Immigration Benefits System: Significant Risks in USCIS's Efforts to Develop its Adjudication and Case Management System
Published: 2017-03-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Each year, USCIS processes millions of applications from foreign nationals seeking to study, work, visit, or live in the United States, and for persons seeking to become U.S. citizens. In 2006, USCIS began the Transformation Program to enable electronic adjudication and case management tools that would allow users to apply and track their applications online.
It is essential that USCIS deploy a seamless electronic system to help ensure the integrity of the immigration process. Such a system should allow the agency to more accurately process immigration and citizenship benefits in a timely manner and identify fraudulent and criminal activity.
This statement summarizes GAO's most recent reports on USCIS's Transformation Program. These reports focus on cost increases and schedule delays and program management challenges that have contributed to increasing risks to the new system. GAO identified the program as one of ten federal high-risk investments in need of attention in 2015.
section_title: What GAO Found
paragraphs: The U.S. Citizenship and Immigration Services' (USCIS) most recent cost and schedule baseline, approved in April 2015, indicates that its Transformation Program will cost up to $3.1 billion and be fully deployed no later than March 2019. This is an increase of approximately $1 billion with a delay of more than 4 years from its initial July 2011 acquisition program baseline. In addition, the program is currently working to develop a new cost and schedule baseline to reflect further delays. Due to the program's recurring schedule delays, USCIS will continue to incur costs for maintaining its existing systems while the program awaits full implementation. Moreover, USCIS's ability to achieve program goals, including enhanced national security, better customer service, and operational efficiency improvements, will be delayed.
Recurring delays are partly the result of challenges in program management. In July 2016, GAO reported that the USCIS Transformation Program had fully addressed some, and partially addressed many other key practices for implementing software development, conducting systems integration and testing, and monitoring the largest program contractors. Nevertheless, GAO reported that the program inconsistently adhered to these practices. For example,
The program had established an environment and procedures for continuously integrating functionality and was conducting various tests and inspections of new software code. However, the program was not consistently adhering to its policies and guidance or meeting stated benchmarks for testing and inspections.
The program had reported experiencing issues such as production defects and bugs in the system as a result of deploying software that had not been fully tested.
The program had mixed success in monitoring its contractors for six contracts that GAO reviewed. For example, a development services contract contained appropriate performance criteria that linked to the program goals, but the program did not clearly define measures against which to analyze differences between services expected and those delivered.
Its software development approach deviated from key practices in part because USCIS policy and guidance were not being updated.
Given the history of development for the Transformation Program and the subsequent commitment of additional resources for a new system, it is more important than ever that USCIS consistently follow key practices in its system development efforts. For example, the program has already reported realizing risks associated with deploying software that has not been fully tested, such as system bugs, defects, and unplanned network outages. If the agency does not address the issues GAO has identified in prior work, then it will continue to experience significant risk for increased costs, further schedule delays, and performance shortfalls.
section_title: What GAO Recommends
paragraphs: In its prior reports, GAO made 30 recommendations to address weaknesses in the management and acquisition of the Transformation Program. USCIS concurred and has fully addressed 17 of the 30 recommendations to date.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the challenges that U.S.  Citizenship and Immigration Services (USCIS) has had in developing an  electronic system to support and modernize the filing and processing of  immigration and citizenship applications. As you know, each year, USCIS,  an agency within the Department of Homeland Security (DHS), processes  millions of mostly paper-based applications and petitions for more than 50  types of immigrant and nonimmigrant-related benefits. Having a seamless  electronic system would assist the agency in accurately processing  immigration and citizenship benefits in a timely manner to eligible  applicants. Such a system would also assist in denying benefits to those  who are ineligible. In addition, the system could help USCIS identify  fraudulent and criminal activity, essential for ensuring the integrity of the  immigration process.
We have long recognized the need to improve the USCIS benefits  application and adjudication processes and underlying technology  infrastructure. For example, in May 2001, we reported that some  applications and petitions—benefit applications—took 2 years or longer to  process. This lengthy process resulted in backlogs of pending  applications. More recently, in September 2016, we reported that USCIS  was unable to comprehensively identify and address fraud trends across  the immigrant investor program in part because of its reliance on paper- based documentation and limitations with using and collecting that data  for the program. According to an official from USCIS’s Fraud Detection  and National Security Directorate, this supporting data could be an  important source for fraud indicators.
In 2006, USCIS embarked on a major initiative, the Transformation  Program, to address processing inefficiencies and transform its current  paper-based system into an electronic account-based system. This  system was expected to incorporate electronic adjudication and account- based case management tools, including tools that would allow applicants  to apply online for benefits. However, since its inception, we have  reported that the program has continually faced management and  development challenges, limiting its progress and ability to achieve its  goals of enhanced national security and system integrity, better customer  service, and operational efficiency. Over the last 10 fiscal years, we have  made 30 recommendations to address weaknesses in the program’s  acquisitions and operations. USCIS has fully addressed 17 of these 30  recommendations. Based in part on our concerns about the  Transformation Program, we identified it as one of ten investments in  need of the most attention when we designated managing information  technology (IT) acquisitions and operations across the federal  government as high risk in 2015.
My testimony today will focus on Transformation Program cost increases  and schedule delays and program management challenges that have  contributed to increasing risks to the new system. In developing this  testimony, we relied on our previous reports, as well as information  provided by the department on its actions in response to our previous  recommendations and ongoing work. A more detailed discussion of the  objectives, scope, and methodology for this work is included in each of  the reports that are cited throughout this statement.
All of the work on which this statement is based was conducted 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: The goals of the Transformation Program are to modernize the paper- based immigration benefits process, enhance national security and  system integrity, and improve customer service and operational  efficiency. Established in 2006, the program comprises many systems,  each of which provides a service to facilitate operations, such as identity  management and risk and fraud analytics. The objectives of the  Transformation Program are to allow applicants to establish an account with USCIS to file and track the  status of the application, petition, or request online;  the USCIS Electronic Immigration System (USCIS ELIS), which is the  main component of the program, to apply risk-based rules  automatically to incoming applications, petitions, and requests to  identify potentially fraudulent applications and national security risks; adjudicators to have electronic access to applications, petitions, and  requests, relevant policies and procedures, and external databases;
USCIS to have management information to track and allocate
USCIS ELIS to have electronic linkages to other agencies, such as  the Departments of Justice and State, for data sharing and security  purposes.
As the main component of the program, USCIS ELIS is to provide case  management for adjudicating immigration benefits. USCIS ELIS relies on  and interfaces with other systems that provide additional capabilities,  such as user authentication and scheduling, to deliver end-to-end  processing. In particular, as of July 2016, the system was expected to  interface with at least 30 other systems, ranging in function from fraud  detection to law enforcement and to online payment.
The program expects to achieve its goals and objectives through the  delivery of five core operating requirements. These core requirements,  which are expected to collectively deliver the program’s mission needs,  are (1) intake and account management; (2) benefits case management;  (3) electronic content management; (4) agency and knowledge  management; and (5) risk and fraud management. Table 1 describes the  five core operational requirements.
subsections: section_title: Program Governance and Oversight
paragraphs: The USCIS Transformation Program is governed by multiple bodies  within DHS and the program. Specifically, DHS governance bodies, such  as the Acquisition Review Board and Executive Steering Committee,  evaluate cost, schedule, and performance of a program and provide  corrective actions when needed. In addition, the department’s Office of  the Chief Information Officer and Office of Program Accountability and  Risk Management conduct oversight of individual programs, which in turn,  informs congressional and Office of Management and Budget oversight.  For example, the Office of Program Accountability and Risk Management  develops periodic reports to ensure that various DHS programs and their  components within the agency satisfy compliance-related mandates and  improve investment management. In addition, the Office of the Chief  Information Officer performs periodic reviews that serve as the basis for  publicly reported program ratings.
Within USCIS, directorates govern divisions and program offices govern  specific functions, such as the Transformation Program. One program  office, the Office of Transformation Coordination, has managed and  overseen the development of USCIS ELIS. Other USCIS directorates and  program offices, including the Office of Information Technology and the  Customer Service and Public Engagement directorate, have supported  the management and oversight of the larger USCIS Transformation  Program.
section_title: Software Development Approach
paragraphs: In April 2015, USCIS officially changed its software development  approach. In particular, USCIS transitioned from a waterfall approach to  develop, test, and deliver USCIS ELIS functionality to an incremental  approach. In an incremental approach, software is developed, tested, and  delivered in smaller components or phases, rather than in the typically  long, sequential phases of a traditional waterfall approach. Incremental  software development is consistent with the Office of Management and  Budget’s IT Reform Plan and the law commonly referred to as the  Federal Information Technology Acquisition Reform Act (FITARA). The  incremental approach chosen by USCIS, called Agile, is intended to allow  subject matter experts to validate requirements, processes, and system  functionality in increments, and deliver the functionality to users in short  cycles.
section_title: Transformation Program Has Experienced Significant Cost Increases and Schedule Delays
paragraphs: Since USCIS began implementation of the Transformation Program in  2006, the effort has experienced significant cost increases and schedule  delays. In particular, the program’s most recent baseline, approved in  April 2015, indicates that the Transformation Program will cost up to $3.1  billion and be fully deployed no later than March 2019.This is an increase  of approximately $1 billion with a delay of more than 4 years from its initial  July 2011 acquisition program baseline. In November 2008, USCIS  awarded a solutions architect contract for approximately $500 million over  a 5-year period to design, develop, test, deploy, and sustain the  Transformation Program by November 2013. In July 2011, DHS officially  approved the Transformation Program’s acquisition program baseline and  supporting operational requirements. This baseline estimate was for  about $2.1 billion and the program was projected to reach full operating  capability no later than June 2014.
In May 2012, USCIS launched the first release of USCIS ELIS. This  release included capabilities associated with all of the system’s core  operational requirements, such as online account setup, case  management, case acceptance, applicant evidence intake, and notice  generation. Subsequent to this first release, USCIS deployed additional  releases to add functionality. This initial USCIS ELIS was used to  process nonimmigrant requests to change or extend their status, USCIS  immigrant fees, and immigrant petitions for foreign nationals who make  investments in U.S. commercial enterprises.
Beginning in 2013, the program was operating beyond its approved  baseline, a situation DHS referred to as being “in breach.” As a result,  we reported in 2015 that the program was not in compliance with DHS  acquisition policies and procedures. To address the breach, DHS  acquisition policies and procedures required that, within 90 days, a new  baseline be approved or a program review be conducted to review the  proposed baseline revisions. We reported that neither of these actions  had taken place since 2013.
However, despite exceeding its approved baseline and operating without  a DHS-approved revised acquisition strategy and baseline, the  Transformation program continued with its system development efforts.  As part of the continued development, USCIS pursued a new acquisition  approach. As we reported in May 2015, changes in its approach  included changes to the software development methodology, contracting  approach, and program architecture and were intended to help address  concerns about delays and cost overruns. See table 2 for a description of  these changes.
The shift in acquisition approach also resulted in the proposed  development of a new USCIS ELIS system. The new system was to be a  separate and distinct system from the previously-developed USCIS ELIS.  In November 2014, after a year and a half of planning and development,  USCIS deployed an initial version of the new USCIS ELIS system to allow  for limited processing of permanent resident card renewals and  replacements. This initial deployment also tested all core processing  capabilities, such as the ability to electronically file or schedule  appointments for collecting biometric information.
Between November 2014 and February 2015, the functionality of the new  USCIS ELIS was enhanced to allow full processing of permanent resident  card renewals and replacements. Nevertheless, during this time, the  Transformation Program continued to operate in breach status, without a  DHS-approved revised acquisition strategy and baseline. In 2015, we  reported that this breach had impacted DHS’ ability to effectively  oversee and govern the program because oversight was no longer being  conducted relative to a current and approved program schedule.
The program’s revised acquisition baseline and strategy were formally  approved in April 2015, over 2 years after the breach. Under its new  acquisition baseline, USCIS estimated the program to cost up to $3.1  billion and to be fully deployed no later than March 2019. This was an  increase of approximately $1 billion and a delay of over 4 years from the  program’s initial approved baseline in July 2011.
The new acquisition strategy represented official DHS approval of the  program’s updated acquisition approach and also formally required that  the old USCIS ELIS be decommissioned and that USCIS continue to  pursue the new USCIS ELIS. In May 2015, we reported that changes in  the Transformation Program acquisition strategy intended, in part, to  address the breach had contributed to significant delays in the program’s  planned schedule.
In July 2016, we once again expressed concerns over program  performance, focusing on the reliability of the program’s cost, schedule,  and scope measurements. For example, we reported that delays in the  schedule could increase the risk that the program would proceed with  future USCIS ELIS development or deployment before it was ready in  order to meet committed dates. In addition, we reported that the program  was at risk of future schedule delays in later USCIS ELIS releases, which  might result in the program exceeding its revised cost or schedule  thresholds. We made twelve recommendations to improve the ability of  USCIS to manage the program. USCIS concurred with our  recommendations and has initiated work to implement them.
USCIS continues to expand the ability of the new USCIS ELIS to process  citizenship and immigration benefits. Specifically, after April 2016, USCIS  deployed the additional capability to process applications for temporary  protected status and additional naturalization forms. However, in August  2016, the program reverted back to the legacy system, called the  Computer-Linked Application Information Management System 4, for  processing the same naturalization form that had been deployed in the  new USCIS ELIS only 4 months earlier. As a result of the switchover and  other technical issues with the new system, the program did not complete  deployment of system functionality associated with its Citizenship line of  business by its September 2016 deadline, resulting in another schedule  breach.
In November 2016, USCIS submitted a breach remediation plan to the  Deputy Under Secretary for Management that identified several root  causes for the breach. These causes included that:  the program’s schedule did not allow time to gather user feedback or  address complexities discovered during development; new requirements were added; and,
USCIS leadership did not provide any consistent performance  requirements on what the program was supposed to accomplish for  specific business lines.
USCIS had planned to re-baseline the program in February 2017 to  account for the September 2016 breach. However, in December 2016,  DHS leadership directed USCIS to stop planning and development for  new lines of business, update its breach remediation plan and acquisition  documentation, and brief leadership on the program’s revised approach  by February 2017. The program submitted a revised remediation plan on  February 1, 2017. The revised plan was subsequently accepted by the  Acting Under Secretary for Management on February 14, 2017.
The revised remediation plan set an expectation that the program would  submit revised acquisition documentation for review including a new  baseline by February 28, 2017. However, according to the Deputy Chief  of the Resource Management Division within the USCIS Office of  Information Technology, the program was granted an extension.  According to this official, the program expects to discuss the revised  acquisition documentation before the Acquisition Review Board in March  2017.
subsections: section_title: Delays are Impacting the Ability of USCIS to Realize the Benefits of Transformation
paragraphs: The Transformation Program’s delays in delivering system functionality  have limited USCIS’s ability to realize its planned cost savings and  operational improvements. With respect to cost savings, the program’s  business case highlighted cost savings that would be realized from  decommissioning legacy systems on full deployment of USCIS ELIS.
However, these legacy systems must remain operational to allow USCIS  to perform its mission until an alternative option is available—thus,  preventing the associated savings from being realized. For example, in  fiscal year 2014, the total cost of maintaining systems that could have  been decommissioned if USCIS ELIS had been fully operational was  approximately $71 million. Further, the business case for the  Transformation Program identified anticipated cost savings from reducing  data entry and mail handling costs. With the continuing delays, however,  USCIS will continue to incur such costs while the program awaits full  implementation.
In addition, the schedule delays have deferred USCIS’s ability to realize  operational improvements tied to the program and intended to resolve  issues we’ve previously reported. For example, the Transformation  Program is expected to implement organizational and business process  changes to better use the new electronic system. According to USCIS,  this increased use of IT should help achieve goals such as reducing the  immigration benefit backlogs through business process change,  improving customer service through expanded electronic filing, and  enhancing national security by authenticating users and integrating with  external agency databases. However, once again, the delays in delivery  of the program mean that these improvements have yet to be achieved.
section_title: Program Management Challenges Contribute to System Performance Risks
paragraphs: Prior to the Transformation Program’s change in acquisition strategy,  USCIS spent more than 8 years and approximately $475 million on  developing the old USCIS ELIS. According to program officials, this  system was decommissioned in April 2016 due to its instability. As we  have reported, the old USCIS ELIS proceeded through development  despite challenges in program management and limited oversight. Given  this history and the subsequent commitment of additional resources for a  new USCIS ELIS, it is more important than ever that USCIS consistently  follow key practices associated with software development, systems  integration and testing, and contract management and execute effective  program oversight and governance.
Inconsistent Software Development Practices Risk Further Program  Costs and Delays  In July 2016, we reported that the program had at least partially adhered  to 7 of 8 key practices for effectively managing Agile software  development in producing USCIS ELIS. We reported that the program  deviated from key software development practices for various reasons.  For example, we reported that the program was not always completing  planning for software releases prior to initiating development as required  in agency policy. The USCIS Chief Information Officer explained that,  although policy requires a program to obtain approval for the scope of  each release prior to proceeding with development, this was no longer the  practice for the Transformation Program. Instead, approval was granted  for six months of development and the scope of that approval was  revisited as needed. In contrast, time frames of individual releases were  expected to vary depending on the scope of the release.
We also found that the program was not consistently following other key  practices and that controls were not always in place to ensure the  program adhered to them. For example, with respect to monitoring and  reporting on program performance through the collection of reliable  metrics, we were unable to track monthly reports on program scope back  to the associated software release backlog. In addressing this matter, the  Business Integration Division within the Office of Transformation  Coordination acknowledged issues regarding traceability. The division  subsequently determined that its process for tracking monthly reports on  program scope back to the associated software release backlog was not  effective since it relied solely on the review of the user stories. The  division acknowledged that requirements traceability is critical to avoid  scope creep and to demonstrate that the features implemented  addressed the mission needs.
With respect to the practice of setting outcomes for Agile software  development, which is the only key practice that the program did not fully  or partially address, the program did not define Agile software  development outcomes. The program provided various reasons for not  addressing the practice. For example, the Chief of OTC stated that the  outcome or goal for the program is to deploy a product line within  baseline cost, schedule, and performance parameters. Nevertheless, we  reported that the program had not established a well understood goal, or  set of goals, for its transition to Agile development. Table 3 describes the  program’s satisfaction of key practices in developing USCIS ELIS.
In not addressing key practices for Agile software development, the  program faces added risks in deploying a system that does not meet the  cost, schedule, or the performance needs of USCIS. We recommended  that the program, with assistance from the department, take seven  actions to provide reasonable assurance that it executes Agile software  development for USCIS ELIS consistent with its own policies and  guidance and follows applicable leading practices. At present, all of these  recommendations remain open.
Testing Practices Need Improvement to Address System  Performance Risks  In this same report, we found that the program was not consistently  following key system integration and testing practices. Specifically, the  program had fully implemented 1 and partially implemented 2 key  practices. For example, the program had established an environment and  procedures for continuous integration and was conducting unit and  integration, functional acceptance, interoperability, and end user tests, as  well as performing code inspection. However, we also found that the  program was not consistently adhering to its policies and guidance or  meeting benchmarks for unit and integration, and functional acceptance  tests, and code inspection. Moreover, test plans, cases, and results were  not fully developed for interoperability and end user testing.
We reported that the implementation of systems integration and testing  deviated from key practices in part because policy and guidance were not  being updated to reflect changes in the approach. For example, with  respect to performing continuous testing, the program did not meet its  stated goals for continuous testing because, according to the USCIS  Chief Information Officer, certain program goals were unrealistic. Table 4  describes the program’s satisfaction of key practices in USCIS ELIS  integration and testing.
In addition, program policy and guidance did not always align with key  practices in systems integration and testing, nor were controls always in  place to ensure adherence to policy and guidance. For example, before a  developer could integrate code with that of other developers or  development teams, peer inspection by another individual was expected  to occur to help ensure that the code met program standards. However,  the program had not established controls to monitor the extent to which  peer inspection had occurred.
As a result of these findings on systems integration and testing, we  reported that the program risked poor system performance after being  released to the public. At that time, this risk was already being realized.  Specifically, the program had reported experiencing issues with USCIS  ELIS as a result of deploying software that had not been fully tested. For  example:  In June 2015, the Quality Assurance Team reported that production  issues, such as bugs and defects, had increased noticeably after the  February 2015 deployment.
In July 2015, the Quality Assurance Team reported that defects  (originating from either production or development) were becoming a  significant part of USCIS ELIS iteration work.
On September 22, 2015, in addition to prior and subsequent outages  of the system, the Quality Assurance Team reported that USCIS ELIS  was unavailable for approximately 15 hours due to issues with code  quality.
On September 24, 2015, USCIS ELIS encountered performance  problems that impacted nearly 5,000 cases. Approximately 2,600 of  these cases had to be abandoned.
In November and December 2015, the Quality Assurance Team  reported that code quality had become a major issue.
In January 2016, the program reported more than 800 minutes in  unplanned network outages.
In February 2016, the program reported missing the threshold for  USCIS ELIS reliability (e.g. mean time between failure), for two  straight months and four of the last six months.
In March 2016, program metrics indicated that production tickets were  increasing faster than they could be addressed.
Based on these findings associated with systems integration and testing,  we made two recommendations to the program. These recommendations  were associated with updating existing policy and guidance for systems  integration and testing and considering additional controls. At present,  these recommendations remain open.
Contract Oversight Practices Limit Contractor Accountability  In the same report, based on a review of six contracts, we found that  USCIS had mixed success in implementing selected key contract  management internal controls. Specifically, we found that contracting  officer representatives were meeting training requirements and USCIS  had documented its rationale for not pursuing selected contracts as  performance based. However, we also reported that the program could  improve contract monitoring to provide reasonable assurance that  contractors were meeting program needs. For example, we reported that
The Agile development services contract contained appropriate  performance criteria that linked to the program goals, but the program  did not clearly define measures against which to analyze differences  between services expected and those delivered. Because oversight of  contractor performance resides with the Office of Transformation  Coordination and management of the contract is the responsibility of  the Office of Information Technology, we reported that the need for  clearly-defined performance measures was particularly important.
The program maintained some required documentation in contract  files and used contractor performance assessments. However, more  clearly defined success measures and evaluation against those  measures could have alerted the program to issues in systems  integration and testing.
Based on these findings, we reported that the agency lacked information  for measuring contractor performance and determining if the Office of  Information Technology was meeting its objectives in supporting the  program. To help improve oversight of these selected contracts, we made  three recommendations focused on contract administration and  supporting controls. Since then, the agency has taken steps to close  these recommendations, successfully closing two of the three. If  effectively implemented, these actions should contribute to improved  administration of the contracts that we assessed in our review.
DHS Oversight Bodies Need to Improve Governance and Oversight  of the Transformation Program  We also reported in May 2015 that the program’s two key governance  bodies were mostly taking actions aligned with leading practices, but that  their decisions were made based on unreliable information. For example,  we reported that the Acquisition Review Board ensured that corrective  actions were identified when cost, schedule, or performance issues  arose. However, the board was not always monitoring performance and  progress toward a predefined cost and schedule or ensuring that  corrective actions were tracked until the desired outcomes were  achieved.
In addition, we found that two DHS offices assisting in overseeing the  program—the Office of Program Accountability and Risk Management  and the Office of the Chief Information Officer— developed program  assessments that reflected unreliable and, in some cases, inaccurate  information. For example, the Office of the Chief Information Officer  performed four assessments of the Transformation Program from June  2013 through June 2014. The most recent assessment available at the  time, from June 2014, stated that the program underwent a re-baseline  for release 5.0 and, as a result, reported an acceptable schedule variance  and positive cost performance. However, at that time, the program had  experienced over a 4-year delay in its schedule and had not performed a  re-baseline to bring it back within cost and schedule thresholds.
Based on these findings, we reported that the ability of governance  bodies to make timely decisions and provide effective oversight was  limited. To help improve program governance, we made four  recommendations. Subsequently, the program addressed one  recommendation by establishing a new baseline, although that baseline  has again been breached. The program has taken steps to close the  remaining recommendations, although the recommendations remain  open.
In summary, the USCIS Transformation Program began officially pursuing  a new acquisition strategy in April 2015 to mitigate risks encountered in  developing the original system. However, this new strategy reflects a  higher cost estimate and a longer amount of time before the system is  fully implemented than the program’s previously approved strategy. In  addition, the program is again encountering issues in development and  production. If the agency does not address issues in its efforts to develop  and test software, oversee contractors, and govern the program it risks  additional cost increases, schedule delays, and performance shortfalls. In  addition, continued delays limit the program’s ability to achieve critical  goals, such as delivering system functionality to enhance customer  service and enhancing national security.
Chairman Perry, Ranking Member Correa, and Members of the  subcommittee, this completes my prepared statement. I would be pleased  to respond to any questions that you may have at this time.
section_title: Contacts and Acknowledgments
paragraphs: If you or your staffs have any questions about this testimony, please  contact Carol C. Harris, Director, Information Technology Acquisition  Management Issues, 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 testimony statement. GAO staff who  made key contributions to this testimony are Michael Holland (Assistant  Director), Mathew Bader (Analyst in Charge), and Nancy Glover.
section_title: Appendix I: Related GAO Products
paragraphs: Immigrant Investor Program: Progress Made to Detect and Prevent  Fraud, but Additional Actions Could Further Agency Efforts, GAO-16-828  (Washington, D.C.: Sept. 13, 2016).
Immigration Benefits System: U.S. Citizenship and Immigration Services  Can Improve Program Management, GAO-16-467 (Washington, D.C.:  July 7, 2016).
Asylum: Additional Actions Needed to Assess and Address Fraud Risks,  GAO-16-50 (Washington, D.C.: Dec. 2, 2015).
Immigrant Investor Program: Additional Actions Needed to Better Assess  Fraud Risks and Report Economic Benefits, GAO-15-696 (Washington,  D.C.: Aug. 12, 2015).
Immigration Benefits System: Better Informed Decision Making Needed  on Transformation Program, GAO-15-415 (Washington, D.C.: May 18,  2015).
H-2A and H-2B Visa Programs: Increased Protections Needed for  Foreign Workers, GAO-15-154 (Washington, D.C.: Mar. 6, 2015).
Immigration Benefits: Improvements Needed to Fully Implement the  International Marriage Broker Regulation Act, GAO-15-3 (Washington,  D.C.: Dec. 10, 2014).
H-2A Visa Program: Modernization and Improved Guidance Could  Reduce Employer Application Burden, GAO-12-706 (Washington, D.C.:  Sept. 12, 2012).
Immigration Benefits: Consistent Adherence to DHS’s Acquisition Policy  Could Help Improve Transformation Program Outcomes, GAO-12-66  (Washington, D.C.: Nov. 22, 2011).
Department of Homeland Security: Progress Made and Work Remaining  in Implementing Homeland Security Missions 10 Years after 9/11,  GAO-11-881 (Washington, D.C.: Sept. 7, 2011).
Immigration Benefits: Actions Needed to Address Vulnerabilities in  Process for Granting Permanent Residency, GAO-09-55 (Washington,  D.C.: Dec. 5, 2008).
USCIS Transformation: Improvements to Performance, Human Capital,  and Information Technology Management Needed as Modernization  Proceeds, GAO-07-1013R (Washington, D.C.: July 17, 2007).
section_title: Appendix II: Status of GAO Recommendations to Improve Transformation Program Performance
paragraphs: Appendix II: Status of GAO Recommendations  to Improve Transformation Program  Performance Recommendation  1.  Document specific performance measures and targets for the pilots, increments, and the  transformed organization that are outcome-oriented, objective, reliable, balanced, limited to  the vital-few, measurable, and aligned with organizational goals.
Increase coordination between program office and the Office of Human Capital to ensure  transformation and human capital change initiatives are aligned.  3.  Plan for the number and types of human resources required in the program office to carry the  4.  Plan for obtaining and developing the IT human capital necessary to support the  5.  Determine the critical skills and competencies that will be needed to achieve future  programmatic results as well as strategies to address gaps in employee numbers,  deployment, and skills and competencies.  6.  Address continuity in key transformation leadership positions and address impacts to time  7.  Use performance expectations and competencies to hold USCIS executives and employees  accountable for achieving the goals of the transformation.  8.  Continue to develop an enterprise architecture that sufficiently guides and constrains the  transformation plans, as DHS works to address limitations in its own enterprise architecture  and alignment processes.  9.  Complete a comprehensive communication strategy that involves communicating early and  often to build trust, ensuring consistency of message, and encouraging two-way  communication. Further, the communication strategy should address plans for  communicating implementation goals and timelines to demonstrate progress.  10.  Complete a comprehensive communication strategy that addresses plans for formally  engaging internal and external stakeholders throughout the transformation, and tailors  information to meet these stakeholders’ specific needs.  11.  Complete a comprehensive communication strategy that addresses plans for a long-term,  detailed strategy to share information with employees and stakeholders over the course of  the transformation.  12.  Document specific performance measures and targets for the pilots, increments, and the  transformed organization that are outcome-oriented, objective, reliable, balanced, limited to  the vital-few, measurable, and aligned with organizational goals.  13.  Develop and maintain an Integrated Master Schedule consistent with these same best  practices for the Transformation Program.  14.  Ensure that the life-cycle cost estimate is informed by milestones and associated tasks from  reliable schedules that are developed in accordance with the nine best practices we  identified.  15.  Re-baseline cost, schedule, and performance expectations for the remainder of the  16.  Ensure that the Acquisition Review Board is effectively monitoring the Transformation  Program’s performance and progress toward a predefined cost and schedule; ensuring that  corrective actions are tracked until the desired outcomes are achieved; and relying on  complete and accurate program data to review the performance of the Transformation  Program against stated expectations.
Recommendation  17.  Ensure that the Executive Steering Committee is effectively monitoring the Transformation  Program’s performance and progress toward a predefined cost and schedule and relying on  complete and accurate program data to review the performance of the Transformation  Program against stated expectations.  18.  Direct the department’s Chief Information Officer to use accurate and reliable information,  such as operational assessments of the new architecture and cost and schedule parameters  approved by the Under Secretary of Management.  19.  Complete planning for software releases prior to initiating development and ensure software  meets business expectations prior to deployment.  20.  Consistently implement the principles of the framework adopted for Agile software  21.  Define and consistently execute appropriate roles and responsibilities for individuals  responsible for development activities consistent with its selected development framework.  22.  Identify all system users and involve them in release planning activities.  23.  Write user stories that identify user roles, include estimates of complexity, take no longer than  one sprint to complete, and describe business value.  24.  Establish outcomes for Agile software development.  25.  Monitor program performance and report to appropriate entities through the collection of  26.  Conduct unit and integration, and functional acceptance tests, and code inspection consistent  27.  Develop complete test plans and cases for interoperability and end user testing, as defined in  the USCIS Transformation Program Test and Evaluation Master Plan, and document the  results.  28.  Clearly define measures against which to analyze differences between services expected  29.  Ensure contracting officer representatives are maintaining complete contract files.  30.  Ensure quality assurance surveillance plans are developed when appropriate.
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