes (two large agencies, two medium agencies, and a small agency);  (2) varying agency structures (e.g., two agencies with components vs.  three agencies without); and (3) agency charges for the four most  commonly identified services: Voice Services, Toll Free Service, Private  Line Services, and Combined (Local and Long Distance) at $20 million  dollars for two large agencies, $3 million dollars for two medium agencies,  and $557 thousand for a single small agency. The resulting five  departments and agencies’ selected for review were the U.S. Department  of Agriculture; U.S. Social Security Administration; Department of  Transportation; Department of Labor; and U.S. Securities and Exchange  Commission.
Because we did not review a statistically representative sample of federal  agencies, we cannot conclude that our results represent the entire federal  government’s level of preparation. However, the five cases studied  illustrate various challenges that these agencies have faced in planning  for the transition to EIS.
To determine the extent to which the selected agencies have made  adequate preparations for their upcoming transitions, we obtained and  reviewed agency documentation, including strategic plans,  telecommunications inventories, and transition-related documentation,  and interviewed agency officials. We then assessed this information  against each of the activities within the five transition planning practices  identified in our prior report on agency transition planning. Based on our  assessment, we classified the status of agency transition planning efforts  to address each sound planning practice activity as “fully implemented,” if  the agency had fully implemented the practice activity or “not  implemented,” if the agency did not demonstrate that it had taken any  actions consistent with the activity. We assigned a status of “partially  implemented” if the agency had taken some, but not all of the actions  included in an activity; had begun the processes to fully implement the  activity; or had approved plans to fully implement the activity at a later  time.
As part of our review of agency efforts to establish telecommunications  inventories, we gathered copies of the inventories and assessed their  reliability. Specifically, we asked agencies for documentation of their  quality control procedures and practices related to ensuring their  accuracy. Additionally, we also interviewed knowledgeable agency  officials about the systems and processes in place to collect and verify  the data. We determined that the inventory information provided by the  Securities and Exchange Commission was sufficient for our purposes, but  the information provided by the other agencies was not due to the lack of  documented procedures to ensure the completeness and accuracy of the  data. This conclusion was considered during our assessment of their  efforts to apply the planning practice related to inventories.
We conducted this performance audit from January 2016 through August  2017, 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.
section_title: Appendix II: Summary of GSA Lessons Learned
paragraphs: Based on experiences during previous telecommunications transitions,  the General Services Administration (GSA) identified 96 lessons learned.  Specifically, it identified 28 lessons learned documented during the  transition to FTS2001 and 68 lessons learned documented during the  transition to Networx. The combined 96 lessons learned relate to  transition planning, execution, and monitoring; regional services,  reporting, and risk management, among others. Of the total 96 lessons,  GSA identified 35 that specifically relate to actions that federal agencies  should take.
Table 7 describes the 35 agency-focused lessons learned identified by  GSA during previous telecommunication transitions and the extent to  which each was addressed in GSA’s EIS transition plans and guidance.
section_title: Appendix III: Comments from General Services Administration
section_title: Appendix IV: Comments from the Department of Labor
section_title: Appendix V: Comments from the Securities and Exchange Commission
section_title: Appendix VI: Comments from the Social Security Administration
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, James R. Sweetman, Jr.,  (Assistant Director), Kendrick Johnson (Analyst in Charge), Mathew  Bader, Paris Hawkins, Sukhjoot Singh, and Priscilla Smith made key  contributions to this report.