Telecommunications: Agencies Are Generally Following Sound Transition Planning Practices, and GSA Is Taking Action to Resolve Challenges
Published: 2008-06-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The General Services Administration (GSA) is responsible for ensuring that federal agencies have access to the telecommunications needed to meet mission requirements. GSA's current telecommunications program, called FTS2001, has contracts in place that will expire by June 2010. Thus, agencies face the difficult task of transitioning their services to a successor program, known as Networx. GAO was asked to determine (1) the extent to which agencies are following sound transition planning practices and (2) the actions GSA is taking to identify and resolve common transition challenges affecting agencies. In performing this work, GAO selected six agencies based on, among other things, their FTS2001 charges; reviewed transition planning at these agencies and GSA; and analyzed GSA documentation of actions to address transition challenges.
section_title: What GAO Found
paragraphs: Selected agencies--the Departments of Homeland Security, Commerce, and Agriculture and the Small Business Administration, U.S. Army Corps of Engineers, and the U.S. Nuclear Regulatory Commission--are generally following sound transition planning practices previously identified by GAO. For example, all have established telecommunications inventories, and most have established transition plans that include transition preparation tasks and time lines. However, other key practices are not being fully implemented at three agencies. For example, Commerce does not plan to clearly define all key transition roles and responsibilities, Homeland Security does not plan to identify local and regional points of contact, and the Nuclear Regulatory Commission does not plan to establish measures of success based on its transition objectives. With limited time available to finalize planning and begin transitions, agencies that do not address gaps in their planning or follow through on plans risk delaying their transitions and increase the likelihood of incurring unnecessary costs. As facilitator for all transition management activities, GSA has identified numerous common challenges that agencies face in making the transition to Networx, and it is taking action to resolve them. GSA uses various forums to identify these challenges, which include ensuring cooperation from incumbent contractors, defining agencies' responsibilities for information security during the transition, and the use of a transition inventory application developed by GSA. To resolve these challenges, GSA has, among other things, modified FTS2001 contracts to help ensure contractor cooperation, developed guidance to clarify information security responsibilities, and established support teams to assist agencies in using the inventory application developed by GSA. GSA's actions should reduce the likelihood that these challenges will hinder transition efforts.

section_title: Letter
paragraphs: The General Services Administration (GSA) is responsible for ensuring  that federal agencies have access to the telecommunications services and  solutions that they need to meet mission requirements. As federal agencies  have evolved in their use of telecommunications, so too has GSA’s  development of contracts to help support their needs. Currently, these  telecommunications contracts not only support agencies’ basic telephony  needs, but also provide an acquisition vehicle for wireless and satellite  services, as well as managed network services and information technology  (IT) security services. In fiscal year 2007 alone, federal agencies spent  approximately $960 million on services acquired through the contracts  under GSA’s current telecommunications program, known as FTS2001.  The FTS2001 contracts are set to expire by June 2010.
In preparation for the end of its current telecommunications contracts,  GSA developed a successor program, known as Networx, and awarded  telecommunications contracts under this program in March and May 2007.  Agencies must now undertake the difficult task of transitioning their  telecommunications services to the Networx contracts. This transition will  involve more than 135 agencies, about 50 types of services, and thousands  of voice and data circuits. It could be the largest telecommunications  services transition ever undertaken by the federal government and will  require coordination among agencies, GSA, and a host of  telecommunications contractors.
This report responds to your request that we determine (1) the extent to  which federal agencies are following sound transition planning practices  and (2) the actions GSA is taking to identify and resolve common  transition challenges affecting agencies.
To determine the extent to which agencies are following sound transition  planning practices, we selected six agencies for review from those that  incurred FTS2001 charges in excess of $1 million for fiscal year 2006. We  selected agencies that would ensure a representation of (1) executive  departments, subagencies, and independent agencies; (2) varying levels of  attendance in the Transition Working Group, an agency forum that is  assisting GSA in its efforts to plan for the transition; and (3) a range of  agency spending for FTS2001 in excess of $1 million. Based on these  criteria, we selected the Departments of Homeland Security, Commerce,  and Agriculture and the Small Business Administration, U.S. Army Corps  of Engineers, and U.S. Nuclear Regulatory Commission. We then obtained  and reviewed documentation (including strategic plans,  telecommunications inventories, and transition-related plans) and  interviewed officials from each of the selected agencies. We assessed this  agency information against sound telecommunications transition planning  practices that we identified in a report issued in 2006. In that report, we  stated that organizations preparing for a telecommunications transition  should    establish a telecommunications inventory,   perform a strategic analysis of telecommunications requirements,   establish a structured transition management approach,   develop a transition plan.
Each of these sound planning practices consists of various components  (for example, developing a transition plan consists of (1) identifying and  documenting objectives and measures of success, (2) determining risks  that could affect success, and (3) defining transition preparation tasks and  developing a time line for these tasks). For the current report, we  classified the status of agency transition planning efforts to address the  practice components as “fully implemented,” if the agency has fully  implemented the sound practice component; “plans to fully implement,” if  the agency has plans to fully implement the component; or “no plans to  fully implement,” if the agency does not have plans to fully implement it.  We discussed our assessments with agency officials and made adjustments  as appropriate.
To determine actions that GSA is taking to identify and resolve challenges,  we analyzed transition guidance and other Networx documentation  developed by GSA and the Interagency Management Council’s Transition  Working Group, such as presentations, meeting minutes, projected time  lines, and a pre-award transition guide. We also interviewed officials from  GSA, FTS2001 incumbent vendors, Networx vendors, and the six agencies  selected for review.
We conducted this performance audit from September 2007 through June  2008, 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. A detailed discussion of  our objectives, scope, and methodology can be found in appendix I.
subsections: section_title: Background
paragraphs: GSA’s existing FTS2001 program is the successor to a line of programs  that have provided long-distance telecommunications to the federal  government. Made up of two large governmentwide contracts—one  awarded to Sprint in December 1998 and one awarded to MCI in January  1999—the program is designed to meet agency needs for various  telecommunication services. It also includes contractors that had been  awarded local telecommunications contracts for selected metropolitan  areas. GSA allowed these contractors to also offer long-distance services  on the FTS2001 contracts—termed “crossover contracts.”
The original terms of the two FTS2001 contracts were set to expire in  December 2006 and January 2007. However, to give itself time to finalize  the contracts intended to succeed the FTS2001 contracts and to provide its  customer agencies additional time to complete their transitions once the  Networx contracts were awarded, GSA negotiated sole-source contracts  (termed FTS2001 bridge contracts) with Sprint and MCI to provide  continuity of service for agencies. These bridge contracts, which extend  the terms of the FTS2001 contracts for no more than 42 months, began in  December 2006 and January 2007 and are to expire at the end of May and  June 2010, respectively.
In October 2003, GSA announced its plans for the Networx program. In  conjunction with a group of senior federal information resource officials  known as the Interagency Management Council (IMC), GSA identified  eight strategic goals for the program:    Service continuity—Contracts should include all services currently  available under FTS2001 to facilitate a smooth transition.
Competitive prices—Prices should be better than those available  elsewhere in the telecommunications marketplace.
High-quality service—Contracts should ensure a high quality of service  throughout the life of the contracts using enforceable agreements.
Full service vendors—Vendors should be capable of providing a broad  array of services and provide follow-on services to avoid duplication of  administrative and contracting costs.
Alternative services—Agencies should be able to choose from a greater  number of competing vendors that provide new, enhanced services and  emerging technologies.
Transition support—Contracts should include provisions that facilitate  transition coordination and support.
Performance-based contracts—Contracts should be performance based  and include service-level agreements where possible.
Operations support—GSA should provide fully integrated ordering, billing,  and inventory management.
In addition, GSA identified goals specific to the Networx transition and  indicated that the ability of GSA and the Networx contractors to deliver  against these goals is essential to the overall success of the transition  effort. These goals include  transitioning telecommunications services before the FTS2001  contracts expire,    expediting the availability of new services, and   minimizing transition expenses.
Under the Networx program, GSA awarded two multiple-award task and  delivery order contracts—Networx Universal and Networx Enterprise— having a combined estimated value of $20 billion. The contracts were  awarded in March and May 2007, respectively.
GSA awarded Networx Universal contracts to AT&T, Verizon Business  Services, and Qwest Government Services. Networx Universal offers voice  and data services, wireless services, and management and application  services, including video and audio conferencing, as well as mobile and  fixed satellite services, with national and international coverage.
GSA awarded Networx Enterprise contracts to AT&T, Verizon Business  Services, Qwest Government Services, Level 3 Communications, and  Sprint Nextel. Networx Enterprise offers services similar to those of  Networx Universal, with a focus on those that are Internet-based, and does  not require coverage of as large a geographic area as does Networx  Universal.
subsections: section_title: Transition Responsibilities
paragraphs: Central to the successful transition from FTS2001 to Networx are  transition planning and execution activities that involve GSA, the agencies,  and FTS2001 and Networx contractors. GSA serves as a facilitator for all  transition management activities and is using contracted support to assist  in tracking transition activities in order to avoid delays and other problems  that can arise throughout the process.
GSA’s primary responsibility is program management of both the FTS2001  and Networx programs. As part of this, GSA is responsible for    providing guidance and assistance to agencies for the transition to  Networx to ensure that unnecessary delays in agency transitions are  avoided;    developing an overall Networx transition strategy, minimizing agency  transition costs, and ensuring that all telecommunications services are  transitioned in a timely manner; and  tracking daily progress of transition efforts, performing program-level  analysis to support transition goals and objectives, and resolving  transition issues.
The GSA organization carrying out these responsibilities is the Federal  Acquisition Service, an organization formed in 2006 from the merger of  GSA’s Federal Technology Service, which had managed the FTS2001  program, and GSA’s Federal Supply Service.
To assist agencies with their transitions from the FTS2001 contracts, GSA  is working with representatives of federal agencies, both directly and  through the IMC. A subgroup of the IMC, the Transition Working Group  (TWG), was established in May 2004 to assist with developing a consensus  on common transition issues that affect multiple agencies. The TWG  coordinates with GSA, agencies, and industry partners to ensure thorough  advance planning and preparation efforts for the transition to Networx.  The TWG also serves as a conduit for communications among GSA and its  customer agencies.
GSA’s customer agencies—those federal agencies acquiring services  through the FTS2001 program—have principal responsibility for the  transition. These agencies are responsible for coordinating transition  efforts with the incumbent and Networx contractors to ensure that  existing services under FTS2001 are disconnected and that new services  are ordered. GSA and the IMC have requested each of the customer  agencies to appoint a transition manager and establish a transition team  that will    manage the agency’s internal transition planning, preparation, and    be responsible for interfacing with GSA, the IMC, and officials within  the agency.
Both the Networx contractors and incumbent FTS2001 contractors are  responsible for supporting agencies in their transition planning and  execution efforts:    Networx contractors will be responsible for delivering services ordered,  developing program-level and agency-level transition plans, and  communicating the status of transition activities with scheduled notices  and reports.
Incumbent FTS2001 contractors are expected to complete all FTS2001  service disconnect orders requested by agencies and assist agency efforts  to prepare for the transition by, for example, helping to identify inventory  information and system requirements.
section_title: GSA and Agencies Have Taken Steps to Address Difficulties Encountered in a Previous Transition
paragraphs: The previous transition of federal telecommunications services was a large  and complex task that underscored the importance of proper transition  management practices. In 2001, we reported that the transition to the  current FTS2001 federal telecommunications contracts encountered  delays and took more than 24 months, which hindered the timely  achievement of program goals. We also reported that transition delays  resulted in raised telecommunications costs. In total, an estimated $74  million in savings was lost due to delays in completing the transition to  FTS2001.
Subsequently, the TWG, in conjunction with GSA, identified 27 lessons  learned from the previous transition. For example, lessons learned include  (1) the need for GSA and agencies to identify funding for the transition  early to ensure that resources are available and (2) the need to ensure that  local agency sites are not responsible for delays due to access issues. Of  the 27 lessons learned, 13 related to transition planning, 11 to transition  execution, and 3 to transition monitoring. Together, the lessons learned  affirmed that applying adequate transition practices—including planning,  executing, and monitoring the transition—increases the likelihood of a  successful transition from FTS2001 contracts to Networx.
GSA and representatives of its customer agencies have taken actions to  address these lessons learned. For example, to address funding for the  transition, GSA and the TWG developed a Taxonomy and Allocation of  Transition Costs document, which the IMC approved, that describes each  type of transition cost and whether GSA or the agency would be  responsible. And to help ensure that local agency sites are not responsible  for delays, GSA has provided guidance to agencies on creating staffing and  training plans to better ensure that those involved are prepared for the  transition effort.
GSA has also developed numerous guidance documents and presentations  related to the transition, as well as several tools. Much of this information  is maintained by GSA in two locations on the Internet—its public Web site  at www.gsa.gov/networx and a Web site accessible only to agency  transition managers and TWG members. Documentation developed  includes, for example, a guide to assist agencies in selecting the vendor  best suited to provide required services while giving all vendors fair  opportunity to be considered for each order—known as the fair  opportunity process. GSA has also developed numerous presentations on  the transition from FTS2001 and briefings presented to agency transition  managers. Further, GSA has developed tools specifically designed to aid  agencies as they transition to Networx, such as a transition inventory  application to help agencies identify and validate their transition  inventories and a tool that agencies can use to price their services against  the various Networx contract offerings.
section_title: GSA Has Provided Agencies Incentives to Transition Early
paragraphs: With GSA’s FTS2001 contracts set to expire by June 2010—within the next  2 years—agencies have a limited time frame within which to complete  their transitions (see fig. 1). As mentioned earlier, the FTS2001 bridge  contracts expire in May and June 2010. In addition, GSA’s FTS2001  crossover contracts with Qwest, Verizon, AT&T, Winstar Communications,  and SBC will expire between January 2008 and May 2010. Therefore,  agencies have approximately 2 years to transition all FTS2001 services  before all FTS2001 contracts expire. Figure 1 depicts these expiration  dates.
To address the approaching expirations, GSA is taking several actions.  First, to provide an incentive to transition early, GSA and the IMC agreed  upon milestones and associated criteria that, if met, would allow agencies  to be reimbursed by GSA for certain transition-related costs. Second, in  meetings with agency Chief Information Officers, GSA has emphasized the  importance of conducting an efficient and timely transition as well as  garnering executive-level buy-in for transition support. Third, GSA’s  Technology Service Managers have been in contact with agencies to  ensure that they are working toward transitioning their FTS2001 services.  Fourth, the collection of GSA documents, presentations, and tools is  geared toward assisting agencies in planning and executing their  transitions.
Specifically, to qualify for reimbursements, an agency must comply with  the following milestones (fig. 2 depicts these milestones against the  transition time line):    By September 30, 2008, agencies are to complete “fair opportunity”  decisions—that is, select their vendors—for all services to be transitioned  from FTS2001 telecommunications contracts.
By January 1, 2010, agencies must submit all transition orders that will  incur costs related to parallel operations. GSA will not reimburse any  costs for parallel operations an agency orders after this date.
By April 1, 2010, agencies must submit all transition orders. GSA will not  reimburse any costs for transition orders an agency places after this date.
section_title: Our Prior Work Has Addressed Telecommunications Transition Planning
paragraphs: We have issued several reports on issues surrounding GSA’s FTS2001 and  Networx telecommunications programs. Specifically, we reported on  difficulties encountered during the previous transition, agency preparation  for the transition to Networx, sound transition planning practices, and  GSA’s cost estimation for the transition to Networx.
In 2001, we reported on difficulties encountered during the transition to  the FTS2001 program. We found that the collective effect of delays  encountered during this complex transition jeopardized the timely  achievement of FTS2001’s program goals. Delays occurred for several  reasons. For example, delays occurred because agency efforts to order  services were impeded by the inability of GSA and the long-distance  contractors to rapidly add, through a contract modification process,  transition-critical services to the FTS2001 contracts. Other identified  reasons for transition delays included that agencies were slow to place  orders for transition services and that contractors had issues with staffing  and billing that impaired their efforts to support agencies’ transition  activities. We also reported that encountered delays would, among other  things, cause agency telecommunications costs to rise.
In 2006, we reported on sound transition planning practices that agencies  could use to improve the likelihood of a smooth transition. These  planning practices are to    establish a telecommunications inventory,   perform a strategic analysis of telecommunications requirements,   establish a structured transition management approach,   develop a transition plan.
Each of these sound planning practices consists of various components  (for example, developing a transition plan consists of (1) identifying and  documenting objectives and measures of success; (2) determining risks  that could affect success; and (3) defining transition preparation tasks and  developing a time line for these tasks).
We assessed the progress of six agencies in preparing for the transition  and reported that although agencies were early in the planning process,  they were generally planning to employ sound transition planning  practices in their transition management efforts. However, officials at two  of the agencies stated that they did not plan to fully identify necessary  resources. Specifically, officials at the Department of Justice indicated  that they would not need additional financial resources, even though they  could not provide an analytical basis for their decision, and officials from  the Department of Energy believed that because the agency’s transition  would be straightforward, identifying human capital needs would not be  necessary. We also reported that GSA had provided agencies with  guidance on performing some but not all of the sound transition planning  practices we identified.
As a result, we recommended that  the Attorney General ensure that the Department of Justice’s planning  efforts include an analysis of the extent to which current financial  resources would be sufficient to conduct an effective transition;  the Secretary of Energy ensure that the department’s planning efforts  included identification of human capital resources needed to conduct  an effective transition; and  the Administrator of General Services, in working with the IMC,  develop and distribute guidance to ensure that our identified sound  practices for transition planning were used.
In response, the three agencies took action or indicated that they planned  to take action to implement our recommendations. The Department of  Justice’s Chief Information Officer indicated that the department intended  to analyze and determine its financial and other resource requirements for  transition in the near future. However, as of April 1, 2008, it had not yet  done so. The Department of Energy provided a transition plan that  indicated that the need for human capital resources for the transition  would be dependent on the Networx contractor or contractors chosen;  once contractors were selected, the agency planned to re-examine its  human capital needs to ensure that adequate support would be provided  for transition execution. Finally, GSA provided guidance to agencies that  addresses our identified sound transition planning practices.
In 2007, we reported on GSA’s development of cost estimates for the  transition to Networx, stating that while it had adequate funding to  support its anticipated transition costs, it did not use sound analysis when  developing its estimate. Accordingly, to ensure that future cost estimates  by GSA were sound and could be used as a reliable basis for decisions, we  recommended that the Administrator of General Services establish an  agencywide policy requiring that cost estimates be developed using best  practices. In addition, we recommended that the Administrator revise the  transition cost estimate for Networx using best practices after the award  of contracts under the Networx program.
To address these recommendations, GSA established an agencywide  policy requiring that its cost estimates be developed using best practices.  Regarding the revision of its transition cost estimate, GSA officials  indicated that once a significant number of agencies have made their fair  opportunity decisions, it will recalculate the transition cost estimate, brief  the IMC, and provide the results to us. Officials stated that GSA will brief  the IMC in June 2008 on the revised transition estimate.
section_title: Selected Agencies Are Generally Following Sound Transition Planning Practices
paragraphs: The selected agencies are generally following the sound  telecommunications transition planning practices that we identified in our  2006 report. For example, all have established telecommunications  inventories for conducting their transitions, and all have ensured that  identified telecommunications needs and opportunities are aligned with  their respective missions, long-term IT plans, and enterprise architecture  plans. However, key practices are not being fully implemented at three  agencies: Commerce, Homeland Security, and the U.S. Nuclear Regulatory  Commission. Officials of these agencies provided various reasons for not  following these practices, including reliance on other entities and  processes to carry them out. For example, for the key practice of  establishing a structured transition management approach, one of the  practice components is identifying key local and regional transition  officials and points of contact who are responsible for disseminating  information. Homeland Security did not plan to identify such local and  regional points of contact; officials stated that when telecommunications  changes occur, the department will rely on processes already in place to  convey information through departmental channels to local contacts.
However, in view of the potentially large number of locations and short  time frames involved in the transition, relying on the standard process  could be risky. If Homeland Security does not identify all of its local points  of contact before it begins transitioning services, communication  difficulties could produce delays in providing the required site access for  vendors (such delays occurred during the previous transition). Agencies  that do not address such gaps in transition planning and follow through on  their plans risk delaying their transitions and increase the likelihood that  the government will incur unnecessary costs.
subsections: section_title: Agencies Have Identified Transition Inventories, but Processes for Maintaining Them Are Not Yet in Place
paragraphs: As described in our 2006 report, sound transition planning practices  include establishing an accurate inventory of current telecommunications  assets and services. First, agencies should have a detailed and complete  transition inventory that represents all of their facilities, components, field  offices, and any other managed sites. It should include information such as  telecommunications services, traffic volumes, equipment, and applications  being used. Second, agencies should have a documented inventory  maintenance process that can be used to ensure that inventories remain  current and reflect changes leading up to, during, and after the transition.  Once established, an inventory maintenance process can ensure that  changes are captured and allow agencies to audit vendor bills against their  inventories throughout the life of the contract.
Agencies should begin efforts to establish a telecommunications inventory  early because the development of an accurate and reliable inventory is  important to ensuring that the agency will be prepared to transition  quickly. Agencies can use their transition inventories to identify  opportunities for optimizing their current technology during strategic  planning and to help determine areas for optimization and/or sharing of IT  resources across the agency.
Table 1 summarizes the extent to which transition planners have  established telecommunications inventories at the U.S. Army Corps of  Engineers (ACE), Department of Homeland Security (DHS), Department  of Commerce (DOC), U.S. Nuclear Regulatory Commission (NRC), Small  Business Administration (SBA), and U.S. Department of Agriculture  (USDA).
As the table shows, all agencies have addressed the first of the two  components of this practice. All six identified telecommunications  inventories that are sufficient for conducting their transitions. Those  agencies with established telecommunications transition inventories are  likely to be better prepared to address strategic considerations and avoid  unnecessary transition delays associated with inventory identification.
However, four of the six agencies had not documented a process to  maintain their inventories to ensure that they remain current, although  three had developed plans to do so:    Agriculture and Commerce have drafted inventory maintenance processes.
NRC’s transition manager stated that the agency plans to develop a  maintenance process as part of its efforts to establish an expense  management system.
Homeland Security does not plan to develop such a process. Homeland  Security’s transition manager stated that the department did not have a  documented inventory maintenance process or policy at its headquarters or  any of its components. The transition manager stated that the department has  instructed its components to maintain their inventories. However, there was  no documentation of this instruction, and the department did not have plans  to document a maintenance process. Without a documented inventory  maintenance process, agencies may not consistently and accurately capture  the changes to their telecommunications inventories during and after  transition, hindering their ability to ensure that they are billed appropriately  by the vendor or to determine areas for optimization and sharing of  telecommunications and IT resources across the agency.
section_title: Half of the Agencies Have Incorporated Strategic Needs into Transition Planning
paragraphs: Sound transition planning practices, as described in our earlier work,  include identifying strategic telecommunications requirements and  incorporating them into transition planning. To accomplish this, agencies  should use an inventory of existing services to determine current and  future telecommunications needs. Agencies should also use the transition  as an opportunity to identify areas for optimization or sharing of  telecommunications and IT resources across the agency. The costs and  benefits of introducing new technology and alternatives for meeting the  agency’s telecommunications needs should be evaluated. Further, the  identified needs and opportunities should be aligned with the agency’s  mission, long-term IT plans, and enterprise architecture plans. The  agency’s telecommunications requirements should shape the agency’s  management approach to the transition and guide other efforts, such as  identifying and allocating resources and developing a transition plan.
Table 2 summarizes the extent to which the six agencies have performed a  strategic analysis of telecommunications requirements.
As the table shows, all six agencies have addressed the second of the two  components of this practice: all have determined that needs and  opportunities are aligned with their missions, long-term IT plans, and  enterprise architecture plans. However, only half (Agriculture, ACE, and  SBA) have fully implemented the other component: identifying current and  future telecommunications needs, areas for optimization and sharing, and  the costs and benefits of any options. One agency (Commerce) has plans  to fully implement this component. That is, Commerce has determined its  current and future telecommunications needs and, according to officials,  plans to identify areas for optimization and sharing, as well as costs and  benefits, before completing the fair opportunity process.
However, two agencies (NRC and Homeland Security) do not have plans  to fully implement this practice:    NRC had identified current and future needs and established long-term  plans to meet those needs, but it does not plan to evaluate the costs and  benefits of alternatives to meeting its telecommunications needs for this  transition. NRC officials stated that they plan to transition only existing  services, and alternatives would not be evaluated until after transition.
Although Homeland Security’s transition plans address strategic needs, the  department did not evaluate the costs and benefits of new technology or  alternatives for meeting its telecommunications needs. Homeland Security  officials stated that they felt this activity was not appropriate because they  did not have the choice not to transition to Networx.
Without assessing the costs and benefits of alternatives for meeting their  needs, NRC and Homeland Security may not be taking full advantage of  the transition as an opportunity to optimize their telecommunications  services, such as by upgrading and optimizing their telecommunications  services, or shifting service to more cost-effective technology. Further, if  agencies do not incorporate strategic requirements into their planning,  they risk making decisions that are not aligned with their long-term goals.
section_title: Most Agencies Have Developed or Plan to Develop a Structured Transition Management Approach
paragraphs: The sound transition planning practices that we identified in our earlier  work include establishing a structured transition management approach.  This entails establishing a transition management team involved in all  phases of the transition and clearly defining responsibilities for key  transition activities, such as project management, asset management,  contract and legal expertise, human capital management, and information  security management. The agency should also ensure a comprehensive  understanding of the transition by identifying those who will be involved  and how transition plans, including transition objectives, will be  communicated. This also involves communicating what is going to happen  and when, such as the frequency of status updates and meetings, and  should include alerting and educating end users to changes or disruptions.  Key local and regional transition officials and points of contact should be  identified who are responsible for disseminating information to employees  and working with the vendor to facilitate transition execution.
In addition, the agency should ensure that it uses established project  management, configuration management, and change management  processes during the transition. Project management processes can be  used to plan and manage transition-related activities, providing a structure  that incorporates performance measurement and project-level control.  Configuration management processes help ensure integrity and  traceability as change occurs. Change management processes help  employees prepare for the procedure and technology changes that may  accompany a transition, reducing the risk that improvement efforts will  fail.
Table 3 summarizes the extent to which the six agencies have established  a structured transition management approach.
With regard to the first component of this practice, one agency (ACE)  established a transition management team and defined all key transition  roles and responsibilities; the remaining five agencies have established  management teams, but have yet to define all roles and responsibilities.
Specifically, three agencies had not yet defined responsibilities for certain  roles, but planned to do so:    Agriculture had not defined the role of legal expertise in its transition  efforts, but it has requested support and was awaiting a response from its  Office of General Counsel.
SBA had yet to define responsibility for asset management, but officials  indicated that they plan to do so.
NRC had yet to define responsibility for information security management,  but officials indicated that they planned to do so.
The remaining two agencies did not plan to fully implement this sound  practice component:    Commerce officials stated that the responsibilities for asset and human  capital management will rest with the department’s transition manager  and each individual component; therefore, the department did not plan to  define responsibilities for these roles.
Homeland Security officials stated that roles such as asset management,  legal expertise, human capital management, and information security  management would not be assigned by name because expertise in these  areas would be available as needed.
However, by not defining key roles and responsibilities for the transition,  these agencies risk extending their transition period as they attempt to  assign appropriate personnel and update them on transition progress and  issues.
With regard to the second component of this practice, one agency (SBA)  identified communications plans and local and regional points of contact.  Four additional agencies plan to fully address this sound practice  component. Specifically:    Agriculture developed a communications plan, and its transition plans  indicated that it will identify transition points of contact by the end of  fiscal year 2008.
Commerce officials stated that they plan to develop transition and  communications plans that will include transition points of contact.
A contractor supporting ACE’s transition is required to develop a  communications plan, and the ACE transition plan indicates that the  contractor is in the process of identifying transition points of contact.
NRC officials stated that they plan to develop a communications plan as  part of the agency’s transition plan, which is to include transition points of  contact.
However, one agency (Homeland Security) does not plan to fully  implement this sound practice component. Specifically, although it has  established lines of communication, it had not identified local and regional  points of contact to facilitate transition execution, because, according to  department officials, when telecommunications changes occur, the  department has a process in place to convey information through  departmental channels to local contacts, and officials believe that this  process will be adequate for any changes that are part of the transition.  However, in view of the potentially large number of locations and short  time frames involved in the transition, relying on the standard process  could be risky. If Homeland Security does not identify all of its local points  of contact before it begins transitioning services, communication  difficulties could produce delays in providing the necessary site access for  vendors (such delays occurred during the previous transition).
With regard to the third component of this practice, ACE is the only  agency currently using all three key management processes—project  management, configuration management, and change management  processes—in the management of its transition, but the other five agencies  were using at least one of these management processes and planned to use  all three. Officials at the five agencies generally provided policies or other  documents indicating that all three processes would be used or stated that  they planned to implement those not yet in use.
Agencies that do not use a sound management approach risk additional  financial costs, extended time lines, and disruptions to the continuity of  their telecommunication systems. Further, without establishing lines of  communication and identifying local and regional points of contact,  agencies may lack the quality of information that is necessary for  comprehensive understanding, accountability, and shared expectations at  all levels.
section_title: Most Agencies Have Identified or Plan to Identify Resources Necessary for the Transition
paragraphs: Our sound transition planning practices include ensuring that the  resources required to successfully plan for the transition are identified. To  do so, the agency should identify any funding requirements for its  transition planning efforts to ensure that resources needed are available.  The organizational need for investments should be identified and the  agency should assess benefits versus costs to justify any resource  requests. Cost-benefit analyses and return-on-investment calculations are  common methods used to justify requests. Transition planning costs that  should be considered include transition project management, software and  hardware upgrades, and establishing reliable inventories.
The agency should also determine staffing levels that may be required  throughout the transition effort, as well as ensure that personnel with the  right skills are in place to support the transition effort. As mentioned  earlier, some of the skills needed are project management, asset  management, contract and legal expertise, human capital management,  and information security expertise. Further, the agency should require  training for those carrying out the transition or operating and maintaining  newly transitioned technology.
Identifying the need for resources early in the planning process is likely to  help to avoid unnecessary spending and delays during the transition.  Further, the resources allocated to the transition effort should reflect the  level of change identified in the agency’s strategic analysis of  telecommunications requirements; that is, if the agency chooses to  implement new technology, it must budget resources accordingly.
Table 4 summarizes the extent to which the six agencies have identified  resources for their transitions.
As table 4 shows, three agencies addressed the first component of this  practice, having identified the level of funding needed to support transition  planning efforts and justified organizational resource requests. However,  three did not: Homeland Security, NRC, and ACE did not address funding  requirements for their transition planning efforts before planning their  transitions and, among other things, identifying inventories. Instead, the  three agencies moved forward with performing transition planning using  existing resources without having analyzed the sufficiency of these  resources. At this late point in the planning process, performing such an  analysis is no longer feasible.
With regard to the second component, two agencies (SBA and Agriculture)  have identified staffing levels that will be needed throughout the  transition, and three plan to do so. ACE and Commerce provided evidence  of efforts under way to identify staffing resources that will be needed, and  NRC officials stated that they plan to address staffing levels in the agency’s  transition plan.
Homeland Security indicated that although staffing specific to the  transition effort was not identified, staffing for the transition was taken  into consideration as part of the department’s acquisition for a wide-area  network under Networx. However, Homeland Security did not provide  documentation to demonstrate that this sound practice component had  been addressed. Without determining staffing needs for its transition  effort, Homeland Security risks underestimating the complexity and  demands of the transition, which may lead to delays and unexpected costs.
As the table shows, three agencies have fully implemented the third  component: Homeland Security, ACE, and SBA have required training for  those involved in the transition. Of the remaining agencies, Commerce has  a draft policy requiring those involved with the transition to meet certain  training requirements, and a draft Agriculture transition plan indicated  that training requirements will be addressed. NRC officials stated that they  plan to identify training requirements in the agency’s transition plan.
As illustrated by lessons learned from the previous transition, agencies  that do not fully analyze their transition-related resource needs may be  underestimating the complexity and demands of the transition effort.  Further, unexpected costs may arise that lead to delays and unnecessary  spending that could have been avoided.
section_title: The Agencies Have Generally Established Transition Plans, but None Have Established Measures of Success
paragraphs: The sound transition planning practices we identified include developing a  transition plan that identifies transition objectives, measures of success,  and risks, and that approaches the transition planning process as a critical  project with a detailed time line. To facilitate this practice, agencies’  transition management teams should undertake the following three  activities:    The agency should identify transition objectives and measures of success.  Transition objectives should be based on the agency’s strategic analysis of  telecommunications requirements and aligned with the agency’s overall  mission and business objectives. Measures of success should be based on  these transition objectives. They are a key tool to help managers assess  progress.
The agency should identify agency-specific risks that could affect  transition success. The importance of the risks should be evaluated  relative to the agency’s mission-critical systems and continuity of  operations plans. Knowing what risks exist and how to mitigate them  appropriately will lessen problems and delays during the transition. This  risk assessment should also include an analysis of information security  risks to determine what controls are required to protect networks and  what level of resources should be expended on controls.
The agency should develop a transition plan that depicts a management  strategy with clearly defined transition preparation tasks and includes a  time line that allows for periodic reporting. This time line should take into  account priorities relative to the agency’s mission-critical systems,  contingency plans, and identified risks.
Table 5 identifies the extent to which the agencies have developed plans  for the transition.
Four of the agencies have plans to fully implement the first component of  this sound practice, with three having documented agency-specific  transition objectives and the remaining planning to do so. And while none  had yet established measures of success, officials at all four stated that  they plan to do so. However, NRC and Homeland Security do not plan to  fully address this component.
Although NRC officials stated that they plan to establish transition  objectives, they do not plan to establish measures of success. Instead of  establishing measures to assess progress toward agency goals, NRC  officials stated that they plan to use GSA-established measures related to  governmentwide transition progress.
Homeland Security officials stated that transition goals were discussed,  but evidence was not provided, and the department had no plans to  establish measures of success. Without documenting objectives for the  transition, Homeland Security may find it difficult to provide those  involved in the transition with clear expectations.
Those agencies that do not establish measures of success based on  documented objectives will lack information that could be used to track  progress toward transition objectives and inform management decisions.
Five agencies plan to fully implement the second component of this sound  practice: identifying agency-specific risks that could affect transition  success. Specifically, for ACE, Agriculture, and Commerce, the agencies’  transition plans indicate that agency-specific transition risks will be  identified. For SBA, a memorandum indicated that a formal risk  assessment will be performed before the transition to Networx. For NRC,  officials stated that risks will be addressed in the agency’s transition plan  and that information security risks will be addressed during the agency’s  fair opportunity process.
One agency, however, did not have plans to fully address this sound  practice component. Homeland Security performed a high-level risk  assessment, but this assessment did not address risks to mission-critical  systems, continuity of operations plans, or information security risks,  which are key components of this practice. Homeland Security officials  stated that information security risk assessments will be performed in  accordance with federal requirements, but they do not intend to identify  information security risks specific to their transition effort. If they do not  analyze risks relevant to the transition, agencies may encounter problems  and delays during the transition because they are not adequately prepared  to mitigate risks.
Four of the agencies fully implemented the third step of this practice,  having transition plans that depicted a management strategy with clearly  defined transition preparation tasks and included a time line that allowed  for periodic reporting. The remaining two agencies’ transition plans  indicate that they will fully implement this sound practice component.
Agencies that do not document measurable objectives and clearly define  transition tasks that take into account agency priorities and risks may find  it difficult to provide those involved in the transition with clear  expectations or gauge transition success. Specifically, without measurable  objectives, managers will lack information that could be used to track  progress toward transition objectives and inform management decisions.
section_title: GSA Is Taking Action to Identify and Resolve Common Transition Challenges
paragraphs: GSA is working with agencies and various forums to identify and resolve  transition challenges facing agencies in making the transition to the  Networx contracts. In working with agencies and vendors through such  forums as the Interagency Management Council’s Transition Working  Group, and a transition help desk, GSA has identified challenges related to  incumbent contractor support during the transition, defining  responsibilities of agencies during the transition to ensure information  security compliance, and use of a transition inventory application  developed by GSA. To resolve the challenges, GSA has, among other  things, modified incumbent FTS2001 contracts to help ensure contractor  support during the transition, developed guidance to clarify agencies’  information security responsibilities, and established support teams to  assist agencies in using the inventory application developed by GSA.
subsections: section_title: GSA Is Working through Various Forums to Identify Common Transition Challenges
paragraphs: As the lead agency for the Networx transition, GSA is responsible for  ensuring that unnecessary delays in agency transitions are avoided, as well  as minimizing agency transition costs and ensuring that all  telecommunications services are transitioned in a timely manner. As part  of its efforts to address its transition responsibilities, GSA is using various  forums to identify transition challenges:    Transition Working Group (TWG)—A subgroup of the Interagency  Management Council, TWG was created in May 2004 and serves as the  primary avenue through which common transition challenges affecting  agencies are identified. TWG is a bi-weekly forum for agency  representatives. It promotes collective government planning related to the  transition and assists with developing a consensus on common issues that  affect multiple agencies.
Direct interaction with individual agencies—GSA interacts directly with  agencies to provide them with individual assistance related to its various  contract offerings, including FTS2001 and Networx. GSA has Technology  Service Managers who are assigned to specific agencies to serve as single  points of contact for GSA’s contract offerings and provide support to  agencies for, among other things, selection, ordering, implementation, and  maintenance of FTS2001 and Networx services. GSA indicated that  agencies can contact their Technology Service Managers to raise  challenges specific to their agency. In addition to the Technology Service  Managers, GSA’s Director of Network Services Programs has been meeting  individually with agency Chief Information Officers and other executive- level leadership to educate them on the benefits of Networx and prepare  for the transition from FTS2001.
Regular interaction with vendors—GSA interacts with vendors in a  number of ways, including regular meetings, vendor-required reporting to  GSA, and GSA-initiated information requests. Specifically, GSA meets  regularly with FTS2001 and Networx vendors (as often as weekly) to  facilitate information sharing and to identify and resolve concerns or  challenges. Vendors are also required to submit monthly status reports to  GSA as well as provide quarterly program reviews. GSA has also requested  information from its vendors to address specific issues. For example, GSA  recently sent a request for information to the vendors to solicit strategies  for enabling agency compliance with a recent initiative by the Office of  Management and Budget (OMB) to improve governmentwide information  security by reducing the number of Internet connections.
Networx Help Desk—The help desk is a resource for agencies and GSA to  track and resolve agency-reported issues such as transition planning  concerns, assistance with GSA tools, and identification of transition  inventories. This help desk is part of GSA’s Transition Coordination  Center, a GSA-established team of GSA personnel and contractors tasked  with facilitating the transition to Networx. The help desk addresses  individual agency concerns or questions and develops weekly reports of  help desk tickets that are reviewed and tracked by GSA. Using these  tickets, GSA has created a knowledge database and identified frequently  asked questions that are available for review by agencies. GSA officials  stated that through the help desk they could likely identify vendors who  deliver services late or provide inadequate support during the transition.  As a result of GSA’s efforts, a number of challenges have been identified:  Incumbent contractor cooperation—The FTS2001 contracts lacked  requirements for the incumbent vendors to provide a certain level of  support to meet agencies’ needs during the transition to Networx.
Organizational conflicts of interest—Agencies found that they were unable  to use current contractors providing telecommunications support to assist  with the transitions to Networx if the particular contractors were also  subcontractors of a Networx vendor.
Information security compliance—Agencies did not have a clear  understanding of their responsibilities during the transition related to  existing information security requirements.
GSA transition inventory application—Agencies encountered difficulties  using an application developed by GSA to assist agencies in identifying  their transition inventories.
Agencies’ statements of work—Delays in the transition process could  result from statements of work developed by agencies that include unclear  requirements.
Contract modification process—Modifications to the Networx contracts  require time and effort of both GSA and the vendors and may extend the  amount of time required for an agency to transition.
OMB security initiative—The OMB initiative to reduce the number of  government Internet connections (mentioned previously) may require  agencies to revisit their Networx transition planning efforts.
Expansion of protest rights—Recent legislation permits protests of orders  above $10 million under multiple-award task and delivery order contracts  such as Networx; if an order is protested, it may delay an agency’s  transition.
More detail on these challenges is presented in the discussion following.
section_title: GSA Has Taken Action to Resolve Common Transition Challenges
paragraphs: GSA has taken various actions to resolve the identified common transition  challenges.
subsections: section_title: Incumbent Contractor Cooperation
paragraphs: In September 2006, TWG members expressed concern that FTS2001  incumbent vendor contracts did not include certain transition-related  provisions. Specifically, the contracts did not require FTS2001 incumbent  vendors to assist in the transition process by providing the ability for  agencies to “fall back” on the incumbent vendors’ services if a specific  transition effort encountered difficulties. Agencies requested clarification  on the level of effort required of the incumbent vendor to reestablish  agency telecommunications services until transition issues could be  remedied.
GSA modified the FTS2001 contracts, including the FTS2001 crossover  contracts, to address these issues. Specifically, all but two FTS2001  crossover contracts were modified to include requirements for incumbent  vendors to restore agency services in the event of problems with transition  to new services. (GSA officials indicated that the remaining two contracts  already included language to address this concern.) Modifications  included provisions for the incumbent contractors to make a reasonable  effort to promptly reactivate service if there was a problem with the  successor contractor’s service and it was necessary to fall back to the  incumbent’s service. In addition, modifications state that the incumbent  contractor’s point of contact should be available during scheduled  cutovers to handle fallback requests. The inclusion of these terms in the  FTS2001 contracts should help to reduce the risk that agencies’  telecommunications transitions will be disrupted by the lack of  cooperation by incumbent contractors, as well as help to ensure that  unnecessary delays are avoided if agencies encounter difficulties in  transitioning to a new contractor.
section_title: Organizational Conflicts of Interest
paragraphs: During a September 2007 meeting, TWG members identified a concern  regarding contractor organizational conflicts of interest. Specifically,  agencies found that they were unable to use certain current contractors  providing telecommunications support to assist with the transition to  Networx because these contractors were also subcontractors of Networx  vendors, and the agencies’ use of such a subcontractor could give a  Networx vendor an unfair competitive advantage. The Federal Acquisition  Regulation (FAR) calls for the exercise of good judgment to resolve a  potential organizational conflict of interest and requires appropriate action  to avoid, neutralize, or mitigate the potential conflict.
To address this challenge, GSA has modified Networx contracts to allow  agencies to use their existing contractor support within defined  boundaries. For example, the modification requires contractors supporting  an agency to (1) avoid situations with the risk of unauthorized disclosure  of information, (2) refuse to divulge information about the agency’s  program, and (3) report conflicts of interest. The modification also calls  for contractors to train their employees on the Procurement Integrity Act  and its penalties. Thus, GSA has established a framework for agencies and  contractors to follow that is intended to address potential or actual  organizational conflicts of interest. Agencies remain responsible for taking  steps to avoid, neutralize, and mitigate conflicts of interest in using  contractors.
section_title: Information Security Compliance
paragraphs: The TWG expressed concern that responsibilities related to the Federal  Information Security Management Act of 2002 were unclear. Specifically,  agencies were unsure of their responsibilities for information security  under Networx versus those of GSA and the vendors. For example,  agencies requested clarification on government responsibility to certify  and accredit the public network during transition and GSA’s information  security responsibilities as the agency providing the contract vehicle for  telecommunications services.
GSA, in consultation with OMB, has provided guidance to agencies that  addresses information security concerns for transition. Specifically, a GSA  briefing to agencies clarifies that agencies are responsible for determining  the impact of the transition on the certification and accreditation of their  systems. In addition, GSA clarified that its responsibilities, as the manager  of the contract vehicle, includes, among other things, reviewing contractor  security plans and reports in accordance with the provisions of the  contract; monitoring and resolving security issues during the life of the  contract; conducting post-award certification and accreditation of  contract awardees’ support systems; and conducting certification and  accreditation on GSA’s billing system related to Networx. GSA’s actions  should help ensure that information security during the transition will be  adequately addressed.
section_title: GSA Transition Inventory Application
paragraphs: The TWG indicated that agencies were having difficulties using an  application developed by GSA to validate their telecommunications  inventories for the transition. In January 2007, GSA created an initial  governmentwide inventory using FTS2001 vendor billing reports, with the  intention of using it to track transition status and aid agencies in planning  for their transitions. To assist in this effort, GSA required agencies to  validate their inventory using a GSA inventory application. As agencies  worked to validate these inventories, the TWG indicated that agencies  encountered difficulties with the application and that the process for  validating their inventories was not clearly defined.
To address this challenge, GSA has taken several actions. GSA has issued  user guidance for its inventory application and has briefed the TWG on the  inventory validation process. GSA has also established inventory  assistance teams to work with agencies to identify and validate their  inventories. These inventory assistance teams are assigned at the request  of an agency and include GSA personnel and contracted support staff.  From September to December 2007, inventory assistance teams worked  with 43 agencies to provide assistance with validating their inventories. As  a result, when GSA established a baseline in January 2008 of the  government’s inventory to be used to measure transition progress, federal  agencies had validated about 92 percent of the almost 4.1 million records  in the inventory. As a result of its actions, GSA has increased the chances  of a successful transition by helping to ensure that agencies have available  to them accurate inventory information.
section_title: Agencies’ Statements of Work
paragraphs: GSA and several of the Networx vendors identified concerns about the  quality of agency statements of work and possible delays as a result of  unclear statements of work. An agency will develop a statement of work  when its telecommunications requirements cannot be met using existing  offerings in the Networx contract. Since statements of work are particular,  those with unclear requirements could extend the time required for GSA to  review and determine whether a modification is necessary. According to  Networx vendors, an unclear statement of work may also require  additional time as they review it to clarify and understand agency  requirements. Lack of clarity may also result in an agency receiving  disparate proposals from vendors, which may not all meet the agency’s  particular needs. Finally, GSA officials stated that there are fewer  contracting staff (the personnel responsible for reviewing agency  statements of work) assigned to Networx than were assigned to FTS2001.  A limited number of staff may increase the amount of time needed for  GSA’s review of agency statements of work.
GSA is taking action to address concerns related to the quality of  statements of work. First, GSA has developed a “Fair Opportunity and  Statement of Work Guide,” intended to provide agencies with a set of  uniform ordering guidelines to obtain services under the Networx  contacts. This guide addresses the definition and documentation of agency  requirements, describes how to determine if a statement of work is  needed, and states that GSA has advisory and consulting services available  to agencies. Second, GSA officials stated that after an agency submits its  finalized statement of work to GSA, it is reviewed for possible legal,  pricing, contracting, management, and technical issues, as well as to  determine whether there are opportunities for the agency’s needs to be  met using existing Networx service offerings. If concerns or errors are  identified, the statement of work is rejected, the agency is briefed on the  cause of rejection, and the agency must revise its statement of work.  Finally, to address the limited number of contracting staff, GSA officials  stated that they plan to add additional staff to better facilitate the contract  review process. The actions being taken by GSA should help address  issues regarding the quality of statements of work developed by agencies  and submitted to vendors.
section_title: Contract Modification Process
paragraphs: Contract modifications require time and effort, from both GSA and the  vendors, to negotiate the terms of the modification and eventually extend  the amount of time required for an agency to transition. In addition to its  responsibility for overseeing the transition, GSA has administrative  responsibility for processing and authorizing contract modifications.  Modifications to the Networx contract are essential to allow agencies to  place orders against requirements that are within the scope of the  Networx contract, but that are not currently available as fixed price  contract items. Contract modifications can also be initiated (1) by a  vendor desiring to add or change specific service offerings or (2) as a  result of a Networx program need determined by GSA. Also, as previously  discussed, GSA officials stated that they have fewer personnel assigned to  Networx who are responsible for reviewing and incorporating contract  modifications than were assigned to the transition to FTS2001.
To address concerns with the contract modification process, GSA  identified existing and planned actions. First, the initial review of agencies’  statements of work is, in part, designed to identify whether a modification  is necessary. Second, GSA developed a contract modification guide to  inform those involved of the process for modifying contracts. Third, in  April 2008, it took steps to automate certain aspects of the contract  modification process. For example, contractors can now draft, submit, and  update contract modifications using an Internet-based application. In  addition, according to GSA officials, contractors can also use this  application to track the modification throughout the process. Last, the  previously mentioned planned increase in contract review staff will also  be used to facilitate the processing of contract modifications.
As a result of actions taken, GSA is making progress in meeting its goals  for processing contract modifications. Its “Fair Opportunity and Statement  of Work Guide” indicates that the majority of modifications should be  completed within 30 business days. As of May 2008, the time to complete a  contract modification varied from 1 business day to more than 106  business days; about 49 percent of its modifications had been made within  30 days. However, many of these took place before GSA had implemented  its automated contract modification tools. These tools and the other  actions GSA has taken have the potential to minimize contract  modification delays.
section_title: OMB Security Initiative
paragraphs: In November 2007, OMB issued a memorandum to improve  governmentwide information security. This initiative, called the Trusted  Internet Connections initiative, seeks to lessen information security risks  by reducing the number of Internet connections maintained by the  government. OMB has asked agencies to analyze and resolve any effects of  this initiative on, among other things, planning related to the agencies’ use  of the Networx contracts. Therefore, agencies may have to revisit their  Networx transition planning efforts if, for example, they find it necessary  to reconfigure their networks to enable the use of fewer Internet  connections.
In response to this initiative, GSA asked Networx vendors to identify  (1) how they can help agencies to meet the goals of the initiative and  (2) any concerns. GSA summarized the vendors’ feedback and on February  25, 2008, it presented the results to OMB, which is leading the initiative in  conjunction with Homeland Security. The summary indicated multiple  areas of support that vendors are willing to provide agencies, such as  assisting agencies in performing a complete inventory and discovery of all  agency Internet connections. In addition, it indicated that the Networx  contracts may need to be modified to allow vendors to offer several of  these services. GSA stated that detailed requirements for this initiative  have yet to be fully developed by Homeland Security and that, as of May 2,  2008, no specific modifications to existing Networx contract offerings  have been identified as necessary. GSA is, however, working with  Homeland Security to define detailed requirements for a new service  offering under Networx to provide a trusted Internet portal service; it  expects this service to be available to the agencies by November 2008. The  actions GSA is taking and has planned should help to ensure that the  Networx contracts can be used by agencies to address OMB’s Trusted  Internet Connections initiative.
section_title: Expansion of Protest Rights
paragraphs: Recent legislation permits protests of orders above $10 million under  multiple-award task and delivery order contracts such as Networx.  Beginning May 27, 2008, the recently enacted National Defense  Authorization Act for Fiscal Year 2008 authorizes bid protests of such  orders; previously, protests were authorized only when an order increased  the scope, period, or maximum value of the contract under which the  order was issued. The protest of an agency’s order may affect the time  available to the agency to complete its transition.
Although officials stated that the impact of this legislation on agency  transitions cannot be known at this time, GSA has briefed IMC members,  TWG members, and agency transition managers on this legislation. The  briefing provided information on the terms of the legislation, and informed  agencies of their expected responsibilities as well as GSA’s expected role.  For example, the briefing indicated that GSA may be asked to provide  input in the event of a protest, but the agency that issued the order would  have primary responsibility to defend the protest. In addition, GSA revised  its “Fair Opportunity and Statement of Work Guide” to reflect this new  legislation. Further, officials stated that they are responding to agency  questions, through the Networx help desk, regarding the bid protest  process. GSA’s actions have helped to inform agency transition officials of  their responsibilities and the impact this legislation may have on their  ordering process.
section_title: Conclusions
paragraphs: Transitioning federal telecommunications services is a large and complex  undertaking. The previous transition resulted in significant delays and  increased costs, taking more than 2 years to complete, which underscores  the importance of making necessary preparations before starting such an  effort. For the current transition, selected agencies are generally following  our sound transition practices, which should help them avoid some of the  delays experienced previously. However, Homeland Security, Commerce,  and NRC are not planning to fully implement key sound practices. Because  the period to conduct their telecommunications transitions is limited,  agencies will be better prepared if they consistently implement all of the  sound practices. If they do not, they risk being unable to complete their  transitions before the expiration of the FTS2001 contracts and increase the  likelihood that the government will incur unnecessary costs.
In managing its $20 billion Networx program, GSA has taken actions to  identify and resolve common transition challenges, including developing  guidance for agency statements of work and creating teams to assist  agencies in establishing transition inventories. These actions should help  to reduce the risk that challenges will lead to unnecessary transition  delays and costs for agencies. Going forward, GSA’s responsibility as  facilitator for the Networx transition will continue to require it to  proactively identify and resolve common transition challenges, complete  actions planned to resolve already identified challenges, and monitor  transition progress.
section_title: Recommendations for Executive Action
paragraphs: To reduce the risk that transition delays could lead to disruptions in  service and increased costs, we are making the following 10  recommendations:  We recommend that the Secretary of Commerce direct the department’s  Chief Information Officer to define the roles of asset and human capital  management for the department’s transition.
We recommend that the Chairman of the U.S. Nuclear Regulatory  Commission direct the commission’s Chief Information Officer to    establish measures of success based on the transition objectives that  the agency plans to develop and    evaluate the costs and benefits of new technology or alternatives to  meeting its telecommunications needs.
We recommend that the Secretary of Homeland Security direct the  department’s Chief Information Officer to address the gaps in its transition  planning. Specifically, the Chief Information Officer should    document the department’s processes for maintaining    evaluate the costs and benefits of new technology or alternatives to  meeting its telecommunications needs;    clearly define the roles of asset management, legal expertise, human  capital management, and information security expertise for the  department’s transition;  identify local and regional points of contact;  include in the department’s planning efforts the identification of human  capital resources needed to conduct an effective transition;    establish goals and measures of success for the department’s transition  efforts to help managers assess progress; and    perform a transition risk assessment that addresses risks to mission- critical systems, continuity of operations plans, and risks to  information security.
section_title: Agency Comments and Our Evaluation
paragraphs: In commenting on a draft of our report, three of the seven agencies  reviewed generally agreed with our report, and two agencies partially  agreed. GSA, Commerce, NRC, and Homeland Security provided written  comments (which are reproduced in apps. II through V), and SBA provided  comments via e-mail. Two agencies, Agriculture and U.S. Army Corps of  Engineers, indicated via e-mail that they had no comments.
Officials from GSA, Commerce, and SBA generally agreed with our  findings:    The Acting Administrator of GSA concurred with the information  pertaining to GSA and expressed appreciation for our acknowledgment of  the actions the agency had taken.
Commerce’s Chief Information Officer indicated that the report provided a  fair assessment of the department’s progress and status to date.
A program manager in SBA’s Office of Congressional and Legislative  Affairs indicated that SBA was satisfied with our findings regarding the  agency.
NRC and the Department of Homeland Security partially agreed with our  report. NRC’s Executive Director for Operations indicated that our report  generally reflects the issues surrounding agency preparedness for  transition. However, the official suggested that we remove our  recommendation that the Commission evaluate the costs and benefits of  new technology or alternatives because such an evaluation had been and  would be conducted as part of the agency’s normal planning processes.  However, our recommendation remains because the Commission did not  perform this activity specifically for the transition to Networx. Performing  such an analysis would provide the Commission with the opportunity to  optimize its telecommunications services in the light of its present and  projected needs. The Executive Director also provided technical  comments, which we incorporated into our report as appropriate; our  assessment of these comments is contained in appendix IV.
The Acting Director of Homeland Security’s Departmental Audit Liaison  Office indicated partial agreement with our report. In particular, regarding  our recommendations that Homeland Security establish goals and  measures of success and perform a transition risk assessment, the  department agreed that a more structured communication of transition  objectives and a specific risk management process for transition would be  beneficial. However, this official indicated that the department disagreed  with five of our recommendations and with a finding regarding its  transition communications planning. The department’s comments  reiterated information on actions that it had taken in these areas that it  considered to meet the goals of the sound practices. However, these  actions are already reflected in our assessment. The specific areas of  disagreement are as follows:    Regarding our recommendation that the department document its  processes for maintaining telecommunications inventories, the official  acknowledged that the department does not have a documented inventory  maintenance process, but stated that our observation was in conflict with  our finding that it had identified a complete telecommunications  inventory. The official added that the department has instructed its  components to maintain their inventories using a GSA tool and  documented GSA procedures. However, our finding that the department  had established an inventory for transition is not in conflict with the  recommendation. While the department had addressed one component of  this sound practice by establishing an inventory for transition, it had not  taken the necessary action to address the other component; it had not  documented the process to be used by its components for inventory  maintenance. Specifically, this sound practice component calls for a  documented inventory maintenance process to lessen the risk that  changes to the inventory during and after transition would not be  consistently and accurately captured.
Regarding our recommendation that the department evaluate the costs  and benefits of new technology or alternatives to meeting its  telecommunications needs, the official indicated that this was in conflict  with our related finding that the department had aligned needs and  opportunities with its mission, long-term IT plans, and enterprise  architecture plans. The official added that its fair opportunity efforts will  include service and cost analyses. However, our recommendation is not in  conflict with the identified finding. Specifically, although the department’s  transition plans addressed strategic needs, it had not performed an  analysis of costs and benefits of new technology or alternatives for  meeting those needs. Regarding decisions made during the fair  opportunity process, our recommendation refers to the sound transition  practice of performing a strategic analysis based on agencywide  telecommunications needs, with the results of this analysis being used to  shape the agency’s transition management approach, transition plan  development, and allocation of resources. In contrast, the fair opportunity  process involves selecting a vendor for the agency’s service orders; at that  point in the process, the agency should have already identified services to  order. Therefore, to be effective, an agency’s evaluation of costs and  benefits of new technology and alternatives would need to take place  before the department’s fair opportunity efforts.
Regarding our recommendation that the department clearly define the  roles of asset management, legal expertise, human capital management,  and information security expertise, the official indicated that the  department can call upon these specialty disciplines as needed. However,  by taking this approach, Homeland Security risks encountering delays as  officials attempt to assign personnel in a time of need and bring them up to  date on transition progress and issues. Defining such roles at the outset, as  advocated by sound transition planning practices, would help avoid such  delays.
Regarding our recommendation that the department identify local and  regional points of contact, the official stated that we had suggested that  the department should identify all personnel that might be involved in any  kind of telecommunication change and stated that such an effort would  include thousands of individuals across the department and all IT field  support personnel. Rather than contacting all these personnel, the Acting  Director indicated that the department had taken steps to alert key  managers at each component. However, this sound practice does not  involve identifying all personnel that might be involved in any  telecommunications change, but rather only identifying those contacts  that will be responsible for facilitating the transition. For example, a  contact is needed for each location where service is provided to facilitate  physical access to equipment during a transition. Homeland Security’s  decision to not identify all contacts responsible for facilitating the  transition does not follow sound transition planning practices and  increases the risk that it will experience delays in providing the necessary  site access for vendors.
Regarding our recommendation that the department identify human  capital resources needed to conduct an effective transition, the official  indicated the department did identify funding and staffing for transition  planning. However, our recommendation is that Homeland Security  determine human capital resources needed throughout the entire  transition effort—not simply the planning effort.
The official acknowledged that Homeland Security had not published a  Networx transition communications plan, but stated that the charter for its  transition work group defined essential communications and activities.  Our report indicates that the department has established lines of  communication in its charter, but as previously discussed, it had not  identified local and regional points of contact. Thus, the department’s  communications planning is incomplete. If Homeland Security does not  identify all of its local points of contact before it begins transitioning  services, communication difficulties could produce delays in providing the  necessary site access for vendors.
As agreed with your staff, unless you publicly announce the contents of  this report earlier, we plan no further distribution of this report until 30  days from the report date. At that time, we will send copies of this report  to other interested congressional committees, the Administrators of  General Services and the Small Business Administration; the Chairman of  the U.S. Nuclear Regulatory Commission; and the Secretaries of  Agriculture, Commerce, Defense, and Homeland Security. We will also  make copies available to others upon request. In addition, the report will  be available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-6240 or by e-mail at koontzl@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. Key contributors to this report are listed in  appendix VI.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to determine (1) the extent to which federal agencies  are following sound transition planning practices and (2) the actions the  General Services Administration (GSA) is taking to identify and resolve  common transition challenges affecting agencies.
To determine the extent to which agencies are following sound transition  planning practices, we selected six agencies for review. Using FTS2001  billing data provided by GSA, we identified total charges for each agency  for fiscal year 2006. These totals ranged from over $145,000,000 to as low  as $28 for 127 separate entities. We then reduced the number of entities  under consideration to a more manageable number by identifying agencies  with total charges in excess of $1 million for fiscal year 2006. From this  group of agencies, we made a judgmental selection of six agencies that  were representative of (1) varying types of organization, including  executive departments, subagencies, and independent agencies;  (2) varying levels of attendance in the Transition Working Group, an  agency forum that is assisting GSA in its efforts to plan for the transition;  and (3) the entire range of agency charges in excess of $1 million. The  departments and agencies selected for review were the Department of  Homeland Security; Department of Commerce; U.S. Department of  Agriculture; Small Business Administration; U.S. Army Corps of Engineers,  a component of the Department of Defense; and U.S. Nuclear Regulatory  Commission.
Because we judgmentally selected the agencies in our review, we cannot  conclude that our results represent the entire federal government’s level of  preparation. However, the six cases studied illustrate various challenges  that agencies may face in planning for the transition to Networx.
To determine the extent to which the selected agencies have made  adequate preparations for their upcoming transitions, we obtained and  reviewed agency documentation, including but not limited to strategic  plans, telecommunications inventories, and transition-related plans, and  interviewed agency officials. We then assessed this information against the  five sound transition planning practices identified in our prior report on  agency transition planning. These practices are (1) establish a  telecommunications inventory, (2) perform a strategic analysis of  telecommunications requirements, (3) establish a structured transition  management approach, (4) identify resources, and (5) develop a transition  plan. Each of these sound planning practices consists of various  components (for example, developing a transition plan consists of  (1) identifying and documenting objectives and measures of success;  (2) determining risks that could affect success; and (3) defining transition  preparation tasks and developing a time line for these tasks).
Based on our assessment, we classified the status of agency transition  planning efforts to address each sound practice component as “fully  implemented,” if the agency has fully implemented the sound practice  component; “plans to fully implement,” if the agency has plans to fully  implement the component; or “no plans to fully implement,” if the agency  does not have plans to fully implement it. We discussed our assessments  with agency officials and made adjustments as appropriate.
To evaluate one of the sound practices, establishing a telecommunications  inventory, we developed criteria to assess the extent to which agencies  had identified complete transition inventories. First, based on data  provided by GSA, we determined whether each agency had validated 90  percent or more of its inventory. Second, we administered a questionnaire  to determine whether each agency had adequate quality control  mechanisms in place to identify and maintain its inventory. If these two  criteria were met, we considered the inventory to be sufficient for a  telecommunications transition.
To determine the actions that GSA is taking to identify and resolve  common transition challenges affecting agencies, we reviewed transition  guidance and other Networx documentation developed by GSA and the  Transition Working Group (TWG) of the Interagency Management Council  (IMC), including presentations, meeting minutes, projected time lines,  GSA’s “Fair Opportunity and Statement of Work Guide,” and the TWG’s  “Networx Transition Guide (Pre-Award)”; interviewed FTS2001 incumbent  vendors and Networx vendors (AT&T, Level3 Communications, Qwest,  Sprint, and Verizon Business) and the six agencies selected for review; and  interviewed GSA officials to identify challenges, guidance, and GSA  current and planned actions for the Networx transition. We assessed  GSA’s efforts to resolve identified challenges by analyzing documentation  and testimonial evidence from GSA on any actions taken to address them.
We performed our work at the Washington, D.C., area offices of the  Department of Homeland Security, Department of Commerce, Department  of Defense, Small Business Administration, U.S. Army Corps of Engineers,  U.S. Department of Agriculture, U.S. Nuclear Regulatory Commission, and  the General Services Administration. We conducted this performance  audit from September 2007 through June 2008, 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 General Services Administration
section_title: Appendix III: Comments from the Department of Commerce
section_title: Appendix IV: Comments from the U.S. Nuclear Regulatory Commission
paragraphs: The following is GAO’s response to the U.S. Nuclear Regulatory  Commission’s letter dated June 13, 2008.
subsections: section_title: GAO Comments
paragraphs: 1.  We clarified our report to better reflect the role of the IMC.  2.  NRC’s comment references our statement that it did not plan to  evaluate the costs and benefits of alternatives to meeting its  telecommunications needs. The official stated that, as its requirements  mature, the agency will evaluate the Networx advanced offerings that  may prove beneficial. However, sound transition planning calls for  performing a cost benefit and analysis specifically for the agency’s  transition effort as part of a strategic analysis that should be used to  shape the agency’s transition management approach, transition plan  development, and allocation of resources. NRC has not performed this  activity for the transition.  3.  NRC’s comment references our statement that it did not plan to  establish measures of success to assess progress toward its goals. NRC  indicated that it plans to use GSA-established measures related to  transition progress and identified various tracking tools. However,  NRC has not established agency-specific objectives for its transition  and, by limiting measures of success to those established by GSA, NRC  may lack information that could be used to track its progress in  achieving its own goals and to inform its own management decisions.  4.  We disagree with NRC’s statement that the introduction of the Office  of Management and Budget’s Trusted Internet Connection (TIC)  initiative should not be characterized as a transition issue. As NRC  goes on to state, agencies that take time to address considerations  relative to TIC may experience delays in their efforts to transition. We  consider this a challenge that may affect agency transitions.  5.  We do not agree with the suggested modification to our  recommendation. NRC’s suggestion would limit its measures of  success to those emphasized by GSA, such as measures of transition  progress. However, sound practices call for agencies to establish  measures for each of its transition objectives to help managers assess  the extent to which those objectives are achieved.
section_title: Appendix V: Comments from the Department of Homeland Security
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, key contributions were made to  this report by James R. Sweetman, Jr., Assistant Director; Gerard Aflague;  Barbara Collier; Jamey A. Collins; Eric Costello; Joel Grossman; Amos  Tevelow; Hai V. Tran; and Merry Woo.