Information Technology: Better Management of Interdependencies between Programs Supporting 2020 Census Is Needed
Published: 2016-08-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Commerce's U.S. Census Bureau plans to significantly change the methods and technology it uses to count the population with the 2020 Decennial Census. The Bureau's redesign of the census relies on the acquisition and development of many new and modified systems. Several of the key systems are to be provided by an enterprise-wide initiative called CEDCAP, which is a large and complex modernization program intended to deliver a system-of-systems for all survey data collection and processing functions.
GAO's objectives for this review included (1) evaluating the extent to which the Bureau is implementing best practices in monitoring and controlling three selected CEDCAP projects, (2) determining the extent to which the Bureau is adequately managing the interdependencies between the CEDCAP and 2020 Census programs, and (3) describing key information security challenges the Bureau faces in implementing the 2020 Census design. GAO selected the three high-priority projects planned for the 2020 design; reviewed Bureau documentation such as project plans and schedules and compared them against relevant guidance; and analyzed information security reports and documents.
section_title: What GAO Found
paragraphs: The three selected Census Enterprise Data Collection and Processing (CEDCAP) projects (of 12 total) in GAO's review partially met best practices for monitoring and controlling. For example, the projects fully met the best practice of establishing a process for taking corrective actions if issues are identified, but they did not fully meet the practice of identifying significant performance deviations. Until project officials implement missing practices, they will be limited in their abilities to monitor and control costs, schedules, and performance.
The 2020 Census program is heavily dependent upon CEDCAP to deliver the key systems needed to support the 2020 Census redesign. However, while the two programs have taken steps to coordinate their schedules, risks, and requirements, they lacked effective processes for managing their interdependencies. Specifically:
Among tens of thousands of schedule activities, the two programs are expected to manually identify activities that are dependent on each other, and rather than establishing one integrated dependency schedule, the programs maintain two separate dependency schedules. This has contributed to misalignment in milestones between the programs.
The programs do not have an integrated list of interdependent program risks, and thus they do not always recognize the same risks that impact both programs.
Among other things, key requirements have not been defined for validating responses from individuals who respond to the census using an address instead of a Bureau-assigned identification number, because of the Bureau's limited knowledge and experience in this area. The lack of knowledge and specific requirements related to this critical function is concerning, given that there is about a year remaining before the Census end-to-end test begins in August 2017 (which is intended to test all key systems and operations to ensure readiness for the 2020 Census).
Officials have acknowledged these weaknesses and reported that they are taking, or plan to take, steps to address the issues. However, until these interdependencies are managed more effectively, the Bureau will be limited in understanding the work needed by both programs to meet milestones, mitigate major risks, and ensure that requirements are appropriately identified.
While the large-scale technological changes for the 2020 Decennial Census introduce great potential for efficiency and effectiveness gains, they also introduce many information security challenges. For example, the introduction of an option for households to respond using the Internet puts respondents at greater risk for phishing attacks (requests for information from authentic-looking, but fake, e-mails and websites). In addition, because the Bureau plans to allow its enumerators to use mobile devices to collect information from households that did not self-respond to the survey, it is important that the Bureau ensures that these devices are adequately protected. The Bureau has begun efforts to address many of these challenges; as it begins implementing the 2020 Census design, continued focus on these considerable security challenges will be critical.
section_title: What GAO Recommends
paragraphs: GAO is making eight recommendations to the Department of Commerce in the areas of project monitoring and control and in managing interdependencies related to schedule, risk, and requirements. The department agreed with all eight recommendations and indicated that it will be taking actions to address them.

section_title: Letter
paragraphs: On October 6, 2015, the U.S. Census Bureau (Bureau) released the first  version of its 2020 Census Operational Plan, which is intended to outline  the design decisions that drive how the 2020 Decennial Census will be  conducted. These design decisions are expected to significantly  transform how the Bureau conducts the Decennial Census, in an effort to  save approximately $5.2 billion. The redesign largely depends on  implementing new technology and systems to modernize and automate  many parts of the census. Accordingly, concurrent with the overhaul of  the 2020 Census, the Bureau is significantly redesigning the information  technology (IT) systems that support each of its surveys, including the  2020 Decennial Census, American Community Survey (ACS), and  Economic Census.
Specifically, for the 2020 Decennial Census, the Bureau plans to  significantly change the methods and technology it uses to count the  population, such as offering an option for households to respond to the  survey via the Internet, providing mobile devices for field enumerators to  collect survey data from households, and automating the management of  field operations. The Bureau’s redesign of the census relies on the  acquisition and development of many new and modified IT systems.  Several of these systems are expected to be provided by an enterprise- wide initiative called Census Enterprise Data Collection and Processing  (CEDCAP). This initiative is a large and complex modernization program  intended to deliver a system-of-systems for all the Bureau’s survey data  collection and processing functions, rather than continuing to rely on  unique, survey-specific systems with redundant capabilities.
Given CEDCAP’s importance to achieving the 2020 Decennial Census  redesign, you asked us to review the Bureau’s efforts to implement it. The  specific objectives of our review were to (1) describe the status of the 12  CEDCAP projects, (2) evaluate the extent to which the Bureau is  implementing best practices in monitoring and controlling selected  projects, (3) determine the extent to which the Bureau is adequately  managing the interdependencies between the CEDCAP and 2020  Census programs, and (4) describe the key information security  challenges the Bureau faces in implementing the 2020 Census design.
To address the first objective, we reviewed relevant CEDCAP program  and project documentation, such as the transition plan, segment  architecture, project charters, and monthly progress reports, and  interviewed Bureau officials on the status and plans of all 12 projects.
To address the second objective, we selected three of the CEDCAP  projects based on those that Bureau officials identified as being the  highest priority for the 2020 Census—(1) Centralized Operational  Analysis and Control Project, (2) Internet and Mobile Data Collection  Project, and (3) Survey (and Listing) Interview Operational Control  Project. We analyzed project schedules, risk registers, and management  reports for these three projects and interviewed Bureau officials on their  efforts to manage these projects. We compared the Bureau’s approach  against best practices for project monitoring and control identified by the  Software Engineering Institute’s Capability Maturity Model® Integration  for Acquisition (CMMI®-ACQ) and for Development (CMMI-DEV).
To address the third objective, we analyzed relevant documentation from  the CEDCAP program and the 2020 Census program, such as risk  management plans, program-level risk registers, master schedules,  program management plans, and requirements management  documentation, and compared them against best practices identified in  CMMI-ACQ and CMMI-DEV, as well as by GAO for managing  interdependencies. We also interviewed Bureau officials from the  CEDCAP and 2020 Census programs on their approach to managing  interdependencies between the two programs.
To address the fourth objective, we reviewed relevant documents, such  as CEDCAP and 2020 Census program risk registers and relevant GAO  reports on information security challenges. We analyzed and aggregated  this information to develop an initial list of information security challenges  the Bureau faces in implementing the 2020 Census design. We validated  the list of key challenges by obtaining input from internal and external  experts in information security and/or Decennial Census operations. We  also reviewed documentation regarding the Bureau’s progress in  implementing our 2013 information security recommendations. Appendix  I contains further details on our objectives, scope, and methodology.
We conducted this performance audit from October 2015 to August 2016  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The Bureau’s mission is to collect and provide comprehensive data about  the nation’s people and economy. Its core activities include conducting  decennial, economic, and government censuses; conducting  demographic and economic surveys; managing international  demographic and socioeconomic databases; providing technical advisory  services to foreign governments; and performing other activities such as  producing official population estimates and projections. One of the  Bureau’s most important functions and largest undertakings is conducting  the Decennial Census, which is mandated by the Constitution and  provides data that are vital to the nation. The information collected is used  to apportion seats in the House of Representatives, realign the  boundaries of legislative districts, and allocate billions of dollars in federal  financial assistance.
The Bureau is part of the Department of Commerce and is headed by a  Director. It is organized into directorates corresponding to key  programmatic and administrative functions, including the IT Directorate  led by the Associate Director for IT and Chief Information Officer, and the  2020 Census Directorate, led by the Associate Director for Decennial  Census Programs.
subsections: section_title: 2020 Census Design Decisions
paragraphs: The Bureau’s October 2015 2020 Census Operational Plan outlines 350  redesign decisions that the Bureau has either made or is planning to  make largely by 2018. The Bureau has determined that about 51 percent  of the design decisions are either IT-related or partially IT-related (84 IT- related and 94 partially IT-related) and the Bureau reported that, as of  April 2016, it had made about 58 percent of these decisions (48 IT-related  and 55 partially IT-related). (See fig. 1 below.)
Examples of decisions that have been made include the following:  Internet response—For the first time on a nationwide scale, the  Bureau will allow individuals/households to respond to the census on  the Internet from a computer, mobile device, or other devices that  access the Internet.
Non-ID processing with real-time address matching—The Bureau  will provide each household with a unique ID by mail. However, users  may also respond to the online survey without the unique ID by  entering their address. This operation includes conducting real-time  matching of respondent-provided addresses.
Non-response follow-up—If a household does not respond to the  census by a certain date, the Bureau will send out employees to visit  the home. These enumerators will use a census application, on a  mobile device provided by the Bureau, to capture the information  given to them by the in-person interviews. The Bureau will also  manage the case workload of these enumerators using an operational  control system that automatically assigns, updates, and monitors  cases during non-response follow-up.
Administrative records—As we reported in October 2015, the  Bureau is working on obtaining and using administrative records from  other government agencies, state and local governments, and third- party organizations to reduce the workload of enumerators in their  non-response follow-up work. For example, the Bureau plans to use  administrative records to identify vacant housing units to remove from  enumerators’ workloads, count households that did not return census  questionnaires, predict best times to complete non-response follow- up, and help process responses it receives either on paper or over the  Internet that do not have a census ID number on them (non-ID  processing).
Mobile devices—The Bureau plans to award a contract that would  provide commercially available mobile phones and the accompanying  service contract on behalf of the Census Bureau to enumerators, who  will use these devices to collect census data. This approach is  referred to as the device-as-a-service strategy.
Cloud computing—The Bureau plans to use a hybrid cloud solution  where it is feasible, and has decided it will use cloud services for the  Internet response option as well as for non-ID processing with real- time address matching.
Address canvassing—The Bureau has decided to reengineer its  address canvassing process to reduce the need for employing field  staff to walk every street in the nation in order to update its address  list and maps. For example, the Bureau plans to first conduct in-office  address canvassing using aerial imagery, administrative records, and  commercial data before sending staff into the field.
Figure 2 provides an overview of additional decisions and assumptions  for the 2020 Census, resulting from the October 2015 operational plan.
Examples of decisions that have not been finalized as of May 2016  include the following.
Invalid return detection and non-ID response validation—The  Bureau has not decided on its approach for identifying whether  fraudulent returns have been submitted for the 2020 Census or the  criteria and thresholds to decide whether further investigation may be  needed, such as field follow-up.
Solutions architecture—While the Bureau has established a notional  solutions architecture for the 2020 Census, it has not decided on the  final design.
Internet response for island areas—The Bureau has not decided on  the extent to which the Internet self-response option will be available  for island area respondents.
Additional uses of cloud—While Bureau officials have decided on  select uses of cloud-based solutions, decisions remain on additional  possible uses. For example, the Bureau is exploring whether it will  use a cloud service provider to support a tool for assigning,  controlling, tracking, and managing enumerators’ caseloads in the  field.
section_title: IT Systems Supporting the 2020 Census
paragraphs: The Bureau’s redesign of the census relies on the acquisition and  development of many new and modified systems. Several of the key  systems are expected to be provided as CEDCAP enterprise systems  under the purview of the IT Directorate. According to Bureau officials, the  remaining systems (referred to as non-CEDCAP systems) are to be  provided by the 2020 Census Directorate’s IT Division or other Bureau  divisions. The 2020 Census Directorate established a Systems  Engineering and Integration program office that is to serve as the  technical arm of the 2020 Census program and is responsible for  ensuring that all the system capabilities needed for the 2020 Census are  developed and delivered, including integration of the CEDCAP and non- CEDCAP systems.
section_title: CEDCAP Program Structure and Relationship to the 2020 Census Program
paragraphs: The CEDCAP program is intended to provide data collection and  processing solutions, which include systems, interfaces, platforms and  environments, to support the Bureau’s entire survey life cycle, including  survey design; instrument development; sample design and  implementation; data collection; and data editing, imputation, and  estimation.
The program consists of 12 projects, which have the potential to offer  numerous benefits to the Bureau’s survey programs, including the 2020  Census program, such as enabling an Internet response option;  automating the assignment, controlling, and tracking of enumerator  caseloads; and enabling a mobile data collection tool for field work.  Eleven of these projects are intended to deliver one or more IT solutions.  The twelfth project—IT Infrastructure Scale-Up—is not intended to deliver  IT capabilities, solutions, or infrastructure; rather, it is expected to provide  funding to the other relevant projects to acquire the necessary hardware  and infrastructure to enable 2020 Census systems to scale to  accommodate the volume of users. Table 1 describes the objectives of  each project.
The eleven projects are to provide functionality incrementally over the  course of 13 product releases. The product releases are intended to  support major tests and surveys at the Bureau through 2020. Of the 13  product releases, 7 are intended to support 6 remaining major tests the  2020 Census program is conducting as it prepares for the 2020 Census,  as well as 2020 Census live production. The remaining 6 releases  support the other surveys such as the ACS and Economic Census. Most  recently, the CEDCAP program had been working on delivering the  functionality needed for the third product release which was to support a  major census test, referred to as the 2016 Census Test—conducted by  the 2020 Census program to inform additional decennial design  decisions.
The 2018 Census End-to-End Test, noted below, is critical to testing all  production-level systems and operations in a census-like environment to  ensure readiness for the 2020 Census. The 2020 Census program plans  to begin this test in August 2017. Figure 3 identifies which of the 13  CEDCAP product releases support the 2020 Census versus other  surveys, as of May 2016.
Each product release is decomposed into increments which follow a 40- day delivery schedule. Each of these 40-day increments focuses on a  subset of functionality to deliver at the end of the increment. The Bureau  determined that iterative deliveries of increments of functionality would  best suit the CEDCAP program, instead of a “big bang” delivery approach  for all solutions across all census and survey operations. Officials  reported that such an approach would be impractical given the complexity  of the program.
To manage this complex program, the CEDCAP Program Management  Office consists of three distinct functions:
Program Governance, Planning, and Execution: This function is  led by the Program Manager and is responsible for strategically  leading, integrating, and managing the 12 projects.
Business Operations: Led by the Assistant Chief of Business  Operations, this function is responsible for project management, risk,  issue, schedule, and budget activities. It focuses on the processes  that are critical to ensuring seamless integration across projects.
Technical Integration: This function is led by the Chief Program  Architect, Chief Program Engineer, and Chief Security Engineer, and  is responsible for supporting integration and execution of projects,  participating in technical reviews, and establishing technical  processes related to design, development, testing, integration, and IT  security.
In addition to the Program Management Office, the Bureau established  the Office of Innovation and Implementation to articulate the overall  business needs across the enterprise and ensure they are fulfilled by the  capabilities to be delivered by CEDCAP. The Office of Innovation and  Implementation is responsible for gathering and synthesizing business  requirements across the Bureau, including for the 2020 Census  Directorate, and delivering them to CEDCAP.
section_title: Prior Related GAO Reports Identified IT Management Challenges
paragraphs: Our prior work has identified the importance of having sound  management processes in place to help the Bureau as it manages the  multimillion dollar investments needed for its decennial census. For the  last decennial, we issued multiple reports and testimonies from 2005  through 2010 on weaknesses in the Bureau’s acquisition, management,  and testing of key 2010 census IT systems.
For example, we reported on significant issues with the Census Bureau’s  Field Data Collection Automation program, which was intended to  develop custom handheld mobile devices to support field data collection  for the census, including in-person follow-up with those who did not return  their census questionnaires (nonresponse follow-up). However, as we  testified in March 2008, the program was experiencing significant  problems, including schedule delays and cost increases from changes in  requirements. Due in part to these technology issues the Bureau was  facing, we designated the 2010 Census a high-risk area in March 2008.
In April 2008, the Bureau decided not to use the handheld devices for  nonresponse follow-up. Dropping the use of handheld devices for  nonresponse follow-up and replacing them with a paper-based system  increased the cost of the census by up to $3 billion. Although the Bureau  worked aggressively to improve the paper-based system that replaced  the handheld computers, we reported in December 2010 that the paper- based system also experienced significant issues when it was put in  operation.
Since the 2010 Census, we have issued additional reports and  testimonies on weaknesses in the Bureau’s efforts to institutionalize IT  and program management controls for the 2020 Census. Relevant  reports include the following:  In September 2012, we reported that the Bureau had taken steps to  draft new processes to improve its ability to manage IT investments  and system development, and to improve its IT workforce planning.  However, we found that additional work was needed to ensure that  these processes were effective and successfully implemented across  the Bureau, such as finalizing plans for implementing its new  investment management and systems development processes across  the Bureau, conducting an IT skills assessment and gap analysis, and  establishing a process for directorates to coordinate on IT workforce  planning. The Bureau has fully addressed our recommendations to  address these weaknesses by, for example, finalizing its investment  management process, conducting an enterprise-wide IT competency  assessment and gap analysis, and developing action plans to address  the identified gaps.
As we reported in November 2013, the Bureau was not producing  reliable schedules for two efforts related to the 2020 Census: (1)  building a master address file and (2) 2020 Census research and  testing. For example, the Bureau did not include all activities and  required resources in its schedules, or logically link a number of the  activities in a sequence. We recommended that the Bureau take  actions to improve the reliability of its schedules, including ensuring  that all relevant activities are included in the schedules, complete  scheduling logic is in place, and a quantitative risk assessment is  conducted. We also recommended that the Bureau undertake a  robust workforce planning effort to identify and address gaps in  scheduling skills for staff that work on schedules. The Bureau has  taken steps to implement these recommendations, but has not fully  implemented them.
In April 2014 and February 2015 we reported on the Bureau’s lack of  prioritization of IT decisions related to the 2020 Census. Specifically,  in April 2014, we reported that the Bureau had not prioritized key IT  research and testing needed for its 2020 Census design decisions.  Accordingly, we recommended that the Bureau prioritize its IT-related  research and testing projects. The Bureau had taken steps to address  this recommendation, such as releasing a plan in September 2014  that identified research questions intended to inform the 2020 Census  operational design decisions. In February 2015, however, we reported  that the Bureau had not determined how key IT research questions  that were identified in the September 2014 plan would be answered— such as the expected rate of respondents using its Internet response  option or the IT infrastructure that would be needed to support this  option. We recommended that the Bureau, among other things,  develop methodologies and plans for answering key IT-related  research questions in time to inform design decisions. The Bureau  has taken steps to implement the recommendations, such as  releasing a preliminary 2020 Census Operational Plan that documents  many key IT-related decisions; however, many other IT-related  questions, including the ones that were identified in our report, are to  remain unanswered until 2016 through 2018.
As a result of the Bureau’s challenges in key IT internal controls and  its looming deadline, we identified CEDCAP as an IT investment in  need of attention in our February 2015 High-Risk report.
Further, we testified in November 2015, that key IT decisions needed  to be made soon because the Bureau was less than 2 years away  from end-to-end testing of all systems and operations to ensure  readiness for the 2020 Census and there was limited time to  implement it. We emphasized that that Bureau had deferred key IT- related decisions, and that it was running out of time to develop,  acquire, and implement the systems it will need to deliver the redesign  and achieve its projected $5.2 billion in cost savings. In addition, we  stated that while the Bureau had made improvements in some key IT  management areas, it still faced challenges in the areas of workforce  planning and information security because it had yet to fill key  positions—most concerning was the lack of a permanent chief  information officer.
We have also reported extensively on the increasing security risks facing  federal agencies’ systems and data. These risks were recently  illustrated by the data breaches at the Office of Personnel Management,  which affected millions of current and former federal employees. As we  have reported, protecting the information systems and the information  that resides on them and effectively responding to cyber-incidents is  critical to federal agencies because the unauthorized disclosure,  alteration, and destruction of the information on those systems can result  in great harm to those involved.
Since 1997, we have designated federal information security as a  government-wide high-risk area. In the February 2015 update to our high- risk list, we further expanded this area to include protecting the privacy of  personally identifiable information that is collected, maintained, and  shared by both federal and nonfederal entities. The data collected from  the Census Bureau, or shared with the Bureau from other federal  agencies, contains personally identifiable information and is protected by  federal law. The wrongful disclosure of confidential census information  could lead to criminal penalties.
section_title: CEDCAP’s 12 Projects Are at Various Stages of Planning and Design
paragraphs: The 12 CEDCAP projects are at varying stages of planning and design.  Nine of the projects began when the program was initiated in October  2014, two of the projects began later in June 2015, and the twelfth  project—IT Infrastructure Scale-Up—has not yet started. The 11  ongoing projects have efforts under way to deliver 17 solutions, which are  in different phases of planning and design.
For 8 of the 17 solutions, the Bureau recently completed an analysis  of alternatives to determine whether it will acquire commercial-off-the- shelf (COTS) solutions or whether they will be built in-house in order  to deliver the needed capabilities. On May 25, 2016, the Bureau  issued a memorandum documenting its decision to acquire the  capabilities using a COTS product. The memorandum also described  the process used to select the commercial vendor. Prior to this  decision, the Bureau had developed several pilot systems to provide  functionality to support the ongoing survey tests, such as the 2016  Census test. For example, the Survey (and Listing) Interview  Operational Control project has been developing a pilot system  referred to as Mojo that serves as an operational control system for  field operations that assigns, controls, tracks, and manages cases.  The Mojo pilot was used in the field in the 2015 Census Test and the  2016 Census Test.
For the remaining 9 IT solutions, the Bureau has identified the  sourcing approach (e.g., buy, build, or use/modify existing system)  and has either identified the solution to be implemented or is in the  process of evaluating potential solutions. For example, the Electronic  Correspondence Portal project is working on combining an existing  government-off-the-shelf product with an existing COTS product.
According to program officials, these projects are expected to deliver their  final production solutions in support of the 2020 Census from March 2019  to March 2020, except for the Centralized Development and Test  Environment project, which has not yet determined when it will deliver the  final production solution for the 2020 Census. All projects are scheduled  to end by September 2020 (see table 2 for more detail).
In 2013, the CEDCAP program office estimated that the program would  cost about $548 million to deliver its projects from 2015 to 2020. In July  2015, the Bureau’s Office of Cost Estimation, Analysis, and Assessment  completed an independent cost estimate for CEDCAP that projected the  projects to cost about $1.14 billion from 2015 to 2020 ($1.26 billion  through 2024).
Bureau officials reported that as of March 2016, the projects have  collectively spent approximately $92.1 million—17 percent of the total  program office estimate and 8 percent of the independent cost estimate.  According to Bureau officials, the CEDCAP program is currently  budgeting its projects to the 2013 program office estimate. Table 2  summarizes the status of the 12 CEDCAP projects and their associated  actual or potential IT solutions, and provides the cost estimates for each  project, as well as the amount project officials reported spending as of  March 2016.
section_title: Selected CEDCAP Projects Partially Met Project Monitoring and Control Best Practices
paragraphs: According to CMMI-ACQ and CMMI-DEV, an effective project monitoring  and control process provides oversight of the program’s performance, in  order to allow appropriate corrective actions if actual performance  deviates significantly from planned performance. Key activities in project  monitoring and control include determining progress against the plan by comparing actual cost and  schedule against the documented plan for the full scope of the project  and communicating the results;  identifying and documenting when significant deviations in cost and  schedule performance (i.e., deviations from planned cost and  schedule that, when left unresolved, preclude the project from  meeting its objectives) have occurred;  taking timely corrective actions, such as revising the original plan,  establishing new agreements, or including additional mitigation  activities in the current plan, to address issues when performance  deviates significantly from the plan; monitoring the status of risks periodically, which can result in the  discovery of new risks, revisions to existing risks, or the need to  implement a risk mitigation plan; and  implementing risk mitigation plans that include sufficient detail such as  start and completion dates and trigger events and dates, which  provide early warning that a risk is about to occur or has just occurred  and are valuable in assessing risk urgency.
However, the three selected CEDCAP projects—Centralized Operational  Analysis and Control project, Internet and Mobile Data Collection project,  and Survey (and Listing) Interview Operational Control project—did not  fully implement these practices. Specifically, the Centralized Operational  Analysis and Control project fully met two of the practices in monitoring  and controlling but did not meet the three other practices. The Internet  and Mobile Data Collection project and Survey (and Listing) Interview  Operational Control project fully met one of the best practices in  monitoring and controlling, but partially met the other four best practices.
Determining progress against the plan—Each of the three projects  partially met this practice. Specifically, the three projects meet weekly  to monitor the current status of each project and produce monthly  reports that document cost and schedule progress. However, the  projects’ planning documents lacked sufficient detail against which to  monitor progress because their plans did not include details about the  full scope of their projects for their entire life cycles. For example,  while project officials have provided key information, such as when  build-or-buy decisions were to be made, when the production systems  are to be initially released, and when the final systems are to be  released to support the 2020 Census, project planning documents for  the three projects do not consistently include this information. This is  especially problematic when the production systems that these  projects are expected to produce need to be implemented in time for  the 2018 end-to-end system integration test, which is to begin in  August 2017 (in about a year).
Bureau officials agreed with our concerns and in June 2016 they  stated that they were in the process of updating the project plans and  expect to be done by August 2016. It will be important that these  plans include the full scope of these projects to enable the project  managers and the CEDCAP program manager to determine progress  relative to the full scope of the projects.
Document significant deviations in performance—Each of the  three selected projects partially met this practice. Specifically, the  Bureau’s monthly progress reports capture schedule and cost  variances and document when these variances exceed the threshold  for significant deviation, which is 8 percent. For example, the Internet  and Mobile data collection project had a cost variance of 20 percent in  September 2015 and the Survey (and Listing) Interview Operational  Control project had a cost variance of 25 percent in September 2015,  which were flagged by the projects as exceeding the significant  deviation threshold.
However, the projects do not have up-to-date cost estimates with  which to accurately identify significant deviations in cost performance.  Specifically, the projects are measuring whether there are significant  deviations in costs against their budgeted amounts, which are based  on a 2013 CEDCAP program office estimate. This estimate was  prepared well before the program began in October 2014 and,  according to program officials, is out of date and was developed  based on very early assumptions and limited details about the  projects. For example, key information such as program requirements  was not available when the 2013 program cost estimate was  prepared. However, since then more information about the program  has become available. For example, program requirements were  finalized in May 2015.
Program officials recognized that the program office estimate needs to  be updated and stated that they planned to update their estimate once  the program and its projects are better understood and more complete  information is available, including the recently completed build-versus- buy decisions. However, until the program cost estimate is updated,  the program lacks a basis for monitoring true cost variances for these  three projects.
Taking corrective actions to address issues when necessary— Each of the three selected projects met this practice. Specifically, the  CEDCAP program has established a process for taking corrective  actions to address issues when needed and, as of April 2016, Bureau  officials stated they have not needed to take any corrective actions to  address CEDCAP program issues. For example, while we found  several significant deviations in cost and schedule for the three  projects in the monthly progress reports, these did not require  corrective actions because they were due to, for example, delays in  contract payments, contract awards, and other obligations for  hardware and software outside the control of the CEDCAP program  office.
Monitoring the status of risks periodically—One project (the  Centralized Operational Analysis and Control project) fully met this  practice and the other two projects partially met this practice.  Specifically, the three projects monitor the status of their risks in bi- weekly project status meetings and monthly risk review board  meetings, have established risk registers, and regularly update the  status of risks in their registers. However, while according to Bureau  officials the projects are to document updates on the status of their  risks in their respective risk registers, the Internet and Mobile Data  Collection and Survey (and Listing) Interview Operational Control  projects do not consistently document status updates. For example as  of April 2016, all four of the Internet and Mobile Data Collection  project’s medium-probability, medium-impact risks had not been  updated in its risk register in 9 months. Also as of April 2016, two of  five of the Survey (and Listing) Interview Operational Control project’s  medium-probability, medium-impact risks had not been updated in the  risk register in 4 months.
Bureau officials recognized the need to document updates in the risk  registers more consistently and stated that efforts were under way to  address this. In May 2016, Bureau officials provided updates on the  Internet and Mobile Data Collection project risk list that showed  improvement in documenting the status of risks for that project for 1  month. In June 2016, Bureau officials stated that they had taken  additional steps to improve how risk registers are updated by, for  example, conducting training sessions for project managers on the  CEDCAP program’s expectations for monitoring and updating the  status of risks, and reviewing project risk registers monthly to ensure  compliance. Bureau officials also stated that they planned to release  an updated version of the CEDCAP Risk Management Plan that more  clearly outlines the process and expectations for monitoring and  updating project risk registers by the end of August 2016. While the  officials have taken positive steps, until actions are fully implemented  to ensure that the projects are consistently documenting updates to  the status of risks in a repeatable and ongoing manner, they will not  have comprehensive information on how risks are being managed.
Implementing risk mitigation plans—Each of the three selected  projects partially met this practice. As of October 2015, the three  projects had developed basic risk mitigation steps for each of the risks  associated with the projects that required a mitigation plan. However,  contrary to industry best practices and the Bureau’s risk management  guidance, these risk mitigation plans lacked important details.  Specifically, none of the mitigation plans for the three projects  contained start or completion dates. Additionally, the Centralized  Operational Analysis and Control and the Internet and Mobile Data  Collection projects did not have any trigger events for their risks that  require risk triggers (e.g., those risks that exceed a predefined  exposure threshold). For example, the Centralized Operational  Analysis and Control project had an active issue in March 2016 that if  late requirements were given to the project, it would face delays in  delivering for the 2016 Census test. This risk did not contain a  detailed risk mitigation plan or a trigger date or description.
In February 2016, Bureau officials recognized that there were issues  with their risk management process and stated that they were working  on addressing them. In April 2016, Bureau officials stated that they  had revised their risk management process to increase the threshold  for requiring risk mitigation plans and trigger events. However, the  April 2016 risk registers did not contain any risks that exceeded the  new risk threshold and, therefore, none of the risks required risk  mitigation plans and trigger events. As a result, it is unclear to what  extent the Bureau has improved its practices in developing detailed  risk mitigation plans and assigning trigger events when required. Until  the three projects establish detailed risk mitigation plans and trigger  events for all of their risks that require both, they will not be able to  identify potential problems before they occur and mitigate adverse  impacts to project objectives.
section_title: The Bureau Lacks Processes for Effectively Managing Interdependencies between CEDCAP and 2020 Census Programs
paragraphs: The CEDCAP and 2020 Census programs are intended to be on parallel  implementation tracks and have major interdependencies; however, the  interdependencies between these two programs have not always been  effectively managed. Specifically, CEDCAP relies on 2020 Census to be  one of the biggest consumers of its enterprise systems, and 2020 Census  relies heavily on CEDCAP to deliver key systems to support its redesign.  Thus, CEDCAP is integral to helping the 2020 Census program achieve  its estimated $5.2 billion cost savings goal. Accordingly, as reported in the  President’s Budget for Fiscal Year 2017, over 50 percent of CEDCAP’s  funding for fiscal year 2017 ($57.5 million of the requested $104 million) is  expected to come from the 2020 Census program.
Nevertheless, while both programs have taken a number of steps to  coordinate, such as holding weekly schedule coordination meetings and  participating in each other’s risk review board meetings, the two programs  lack processes for effectively integrating their schedule dependencies,  integrating the management of interrelated risks, and managing  requirements. Without effective processes for managing these  interdependencies, the Bureau is limited in its ability to understand the  work needed by both programs to meet agreed upon milestones, mitigate  major risks, and ensure that requirements are appropriately identified.
subsections: section_title: CEDCAP and 2020 Census Programs Do Not Have an Effective Process for Integrating Schedule Dependencies
paragraphs: According to GAO’s Schedule Assessment Guide, major handoffs  between programs should be discussed and agreed upon and all  interdependencies in the programs’ schedules should be clearly identified  and logically linked so that dates can be properly calculated. The guide  also specifies that changes in linked activities can automatically  reforecast future dates, resulting in a dynamic schedule, and that  attempting to manually resolve incompatible schedules in different  software can become time-consuming and expensive, and thus should be  avoided. Moreover, constantly updating a schedule manually defeats the  purpose of a dynamic schedule and can make the schedule particularly  prone to error. According to best practices, if manual schedule  reconciliation cannot be avoided, the parties should define a process to  preserve integrity between the different schedule formats and to verify  and validate the converted data whenever the schedules are updated.
About half of CEDCAP’s major product releases (7 of 13) are intended to  align with and support the major tests and operations of the 2020 Census.  Accordingly, the CEDCAP and 2020 Census programs have both  established master schedules that contain thousands of milestones and  tens of thousands of activities through 2020 Census production and have  identified major milestones within each program that are intended to align  with each other. In addition, both program management offices have  established processes for managing their respective master schedules.
However, the CEDCAP and 2020 Census programs maintain their master  schedules using different software where dependencies between the two  programs are not automatically linked and are not dynamically responsive  to change. Consequently, the two programs have been manually  identifying activities within their master schedules that are dependent on  each other, and rather than establishing one dependency schedule, as  best practices dictate, the programs have each developed their own  dependency schedule and meet weekly with the intent of coordinating  these two schedules. In addition, the programs’ dependency schedules  only include near-term schedule dependencies, and not future milestones  through 2020 Census production. For example, as of February 2016, the  dependency schedules only included tasks associated with the CEDCAP  product release in support of the 2020 Census program’s 2016 Census  Test through July 2016. According to Bureau officials, they are currently  working to incorporate activities for the next set of near-term milestones in  the dependency schedules, which are to support the 2016 Address  Canvassing Test.
Nonetheless, this process has proven to be ineffective, as it has  contributed to the misalignment between the programs’ schedules. For  example:
The CEDCAP program originally planned to complete build-or-buy  decisions for several capabilities by October 2016, while the 2020  Census timeline specified that these decisions would be ready by  June 2016. In November 2015, CEDCAP officials stated that they  recognized this misalignment and decided to accelerate certain build- or-buy decisions to align with 2020 Census needs.
As of April 2016, while CEDCAP’s major product releases need to be  developed and deployed to support the delivery of major 2020 Census  tests, CEDCAP’s releases and 2020 Census major test milestones  were not always aligned to ensure CEDCAP releases would be  available in time. For example, development of CEDCAP release 7,  which was intended to support the 2017 Census Test, was not  scheduled to begin until almost a month after the 2017 Census Test  was expected to begin (December 2016), and was not planned to be  completed until about 2 months after the 2017 Census Test was  expected to end (July 2017). Bureau officials acknowledged that  CEDCAP release dates needed to be revised to accurately reflect the  program’s current planned time frames and to appropriately align with  2020 Census time frames. Officials provided updated documentation  in June 2016 which was intended to better align CEDCAP and 2020  Census time frames. However, officials also stated in June that  following the May 2016 decision to acquire many of the CEDCAP  solutions, the implementation schedule is being negotiated with the  selected vendor and is subject to change.
Adding to the complexity of coordinating the two programs’ schedules, as  we testified in November 2015, several key decisions by the 2020 Census  program are not planned to be made until later in the decade, which may  impact CEDCAP’s ability to deliver those future requirements and have  production-ready systems in place in time to conduct end-to-end testing,  which is to begin in August 2017. For example, the Bureau does not  plan to decide on the full complement of applications, data, infrastructure,  security, monitoring, and service management for the 2020 Census— referred to as the solutions architecture—until September 2016. The  Bureau also does not plan to finalize the expected response rates for all  self-response modes, including how many households it estimates will  respond to the 2020 survey using the Internet, telephone, and paper, until  October 2017.
Figure 4 illustrates several IT-related decisions which are not scheduled  to be made until later in the decade and may impact CEDCAP’s ability to  prepare for the end-to-end test and 2020 Census.
Further exacerbating the difficulties with the two programs managing  separate dependency schedules is that, as of May 2016 (a year and a  half into the CEDCAP program), their process for managing the  dependencies had not been documented. In response to our draft report,  program officials provided documentation of this process. However, as  previously mentioned, the current process is ineffective, thus  documenting the as-is process does not help the Bureau. Further, while  the programs intend to revise their respective schedules to correct the  existing misalignments identified in this report, continuing to rely on an  ineffective process for manually aligning their milestones will likely lead to  future misalignment as changes occur.
Thus, until the Bureau modifies its current process to ensure complete  alignment between the 2020 and CEDCAP programs by, for example,  maintaining a single dependency schedule, it will be limited in its ability to  ensure that both programs are planning and measuring their activities  according to the same agreed upon time frames. Moreover, until program  officials document the modified process for managing the schedule  dependencies, the Bureau cannot ensure that it has a repeatable process  and that an integrated dependency schedule (if established) will stay  current and help avoid future misalignments.
section_title: CEDCAP and 2020 Census Programs Do Not Have an Integrated List of Risks Facing Both Programs
paragraphs: According to GAO best practices on enhancing and sustaining  collaboration among federal agencies, to achieve a common outcome,  stakeholders should work together to jointly define and agree on their  respective roles and responsibilities, and establish strategies that work in  concert with each other or are joint in nature. Additionally, according to  CMMI-ACQ and CMMI-DEV, effective risk management calls for  stakeholder collaboration on identifying and mitigating risks that could  negatively affect their efforts.
Both the CEDCAP and 2020 Census programs have taken steps to  collaborate on identifying and mitigating risks. For example, both  programs have processes in place for identifying and mitigating risks that  affect their respective programs, facilitate risk review boards, and have  representatives attend each other’s risk review board meetings to help  promote consistency. However, these programs do not have an  integrated list of risks (referred to as a risk register) with agreed-upon  roles and responsibilities to jointly track risks that heavily impact them and  instead separately track these risks. This decentralized approach  introduces two key problems.
First, there are inconsistencies in tracking and managing interdependent  risks. Specifically, selected risks were recognized by one program’s risk  management process and not the other. This included the following  examples as of March 2016:
The CEDCAP program identified the lack of real-time schedule  linkages as a high probability, high-impact risk in its risk register,  which as of March 2016 had been realized and was considered an  issue for the program. However, the 2020 Census program had not  recognized this as a risk in its risk register.
While CEDCAP had identified the ability to scale systems to meet the  needs of the Decennial Census as a medium-probability, high-impact  risk in its risk register, the 2020 Census program had not recognized  this as a risk in its risk register.
The CEDCAP program had identified the need to define how the  Bureau will manage and use cloud services to ensure successful  integration of cloud services with existing infrastructure as a low  probability, high-impact risk in its risk register; however, the 2020  Census program had not recognized the adoption of cloud services as  a formal risk in its risk register. This is especially problematic as the  2020 Census program recently experienced a notable setback  regarding cloud implementation. Specifically, the 2020 Census  program was originally planning to use a commercial cloud  environment in the 2016 Census Test, which would have been the  first time the Bureau used a cloud service in a major census test to  collect census data from residents in parts of the country. However,  leading up to the 2016 Census Test, the program experienced stability  issues with the cloud environment. Accordingly, in March 2016, the  2020 Census program decided to cancel its plans to use the cloud  environment in the 2016 Census Test. Officials stated that they plan  to use the cloud in future census tests.
According to 2020 Census program officials, they did not consider the  lack of real-time schedule linkages to be a risk because they were  conducting weekly integration meetings and coordinating with CEDCAP  on their schedules to ensure proper alignment. However, as stated  previously, attempting to manually resolve incompatible schedules in  different software can be time-consuming, expensive, and prone to errors,  and the Bureau’s process for managing schedule dependencies between  the CEDCAP and 2020 Census programs is ineffective. Regarding the  lack of scalability and cloud services risks in the 2020 Census risk log,  2020 Census program officials acknowledged that it was an oversight and  that they should have been recognized by the program as formal risks.
The second problem of not having an integrated risk register is that  tracking risks in two different registers can result in redundant efforts and  potentially conflicting mitigation efforts. For example, both programs have  identified in their separate risk registers several common risks, such as  risks related to late changes in requirements, integration of systems,  human resources, build-or-buy decisions, and cybersecurity. These  interdependent risks found in both risk registers can introduce the  potential for duplicative or inefficient risk mitigation efforts and the need  for additional reconciliation efforts.
Until the Bureau establishes a comprehensive list of risks facing both the  CEDCAP and 2020 Census programs, and agrees on their respective  roles and responsibilities for jointly managing this list, it will continue to  have multiple sets of inconsistent risk data and will be limited in its ability  to effectively monitor and mitigate the major risks facing both programs.
section_title: Processes for Managing Requirements between CEDCAP and 2020 Census Have Not Been Finalized
paragraphs: According to CMMI-ACQ and CMMI-DEV, requirements management  processes are important for enabling programs to ensure that its set of  approved requirements is managed to support the planning and execution  needs of the program. Such a process should include steps to review and  obtain commitment to the requirements from stakeholders and manage  changes to requirements as customer needs evolve.
The Bureau’s Office of Innovation and Implementation serves as the link  in managing requirements between the 2020 Census and CEDCAP  programs. This office is responsible for gathering and synthesizing  business requirements across the Bureau, including from the 2020  Census program, and delivering them to CEDCAP. Additionally, for the  2020 Census program, the Bureau established the 2020 Census Systems  Engineering and Integration program office, which is responsible for  delivering 2020 Census business requirements to the Office of Innovation  and Implementation. CEDCAP receives the requirements on an  incremental basis, and as mentioned previously, CEDCAP builds  functionality containing subsets of the requirements in the 40-day cycles.  CEDCAP has delivered 12 increments of system functionality to support  the first three releases.
However, as of April 2016, the Office of Innovation and Implementation’s  process for collecting and synthesizing requirements, obtaining  commitment to those requirements from stakeholders, and managing  changes to the requirements had been drafted, but not yet finalized. In  July 2016, Bureau officials stated that due to the recent selection of a  commercial vendor to deliver many of the CEDCAP capabilities, they do  not plan to finalize this process until January 2017. Additionally, as of  April 2016, the 2020 Census Systems Engineering and Integration  program had not yet finalized its program management plan, which  outlines, among other things, how it is to establish requirements to be  delivered to the Office of Innovation and Implementation, which are then  to be delivered to CEDCAP. According to program officials, they have  been working on a draft of this plan and expect it to be finalized by the  end of August 2016. As a result, the Bureau has developed three  CEDCAP releases without having a fully documented and institutionalized  process for collecting those requirements.
In addition, the 2020 Census program identified about 2,500 capability  requirements needed for the 2020 Census; however, there are gaps in  these requirements. Specifically, we determined that of the 2,500  capability requirements, 86 should be assigned to a test prior to the 2020  Census, but were not. These included 64 requirements related to  redistricting data program, 10 requirements related to data products and  dissemination, and 12 requirements related to non-ID response  validation. Bureau officials stated that the 74 redistricting data program  and data products and dissemination requirements have not yet been  assigned to a Census test because they have not yet gone through the  Bureau’s quality control process, which is planned for later this calendar  year.
Regarding the 12 non-ID response validation requirements, Bureau  officials stated that once this area is better understood, a more complete  set of requirements will be established, and then they will assign the  requirements to particular tests, as appropriate. As of April 2016, the  Bureau was in the early stages of conducting research in this area. Thus,  it has not tested non-ID response validation in the 2013, 2014, or 2015  Census tests. These tests were intended to, among other things, help  define requirements around critical functions.
With about a year remaining before the 2018 Census end-to-end test  begins, the lack of experience and specific requirements related to non-ID  response validation is especially concerning, as incomplete and late  definition of requirements proved to be serious issues for the 2010  Census. Specifically, leading up to the 2010 Census, we reported in  October 2007 that not fully defining requirements had contributed to both  cost increases and schedule delays experienced by the failed program to  deliver handheld computers for field data collection—contributing to an up  to $3 billion overrun. Increases in the number of requirements led to the  need for additional work and staffing. Moreover, we reported in 2009 and  2010 that the Bureau’s late development of an operational control system  to manage its paper-based census collection operations resulted in  system outages and slow performance during the 2010 Census. The  Bureau attributed these issues, in part, to the compressed development  and testing schedule.
As the 2020 Census continues to make future design decisions and  CEDCAP continues to deliver incremental functionality, it is critical to  have a fully documented and institutionalized process for managing  requirements. Additionally, until measures are taken to identify when the  74 requirements related to the redistricting data program and data  products and dissemination will be tested, and to make developing a  better understanding of, and identifying requirements related to, non-ID  response validation a high and immediate priority, or to consider  alternatives to avoid late definition of such requirements, the Bureau is at  risk of experiencing issues similar to those it experienced during the 2010  Census.
section_title: Census Bureau Faces Several Information Security Challenges in Implementing the 2020 Census
paragraphs: While the Bureau plans to extensively use IT systems to support the 2020  Census redesign in an effort to realize potentially significant efficiency  gains and cost savings, this redesign introduces numerous critical  information security challenges.
Developing policies and procedures to minimize the threat of  phishing—Phishing is a digital form of social engineering that uses  authentic-looking, but fake, e-mails, websites, or instant messages to  get users to download malware, open malicious attachments, or open  links that direct them to a website that requests information or  executes malicious code. Phishing attacks could target respondents,  as well as Census employees and contractors. The 2020 Census will  be the first one in which respondents will be heavily encouraged to  respond via the Internet. The Bureau plans to highly promote the use  of the Internet self-response option throughout the nation and  expects, based on preliminary research, that approximately 50  percent of U.S. households will use this option. This will likely  increase the risk that cyber criminals will use phishing in an attempt to  steal personal information. A report developed by a contractor for the  Bureau noted that criminals may pretend to be a census worker,  caller, or website, to phish for personal information such as Social  Security numbers and bank information.
Further, phishing attacks directed at Census employees, including  approximately 300,000 temporary employees, could have serious  effects. The U.S. Computer Emergency Readiness Team (US-CERT)  has recently reported on phishing campaigns targeting federal  government agencies that are intended to install malware on  government computer systems. These could act as an entry point for  attackers to spread throughout an organization’s entire enterprise,  steal sensitive personal information, or disrupt business operations.
To minimize the threat of phishing, organizations such as US-CERT  and the National Institute of Standards and Technology (NIST)  recommend several actions for organizations, including  communicating with users. Additionally, as we previously reported,  in 2015 the White House and the Office of Management and Budget  identified anti-phishing as a key area for federal agencies to focus on  in enhancing their information security practices.
Ensuring that individuals gain only limited and appropriate  access to 2020 Census data—The Decennial Census plans to  enable a public-facing website and mobile devices to collect  personally identifiable information (PII) (e.g., name, address, and date  of birth) from the nation’s entire population—estimated to be over 300  million. In addition, the Bureau is planning to obtain and store  administrative records containing PII from other government agencies  to help augment information that enumerators did not collect. Further,  the 2020 Census will be highly promoted and visible throughout the  nation, which could increase its appeal to malicious actors.  Specifically, cyber criminals may attempt to steal personal information  collected during and for the 2020 Decennial Census, through  techniques such as social engineering, sniffing of unprotected traffic,  and malware installed on vulnerable machines.
We have reported on challenges to the federal government and the  private sector in ensuring the privacy of personal information posed by  advances in technology. For example, in our 2015 High Risk List, we  expanded one of our high-risk areas—ensuring the security of federal  information systems and cyber critical infrastructure—to include  protecting the privacy of PII. Technological advances have allowed  both government and private sector entities to collect and process  extensive amounts of PII more effectively.
However, the number of reported security incidents involving PII at  federal agencies has increased dramatically in recent years. Because  of these challenges, we have recommended, among other things, that  federal agencies improve their response to information security  incidents and data breaches involving PII, and consistently develop  and implement privacy policies and procedures. Accordingly, it will be  important for the Bureau to ensure that only respondents and Bureau  officials are able to gain access to this information, and that  enumerators and other employees only have access to the  information needed to perform their jobs.
Adequately protecting mobile devices—The 2020 Census will be  the first one in which the Census Bureau will provide mobile devices  to enumerators to collect PII from households who did not self- respond to the survey. The Bureau plans to use a contractor to  provide approximately 300,000 census-taking-ready mobile devices to  enumerators. The contractor will be responsible for, among other  things, the provisioning, shipping, storage, and decommissioning of  the devices. The enumerators will use the mobile devices to collect  data from non-response follow-up activities.
Many threats to mobile devices are similar to those for traditional  computing devices; however, the threats and attacks to mobile  devices are facilitated by vulnerabilities in the design and  configuration of mobile devices, as well as the ways consumers use  them. Common vulnerabilities include a failure to enable password  protection and operating systems that are not kept up to date with the  latest security patches. In addition, because of their small size and  use outside an office setting, mobile devices are easier to misplace or  steal, leaving their sensitive information at risk of unauthorized use or  theft.
In 2012 we reported on key security controls and practices to reduce  vulnerabilities in mobile devices, protect proprietary and other  confidential business data that could be stolen from mobile devices,  and ensure that mobile devices connected to the organization’s  network do not threaten the security of the network itself. For  example, we reported that organizations can require that devices  meet government specifications before they are deployed, limit  storage on mobile devices, and ensure that all data on the device are  cleared before the device is disposed of. Doing so can help protect  against inappropriate disclosure of sensitive information that is  collected on the mobile devices. Accordingly, we recommended,  among other things, that the Department of Homeland Security, in  collaboration with the Department of Commerce, establish measures  about consumer awareness of mobile security. In September 2013,  the Department of Homeland Security addressed this  recommendation by developing a public awareness campaign with  performance measures related to mobile security.
Ensuring adequate control in a cloud environment—The Bureau  has decided to use cloud solutions whenever possible for the 2020  Census; however, as stated previously, it has not yet determined all of  the needed cloud capabilities. In September 2014, we reported that  cloud computing has both positive and negative information security  implications for federal agencies. Potential information security  benefits include the use of automation to expedite the implementation  of secure configurations on devices, reduced need to carry data on  removable media because of broad network access, and low-cost  disaster recovery and data storage. However, the use of cloud  computing can also create numerous information security risks for  federal agencies, including that cloud service vendors may not be  familiar with security requirements that are unique to government  agencies, such as continuous monitoring and maintaining an  inventory of systems. Thus, we reported that, to reduce the risks, it is  important for federal agencies to examine the specific security  controls of the provider the agency is evaluating when considering the  use of cloud computing.
In addition, in April 2016, we reported that agencies should develop  service-level agreements with cloud providers that specify, among  other things, the security performance requirements—including data  reliability, preservation, privacy, and access rights—that the service  provider is to meet. Without these safeguards, computer systems  and networks, as well as the critical operations and key infrastructures  they support, may be lost; information—including sensitive personal  information—may be compromised; and the agency’s operations  could be disrupted.
Adequately considering information security when making  decisions about the IT solutions and infrastructure supporting  the 2020 Census—Design decisions related to the 2020 Census will  have security implications that need to be considered when making  decisions about future 2020 Census design features. As described  previously, as of April, the Census Bureau still had to make 350  decisions about the 2020 Census, and half of those have an IT  component. For example, the Bureau has not yet made decisions  about key aspects of its IT infrastructure to be used for the 2020  Census, including defining all of the components of the solution  architecture (applications, data, infrastructure, security, monitoring,  and service management), deciding whether it will develop a mobile  application to enable respondents to submit their survey responses on  their mobile devices, and deciding how it plans to use cloud providers.
We have previously reported on challenges that the Bureau has had  in making decisions in a timely manner. Specifically, in April 2014, and  again in April 2015, we noted that key decisions had yet to be made  about the 2020 Census, and noted that as momentum builds toward  Census Day 2020, the margin for schedule slippages is getting  increasingly slim. The Chief Information Security Officer echoed these  concerns, stating that any schedule slippage can affect the time  needed to conduct a comprehensive security assessment. As key  design decisions are deferred and the time to make such decisions  becomes more compressed, it is important for the Bureau to ensure  that information security is adequately considered and assessed when  making design decisions about the IT solutions and infrastructure to  be used for the 2020 Census.
Making certain key IT positions are filled and have appropriate  information security knowledge and expertise—As our prior work  and leading guidance recognize, having the right knowledge and skills  is critical to the success of a program, and mission-critical skills gaps  in such occupations as cybersecurity pose a high-risk to the nation.  Whether within specific federal agencies or across the federal  workforce, these skills gaps impede federal agencies in cost- effectively serving the public and achieving results. Because of this,  we added strategic human capital management, including  cybersecurity human capital, to our High Risk List in 2001, and it  remains on that list today. These skills gaps are also a key  contributing factor to our high-risk area of ensuring the security of  federal information systems. As we reported in February 2015,  although steps have been taken to close critical skills gaps in the  cybersecurity area, it remains an ongoing problem and additional  efforts are needed to address this issue government-wide.
We also reported in February 2015, that the Bureau continues to have  critical skills gaps, such as in cloud computing, security integration  and engineering, enterprise/mission engineering life-cycle,  requirements development, and internet data collection. The Bureau  has made some progress in addressing its skills gaps and continues  to work toward ensuring that key information security skills are in  place. However, it has faced longstanding vacancies in key IT  positions, such as the Chief Information Officer (vacant from July  2015 to June 2016) and the CEDCAP Chief Security Engineer (vacant  since October 2015). Ensuring that key positions are filled with staff  who have the appropriate expertise will be important to ensure that  security controls are adequately designed in the systems used to  collect and store census data.
Ensuring that contingency and incident response plans are in  place that encompass all of the IT systems to be used to support  the 2020 Census—Because of the brief time frame for collecting data  during the Decennial Census, it is especially important that systems  are available for respondents to ensure a high response rate.  Contingency planning and incident response help ensure that if  normal operations are interrupted, network managers are able to  detect, mitigate, and recover from a service disruption while  preserving access to vital information. Implementing important  security controls including policies, procedures, and techniques for  contingency planning and incident response helps to ensure the  confidentiality, integrity, and availability of information and systems,  even during disruptions of service.
However, we have reported on weaknesses across the federal  government in these areas. Specifically, in April 2014 we estimated  that federal agencies (including the Department of Commerce) had  not completely documented actions taken in response to detected  incidents reported in fiscal year 2012 in about 65 percent of cases.  We made a number of recommendations to improve agencies’ cyber  incident response practices, such as developing incident response  plans and procedures and testing them.
Adequately training Bureau employees, including its massive  temporary workforce, in information security awareness—The  Census Bureau plans to hire an enormous temporary workforce  during the 2020 Census activities, including about 300,000 temporary  employees to, among other things, use contractor-furnished mobile  devices to collect personal information from households that have not  yet responded to the Census. Because uninformed people can be one  of the weakest links when securing systems and networks,  information security awareness training is intended to inform agency  personnel of the information security risks associated with their  activities and their responsibilities in complying with agency policies  and procedures designed to reduce these risks. However, ensuring  that every one of the approximately 300,000 temporary enumerators  is sufficiently trained in information security will be challenging.  Providing training to agency personnel, such as this new and  temporary staff, will be critical to securing information and systems.
Making certain security assessments are completed in a timely  manner and that risks are at an acceptable level—According to  guidance from NIST, after testing an information system, authorizing  officials determine whether the risks (e.g., unaddressed  vulnerabilities) are acceptable and issue an authorization to operate.  Each of the systems that the 2020 Census IT architecture plans to  rely on will need to undergo a security assessment and obtain  authorization to operate before it can be used for the 2020 Census.
Properly configuring and patching systems supporting the 2020  Census—Configuration management controls ensure that only  authorized and fully tested software is placed in operation, software  and hardware are updated, information systems are monitored,  patches are applied to these systems to protect against known  vulnerabilities, and emergency changes are documented and  approved. We reported in September 2015 that for fiscal year 2014,  22 of the 24 agencies in our review (including the Department of  Commerce) had weaknesses in configuration management controls.  Moreover, in April 2015, US-CERT issued an alert stating that cyber  threat adversaries continue to exploit common, but unpatched,  software products from vendors such as Adobe, Microsoft, and  Oracle. Without strong configuration and patch management, an  attacker may exploit a vulnerability not yet mitigated, enabling  unauthorized access to information systems or enabling users to have  access to greater privileges than authorized.
The Bureau’s acting Chief Information Officer and its Chief Information  Security Officer have acknowledged these challenges and described the  Bureau’s plans to address them. For example, the Bureau has developed  a risk management framework, which is intended to ensure that proper  security controls are in place and provide authorizing officials with details  on residual risk and progress to address those risks. In addition, the  Bureau has also embedded three security engineers in the 2020 Census  program to provide assistance and guidance to project teams. Bureau  officials also stated that they are in the process of filling—or plan to fill— vacancies in key positions and intend to hire staff with expertise in key  areas, such as cloud computing. To minimize the risk of phishing, Bureau  officials note that they plan to contract with a company to monitor the  Internet for fraudulent sites pretending to be the Census Bureau.  Continued focus on these considerable challenges will be important as  the Bureau begins to develop and/or acquire systems and implement the  2020 design.
We have previously reported on Census Bureau weaknesses that are  related to many of these information security challenges. Specifically, we  reported in January 2013 that the Bureau had a number of weaknesses in  its information security controls due, in part, to the fact that it had not fully  implemented a comprehensive information security program. Thus, we  made 13 public recommendations in areas such as security awareness  training, incident response, and security assessments. We also made 102  recommendations to address technical weaknesses we identified related  to access controls, configuration management, and contingency  planning.
As of June 2016, the Bureau had made significant progress in addressing  these recommendations. Specifically, it had implemented all 13 public  recommendations and 92 of 102 technical recommendations. For  example, the Bureau developed and implemented a risk management  framework with a goal of better management visibility of information  security risks; this framework addressed a recommendation to document  acceptance of risks for management review.
We have work under way to evaluate whether the 10 remaining  recommendations have been fully addressed. These recommendations  pertain to access controls and configuration management, and are related  to two of the security challenges we previously mentioned—ensuring  individuals gain only limited and appropriate access, and properly  configuring and patching systems. The Bureau’s progress toward  addressing our recommendations is encouraging; however, completing  this effort is necessary to ensure that sensitive information is adequately  protected and that the challenges we outline in this report are overcome.
section_title: Conclusions
paragraphs: The CEDCAP program’s 12 projects have the potential to offer numerous  benefits to the Bureau’s survey programs, including the 2020 Census  program, such as enabling an Internet response option; automating the  assignment, controlling, and tracking of enumerator caseloads; and  enabling a mobile data collection tool for field work. While the Bureau has  taken steps to implement these projects, considerable work remains  between now and when its production systems need to be in place to  support the 2020 Census end-to-end system integration test—in about a  year.
Although the three selected CEDCAP projects had key project monitoring  and controlling practices in place or planned, such as producing monthly  progress reports, gaps exist in other important ways to monitor and  control projects, such as the lack of detailed project plans, documentation  of risk status updates, and complete risk mitigation plans. While officials  plan to update the project plans with more detail, until the program and  the selected projects address these other gaps, they are at risk of not  adequately monitoring these projects.
Given the numerous and critical dependencies between the CEDCAP and  2020 Census programs, their parallel implementation tracks, and the  2020 Census’ immovable deadline, it is imperative that the  interdependencies between these programs are effectively managed.  However, this has not always been the case. While actions such as  weekly meetings to discuss the programs’ respective schedules  demonstrate that the programs are trying to coordinate, additional actions  would help better align the programs. Specifically, until the two programs  establish schedules that are completely aligned, develop an integrated list  of all interdependent risks, and finalize processes for managing  requirements, both programs are at risk of not delivering their programs  as expected.
Finally, while the large-scale technological changes for the 2020  Decennial Census introduce great potential for efficiency and  effectiveness gains, it also introduces many information security  challenges, including educating the public to offset inevitable phishing  scams. Continued focus on these considerable security challenges and  remaining open recommendations will be important as the Bureau begins  to develop and/or acquire systems and implement the 2020 Census  design.
section_title: Recommendations for Executive Action
paragraphs: To ensure that the Bureau is better positioned to deliver CEDCAP, we are  recommending that the Secretary of Commerce direct the Director of the  Census Bureau to take the following eight actions:
Update the CEDCAP program office cost estimate to reflect the  current status of the program as soon as appropriate information  becomes available.
Ensure that updates to the status of risks are consistently  documented for CEDCAP’s Internet and Mobile Data Collection and  Survey (and Listing) Interview Operational Control projects.
Ensure that CEDCAP’s Internet and Mobile Data Collection, Survey  (and Listing) Interview Operational Control, and Centralized  Operational Analysis and Control projects establish detailed risk  mitigation plans on a consistent basis and that the Internet and Mobile  Data Collection and Centralized Operational Analysis and Control  projects establish trigger events for all relevant risks.
Define, document, and implement a repeatable process to establish  complete alignment between CEDCAP and 2020 Census programs  by, for example, maintaining a single dependency schedule.
Establish a comprehensive and integrated list of all interdependent  risks facing the CEDCAP and 2020 Census programs, and clearly  identify roles and responsibilities for managing this list.
Finalize documentation of processes for managing requirements for  CEDCAP.
Identify when the 74 requirements related to redistricting data  program and data products and dissemination will be tested.
Make developing a better understanding of and identifying  requirements related to non-ID response validation a high and  immediate priority, or consider alternatives to avoid late definition of  such requirements.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from the  Department of Commerce, which are reprinted in appendix II. In its  comments, the department agreed with all eight of our recommendations  and indicated that it will be taking actions in response to our  recommendations. The department also stated that for several of the  recommendations it believed that some additional context should be  included in our report, which we discuss below.
First, the department reported that the Census Bureau decided on May  25, 2016, to use a commercial off-the-shelf solution in combination with  in-house solutions for the data collection component of the 2020 Census,  which is to be delivered by the CEDCAP program. We updated relevant  statements in our report to reflect this recent decision.
In response to our first recommendation to update the CEDCAP program  office cost estimate to reflect the current status of the program as soon as  appropriate information becomes available, the department agreed and  noted that with the recent May 2016 decision, the Bureau has begun work  on new program life cycle cost estimates. This is a positive step forward,  and it will be important that the Bureau prepares a reliable estimate in a  timely manner in order to have a basis for monitoring true cost variances  for the three selected CEDCAP projects we reviewed.
The department agreed with our fourth recommendation to define,  document, and implement a repeatable process to establish complete  alignment between CEDCAP and the 2020 Census program by, for  example, maintaining a single dependency schedule. Specifically, the  department stated that the Bureau must maintain schedule alignment  between the 2020 Census and CEDCAP programs through a single  integrated schedule. The department further stated that the 2020 Census  is the program of interest and, as such, it must and will drive the schedule  for all solutions that support it, including CEDCAP solutions. The  department also stated that the 2020 Census manages its master  schedule through the Primavera software package, as recommended  earlier in the decade by GAO.
However, GAO does not make recommendations on the use of specific  software packages, and thus did not make such a recommendation to the  Bureau. The Bureau’s selection of a software tool should have been  based on an assessment of the costs, benefits, and risks associated with  alternative solutions. Regardless of the software packages used, the  2020 Census schedule is dependent on the delivery of CEDCAP  solutions and, as we state in the report, the process for integrating the  schedule dependencies between these two programs is ineffective. Thus,  we maintain that until the Bureau modifies its current process to ensure  complete alignment between the 2020 Census and CEDCAP programs  by, for example, maintaining a single dependency schedule, it will be  limited in its ability to ensure that both programs are planning and  measuring their activities according to the same agreed-upon time  frames.
In response to our fifth recommendation to establish a comprehensive  and integrated list of all interdependent risks facing the CEDCAP and  2020 Census programs, the department agreed and stated that the 2020  Census program should better monitor interdependent risks through an  integrated risk register. The department further stated that it uses an  enterprise risk management tool to enable access to an integrated list of  all active risks, including interdependent risks. It also stated that linkages  between the two programs’ risk registers can be flagged and tracked  using these processes and then used to ensure the same process for  responding to emerging risks are followed. However, although the  Bureau’s comments discuss capabilities of its enterprise risk  management tool that could help address our recommendation, during  our review the two programs’ interdependent risks were not being linked  or tracked in an integrated manner, and we have not received additional  evidence to demonstrate that further actions had been taken by the  Bureau to address this.
The department agreed with our seventh recommendation to identify  when the 74 requirements related to redistricting data program and data  products and dissemination will be tested. In its letter, the department  stated that the Bureau had been conducting research on the highest- priority areas and activities relative to core operational and cost-efficiency  requirements due to budget limitations this decade, but that planning and  requirements development for these two areas are now under way. The  Bureau intends to ensure that any testing needs are prioritized for  inclusion in the 2018 end-to-end census test. Full implementation of our  recommendation should help ensure that the requirements are sufficiently  tested prior to the 2020 Census.
In response to our eighth recommendation to make identifying  requirements related to non-ID response validation a high and immediate  priority, or consider alternatives to avoid late definition of such  requirements, the department agreed that non-ID response requirements  should continue to receive attention and priority. The department also  noted that non-ID response validation operations have been conducted  for several censuses, using a paper process, and that they validated  these responses prior to tabulating the data to ensure that the response  was legitimate and not duplicative.
However, while the Bureau has prior experience conducting non-ID  response validation operations in a controlled, small-scale paper-based  environment, 2020 will be the first decennial census that the Bureau  introduces an Internet response option on a wide scale, as well as the  first time the Bureau attempts non-ID response collection via the Internet.  According to Bureau officials, the use of the Internet to collect non-ID  responses introduces the potential for a much higher volume of  responses that will need to be validated than if the Bureau were to use a  paper-based non-ID approach. The Bureau has also reported that  Internet-based non-ID response collection increases the likelihood of  fraudulent responses. Given that the Bureau is in the early stages of  conducting research and developing requirements in this area and there  is only a year remaining before the 2018 Census end-to-end test begins,  we maintain that the lack of experience and specific requirements related  to non-ID response validation is highly concerning, and our  recommendation to make this a high and immediate priority or consider  alternative approaches needs to be implemented.
The department also stated that the Bureau has a long history of and  demonstrated commitment to ensuring the confidentiality of the  information provided by the public. It stated that implementing strong  protections for all of its solutions and conforming to leading cybersecurity  and fraud prevention best practices will be paramount for the self- response and field data collection operations. We agree and are  encouraged by the significant progress the Bureau has made in  addressing our prior recommendations on information security  weaknesses.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretary of  Commerce, the Director of the U.S. Census Bureau, and interested  congressional committees. In addition, the report will be 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) 512-4456 or Chac@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: Our objectives were to (1) describe the status of the 12 Census  Enterprise Data Collection and Processing (CEDCAP) projects, (2)  evaluate the extent to which the U.S. Census Bureau (Bureau) is  implementing best practices in monitoring and controlling selected  CEDCAP projects, (3) determine the extent to which the Bureau is  adequately managing the interdependencies between the CEDCAP and  2020 Census programs, and (4) describe the key information security  challenges the Bureau faces in implementing the 2020 Census design.
To describe the status of the 12 CEDCAP projects, we reviewed relevant  CEDCAP program and project documentation, such as the transition plan,  segment architecture, project charters, monthly progress reports, and the  program office cost estimate and independent cost estimate. We used the  information in this documentation to summarize the 12 projects in terms  of project objectives, overall time frames, estimated costs, and amount  spent to date, among other things. We also interviewed Bureau officials,  including the CEDCAP program manager, on the status and plans of all  12 projects.
To evaluate the extent to which the Bureau is implementing best practices  in monitoring and controlling selected CEDCAP projects, we selected  three projects based on those that Bureau officials identified as being the  highest priority for the 2020 Census—(1) Centralized Operational  Analysis and Control Project, (2) Internet and Mobile Data Collection  Project, and (3) Survey (and Listing) Interview Operational Control  Project. We reviewed program management documentation for the  selected projects against project monitoring and controlling best practices  identified by the Software Engineering Institute’s Capability Maturity  Model® Integration for Acquisition (CMMI®-ACQ) and for Development  (CMMI-DEV). These key practices included determining progress against the plan, documenting significant deviations in performance,  taking corrective actions to address issues when necessary, monitoring the status of risks periodically, and  implementing the risk mitigation plan.
Specifically, we analyzed program management documentation, including  the program management plan, schedule management plan, risk  management plan, transition plan, and segment architecture. We also  analyzed documentation for each of the three selected projects, including  project charters, schedules, risk registers, and monthly progress reports.  Further, we interviewed Bureau officials, including the CEDCAP program  manager and the project managers for each of the selected projects, on  their efforts to manage these projects. We assessed the evidence against  the best practices to determine whether each project fully, partially, or did  not meet the best practices. Specifically, “met” means that the Bureau  provided complete evidence that satisfies the entire criterion, “partially  met” means the Bureau provided evidence that satisfies some but not all  of the criterion, and “not met” means the Bureau provided no evidence  that satisfies any of the criterion.
To determine the extent to which the Bureau is adequately managing the  interdependencies between the CEDCAP and 2020 Census programs,  we compared program documentation related to managing  interdependencies against best practices identified in CMMI-ACQ and  CMMI-DEV, as well as by GAO. Specifically, we analyzed relevant  documentation from both programs, such as risk management plans,  program-level risk registers, master schedules, dependency schedules,  program management plans, and requirements management  documentation. We also reviewed the 2020 Census Operational Plan,  artifacts from meetings of the CEDCAP and 2020 Census Executive  Steering Committees, and presentations from the 2020 Census Program  Management Review meetings. For assessing schedule dependencies  between the CEDCAP and 2020 Census programs, we reviewed both  programs’ master schedules and other program planning documents that  contained major milestones and compared the dates against each other.  We identified any potential misalignment in major milestones between the  two programs and discussed these with CEDCAP and 2020 Census  program officials. We summarize these misalignments in our report. We  also interviewed Bureau officials from the CEDCAP and 2020 Census  programs, including the CEDCAP program manager, Associate Director  of Decennial Census Programs, the Chief of the Bureau’s Office of  Innovation and Implementation, and the Bureau’s acting Chief Information  Officer, on their approach to managing schedule, risk, and requirement  interdependencies between the two programs.
To describe the key information security challenges the Bureau faces in  implementing the 2020 Census design, we reviewed documentation on  the 2020 Census design—including the 2020 Census Operational Plan,  CEDCAP and 2020 Census program risk registers, and a report  developed by a contractor for the 2020 Census—and interviewed staff  within the Bureau’s Office of the Chief Information Security Officer. We  developed a list of key assumptions on the design of the 2020 Census  based on the documentation and input from Bureau officials. We also  reviewed reports by GAO and others on information security challenges  faced across the federal government. We synthesized the information in  these reports to determine which security practices were most important  given the design assumptions of the 2020 Census, to develop an initial  list of key challenges.
We then obtained input on our initial list of challenges from relevant  experts and the Census Bureau. Specifically, we identified relevant  experts within two of the Bureau’s key advisory groups—the National  Academy of Sciences and Census Scientific Advisory Committee. These  advisory groups consist of academic and industry experts from various  fields, including information technology, and they meet with the Bureau  regularly to provide feedback on various areas, including the 2020  Census program. We also identified relevant experts within the  information security field on GAO’s Executive Council on Information  Management and Technology, including the Chair of the Association for  Computing Machinery’s Committee on Computers and Public Policy; the  Executive Director for the National Association of State Chief Information  Officers; and the Executive Director of the Center for Education and  Research in Information Assurance and Security. We provided our list of  key information security challenges to these experts, and obtained their  perspectives. Finally, we provided the list to the Census Bureau’s Acting  Chief Information Officer and the Chief Information Security Officer, to  gain their feedback on our list and allow them the opportunity to respond  with the Bureau’s plans for the challenges.
We also determined the Bureau’s progress in addressing  recommendations from our 2013 public and limited official use only  reports by reviewing Bureau documentation, such as the Bureau’s Risk  Management Framework, IT Security Program Policy, and guidelines and  procedures for incident response plan tests. We compared the agency  documentation to the relevant information security best practices for each  of the recommendations, to determine how many recommendations had  been implemented.
We conducted this performance audit from October 2015 to August 2016  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 U.S. Department of Commerce
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, the following staff made key  contributions to this report: Shannin G. O’Neill (Assistant Director),  Jeanne Sung (Analyst in Charge), Andrew Beggs, Chris Businsky, Juana  Collymore, Lee McCracken, and Kate Sharkey.