Library of Congress: Strong Leadership Needed to Address Serious Information Technology Management Weaknesses
Published: 2015-03-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Library of Congress is the world's largest library, whose mission is to make its resources available and useful to Congress and the American public. In carrying out its mission, the Library increasingly relies on IT systems, particularly in light of the ways that digital technology has changed the way information is created, shared, and preserved.
The House Appropriations Committee report accompanying the 2015 legislative branch appropriations bill required GAO to conduct a review of IT management at the Library. GAO's objectives focused on the extent to which the Library has established and implemented key IT practices and requirements in, among other areas: (1) strategic planning, (2) governance and investment management, (3) information security and privacy, (4) service management, and (5) leadership. To carry out its work, GAO reviewed Library regulations, policies, procedures, plans, and other relevant documentation for each area and interviewed key Library officials.
section_title: What GAO Found
paragraphs: The Library of Congress has established policies and procedures for managing its information technology (IT) resources, but significant weaknesses across several areas have hindered their effectiveness:
Strategic planning: The Library does not have an IT strategic plan that is aligned with the overall agency strategic plan and establishes goals, measures, and strategies. This leaves the Library without a clear direction for its use of IT.
Investment management: Although the Library obligated at least $119 million on IT for fiscal year 2014, it is not effectively managing its investments. To its credit, the Library has established structures for managing IT investments—including a review board and a process for selecting investments. However, the board does not review all key investments, and its roles and responsibilities are not always clearly defined. Additionally, the Library does not have a complete process for tracking its IT spending or an accurate inventory of its assets. For example, while the inventory identifies over 18,000 computers currently in use, officials stated that the Library has fewer than 6,500. Until the Library addresses these weaknesses, its ability to make informed decisions will be impaired.
Information security and privacy: The Library assigned roles and responsibilities and developed policies and procedures for securing its information and systems. However, its implementation of key security and privacy management controls was uneven. For example, the Library's system inventory did not include all key systems. Additionally, the Library did not always fully define and test security controls for its systems, remediate weaknesses in a timely manner, and assess the risks to the privacy of personal information in its systems. Such deficiencies also contributed to weaknesses in technical security controls, putting the Library's systems and information at risk of compromise.
Service management: The Library's Information Technology Services (ITS) division is primarily responsible for providing IT services to the agency's operating units. While ITS has catalogued these services, it has not fully developed agreements with the other units specifying expected levels of performance. Further, the other units were often not satisfied with these services, which has contributed to them independently pursuing their own IT activities. This in turn has resulted in units purchasing unnecessary hardware and software, maintaining separate e-mail environments, and managing overlapping or duplicative IT activities.
Leadership: The Library does not have the leadership needed to address these IT management weaknesses. For example, the agency's chief information officer (CIO) position does not have adequate authority over or oversight of the Library's IT. Additionally, the Library has not had a permanent CIO since 2012 and has had five temporary CIOs in the interim.
In January 2015, at the conclusion of GAO's review, officials stated that that the Library plans to draft an IT strategic plan within 90 days and hire a permanent CIO. If it follows through on these plans, the Library will be in a stronger position to address its IT management weaknesses and more effectively support its mission.
section_title: What GAO Recommends
paragraphs: GAO is recommending that the Library expeditiously hire a permanent CIO. GAO is also making 30 other recommendations to the Library aimed at establishing and implementing key IT management practices. The Library generally agreed with GAO's recommendations and described planned and ongoing actions to address them.

section_title: Letter
paragraphs: The Library of Congress is the United States’ oldest federal cultural  institution and plays an important role in the life of the nation. Since its  founding in 1800 as mainly a reference and lending library for members of  Congress, it has grown to include the world’s largest library, with a  mission to support the Congress in fulfilling its constitutional duties and to  further the progress of knowledge and creativity for the benefit of the  American people. In addition to maintaining its collection of books,  recordings, photographs, maps, manuscripts, and other items, the Library  provides research and policy analysis to members of Congress and their  staff. Further, since the late 19th century, the Library of Congress has  been home to the U.S. Copyright Office, which is responsible for  administering and sustaining an effective national copyright system.
As technology has advanced and the needs of its users have evolved, the  Library has increasingly relied on information technology (IT) to carry out  its mission, and these changes have required it to reexamine how it will  accomplish its mission in the future. Digital technology is fundamentally  changing how information is created, shared, and preserved, while the  Internet has changed the public’s expectations about access to  information. For example, the public no longer has to physically visit a  library to obtain free access to many of its collection items.
To help ensure the effective management of the Library’s IT resources,  the House Appropriations Committee report accompanying the fiscal year  2015 legislative branch appropriations bill required GAO to review the  actions taken by the Library to manage the IT supporting its programs  and operations. Our specific objectives for this review were to assess the  extent to which the Library (1) addressed in its strategic planning the IT  and related resources required to meet its goals and objectives; (2)  established an IT governance structure to manage the selection, control,  and evaluation of IT investments; (3) used key IT acquisition and  development best practices; (4) established programs for ensuring the  information security and privacy protection of its information and  information systems; (5) used best practices for managing IT services;  and (6) has a chief information officer (CIO) with authority to exercise  control and oversight of IT management functions.
To address our objectives, we compared Library policies, procedures,  and implementation in the six IT-management-related areas with federal  laws and guidance and with key practices identified by industry and  GAO—many of which the Library has embraced. Specifically, we did the  following:
Reviewed Library strategic planning documents, including its agency- wide strategic plan, draft IT-specific strategic plan, enterprise  architecture documentation, and human capital plan to determine if  the Library’s planning for IT was aligned with the strategic goals of the  agency, whether it had developed an enterprise architecture that  described its current and planned business process and IT  environment, and whether it had identified skills needed to achieve its  goals and any gaps it needed to fill.
Reviewed Library policies, procedures, and other documentation for  IT investment management, including documentation relating to the  activities of its IT Steering Committee and other oversight bodies, and  compared them to recognized practices for establishing a disciplined,  repeatable process for IT investment management. We further  examined documentation related to three selected investments  undergoing the Library’s investment management process to assess  the information that was used to select and oversee these  investments. We also reviewed Library spending data, including its  annual expenditures on IT, and information on its inventory of  investments and assets, to determine if these were comprehensive.
Examined Library policies and procedures to determine if they  reflected best practices for selected key acquisition areas—risk  management, requirements development, cost estimation, and  scheduling. We also reviewed documentation for the three selected  investments to determine the extent to which they had implemented  these practices.
Assessed Library policies, procedures, and other documentation  related to its information security and privacy programs against  relevant federal guidance. To do so, we selected nine information  systems across the Library to determine the extent to which the  Library had implemented management controls in key areas related to  information security and privacy. We also conducted testing to  determine whether appropriate technical security controls had been  applied. Further, we visited Library data center facilities in the greater  Washington, D.C., area to assess physical, environmental, and other  controls intended to protect the assets at these facilities.
Examined policies and documentation for managing IT services  across the Library to determine if they supported the needs of the  organization. This included reviewing a service catalog and service- level agreements developed by the Library’s central IT organization— ITS—for services it provides to other units within the Library. We also  conducted a customer satisfaction survey of other units to determine  their level of satisfaction with ITS’s service and sent a structured  questionnaire to each service unit to identify potentially duplicative IT  activities across the Library.
Reviewed polices outlining the responsibilities of the CIO and other  key officials, and reviewed documentation to determine if these  officials were carrying out their responsibilities for effective leadership  of IT management.
For each objective, we also interviewed key officials with responsibilities  for IT management at the Library. These included the Librarian of  Congress, the former Deputy Librarian, the former acting CIO, the head of  ITS, the Chief Information Security Officer, heads of the various service  units, and IT staff at the service units, among others.
We conducted this performance audit from April 2014 to March 2015 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. Additional details on our  objectives, scope, and methodology can be found in appendix I.
subsections: section_title: Background
paragraphs: Established in 1800, the Library of Congress is the nation’s oldest federal  cultural institution and serves as the research arm of Congress. Its  mission is to support Congress in fulfilling its constitutional duties and to  further the progress of knowledge and creativity for the benefit of the  American people.
The Library of Congress is the largest library in the world, with more than  158 million items on approximately 838 miles of bookshelves. The  collections include more than 36 million books and other print materials,  3.5 million recordings, 13.7 million photographs, 5.5 million maps, 6.7  million pieces of sheet music, and 69 million manuscripts.
The Library receives some 15,000 items each working day and adds  approximately 12,000 items to its collections daily. These items are  received through a variety of sources, including the copyright registration  process, as the Library is home to the U.S. Copyright Office. Materials are  also acquired through gift, purchase, other government agencies (state,  local, and federal), Cataloging in Publication (a pre-publication  arrangement with publishers), and exchange with libraries in the United  States and abroad. Items not selected for the collections or other internal  purposes are used in the Library’s national and international exchange  programs. Through these exchanges the Library acquires material that  would not be available otherwise. The remaining items not selected for  collections or exchange programs are made available to other federal  agencies and are then available for donation to educational institutions,  public bodies, and nonprofit tax-exempt organizations in the United  States.
The Library collaborates with external communities nationally and  internationally through, among other things, activities relating to  preservation, research, and education. For example, the Library collects,  preserves, and makes accessible first-hand accounts of U.S. veterans so  that future generations may hear directly from veterans. Additionally, in  collaboration with the United Nations Educational Scientific and Cultural  Organization, as well as partner libraries and cultural institutions from  around the world, the Library established the World Digital Library. This  effort makes available on the Internet, free of charge, and in multilingual  format significant primary materials from many countries and cultures.  Further, the Library maintains Congress.gov, which is the official website  for U.S. federal legislative information.
subsections: section_title: Organization of the Library
paragraphs: Positioned within the legislative branch, the Library is led by the Librarian  of Congress, who is nominated by the President and confirmed by the  Senate. There have been 13 Librarians of Congress since the founding of  the Library. The Deputy Librarian shares with the Librarian the overall  responsibility for governing the Library and has the delegated authority to  act on behalf of the Librarian.
The Library encompasses several service and support units, including the  following:
Office of the Librarian: The Office of the Librarian has overall  management responsibility for the Library and carries out certain  executive functions. It includes the Office of the Chief Financial  Officer, the Office of the General Counsel, the Congressional  Relations Office, the Office of Communications, the Development  Office, the Office of Contracts and Grants Management, and the  Office of Special Events and Public Programs.
Congressional Research Service (CRS): Established by statute in  1914,legislative research and analysis services. CRS is led by a Director,  who is appointed by the Librarian in consultation with the Joint  Committee on the Library and serves under the general direction of  the Librarian of Congress.
CRS is responsible for providing Congress with nonpartisan
United States Copyright Office: Established by statute in 1897, the  Copyright Office is responsible for administering the Copyright Act,  including copyright registration, recordation, mandatory deposit, and  certain statutory licenses. The office is led by the Register of  Copyrights, who is appointed by and serves under the general  direction of the Librarian of Congress.
Law Library: Congress established its Law Library in 1832 to provide  ready access to reliable legal materials.
Library Services: Library Services develops and preserves the  Library’s collections, which document the history and creativity of the  American people in almost all media and formats and record the  world’s knowledge in some 470 languages. Library Services also  includes the National Library Service for the Blind and Physically  Handicapped (NLS), which directs the production of books and  magazines in Braille and recorded formats as well as specially  designed audio playback equipment. Further, Library Services  administers the Library’s six overseas offices—located in Brazil,  Egypt, India, Indonesia, Kenya, and Pakistan. These offices are  tasked with acquiring, cataloging, and preserving collections from  developing countries.
Office of Strategic Initiatives (OSI): The mission of OSI is to support  the Library’s vision and strategy by directing the overall digital  strategic planning for the Library and the national program for long- term preservation of digital cultural assets. This office includes ITS,  which is to support the Library’s IT systems and infrastructure.
Office of Support Operations (OSO): OSO is made up of several  offices that provide essential infrastructure services to the entire  Library. These include the Office of Opportunity, Inclusiveness, and  Compliance; Integrated Support Services; Human Resource Services;  and the Office of Security and Emergency Preparedness (OSEP).
Figure 1 provides a simplified depiction of the Library’s organization.
An Executive Committee, made up of the heads of the major service units  of the Library and chaired by the Librarian, sets overall Library policy and  practices, and advises the Librarian.
For fiscal year 2014, the Library was appropriated $618,776,000 for its  operations and was authorized to maintain 3,746 full-time equivalents.  For fiscal year 2015, the Library was appropriated $630,853,000, and,  for fiscal year 2016, the Library requested $666,629,000.
section_title: Library of Congress IT Environment
paragraphs: Like other federal agencies, the Library relies on a host of IT systems to  carry out its mission. These include standard hardware (e.g., desktop and  laptop computers, printers, and servers) and software (e.g., e-mail,  standard office productivity programs such as word processing and  spreadsheet programs, and Internet resources) that Library employees  use to carry out their day-to-day work. It also makes use of administrative  and business systems, such as accounting, financial planning and  budgeting, and human resources systems.
A number of IT systems support Library-wide activities. For example:  ITS Library of Congress Data Network: The ITS Library of  Congress Data Network provides network connectivity for Library  personnel at Washington, D.C., metropolitan area facilities, with the  exception of personnel that rely on the OSEP Physical Security  Network.
OSEP Physical Security Network: The OSEP Physical Security  Network is the technical infrastructure used for the systems that  protect facilities, collections, assets, staff, and visitors. These systems  include intrusion alarms, card readers for access control, closed- circuit video cameras, monitors, and recorders.
ITS Application Hosting Environment: The ITS Application Hosting  Environment is the technical infrastructure used to support service  units’ business systems, with the exception of financial business  systems and systems used by CRS and OSEP.
ITS Library of Congress Office Automation System: The ITS  Library of Congress Office Automation System is the technical  infrastructure used to support file and print services, as well as office  automation tools, for Library personnel, with the exception of CRS.
Office of the Chief Financial Officer Momentum: Momentum is the  Library’s central financial management system. The U.S. Capitol  Police, Congressional Budget Office, Office of Compliance, and Open  World Leadership Center also use this system to record and maintain  their financial information. This system is hosted on the ITS Financial  Hosting Environment.
In addition, the Library’s service units have systems that support their  various specific missions. For example:
Copyright Electronic Copyright Office (eCO): Members of the  public (e.g., authors and other copyright owners) use the eCO system  to register basic claims to copyright. The Copyright Office also uses  the system to manage the registration process. The ITS Application  Hosting Environment hosts the eCO system.
CRS Enterprise Infrastructure General Support System: The CRS  Enterprise Infrastructure General Support System is the technical  infrastructure (e.g., servers and network devices) used to support  CRS applications (e.g., the system used to develop CRS reports), as  well as file and print services and office automation tools (e.g., e-mail,  word processing, and collaboration tools) for CRS personnel.
Library Services System Management Information Network II  (SYMIN II): Library Services uses SYMIN II to manage accounting  transactions for the Federal Library and Information Network  (FEDLINK) program. This system is hosted on the ITS Financial  Hosting Environment, which is used to support financial systems.
NLS Production Information & Control System/NLS Integrated  Operations Support System (PICS/NIOSS): NLS uses PICS/NIOSS  to manage the process of producing, distributing, and maintaining  audiobooks (i.e., the electronic files used to present print information  to a reader in audio format). This system is hosted on the ITS  Application Hosting environment.
subsections: section_title: IT Responsibilities
paragraphs: Much of the responsibility for the Library’s IT rests with OSI. The office is  headed by the Associate Librarian for Strategic Initiatives, who also  serves as the Library’s CIO. The CIO’s responsibilities include  coordination of key IT management areas, such as investment  management, enterprise architecture, and information security.
Within OSI, ITS has various responsibilities for supporting the Library’s IT  infrastructure. These include supporting the service units by planning,  designing, developing, and maintaining systems and the infrastructure  supporting those systems.
As of September 2014, the Library had at least 380 staff dedicated to  various IT functions. Most of these (about 250) were in OSI, while the  rest were distributed throughout the rest of the organization, with Library  Services and CRS having the most IT staff among the other service units.  In addition, the Library relies on contractors to fill certain skill gaps, where  necessary. Table 1 shows the number of IT staff—excluding  contractors—across the agency.
The Library obligated at least $119 million for IT during fiscal year 2014.  Of that, about $46 million was obligated for IT staff salaries, and the other  $73 million was for non-pay obligations (e.g., goods and services).  Although OSI accounts for most of the Library’s IT spending, other  service units also make investments in IT that collectively represent a little  less than half of the organization’s IT spending. Table 2 shows IT  spending across the Library.
Examples of major investments in IT at the Library include the following:
Office of the Chief Financial Officer Momentum Upgrade and  Migration: As previously mentioned, Momentum is the Library’s  financial system. The Library is making additional investments in this  system in order to move Momentum to a cloud-based environment.  After this effort is completed, the Library plans to migrate the Architect  of the Capital’s financial management system into the Library’s  Momentum environment.
OSO Facility and Asset Management Enterprise (FAME): FAME is  an existing library business system used to perform facility  management functions (e.g., asset, space, and facility management).  The system relies on commercial, off-the-shelf software. The Library  is investing in additional modules of the underlying software relating to  the management of work orders, keys, reservations, event support,  and customer service.
OSI and Library Services Twitter Research Access: The Library  plans to develop a pilot for making a collection of “tweets” (i.e., brief  messages of up to 140 characters in length) from the online social  networking service Twitter available for research access. The  Library and Twitter signed an agreement that gave the Library, under  specific terms and conditions, all public tweets that were made from  2006 through April 2010. The Library and Twitter also agreed that  Twitter would provide all public tweets on an ongoing basis under the  same terms.
Control over the Library’s IT spending lies primarily with each of the  individual service units—some of which have their own IT organizations  and CIOs. For example:
CRS: The Information Technology and Management Office, which is  led by the CRS CIO, is responsible for managing the majority of the IT  systems used by CRS staff.
Copyright Office: The Copyright Office of the CIO, which is led by  the Copyright CIO, is responsible for maintaining the Copyright Office  IT systems.
Library Services: The Automation Planning & Liaison Office within  Library Services is responsible for procuring IT hardware, software,  and services; managing IT assets; and coordinating with other Library  IT organizations.
These organizations are accountable to the heads of their respective  service units. For example, the CIO for CRS reports to the Director of  CRS, not to the Library of Congress CIO.
section_title: Reported Challenges in IT Management at the Library
paragraphs: As GAO and others have highlighted in several reports, the Library has  faced long-standing challenges in effectively managing its IT. In 1996, we  issued a report on a management review of the Library, covering six  major issue areas, including its use of IT. Among other things, the  review found that (1) the Library lacked a sufficient strategic focus on  information resources management that was linked to its mission  objectives; (2) its existing technology infrastructure was not integrated  across the Library at a level appropriate to reduce interfaces between  systems, lessen the need for maintenance resources, and minimize  redundant data; (3) technology programs and projects were not managed  as investments, with insufficient attention paid to program and project  costs, priorities, and performance; and (4) the Library had not decided  whether it should continue to build new systems in-house or whether it  would be more cost-effective to acquire these capabilities elsewhere. The  report recommended a number of actions the Library could take to  improve its management of IT in these areas. In commenting on the  report, the Library acknowledged the need to link information resources to  its mission objectives and re-focus its infrastructure to reflect changes in  the technology environment.
The findings in this report were echoed in a review conducted by the  National Academy of Sciences and in several reports from the Library’s  Inspector General (IG). In 2000, the National Academy of Sciences  released a report, commissioned by the Library, that examined the need  for the Library to develop a digital strategy to cope with the fact that  content was increasingly being produced in digital forms. The study  found that all Library service units spent money on IT and that this  spending was not fully coordinated across the Library. It was unable to  quantify this spending because the Library had not established financial  accounting for IT. The study concluded that “hadow systems and  duplication are the inevitable outcome of such arrangements.”  Additionally, the study found that strategic direction for IT must come from  the office of the Librarian, but that the most senior members of that  office—the Librarian of Congress, Deputy Librarian, and Chief of Staff— did not have any specific background or expertise in IT. Further, the  report identified a number of findings relating to information security,  referring to this issue as “y far the most serious infrastructure problem”  at the Library. The study made a number of recommendations, including  that the Library (1) establish a Library-wide committee tasked with,  among other things, approving significant IT investments; (2) appoint a  second Deputy Librarian in order to provide strategic direction for the  Library’s IT; and (3) address its information security findings.
In March 2009, the Library’s IG reported on the agency’s IT strategic  planning efforts since the issuance of the National Academy report,  including the extent to which the Library had implemented the report’s  recommendations. The report noted that the Library had made many  technology improvements, including migrating from mainframe systems,  updating the storage architecture, building an alternate computing facility  that provides backup for its data centers, building a secure financial  hosting environment, and developing a National Institute of Standards  and Technology-compliant certification and accreditation process.report further noted that the Library had standardized internal and  external websites, developed digital collections containing more than 300  terabytes of data, and built a network of national and international digital  partners.
However, the IG also reported that the strategic planning process at the  Library was not well integrated with essential planning components and  not instituted Library-wide. Specifically, strategic planning for IT was not  linked directly to the overall Library strategic plan and did not have a  “forward-looking” view; strategic planning was not linked to the IT  investment process; the organizational structure of the ITS directorate did  not foster strategic planning and good IT governance; areas of overlap  existed in support services and systems, including a number of service  units that maintained their own technology offices and help desk  functions; the Library was missing an enterprise architecture program,  which should be coupled with a strategy for implementing future  technology; and ITS customer service needed improvement, to include  the use of service-level agreements.
The IG stated that these findings were in large part the result of an  unclear sense of how IT planning fits into the Library’s mission and the  roles and responsibilities of its employees, as well as a lack of linkage  between IT strategic planning processes and actual performance. The IG  made a number of recommendations to address these weaknesses, and  Library management agreed with the majority of the report’s findings and  recommendations.
The Library’s IG issued a follow-up report in December 2011, in which it  found that the Library had made progress toward implementing the  recommendations made in its prior report, but not as much as expected.Specifically, it reported that the Library needed to (1) develop an updated  OSI strategic plan, (2) improve data for IT investments, (3) separate the  IT function from OSI and establish an Office of the Chief Information  Officer, (4) develop a structured procedure to continuously identify and  prevent duplicative IT costs throughout the Library by consolidating IT  services, (5) increase oversight of the Library’s enterprise architecture,  and (6) strengthen customer service to the service units. Library  management concurred with 17 of the 21 recommendations the IG made  in its report.
More recently the IG has reported on challenges relating to (1)  procurement of IT workstations, (2) oversight of the National Library  Catalog Project, and (3) certification and accreditation.
In September 2012, the IG reported that a lack of inventory controls  had resulted in unnecessary purchases and an aging IT inventory.
Specifically, the IG found that the Library’s logistics directorate and  ITS did not effectively coordinate with service units, which resulted in  unnecessary purchases, such as 484 24-inch, flat-panel monitors that  had sat undistributed at the Library’s warehouse since 2008, and 224  24-inch, flat-panel monitors that were purchased in 2010 but also sat  in the warehouse undistributed. The IG recommended, among other  things, that ITS improve its communications and transparency with  service units. The Library concurred with this recommendation.
In September 2013, the IG reported that the Library did not provide  effective oversight of the National Library Catalog Project.Specifically, the IG found that the Library’s IT Steering Committee  (ITSC)—the committee responsible for reviewing and analyzing IT  investments—did not review Library Services’ now-terminated $2.2  million National Library Catalog project despite its meeting the cost  criterion requiring oversight by the committee (i.e., 3-year costs  exceeding $1 million). The IG stated that the ITSC did not review this  investment because it was in development prior to the formation of the  committee. The IG recommended that the ITSC review any other  investments in development that met criteria requiring its oversight.  The Library agreed with the recommendation.
In October 2014, the IG reported that governance and management  oversight of the Library’s certification and accreditation process  needed to be strengthened. Specifically, the IG found that security  assessments and remedial action plans were not always completed in  a timely manner. The IG recommended, among other things, that the  Library ensure that the security assessments and plans be completed  in accordance with Library policy and establish an enforcement  mechanism to ensure that remedial action plans are addressed. The  Library concurred with these recommendations.
Congress has also recognized the Library’s IT management challenges.  For example, in its report accompanying the fiscal year 2012 legislative  branch appropriations bill, the House Appropriations Committee directed  the Librarian of Congress to consider managing within the Office of the  Librarian all Library IT planning and resource allocations to ensure that IT  requirements are properly prioritized and resources are effectively used.
section_title: Key IT Management Disciplines
paragraphs: GAO has identified a set of essential and complementary management  disciplines that provide a sound foundation for IT management. These  include the following:
Strategic planning: Strategic planning defines what an organization  seeks to accomplish and identifies the strategies it will use to achieve  desired results. A defined strategic planning process allows an  agency to clearly articulate its strategic direction and to establish  linkages among planning elements such as goals, objectives, and  strategies. A well-defined IT strategic planning process helps ensure  that an agency’s IT goals are aligned with its strategic goals. Also as  part of their strategic planning efforts, organizations should develop  an enterprise architecture, which is an important tool to help guide an  organization toward achieving the goals and objectives in its IT  strategic plan, and implement human capital management practices  to sustain a workforce with the skills necessary to execute the  organization’s strategic plan. Library policy also recognizes the  importance of IT strategic planning, enterprise architecture, and  sustaining a workforce that is aligned with the strategic plan.
IT investment management: IT projects can significantly improve an  organization’s performance, but they can also become costly, risky,  and unproductive. Agencies can maximize the value of IT investments  and minimize the risks of IT acquisitions by having an effective and  efficient IT investment management and governance process, as  described in GAO’s guide to effective IT investment management.
Recognizing the importance of IT investment management, in 1996  Congress passed the Clinger-Cohen Act, which requires executive  branch agencies to establish a process for selecting, managing, and  evaluating IT investments in order to maximize the value and assess  and manage the risks of IT acquisitions. Although not required to do  so, the Library has embraced this requirement.
System acquisition and development: Agencies should follow  disciplined processes for developing or acquiring IT systems. These  include requirements development, risk management, and cost  estimating and scheduling, among others. Best practices in these  areas have been identified by organizations such as Carnegie Mellon  University’s Software Engineering Institute (SEI) and GAO.
Information security and privacy: Federal agencies rely extensively  on IT systems and electronic data to carry out their missions. Effective  security for these systems and data is essential to prevent data  tampering, disruptions in critical operations, fraud, and inappropriate  disclosure of sensitive information, including personal information  entrusted to the government by members of the American public.  Recognizing the importance of information security and privacy,  Congress enacted the Federal Information Security Management Act  of 2002 (FISMA), which requires executive branch agencies to  develop, document, and implement an agency-wide information  security program. Additionally, in order to help agencies develop  such a program, the National Institute of Standards and Technology  (NIST) has developed guidance for information security and privacy.  Although it is not subject to FISMA, the Library has embraced the  law’s requirements as well as NIST guidance for information security  and privacy.
Service management: Agencies should develop and implement a  process for ensuring that IT services are aligned with the business  needs of an organization and actively support them. The Information  Technology Infrastructure Library practices are a widely accepted  approach to IT service management.ITS, the Library has adopted these practices for managing ITS’s  services.
According to the Director of  IT leadership: Effective leadership, such as that of a CIO, can drive  change, provide oversight, and ensure accountability for results.  Congress has also recognized the importance of having a strong  agency CIO. For example, as part of the Clinger-Cohen Act, Congress  required executive branch agencies to establish the position of  agency CIO. The act also gave these officials responsibility and  accountability for IT investments, including IT acquisitions, monitoring  the performance of IT programs, and advising the agency head  whether to continue, modify, or terminate such programs. More  recently, in December 2014, Congress passed federal information  technology acquisition reform legislation (commonly referred to as  FITARA), which strengthened the role that agency CIOs are to play in  managing IT. For instance, the law required executive branch  agencies to ensure that the CIO had a significant role in the decision  process for IT budgeting, as well as the management, governance,  and oversight processes related to IT. As previously mentioned,  although not required to do so, the Library has established a CIO  position, and has made this official responsible for, among other  things, overseeing the Library’s enterprise architecture and IT  investment management processes.
section_title: Library’s Approach to IT Lacks Key Planning Practices to Effectively Guide Efforts
paragraphs: Comprehensive strategic planning is essential for an organization to  define what it seeks to accomplish, identify strategies to efficiently  achieve the desired results, and effectively guide its efforts. Key elements  of IT strategic planning include an IT strategic plan and an enterprise  architecture that together outline the agency’s IT goals, measures, and  timelines. In addition, effective human capital management is critical to  sustaining an IT workforce with the necessary skills to execute a range of  management functions that support the agency’s mission and goals.
However, the Library has not completed an IT strategic plan. An IT  strategic plan has been drafted, but it does not identify strategies for  achieving defined goals and interdependencies among projects.  Regarding enterprise architecture, the Library has developed an  architecture intended to reflect the current state of its IT systems and  operations, but, according to the official who served as acting CIO from  April 2014 to January 2015, the architecture is not reliable. Further, the  Library has not developed a target architecture that defines its desired  state or a plan for achieving this state. Senior Library officials noted that  the agency had not made IT strategic planning or enterprise architecture  a priority. At the conclusion of our review in January 2015, the Library’s  Chief of Staff stated that the agency plans to draft a new IT strategic plan  within 90 days.
Further, the Library has not performed an organization-wide assessment  of IT skills or future needs. Instead, each service unit is responsible for  undertaking this assessment on its own. Until it fully implements key  elements of IT strategic planning, the Library cannot be assured that its IT  investments will match its strategic direction and effectively position the  agency to cope with future challenges.
subsections: section_title: Library Lacks a Strategic Plan to Guide Its IT Investments
paragraphs: As we have previously reported, an IT strategic plan serves as an  agency’s vision or road map and helps align its information resources with  its business strategies and investment decisions. Key elements of an IT  strategic plan include, among other things, (1) alignment with the  agency’s overall strategic plan, (2) results-oriented goals and  performance measures that permit it to determine whether it is  succeeding, (3) strategies it will use to achieve desired results, and (4)  descriptions of interdependencies within and across projects so that these  can be understood and managed. Further, Library policy states that OSI  has primary responsibility for setting the Library’s IT strategic direction.
In 2010, the Library developed its most recent overall strategic plan for  fiscal years 2011 through 2016. The plan included five strategic goals  and strategies to achieve those goals, including strategies involving IT.  For example, strategies for achieving the goal of managing proactively for  demonstrable results included implementing an enterprise architecture  program and improving IT governance and investment management  processes. As another example, one strategy for achieving the goal of  sustaining an effective national copyright system was to improve  processes and IT infrastructure to ensure timeliness of copyright  registration.
However, the Library has not completed an IT strategic plan. The official  who served as Deputy Librarian from June 2012 to December 2014  explained that, during his tenure he provided the Librarian with draft  versions of agency-wide and IT-specific strategic plans that he had  developed. The draft IT plan covered fiscal years 2015 to 2020 and  addressed some, but not all, key IT strategic planning elements.  Specifically, the plan included five goals: (1) use a shared services  approach, (2) establish the most effective IT organization and  governance, (3) apply outside consultation and guidance where  applicable to meet library needs, (4) align Library staff skills with its IT  needs, and (5) ensure high levels of information security and  preservation.
However, the draft IT plan did not identify what strategies the Library  would use to achieve these goals and related performance measures.  Additionally, the plan did not describe interdependencies between  projects, which would help further define the relationships between  projects and shared services. The former Deputy Librarian explained that  the IT strategic plan would be followed by an IT support plan, which would  include initiatives, projects, milestones, and timelines for implementing  the IT strategic plan.
Further, the date for completing the Library’s IT strategic plan slipped  twice. Specifically, during a hearing on the Library’s fiscal year 2015  budget in March 2014, the former Deputy Librarian first committed to  delivering the IT strategic plan by the end of August 2014.  Subsequently, that date slipped to January 2015, and then was delayed  again to September 2015. Moreover, we were told by the Librarian in  December 2014 that the draft IT plan was merely a starting point for the  Library’s IT strategic planning efforts and is not the agency’s official draft.  In January 2015, at the conclusion of our review, the Chief of Staff stated  that the Library plans to draft a new IT strategic plan within 90 days. The  Librarian stated that the Library intends to finalize the plan by September  2015.
If the Library finalizes an IT strategic plan that sets forth a long-term  vision and the intermediate steps that are needed to guide the agency, it  will be better positioned to effectively prioritize investments and use the  best mix of limited resources to move toward its longer-term, agency-wide  goals.
section_title: Enterprise Architecture Has Not Been Fully Developed
paragraphs: Like an IT strategic plan, an enterprise architecture is an important tool to  help guide an organization’s IT investments by ensuring that the planning  and implementation of those investments take full account of the business  and technology environment in which the systems are to operate.  According to our research, a well-defined enterprise architecture  thoroughly describes the current and target states of an organization’s IT  systems and business operations and identifies the gaps and specific  intermediate steps it plans to take to achieve the target state.
Additionally, in order to enable institutional commitment to an enterprise  architecture, agencies should, among other things, develop an  organizational policy for enterprise architecture and establish an  executive committee representing the enterprise that is responsible and  accountable for enterprise architecture.
To its credit, the Library has established a policy and executive committee  for enterprise architecture. This policy describes roles and  responsibilities for developing, maintaining, and using the enterprise  architecture. For example, the agency’s chief architect is to report to the  CIO and is responsible for, among other things, coordinating and  overseeing business and IT planning and advising key stakeholders in  business and IT planning. Additionally, the policy makes the Library’s  Executive Committee responsible for ensuring that the architect assumes  responsibility for the Library’s enterprise architecture.
However, the Library of Congress has not fully developed its enterprise  architecture. The agency has an enterprise architect who developed an  architecture that describes the current state of the Library’s IT systems  and operations, to include performance, business, data, services, and  technology. However, management has raised concerns about the  architecture’s reliability. For example, according to the former acting CIO,  data for the architecture were not gathered from management and  validated stakeholders (i.e., individuals identified by their respective  service unit as being knowledgeable about the current and target states  of the unit’s IT systems and business operations). Instead, the enterprise  architect gathered information for the architecture by interviewing over  500 employees across the Library. Additionally, the architecture does not  reflect the target state of the Library’s IT systems and business  operations, or the gaps and specific steps that the Library should take to  achieve the target state.
The lack of progress in developing the enterprise architecture was  enabled, in large part, by limited oversight from the Library’s CIO.  According to the former acting CIO, developing the Library’s enterprise  architecture was not a priority for the previous CIOs. She also told us that  the previous CIOs did not effectively oversee the enterprise architect. In  the absence of appropriate oversight, according to the acting CIO, the  enterprise architect has taken an isolated, self-directed approach to  developing the architecture, which has not met the organization’s needs.
The Library has taken initial steps toward improving its architecture.  According to the former acting CIO, the three individuals who have  recently served as acting CIO on a rotating basis collectively decided to  improve the management of the enterprise architect. That official also  stated that, in order to improve the reliability of the data collected by the  enterprise architect, that individual is now required to collect data from  stakeholders in each service unit who have been identified by the ITSC.  Additionally, at the conclusion of our review, the former acting CIO stated  that the enterprise architect has been detailed to work under the direction  of the Deputy Director of ITS until April 2015 so that his work can be  integrated with other architecture work in ITS. Further, she stated that an  independent, expert reviewer will assess the enterprise architect’s work  and determine how the Library can move its architecture to the next level  of maturity. That official also stated that strategic direction for the  enterprise architecture program will be integrated with the Library’s IT  strategic plan.
Until the Library establishes and implements an approach to developing a  well-defined enterprise architecture—to include providing adequate  oversight of the work performed by the enterprise architect—there is  increased risk that organizational operations and supporting technology  infrastructures and systems will be duplicative, poorly integrated,  unnecessarily costly to maintain, and unable to respond quickly to shifting  environmental factors.
section_title: Library Has Largely Not Assessed Current and Future IT Skills
paragraphs: Key to an agency’s success in managing its IT systems is sustaining a  workforce with the necessary knowledge, skills, and abilities to execute a  range of management functions that support the agency’s mission and  goals.capital management, which includes assessing current and future agency  skill needs by, for example, analyzing the gaps between current skills and  future needs, and developing strategies for filling the gaps. Taking such   Achieving such a workforce depends on having effective human  steps is consistent with activities outlined in human capital management  models that we and the Office of Personnel Management have  developed.
Although its human capital plan calls for the organization to assess gaps  in current and anticipated skills across all employees within the Library,such an assessment has not been performed for IT skills. Additionally,  although identifying skills and competencies that are clearly linked to an  agency’s mission and longer-term IT goals is essential—especially in an  organization like the Library, which has IT staff in every service unit—the  Library’s IT human capital plan does not provide information about future  IT human resource needs.
The former acting CIO acknowledged that the Library has not performed  an organization-wide assessment of skills or future needs. Instead,  according to the acting CIO, each service unit is responsible for managing  its own human capital skills. For example, that official told us that, with  respect to OSI, skills and competencies are identified when an individual  leaves the organization, or when OSI plans to hire additional staff.  However, this approach does not provide the CIO with visibility into the  service units’ IT human capital efforts. We have previously reported that  CIOs at executive branch agencies without sufficient influence over the  hiring of IT staff were limited in their ability to ensure appropriate IT staff  were being hired to meet mission needs.
The Library has taken initial steps to assess the needs of its IT workforce.  According to the Director of Human Resources Services, the Library’s  Human Capital Planning Board conducted a pilot initiative in the  Acquisitions and Bibliographic Access Directorate within Library Services  to identify competencies and skills, including those relating to IT.  According to the Director of Human Resources Services, the Library  plans to identify skills and competencies, including those relating to IT, to  be used initially in order to assess the skills for three succession planning  groups: senior-level executives, managers/supervisors, and succession  target occupations. This official stated that this effort is expected to  extend into fiscal year 2016, and that the Library plans to institutionalize  this approach in other Library offices. However, the Library has yet to  establish a date for completing the effort.
Until the Library ensures that its human capital planning and analysis  address the specific competencies and skills critical to meeting its future  IT needs, the agency jeopardizes its ability to deliver IT support.  Additionally, without an organization-wide approach to assessing needed  IT skills, the Library is at risk of developing a workforce in each service  unit with overlapping competencies.
section_title: Library Is Not Effectively Managing the Selection and Oversight of IT Investments
paragraphs: Ensuring that investments in IT meet the needs of the organization and  are being effectively managed is important for any federal agency.  Congress has recognized the importance of effective IT investment  management by requiring agencies in the executive branch to establish  an investment management process. Although not required by law to do  so, the Library has also begun to establish such a process. Specifically,  the Library’s Information Resource Management Policy and  Responsibilities calls for the Library to align IT investments with its  strategic goals and to connect strategic planning, enterprise architecture,  and IT investment management in order to design and leverage Library  resources to meet the needs of Congress and the public.
Since 2010, the Library has taken steps to build a foundation for  managing its IT investments, including instituting an investment board  and establishing elements of a process for selecting investments.  However, the Library has not implemented an IT investment management  process that fully addresses key practices. In particular, its investment  board has not always operated as intended. Further, the Library’s process  for selecting IT investments is not aligned with decisions to fund  investments, and no process has been established for reselecting  ongoing investments. Moreover, the Library, including its service units,  did not always follow its own policy for including major investments in its  agency-wide investment review process. Regarding investment oversight,  the Library established a process for overseeing the performance of  selected investments, but the data informing this process were not always  complete. Moreover, the Library does not have a comprehensive process  for tracking its IT spending and does not have an accurate inventory of its  IT assets. Consequently, the Library does not know how much it spends  annually on IT or what kinds of equipment it is currently using. Finally, the  Library is not managing its IT as a portfolio to determine that capabilities,  once implemented, are delivering intended value and that the agency is  identifying the appropriate mix of IT projects that best meet its mission  needs.
These weaknesses can be attributed, in part, to unclear or incomplete  policies as well as inconsistent implementation of the policies that have  been developed. Until the Library addresses these weaknesses, it will not  have the investment structure and processes needed to effectively  manage its IT projects, systems, and assets.
subsections: section_title: Key Practices for Managing Individual IT Investments Have Not Been Fully Established or Implemented
paragraphs: GAO’s IT investment management framework is composed of five  progressive stages of maturity that mark an agency’s level of  sophistication with regard to its IT investment management capabilities.Such capabilities are essential to the governance of an organization’s IT  investments. At the Stage 2 level of maturity, an organization lays the  foundation for sound IT investment processes that help it attain  successful, predictable, and repeatable investment control processes at  the project level. These processes focus on the agency’s ability to select,  oversee, and review IT projects.
According to the framework, Stage 2 critical processes include the  following:  Instituting the investment board: As part of this process, an agency  is to establish an enterprise-wide investment review board to be  responsible for defining and implementing the IT investment  management governance process.
Selecting investments that meet business needs: As part of this  process, an agency is to establish and implement policies and  procedures for selecting and reselecting IT investments that meet the  agency’s needs.
Providing investment oversight: This process includes establishing  and implementing policies and procedures for overseeing IT projects  and ensuring that they align with the agency’s business needs.
Capturing investment information: This process includes  establishing and implementing policies and procedures for developing  and maintaining a comprehensive repository of information on IT  investments and assets.
subsections: section_title: Library Has Established an Investment Board, but Its Policies and Procedures Are Not Always Clear
paragraphs: The establishment of decision-making bodies or boards is a foundational  component of effective IT investment management. According to the IT  investment management framework developed by GAO, an organization  should, among other things, establish an enterprise-wide investment  review board to be responsible for defining and implementing IT  investment governance policies and procedures. In order for the IT  investment management process to function effectively, an investment  board must operate within its assigned authority and responsibility so that  investments are properly aligned with the organization’s objectives and  are reviewed by those with the authority to make IT management  decisions. Additionally, the organization’s IT investment management  process should describe how these processes are coordinated with other  organizational plans, processes, and documents, including, at a  minimum, the IT strategic plan and enterprise architecture.
The Library established an investment board that is responsible for  defining and implementing IT investment governance policies and  procedures. Specifically, the Library’s policy on information resource  management established the ITSC, an investment board made up of  senior officials from across the Library’s various service units. The policy  requires the board to review major investments in IT that meet at least  one of several agency-defined criteria. These include those investments  that are high risk, have high visibility (internally or externally), or have  estimated 3-year costs exceeding $1 million. The Library’s information  resource management policy also gives the ITSC responsibility for  formalizing the policies and procedures for selecting and managing IT  investments. Library policy also describes IT management responsibilities  of the Executive Committee—the Library’s most senior governance  board. For example, this committee is to provide strategic mission and  priority guidance to the ITSC.
However, the Library has not clearly defined the division of  responsibilities between the two bodies. Specifically, although Library  policy gives IT investment selection decision-making authority to both the  ITSC and the Executive Committee, it does not clearly specify when the  ITSC should make a decision and when circumstances require an  Executive Committee decision. Since the establishment of the ITSC in  2010, the Executive Committee has not made any decisions regarding  the selection of IT investments; instead, the ITSC has made all such  decisions.
In March 2014, the ITSC developed a process for determining when  investments are to be reviewed by the Executive Committee; however,  this process has not yet resulted in any decisions being escalated to the  Executive Committee. Moreover, the Director of ITS, who also chaired the  ITSC from July 2013 to January 2015, stated that this process had not  been approved by the Librarian or the Executive Committee. According to  this individual, he plans to submit this revision to the Office of the  Librarian as part of a Library-wide effort to streamline and centralize  Library policies.
Additionally, the Library’s investment management process is not fully  coordinated with its IT strategic plan and enterprise architecture.  Specifically, as previously mentioned, the Library does not have an IT  strategic plan or a complete enterprise architecture to guide its IT  investment decisions and ensure that those decisions meet the  organization’s business needs. Coordination between the Library’s  investment management process and its efforts to improve its strategic  plan and enterprise architecture could help ensure that investments  support the Library’s strategic goals and do not duplicate existing  investments. Until Library policy is updated to clearly define the roles and  responsibilities of the ITSC and Executive Committee and these bodies  operate according to their designated authority and responsibilities, the  Library cannot ensure that investments are properly aligned with the  business needs of the entire organization. In addition, without a strategic  plan, enterprise architecture, and a process for linking these areas to the  investment management process, the ITSC and Executive Committee will  not have a roadmap needed to make investment decisions that best meet  the needs of the Library.
section_title: Library Has Not Fully Developed and Implemented a Selection Process
paragraphs: According to our IT investment management framework, to support well- informed decisions, organizations should establish and implement  policies and procedures for selecting and reselecting IT investments that  meet the agency’s needs, and these policies should integrate funding and  selection decisions. Documenting and implementing these processes are  basic steps toward realizing increased maturity in how the organization  selects its IT projects.
To its credit, the Library developed policies and procedures that outline  how IT investments are to move through the selection process, from initial  proposal to final approval, with steps for evaluating and prioritizing the  investments based on their alignment with business needs. As previously  mentioned, Library policy requires the ITSC to review investments that  are high risk, have high visibility, or have estimated 3-year costs  exceeding $1 million. Before an investment is selected, the ITSC is to  assign it a score based on quantifying its risk factors (e.g., high cost,  length of development cycle, lack of clear and measurable objectives)  and then evaluating those factors along with the significance of its  program benefits (e.g., how it will contribute to organizational  performance or how it will respond to user needs). The ITSC is then to  use the score to determine whether it will select the investment for project  development.
However, the Library has not developed policies or procedures for  reselecting investments that are already operational for continued  funding. This is important because, according to the former acting ITSC  chair, operational investments account for the majority of the Library’s IT  spending. That same official also stated that the Library decided not to  review, as part of its investment management process, investments that  were either in development or already operational prior to the  establishment of the ITSC in February 2010. For instance, in September  2013, the Library’s IG reported that the ITSC did not review Library  Services’ now-terminated $2.2 million National Library Catalog project  because it was in development prior to the ITSC’s formation. In October  2013, the former acting ITSC chair directed the members to bring before  the committee any projects that (1) met the Library’s definition of major  investments in IT that are to be reviewed by the ITSC, (2) were still in  development, and (3) were in development prior to the establishment of  the ITSC in February 2010. While this was a positive step, this decision  did not address investments that were operational. Additionally, because  the decision was made 3 years after the creation of the ITSC, there were  likely some IT investments that were developed and completed during  this time that did not receive ITSC review. According to the former acting  ITSC chair, the Library will consider whether to review additional  investments in the future.
In addition, the Library does not have policies and procedures for  integrating funding and selection decisions. In fact, according to the  former acting ITSC chair, ITSC selection does not affect decisions to  allocate funding for investments, because, in some instances, the service  units secure funding for their investments before the selection process  begins. The former acting ITSC chair added that, as a compensating  control, the ITSC could request that ITS not devote its own resources to  an investment until the committee’s concerns are resolved. However, this  process would not affect the investment if the service unit proposing it  decides not to use ITS resources. Until the Library fully integrates IT  investment selection with funding decisions, selection decisions may not  reflect an organization-wide perspective on what IT investments may best  meet the Library’s needs.
Further, the Library, including its service units, did not always follow its  process for selecting new investments. Specifically, the ITSC does not  review all major IT investments that, according to its policy, should be  reviewed. For example, as discussed in more detail in our report on the  Copyright Office, the office did not present four of its recent IT initiatives  to the ITSC, despite each having estimated 1-year costs exceeding $1  million. In addition, the ITSC did not review the Twitter Research Access  investment while it was in the planning stages because it was approved  by the Executive Committee without going through the Library’s selection  process. However, by not going through the Library’s selection process,  investments are not subject to the selection reviews, which evaluate,  among other things, cost, schedule, scope, strategic impact, and  customer needs on an enterprise-wide level. For example, as discussed  in more detail later in the report, the Twitter Research Access investment  did not create a reliable cost estimate nor did it develop a schedule.  Going through the selection process would help ensure that investments  are better planned and better aligned with agency needs from the outset,  which could eliminate or reduce the severity of future problems during  system development.
Until it establishes and implements a complete selection process for all  major IT investments that links its IT investment selection decisions with  agency funding decisions, the Library is at greater risk of not selecting the  appropriate mix of IT investments that would best meet its organizational  and technological needs as well as support its priorities for improvement.
section_title: Library Has Established a Process for Overseeing Investments, but Data Used Were Not Always Complete
paragraphs: As with investment selection, organizations should have a documented,  well-defined process for overseeing investments once they have been  selected to ensure that they continue to align with the agency’s business  needs. Effective investment oversight and evaluation involves, among  other things, developing policies and procedures for reviewing the  progress ongoing projects have made in meeting cost, schedule, and risk  expectations.
The ITSC established procedures to assess the progress of investments  in development. These reviews center on quarterly reports submitted to  the ITSC by the investment teams, which update the board on, among  other things, cost and schedule variances, as well as how the teams are  managing key risks.
However, for the three selected investments that we reviewed,schedule, and risk data in the quarterly performance reports were not  always complete or reliable.
Regarding cost information, one investment—Momentum Upgrade  and Migration—included initial and current cost estimates and the  variances between the two figures in its July 2014 quarterly report.  However, the other two investments—FAME and Twitter Research  Access—did not provide all cost information in their July 2014  submissions. For the FAME investment, although OSO provided cost  information for the investment as a whole, it listed the costs needed to  achieve its next key milestone in September 2014 as $0. Finally, the  Twitter Research Access investment did not provide any cost  information in its quarterly report submitted in July 2014. In a written  response to our findings, the Library acknowledged that this  information was omitted for the Twitter Research Access investment,  and stated that this information was included in the subsequent report.  Moreover, the cost information provided in these reports is not fully  reliable. Specifically, as discussed in more detail later in the report,  the initial cost estimates for all three investments were not  comprehensive.
With respect to schedule information, two of the three investments—  Momentum Upgrade and Migration and Twitter Research Access— submitted all schedule information as part of their quarterly  performance reports submitted in July 2014. Regarding FAME,  although the Library identified the planned start and completion dates  for the investment, the investment did not provide any meaningful  information regarding its next quarter. Rather, the relevant section of  the quarterly performance report simply stated “9/30/2014,” which was  the last day of the relevant quarter. Moreover, the schedule  information provided in the reports was not fully reliable. Specifically,  as explained in more detail later in this report, one investment— Twitter Research Access—did not develop a project schedule, and  the other investments’ schedules were not well-constructed.
Regarding risk, as discussed in more detail later in this report, the  three investments did not always document the context and  consequences of occurrence for all risks, and one of the  investments—FAME—did not describe mitigation plans for all risks.
Library officials recognized the need to make improvements to these data  and recently revised the quarterly performance report template in order to  help facilitate improvements. Until its oversight processes are informed by  complete and accurate investment information, the Library cannot ensure  that its investments are meeting expectations related to cost, schedule,  and risk. Without this information, the Library may not be able to see the  early warning signs that indicate the need for corrective action, resulting  in failed investments or investments that do not adequately support  business processes, meet user needs, or provide a successful return on  investment.
section_title: Library Does Not Have an Accurate Inventory of Its IT Spending and Assets
paragraphs: To make informed decisions regarding IT investments, an organization  must be able to acquire, store, and retrieve pertinent information about  each investment to be used in future investment management decisions.
As we have reported, for this critical area, the organization should  establish and implement a process for maintaining a full and accurate  accounting of IT-related expenditures. In addition, the organization  should track information on the organization’s IT assets, including, for  instance, the physical location and owner of each resource. According to  the GAO IT investment management framework, effectively capturing  investment information requires using a standard, documented procedure  for developing and maintaining IT data that are not only useful for  decision-making, but are also timely, sufficient, complete, and  comparable.
The Library has not fully established and implemented a process for  maintaining a full accounting of IT-related expenditures. Instead, it only  collects information on the investments reviewed by the ITSC, which  includes investment charters, cost-benefit analyses, and performance  reports. on IT.
Consequently, the Library does not know how much it spends  In the absence of this information, we estimated that the Library obligated  at least $119 million on IT for fiscal year 2014. We based this estimate on  data from the Library’s accounting and human resources systems. This  allowed us to identify spending on IT equipment and services as well as  salary information for staff performing IT-related functions. However, as  discussed in more detail in appendix I, this $119 million does not reflect  all of the Library’s IT spending.
At the conclusion of our review in December 2014, the Library’s Chief  Financial Officer told us that the Library has required that service units  indicate, for planned fiscal year 2015 expenditures, whether the  expenditures relate to IT. A senior advisor to the Chief Financial Officer  estimated that the Library would be able to provide a reliable IT spending  figure by March 2015. However, the Library has not established guidance  to assist service units in classifying planned IT expenditures.
The cost estimates for the investments reviewed by the ITSC in fiscal year 2014  collectively totaled approximately $12.5 million, which is a small percentage of the  Library’s overall IT spending.
With regard to capturing IT asset information, the Library’s primary asset  inventory system is highly inaccurate. Integrated Support Services, a  division of OSO, has developed a system to track and manage the  Library’s assets, including those assets related to IT. However, many of  these IT assets are no longer in use. For example, the system lists over  18,000 “active” personal computers, even though, according to Library  officials, it actually has fewer than 6,500 personal computers in use. The  list of “active” personal computers includes over 12,000 computers from  the manufacturer from which the Library primarily purchases computers  and more than 5,000 computers from four other manufacturers. Without  an accurate inventory, there is increased risk of undetected theft and loss.
In a written response, the Library acknowledged that its primary inventory  system does not have reliable information on IT hardware. The Library  cited multiple reasons for this weakness, including that its primary  inventory system contains legacy data from an obsolete, decommissioned  system. Additionally, the Library stated that a comprehensive inventory of  non-capitalized assets has not been conducted in several years. Further,  the Library said that its current policy on inventory management does not  require non-capitalized assets to be identified in its primary inventory  system.
The Library also noted that ITS and CRS maintain other systems with  accurate and reliable information about the majority of hardware  connected to the Library’s network. It added that the items in the ITS and  CRS systems make up the vast majority of the IT inventory in the  Library.most Library IT hardware currently in use, they do not have information  on the hardware in the primary inventory system that is no longer in use.  Without this information, the Library cannot provide the disposition of the  hardware that is no longer being used. Additionally, maintaining this  information in separate systems can increase the risk of unnecessary  purchases of items already on hand, which, as discussed later in this   However, while these systems may have reliable information on  report, has occurred at the Library. Further, the ITS and CRS systems do  not include information on IT not connected to the Library’s network.
At the conclusion of our review, the Library outlined steps it plans to take  to address the reliability of its primary inventory. These include revising its  policy in early 2015 to require key non-capitalized IT hardware assets to  be identified in the Library’s primary inventory system and populating the  Library’s primary inventory system with data from the ITS and CRS  systems. The Library added that, because it has not yet developed a  process for this, it will not have an accurate inventory in its primary  system until March 2016.
Without fully developing and implementing a process for maintaining a full  accounting of IT-related expenditures, the Library will not have the  information needed to make informed decisions. Further, until it ensures  that its primary inventory system has accurate information on IT  hardware, there is increased risk of unnecessary purchases of items  already on hand.
section_title: Library Has Not Begun to Manage Its Investments as a Portfolio
paragraphs: Once an agency attains Stage 2 maturity, it needs to implement critical  processes for managing its investments as a portfolio to move on to  Stage 3. An IT investment portfolio is the combination of an organization’s  IT assets, resources, and investments (including those in production).  Taking an agency-wide perspective enables an organization to consider  new proposals along with previously funded investments, identifying the  appropriate mix of IT projects that best meet mission needs,  organizational needs, technology needs, and priorities for improvement.  According to GAO’s IT investment management framework, Stage 3  critical processes include, among others, (1) conducting post- implementation reviews to compare actual investment results with  decision makers’ expectations for cost, schedule, performance, and  mission improvement outcomes; (2) defining the portfolio criteria; (3)  creating the portfolio; and (4) evaluating the portfolio.
Although the Library has established procedures for conducting post- implementation reviews, it has yet to apply these procedures to all  operational investments. Specifically, in August 2014 and September  2014, the ITSC developed templates and instructions for conducting the  reviews. At the conclusion of our review in March 2015, the interim CIO  stated that the ITSC performed the first four post-implementation reviews.  Although this is a positive step, the Library has yet to perform these  reviews on all of its operational investments. Until such reviews are  consistently performed on all operational investments, the Library will not  be able to learn from all past investments and evaluate the effectiveness  of its investment management process.
With respect to defining portfolio criteria and creating and evaluating the  portfolio, according to the former acting ITSC chair, the agency has not  concentrated on implementing these Stage 3 key practices because it has  focused its resources on establishing the Stage 2 practices associated  with building the IT investment management foundation at the level of the  individual investment. Full implementation of the Stage 3 critical  processes associated with portfolio management will provide the Library  with the capability to determine whether it is selecting the mix of products  that best meet the agency’s business needs.
section_title: Library of Congress Has Not Fully Established and Implemented Key IT Acquisition Practices
paragraphs: The Software Engineering Institute (SEI) at Carnegie Mellon University,  GAO, and others have developed and identified best practices to help  guide organizations to effectively plan and manage their acquisitions of  major IT systems. Our prior reviews have shown that proper  implementation of such practices can significantly increase the likelihood  of delivering promised system capabilities on time and within budget.  These practices include, among others, risk management, requirements  development, cost estimating, and scheduling.
However, the Library has not developed policies in these areas that  address key practices. Partly because the Library does not have  organization-wide policies in these areas, the selected investments that  we examined did not fully implement key practices for risk management, requirements development, cost estimating, and scheduling. Until the  Library establishes and implements these practices, there is increased  risk that its investments will incur cost overruns and schedule slippages  and fail to deliver capabilities needed to meet the mission of the Library.
subsections: section_title: Risk Management Practices Were Not Fully Established and Implemented
paragraphs: Risk management is a process for anticipating problems and taking  appropriate steps to mitigate risks and minimize their impact on program  commitments. According to leading industry guidance,following elements: developing a risk management strategy; identifying and documenting risks; evaluating, categorizing, and prioritizing risks; developing risk mitigation plans; and monitoring the status of each risk periodically and implementing the  risk mitigation plans as appropriate.
Organizations should establish a risk management policy that calls for  these elements to be addressed by individual investments.
The Library of Congress has not established an organization-wide policy  for IT risk management. Instead, only one directorate within a service  unit—OSI’s ITS—has developed guidance in this area. This guidance  includes templates for a risk management strategy and a risk register.  The risk register provides a mechanism for investments to identify,  document, evaluate, categorize, and prioritize risks; develop risk  mitigation plans; and monitor the status of risks and implement risk  mitigation plans as needed. However, this guidance is not mandatory for  any projects in the Library—including those that are managed by ITS.
The risk management strategy addresses the specific actions and management  approach used to apply and control the risk management program. It also includes  identifying and involving relevant stakeholders in the risk management process. did not establish a strategy for the FAME and Twitter Research  Access investments.
Identify and document risks to include the context, conditions,  and consequences of risk occurrence: Although each of the three  selected investments identified risks, they did not always document  the context and consequences of risk occurrence. For example, the  FAME investment charter identified four risks—business requirements  and process, technical support resources, project funding, and  contract.these risks that would provide additional context and consequences of  risk decisions. As another example, the Twitter Research Access  investment charter included a risk regarding limited institutional  support and prioritization, but did not provide the context needed for  management to fully understand this risk. As a final example, the  Momentum Upgrade and Migration acquisition plan included a risk  that was described as “resources.” Although the description of the risk  mitigation plan provides some context for this risk, the acquisition plan  does not describe the consequences of this risk’s occurrence.
However, the charter did not include any descriptions of
Evaluate, categorize, and prioritize risks using defined risk  categories and parameters: The three selected investments did not  always evaluate, categorize, and prioritize risks using defined risk  categories and parameters. Specifically, for the Twitter Research  Access and FAME investments, the Library evaluated, categorized,  and prioritized all of the identified risks; however, it did not do so using  defined risk categories. With respect to the Momentum Upgrade and  Migration investment, the Library evaluated, categorized, and  prioritized risks identified in the risk register, but did not do so for  additional risks identified in its acquisition plan.
Develop risk mitigation plans in accordance with the risk  management strategy: The Library of Congress did not develop risk  mitigation plans for all risks identified for the selected investments,  and plans that were developed were not done so in accordance with  risk management strategies. Specifically, for the Twitter Research  Access and Momentum Upgrade and Migration investments, although  the Library developed risk mitigation plans for all identified risks, it did  not develop them in accordance with risk management strategies for  those investments. With regard to the FAME investment, the Library  did not develop risk mitigation plans for any of the identified risks.
Monitor the status of each risk periodically and implement the  risk mitigation plans as appropriate: Although the Library’s IT  investment management process requires quarterly reports on,  among other things, risks identified in the investments’ charters, the  reports for the three investments did not fully address this information.  Specifically, for the Twitter Research Access investment, although the  July 2014 quarterly report included the identified risks and their  associated mitigation plans, it did not fully document the context of  risk occurrence. With respect to the Momentum Upgrade and  Migration and FAME investments, the risk sections of the July 2014 quarterly reports did not identify any risks or risk mitigations plans.
The incomplete implementation of risk management can be attributed to  the lack of an organization-wide policy, as noted previously. At the  conclusion of our review, the Library acknowledged that it has not  established an organization-wide policy for risk management and stated  that it would establish a policy that requires all IT acquisitions valued at  $100,000 or more to follow a Library-wide risk management policy and  process. The Library stated that this new risk management policy and  process will be established for fiscal year 2016. Until the Library  establishes and implements organization-wide risk management policies  and procedures, officials will not have assurance that risks facing IT  investments are being adequately addressed.
section_title: Requirements Development Practices Were Not Fully Established and Implemented
paragraphs: Requirements establish what the system is to do, how it is to do it, and  how it is to interact with other systems. According to leading practices,  effective requirements development includes eliciting stakeholder needs,  developing customer requirements, and prioritizing customer  requirements. In order to enable consistent implementation, processes  for requirements development should be established in organizational  policy.
The Library of Congress has not established an organization-wide policy  for requirements development. Although ITS has developed requirements  management guidance that ITS investments are required to follow, this  guidance does not apply to other service units’ investments. This  guidance includes a template for documenting requirements, including  those developed by customers.
Additionally, while the Library implemented key requirements  development practices for two of the three selected investments, it did not  consistently do so for the third. For two of the investments—Twitter  Research Access and Momentum Upgrade and Migration—the Library  elicited stakeholder needs and developed prioritized customer  requirements. For example, for the Twitter Research Access investment,  Library Services convened a group of stakeholders, referred to as the  Twitter Access Group, to develop functional requirements to support  research access to the Twitter archive. Based on these efforts, that group  developed customer functional requirements and prioritized them by  placing them into three priority categories.
However, the FAME investment did not fully implement key requirements  development practices. Specifically, the Library elicited customer needs  and developed customer requirements for only one of the three  components of the FAME investment and did not prioritize them. In a  written response, Integrated Support Services acknowledged that it had  not elicited customer needs for all three components of the FAME  investment, stating that it would do so as the components are  implemented. It explained that this is appropriate because FAME uses  commercial, off-the-shelf software with “out-of-the-box” functionality.  However, according to leading practices, while requirements will evolve  as more is learned about the selected product, some stakeholder needs  should be elicited and developed prior to the selection of a commercial,  off-the-shelf solution to ensure that the solution meets those needs.
The incomplete implementation of requirements development practices  can also be attributed to the lack of an organization-wide policy, as  discussed previously. At the conclusion of our review, the Library  acknowledged that it has not established an organization-wide policy for  requirements development and stated that it would do so, consistent with  the industry guidance cited in this report. The former acting CIO stated  that the Library intends to finalize this policy by September 2015. Until the  Library establishes and implements a consistent requirements  development process across the organization, it will not have assurance  that its IT investments will meet stakeholder and customer needs.
section_title: Cost Estimating Practices Were Not Fully Established and Implemented
paragraphs: Reliable cost estimates are critical for successfully delivering IT  investments. Such estimates provide the basis for informed investment  decision making, realistic budget formulation, meaningful progress  measurement, and accountability for results. GAO’s Cost Estimating and  Assessment Guide defines 12 leading practices related to four  characteristics—comprehensive, well-documented, accurate, and  credible—that are important to developing high-quality, reliable  estimates. To institutionalize cost estimating best practices,  organizations should establish policies that require cost estimates to  demonstrate these four characteristics.
The Library of Congress has not established an organization-wide policy  for cost estimating. Instead, only one directorate within a service unit— ITS—has developed guidance in this area that ITS projects are largely  required to follow. Moreover, ITS’s cost estimating guidance does not  substantially address the leading practices relating to developing high- quality, reliable estimates. Specifically, the guidance partially addresses  the well-documented characteristic and minimally addresses the  comprehensive, accurate, and credible characteristics.
Table 3 shows the extent to which the guidance addressed the four  characteristics.
The weaknesses in the Library’s cost estimating policies and guidance  are reflected in the estimates for the selected investments. To its credit,  the Library developed cost estimates for all three selected investments.  However, none of the estimates fully met the comprehensive  characteristic, which is necessary for the estimate to fully address the  other three characteristics. Specifically, one of the three selected  investments’ estimates—the estimate for the Momentum Upgrade and  Migration investment—partially met the comprehensive characteristic,  and the other two estimates minimally met the comprehensive  characteristic. Regarding Momentum Upgrade and Migration, to its credit,  the Library developed documentation that defined several components of  the investment, including its assumptions about the investment, key risks,  and a schedule. However, the cost documentation does not include  enough detail to ensure that all costs are included. For example, costs for  government staff are not clearly described in the documentation.  Additionally, the estimating documentation was not always structured in  sufficient detail to ensure that costs are neither omitted nor double  counted.
Regarding the estimates for the Twitter Research Access and FAME  investments, although the estimates included some costs, they did not  include enough detail to confirm that all costs were included. For  example, neither estimate included a work breakdown structure—which is  the cornerstone of every project because it defines in detail the work  necessary to accomplish a project’s objectives. Additionally, the estimates  did not include all cost-influencing assumptions.
At the conclusion of our review, the Library acknowledged that it had not  established an organization-wide policy for cost estimating and stated that  it would establish, by December 2015, cost estimating guidance for all IT  projects with an initial investment over $1 million. Until the Library  establishes and implements an effective cost estimating process, there is  increased risk that cost estimates may not be reliable—thereby impairing  its ability to make well-informed funding decisions and affecting how it  allocates resources across competing investments.
section_title: Scheduling Practices Were Not Fully Established and Implemented
paragraphs: The success of an IT investment depends in part on having an integrated  and reliable master schedule that defines when the investment’s set of  work activities and milestone events are to occur, how long they will take,  and how they are related to one another. Among other things, a reliable  schedule provides a road map for systemic execution of an IT investment  and the means by which to gauge progress, identify and address potential  problems, and promote accountability. GAO’s Schedule Assessment  Guide defines 10 leading practices related to four characteristics— comprehensive, well-constructed, credible, and controlled—that are vital  to having an integrated and reliable master schedules. To  institutionalize sound scheduling practices, organizations should establish  policies that require schedules to demonstrate these four characteristics.
The Library of Congress has not established an organization-wide policy  for scheduling. As with cost estimating, ITS has developed some  guidance in this area that ITS projects are largely required to follow.  Additionally, the guidance does not substantially address the leading  practices related to developing integrated and reliable master schedules.  Specifically, ITS’s guidance minimally addresses the credible and  controlled characteristics and does not address the comprehensive and  well-constructed characteristics. Table 4 shows the extent to which ITS’s  scheduling guidance addresses the four characteristics.
The weaknesses in the Library’s scheduling policies and guidance are  reflected in the schedules for the three selected investments. One  investment—Twitter Research Access—did not develop a schedule,  and the other investments’ schedules did not substantially address the  well-constructed characteristic, which relates to the foundational practices  for a high-quality, reliable schedule. The FAME investment developed two  schedules—each of which relates to one of the investment’s projects— that, considered together, partially addressed the well-constructed  characteristic. Specifically, the activities in each schedule were largely  sequenced with straightforward logic. However, the schedules did not  include valid critical paths, and their float values do not always  accurately represent schedule flexibility.
At the conclusion of our review in January 2015, the Director of Integrated  Support Services stated that the schedules we reviewed were immature  because they were created when project management activities were just  beginning. He also provided two updated schedules, stating that they  were more robust and addressed the weaknesses we identified. We  reviewed one of the two schedules and found that the schedule partially  addressed the well-constructed characteristic. Similar to the previous  schedules, it did not include a valid critical path and the float values did  not always accurately represent schedule flexibility. In contrast to the  other schedules, however, the updated schedule was not sequenced with  straightforward logic. For example, 25 (20.2 percent) of the remaining 119  activities did not have successor activities. Not linking related activities  can cause problems because changes to the durations of these activities  will not accurately change the dates for related activities. Additionally, 40  (32.3 percent) of the remaining activities were constrained by “finish no  earlier than” dates, which is significant because it means that these  activities would not be allowed to finish earlier, even if their respective  predecessor activities have been completed.
The Momentum Upgrade and Migration investment developed a schedule  that minimally addressed the well-constructed characteristic. For  example, 400 (33.9 percent) of the remaining 1,129 activities did not have  successor activities. Additionally, the schedule did not have a valid critical  path, and its float values did not always accurately represent schedule  flexibility.
At the conclusion of our review, the Library acknowledged that it had not  established an organization-wide policy for scheduling and stated that it  will develop a schedule management process based on GAO’s and other  best practices and will establish a Library-wide policy that requires all  investments to follow the new schedule management process. The  Library stated that the new policy and process will be established for  fiscal year 2016. However, the Library has yet to establish a date for  completing the effort.
Until the Library establishes and implements a process for effectively  managing its schedules, there is increased risk of schedule slippages and  cost overruns. Additionally, it will be difficult for the Library to obtain  meaningful measurement and oversight of investment status and  progress, as well as accountability for results.
section_title: Security and Privacy Weaknesses Threaten Information and Systems That Support the Library’s Mission
paragraphs: Protecting its data and information systems is a key objective for any  federal agency. This is essential not only to defend an agency’s  operations against disruption by cyber attacks, but also to protect  sensitive information entrusted to it by members of the public. To protect  their systems and information, agencies should establish information  security and privacy programs and effectively implement management  and technical security and privacy controls. Toward this end, NIST has  developed guidance to assist federal agencies in developing and  implementing information security and privacy programs.
Consistent with NIST guidance, the Library established security and  privacy programs by delineating roles and responsibilities and developing  policies and procedures. However, it has not fully implemented  management controls to ensure the protection of its systems and  information. Specifically, while the Library did establish and implement a  process for handling security incidents, it did not (1) have a complete  inventory of its systems for purposes of monitoring security controls, (2)  fully outline security controls in system security plans, (3) conduct  complete security testing of its systems, (4) develop and complete in a  timely fashion plans for remediating identified security weaknesses, (5)  establish contingency plans for its systems, (6) fully document security  training policies or ensure that all users had taken required training, (7)  include security-related requirements in all applicable contracts for IT  services, or (8) fully assess risks to the privacy of personal information in  its systems. Further, we identified numerous weaknesses in technical  security controls at the Library related to preventing unauthorized access  to and securely configuring systems. Until it addresses these  weaknesses, the Library’s systems and the information they contain will  be at increased risk of compromise.
subsections: section_title: Library Established Security and Privacy Programs for Information Systems
paragraphs: NIST guidance calls for agencies to develop, document, and implement  programs for securing information systems, and protecting the privacy of  personal information in those systems. With respect to information  security, such a program should include risk-based policies and  procedures that cost-effectively reduce information security risks to an  acceptable level and ensure that information security is addressed  throughout an information system’s life cycle. Additionally, information  security programs should include a process for planning, implementing,  evaluating, and documenting remedial actions to address any deficiencies  in information security policies, procedures, and practices.
Regarding privacy, according to NIST guidance, organizations should  implement a broad set of controls to ensure the appropriate use and  protection of personal information maintained by the organization. This  includes establishing an organization-wide program overseen by a chief  privacy officer, conducting privacy impact assessments to assess the  privacy risks associated with collecting and using personal information,  and providing an organized and effective response to privacy incidents.
subsections: section_title: Library Developed Security- Related Policies and Procedures
paragraphs: The Library took steps to establish protections for its systems as part of  its information security program. It assigned overall responsibility for  securing the agency’s information and systems to appropriate officials,  including, among others, the
Librarian, who is responsible for ensuring that the Library’s security  program is being implemented;
Deputy Librarian, who is responsible for enforcing the Library’s
CIO, who is responsible for overseeing the Library’s program; and
Chief Information Security Officer (CISO), who is to act as the single  point of contact for all information security activities.
Additionally, Library business owners are responsible for ensuring that  systems they are responsible for are developed in accordance with, and  comply with, Library information security policies.
The Library also documented information security policies and  procedures to safeguard its information and systems and to reduce the  risk and minimize the effects of security incidents. For example, the  Information Technology Security Policy of the Library of Congress  established the agency’s overall information security program and sets  ground rules under which it is to operate and safeguard its information  and information systems to reduce the risk and minimize the effect of  security incidents. In addition, the Library’s General Information  Technology Security identifies specific IT control requirements for all  information systems, including measures and controls designed to  respond to any incidents that occur and recovery of information resources  in the event of a disaster. The Library recently updated this directive to  align with the latest revision to NIST’s guidelines for building effective  security plans, which according to NIST outlines expanded security and  privacy controls and provides a more holistic approach to information  security.
section_title: Library Developed Policies Aimed at Protecting the Privacy of Information
paragraphs: The Library has also taken steps to protect the privacy of data processed  by its systems. It designated the Library’s General Counsel as the  agency’s Chief Privacy Officer, which includes overall responsibility for  managing the protection of personally identifiable information (PII)  maintained by the Library’s systems.
The agency also documented a policy for protecting PII and responding to  reports of unauthorized access or improper disclosure of PII. Specifically,  the Library regulation Protection and Disclosure of Personally Identifiable  Information establishes, among other things, the following requirements  for the Chief Privacy Officer and service units:  Incident handling: Any known or suspected unauthorized access to  or improper disclosure of PII must be reported by the impacted  service unit immediately to both the Chief Privacy Officer and the IG,  who are to coordinate a response to minimize any harm. The Library  has also developed guidance for responding to privacy incidents  relating to information systems.
PII training: The Chief Privacy Officer and service units are  responsible for the provision of PII training to Library employees.
Assessment of privacy risks: Service units are required to identify  PII and the purposes for which it is used, assess the sensitivity of the  information, and determine appropriate levels of protection.
Separately, the Library’s General Information Technology Security  Directive requires system owners to conduct privacy impact  assessments for all systems in order to mitigate privacy risks.
Oversight of privacy activities: The Chief Privacy Officer has overall  responsibility for all of the Library’s privacy information activities,  including the assurance of privacy policy compliance.
section_title: Library Has Not Fully Implemented Security and Privacy Management Controls
paragraphs: Although the Library established security and privacy programs for  information systems, it did not fully implement management controls  associated with these processes.
subsections: section_title: Library Established and Implemented an Incident Handling Process for Selected Incidents
paragraphs: Even strong controls may not block all intrusions and misuse, but  organizations can reduce the risks associated with such events if they  take steps to promptly report and respond to them before significant  damage is done. In addition, analyzing security incidents allows  organizations to gain a better understanding of the threats to their  information and the costs of their security-related problems. Such  analyses can pinpoint vulnerabilities that need to be eliminated so that  they will not be exploited again. Incident reports can be used to provide  valuable input for risk assessments, help in prioritizing security  improvement efforts, and illustrate risks and related trends for senior  management. NIST guidance recommends that agency information  security programs include, among other things, procedures for reporting  and responding to security incidents.
The Library has established and implemented an incident handling  process. Specifically, it developed procedures for reporting and  responding to security incidents. Additionally, for the 22 selected incidents  we reviewed, the Library followed these procedures, to include  documenting, analyzing, halting the spread of or limiting the damage  caused by, and recovering from the incidents, as appropriate.
As a result, the Library has increased assurance that it will be able to  promptly report and respond to intrusions and misuse before significant  damage is done.
section_title: Inventory of Systems Was Not Complete or Accurate
paragraphs: According to NIST guidelines, agencies should develop and maintain an  inventory of their information systems. A complete and accurate  inventory of major information systems is a key element of managing the  agency’s IT resources, including the security of those resources. The  inventory can be used to track agency systems for purposes, such as  periodic security testing and evaluation, patch management, contingency  planning, and identifying system interconnections. Further, ITS policy  requires the CISO to develop an inventory that includes all general  support systems and major applications.
However, the Library’s inventory of its information systems was not  complete and accurate. In particular, an inventory maintained by the  CISO did not include systems identified in inventories maintained by  Library Services. For example, the list maintained by the CISO had 30  Library Services systems, but the list provided to us by Library Services in  May 2014 identified 46 systems. After we raised the discrepancy with  Library Services, officials from that service unit provided us with a revised  list of 70 systems. Moreover, none of the lists maintained by the CISO or  Library Services included the networks used by the overseas offices, and  the Chief of the Library Services Automation and Planning Office  acknowledged that these systems have not been certified and accredited.
According to the CISO, he did not know about some of the missing  systems until they were brought to his attention by GAO. The CISO noted  that there were a few systems that needed to be included in the system  list. He added that in fiscal year 2015 the Library plans to implement a  new system for managing its security program, which will include  scanning the Library’s network to identify its systems. In addition, the  CISO stated that many of the systems not included in the various  inventories are legacy systems that have been exempted from performing  key information security management processes. Specifically, according  to Library policy, all low-impact operational IT systems implemented prior  to August 20, 2004, that have not undergone a major change (e.g.,  software or hardware upgrade) are not required to undergo a triennial  certification and accreditation. However, without a complete inventory that  includes all legacy systems, there is increased risk that the Library will not  be able to track legacy systems that undergo a major change and ensure  that appropriate controls are put in place to protect them.
Further, the CISO stated that the Library is taking steps to mitigate risks  at its overseas offices. For example, according to the CISO, the Library is  performing vulnerability scans of the offices, upgrading the operating  system of their workstations, and routing their e-mails through the  Library’s firewalls. Although these steps should improve the security of  these offices, the Library will not be able to identify all risks associated  with the overseas offices—and thus ensure that controls have been  implemented to appropriately mitigate those risks—without certifying and  accrediting the networks for those sites.
Until the Library has a complete and accurate inventory of its systems, it  cannot ensure that the appropriate security controls have been  implemented to protect these systems.
section_title: Library Did Not Fully Establish and Implement a Process for Documenting Key Controls in System Security Plans
paragraphs: The objective of system security planning is to improve the protection of  IT resources. A system security plan is to provide a complete and up-to- date overview of the system’s security requirements and describe the  controls that are in place—or planned—to meet those requirements.  According to NIST guidelines, system security plans should include  descriptions of how security controls are implemented and, for controls  recommended by NIST but not implemented, a justification for why the  controls were deemed not necessary for the system. Further, to the  extent that a system relies on controls established for another system,  known as inherited or common controls, NIST guidelines call for  describing those controls, noting that organizations should assess how  effective they are for the new system being planned and identify  compensating or supplementary controls as needed.
Library policy does not fully address NIST guidelines. Specifically,  although Library policy calls for system security plans to describe or  reference security controls that fulfill the security requirements of the  system, it does not explicitly require plans to describe common controls.
This weakness in Library policy was reflected in the system security plans  for most of the nine selected systems that we reviewed. only two of the nine plans—the plans for the Application Hosting  Environment and the OSEP Physical Security Network—described all of  the common controls on which those systems relied. By contrast, the  security plan for the Enterprise Infrastructure General Support System did  not always describe controls that were inherited; instead, the plan said  that the controls were inherited from the information security program  without identifying what system was responsible for implementing them.  Additionally, the security plan for eCO did not always describe controls  inherited from the Library of Congress Data Network and the Application  Hosting Environment.
In addition, the plan for one system did not always include descriptions of  how security controls were implemented. Specifically, for PICS/NIOSS  the system security plan identified controls that were implemented, but  did not include associated descriptions.
As previously mentioned, the nine systems we reviewed were the ITS Library of  Congress Data Network, OSEP Physical Security Network, CRS Enterprise Infrastructure  General Support System, ITS Application Hosting Environment, ITS Library of Congress  Office Automation System, Copyright Electronic Copyright Office (eCO), Library Services  System Management Information Network II (SYMIN II), NLS Production Information  Control System/NLS Integrated Operations Support System (PICS/NIOSS), and Office of  the Chief Financial Officer Momentum. he acknowledged that the description of these controls in the plan was  not acceptable.
The CISO acknowledged the weaknesses with the plans and stated that,  until recently, he did not have the resources needed to audit these plans.  This official added that the Library recently hired an IT specialist with  previous experience reviewing certification and accreditation packages,  including security plans, and that this specialist has started to audit these  packages.
Without complete system security plans, it will be difficult for agency  officials to make fully informed judgments regarding the risks involved in  operating those systems, increasing the risk that the confidentiality,  integrity, or availability of the systems could be compromised.
section_title: Library Did Not Conduct Complete Security Testing
paragraphs: A key element of an information security program is regular testing and  evaluation to ensure that systems are in compliance with policies and that  the policies and controls are both appropriate and effective. Such testing  demonstrates management’s commitment to the security program,  reminds employees of their roles and responsibilities, and identifies areas  of noncompliance and ineffectiveness requiring remediation. NIST  guidance emphasizes that agencies should regularly test the  implementation of security controls to determine the extent to which they  are implemented correctly, are operating as intended, and meet security   NIST also notes that security testing should assess both  requirements.the controls implemented by a system and those inherited from other  systems.
The Library has taken steps to establish a policy on security testing that is  consistent with NIST guidance, but has not finalized guidance on how the  policy is to be implemented. Until recently, Library policy required that  security testing of all controls for a particular system be conducted as part  of the system’s triennial certification and accreditation process. However,  in November 2014, the Library revised its policy to require near-real-time  testing—an approach commonly referred to as continuous monitoring.Specifically, the Library now requires service units to assess the risk  associated with each security control through a continuous monitoring  program and perform testing as frequently as needed in order to  appropriately mitigate the risks. According to the CISO, this policy is to be  implemented by service units when the certification and accreditation of  their systems are due to be renewed. Although the Library has  established policy for continuous monitoring, its guidance on how service  units are to carry out this policy has not been finalized.
Additionally, the Library did not always follow its policy. In particular, each  of the nine selected systems inherited security controls relating to the  Library’s information security program, but, according to the CISO, the  Library has not assessed these inherited controls to ensure that they  have been appropriately implemented. The CISO acknowledged that  these controls should be tested periodically and stated that the Library  plans to do so as part of the implementation of a new system for  managing its information security program, which is to occur in fiscal year  2015.
Additionally, the Library’s security testing did not always identify control  weaknesses. For example:
Although all nine selected systems’ most recent security testing  documentation reported that appropriate background investigations  had been performed, we identified seven individuals with elevated  privileges to three systems—Library of Congress Data Network,  PICS/NIOSS, and OSEP Physical Security Network—for which the  Library did not have a record of a background investigation.
Although seven systems’ most recent security evaluations reported  that privacy impact assessments had been developed as  appropriate, we found that four of these systems—Library of  Congress Office Automation System, eCO, SYMIN II, and  Momentum—had never completed such an assessment.
Further, the Library did not complete security assessments in a timely  manner for three systems. As of January 2015, three systems—SYMIN II,  Library of Congress Office Automation System, and Library of Congress  Data Network—had not completed security assessments consistent with  Library policy, which requires such assessments to be performed at least  every 3 years.
With respect to SYMIN II, the CISO stated that ITS opened a remedial  action plan that tasks Library Services with completing this  assessment.
Regarding the Library of Congress Office Automation System and  Library of Congress Data Network, the ITS Assistant Director for  Operations signed waivers for the systems that extended the deadline  for completing the security assessments to October 2015 and July  2015, respectively. This was because the contractor to be used to  perform the testing was not available as it was performing testing on  the Library’s financial hosting environment.
Although, to its credit, the Library analyzed and accepted the risk of not  performing testing as scheduled, such lapses between testing can  significantly increase the risk that exploitable weaknesses will not be  identified and addressed in a timely manner. Without comprehensive and  effective testing, the Library does not have reasonable assurance that its  security controls for the selected systems are working as intended,  increasing the risk that attackers could compromise the confidentiality,  integrity, or availability of the systems.
section_title: Library Did Not Always Develop Remedial Action Plans and Did Not Always Close Those That Had Been Developed in a Timely Fashion
paragraphs: When a security weakness is identified as part of security testing,  agencies should develop a remedial action plan, also known as a plan of  action and milestones (POA&M) to address the issue. Such a plan assists  agencies in identifying, assessing, prioritizing, and monitoring progress in  correcting security weaknesses that are found in information systems.  NIST guidance emphasizes the use of such plans in order to document  the organization’s planned actions to correct identified weaknesses.
The Library has established a policy for developing and monitoring  remedial action plans. According to Library policy, when weaknesses are  discovered during a security assessment, a POA&M must be produced,  to include a schedule for implementing any mitigation.
However, the Library did not always follow its policy. Specifically, eight of  the nine systems that we reviewed had POA&Ms that were delayed and,  in many cases, POA&M items were over a year past their expected  completion date. For one system—the OSEP Physical Security  Network—although OSEP’s 14 open POA&M items from its security  testing in September 2013 were to be completed by September 2014,  according to the CISO, OSEP has not reported any updates for these  items since they were opened in September 2013. Additionally, as of  December 2014, of the 229 items included in the POA&Ms for the other  eight selected systems, 49 had a status of “delayed.” Of particular  concern are the 28 POA&M items for PICS/NIOSS that were identified in  2011 and have yet to be completed. Table 5 shows the number of  delayed POA&M items for the other eight selected systems.
The CISO acknowledged that POA&M closure has been a known issue  for some time, noting that some items have been open for multiple years.  As previously mentioned, Library business owners are responsible for  ensuring that their systems are in compliance with Library information  security policies. At the conclusion of our review in March 2015, the  interim CIO stated that she received briefings on the status of POA&Ms in  February and March 2015 and will meet with the heads of service units to  review older POA&M items and discuss their resolution.
Until weaknesses with the Library’s remediation of vulnerabilities have  been resolved, they will compromise the ability of the agency to track,  assess, and accurately report the status of the agency’s information  security program.
section_title: Library Systems Did Not Always Have Authorization to Operate
paragraphs: Under NIST guidance, after testing is completed, organizations are to  compile an authorization package—composed of the security plan, testing  report, and POA&M items—for the system’s authorizing official to  review. The authorizing official is a senior official or executive with the  authority to formally assume responsibility for operating an information  system at an acceptable level of risk. According to NIST guidance, if the  authorizing official, after reviewing the authorization package, deems that  the risks (e.g., unaddressed vulnerabilities) are acceptable, an  authorization to operate is issued for the information system. The  information system is authorized to operate for a specified time period in  accordance with the terms and conditions established by the authorizing  official. Additionally, NIST guidance states that authorizing officials can  also deny authorization to operate for an information system or, if the  system is already operational, halt operations if unacceptable risks exist.
To its credit, the Library’s policy is consistent with NIST guidance;  specifically, it requires authorization packages to be created prior to  receiving authorization to operate. that, until the system has authorization to operate, it cannot be deployed  as an operational system. Until recently, Library policy required that  systems be reauthorized every 3 years as part of the certification and  accreditation process. In November 2014, as part of the Library’s  adoption of continuous monitoring, the Library revised its policy to require  that, after the initial authorization to operate is in place, systems only be  reauthorized in the event of a major change (e.g., software or hardware  upgrade). According to draft Library guidance on implementing  continuous monitoring, in place of the 3-year reauthorization cycle,  authorizing officials will review the reported security status on an ongoing  basis to form a continuous authorization decision.
Additionally, Library policy states  However, the Library did not always consistently implement its policy. As  of January 2015, four systems—SYMIN II, eCO, Library of Congress  Office Automation System, and Library of Congress Data Network—were  operating without a current authorization.
Library of Congress, Information Technology Security Directive 01.
With respect to SYMIN II, it did not have this authorization because,  as previously mentioned, it had not completed its security testing.
Regarding eCO, the Deputy Director of the Copyright Office’s  Technology Office signed a waiver moving the date for the  authorization package to be completed from May 2014 to May 2015.  The waiver cited multiple upgrades that were to occur between May  2014 and May 2015.
Regarding the Library of Congress Office Automation System and the  Library of Congress Data Network, the ITS Assistant Director for  Operations signed waivers for the systems that allowed them to  postpone their authorization to operate to October 2015 and July  2015, respectively. The waivers cited the need to complete testing,  which was delayed because the contractor used to perform that  testing was engaged in security testing for another system.
Additionally, for two systems—the OSEP Physical Security Network and  the Application Hosting Environment—the Library did not ensure that  authorizations to operate were signed in a timely manner.
With respect to the OSEP Physical Security Network, although the  system has been operational since 2003, the Library did not authorize  the system to operate until February 2015. This is particularly  concerning because the Library has classified this system as high  impact—that is, it has determined that the loss of the system’s  confidentiality, integrity, or availability could be expected to have a  catastrophic effect on organizational operations, organizational  assets, or individuals. In a written response, the Library stated that,  although OSEP completed an authorization package for this system in  September 2013, the authorization was not completed until February  2015 because of a lack of program oversight.
Regarding the Application Hosting Environment, although ITS signed  the authorization to operate for the system in October 2014, this was  4 months later than allowed by Library policy. During this time, the  Application Hosting Environment continued to operate. Similar to  eCO, the Director of ITS signed a 4-month waiver that extended the  authorization to operate, citing the need for additional time to finalize  the authorization package.
The CISO acknowledged that these systems did not have authority to  operate, but noted that, instead of just extending the authorization, the  Library requires service units to sign a waiver reflecting a risk-based  decision to continue operating the systems without authorization.  Although extending the time required to obtain authorization to operate  may occasionally be valid, the Library’s persistent use of these waivers  increases the probability that risks, such as unaddressed vulnerabilities,  are not being communicated to management. This concern is heightened  by the sometimes extended length of time associated with these delays.
The CISO also added that these weaknesses should not recur once the  Library implements its continuous monitoring program, because service  units will not need to reauthorize systems at the end of each certification  and accreditation cycle. Instead, the Library’s continuous monitoring  program will allow authorizing officials to review the reported security  status on an ongoing basis to make continuous authorization decisions. If  the Library fully establishes and implements its continuous monitoring  program, it will be better positioned to ensure that continuous  authorization decisions are fully informed. However, as previously  mentioned, although the Library has established policy for continuous  monitoring, its guidance on how service units are to carry out this policy  has not been finalized. Until its approach to continuous monitoring is fully  implemented, the Library will not have assurance that appropriate officials  have been informed of system risks and that these officials have either  accepted these risks and assumed responsibility for them, or halted  system operations until the risks are acceptable.
section_title: Library Systems Did Not Always Have Contingency Plans
paragraphs: Contingency planning controls are intended to provide assurance that,  when unexpected events occur, essential operations can continue without  interruption or can be promptly resumed and that sensitive data are  protected. Losing the capability to process, retrieve, and protect  electronically maintained information can significantly affect an entity’s  ability to accomplish its mission. If contingency planning controls are  inadequate, even relatively minor interruptions can result in lost or  incorrectly processed data, which can cause financial losses, expensive  recovery efforts, and inaccurate or incomplete information. According to  NIST guidelines, agencies should develop contingency plans for their  information systems that, among other things, provide established  procedures for assessment and recovery of systems following a system  disruption.
The Library has developed a policy on contingency planning that requires  system owners to ensure, for each IT system under their purview, the  development and maintenance of a contingency plan. These plans should  include, among other things, procedures for ensuring that the systems are  successfully recovered.
However, only three of the nine selected systems—Enterprise  Infrastructure General Support System, eCO, and Momentum—had a  contingency plan that addressed NIST guidance and Library policy. For  three of the systems—the Application Hosting Environment, Library of  Congress Data Network, and the Library of Congress Office Automation  System—their security plans indicated that contingency planning was to  be addressed in the Library’s Information Technology Continuity of  Operations Plan; however, this plan does not include specific procedures  for recovering these systems. Additionally, three systems—OSEP  Physical Security Network, SYMIN II, and PICS/NIOSS—have not  established contingency plans.
The CISO acknowledged that these systems did not have contingency  plans and stated that he will open POA&Ms for them to be created. Until it  develops contingency plans for its key information systems, the Library  may have delays in recovering systems or may be unable to recover  systems entirely in the event of a large disaster.
section_title: Security Awareness and Privacy Training Policies Were Not Fully Documented, and Training Was Not Tracked or Completed by All Users
paragraphs: According to NIST guidelines, agencies should provide basic security  awareness training to all information system users as part of initial  training for new users, and regular refresher training to all users on an  agency-defined basis. This training should inform personnel, including  contractors and other users of information systems supporting the  operations and assets of an agency, of information security risks  associated with their activities and their roles and responsibilities to  effectively implement the practices that are designed to reduce these  risks. In addition, NIST guidelines call for organizations to administer  basic privacy training on a regular basis.
The Library has established policies and procedures that generally  address NIST guidelines on security awareness training. Specifically,  Library policy requires all personnel, including staff, contractors, and  volunteers with access to Library of Congress IT systems, to complete the  IT security awareness training on an annual basis. The Chief Privacy  Officer and CISO told us that privacy is also covered in the Library’s  annual security awareness training, and the CISO provided a copy of the  fiscal year 2014 training, which addresses employee responsibilities for  handling PII.
However, the Library did not ensure that all required users completed  security awareness and privacy training. Of the personnel tracked in its  database of record, the Library estimated that 4,131 of 4,145 users (99.7  percent) completed the required awareness training in fiscal year 2014.  However, we identified 1,345 user accounts—204 from OSEP, 42 from  CRS, and 1,099 from the rest of the Library—with access to Library IT  systems that were not tracked in the database. Library officials were  unable to provide comprehensive information on how many of the  additional personnel had completed the required awareness training.
Regarding the 204 accounts in OSEP, the Library reviewed 47  accounts that we identified. Of those, the Library found 8database of record, and only 3 of those individuals reportedly took the  training in fiscal year 2014. According to the Director of Workforce  Performance and Development, many of these accounts are Capitol  Police personnel who have access to OSEP’s Physical Security  Network, but who are not tracked in the Library’s database of record.  The CISO stated that the Library does not provide security awareness  training to these users. Instead, they rely on the Capitol Police to  provide adequate training. Additionally, OSEP stated that, although  the Capitol Police provide training to their staff, the Library does not  ensure that all Capitol Police users of Library systems have  completed the training.   in its
Of the 42 accounts from CRS, the Library found 28 names in its  database of record—only 12 of which reportedly took the training in  2014.
With respect to the 1,099 accounts for the rest of the Library, the  Library reviewed 103 accounts. Of those, the Library found 55 in the  database of record, and only 14 of those individuals reportedly took  the training in 2014.
The Library cited multiple reasons for the differences between the  accounts we identified and the training database of record. According to  the Director of the Office of Workforce Performance and Development,  some of the accounts that we identified appeared to be associated with  personnel who no longer work for the Library. Additionally, that official  stated that, in some cases, the user name for an individual was different  in the training database of record and the database used to authorize  access to Library systems.
At the conclusion of our review, the Assistant Director for Human  Resource Operations stated that the Human Resources Services, ITS,  and other appropriate offices will assemble a complete and accurate list  of staff, contractors, and others with access to Library networks in fiscal  year 2014. That official added that Human Resources Services will also  implement a process for obtaining a complete and accurate listing of staff  for the next cycle of training.
Until the Library ensures that all personnel with access to its network take  security awareness training, it will have less assurance that they have a  basic awareness of information security issues and agency security and  privacy policies and procedures.
section_title: Contracts Did Not Always Address Security and Privacy Requirements
paragraphs: The Library relies on the services of contractors to operate and secure its  computer systems on its behalf. While contractor personnel who operate  systems and provide services to federal agencies can provide significant  benefits, they, as with government employees, can also introduce risks to  agency information and systems, such as the unauthorized access, use,  disclosure, and modification of federal data.
In order to ensure that contractors meet information security and privacy  requirements, NIST recommends that organizations include information  security and privacy requirements in their contracts for IT systems and  services. Toward this end, Library policy calls for all IT contracts to  require contractors to comply with Library security and privacy  requirements. Additionally, the Library has developed standard  sections addressing NIST guidelines that are required in all IT  solicitations.
However, contracts for eight of the nine selected systems we reviewed  did not fully address Library security and privacy requirements for IT  system and services contracts. Specifically, only one contract—for  PICS/NIOSS—included the standard sections that Library policy requires.
In a written response, the Library agreed that contracts for eight systems  did not address Library requirements and explained that this occurred  because internal reviewers did not consistently identify the missing  information. The Library also has made draft revisions to its contractual  security requirements because officials determined that the prior  requirements were overly broad. These revisions are consistent with  NIST guidelines. For example, the standard sections require the  contractor’s work to be conducted in accordance with the latest version of  NIST’s information security and privacy controls. The Library told us  that the Office of General Counsel is to review these requirements for  promulgation in fiscal year 2015. However, the Library has yet to  establish a date for finalizing these requirements.
In the interim, the Library stated that service units are to review all current  contracts for IT systems and services to ensure that the current  requirements have been incorporated. The Library added that the Office  of Contracts and Grants Management, with support from the Office of  General Counsel, will continue to review statements of work for IT  systems and services and identify any potential gaps in IT security  requirements prior to contract award.
Until the Library finalizes its standard contract sections for information  security and privacy and ensures that contracts for IT systems and  services include these provisions, it increases the risk that meeting  enterprise-wide security requirements could require costly contract  modifications or that these requirements will not be implemented  according to Library policy.
section_title: Library Did Not Fully Assess Privacy Risks in Privacy Impact Assessments
paragraphs: According to NIST guidelines, agencies should assess privacy risks of an information system when developing a privacy impact assessment.These risk assessments are intended to help program managers and  system owners identify privacy risks and techniques to reduce those  risks.
Library policy is consistent with NIST guidance. Specifically, it calls for  privacy impact assessments to be performed for all Library systems.
However, the Library only conducted privacy impact assessments for two  of the nine selected systems we reviewed—Enterprise General Support  System and PICS/NIOSS.
As previously mentioned, the security tests for four systems—Library  of Congress Office Automation System, eCO, SYMIN II, and  Momentum—reported that privacy impact assessments had been  developed as appropriate; however, when asked for copies of these  assessments, Library officials responsible for these systems stated  that privacy impact assessments had not been performed. According  to the CISO, POA&M items have been opened for privacy impact  assessments to be performed on these systems.
Security testing for the OSEP Physical Security Network stated that  the system did not have a privacy impact assessment and this has  been an open POA&M item since September 2013.
Security testing for the Application Hosting Environment determined  that the system did not have a privacy impact assessment. In  describing the risk associated with this weakness, the test report  stated that, although there may be systems hosted on the Application  Hosting Environment that collect, process, or store PII, these systems  have their own privacy impact assessments. However, as previously  noted, eCO, which is hosted on the Application Hosting Environment,  did not have a privacy impact assessment. The testing report also  recommended that the Library conduct a privacy impact assessment  to verify that the Application Hosting Environment does not collect,  process, or store PII independent of the systems that it hosts.
Regarding the Library of Congress Data Network, its security plan  states that this control is not applicable because the system does not  collect, maintain, or disseminate information—it only transfers data  from one place to another. However, NIST guidance calls for privacy  impact assessments to be performed to assess risks resulting not only  from the collection, storing, or use of PII, but also the transmission of  such data.
One reason for the inconsistent performance of privacy impact  assessments is the lack of oversight to ensure compliance with Library- wide privacy policy and requirements. According to the Library’s General  Counsel, who also serves as the Chief Privacy Officer, the Office of  General Counsel does not review the Library’s privacy program because  it is not required to do so. Rather, that official told us that she relies on the  service units to carry out their responsibilities. However, according to  Library policy, the Chief Privacy Officer has overall responsibility for all of  the Library’s privacy information activities, including ensuring PII policy  compliance.shall have overall responsibilities for managing the protection of PII  maintained in the Library’s systems and files.
Additionally, the policy states that the Chief Privacy Officer  Until the Chief Privacy Officer establishes and implements a process for  reviewing the Library’s privacy program, including ensuring that privacy  impact assessments have been conducted for all IT systems, PII  collected by the Library will be at increased risk of compromise.
section_title: Control Weaknesses Threaten Library Information and Systems
paragraphs: A basic management objective for any agency is to protect the resources  that support its critical operations and assets from unauthorized access.  An agency can accomplish this by designing and implementing controls  that are intended to prevent, limit, and detect unauthorized access to  computer resources (e.g., data, programs, equipment, and facilities), and  securely configure information systems, thereby protecting them from  unauthorized disclosure, modification, and loss. Controls relating to these  areas include policies, procedures, and protections regarding  authorization, identification and authentication, cryptography, background  investigations, and environmental safety. Weaknesses in these areas  increase the risk of unauthorized use, disclosure, modification, or loss of  sensitive information and information systems supporting the Library’s  mission.
The Library did not effectively implement or securely configure key  security tools and devices on the nine selected systems to sufficiently  protect users and information from threats to confidentiality, integrity, and  availability. Specifically, weaknesses existed in the following control  categories:
Authorization: The Library did not always establish and implement a  process for documenting approvals for elevated permissions to  selected systems. NIST guidance and Library policy call for such a  process in order to ensure that only authorized users can access a  system. Specifically, only one of the nine selected systems— Momentum—provided records documenting who approved accounts  with elevated privileges and why those accounts were created. At the  conclusion of our review, the Library acknowledged in a written  response that it had not fully established and implemented such a  process. The Library stated that the IT Security Group has requested  account creation procedures from all information system security  officers and will create a POA&M for all systems without these  procedures. Until the Library establishes and implements a process  for documenting elevated permissions, in the event of an incident the  Library may not be able to determine if an account was appropriately  created or had been accidentally or maliciously assigned  inappropriate permissions.
Identification and authentication: The Library did not always require  two-factor authentication for access to sensitive Library resources.  NIST recommends using multifactor authentication for users to   Until the Library consistently uses two- access network resources.factor authentication, there is increased risk that its systems will not  limit access appropriately.
Cryptography: The Library did not always ensure that sensitive  information transmitted across its network was being adequately  encrypted. NIST recommends that organizations employ  cryptographic mechanisms to prevent unauthorized disclosure of  information during transmission. In a written response at the  conclusion of our review, the Library acknowledged this weakness  and opened a POA&M to address it, with a scheduled completion date  of July 2015. Until the Library addresses this weakness, there is  increased risk that an individual could capture information, such as  user credentials or other sensitive data, and use the information to  gain unauthorized access to data and system resources.
Background investigations: As previously mentioned, the Library  did not perform background investigations for seven individuals with  elevated privileges to three systems—Library of Congress Data  Network, PICS/NIOSS, and OSEP Physical Security Network. NIST  guidance and Library policy call for personnel to undergo  background screening commensurate with their level of access to  Library systems in order to ensure that they are trustworthy and meet  established security criteria. At the conclusion of our review, the  Library said in a written response that it would take action to address  this by performing background investigations for six of the individuals.  The Deputy Chief of OSO stated that the office removed elevated  privileges to the OSEP Physical Security Network for the remaining  individual.
Environmental safety: The Library did not ensure that an annual  inspection of the fire suppression system for the primary data center  was performed in a timely manner. NIST recommends that  organizations employ and maintain fire suppression and detection  systems for the information systems and regularly inspect those  systems for deficiencies. After we informed the Library of this issue,  an inspection of the system was performed.
In addition to the above weaknesses, we identified other security  weaknesses in controls related to authorization, configuration  management, boundary protection, patch management, and physical  security that limit the effectiveness of the security controls on the selected  systems and unnecessarily place sensitive information at risk of  unauthorized disclosure, modification, or exfiltration. We intend to issue a  separate report with limited distribution to describe in greater detail the  control weaknesses we identified during this review.
section_title: Library Has Not Ensured That IT Services Are Supporting Organizational Needs, Resulting in Inconsistent Satisfaction with Services and Duplicative or Overlapping Efforts
paragraphs: Recognized industry best practices call for ensuring that an organization’s  IT services are aligned with and actively support its business needs. As  the central IT organization within the Library, the Office of Strategic  Initiative’s Information Technology Services (ITS) directorate is  responsible for providing an array of IT services to other units within the  Library.
However, ITS has not ensured that its services support the business  needs of the Library. While it has developed a catalog that identifies the  services it provides to other units within the agency, it has not established  service-level agreements for all these services that include agreed-upon  performance targets. The Library has drafted a new policy for such  service-level agreements, but it has yet to be finalized. Further, our  survey of service units within the Library revealed that they were often not  satisfied with the services provided by ITS. Although ITS has begun to  conduct customer satisfaction surveys, it has not developed a plan for  improving satisfaction with its services Library-wide. Moreover,  inconsistent satisfaction with the services provided by the Library’s central  IT office has likely contributed to duplicative or overlapping efforts across  the Library. Specifically, units across the Library performed many of the  same functions as ITS, including maintaining their own networks and  servers, purchasing duplicate copies of desktop software, and  maintaining duplicative security solutions.
subsections: section_title: Key Service Management Practices Have Not Been Implemented
paragraphs: The development and implementation of Information Technology  Infrastructure Library practices are widely recognized as hallmarks of  successful public and private IT organizations.key practices to ensure that IT services are aligned with the business  needs of an organization and actively support them. For example:
A service catalog identifies all current IT services delivered by the  service provider to its customers.
A service-level agreement (SLA) establishes agreement between an  IT service provider and a customer to describe the IT services, specify  the responsibilities of both parties, and document the expected  service-level targets.agreements are to be structured such that IT services and customers  are covered in a manner best suited to the organization’s needs (e.g.,  one agreement for each service or one for each customer).
Organizations should define how these  As the central IT organization within the Library, ITS provides services to  the various service units. According to Library policy, ITS management  and staff are to work to satisfy customer requirements, provide  outstanding customer service, and represent customer interests. The  Director of ITS stated that ITS has adopted Information Technology  Infrastructure Library practices in order to meet customer needs.
Although ITS has developed a service catalog, it has not fully established  SLAs.
Service Catalog: To its credit, ITS developed a service catalog that  captures its current IT services. Specifically, the catalog identified 31  administrative, management, and technical IT services that are  available to ITS customers. For example, ITS provides services that  cover service desks (e.g., problem management), backup and  recovery, and network services (e.g., design, construction, security  and maintenance).
SLAs: The Library has not defined a structure for ensuring that IT  services and customers are covered by SLAs in a manner that meets  the service units’ needs. In the absence of such a structure, ITS has  established 19 SLAs with individual service units, each of which  describes the services that ITS will provide and the roles and  responsibilities of each party. For example, ITS established an SLA  with the Copyright Office for the management, operation,  maintenance, and security of eCO. The SLA identifies six services— including services relating to disaster recovery and database  management—and describes the roles and responsibilities for both  ITS and Copyright. However, the 19 SLAs do not fully address all IT  services and customers, or always establish expected service-level  targets. Specifically:
The SLAs do not address all of the services in ITS’s service  catalog. Specifically, the agreements collectively only address 14  of the 31 services ITS provides to the Library of Congress. For  example, ITS does not have a SLA that addresses the services it  provides CRS for its Enterprise Infrastructure General Support  System.
The SLAs do not include service-level targets for all services.
Specifically, only 9 of the 19 SLAs contained such targets,  covering 3 of the 31 services. For example, according to the SLA  governing the management of eCO, in the event of a disaster that  affects IT operations in the main data center, ITS is to recover the  eCO system at its alternate computing facility within 24 hours of  the disaster. However, ITS did not establish targets for any of the  other 28 services in its service catalog, such as the amount of  time systems are available as part of its hosting service.
According to the ITS Assistant Director for Operations, ITS recently  established service-level targets for one additional service: the service  desk. These targets pertained to how quickly problems should be  resolved, depending on their severity. He added that these targets reflect  ITS’s intent to provide the same level of service to all of its customers.  However, the service units have not agreed to these targets. According to  the ITS Assistant Director for Operations, he briefed the services units on  these targets and received feedback, but acknowledged that ITS did not  establish formal agreements with the service units. Without agreement  from the service units, it is unclear whether these service-level targets will  meet the unique business needs of the Library’s service units.
The ITS Assistant Director for Operations further stated that ITS has  drafted a policy documenting its approach to developing SLAs. If  approved, the policy will call for ITS to continue to develop two types of  SLAs—(1) those with individual service units to define a unique service,  and (2) SLAs with the Library of Congress as a whole. Although the draft  policy calls for the use of service-level targets for Library-wide SLAs, it  does not do so for SLAs with individual service units. Moreover, given that  the policy is to govern ITS, it is unclear whether the policy will reflect an  SLA structure that covers the IT services and customers in a manner best  suited to meet the needs of both ITS and its customers. For example, the  policy would no longer allow ITS to enter into agreements with individual  service groups within a service unit—such as NLS. At the conclusion of  our review, the ITS Assistant Director for Operations told us that ITS  submitted the policy to the Library’s interim CIO in January 2015. He also  stated that the ITSC and Executive Committee will complete their reviews  by May 2015 and that SLAs under the new policy will be completed by  September 2015.
Until the Library establishes and implements an SLA structure—to include  the use of service-level targets—that meets the needs of the organization,  there is increased risk that ITS will not provide services that meet the  needs of its customers. In the case of the Copyright Office, this risk has  been realized. For example, according to the Copyright CIO, the Library  controls when eCO is shut down for maintenance and these have, at  times, been scheduled during periods of heavy traffic from the office’s  external users.
section_title: Service Units Were Often Not Satisfied with Library IT Services, but ITS Has Not Established a Plan for Improvement
paragraphs: The weaknesses in ITS’s implementation of service-level management  practices were reflected by inconsistent satisfaction with the services that  it provides. To be successful, IT organizations should measure the  satisfaction of their users and take steps to improve it. In this regard,  effectively managing activities to improve user satisfaction requires  planning and executing such activities in a disciplined fashion. The  Software Engineering Institute’s IDEALSM model is a recognized approach  for managing efforts to make system improvements. According to this  model, user satisfaction improvement efforts should include a written plan  that serves as the foundation and basis for guiding improvement  activities, including obtaining management commitment to and funding for  the activities, establishing a baseline of commitments and expectations  against which to measure progress, prioritizing and executing activities  and initiatives, determining success, and identifying and applying lessons  learned. Through such a structured and disciplined approach,  improvement resources can be invested in a manner that produces  optimal results.
However, ITS has not demonstrated that user satisfaction improvement  efforts are being guided by a documented plan that defines prioritized  improvement projects and associated resource requirements, schedules,  and measurable goals and outcomes. Instead, efforts that the office  undertook to improve user satisfaction were ad hoc and did not meet with  success. Specifically, ITS only measures user satisfaction for 1 of the 31  services it provides to other service units (help desk services).
In the absence of comprehensive data on ITS customer satisfaction, we  surveyed the heads of the Library’s seven service units, as well as the  head of NLS, about the extent to which they were satisfied with the IT  services provided by ITS. The results showed that ITS’s customers—the  Library’s service units—vary in the extent to which they are satisfied with  the services provided by ITS, but collectively these customers are  generally not satisfied.
Specifically, the average score for all IT services provided by ITS was  3.17 (on a 5-point satisfaction scale, where 1 is very dissatisfied and 5 is  very satisfied), and the scores for each service ranged from a low of  2.33 to a high of 4.40. More specifically, only 2 of the 29 services had an  average score above 4, indicating that service units were generally very  satisfied or somewhat satisfied with these services. The majority of the  services—19 of the 29 services—ranged from 3.75 to 3.0, indicating that  service units were generally neither satisfied nor dissatisfied or somewhat  satisfied with these services. Lastly, a little more than a quarter of the  services (8 of 29) had an average score below 3, which indicates that  service units were generally neither satisfied nor dissatisfied or somewhat  dissatisfied. Table 6 shows the average customer satisfaction score for  each of the 29 IT services that ITS provides.
In addition to providing scores, the survey respondents also provided  written comments. Five factors were cited by two or more respondents as  contributing to their dissatisfaction with the services provided by ITS:
Lack of transparency: Six of the eight respondents cited a lack of  transparency from ITS as a source of dissatisfaction with its services.  For example, two respondents discussed transparency issues with the  Library’s IT Continuity of Operations Planning: one cited issues with  testing, while the other discussed a need for more transparency with  respect to the decision making on the priority of systems to be  recovered in the event of a disaster. Further, one respondent stated  that OSI/ITS develops the IT strategic direction for the organization  without consulting with the senior leadership of the respondent’s  service unit.
Poor quality of service: Five respondents cited the poor quality of  service provided by ITS as a key source of dissatisfaction. For  example, three respondents described problems with the Library’s  telework infrastructure, noting that the service is frequently  unavailable. Additionally, two respondents stated that the  configuration of the software used to prevent access to certain  websites results in overbroad restrictions. One respondent also noted  that the implementation of the process used to gain access to  restricted sites is uneven—some requests are resolved in a timely  manner, while others are not. In addition, one respondent stated that  during recent data center emergencies, data were lost by ITS.  Similarly, according to that respondent, during a power outage in  2009, ITS could not maintain power to the data center because of  known problems with one of its emergency power devices, resulting in  unplanned outages and disruptions to day-to-day operations.
Inconsistent implementation of IT management processes: Five  respondents cited inconsistent implementation of IT management  processes as one of the reasons for their dissatisfaction with some of  the services provided by ITS. For example, two respondents  described weaknesses in ITS’s implementation of project  management practices, noting that ITS needs more experienced  project managers and improvements in cost estimating. Additionally,  four respondents cited problems with ITS’s change management  practices: two respondents stated that ITS frequently does not follow  its established process, one said that the process takes months to  review applications, and the other said that more consistent  configurations and settings are needed. Furthermore, two  respondents stated that the Library has not conducted testing needed  for its continuity of operations and disaster recovery process.  Additionally, three respondents described challenges relating to the  certification and accreditation process, citing problems with cost,  timeliness, and inconsistent implementation.
Inconsistent communication: Four respondents cited inconsistent  communication as a reason for dissatisfaction with some of the  services provided by ITS. For example, three respondents stated that  ITS did not always effectively communicate when outages in IT  systems were to occur. One respondent described instances where  they were informed of outages affecting public-facing systems from  external customers before they were notified by ITS. In addition, one  respondent described instances where they received conflicting  information and direction from ITS.
Use of outdated technology: Four respondents cited outdated  technology used by ITS as a reason for dissatisfaction with its  services. For example, two respondents stated that ITS needs to  invest in a modern infrastructure; one respondent explained that,  without such an infrastructure, the Library will not be able to meet the  technical requirements for acquiring and stewarding digital collections.
According to ITS, it has recently taken steps to measure and improve  user satisfaction. For example, in September 2014, ITS began conducting  surveys of customers that used its service desk, and reported that it  received very positive feedback on this service.
However, ITS has not demonstrated that user satisfaction improvement  efforts are being guided by a documented plan that defines prioritized  improvement projects and associated resource requirements, schedules,  and measurable goals and outcomes. Given the Library’s reliance on IT  services provided by ITS, as well as the results of our survey, it is critical  that ITS identify and implement improvements in a disciplined and  structured fashion. For example, as discussed later in this report,  continued dissatisfaction with ITS services may have led customers to  perform the services themselves in order to improve their IT performance  and decrease their reliance on ITS. Without a documented improvement  plan, efforts to improve user satisfaction may be reduced to trial and  error, and ITS will not be able to adequately ensure that it is effectively  investing resources on improvement efforts that will satisfy users.
section_title: Duplicative or Overlapping IT Activities Are Being Performed by Service Units across the Library
paragraphs: The lack of an enterprise-wide approach to managing IT, in combination  with dissatisfaction with the services provided by ITS, has contributed to  other service units independently performing duplicative or overlapping  activities in support of their business needs. For example, although ITS is  responsible for the Library’s primary IT service desk (which provides IT  troubleshooting service to all Library personnel), CRS and Library  Services maintain separate service desks for their personnel. According  to the CRS CIO and the Chief of Library Services Automation Planning &  Liaison Office, although the service desks maintained by CRS and Library  Services perform some functions that ITS’s service desk performs (e.g.,  resetting passwords), their service desks also perform unique functions.  However, because they perform some overlapping functions, the Library  may be spending more than it needs to on these service desks.
As another example, as previously mentioned, according to the official  who served as acting CIO from April 2014 to January 2015, each service  unit is responsible for managing its own human capital skills. For  example, that official told us that, for its own staff needs, OSI identifies  skills and competencies when an individual leaves the organization or  when OSI plans to hire additional staff.
Additionally, although the service units vary in the extent to which they   in the past 3  purchase IT, all of them have purchased commodity ITyears. For example, most of the service units have purchased desktops,  laptops, and workstation software. Table 7 identifies commodity IT  purchased by Library service units and NLS in the past 3 years.
As a result, there is increased risk that the service units will make  duplicative investments in commodity IT. In the case of monitors and  workstation software, this risk has been realized. Because, as previously  discussed, the Library did not have an accurate inventory of its non- capitalized IT assets, we visited the Library’s warehouse in Landover,  Maryland. At that facility, we observed that, as of December 2014, ITS  had approximately 100 24-inch monitors that were purchased in 2010.  However, instead of using the monitors purchased by ITS, Library  Services purchased 82 additional 24-inch monitors between June 2013  and July 2014. Of particular concern is that Library Services purchased all  of these monitors after the Library’s IG issued a report noting this surplus  of monitors.
According to Library Services, at the time that it purchased the monitors,  it was not aware that ITS had 24-inch monitors. It added that ITS  previously maintained a “PC Store” from which Library Services acquired  computers, monitors, printers, and scanners; however, this service was  discontinued about 3 years ago. Since that time, according to Library  Services, its attempts to purchase equipment have met with mixed  success, and it has often needed to acquire equipment independently.
Finally, Library Services stated that it recently became aware of monitors  available through ITS and is working with them to obtain as many as  possible to meet its needs.
The Library has also made duplicative investments in desktop software,  which has led the Library to purchase too many licenses. For example,  collectively, the Copyright Office, Library Services, and ITS purchased  459 licenses to Microsoft’s Visio 2010 Professional, but as of November  2014 were only using 227. According to the ITS Assistant Director for  Operations, service units are responsible for tracking the usage of  licenses that they procure. He noted, however, that ITS is implementing a  new system to be used to track and analyze data on the usage of  software licenses. Additionally, according to the ITS Assistant Director for  Operations, in some cases the Library has decided to purchase more  licenses than are currently required in anticipation of additional Library  employees, existing employees who will be reassigned to roles requiring  the licenses, and new contractors who will need the licenses. However,  this does not explain why the Library is not using almost half of the  licenses it purchased for this application.
According to the Copyright Office Chief of Operations, the Copyright  Office needs software that can allow access to the many and varied  digital formats submitted by registration customers. He added that, in  recent years, ITS has increasingly required the Copyright Office to  purchase its own licenses for applications that were previously centrally  funded and that the Copyright Office does not consistently receive  information from ITS regarding what licenses the Library has or how  many users are on each license.
In addition to purchasing commodity IT, each of the service units and NLS  perform many of the same types of IT activities. For example, CRS, NLS,  OSO, and OSI manage and support servers. Table 8 identifies key IT  activities independently performed by the service units.
In performing these activities, the Library has made potentially duplicative  investments in IT for four of the eight IT activities identified above.  Specifically:
Server management and support: ITS and CRS each operate and maintain separate environments for the same server virtualizationsolution: VMware. As another example, OSEP and CRS maintain,  separate from ITS’s Application Hosting Environment, their own  technical infrastructures for hosting their organizations.
Network management: OSEP’s Physical Security Network is  completely separate from the rest of the Library’s network.  Consequently, OSEP acquires and maintains network devices, many  of which would not be needed if its systems were hosted on the  Library of Congress Data Network. Additionally, although more  integrated with the Library of Congress data network than OSEP’s  network, CRS’s Enterprise Infrastructure General Support System  also includes a number of network devices that CRS purchases and  manages largely independent of ITS.
Directory services management: ITS, CRS, and OSEP maintain  separate environments for authenticating and authorizing users and  computers. These three organizations also maintain separate e-mail  environments. Additionally, ITS and OSEP both operate and maintain  different solutions for performing two-factor authentication.
Internet and web management: Although OSI has a Web Services  division, which is responsible for developing strategies, plans,  standards, and policies to guide the Library’s web initiatives, the  Copyright Office updated its website in July 2014 independently of  OSI’s Web Services division. The Special Assistant to the Register of  Copyrights stated that this was because OSI did not understand the  office’s requirements and needs. However, the Chief of the Web  Services division stated that he had met with Copyright staff and  attempted to reach agreement on updating the website  collaboratively.
In addition, although the Copyright Office only performs two of the above- mentioned IT activities, officials have recently expressed their intent to  make additional investments in IT that could be duplicative of activities  performed by ITS. In particular, the Copyright Office has requested  funding for its own software application development environment, as well  as a “digital repository” for deposits of works (e.g., films, books, music,  photographs, and software) for which copyright owners are asserting  ownership and seeking protection. However, ITS has a software  application development environment, and currently works with the  Copyright Office to maintain digital deposits.
Another consequence of potentially duplicative IT activities is that the  Library may be spending more than it needs to on IT-related staff. As  previously mentioned, the IT activities performed outside of OSI and ITS  are performed and led by the 134 IT staff that work for other service units.  In fiscal year 2014, the Library spent about $15 million on the salaries for  these staff. Table 9 identifies the amount that each service unit spent on  salaries for IT staff in fiscal year 2014.
As described in more detail below, officials from CRS and OSEP offered  various reasons for why they needed to manage much of their IT  independent of ITS, and the Copyright Office described reasons why the  structure used to manage its IT systems is not adequate.
According to the Director of CRS, CRS tries to leverage ITS resources  whenever possible, and the Director described the division between  ITS and CRS as a “division of labor.” However, the Director also  stated that CRS needs to maintain independence when managing its  IT because of its unique mission in support of Congress. In particular,  the Director stated that CRS must be able to (1) provide information to  Congress quickly and (2) keep its information confidential. Regarding  the timeliness of CRS’s responses to Congress, a senior advisor to  the CRS Director noted that CRS is directed by law to provide efficient  and effective service to Congress. With respect to confidentiality,  the Deputy Director of CRS told us that CRS considers its information  gathering to be covered under the “Speech or Debate Clause” of the  U.S. Constitution. Accordingly, that individual stressed the  importance of keeping CRS’s information confidential, and expressed  concern about storing CRS data with the rest of the Library’s data. To  this end, the Director of CRS stated that it must have separate IT  because its IT group has a better understanding of what CRS and  Congress need than ITS. A senior advisor to the CRS Director added  that CRS is directed by law to have “the maximum practicable  administrative independence” in performing its duties to Congress.  According to this individual, the division between ITS and CRS has  evolved over the years as a result of this administrative  independence.
Regarding OSEP, a senior electronic security engineer explained that  it maintains its systems independent of ITS because it has always  done so. In particular, that official stated that previous iterations of its  camera and physical intrusion detection systems were not integrated  with IT and, therefore, OSEP did not need the assistance of ITS. He  noted, however, that these systems are now integrated with IT. The  OSEP Director said the office is open to a solution that involves ITS  but that ITS had expressed a lack of knowledge of security systems.  The Director added that OSEP coordinated with ITS on a statement of  work for an assessment of staffing, technology improvements, and  best practices for its IT.
With respect to the Copyright Office, its General Counsel stated in a  memo prepared for GAO that the “current IT regime impedes the  Copyright Office’s ability to carry out its legal responsibilities.” Among  other things, the General Counsel stated that the existing Library IT  infrastructure cannot ensure the security or integrity of digital deposits.  For example, she explained that the Library has decided to host  Copyright IT systems in the same environment as other Library  systems, with the result that ITS staff—not Copyright Office staff—are  responsible for administering many of the security controls.  Additionally, the General Counsel stated that, despite the requirement  to be able to retain published works for 75 years and unpublished  works for the full term of the copyright, the Copyright Office’s eCO  system does not have the capability to validate the integrity of these  works. Further, the Library does not have any systems that are  capable of storing digital deposits for 75 years or more.
These concerns are understandable, given that service units were often  not satisfied with the services provided by ITS. Accordingly, service units  may believe that pursuing IT solutions and commodity IT independent of  ITS is their only viable alternative. Nevertheless, allowing service units to  do so likely increases costs and inefficiencies.
Our research on reducing duplicative IT investments in the executive  branch has found that through the Office of Management and Budget’s  PortfolioStat initiative—a process where agencies gather information on  their IT investments and develop plans for consolidation and increased  use of shared-service delivery models—agencies can avoid duplicative,  wasteful, and low-value investments. Congress also recently recognized  the value of these reviews when it required executive branch agencies to  complete them annually. However, the Library has not performed such  a review. Service units’ independent pursuit of IT activities presents an  opportunity for the Library to both explore the costs and benefits of the  existing duplicative or overlapping IT activities and identify areas for  consolidating or eliminating services where appropriate.
The individual who served as the Deputy Librarian from June 2012 until  December 2014 acknowledged that service units perform IT activities that  are duplicative of ITS. The former Deputy Librarian also noted that one of  the goals of the draft IT strategic plan that he led the development of was  to use shared services to collaboratively establish IT systems that meet  common requirements across organizations. The former Deputy Librarian  also described actions that he took to consolidate IT management during  his tenure:
Web Governance Board: According to the former Deputy Librarian,  in 2010, he established the Web Governance Board in order to ensure  that the Library’s web presence is coordinated across the service  units. The Deputy Librarian chaired this board from January 2010 until  December 2014. He added that, prior to the development of the  board, many of the service units developed their websites  independently. Additionally, the former Deputy Librarian stated that he  led the development of the Library’s web strategy, which identified  three core areas for transforming the Library’s web presence: (1)  Congress, (2) National Library, and (3) Copyright. However, as  previously mentioned, the Copyright Office updated its website in July  2014 independent of OSI’s Web Services division.
Geospatial information systems: The former Deputy Librarian told  us that the Law Library, CRS, and Library Services previously  pursued geospatial information system solutions independently.  However, he tasked these service units with collaboratively  implementing a geospatial hosting environment that will enable  Library of Congress staff and patrons, as well as Congress, to perform  research and analysis using geospatial datasets acquired by the  Library.
Mobile devices: According to the former Deputy Librarian, in the  past, service units independently acquired cell phones for managers.  He told us that in 2014, as part of a program to upgrade the Library’s  aging cell phones, he required the service units to acquire cell phones  using one contract.
Although these activities could improve coordination and thus reduce  overlap in IT activities throughout the Library, in the absence of a  PortfolioStat-type assessment of the costs and benefits of consolidating  IT activities, the service units will continue to spend money on IT that may  not constitute an efficient use of Library resources. Until such an  assessment is completed, the Library will not be able to justify whether its  IT spending provides the appropriate balance of meeting business needs  and saving taxpayer dollars.
section_title: Library Lacks Strong Leadership Needed to Address Its IT Management Weaknesses
paragraphs: Our research and experience at federal agencies indicates that agencies  should have a CIO with responsibility for managing their IT—including  commodity IT—and clearly define responsibilities between the CIO and  officials responsible for IT management at component organizations.  Congress has also recognized the need for strong CIOs, and recent  legislation has reaffirmed this by strengthening the CIO position in  executive branch agencies.
However, the Library does not have the leadership needed to address the  IT management weaknesses identified in this report. Specifically, the  Library’s CIO does not have adequate responsibility for the agency’s IT— in particular, authority over commodity IT and oversight of investments in  mission-specific systems made by other service units. Further,  responsibilities and authorities of the CIO and personnel responsible for  IT management at the service unit level have not been clearly defined.  These challenges have been exacerbated by the fact that the Library has  had five temporary CIOs since 2012 and by the recent reassignment of  the Deputy Librarian, who, in the absence of a CIO, had led a number of  IT efforts.
After we shared our preliminary results with the Library, the Librarian  announced plans to hire a permanent CIO and Deputy CIO. According to  the Chief of Staff, the Library plans to appoint these officials by  September 2015. While appointing a permanent CIO could potentially  address the Library’s gap in IT leadership, the details of this position have  yet to be fully defined. Until it establishes strong IT leadership, the Library  will continue to face difficulties in addressing its numerous IT  management weaknesses.
subsections: section_title: Library CIO Does Not Have Adequate Responsibility for Managing IT
paragraphs: According to our research and experience at federal agencies, leading  organizations adopt and use an enterprise-wide approach to managing IT  under the leadership of a CIO that includes the following:
Responsibility for commodity IT: The CIO should have the  responsibility and authority, including budgetary and spending control,  for commodity IT across the entity. Consolidating commodity IT under  a CIO can help to reduce duplicative services and make it easier for  an organization to effectively negotiate with vendors for volume  discounts and improved service levels. We have previously reported  that, according to CIOs, more control over component-level IT  funding, including commodity IT, could help ensure greater visibility  into and influence on the effective acquisition and use of IT.
Oversight of mission-specific systems: The CIO should have the  ability to adequately oversee mission-specific systems to ensure that  funds being spent on component agency investments will fulfill  mission needs. We previously reported on the importance of agency  CIOs having adequate oversight to ensure that funds being spent on  IT component agency investments, including mission-specific  systems, are aligned with the needs of the organization.
Clear relationships between CIO and components: The  responsibilities and authorities governing the relationships between  the CIO and component organizations should be defined. We have  previously reported that the effectiveness of agency CIOs depends in  large measure on having clear roles and authorities.
Congress has also recognized the importance of having a strong agency  CIO. In 1996, Congress passed the Clinger-Cohen Act, which established  the position of agency CIO for executive branch agencies and gave these  officials responsibility and accountability for IT investments, including IT  acquisitions, monitoring the performance of IT programs, and advising   the agency head whether to continue, modify, or terminate such  programs. information technology acquisition reforms, which required most  executive branch agencies to ensure that the CIO had a significant role in  the decision process for IT budgeting, as well as the management,  governance, and oversight processes related to IT. This legislation also  required that CIOs review and approve (1) all contracts for IT or IT  services prior to executing them and (2) the appointment of any other  employee with the title of CIO, or who functions in the capacity of a CIO,  for any component organization within the agency. Although these laws  are not applicable to the Library, they demonstrate that Congress  recognizes the importance of strong CIOs in federal agencies.
Clinger-Cohen Act of 1996, Pub. L. No. 104-106 (Feb. 10, 1996), §§ 5122 & 5125; 40  U.S.C. § 11315 and 44 U.S.C. § 3506(a).
Commodity IT: The Library’s CIO does not have responsibility for the  Library’s entire commodity IT even though a significant portion of the  Library’s IT funding is allocated and spent at the service unit level on  commodity IT systems. As previously mentioned, each service unit  has independently purchased commodity IT in the past 3 years, and,  in some cases, this has led to wasteful spending.
Mission-specific systems: The Library’s CIO does not have the  ability to adequately oversee mission-specific systems to ensure that  funds being spent on component agency investments will fulfill  mission needs. As previously mentioned, although the Library has  established elements of an investment management process, the  ITSC, which is to be chaired by the CIO, does not review all major IT  investments. Additionally, as noted previously, the former acting ITSC  chair told us that ITSC approvals do not affect decisions to allocate  funding for investments, as service units have already secured  funding for the investments before the selection process begins. Until  the Library gives its CIO adequate visibility into mission-specific  systems, there is increased risk that these investments will experience  significant cost and schedule overruns, with questionable mission- related achievements.
Relationships between CIO and component IT leadership: The  Library has not clearly defined the responsibilities and authorities  governing the relationships of the CIO and component organizations.  In particular, although each service unit performs IT management  activities to varying extents, the Library has not defined the  relationships between the CIO and those in the service units  responsible for those functions. Of particular concern is the lack of  defined relationships between the Library’s CIO and the other two CIO  positions that exist in the Library—one at the Copyright Office and the  other at CRS. Until the responsibilities and authorities governing the  relationships between the Library CIO and service unit IT leadership  are clearly defined, the Library CIO may not be able to effectively  manage and oversee component IT spending.
section_title: Library Has Had Five Temporary CIOs in the Past 2 Years, and Deputy Librarian Who Led IT Efforts Was Recently Reassigned
paragraphs: Compounding the lack of CIO authority, the Library has lacked consistent  leadership in this position. We have previously noted that one element  that influences the likely success of an agency CIO is the length of time  the individual in the position has to implement change. For example, in  our prior work on agency CIOs, we reported that CIOs and former agency  IT executives believed it was necessary for a CIO to stay in office for 3 to  5 years to be effective and 5 to 7 years to fully implement major change  initiatives in large public sector organizations.
However, since the departure of the most recent permanent CIO in 2012,  four individuals have served as acting CIO, and another was recently  appointed to serve in an interim capacity until a permanent CIO is found.  Upon the last permanent CIO’s departure in June 2012, the Deputy CIO  served as acting CIO until August 2013. Subsequently, three senior  officials within OSI took turns serving as CIO, with the first two serving in  that role for 4 months each, and the third from April 2014 to January  2015. The most recent former acting CIO noted that she was originally  only assigned to serve in the position for 4 months. However, her tenure  as acting CIO was extended twice: once in August 2014, when it was  extended until December 2014, and again in December 2014, when it  was extended until March 2015. Finally, in January 2015, a new interim  CIO was appointed when the Librarian detailed the Director of the Office  of Public Records and Repositories at the Copyright Office to that position  until a permanent CIO is appointed.
According to the official who served as Deputy Librarian from June 2012  until December 2014, he did not advocate for hiring a CIO during his  tenure for two reasons. First, he stated that the Library needed to develop  an IT strategic plan before appointing a permanent CIO in order to  provide that individual with priorities. Second, the former Deputy Librarian  explained that he did not want to hire a CIO to oversee, among other  things, the IT activities performed by CRS and the Copyright Office, when  he had not been empowered by the Librarian with the authority to  manage these offices’ IT activities.
In the absence of a CIO, the former Deputy Librarian managed many of  the Library’s recent IT efforts. For example, as previously mentioned, the  former Deputy Librarian (1) drafted an IT strategic plan, (2) chaired the  Web Governance Board, and (3) led the Library’s efforts to consolidate  mobile phone contracts and geospatial information systems.
However, in December 2014, the Librarian reassigned the individual  serving as Deputy Librarian to be a senior advisor to the Librarian.
Subsequently, in January 2015, the Librarian appointed the Law Librarian  to be the new Deputy Librarian.
After we shared the preliminary results of our review with the Library in  January 2015, the Librarian announced plans to hire a permanent CIO  and deputy CIO; according to the Chief of Staff, the Library plans to do so  by September 2015. While this search is conducted, the interim CIO will  be responsible for drafting the Library’s IT strategic plan, chairing the  Web Governance Board, and leading the Library’s efforts to consolidate  mobile phone contracts and geospatial information systems. Although  appointing a permanent CIO could potentially address the Library’s gap in  IT leadership, the details of this position have yet to be fully defined. If the  Library hires a permanent CIO with responsibility for IT, sufficient  authority, and clearly defined responsibilities, it will be better positioned to  effectively acquire, operate, and maintain its IT in support of its mission.
section_title: Conclusions
paragraphs: As information is increasingly created, shared, and preserved digitally,  effectively managing its IT resources will be even more critical for the  Library to carry out its mission of preserving and making available the  knowledge and creative output of the American people. To its credit,  although not required to do so, the Library has embraced standards and  practices set forth in laws that require executive branch agencies to  develop processes for investment management, information security, and  privacy. However, widespread weaknesses in implementing these  processes and several other IT management disciplines call into question  whether the Library is well positioned to meet the challenges of making  the most efficient and productive use of its technology resources. Just as  important, the Library’s lack of strong, consistent leadership in these  areas has hampered its ability to make needed improvements in the face  of long-standing challenges.
Specifically, without an up-to-date IT strategic plan that is linked to the  overall agency strategic plan and includes goals, performance measures,  strategies, and interdependencies among projects, the Library will lack a  clear definition of what it wants to accomplish with IT and strategies for  achieving those results. This challenge is compounded by the lack of a  complete and reliable enterprise architecture that accurately captures the  Library’s current IT environment, describes its target environment, and  outlines a strategy for transitioning from one to the other. Additionally, the  Library will be hindered in carrying out an IT strategy without an  organization-wide assessment of its human capital needs, and plans for  addressing any gaps.
Further impeding the Library’s ability to make strategic decisions is an  incompletely implemented process for managing the selection and  oversight of its IT investments. Specifically, the lack of clearly defined  roles and responsibilities and other gaps in policies have resulted in an  inconsistent approach to reviewing and selecting investments for the  Library’s portfolio. As a result, there is less assurance that proposed  investments are receiving adequate scrutiny and that the Library is  expending its resources on the appropriate mix of systems that will  effectively and efficiently meet its needs. Moreover, by not applying  adequate oversight to investments that have already been selected, the  Library is not in a position to ensure that they are meeting cost, schedule,  and performance goals and delivering the capabilities the agency needs  to carry out its mission. More basically, because the Library does not  have accurate data on what it spends on IT each year or an accurate  inventory of IT assets, it is limited in its ability to make informed  investment decisions or ensure that it does not waste money on IT.
Concerns about the Library’s ability to acquire IT systems that meet its  needs are further raised by the absence of organization-wide policies to  ensure that its systems acquisition process follows disciplined practices in  the areas of risk management, requirements development, cost  estimating, and schedule development. The lack of such policies has led  to the incomplete implementation of these practices among the  investments we reviewed. Without following such key practices, the  Library will be challenged in ensuring that systems are delivered on time  and within budget and that they deliver the capabilities needed by its  users.
Another significant area of concern is the Library’s inconsistent  implementation of agency-wide information security and privacy  programs. While, to its credit, the Library has established roles and  responsibilities and policies and procedures for information security and  privacy, significant weaknesses in implementing key security  management controls call into serious question whether the information  and systems at the Library are being adequately protected. These  weaknesses, in areas such as documenting security controls, conducting  security testing, developing remedial action plans, establishing  contingency plans, carrying out security training, ensuring that contracts  address security requirements, and assessing risks to privacy, could  provide opportunities for either intentional or inadvertent compromise of  the Library’s systems, resulting in unauthorized access, modification, or  loss of sensitive information, or disruption to the Library’s operations.  These issues are further highlighted by a number of weaknesses we  found in technical security controls that are intended to limit unauthorized  access to the Library’s systems and ensure their integrity.
While ITS—as the central IT organization within the Library—is  responsible for providing IT-related services to the Library’s other units,  the lack of satisfaction with these services has contributed to the other  units pursuing their own IT activities, potentially resulting in duplicative  investments and wasted resources. Although the reasons units provided  for managing much of their IT independently are understandable given  inconsistent satisfaction with the services provided by ITS, allowing  service units to do so likely increases costs and inefficiencies. Without a  plan for improving the units’ satisfaction with ITS services and an  organization-wide evaluation of the costs and benefits of the Library’s  fragmented approach to carrying out IT activities, the agency may be  missing opportunities to eliminate duplication, improve the efficiency of its  delivery of IT services, and save taxpayer dollars.
Key to all these shortcomings, the Library has lacked consistent, effective  leadership for its IT efforts. Because the Library’s CIO position lacks  adequate authority and oversight, the agency has diminished assurance  that investments in IT are being coordinated organization-wide and that  they provide an appropriate mix of capabilities that support the Library’s  mission while avoiding unnecessary duplication.
The Library’s intention to appoint a permanent CIO is a positive  development, but it will be important to clearly define this position and  ensure that this official has sufficient authority to address the many  challenges facing the Library’s IT management. If it follows through on  plans to appoint such an official and invests the position with the  appropriate authority, the Library will be in a stronger position to address  the IT management challenges we have identified and make a more  effective and efficient use of technology to support its mission.
section_title: Recommendations
paragraphs: To provide stable, consistent, and effective leadership for addressing the  weaknesses identified in this report, as well as for improving the  organization’s management of IT, we recommend that the Librarian  expeditiously hire a permanent chief information officer responsible for  managing the Library’s IT and ensure that this official has clearly defined  responsibilities and adequate authority, consistent with the role of a chief  information officer as defined by best practices. This should include,  among other things, (1) responsibility for commodity IT; (2) oversight of  mission-specific systems, through the ITSC or another oversight  mechanism; and (3) clarification of responsibilities and authorities  between the Library CIO and service unit IT leadership.
To provide strategic direction for the Library’s use of its IT resources, we  recommend that the Librarian of Congress take the following 3 actions:
Complete an IT strategic plan within the time frame the Library has  established for doing so. The plan, at a minimum, should (1) align with  the agency’s overall strategic plan, (2) provide results-oriented goals  and performance measures, (3) identify the strategies for achieving  the desired results, and (4) describe interdependencies among  projects.
Establish a time frame for developing a complete and reliable  enterprise architecture that accurately captures the Library’s current  IT environment, describes its target environment, and outlines a  strategy for transitioning from one to the other, and develop the  architecture within the established time frame.
Establish a time frame for implementing a Library-wide assessment of  IT human capital needs and complete the assessment within the  established time frame. This assessment should, at a minimum,  analyze any gaps between current skills and future needs, and  include a strategy for closing any identified gaps.
To provide a framework for effective IT investment management and  ensure that the Library has accurate information to support its decisions,  we recommend that the Librarian take the following 10 actions:
Clarify investment management policy to identify which governance  bodies are responsible for making investment decisions, and under  what conditions.
Establish and implement a process for linking IT strategic planning,  enterprise architecture, and IT investment management.
Establish and implement policies and procedures for reselecting  investments that are already operational.
Establish and implement policies and procedures for ensuring that  investment selection decisions have an impact on decisions to fund  investments.
Ensure that appropriate governance bodies review all investments  that meet defined criteria.
Require investments in development to submit complete investment  data (i.e., cost and schedule variances and risk management data) in  quarterly reports submitted to the ITSC.
Fully establish and implement policies, to include guidance for service  units on classifying expenditures as IT, for maintaining a full  accounting of the Library’s IT-related expenditures.
Fully establish and implement policies for developing a  comprehensive inventory of IT assets.
Implement policies and procedures for conducting post- implementation reviews of investments.
Fully establish and implement policies and procedures consistent with  the key practices on portfolio management, including (1) defining the  portfolio criteria, (2) creating the portfolio, and (3) evaluating the  portfolio.
To effectively plan and manage its acquisitions of IT systems and  increase the likelihood of delivering promised system capabilities on time  and within budget, we recommend that the Librarian take the following 4  actions:
Complete and implement an organization-wide policy for risk  management that includes key practices as discussed in this report,  and within the time frame the Library established for doing so.
Establish and implement an organization-wide policy for requirements  development that includes key practices as discussed in this report.
Establish and implement an organization-wide policy for developing  cost estimates that includes key practices as discussed in this report.
Establish a time frame for finalizing and implementing an  organization-wide policy for developing and maintaining project  schedules that includes key practices as discussed in this report, and  finalize and implement the policy within the established time frame.
To better protect IT systems and reduce the risk that the information they  contain will be compromised, we recommend that the Librarian take the  following 10 actions:
Develop a complete and accurate inventory of the agency’s  information systems.
Revise information security policy to require system security plans to  describe common controls, and implement the policy.
Ensure that all system security plans are complete, including  descriptions of how security controls are implemented and  justifications for why controls are not applied.
Conduct comprehensive and effective security testing for all systems  within the time frames called for by Library policy, to include  assessing security controls that are inherited from the Library’s  information security program.
Ensure that remedial action plans for identified security weaknesses  are consistently documented, tracked, and completed in a timely  manner.
Finalize and implement guidance on continuous monitoring to ensure  that officials are informed when making authorization decisions about  the risks associated with the operations of the Library’s systems.
Develop contingency plans for all systems that address key elements.
Establish and implement a process for comprehensively identifying  and tracking whether all personnel with access to Library systems  have taken required security and privacy training.
Establish a time frame for finalizing and implementing the Library’s  standard contract sections for information security and privacy  requirements, and finalize and implement the requirements within that  time frame.
Require the chief privacy officer to establish and implement a process  for reviewing the Library’s privacy program, to include ensuring that  privacy impact assessments are conducted for all information  systems.
To help ensure that services provided by ITS meet the needs of the  Library’s service units, we recommend that the Librarian take the  following 2 actions:
Finalize and implement a Library-wide policy for developing service- level agreements that (1) includes service-level targets for  agreements with individual service units and (2) covers services in a  way that best meets the need of both ITS and its customers, including  individual service units.
Document and execute a plan for improving customer satisfaction with  ITS services that includes prioritized improvement projects and  associated resource requirements, schedules, and measurable goals  and outcomes.
In addition, to help ensure an efficient and effective allocation of the  agency’s IT resources, we recommend that the Librarian take the  following action:
Conduct a review of the Library’s IT portfolio to identify duplicative or  overlapping activities and investments, including those identified in  our report, and assess the costs and benefits of consolidating  identified IT activities and investments.
In a subsequent report with limited distribution, we will also be making a  number of recommendations to address weaknesses we identified in  technical security controls at the Library.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this product to the Library of Congress for  comment. In his written comments, reproduced in appendix II, the  Librarian stated that he generally concurred with our recommendations. In  this regard, he described ongoing and planned actions to address them,  and provided milestones for completing these actions. If effectively  implemented, these actions should help address the weaknesses we  identified. The Library also provided technical comments that were  incorporated, as appropriate.
We are sending copies of this report to the appropriate congressional  committees, the Librarian of Congress, and other interested parties. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-6253 or willemssenj@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 key contributions to this  report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The House Appropriations Committee report accompanying the fiscal  year 2015 legislative branch appropriations bill required GAO to review  the Library of Congress’s management of information technology (IT).  Our specific objectives for this review were to assess the extent to which  the Library of Congress (1) addressed in its strategic planning the IT and  related resources required to meet its goals and objectives; (2)  established an IT governance structure to manage the selection, control,  and evaluation of IT investments; (3) used IT acquisition and  development best practices; (4) established programs for ensuring the  information security and privacy protection of its information and  information systems; (5) used best practices for managing IT services;  and (6) has a chief information officer (CIO) with authority to exercise  control and oversight of IT management functions.
To address our first objective, we reviewed the agency’s overall strategic  plan, and evaluated its draft IT-specific strategic plan against key  practices for IT strategic planning that we have previously identified.Those best practices include developing an IT strategic plan that aligns with the agency’s overall strategic plan, provides results-oriented goals and performance measures that describes interdependencies within and across projects so that these  permit it to determine whether it is succeeding,  identifies the strategies it will use to achieve desired results, and  can be understood and managed.
Additionally, because an enterprise architecture can help an organization  determine how it can most effectively execute its IT strategic plan, we  evaluated the agency’s enterprise architecture documentation against key  practices identified in our enterprise architecture framework to determine  the extent to which the Library had established a well-defined enterprise  architecture, as well as demonstrated institutional commitment to its  architecture. Those practices include developing an architecture that thoroughly describes the current and  target states of an organization’s IT systems and business operations  and identifies the gaps and specific intermediary steps that the  organization plans to take to achieve its target state; developing an organizational policy for enterprise architecture; and establishing an executive committee representing the enterprise that  is responsible and accountable for enterprise architecture.
Further, because of the importance of sustaining an IT workforce with the  necessary skills to execute an agency’s strategic plan, we obtained and  reviewed the Library’s human capital plan. We compared this plan to  best practices we have identified in human capital management. Those  practices include analyzing the gaps between current skills and future needs and developing strategies for filling the gaps.
We also interviewed the enterprise architect, architecture review board  chair, Director of the Information Technology Services (ITS) directorate,  former acting Chief Information Officer (CIO), former Deputy Librarian,  and Librarian of Congress to obtain information about the Library’s IT  strategic planning activities.
In addressing our second objective, we compared agency documentation  against critical processes associated with Stages 2 and 3 of GAO’s  information technology investment management framework.the framework includes the following key processes:  instituting the investment board, providing investment oversight, and capturing investment information.  selecting investments that meet business needs,Stage 3 includes the following critical processes: defining the portfolio criteria, creating the portfolio, evaluating the portfolio, and conducting post-implementation reviews.
Specifically, we reviewed written policies, procedures, guidance, and  other documentation that provided evidence of establishing commitment  to critical processes, such as Library of Congress Regulation 1600:  Information Resource Management Policy and Responsibilities; the  Library of Congress Information Resource Management Plan; the IT  Steering Committee charter; and guidance and templates for the selection  process, development stage oversight, and the post-implementation  review process. We also reviewed IT Steering Committee meeting  minutes to determine whether the committee was successfully  implementing its documented policies and procedures, as well as for  evidence of its decision-making processes. In addition, we reviewed data  from the system used by Integrated Support Services to track and  manage the Library’s assets, including those relating to IT.
Additionally, we selected three investments as case studies to determine  the extent to which key activities associated with the critical processes  were being carried out. To choose these investments, we identified the 16  investments that the IT Steering Committee was overseeing or  considering for review as of July 2014. To narrow this list, we excluded  investments that (1) were in the planning stages, (2) had been completed,  or (3) would be fully deployed prior to the completion of our review. We  then selected the one investment that was managed by more than one  service unit: Library Services and the Office of Strategic Initiatives’ (OSI)  Twitter Research Access investment. We then selected two investments  sponsored by service units other than Library Services and OSI to ensure  coverage of other service units. These additional two investments were  the Office of Support Operations’ (OSO) Facility Asset Management  Enterprise (FAME) investment and the Office of the Librarian’s  Momentum Upgrade and Migration investment.
For these three investments, we reviewed evidence of the implementation  of project-level IT investment management processes, including  investment concept proposals, investment charters, development stage  quarterly reports, budget plans, and an IT Steering Committee scoring  worksheet that evaluated risk factors along with the significance of  potential benefits. Further, we conducted interviews with officials  responsible for managing the selected investments, including the  Library’s investment management portfolio officer, former acting IT  Steering Committee chair, and former acting CIO.
We did not assess progress in establishing the capabilities found in  Stages 4 and 5 because the Library has not yet implemented Stage 3  processes.
In addition, because the Library had not established and implemented a  process for tracking IT spending, we developed an estimate of how much  it spent on IT during fiscal year 2014 using data from the Library’s  accounting and human resources systems. With respect to IT equipment  and services captured in the Library’s accounting system, we identified  budget object class codes (i.e., codes used by the Library to classify  spending) associated with IT. To do so, we performed the following three  steps:
First, we asked the Office of the Chief Financial Officer to identify  budget object classification codes that, based on the executive  branch definition of IT, were associated with IT. The Library  identified 16 codes associated with IT.
Second, we identified budget object classification codes that are  consistent with the Technical Reference Model in OMB’s Federal  Enterprise Architecture Reference Model.26 codes.
Third, we shared the additional 26 budget object classification codes  with the Library Office of the Chief Financial Officer, the National  Library Service for the Blind and Physically Handicapped (NLS), and  ITS to review, comment, and provide additional information. Based on  their comments, we removed 16 codes from our review and added 1  code.
As a result, we identified 27 budget object classification codes that were  associated with IT, 4 of which were associated with both IT and non-IT  spending. We then asked the Library to provide us with detailed  information for all obligations it made in fiscal year 2014 that were  associated with these codes. For the 4 codes that were used to classify  both IT and non-IT spending, we identified the obligations classified under  these codes that were greater than $2,500. For these selected  obligations, we asked the service units to identify, based on the executive  branch definition of IT, obligations associated with IT. We then added  these obligations to those associated with the other 23 codes to complete  our estimate of the Library’s IT equipment and services.
Regarding the data in the Library’s human resource system, we obtained  from the Library’s Human Resources division (1) the number of Library  staff employed under IT-related job series during fiscal year 2014 and (2)  the salary information, in aggregate form, for those employees during that  fiscal year. We then added this information to our estimate of the Library’s  IT equipment and services. We used this combined figure as our estimate  of the Library’s IT spending for fiscal year 2014. We then shared our  estimate with each service unit to review, comment, and provide  additional information.
To determine the reliability of the IT spending data, we reviewed Office of  the Chief Financial Officer documentation and previous Office of the  Inspector General Reports on the Library’s financial statements, and  interviewed Office of the Chief Financial Officer officials familiar with the  financial system to understand the controls used on to create and classify  obligations. We determined that the data were sufficiently reliable for our  purpose, which was to provide an estimate of the Library’s IT spending;  however, the estimate does not reflect all of the Library’s IT spending. For  example, the Library has not defined IT and has not fully established  guidance on how to classify IT expenses in its financial accounting  system, Momentum. Although Library guidance identifies 5 budget object  classification codes as being associated with IT, as noted, we identified  additional codes that are used for IT transactions. Additionally, the Library  did not ensure that all IT-related transactions were properly associated  with IT-related codes. For example, OSI associated about $2.5 million of  its IT budget with a code that, according to Library guidance, excludes IT  spending.
Further, as discussed previously, our estimate does not reflect obligations  of $2,500 or less that are associated with 4 budget object classification  codes for which the Library made both IT and non-IT obligations. In  addition, our estimate does not include salary information for all staff that  perform key IT activities. In response to our request for the salary  information for all staff whose primary job responsibility is IT, the  Assistant Director of Human Resources Services provided information on  employees whose job title related to the information technology  management series (2210). However, a Copyright budget analyst and the  Library’s Chief Financial Officer stated that the Library has employees  that perform key IT activities, but whose job titles fall outside of the  information technology management series.
To determine the reliability of the cost estimates for the investments  reviewed by the Library’s IT Steering Committee, we (1) performed  testing for obvious errors in accuracy and completeness, and (2)  interviewed officials knowledgeable about the template used to produce  the estimates. Additionally, as discussed in more detail below, we also  assessed the extent to which the estimates were created using leading  practices consistent with a comprehensive estimate, as identified in  GAO’s Cost Estimating and Assessment Guide. However, none of the  investments’ estimates fully met the comprehensive characteristic.  Despite this limitation, we believe that the cost data are sufficiently  reliable for our purpose—that is, as an indicator of the general range of  the portion of the Library’s IT spending that is reviewed by the ITSC.
To address the third objective, we compared Library policies and  procedures in key IT acquisition management areas—risk management,  requirements development, cost estimating, and scheduling—to leading  practices identified by industry and GAO. We also determined the extent  to which the three selected investments identified above were  implementing these key IT acquisition practices. Specifically, with respect  to risk management and requirements development, we reviewed policies  and procedures developed by ITS, as well as acquisition documentation  from the three selected investments, and compared them to risk  management and requirements development best practices identified by  the Software Engineering Institute’s (SEI) Capability Maturity Model®  Integration for Acquisition (CMMI-ACQ).
The key risk management practices were developing a risk management strategy; identifying and documenting risks; evaluating, categorizing, and prioritizing risks; developing risk mitigation plans; and monitoring the status of each risk periodically, and implementing the  risk mitigation plans as appropriate.
The key requirements development practices were eliciting stakeholder needs, developing customer requirements, and prioritizing customer requirements.
We analyzed investment risk documentation, including risks identified in  investment charters, acquisition plans, and risk registers; risk mitigation  plans; and quarterly performance reports submitted to the IT Steering  Committee. Additionally, we assessed investment requirements  development documentation, such as requirements obtained from  customers and other stakeholders, and a system gap analysis. Further,  we interviewed officials responsible for managing the investments to  obtain additional information about their risks, requirements, and  practices for managing them. We shared our analysis with Library officials  to review, comment, and provide additional information, and we adjusted  our analysis where appropriate.
With regard to cost estimating, we reviewed policies and procedures  developed by ITS, as well as cost estimating documentation from the  three selected investments, and compared them to leading practices set   This guide  forth in GAO’s Cost Estimating and Assessment Guide.identifies 12 leading practices that represent work across the federal  government and are the basis for a high-quality, reliable cost estimate. An  estimate created using the leading practices exhibits four broad  characteristics: it is accurate, well documented, credible, and  comprehensive. Each of these characteristics is associated with a specific  set of leading practices, which in turn are made up of a number of specific  tasks. We assessed ITS’s guidance against each of the four  characteristics. Each characteristic was assessed as either being fully  met—the Library provided complete evidence that satisfies the associated  tasks of the leading practices; substantially met—the Library provided  evidence that satisfies a large portion of the associated tasks of the  leading practices; partially met—the Library provided evidence that  satisfies about half of the associated tasks of the leading practices;  minimally met—the Library provided evidence that satisfies a small  portion of the associated tasks of the leading practices; or not met—the  Library did not provide evidence that satisfies any of the associated tasks  of the leading practices.
In assessing the reliability of the estimates developed by the three  selected investments, we only assessed practices associated with the  comprehensive characteristic. We did so because none of the  investments’ estimates fully met the comprehensive characteristic, and  this characteristic must be completed in order for the estimate to fully  address the other three characteristics. We assessed these estimates  using the same scoring methodology (i.e., fully met, substantially met,  partially met, minimally met, and not met) as described above for the  review of ITS’s cost estimating policies and procedures. We shared our  analysis with Library officials to review, comment, and provide additional  information.
Finally, regarding our assessment of the Library’s scheduling, we  reviewed policies and procedures developed by ITS, as well as  scheduling documentation from the selected investments, and compared  them to leading practices set forth in the exposure draft of GAO’s   This guide defines 10 leading practices  Schedule Assessment Guide.that are vital to having integrated and reliable master schedules. Similar  to a well-developed cost estimate, a schedule created using the leading  practices exhibits four broad characteristics: it is comprehensive, well- constructed, credible, and controlled. Each characteristic is associated  with a specific set of leading practices, which, in turn, are made up of a  number of specific tasks. We assessed ITS’s guidance against each of  the four characteristics.
In assessing the reliability of the schedules developed by the selected  investments, we only assessed practices associated with the well-  constructed characteristic. We did so because none of the schedules  substantially addressed the practices associated with this characteristic,  and because this characteristic relates to the foundational practices for a  high-quality, reliable schedule. We assessed ITS’s policies and  procedures, as well as the investment schedules using the same  methodology (i.e., fully met, substantially met, partially met, minimally  met, and not met) as previously described for our assessment of ITS’s  cost estimating policies and procedures. We shared our analysis with  Library officials to review, comment, and provide additional information,  and we adjusted our analysis where appropriate.
To address our fourth objective, we reviewed relevant information security  and privacy laws and guidance, including National Institute of Standards  and Technology (NIST) standards and guidance, to identify federal  security and privacy control guidelines. We then reviewed the Library’s  security and privacy policies and procedures to determine their  consistency with these guidelines.
Additionally, we selected nine Library systems as case studies to  determine the extent to which NIST guidelines and Library policy were  being implemented. We chose these systems by following these six  steps:
First, using lists of systems developed by the Chief Information  Security Officer (CISO), the Copyright Office, and Library Services as  the basis for our selected systems, we separated the systems into  eight groups—each of the seven service units, as well as NLS. With  two exceptions—Law Library and OSI (both of which are discussed  later in this section)—we only selected one system from each group.
Second, in order to narrow the list of systems, we excluded those with  a “low” Federal Information Processing Standards (FIPS) 199  impact level. Because the Law Library only had one system, which  was labeled as having a “low” FIPS 199 impact level, we did not  select any systems from this service unit.
Third, we selected the Library’s “tier 0 systems”—that is, general  support systems use to support critical IT systems that need to be  restored before any other systems in the event of a disaster. The  three tier 0 systems are the ITS Application Hosting Environment, ITS  Library of Congress Data Network, and ITS Library of Congress Office  Automation System.
Fourth, we identified the Library’s other general support systems and  selected the Congressional Research Service’s (CRS) general  support system that also processes personally identifiable  information—the Enterprise Infrastructure General Support System— as well as the Office of Security and Emergency Preparedness  (OSEP) general support system that is classified as having a “high”  FIPS 199 impact level—the OSEP Physical Security Network.
Fifth, for groups without an associated system, we identified the  Library’s “tier 1” systems (i.e., systems that are to be restored within  24 hours in the event of a disaster). We identified four systems:  Copyright’s eCO system, the Office of the Librarian’s Momentum  system, Library Services’ Federal Library and Information Network  (FEDLINK) Customer Account Management System, and Library  Services’ System Management Information network (SYMIN) II. From  these, we selected Copyright’s eCO system and the Office of the  Librarian’s Momentum system. For Library Services, we randomly  selected SYMIN II from the two systems.
Finally, because NLS did not have any general support systems or tier  1 systems, we identified NLS systems with a moderate FIPS 199  impact level and randomly selected the NLS Production Information  Control System/NLS Integrated Operations Support System  (PICS/NIOSS).
In summary, this selection process resulted in the following nine systems:
CRS Enterprise Infrastructure General Support System,
OSEP Physical Security Network, eCO,
OFCO Momentum,
SYMIN II, and
PICS/NIOSS.
ITS Application Hosting Environment,  ITS Library of Congress Data Network,  ITS Library of Congress Office Automation System,  Using NIST guidelines for an effective agency-wide information security  program, we evaluated the Library’s information security program in the  following areas:  Incident handling: We compared the Library’s incident handling  procedures to NIST guidance on the key steps that agencies should  take when responding to incidents. To determine the effectiveness  of the Library’s response to incidents, we selected 22 incidents to  review as case studies. To choose the incidents, we obtained a list of  all incidents reported between October 1, 2013, and September 2,  2014. In order to narrow the list of incidents, we removed (1) incidents  for which the Library determined that the incident did not require  investigation or was a false positive and (2) incidents with a status of  open or canceled. We then separated the remaining incidents into  eight groups—each of the categories that the Library uses to classify  incidents. With the exception of one category—recon activity—we  randomly selected 3 incidents from each category. For the recon  category, we selected its 1 incident for our review. For these selected  incidents, we reviewed documents from the Library’s incident tracking  system to determine the extent to which the Library had performed  analysis, containment, eradication, recovery, reporting, and post- incident procedures in accordance with NIST guidance. To verify the  reliability of the data in the agency’s incident handling system, we  examined it for obvious outliers, omissions, and errors. We  determined that these data were sufficient for our purposes, which  was to select incidents to use as case studies and determine the  extent to which the Library handled those incidents consistent with  NIST guidance.
Inventory of systems: We assessed the Library’s policy for its  system inventory against relevant NIST guidelines.comprehensiveness and accuracy of the Library’s system inventory,  we compared the inventory provided to us by the Library’s CISO with  a separate list provided by Library Services. We also asked the CISO  and officials from each service unit to verify the accuracy and  completeness of these lists. Although we determined the inventory  was not complete and accurate, we believe that the system lists  collectively, with lists of tier 0, tier 1, and general support systems, are  sufficiently reliable for our purpose—that is, to select systems as case  studies for our review.
System security plans: We compared Library policy on system  security plans with relevant NIST guidance.assessed system security plans for the nine selected systems against  the NIST guidelines.
Security test and evaluation: We assessed Library policy on  security testing against relevant NIST guidelines.compared testing documentation for the nine selected systems  against the NIST guidance and Library policy.
Remedial action plans: We compared Library policy on plans of  action and milestones (POA&M) with relevant NIST guidance.Additionally, we reviewed POA&Ms for the nine selected systems and,  for eight of the systems, identified the number of POA&M items that  were delayed, as of December 2014. Regarding the OSEP Physical  Security Network, OSEP had not reported any updates to its POA&M  items since September 2013; we identified the number of items that  were open as of that date, when the items were originally reported. To  verify the reliability of the agency’s POA&M data, we examined them  for obvious outliers and errors. Excluding the data for the OSEP  Physical Security Network, which had not been updated since  September 2013, we determined that the POA&M data were sufficient  for our purpose, which was to identify the number of items with a  status of “delayed.”
Authorization to operate: We assessed Library policy on   We also  authorization to operate against relevant NIST guidelines.assessed the extent to which the Library completed authorizations to  operate for the nine selected systems. In instances where the  authorizations had not been completed, we interviewed Library  officials responsible for the systems and, where relevant, reviewed  documentation in which the Library, for a defined period of time,  waived the requirement to authorize the system to operate.
Contingency planning: We compared Library policy on contingency  planning with relevant NIST guidance. In addition, we determined  the extent to which the Library developed contingency plans for the  nine selected systems, as called for by NIST guidance and Library  policy.
Security and privacy awareness training: We assessed Library  policy on security and privacy training against relevant NIST  guidance. Additionally, we obtained the lists of users identified in  three systems: ITS Library of Congress Office Automation System,  CRS Enterprise Infrastructure General Support System, and OSEP  Physical Security Network. We did so because these were the three  systems in our sample for which the Library maintains instances of the  Library’s primary service for authenticating and authorizing users. We  then compared these lists with the list of users the Library reported as  having completed the security and privacy awareness training in fiscal  year 2014. We shared our analysis with Library officials to review,  comment, and provide additional information.
Contract requirements for information security: We compared  Library policy on contract requirements for information security with  relevant NIST guidance.which the contracts supporting the nine selected systems included the  contract requirements called for by Library policy and NIST guidance.
In addition, we determined the extent to  To evaluate the Library’s controls over its information systems, we used  our Federal Information System Controls Audit Manual, which contains  guidance for reviewing information system controls that affect the  confidentiality, integrity, and availability of computerized information. We  also used NIST standards and guidelinesprocedures, practices, and standards. Specifically, we reviewed controls  in the following areas:
Authorization: For all users with elevated privileges to the selected  nine systems, we reviewed the extent to which those users had been  authorized to use the system with those elevated permissions,  consistent with NIST guidance.
Identification and authentication: With respect to the selected  systems, we assessed controls used to authenticate and authorize  users against NIST guidance.
Cryptography: We observed configurations for providing secure data  transmissions across the network to determine whether sensitive data  were being encrypted consistent with NIST guidance.
Background investigations: We identified all users with elevated  privileges to the selected nine systems and then asked the Library’s  personnel security officer whether the Library had performed a  background investigation for each, consistent with NIST guidanceand Library policy.
Physical security and environmental safety: We identified four  Library facilities in the United States that include an IT data center: (1)  the James Madison Building on Capitol Hill; (2) the NLS facility in  northwest Washington, D.C.; (3) the Packard Campus of the National  Audio-Visual Conservation Center in Culpepper, Virginia; and (4) the  Library’s alternate computing facility in Manassas, Virginia. We visited  each of these facilities and assessed the physical security and  environmental controls supporting their data centers against relevant  NIST guidance. Additionally, because the Library did not have an  accurate inventory of its non-capitalized IT assets, we also visited the  Library’s warehouse in Landover, Maryland, and assessed the  physical security and environmental controls supporting this facility.
To address our fifth objective, we evaluated ITS’s service management  documentation against leading industry practices for managing IT services identified in the Information Technology Infrastructure Library. We evaluated the service management practices of ITS, which functions  as the Library’s central IT organization and is the primary provider to each  service unit throughout the Library. The service management practices  were developing a service catalog; defining how service-level agreements (SLA) should be structured so  that IT services and customers are covered in a manner best suited to  the organization’s needs; and establishing SLAs consistent with that structure that describe the IT  services, specify roles and responsibilities of both parties, and  document service level targets.
Specifically, we reviewed ITS’s service catalog and SLAs between ITS  and its customers. We also we conducted interviews with officials  responsible for managing ITS’s services, including the Director of ITS,  and the ITS Assistant Director for Operations.
Lou Hunnebeck and Colin Rudd, ITIL: Service Design © (London: The Stationary Office,  2011). The guide is available at: http://www.axelos.com/Publications-Library/IT-Service- Management-ITIL/.
IDEALSM—namely, establishing a written plan that serves as the basis for  guiding its improvement activities. Because the Library did not have  comprehensive metrics for the satisfaction with ITS’s services, we  conducted a web-based survey of ITS customers. We designed a draft  questionnaire in close collaboration with our survey specialist. We also  conducted pretests with four officials: one official representing the largest  service unit (Library Services), one official representing the smallest  service unit (Law Library), the Director of ITS, and the former acting CIO.  From these pretests, we made revisions as necessary to reduce the  likelihood of overall and item non-response as well as reporting errors on  our questions.
We sent the survey via e-mail to the head of each service unit, as well as  the head of NLS, on October 15, 2014. Log-in information was e-mailed  to all contacts. We e-mailed those who had not completed the  questionnaire at multiple points during the data collection period, and we  closed the survey on November 3, 2014. We received a completed  questionnaire from each service unit and NLS.
Because we surveyed all of the unit heads and therefore did not conduct  any sampling for our survey, our data are not subject to sampling errors.  However, the practical difficulties of conducting any survey may introduce  non-sampling errors. For example, differences in how a particular  question is interpreted, the sources of information available to  respondents, or the types of people who do not respond to a question can  introduce errors into the survey results. We included steps in both the  data collection and data analysis stages to minimize such non-sampling  errors. Our analysts answered respondent questions and resolved  difficulties that respondents had in completing our survey. Although the  survey responses cannot be used to generalize the opinions and  satisfaction of all customers that receive services from ITS, the responses  provide data for our defined population.
The final questionnaire asked the heads of the service units and NLS to  identify the extent to which they are satisfied or dissatisfied with the  services provided by ITS.providing satisfactory IT services to its customers, we described the  results on a 5-point satisfaction scale, where 5 is “very satisfied” and 1 is  “very dissatisfied.”
To determine the extent to which ITS is  To obtain additional narrative and supporting context from stakeholders,  survey respondents were given multiple opportunities to provide  additional open-ended comments throughout our survey. Using these  open-ended responses, we conducted a content analysis in order to  identify common factors. We then totaled the number of times each factor  was mentioned by a respondent, choosing to report on the factors that  were identified by two or more respondents.
Further, in order to determine the extent to which service units performed  duplicative or overlapping IT activities, we sent a structured questionnaire  to each service unit, as well as NLS.respondent to identify the extent to which they (1) purchased commodity  IT in the past 3 years; (2) performed significant IT activities, as defined by  the Information Technology Infrastructure Library; and (3) performed IT  service desk functions. We also reviewed network diagrams and system  security plans for the nine systems we selected as part of our fourth  objective.
In addition, we reviewed portions of the Library’s hardware and software  inventories to determine if it had made duplicative IT investments in  selected areas:
Monitors: Because the Library did not have an accurate inventory of  its non-capitalized IT assets, we visited the Library’s warehouse in  Landover, Maryland, and reviewed the facility’s physical and  environmental controls. At that facility, we observed that ITS had  approximately 400 19-inch monitors purchased in 2008 and about 100  24-inch monitors that were purchased in 2010. Although these  monitors were several years old, according to ITS officials, they had  never been used and were still in their original packaging. In order to  determine whether service units purchased duplicative monitors, we  asked each service unit, but not including OSI, to provide an inventory  of its monitors. We received inventories from NLS, the Law Library,  and Library Services. We then identified 19-inch and 24-inch  monitors in these inventories (1) that were of a different model  number than those purchased by ITS and (2) for which their  respective manuals were copyrighted later than 2008 for the 19-inch  monitors and later than 2010 for the 24-inch monitors.
Software licenses: We identified software applications that were  purchased by more than one service unit and determined the extent to  which the Library purchased too many or too few licenses. To select  the applications, we used the software inventories developed by ITS  and CRS with automated tools for deploying software to workstations  that they manage. First, for the ITS inventory, we identified  applications that were deployed to two or more service units. Second,  in order to ensure that we only selected software purchased by the  Library, we removed any applications that were published by the  Library itself. Third, using an open source search, we removed  applications that can be legally obtained for free. Fourth, we removed  applications that were being used for entities outside of the Library.  Fifth, we eliminated purchases made by the Library’s Inspector  General. Based on these steps, we identified 24 applications. We then  compared these 24 applications to CRS’s application inventory to  determine whether CRS purchased any of these applications. For  these 24 applications, we obtained the relevant license agreements,  and compared the number of licenses purchased to the number of  licenses deployed throughout the Library. We chose to report on  applications where the Library purchased at least 100 more licenses  than it had deployed. To verify the reliability of the data on the number  of deployed licenses, we examined it for obvious outliers, omissions,  and errors, and interviewed officials familiar with the data to gain an  understanding of the controls used to create and maintain the data.  We determined that these data were sufficient for our purposes, which  was to describe the number of Microsoft Visio 2010 Professional  licenses the Library deployed.
We discussed the duplicative IT activities and investments with officials  responsible for managing IT in CRS, the Copyright Office, Library  Services, and OSEP.
To address our sixth objective, we evaluated the Library’s IT policies and  the position description of the Library’s CIO against key practices we  identified based on our research on and experience with federal  agencies. These practices related to the following areas:
Commodity IT: The CIO should have the responsibility and authority,  including budgetary and spending control, for commodity IT.
Mission-specific systems: The CIO should have the ability to  adequately oversee mission-specific systems to ensure that funds  being spent on component agency investments will fulfill mission  needs.
Relationships between CIO and components: The responsibilities  and authorities governing the relationship between the CIO and  component organizations should be defined.
We also compared the tenure of the Library’s recent CIOs to results from  our research which found that CIOs and former agency IT executives  believed it was necessary for a CIO to stay in office for 3 to 5 years to be  effective and 5 to 7 years to fully implement major change initiatives in  large public-sector organizations. Further, we interviewed the Chief of  Staff, former Deputy Librarian, and Librarian of Congress to obtain  information about the Library’s plans for hiring a full-time CIO.
We conducted this performance audit from April 2014 to March 2015 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: Comments from the Library of Congress
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, individuals making contributions  to this report included Lon Chin, Nick Marinos, and Christopher Warweg  (assistant directors), Kaelin Kuhn (analyst-in-charge), Sher’rie Bacon,  Chris Businsky, Sa’ar Dagani, Neil Doherty, Torrey Hardee, Thomas  Johnson, Abishek Krupanand, Jennifer Leotta, Lee McCracken, David  Plocher, Antonio Ramirez, Meredith Raymond, Karen Richey, Kelly  Rubin, Kate Sharkey, Andrew Stavisky, Tina Torabi, Kevin Walsh, Shawn  Ward, and Charles Youman.