Information Technology: FDA Needs to Fully Implement Key Management Practices to Lessen Modernization Risks
Released: 2012-04-16T00:00:00

Letter

Background

An agency within the U.S. Department of Health and Human Services (HHS), FDA is responsible for promoting and protecting the public health by ensuring the safety, efficacy, and security of human and veterinary drugs, biological products, and medical devices, and ensuring the safety and security of our nation’s food supply, cosmetics, and products that emit radiation. The agency is also responsible for ensuring the proper labeling of foods, drugs, medical devices, tobacco, and cosmetics. Its work also includes advancing public health by facilitating innovations and promoting public access to science-based information on medicines, devices, and foods. The agency does not regulate meat, poultry, and certain egg products, which are regulated by the U.S. Department of Agriculture.

FDA performs regulatory activities that include reviewing and approving new drugs and certain medical products; inspecting manufacturing facilities for compliance with regulations and good manufacturing practices; and conducting postmarket surveillance of food, drug, and medical products to ensure that products are safe; tracking and identifying the source of outbreaks of foodborne illnesses; and issuing recall notices and safety alerts for products that threaten the public health.

FDA exercises its core functions through four directorates: the Offices of Medical Products and Tobacco; Foods; Global Regulatory Operations and Policy; and Operations. These offices, along with the Office of the Chief Scientist, report to the FDA Commissioner and carry out their missions through seven centers and through FDA’s ORA.

Office of Medical Products and Tobacco:

Center for Biologics Evaluation and Research. Regulates and evaluates the safety and effectiveness of biological products, such as blood and blood products, vaccines and allergenic products, and protein-based drugs.

Center for Drug Evaluation and Research. Promotes and protects the public health by ensuring that all prescription and over-the-counter drugs are safe, as well as by reviewing and regulating clinical research.

Center for Devices and Radiological Health. Promotes and protects the public health by ensuring the safety and effectiveness of medical devices and preventing unnecessary human exposure to radiation from radiation-emitting products.

Center for Tobacco Products. Oversees tobacco product performance standards, reviews premarket applications for new and modified risk tobacco products and new warning labels, and establishes and enforces advertising and promotion restrictions.

Center for Food Safety and Applied Nutrition. In conjunction with FDA’s field staff, promotes and protects the public health, in part by ensuring the safety of the food supply and that foods are properly labeled, and ensures that cosmetics are safe and properly labeled.

Center for Veterinary Medicine. Promotes and protects the public health and animal health by helping to ensure that animal food products are safe; and by evaluating the safety and effectiveness of drugs to treat companion animals and those used for food-producing animals.

Office of the Commissioner:

National Center for Toxicological Research. Conducts peer-reviewed scientific research and provides expert technical advice and training to support FDA’s science-based regulatory decisions.

Office of Global Regulatory Operations and Policy:

Office of Regulatory Affairs. Leads FDA field activities and provides FDA leadership on imports, inspections, and enforcement policy. ORA supports the FDA product centers by inspecting regulated products and manufacturers, conducting sample analysis on regulated products, and reviewing imported products offered for entry into the United States. The office also develops FDA-wide policy on compliance and enforcement and executes FDA’s Import Strategy and Food Protection Plans.

FDA’s Reliance on IT

FDA relies extensively on IT to fulfill its mission and to support related administrative needs. The agency has systems dedicated to supporting the following major mission activities:

Reviewing and evaluating new product applications, such as for prescription drugs, medical devices, and food additives. These systems are intended to help FDA determine whether a product is safe before it enters the market. For example, the Document Archiving, Reporting, and Regulatory Tracking System is intended to manage the drug and therapeutics review process.

Tracking and evaluating firms to ensure that products comply with regulatory requirements. For example, the Field Accomplishments and Compliance Tracking System (FACTS) supports inspections, investigations, and compliance activities.

Monitoring the safety of products on the market by collecting and assessing adverse reactions to FDA-regulated products, such as illnesses due to food or negative reactions to drugs. For example, the Vaccine Adverse Event Reporting System accepts reports of adverse events that may be associated with U.S.-licensed vaccines from health care providers, manufacturers, and the public.

In addition, FDA relies on various systems that support its administrative processes, such as payroll administration and personnel systems. All of the agency’s systems are supported by an IT infrastructure that includes network components, critical servers, and multiple data centers.

The information that FDA receives is growing in volume and complexity. According to the agency, from 2001 to 2011, the number of import shipments that it inspected for admission into the United States increased from about 7 million imports reviewed annually to over 22.6 million. Additionally, in 2011, the agency estimated that 15 percent of the U.S. food supply was imported, including 60 percent of fresh fruits and vegetables and 80 percent of seafood. Advances in science and the increase in imports are factors affecting the complexity of information that FDA receives. The ability of the agency’s IT systems and infrastructure to accommodate this growth is crucial to FDA’s ability to accomplish its mission effectively.

Compounding these challenges, reports and studies, both by FDA and others, have noted limitations in a number of key aspects of FDA’s IT environment, including data availability and quality, IT infrastructure, the agency’s ability to use technology to improve regulatory effectiveness, and IT management. In 2007, the FDA Science Board issued a report, FDA Science and Mission at Risk, which provided a broad assessment of challenges facing the agency. Specifically, this study found that the agency’s IT infrastructure was outdated and unstable, and it lacked sufficient controls to ensure continuity of operations or to provide effective disaster recovery services. The Science Board also stated that the agency did not have sufficient IT staff with skills in such areas as capital planning/investment control and enterprise architecture; that processes for recruitment and retention of IT staff were inadequate; and that the agency did not invest sufficiently in professional development. Further, the Science Board found that information was not easily and immediately accessible throughout the agency (including critical clinical trial data that were available only in paper form), hampering FDA’s ability to regulate products. Data and information exchange was impeded because information resided in different systems that were not integrated. According to the Science Board, FDA lacked sufficient standards for data exchanges, both within the agency and between the agency and external parties, reducing its capability to manage the complex data and information challenges associated with rapid innovation, such as new data types, data models, and analytic methods.

Also in 2007, FDA commissioned Deloitte Consulting, LLP, to examine ways in which the agency could better meet increased demand for information and make decisions more quickly and easily. Deloitte’s study stated that FDA needed to develop both a common enterprise information management architecture and an IT architecture to facilitate both short- term operational gains, such as improved information access, and long- term gains in strategic flexibility. Deloitte noted that FDA’s former decentralized approach to IT, in which the centers developed their own systems, had led to duplicative work efforts, tools, and information.

Prior GAO Reports Have Highlighted Challenges with FDA’s IT Systems and Modernization Efforts

We also have previously reported on FDA’s systems and modernization efforts and noted deficiencies in its IT management. For example, in a June 2009 report on the agency’s plans for modernizing its IT systems, we noted that FDA lacked a comprehensive IT strategic plan that included results-oriented goals and performance measures to guide the agency’s modernization projects and activities. We also pointed out that FDA had made mixed progress in establishing important IT management capabilities that are essential in helping ensure a successful modernization. These capabilities included investment management, information security, enterprise architecture development, and human capital management. To help ensure the success of the agency’s modernization efforts, we recommended that it expeditiously develop a comprehensive IT strategic plan, give priority to architecture development, and complete key elements of its IT human capital planning. FDA agreed with our recommendations and identified actions initiated or planned to address them.

In addition, we have previously identified problems with FDA’s Operational and Administrative System for Import Support (OASIS) import-screening system. Specifically, we reported in 2008 that OASIS had an inaccurate count of foreign establishments manufacturing drugs because unreliable manufacturer identification numbers were generated by customs brokers. FDA officials said these errors resulted in the creation of multiple records for a single establishment, which led to inflated counts of establishments offering drugs for import into the U.S. market. While FDA officials acknowledged this problem, they were unable to provide us with an estimate of the extent of these errors. In addition, the agency did not have a process for systematically identifying and correcting these errors. Accordingly, we made recommendations aimed at correcting these deficiencies; however, FDA did not comment on these recommendations. In September 2010, we reported that OASIS still provided an inaccurate count of foreign establishments manufacturing drugs offered for import into the United States.

Further, in September 2009, we reported that Customs and Border Protection’s import screening system did not notify OASIS when imported food shipments arrived at U.S. ports. We pointed out that, without access to time-of-arrival information, FDA did not know when shipments that require examinations or reinspections arrive at the port, which could increase the risk that unsafe food may enter U.S. commerce. We therefore recommended that Customs and Border Protection ensure that its new screening system communicates time-of-arrival information to FDA, and the agency agreed with this recommendation. In May 2010, we testified that, according to FDA officials, Customs and Border Protection had modified its software to notify FDA of a shipment’s time of arrival.

GAO-08-597. commit to taking action on them. Further, in February 2009, we reported that Customs and Border Protection, the National Marine Fishery Service, and FDA each collected information on seafood products to meet their respective responsibilities, but did not effectively share information that could be used to detect and prevent inaccurate labeling of seafood. As a result, we recommended that the three agencies develop goals, strategies, and mechanisms for interagency information sharing, which the agencies generally agreed with. Finally, in May 2010, we testified that the lack of a unique identifier for firms exporting food products may have allowed contaminated food to evade FDA’s review, and that the agency did not always share information on food distribution lists with states. We pointed out that this impeded states’ efforts to remove contaminated products from grocery stores and warehouses.

IT Organizational Structure and Governance

Driven in part by the various studies of the agency’s IT environment, in May 2008 FDA transitioned to an enterprisewide approach to IT management. Prior to this transition, the agency’s IT management was decentralized, with each center having its own Office of Technology. According to FDA officials, this led to an environment in which systems did not interoperate and were often redundant and investment in IT infrastructure and systems development was inadequate.

In moving to an enterprisewide approach, the agency transferred responsibility for managing IT from individual components (centers and ORA) to a new centralized Office of Information Management (OIM). OIM resides within FDA’s Office of Operations and is headed by the Chief Information Officer (CIO). The CIO reports to the agency’s Chief Operating Officer. As head of OIM, the CIO is responsible for managing IT, creating a foundation to enhance the interoperability of systems, and managing more than 400 staff assigned to this office.

OIM is composed of five divisions: Business Partnership and Support, Systems Management, Infrastructure Operations, Technology, and Chief Information Officer Support. It is responsible for managing IT and other related services enterprisewide. This includes developing the architecture, standards, policies, governance, best practices, and technology road map that support the business priorities of the agency, including managing IT infrastructure, telecommunications, security, business continuity and disaster recovery, strategic planning, capital planning and investment control, enterprise architecture, and applications development and management; advising and providing assistance to the FDA Commissioner and senior management officials on IT resources and programs; establishing and overseeing implementation of agency IT policy and governance, procedures, and processes for conformance with the Clinger-Cohen Act and the Paperwork Reduction Act; and working with FDA business areas to develop and communicate the overall vision for the agency’s IT program.

In early March 2012, the CIO began developing a new Project Management Office.Governance Board is expected to perform investment evaluations and project assessments. FDA’s senior executive team, which is comprised of the Deputy Commissioners, the Associate Commissioner for Regulatory Affairs, Center Directors, and the CIO, is responsible for governance of all IT investments.

FDA’s IT Budget

FDA received about $418 million in IT funding for fiscal year 2012. For fiscal year 2011, the agency’s IT budget was approximately $439 million, as illustrated in figure 1.

As illustrated in figure 2, about 60 percent of FDA’s reported IT costs in fiscal year 2011 supported IT operations and infrastructure, such as network servers, telecommunications, and computers, with the remaining 40 percent supporting the development and modernization of IT systems.

FDA Lacks a Comprehensive List of Its IT Systems

Federal guidance calls for agencies to prepare and maintain a comprehensive list of their IT systems. Specifically, OMB Circular No. A- 130 guidance calls for a complete inventory of agency information, to include identifying and describing information services, such as systems and databases, used throughout the agency. In addition, GAO’s IT investment management framework, stresses that a foundational practice for effectively managing an organization’s investments is having an up-to-date and complete collection of information on its assets, including systems, software applications and tools, and licensing agreements. According to the framework, to make good investment decisions, an organization should maintain pertinent information about each investment and store that information in a retrievable format, such as a central repository, to be used in future investment decisions. Such a repository is to include, among other things, the current life cycle phase of the system; the responsible organizational unit; the costs to date and anticipated future costs; and the interfaces and dependencies with other systems. The framework also notes that the inventory should contain information used to measure the progress and value of the investments, such as benefits to the mission, schedule, risk assessments, and performance metrics. Without a complete inventory of IT information, an organization cannot develop an adequate investment control process, and consequently, will lack the foundation for demonstrating the impact of alternative investment strategies and funding levels for the agency’s inventory of information resources.

Although FDA reported spending approximately $439 million for IT investments in fiscal year 2011, the agency does not have a comprehensive list of IT systems identifying and providing key information about the systems that it currently uses or is developing. In response to our request for an inventory of systems, FDA officials pointed to two sources that partly identified key elements of the agency’s systems: information contained in key budget and planning documents it prepares annually for submission to OMB, and a list of 21 mission-critical systems(see app. III for the list of 21 systems and modernization initiatives).

However, while these sources identified certain key investments with varying levels of detail as to cost, purpose, and status, the CIO and agency officials responsible for developing an inventory acknowledged that the information was not comprehensive and lacked critical details about systems that would be essential to effectively managing the agency’s IT investments. Specifically, OMB requires federal departments and agencies, including the Department of Health and Human Services—of which FDA is a component—to annually provide information related to their IT investment portfolios (called exhibit 53s) and capital asset plans and business cases for major investments (called exhibit 300s). The purpose of the exhibit 53 is to identify all IT investments—both major and nonmajor—and their associated costs for which funding is being sought in a particular fiscal year. The exhibit 300s provide a business case for each major IT investment, and agencies are required to provide information on each major investment’s cost, schedule, and performance.

For fiscal year 2011, FDA’s exhibit 53 identified development and operations and maintenance costs for 44 IT investments. (See app. IV for a list of the 44 IT investments.) For example, one of the 44 line items in the exhibit 53 identified an investment for FDA’s Information and Computing Technologies for the 21st Century (ICT21), with about $68 million in funding for fiscal year 2011. In addition, FDA submitted an exhibit 300 for eight major investments. Among these investments were ICT21 and the Automated Laboratory Management project, which is to facilitate communication between FDA labs by creating an electronic environment based on a standardized format.

However, while these documents contain key IT information, such as costs of the investments, they did not present a comprehensive list of FDA’s systems with the detailed information that would be essential to managing the agency’s portfolio. For example, the exhibit 53 provides investment cost information for the previous year, current year, and budget year, but does not include any information on the performance of the investments. Further, while exhibit 300s provide information on the major investments, they do not provide comprehensive detailed information on the systems that comprise these investments. For example, exhibit 300s may not include detailed information on the systems’ interfaces, dependencies, or performance.

In addition to the OMB budget documents, the agency’s list of 21 mission- critical systems and modernization initiatives did not fully identify FDA’s IT systems. Agency officials acknowledged that this list was partly derived from a list of enterprisewide systems discussed in our prior (June 2009) report and did not include all systems. For example, while the list did include some of the regulatory systems critical to CFSAN’s mission, such as MARCS, the FDA Unified Registration and Listing System, and the Low-Acid Canned Foods system, the list did not include other systems identified by the centers as critical to their missions. Among these, the list did not include information on two of three mission-critical systems belonging to the Center for Drug Evaluation and Research: the Document Archiving, Reporting and Regulatory Tracking System, which tracks drug applications; and the Electronic Drug Registration and Listing System, which automates drug firm registrations and implements unique identifiers for all firms. Further, FDA’s list did not include the key regulatory and administrative systems used by CFSAN—the CFSAN Adverse Events Reporting System and the Food Applications Regulatory Management system—both of which were identified on the exhibit 53 to OMB.

According to FDA’s CIO, the agency is in the process of reviewing IT projects of over $5 million and identifying potential improvements in its capital planning and investment control process to increase insight into the IT portfolio. However, the CIO and a senior technical advisor could not say when the comprehensive list of systems would be finalized. Until the agency has a comprehensive inventory of its IT assets, it will lack the information needed to ensure that it is identifying the appropriate mix of investments that best meet its needs and priorities. Further, lacking such an inventory, the agency substantially diminishes its ability to provide a full picture of the current state of its investments, its vision of the future, and its plan for getting there.

While FDA Has Taken Steps to Modernize Its IT, Much Work Remains, and It Has Not Implemented Key Management Capabilities

FDA has completed several projects aimed at, among other things, modernizing its IT infrastructure and administrative processes. These projects include a data center migration and consolidation effort and efforts aimed at standardizing data across systems. The agency has also nearly completed one major mission-critical system modernization project that provides capabilities supporting its regulatory mission. Nevertheless, much work remains on FDA’s largest mission-critical system modernization project, MARCS, and a lack of adequate planning, among other things, makes it uncertain when or if it will meet its goals of replacing eight key legacy systems and providing needed functionality. In addition, FDA has not yet fully implemented key IT management capabilities to guide and support its modernization effort, such as IT strategic planning, enterprise architecture development and implementation, and IT human capital planning.

Data Center Modernization Effort Is Complete, and One Regulatory Modernization Effort Is Nearly Complete

FDA has completed a major effort to modernize its IT operations and infrastructure by consolidating its data centers. Specifically, the ICT21 data center modernization and migration effort replaced the agency’s aging data center infrastructure with modern equipment and consolidated its data centers. The effort began in 2008 and was completed in 2011. According to FDA, this effort provided the foundation for modern, networked information and shared data resources and positioned the agency to tackle the challenges of building the next generation of application systems and software tools. FDA officials further noted that the new data centers provide users with greater access to information, having decreased unscheduled system downtime, and that the centers have formalized and standardized the agency’s development, test, and production environments to improve operations.

FDA has also nearly completed one of its major enterprisewide mission- critical systems modernization efforts—Medwatch Plus—which is estimated to cost about $56 million. Medwatch Plus is to provide a reporting portal for the public to submit adverse event reports as well as the capability to create reports to inform the public of safety problems. FDA receives more than 600,000 voluntary postmarketing adverse event reports annually from manufacturers, health care professionals, and consumers for all FDA-regulated products, many of which are submitted as paper reports. According to the agency, the portal provides a user- friendly electronic submission capability, encouraging the reporting of information in a quality and uniform manner. In May 2010, FDA reported that the agency had deployed the Electronic Safety Reporting Portal. This website can be used to report safety problems related to foods, including animal feed and animal drugs, as well as adverse events occurring on human gene transfer trials. According to officials, the project was in operations and maintenance, and the agency’s project documentation reported that the project will be enhanced to reflect recent legislation.

Another part of the Medwatch Plus project, the FDA Adverse Event Reporting System is to provide tools for the analysis of adverse events and safety report information. According to FDA, the system will enable the agency to improve the timeliness, accuracy, and usability of its product safety surveillance data by significantly reducing delays and errors associated with manual data entry and coding of paper reports. The system is initially being developed for the analysis of drug and biologic products. FDA estimates that the FDA Adverse Event Reporting System will be deployed in 2012.

Considerable Work Remains on MARCS

While FDA has made important progress toward completing ICT21 and Medwatch Plus, considerable work remains to complete the MARCS program. Initiated in 2002, the program is one of the agency’s largest and costliest system efforts, receiving $37 million of FDA’s 2011 modernization and operations funding and having a total estimated cost of $280 million.

The need for MARCS arose from problems experienced with FDA’s critical compliance systems, such as OASIS. According to the Program Manager, these and other ORA systems were developed in a stove-piped manner, and thus did not easily interface with other FDA systems in place or being developed. Specifically, the Program Manager noted that, while it is not impossible, it is expensive and difficult to develop these interfaces. As a result, FDA employees did not have immediate access to needed information and often had to make time-consuming efforts to locate the information manually or in other systems.

The MARCS program is intended to support ORA’s critical work of safeguarding food, drugs, medical devices, biologics, and veterinary products that the agency regulates. By enhancing existing applications and developing new systems, it is to provide information to headquarters and field users to perform inspections, compliance activities, and laboratory operations. Specifically, it is to automate the workflow and help track and manage information about firm compliance with FDA’s regulations. In addition, the program is also intended to be used by other federal, state, and industry users to help support FDA’s public health mission. For example, the program is expected to provide improvements in interfacing and exchanging data with U.S. Customs and Border Protection to inspect products imported into the United States. Further, the program is intended to eliminate FDA’s existing stove-piped databases to provide automated data and sharing among domestic and foreign inspections. In this regard, FDA plans to update and replace eight key ORA systems that facilitate FDA’s compliance activities.

However, despite its importance to FDA’s overall modernization efforts, much of the planned functionality has not been delivered, and FDA has yet to retire the legacy systems MARCS was intended to replace. A series of rebaselines and changes to accommodate short-term needs resulted in repeated shifts in the approach and revisions to the target dates for completing the program:

Since 2002, when the program was initiated, requirements were changed and broadened to include the replacement of six additional legacy systems from the two originally planned.

In 2005, development was put on hold, and efforts and funding were redirected toward FDA’s data center modernization effort and toward providing web-enabled versions of the two original legacy systems, OASIS and FACTS. The program was rebaselined in 2006, 2007, and 2009 to accommodate additional cost or functionality and the replacement of additional legacy systems. According to FDA, in 2010, the agency updated and revalidated MARCS requirements.

In August 2011, FDA again rebaselined the MARCS program estimates to account for new legislative and resulting regulatory requirements based on the FDA Food Safety Modernization Act. It estimated that the total life-cycle cost would be $282.7 million and planned to deploy a significant portion of MARCS and retire its legacy systems by July 2014. (For a history of MARCS see app. V.)

Nonetheless, as of February 2012, FDA still had considerable work to accomplish on MARCS. While the agency deployed a tool—the Predictive Risk-based Evaluation for Dynamic Import Compliance Targeting (PREDICT)—to improve the efficiency of the inspection process through targeting high-risk imports, FDA had not yet been able to retire any of the eight legacy systems MARCS was intended to replace. Further, of the approximately 30 planned service components, processes, of the program, only 8 were in the implementation or operations and maintenance phases, while the remaining 22 were in earlier phases, such as requirements analysis. Of these 22, FDA had yet to begin work on 12 components.

Figure 3 shows the life-cycle phases components as provided by FDA.

While FDA noted that there are 37 components, for the purpose of reporting status, the agency grouped 6 components into the Field Work Manager component and 3 into Work Assignment and Accomplishment Management Services, resulting in 30 total components.

FDA follows HHS’s Enterprise Performance Life Cycle Framework, in which projects pass through 10 life-cycle phases: initiation, concept, planning, requirements analysis, design, development, test, implementation, operations and maintenance, and disposition.

FDA Has Not Developed an Integrated Master Schedule for MARCS to Effectively Gauge Progress

One critical management tool to effectively determine work remaining of complex systems that involve the integration of a number of components is having a reliable IMS that is used to monitor all of the program’s work activities, how long the activities will take, and how the activities are related to one another. The IMS is a top-level schedule that is linked to lower-level schedules that define all of the tasks necessary to complete the project, including work to be performed both by the government and contractors, and that includes all tasks for the life cycle of the project. As such, the IMS provides both a roadmap for systematic execution of a program, and a means by which to gauge progress. It is a critical tool for determining what work remains and the expected cost to complete it and for identifying and addressing potential problems.

While the Program Manger provided a fiscal year 2011 schedule and multiple 2012 subproject schedules, these documents lacked key information that is required in an IMS. Specifically, the fiscal year 2011 schedule does not identify all current and future tasks for the program, and does not reflect the work to be performed by the government as well as the contractor. The schedule reflects activities through fiscal year 2012, but lacks key information on the program’s milestones and schedules for the rest of the project, which runs beyond fiscal year 2014.fiscal year, which does not identify the full scope of the project. Further, the schedule is based on tasks and lower-level schedules of the integration contractor and does not include tasks to be performed by the government. As a result, it does not have the key capability to provide a summary of progress on all lower-level tasks or of the effects of changes to lower-level schedules and tasks on the overall project. Thus, it cannot be used to gauge progress on the entire project and evaluate the effect of changes to individual tasks on the project as a whole.

Consequently, FDA is only projecting work through the current Instead of an IMS, the MARCS contractor program manager noted that FDA and the contractor are using separate schedules to manage the work and are coordinating their schedules at biweekly meetings. FDA officials also told us that they had not developed a detailed schedule of future tasks because there are many unknowns, including funding availability and changes to functionality needed as a result of legislation such as the FDA Food Safety Modernization Act. While our cost estimating guide says that a comprehensive schedule should reflect all activities for a project, it recognizes that there can be uncertainties and unknown factors in schedule estimates due to, among other things, In response to such uncertainties and unknowns, the limited data. guidance discusses the need to perform a schedule risk analysis to determine the level of uncertainty and to help identify and mitigate the risks.

GAO-09-3SP. rescoped version of the program, FDA increases the risk that it will be unable to successfully execute all activities needed to complete the program, resulting in additional delays in delivering improved functionality and retiring legacy systems.

FDA Has Not Fully Established Key IT Management Capabilities Needed to Guide Its Modernization Efforts

An agency’s chance of success in modernizing its IT systems, particularly for large and costly programs such as MARCS, is improved if it institutes key IT management capabilities. However, FDA has not fully established key IT management capabilities including IT strategic planning, enterprise architecture, and IT human capital planning. As the agency undertakes its modernization initiatives, an IT strategic plan should serve as the agency’s vision or roadmap and help align its information resources with its business strategies and investment decisions. Further, an enterprise architecture can provide a blueprint for the modernization effort by defining models that describe how an organization operates today (the “as-is” state), and how it intends to operate in the future (the “to-be” state), along with a plan for transitioning to the future state. In addition, strategic human capital planning is essential to ensuring that an organization has the right number of people with the right mix of knowledge and skills to achieve current and future program results. Until FDA establishes these capabilities, successful completion of its modernization efforts is in jeopardy.

As we have previously reported, IT strategic plans serve as an agency’s vision or roadmap and help align its information resources with its business strategies and investment decisions. Further, such a plan is an important asset to document the agency’s vision for the future in key areas of IT management, including enterprise architecture development and human capital planning. Among other things, the plan might include the mission of the agency, key business processes, IT challenges, and guiding principles. Further, a strategic plan is important to enable an agency to consider the resources, including human, infrastructure, and funding, that are needed to manage, support, and pay for projects. For example, a strategic plan that identifies what an agency intends to accomplish during a given period helps ensure that the necessary infrastructure is put in place for new or improved capabilities. In addition, a strategic plan that identifies interdependencies within and across individual IT systems modernization projects helps ensure that the interdependencies are understood and managed, so that projects—and thus system solutions—are effectively integrated.

FDA does not have an actionablegoals and corresponding tasks to guide its overall modernization efforts, although our June 2009 report recommended that it develop one. While the agency drafted an IT strategic plan in May 2010, this plan has not been completed or approved by agency executives. A senior technical advisor stated that the plan was not sufficiently detailed or actionable and the agency is revising and updating the plan. However, the official was unable to provide details on when it would be finalized or available for review. In January 2012, FDA’s CIO stated that the agency was undertaking an extensive effort to collect feedback to inform a strategic direction.

IT strategic plan that identifies specific Our prior report recommended that FDA develop an IT strategic plan that includes results-oriented goals, strategies, milestones, and performance measures and use this plan to guide and coordinate its modernization projects and activities. recommendation, FDA will lack a comprehensive picture of the goals of its efforts and the strategies that will be used to meet them. Consequently, FDA risks proceeding with IT modernization efforts that are not well planned and coordinated, that are not sufficiently aligned with the agency’s strategic goals, and that include dependent projects that are not synchronized.

GAO-09-523. describing in detail the steps to be taken and tasks to be performed in managing the enterprise architecture program, including a detailed work breakdown and estimates for funding and staffing. When planning IT modernization, a to-be enterprise architecture provides a view of what is planned for the agency’s performance, business, data, services, technology, and security architectures, and is supplemented with a plan for transitioning from the as-is to the to-be state. This is critical in order to coordinate the concurrent development of IT systems in a manner that increases the likelihood that systems will be able to interoperate and that they will be able to use the IT infrastructure that is planned going forward. In addition, organizations can develop an architecture in segments— referred to as a segment architecture—that correspond to business areas or domains in order to divide the development process into manageable sections. According to the Federal Enterprise Architecture Practice Guidance, prioritizing segments should precede building them, and developing the segment architecture should take place before an agency executes its IT projects for a segment. Attempting to define and build major IT systems without first completing either an enterprisewide architecture or, where appropriate, the relevant segment architectures, is risky.

We reported in 2009 that FDA had made mixed progress in establishing its enterprise architecture and that the agency did not yet have an architecture that could be used to efficiently and effectively guide its modernization efforts. Since then, the agency’s enterprise architecture has remained incomplete.

Specifically, the agency has developed a draft enterprise architecture management plan; however, according to FDA’s Chief Enterprise Architect, the plan needs to be rewritten to reflect recent guidance from OMB and HHS, as well as the new CIO’s vision. In addition, the plan does not address all the elements called for by GAO’s enterprise architecture management maturity framework, such as identifying needed funding and staff resources. The Chief Enterprise Architect estimated that the revised enterprise architecture management plan would be completed in April 2012.

Further, FDA has not completed its as-is architecture, particularly in describing its current environment in terms of technology, performance, and security; nor has FDA completed its to-be architecture by describing, for example, desired end-to-end business information flows, or developed an enterprise architecture transition plan. FDA has developed architecture products that describe aspects of the as-is enterprise architecture in terms of business processes, information, and IT systems. For example, it has drafted a graphical high-level view of FDA’s business process hierarchy, which shows the core mission processes, mission-enabling processes, and IT capabilities; and has produced a report of current FDA information exchange packages and identified data standards. However, FDA’s architecture products do not adequately describe its as-is environment in terms of technology, performance, and security. For example, although FDA has defined a high-level technical standards review process and identified certain as-is technology products, it has not described enterprise-level as-is technology infrastructure assets, such as common application servers and communications networks that currently support enterprise application systems and services; and

FDA’s architecture products do not describe enterprise-level as-is performance issues and security concerns.

These descriptions are important since they provide a basis for making decisions on enterprise investments and developing an enterprise transition roadmap.

FDA has developed an initial draft of its target enterprise architecture that describes aspects of its to-be environment. The target enterprise architecture is defined in terms of business needs, information, services, technology, and security. For example, it identifies business functions (e.g., facility inspection) performed by FDA, the classes of data (e.g., facility inspection data) used by the business functions (e.g., product review and approval), and the types of technology infrastructure (e.g., enterprise service bus) used across FDA. The target enterprise architecture also includes a technical reference architecture diagram that identifies logical groupings of services and a services integration framework.

Nonetheless, the target architecture does not adequately describe FDA’s to-be environment. For example, the target architecture does not include to-be end-to-end business information flows that identify the information used by FDA in its business processes, where the information is needed, and how the information is shared to support mission functions. These artifacts are necessary to help FDA identify process gaps and information-sharing requirements among its business functions, data centers, and systems; across business segments; and with external business partners (e.g., life sciences companies and food companies). Moreover, it does not identify enterprise policies for the way information is acquired, accessed, shared, and used within FDA and by its business partners. Further, it does not describe common application components and reusable services expected to be leveraged by all segments and identify as-is cross-agency applications that are expected to be part of the target environment.

In addition, the FDA target architecture does not include performance measures that focus on the long-term performance of the entire agency and performance targets established for all key business processes and agency services. This information is important since it establishes a basis for defining the expected performance of related segments and the technical performance of the supporting application systems and services. Moreover, FDA has not adequately described its to-be environment in terms of technology. For example, although the Chief Enterprise Architect indicated that cloud computing services and solutions would be adopted for sharing information internally and externally, the architecture does not yet provide the timelines for transitioning to cloud computing and identify what databases, services, and platforms are to take advantage of cloud-based services.

Further, FDA has completed only 1 of 12 architecture segments that will make up its enterprise architecture, and continues to conduct modernization and system development efforts for segments it has not completed. Finally, FDA has not developed plans that address the risk of proceeding with modernization projects in the absence of a complete architecture.

We previously recommended that FDA accelerate development of its segment and enterprise architecture, including the as-is and to-be architectures and the associated transition plan. As long as its enterprise architecture and segment architectures lag behind its modernization projects, FDA increases the risk that its modernization projects will not conform to its planned environment and that the IT solutions that it pursues will not be defined, developed, and deployed in a way that promotes sharing and interoperability, maximizes shared reuse, and minimizes overlap and duplication. Finally, without a plan to address risks associated with an incomplete target architecture and transition plan, there is no assurance that appropriate actions will be taken, including risk identification and prioritization, risk response, and risk monitoring and control.

The success or failure of federal programs, like those of other organizations, depends on having the right number of people with the right mix of knowledge and skills. In our prior work, we have found that strategic human capital management is essential to the success of any organization. Strategic human capital management focuses on two principles that are critical in a modern, results-oriented management environment:

People are assets whose value can be enhanced through investment.

An organization’s human capital approaches must be aligned to support the mission, vision for the future, core values, goals and objectives, and strategies by which the organization has defined its direction.

For example, our prior work has shown negative cost and schedule implications for complex services acquisitions at the Department of Homeland Security that did not have adequate staff. See GAO, Department of Homeland Security: Better Planning and Assessment Needed to Improve Outcomes for Complex Service Acquisitions, GAO-08-263 (Washington, D.C.: Apr. 22, 2008). long-term goals), analyzing the gaps between current skills and future needs, and developing strategies for filling gaps.

However, FDA has not adequately planned for its human capital needs, although our June 2009 report recommended that it do so. Our prior review found that the agency had not inventoried the skills of its IT workforce, determined present or future skills needs, or analyzed gaps. Since our prior review, the agency has made limited progress in assessing its IT human capital needs.

In March 2010, FDA reported the results of its workforce assessment of OIM’s Division of Systems. The report documented current workforce characteristics based on a survey of Division of Systems employees and recommended steps for the division to better align its functions and responsibilities with the needs of the centers. However, the survey was limited to only one of OIM’s five divisions (Division of Systems Management), and did not consider work performed by contractors. Further, while the assessment identified staff concerns with their ability to perform current and future tasks, it only provided a snapshot of current capabilities, and did not include an estimate of skills and resources needed to perform future work or an assessment of whether the skills and abilities of the current workforce are sufficient to meet future needs.

In August 2011, the agency reported on a more comprehensive study of IT staff skills and resource allocations. This study was also, in part, based on a survey of OIM’s IT staff, and it included all five of OIM’s divisions. However, the study was focused on current workload information and included staff’s self-reported estimates of calendar year 2010 hours and a prediction of 2011 hours for IT functional areas. The study was not based on an assessment of needs to achieve future IT plans. Further, the study did not include a gap analysis based on future IT plans.

Thus, FDA has yet to conduct a full assessment of future needs, and develop a plan to address them. When asked about additional plans to address the gaps in its IT human capital planning, the Acting Chief Operating Officer said that further IT human capital assessments and planning would not occur until the new CIO could be briefed on the assessments that have been performed to date and the findings.

The CIO stated that workforce modernization is one of the most critical needs for FDA to effectively meet its future IT goals. According to the CIO, each of FDA’s operating divisions was in the process of identifying the skill sets needed to replace OIM staff that departed the agency. The CIO cited shortages in staff that have experience building clinical data warehouses—a critical agency need. The CIO also stated that the agency’s IT staff skills have been limited by inadequate training and added that FDA plans to fill the agency’s human capital gaps through obtaining external expertise and internal development. However, without a human capital plan to guide these efforts, FDA risks not obtaining the right number of people with the right mix of skills to meet its goals.

Moreover, beyond deficiencies in its staff skill sets and inadequate training, the agency’s ability to manage IT has also been hindered by changes in leadership. Since 2008, the agency has had five CIOs, potentially hampering its ability to plan and effectively implement a long- range IT strategy. For example, the agency had two acting CIOs during 2011, with a permanent CIO only being selected recently (in October 2011). According to the former Acting CIO, FDA filled positions with acting officials in order to address specific goals. For example, in March 2011, he was moved from his position as OIM Director of IT Infrastructure to the acting CIO position because FDA considered his expertise essential to completing the data center consolidation effort. However, without a CIO with a broad view of IT strategic goals, the agency was unable to focus on its longer-term objectives. Further, this has led to planning delays in key areas such as IT strategic planning, enterprise architecture development, and human capital management. In September 2011, for example, the agency’s Chief Operating Officer said that IT human capital plans were on hold until the new CIO was in place. We noted previously that one element that influences the likely success of an agency CIO is the length of time the individual in the position has to implement change. For example, our prior work has noted that it can take 5 to 7 years to fully implement major change initiatives in large public and private sector organizations and to transform related cultures in a sustainable manner.

In our previous review of FDA’s modernization efforts, we recommended that the agency develop a human capital plan that includes an assessment of skills, determines needs, and analyzes gaps. Until the agency does so and maintains stable leadership to guide its efforts, the agency risks not having adequate management and staff in key areas necessary to effectively manage its IT modernization efforts.

FDA Has Made Mixed Progress in More Effectively Sharing and Integrating Data

Data sharing is critical for FDA to effectively carry out its mission. As previously noted, the agency needs timely access to data to be able to support its product review and approval process, its inspection of imports and manufacturing facilities, and its postmarket surveillance activities. Further, the agency needs to collect data from and share them with a wide array of partners, including public health organizations, importers, and other federal entities, as well as the general public. Specifically, it needs standardized data to effectively compare information of thousands of drug studies and clinical trials. Both we and the HHS Inspector General have previously identified challenges, such as inconsistent naming conventions, in the agency’s ability to share information, both internally and with external partners.

FDA has taken some steps to improve its sharing of data, but much more remains to be done. Specifically, the agency has several initiatives under way to more effectively share its data, including adopting an enterprisewide standard for formatting data, and several projects aimed at enhancing its ability to share data, both internally and with external partners. However, these projects have made mixed progress, and more significant work remains for FDA to fully implement standardized data sharing across the agency.

FDA Has Adopted an Enterprisewide Standard to Facilitate Data Sharing and Analysis

Data standardization includes ensuring that information is submitted and stored in a consistent format using consistent terminology. Developing systems based on the use and enforcement of data standards helps ensure that information collected is complete and consistent and that users of the data exchanged have a common understanding. The ultimate benefit of standardizing data is to make it easier to collect, compare, maintain, and analyze.

FDA has made progress in one significant initiative aimed at achieving more effective sharing of data: its adoption of an enterprisewide data standard that can be applied to food, drugs, and medical devices. Specifically, it has adopted an HL7 international health care informatics interoperability standard as its enterprisewide data model. The standard that the agency has adopted—Reference Information Model, HL7 version 3—provides a set of rules that allow information to be shared and processed in a uniform and consistent manner. For example, it specifies formats for presenting the names of firms or products, descriptions of disease symptoms, or the gender of a patient (e.g., “M” or “Male”). This standardization of data formats should help ensure consistency in how information on products is submitted to FDA; it also should facilitate analysis of the data by making it easier to compare information across products or to identify patterns in large numbers of data (i.e., data mining). As such, it should provide the foundations for FDA’s efforts to standardize data enterprisewide.

FDA is applying this standard to multiple categories of products, including food, drugs, and medical devices, in order to facilitate the input, reading, and comparison of information on applicable products submitted to the agency for approval. For example, it has established an Electronic Submissions Gateway, which provides a virtual “mailbox” that accepts submissions of drug studies and other information. In addition, the gateway has an HL7 screening capability that reviews submissions to ensure that they meet FDA’s data standards. This could facilitate the drug companies submitting data to ensure the information is consistent with the required standard.

However, according to the agency, currently only about 60 percentclinical trial data is being submitted electronically, with the remainder being submitted on paper. The amount of paper submissions hinders the agency’s development and implementation of standardized data for electronic submission. The adoption of electronic submission continues to be limited because its use is voluntary, in that submitters can choose to use the older paper format that does not conform to the data standards. FDA officials said they are promoting electronic submission of applications and reports by educating submitters on the benefits of electronic submissions.

In addition to its adoption of an enterprisewide data standard, FDA has developed an approach to standardizing firm registration data that it receives in a nonstandard format. consistency in data on firms, agency officials acknowledged that there is considerable work remaining to implement data standardization across the agency. Moreover, these officials stated that acquiring the staff with needed expertise in areas such as data modeling remains a challenge. For example, FDA is developing a wide array of standards in collaboration with industry representatives to evaluate and reach agreement on how these standards will be implemented and adopted.

Data-Sharing Projects Have Made Mixed Progress

In addition to its adoption of the HL7 data standard, FDA has several initiatives that are intended to enhance the sharing of data throughout the agency. Of four such initiatives, two are in the mixed phase of development, one is in an early stage of development, and the other is on hold pending a reevaluation. Table 2 shows the progress these projects have made since 2009.

The Firms Master List Services standardizes and validates the facility name and address data received from imports, registration and listing systems, and inspections. The Firms Master List Services is used by MARCS and Automated Laboratory Management.

Janus was intended to provide FDA with a comprehensive clinical-trial and population-health-data warehouse and analytical tools to enable reviewers to search, model, and analyze data, improving FDA’s management of structured scientific data. However, since 2009, this project has only progressed from the planning to the requirements phase. According to the CIO, the project’s requirements became too extensive and limited progress was being made in developing the data warehouse. The CIO further noted that FDA did not have the needed expertise for a project this size and scope, and further work has been stopped pending reevaluation. Further, the CIO said that when the project is restarted, the agency will use an Agiledevelopment approach to provide added capabilities incrementally over shorter timeframes to more effectively manage the project.

FDA Has Not Adequately Assessed Data-Sharing Opportunities within the Center for Food Safety and Applied Nutrition

OMB and the Federal CIO Council guidance state that agencies should analyze their business and information environments to determine information-sharing requirements and identify improvement opportunities.information sharing within the agency and other government agencies. Further, OMB guidance requires federal agencies to analyze the information used in their business process to indicate where the information is needed and how it is shared to support mission functions. Documenting information flows is an initial step in developing systems and databases that are organized efficiently, are easier to maintain, and meet the user’s needs.

The agency’s enterprise architecture should demonstrate However, we have previously identified deficiencies in CFSAN’s ability to effectively share information, such as information on recalls of contaminated foods. In particular, CFSAN has 21 different databases and systems that contain information critical to its mission. (See app. VI for details on the center’s systems.) These databases and systems contain information on adverse events; seafood inspection; milk shippers; shellfish shippers; retail food safety inspections; toxicological effects of food ingredients and additives; and FDA research on food, animal feed, veterinary medicine, and cosmetics, among others.

The center now has data-sharing initiatives under way, but it has not performed a comprehensive review to identify opportunities for improved data sharing within the center. CFSAN has conducted some work to improve the sharing of data among these systems and databases. For example, according to the agency, the center has plans for a web-based application designed to standardize vocabularies across systems and enable enterprisewide searching of its disparate data collections.

Nonetheless, the center has not comprehensively assessed its information-sharing needs and capabilities to identify further opportunities for data sharing and system integration. This would examine how information moves between business processes and identify efficiencies that could be gained by grouping related information into corresponding databases. Instead, the center has identified opportunities for data sharing on an ad hoc basis, relying primarily on the expertise of its staff. CFSAN officials acknowledged that integration among its databases could be improved to more effectively share data and streamline processes. For example, certain firms are currently required to access two separate databases to complete the low-acid canned foods registration process. Further, officials noted that the center’s systems were generally created in response to a specific need or legislation and are thus stove-piped, with little overlap of information. However, without identifying opportunities for greater and more efficient information sharing, FDA and CFSAN face a risk of continuing to maintain an IT environment that requires greater effort to access needed information.

Conclusions

While FDA has taken several important steps toward modernizing its IT environment, much remains to be done, and these efforts have not been guided by key foundational IT management practices, which expose them to significant risk. Specifically, because FDA does not have a comprehensive list of its systems, it cannot ensure that it is investing in the mix of projects that will best support its mission and that it is managing them appropriately. Further, while FDA has taken foundational steps for IT modernization—including consolidating and updating its data centers and completing modernization projects for some IT systems— FDA has experienced ongoing delays and changes of direction to the MARCS program, one of its largest systems modernization efforts. This state of flux is exacerbated by the lack of an IMS for the program, resulting in uncertainty about when, or if, the planned functionality will be delivered and the ORA legacy systems retired. Compounding these concerns, FDA has yet to establish key IT planning and management disciplines that remain essential for carrying out a successful modernization effort. Without an actionable IT strategic plan, a complete enterprise architecture, and attention to its IT human capital needs, FDA will continue to be challenged in completing its modernization efforts. If implemented, our previous recommendations to establish these IT capabilities could help FDA successfully carry out these efforts. Finally, while FDA has taken important steps to improve its sharing of mission- critical data, until CFSAN conducts a full assessment of its data-sharing needs it may be missing opportunities for increased efficiencies and a reduction in duplication and unnecessary effort. While the agency’s new CIO is reassessing several aspects of FDA’s modernization program, it remains crucial that any future efforts are guided by rigorous and disciplined planning and management.

Recommendations for Executive Action

To help ensure the success of FDA’s modernization efforts, we are recommending that the Commissioner of FDA direct the CIO to take the following four actions:

Take immediate steps to identify all of FDA’s IT systems and develop an inventory that includes information describing each system, such as costs, system function or purpose, and status information, and incorporate use of the system portfolio into the agency’s IT investment management process.

In completing the assessment of MARCS, develop an IMS that identifies which legacy systems will be replaced and when; identifies all current and future tasks to be performed by contractors and FDA; and defines and incorporates information reflecting resources and critical dependencies.

Monitor progress of MARCS against the IMS.

Assess information-sharing needs and capabilities of CFSAN to identify potential areas of improvements needed to achieve more efficient information sharing among databases and develop a plan for implementing these improvements.

Agency Comments and Our Evaluation

HHS provided written comments on a draft of this report, signed by the Assistant Secretary for Legislation (the comments are reproduced in app. II). In its comments, the department neither agreed nor disagreed with our recommendations but stated that FDA has taken actions to address many of the issues in our report.

In its comments, HHS stated that FDA’s initiative to modernize its IT infrastructure comprises multiple phases. The first phase includes the data center modernization effort, which the department stated has provided FDA with an advanced computing infrastructure and a production data center with a secure computing environment. According to HHS, this infrastructure modernization and consolidation effort serves as the foundation for all other transition activities, and positions FDA to move forward with the second phase: implementing data center operation management and service contract efficiencies while working on modernizing and consolidating software systems with similar business processes and expediting the retirement of legacy systems.

Our report recognizes the progress that FDA has made in modernizing its data center infrastructure, and we agree that this effort is a key component of the agency’s overall modernization initiative. However, as we also noted, over the last decade—and concurrent with its data center modernization effort—FDA has spent tens of millions of dollars on software systems modernization projects that were intended to provide updated functionality and enable the retirement of legacy systems. In particular, FDA spent approximately $160 million from fiscal year 2002 to fiscal year 2011 on MARCS, yet it has repeatedly delayed milestones for delivering capabilities and retiring legacy systems. Moreover, this spending on system development and modernization has occurred in the absence of fully implemented IT management capabilities such as an IT strategic plan, a complete enterprise architecture, and a strategic approach to IT human capital, as well as an IMS for MARCS.

HHS also identified several recent efforts that it stated will address issues we raised in our report:

FDA’s senior executive team (which includes the CIO) has committed to governing the agency’s IT portfolio. As part of these responsibilities, the team has conducted sessions to identify the top 5 to 10 capabilities that are needed for the agency to meet the challenges of operating in a globalized regulatory environment. Further, to assist in the management of IT investments, FDA’s Office of Information Management is in the process of establishing a new Project Management Office to provide effective services aligned with the agency’s strategic priorities.

FDA has initiated several large program or project reviews to identify areas for improvement, potential for streamlining, and projects that should be stopped, continued, or started. Specifically, FDA has evaluated, and halted, the Janus project, and is conducting a detailed review of MARCS. The agency is also revising its draft IT strategic plan and working to define and implement its enterprise architecture.

FDA is assessing its IT workforce in Office of Information Management divisions to identify skill-set gaps, develop staff training plans, and identify resource needs. The agency stated that it has set aside training dollars and approved staff training plans, but acknowledged that workforce development activities must be a recurring process in order to ensure its skills keep pace with evolving technologies and methodologies. Further, the agency stated that FDA is committed to placing permanent leadership in all remaining acting positions that report directly to the CIO. Specifically, FDA has posted and closed job vacancy announcements for these positions and is evaluating applicants.

As noted in our report, we recognize and support these efforts, many of which have been initiated by the recently hired CIO. The success of these efforts could be enhanced by FDA’s full implementation of the recommendations that we have made in this report and in our 2009 report.

Finally, with regard to our recommendation that FDA develop an IT systems inventory that includes information describing each system— such as costs, system function or purpose, and status information—and incorporate use of the system portfolio into the agency’s IT investment management process, FDA provided an inventory of systems after we sent the draft report for review. This inventory included information on 282 IT systems, but did not provide all key information, such as cost and status. Moreover, agency officials stated that the inventory had not yet been validated for completeness and accuracy.

HHS also provided technical comments on the report, which we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the Commissioner of the Food and Drug Administration, appropriate congressional committees, and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have questions on matters discussed in this report, please contact me at (202) 512-6304 or melvinv@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made contributions to this report are listed in appendix VII.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to (1) assess the Food and Drug Administration’s (FDA) current portfolio of information technology (IT) systems, including the number of systems in use and under development, and their purpose and costs; (2) assess the status and effectiveness of FDA’s efforts to modernize the mission-critical systems that support its regulatory programs; and (3) examine the agency’s progress in effectively integrating and sharing data among key systems.

To assess FDA’s portfolio of IT systems, we reviewed documentation identifying key systems and major modernization initiatives, the Office of Management and Budget’s (OMB) exhibit 300s and exhibit 53s, and a list of FDA’s mission-critical systems. We evaluated FDA’s list of IT systems and modernization initiatives and assessed it against OMB guidance and GAO’s IT investment management framework. We reviewed the agency’s budget submissions and the investments listed for fiscal year 2011 exhibits 53 and 300 and compared them to other agency documentation providing systems’ descriptions. We interviewed agency officials responsible for developing a portfolio of IT systems and the Chief Information Officer (CIO) to assess the agency’s plans for identifying improvements in its process of identifying and overseeing a comprehensive IT portfolio.

Department of Health and Human Services, Enterprise Performance Life Cycle Framework (Washington, D.C.: September 2011). data reflected on the agency’s federal IT Dashboard. Further, because Mission Accomplishments and Regulatory Compliance Services (MARCS) was one of the agency’s largest and costliest mission-critical modernization efforts and was considered essential to the Office of Regulatory Affairs’ (ORA) compliance activities, we evaluated the project’s status and whether the effort is following best practices. Specifically, we assessed the program’s documentation, including agency plans, schedules, and contractor statements of work, as well as various components and interviewed relevant project managers and technical specialists. We compared FDA’s schedules with best practices for developing an integrated master schedule to plan and manage the effort.

We also evaluated FDA’s progress in addressing our prior recommendations related to FDA’s implementation of key IT management practices: IT strategic planning, enterprise architecture, and IT human capital planning. To do so, we looked at whether policies or processes were in place for IT investment management, human capital, and enterprise architecture. We based our analysis on three frameworks: our IT investment management framework, our framework for strategic human capital management, and our enterprise architecture management maturity framework.

The IT investment management framework provides a rigorous standardized tool for evaluating an agency’s IT investment management processes and a roadmap agencies can use for improving their investment management processes.

The framework for strategic human capital management lays out principles for managing human capital. We evaluated FDA’s policies and procedures against this framework.

The enterprise architecture management maturity framework describes stages of maturity in managing enterprise architecture.

Each stage includes core elements, which are descriptions of a practice or condition that is needed for effective enterprise architecture management. We evaluated FDA’s implementation of four core elements from stage 2 (Creating the Management Foundation for Enterprise Architecture Development and Use). We did not perform a complete enterprise architecture management maturity framework assessment, and we did not audit specific IT projects to analyze how well the policies and procedures were implemented. To supplement the framework criteria, we used criteria from the Federal Enterprise Architecture Practice Guidance issued by OMB and compared FDA’s progress on its architecture with these criteria.

To determine the agency’s progress in effectively integrating and sharing data among key systems, we reviewed project plans, schedules, and other documents describing FDA’s efforts to implement Health Level Seven (HL7) data standardization for the exchange and analysis of information. We also assessed the progress of modernization initiatives aimed at improving standards and data sharing. Specifically we assessed FDA’s modernization initiatives by comparing the Enterprise Performance Life Cycle stage of the projects from 2009 with the project stages in 2012.

We selected FDA’s Center for Food Safety and Applied Nutrition (CFSAN) to assess sharing across databases supporting FDA’s regulatory mission because of previously identified deficiencies in specific functions, such as sharing on recalls of contaminated foods. We analyzed the number of CFSAN databases, their purposes, and corresponding IT systems used, and assessed the efforts and methodology used by the center to improve information sharing and exchange between databases against OMB and Federal CIO Council enterprise architecture guidance.

We supplemented our analysis with interviews of the agency’s CIO, Chief Technology Officer, Chief Enterprise Architect, Senior Technical Advisor, and other relevant IT managers regarding management of FDA’s IT portfolio, the status of and plans to modernize key systems such as MARCS, shortfalls in mission-related systems, IT strategic and human capital planning, status of enterprise architecture development, and efforts to improve interoperability of systems that support FDA’s regulatory mission. In addition, we visited FDA facilities at the Port of Baltimore in Baltimore, Maryland, to observe a demonstration of new capabilities to screen imports. We requested and received documentation from FDA on its agencywide modernization projects, including descriptions of their purpose and project summary status reports showing their expected completion dates and other milestones.

We conducted this performance audit primarily at FDA’s headquarters in White Oak, Maryland, from March 2011 to March 2012 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.

Appendix II: Comments from the Department of Health and Human Services

Appendix III: Food and Drug Administration IT Mission-Critical Systems and Modernization Initiatives

FDA provided us with the following list of 21 mission-critical systems and modernization initiatives in response to our request for the agency’s IT portfolio.

Appendix IV: FDA IT Investments

The following table provides details on FDA’s IT investments, as described in the agency’s fiscal year 2013 exhibit 53 submission.

Appendix V: Mission Accomplishment and Regulatory Compliance Services History

FDA began the MARCS effort in 2002, and since that time has made several shifts in its approach. At that time, ORA envisioned that the program would replace its two key legacy systems, the Operational Administrative System for Import Support (OASIS) and the Field Accomplishments and Compliance Tracking System (FACTS). Since 2002, the program’s requirements were changed and broadened to include replacement of six additional legacy systems. In April 2005, FDA developed a design that envisioned a set of integrated service components intended to provide the applications and tools to support the agency’s import operations, field operations, compliance operations, firm management, workload management, and selected aspects of laboratory operations. The agency estimated that development would cost about $75 million and be completed in 2008.

However, later in 2005, a decision was made to put the current vision for the program on hold, and instead implement web-enabled versions of OASIS and FACTS. According to an Office of Information Management (OIM) supervisory IT specialist, the migration to web-enabled systems allowed the agency to implement single sign-on and enabled the legacy systems to integrate more easily with new functionality. According to the Program Manager and contract officials, the decision to implement web- enabled versions was also motivated by vendor plans to halt support for the current OASIS and FACTS platform and uncertainty about funding for the program.

In April 2006, FDA rebaselined the program estimate to include development costs and maintenance costs for the entire program life cycle. FDA estimated that the total life-cycle cost would be $221.4 million, and the investment would end in August 2019. It estimated that development would cost $113.8 million, and most development would be complete by November 2012.

According to the Program Manager and contract officials, between 2006 and 2009, FDA’s work included the following: In 2006, migration of OASIS and FACTS to a web-enabled version was completed.

In May 2007, the program was rebaselined again with a slight increase in development costs to $115 million.

In 2008, migration to a new operating system, UNIX, was completed.

In late 2008, the agency began development of the Predictive Risk- based Evaluation for Dynamic Import Compliance Targeting (PREDICT), intended to replace the automated import admissibility screening module of OASIS, which relied on direct inputs of rules, providing risk ranking, automated database lookups, and warnings in the case of data anomalies or likely violations.  During this time, additional legacy systems were planned for inclusion in the program, and the agency also developed some of the support services envisioned such as firm management and a document repository.

In 2009, the collection of legacy systems planned for the program was based on a wide variety of disparate technologies with redundant and inconsistent data. According to officials, the program received multiyear funding to resume development of the system based on the design from 2005. FDA awarded a master integrator contract in late 2009 for incremental development of MARCS by a single integrator. In May 2009, the agency rebaselined the program to accelerate delivery of functionality and include PREDICT. FDA’s rebaselined estimate for the life-cycle cost was $253.6 million with development costs of $143.3 million, based on completing most development in September 2014. According to FDA, in 2010, the agency updated and revalidated the program’s requirements.

According to OMB exhibit 53s from 2004 to 2013, FDA has spent approximately $160 million from fiscal year 2002 to fiscal year 2011 on MARCS. Figure 4 shows these expenditures, as well as enacted spending for fiscal year 2012.

In August 2011, FDA again rebaselined the program estimates to account for new legislative and regulatory requirements based on the FDA Food Safety Modernization Act. It estimated that the total life-cycle cost will be $282.7 million and planned to deploy a significant portion of MARCS and retire its legacy systems by July 2014. Table 5 provides details on the program estimates over time.

Appendix VI: Center for Food Safety and Applied Nutrition IT Systems Investments

To fulfill its regulatory mission, FDA’s CFSAN relies on various information systems. According to FDA documentation and interviews with agency officials, the center funds 21 databases and their associated systems. These systems fall into seven major categories such as registration, regulatory management, and adverse events. The following table provides details on the seven categories and a brief description of the systems that comprise them.

Appendix VII: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, key contributions were made to this report by Christie Motley, Assistant Director; Neil Doherty; Anh Le; Jason Lee; J. Chris Martin; Lee McCracken; Umesh Thakkar; Daniel Wexler; Merry Woo; and Charles Youman.