Financial Management: Department of Homeland Security Faces Significant Financial Management Challenges
Released: 2004-07-29T00:00:00

Letter

Background

In the aftermath of the terrorist attacks of September 11, 2001, responding to potential and real threats to homeland security became one of the federal government’s most significant challenges. To address this challenge, the Congress passed, and the President signed, the Homeland Security Act of 2002, which merged 22 federal agencies and organizations into DHS, making it the department with the third largest budget in the federal government, about $40 billion for fiscal year 2005. In January 2003, we designated implementation and transformation of the new Department of Homeland Security as high risk based on three factors: (1) the implementation and transformation of DHS is an enormous undertaking that will take time to achieve in an effective and efficient manner, (2) components to be merged into DHS already face a wide array of existing challenges, and (3) failure to effectively carry out its mission would potentially expose the nation to very serious consequences. As we previously reported, one of the department’s key challenges is integrating the components’ respective financial management systems, many of which were outdated and had limited functionality, as well as addressing weaknesses from the inherited components.

The Homeland Security Act of 2002 states that DHS’s missions include, among other things, preventing terrorist attacks within the United States, reducing America’s vulnerability to terrorism, minimizing subsequent damage, and assisting in the recovery from attacks that do occur. To help accomplish this integrated homeland security mission, the various mission areas and associated programs of 22 federal agencies were merged, in whole or in part, into DHS. The department’s organizational structure consists of eight major components—the U.S. Coast Guard (Coast Guard), the U.S. Secret Service, the Bureau of Citizenship and Immigration Services (CIS), and five directorates, each of which is headed by an Under Secretary: Information Analysis and Infrastructure Protection, Science and Technology, Border and Transportation Security, Emergency Preparedness and Response, and Management. Within the Management Directorate is DHS’s Office of the Chief Financial Officer (OCFO), which is assigned primary responsibility for functions, such as budget, finance and accounting, strategic planning and evaluation, and financial systems for the department. OCFO is also charged with ongoing integration of these functions within the department.

The CFO Act requires the agency’s CFO to develop and maintain an integrated accounting and financial management system that provides for complete, reliable, and timely financial information that facilitates the systematic measurement of performance at the agency, the development and reporting of cost information, and the integration of accounting and budget information. The act also requires that the agency’s CFO be qualified, presidentially appointed, approved by the Senate, and report to the head of the agency. FFMIA requires that CFO Act agencies implement and maintain financial management systems that substantially comply with federal financial management systems requirements, applicable accounting standards, and the U.S. Government Standard General Ledger at the transaction level. It also requires auditors to report whether the agency’s financial management systems substantially comply with the three requirements of FFMIA. While not required to comply with provisions of the CFO Act or FFMIA, the Accountability of Tax Dollars Act of 2002, requires DHS to prepare and have audited financial statements annually. The Accountability of Tax Dollars Act of 2002, however, does not require compliance with the CFO Act or FFMIA.

In identifying improved financial performance as one of its five governmentwide initiatives, the President’s Management Agenda recognized that an unqualified financial audit opinion is a basic prescription for any well-managed organization and that without sound internal control and accurate and timely financial information, it is not possible to accomplish the agenda and secure the best performance and highest measure of accountability for the American people. In addition, the Joint Financial Management Improvement Program (JFMIP) Principals have defined certain measures, in addition to receiving an unqualified financial statement opinion, for achieving financial management success. These additional measures include being able to routinely provide timely, accurate, and useful financial and performance information, having neither material internal control weaknesses nor material noncompliance with laws and regulations, and meeting the requirements of FFMIA.

DHS obtained a consolidated financial audit for the 7-month period from March 1, 2003, to September 30, 2003, and received a qualified opinion from its independent auditors on its consolidated balance sheet as of September 30, 2003, and the related statement of custodial activity for the 7 months ending September 30, 2003. Auditors were unable to opine on the consolidated statements of net costs and changes in net position, combined statement of budgetary resources, and consolidated statement of financing. The auditors reported 14 reportable conditions on internal control, 7 of which were considered to be material weaknesses.

DHS Inherited Significant Weaknesses from Its Component Agencies

When DHS was created in March 2003 and merged with 22 diverse agencies, there were many known financial management weaknesses and vulnerabilities in the inherited agencies. For 5 of the agencies that transferred to DHS—Customs Service (Customs), Transportation Security Administration (TSA), Immigration and Naturalization Service (INS), Federal Emergency Management Agency (FEMA), and Federal Law Enforcement Training Center (FLETC)—auditors had reported 30 reportable conditions, 18 of which were considered material internal control weaknesses. Further, of the four component agencies—Customs, TSA, INS, and FEMA—that had previously been subject to stand-alone audits, all four agencies’ systems were found not to be in substantial compliance with the requirements of FFMIA.

Most of the 22 components that transferred to DHS had not been subjected to significant financial statement audit scrutiny prior to their transfer, so the extent to which additional significant internal control deficiencies existed was unknown. For example, conditions at the Coast Guard have surfaced because of its greater relative size and increased audit scrutiny at DHS as compared to its former legacy agency, the Department of Transportation (DOT). As part of DOT’s financial statement audit, the Coast Guard had no specifically attributable reported weaknesses identified. However, newly identified weaknesses related to the Coast Guard were one of the main reasons that independent auditors issued a qualified opinion on DHS’s consolidated balance sheet and why they were unable to provide an opinion on other financial statements for the 7 months ending September 30, 2003.

For fiscal year 2002 and prior to its transfer to DHS, Customs’ auditors reported nine internal control weaknesses, including weaknesses in its ability to monitor the effectiveness of its internal controls over entry duties and taxes, controls over drawback claims, security issues in information technology (IT) systems, and issues concerning the strength of its core financial systems. These weaknesses can result in inaccurate reporting of certain material elements of Customs’ financial situation, system security weaknesses that could leave Customs’ information vulnerable to unauthorized access, and the necessity of extensive manual procedures and analyses to process routine transactions. Finally, these weaknesses contributed to Customs’ systems inability to substantially comply with the requirements of FFMIA.

Although TSA is a relatively new agency formed after the September 11, 2001, terror attacks, its auditors reported six internal control weaknesses, including weaknesses in the hiring of qualified personnel, financial reporting and systems, property accounting and financial reporting, financial management policies, administration of screener contracts, and maintenance of adequate information in its personnel files. These weaknesses can result in uncontrolled spending of taxpayer dollars, misplaced or unaccounted for property, and challenges in producing financial statements. In its first year audit ending September 30, 2002, TSA obtained an unqualified audit opinion on its financial statements. However, TSA’s systems did not substantially comply with the requirements of FFMIA.

INS’s auditors reported four internal control weaknesses as of February 28, 2003, including weaknesses in the functionality of its financial systems; recording accounts payable and related accruals; financial reporting; and controls over its financial management system. Weaknesses such as these have existed for several years and contribute to INS’s systems continuing inability to substantially comply with the requirements of FFMIA. Although the weaknesses did not interfere with the agency’s ability to obtain an unqualified opinion on its financial statement audit, they did result in the need for extensive manual effort to prepare reliable financial information and record basic financial transactions to aid management in decision making.

FEMA’s auditors reported seven internal control weaknesses for fiscal year 2002, including weaknesses in information security controls over its financial systems environment; financial system functionality; financial reporting process; real and personal property system processes; account reconciliation processes; accounts receivable processes; and the lack of a process to evaluate the accuracy of a new claims estimation methodology. These weaknesses resulted in the need for extensive manual effort to compile financial information because FEMA’s financial systems were unable to perform certain basic accounting functions efficiently. Further, FEMA’s systems were unable to accurately track basic accounting information, such as real and personal property and accounts receivable. Many of these weaknesses specifically contributed to FEMA’s systems’ failure to substantially comply with the requirements of FFMIA.

Finally, FLETC’s auditors reported four internal control weaknesses for fiscal year 2002. These weaknesses resulted from FLETC not having adequate policies and procedures in place to ensure that funds obligated were proper and that costs for construction in progress were recorded properly. Further, auditors found that FLETC was not taking the steps necessary to be in compliance with certain Office of Management and Budget requirements. Many of these weaknesses lead to FLETC’s systems’ inability to substantially comply with the requirements of FFMIA.

Some Progress Made in Addressing Inherited Weaknesses

DHS has made some progress in addressing the internal control weaknesses it inherited from component agencies. Nine of the 30 internal control weaknesses identified in prior component financial statement audits have been closed as of September 30, 2003. The remaining 21 issues represent continuing weaknesses that have been reported in DHS’s first Performance and Accountability Report. Nine of these were combined and reported as 3 material weaknesses, while 5 were reported as reportable conditions. The department’s independent auditors classified the remaining 7 weaknesses as lower level observations and recommendations. Table 1 summarizes the status of the 30 weaknesses DHS inherited from component agencies as of September 30, 2003.

Auditors reported 6 additional weaknesses as of September 30, 2003, bringing the total number of reportable conditions for DHS to 14 for fiscal year 2003, 7 of which were considered to be material weaknesses. A description of these weaknesses can be found in appendix II. As mentioned previously, several of the departmentwide weaknesses resulted from combining previously identified weaknesses or reclassifying them, rather than from resolving the underlying internal control weaknesses. For example, in fiscal year 2003, DHS’s auditors reported a departmentwide material weakness related to financial systems functionality and technology. This weakness resulted from combining what accounted for 7 of the inherited weaknesses—3 from Customs, 2 from FEMA, 1 from INS, and 1 from TSA. Appendix III provides detailed information on the status of each of the 30 inherited weaknesses, including how they were reported in DHS’s Performance and Accountability Report.

Component agencies took various steps to resolve nine of the previously identified weaknesses inherited from component agencies. For example, Customs had a previously identified weakness related to the effectiveness of its internal controls over accurate reporting of entry duties and taxes. This weakness was resolved by reinstituting a program that Customs had in place prior to the terrorist attacks of September 11, 2001, which allows for more accurate reporting of these taxes and duties. Another weakness DHS inherited relates to FEMA’s inability to identify and record certain accounts receivable in a timely manner. FEMA’s accounts receivable processes were strengthened to ensure that accounts receivable are determined and recorded on a timely basis. In order to resolve several weaknesses at FLETC and TSA, various policies and procedures were implemented at these components to ensure that financial information was recorded and properly approved. Further, TSA has hired additional staff, thereby resolving its weaknesses of not having a sufficient number of qualified accounting personnel.

In addition to the 7 material weaknesses and 7 reportable conditions reported in DHS’s 2003 financial statement audit, DHS reported 12 additional weaknesses that affect the department’s full compliance with certain objectives of 31 U.S.C. 3512(c), (d) (commonly known as the Federal Managers’ Financial Integrity Act of 1982 (FMFIA)). FMFIA requires that management ensure that it has an organizational structure that supports the planning, directing, and controlling of operations to meet agency objectives; clearly defines key areas of authority and responsibility; and provides for appropriate lines of reporting. The standards also define internal control as a key component necessary to ensure that financial reporting information is reliable. Examples of the FMFIA weaknesses reported by DHS included deficient controls over laws and regulations regarding the border entry process, nonconformance related to system security, and lack of oversight and administration of major contracts at TSA.

Of the seven departmentwide material weaknesses reported by DHS’s auditors for fiscal year 2003, four were newly identified and contributed to the auditors’ inability to render an opinion on all of DHS’s financial statements. Newly identified weaknesses included the lack of procedures at DHS to verify the accuracy and completeness of balances transferred on March 1, 2003, and significant weaknesses with the number of qualified financial management personnel employed by the department. DHS’s auditors also found significant deficiencies at the Coast Guard and Secret Service, preventing them from being able to express an opinion on certain financial statements.

In addition to the internal control weaknesses cited in its 2003 financial statement audit, there were other weaknesses that, while not material to DHS on a departmentwide basis, are still important weaknesses that need to be addressed. FEMA, Customs, and TSA each had weaknesses at the time of their transfer to DHS. However, in the 2003 audit report, these weaknesses were classified as observations and recommendations, a much less serious classification. Lower classification within DHS does not mean that the issues are now somehow less severe, it merely refers to the materiality of a component within DHS. Considered against operations or assets of the stand-alone entity, these issues by themselves were relatively more significant than when considered in the context of the much larger consolidated operations of DHS as a whole. Resolving all previously reported internal control weaknesses, regardless of the current designation at DHS, is key to DHS’s ability to produce relevant and reliable financial information.

DHS’s CFO testified that the department is committed to resolving the remaining weaknesses and has developed a plan to do so. According to the CFO’s plans, corrective actions will be developed by each applicable bureau or directorate and submitted to the OCFO. Currently, DHS’s OCFO has compiled a summary document with the corrective action plans as submitted by the applicable bureau or directorate. According to this document, corrective action plans of varying levels of detail are in place to address 12 of the 14 internal control weaknesses, some of which are scheduled to be completed by the end of fiscal year 2004. However, 2 material internal control weaknesses—Financial Systems Functionality and Technology and Transfer of Funds, Assets, and Liabilities to DHS—do not currently have any planned corrective actions in place.

Along with developing corrective action plans, the CFO testified that DHS plans to implement a departmentwide tracking system to monitor the status of corrective actions. DHS has begun working with a contractor to design and implement a tracking system for outstanding weaknesses identified during the department’s independent financial audits. While this system is still being developed by the OCFO, with assistance from contractors, it is not yet fully functional and does not include information on all reported weaknesses. Until such time that it does, it will provide limited oversight and information on the status of corrective actions to address weaknesses at DHS. While progress has been made to address the known material weaknesses, much work still remains. Follow-through with planned corrective actions is paramount. The support of top officials at the department will be key in ensuring that the necessary resources are available to address the weaknesses and to ensure that they are resolved in a timely manner.

DHS Is in the Early Stages of Integrating Its Financial Management Systems

DHS intends to acquire and deploy an integrated financial enterprise solution and reports that it has reduced the number of its legacy financial systems. DHS has established the Resource Management Transformation Office (RMTO) within the Management Directorate to manage its financial enterprise solution project. However, the acquisition is in the early stages, and continued focus and follow through, among other things, will be necessary for it to be successful.

RMTO has termed its financial enterprise solution project “electronically Managing enterprise resources for government effectiveness and efficiency” (eMerge), which according to the RMTO’s Strategic Framework, “establishes the strategic direction for migration, modernization, and integration of DHS financial, accounting, procurement, personnel, asset management and travel systems, processes, and policies.” DHS expects the acquisition and implementation of the financial enterprise solution to take place over a 3-year time period and cost approximately $146 million.

According to the strategic framework DHS provided to us, the development of an integrated financial enterprise solution will be accomplished in three phases. Phase I includes defining, acquiring, and testing the planned solution. Phase II involves implementing the solution throughout DHS, and Phase III is ongoing maintenance of the solution. According to DHS, the eMergevendor selection to occur in April or May of 2004. However, vendor proposal requests were issued in June 2004 and selection is to be completed in July 2004.

Concurrent with eMerge, DHS has issued a request for quotation (RFQ) for an interim project—the Business Automation Initiative—to be developed by contractors during 2004. The RFQ requested system proposals to automate purchase requests for the department and to streamline the employee entry/exit process. Another interim initiative was considered by the department to integrate data mining and warehousing, improve grants visibility (beginning with first responder grants), and streamline financial statement consolidation. However, instead of pursuing this interim solution, DHS plans to include it in the requirements of the eMerge initiative and obtained approval of the requirements from various high-level DHS officials. Additionally, a request for proposal (RFP) was issued by DHS for the eMerge initiative. However, these documents were not provided to us until after we completed our fieldwork. Thus, we are not providing description, analysis, or evaluation of such information in this report, and we are unable to determine if DHS, through the RMTO, is developing a financial enterprise solution that will be in alignment with departmentwide information technology plans, many of which are still under development.

Nevertheless, we have found that similar projects have proven challenging and costly for other federal agencies. For example, we have reported on the efforts of National Aeronautics and Space Administration (NASA), and the District of Columbia Courts (DC Courts) to acquire new information systems. NASA is on its third attempt in 12 years to modernize its financial management process and systems, and has spent about $180 million on its two prior failed efforts. DC Courts began its system acquisition in 1998 and has struggled in its implementation. One of the key impediments to the success of integration efforts at NASA was the failure to involve key stakeholders in the implementation or evaluation of system improvements. As a result, new systems failed to meet the needs of key stakeholders. DC Courts struggled in developing requirements that contained the necessary specificity to ensure the system developed would meet its users’ needs. To avoid similar problems, it is important, among other things, that DHS ensure commitment and extensive involvement from top management and users in eMergeAlthough we did not perform audit procedures to determine the impact of these reductions, reduction of service providers prematurely, without considering the provider’s reliability, or without an overall consolidation plan, could be negative if it interferes with the enterprise approach or causes significant short-term inefficiencies for agencies that must quickly adapt to other systems.

It Is Not Known Whether DHS’s Planned Financial Management Systems Will Be Able to Meet the Requirements of Relevant Financial Management Improvement Laws

It is too early to tell whether DHS’s planned financial enterprise solution will be able to meet the requirements of relevant financial management improvement laws-–those currently applicable to DHS (such as FMFIA), as well as some not applicable that are subject to pending legislation. DHS is currently subject to most financial management improvement laws except for the CFO Act and FFMIA. The goals of the CFO Act and FFMIA are to provide the Congress and agency management with reliable financial information for managing and making day-to-day decisions and to improve financial management systems and controls to properly safeguard the government’s assets. Further, the CFO Act requires certain agencies to have a qualified, presidentially appointed, Senate-confirmed CFO who reports to the head of the agency.

FFMIA requires major departments and agencies covered by the CFO Act to implement and maintain financial management systems that comply substantially with (1) federal financial management systems requirements, (2) applicable federal accounting standards, and (3) the U.S. Government Standard General Ledger at the transaction level. Although DHS is not currently subject to FFMIA, its auditors disclosed systems deficiencies in its financial management information systems, the application of accounting standards, and recording of financial transactions, all of which relate to the requirements of FFMIA. Based on these weaknesses it is likely that DHS’s systems would not have been in substantial compliance with the requirements of FFMIA. Table 3 lists relevant financial management laws and describes their relationship to DHS.

DHS is currently required to have annual audits under the Accountability of Tax Dollars Act and to report on its internal controls under FMFIA. Although DHS’s CFO has testified that DHS complies with the audit provisions of the CFO Act and will continue to do so, we believe DHS should be a CFO Act agency and be subject to the requirements of FFMIA. DHS should not be the only cabinet-level department not covered by what is the cornerstone for pursuing and achieving the requisite financial management systems and capabilities in the federal government.

Given its early implementation, it is too early to tell whether DHS’s planned financial enterprise solution will meet the requirements of financial management laws it is currently not subject to. While DHS systems must meet the requirements of laws they are currently subject to, it is also important that DHS be proactive and incorporate the requirements of the CFO Act and FFMIA. It would certainly make good business sense to do so given DHS’s size and mission.

DHS has implemented a commercial-off-the-shelf tool called Dynamic Object Oriented Requirements System (DOORS) to track the requirements of various laws, regulations, and circulars place on the development of an integrated financial system. DOORS is intended to be DHS’s repository of all applicable system, process, technological, data, or other requirements. DHS estimated that several thousand compliance requirements will be tracked using DOORS once analysis is completed. After the repository is complete, requirements reports are to be printed directly from DOORS and attached to future RFPs to ensure that contractors are aware of the legislative requirements of the systems to be developed. A system to record, track, and link all legislative requirements as a financial management system is being developed is important. Also important is that DHS be statutorily required to comply with the CFO Act and FFMIA and that the systems DHS acquires are capable of meeting the requirements of those laws, as well as ones currently applicable. Meeting these financial management improvement requirements will help produce timely and useful financial and business information.

Conclusions

Since its inception in March 2003, DHS has been faced with many challenges, including how to integrate its financial management processes and systems. Steps have been taken to address the 30 internal control weaknesses it inherited from its component agencies. However, to ensure financial accountability and establish an effective financial environment, DHS must address all outstanding inherited weaknesses, as well as address the newly identified department-level weaknesses. Through the eMerge initiative, DHS has plans to integrate and consolidate its financial and business systems. But without such things as continued active oversight from top-level management and systematic approaches to this integration, DHS could find itself in the same position as other federal departments— producing an ineffective and costly financial management system that does not provide the information needed by management or meet the requirements of financial management laws. Finally, we believe that it is of critical importance that DHS be statutorily required to comply with the important financial management reforms legislated in the CFO Act and FFMIA. The financial management improvements of FFMIA build on the CFO Act by emphasizing the need for agencies to have systems that can generate reliable, useful, and timely information with which to make fully informed decisions and to ensure accountability on an ongoing basis. This issue is still of foremost importance, especially as DHS continues its financial management system integration and development.

Matter for Congressional Consideration

In view of the size of DHS and the importance of the CFO Act and FFMIA in improving financial management and its applicability to all other cabinet departments, the Congress may wish to consider the following action: Enact legislation to designate DHS as a CFO Act agency.

Recommendations for Executive Action

We are making eight recommendations for executive action at DHS that will improve financial management at the department. Specifically, we recommend that the Secretary of Homeland Security direct the Under Secretary for Management to do the following: Continue to maintain strong involvement of key stakeholders and top management throughout the acquisition and implementation of the eMerge Maintain a tracking system of all auditor-identified and management- identified control weaknesses.

Agency Comments and Our Evaluation

We obtained written comments on a draft of this report from DHS’s Chief Financial Officer. The comments DHS provided to us are reprinted in appendix IV.

In commenting on a draft of this report, DHS generally agreed with the overall findings and recommendations. However, in response to our recommendation to incorporate all internal control weaknesses in the tracking system DHS is currently developing, DHS felt the recommendation was too broad and suggested that we change the language to reflect tracking of all auditor-identified and management-identified internal control weaknesses. The original intent of our recommendation was to encourage DHS to track and resolve all auditor reported material weaknesses, reportable conditions, and observations and recommendations, similar to those discussed throughout this report. We fully support DHS including all management-identified control weaknesses as well, and have updated our recommendation accordingly. Additionally, DHS commented on its commitment to full adherence to the CFO Act and FFMIA. We applaud the current leadership at DHS for voluntarily complying with some audit provisions of the CFO Act, however, we continue to strongly support passage of legislation that would statutorily make DHS a CFO Act agency, and thus guarantee future requirements to adhere to important financial management legislation.

As arranged with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days after the date of this letter. At that time, we will send copies of this report to interested congressional committees and subcommittees. We will also make copies available to others on request. In addition, the report will be available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report or wish to discuss it further, please contact me at (202) 512-6906 or Casey Keplinger, Assistant Director, at (202) 512-9323. In addition, Heather Dunahoo and Scott Wrightson made key contributions to this report.

Scope and Methodology

To identify what were the existing weaknesses in the Department of Homeland Security’s (DHS) component agencies’ financial management systems, we reviewed relevant DHS Office of Inspector General (OIG) reports and our January 2003 report on major management challenges at DHS and looked at how such challenges are being addressed. We also reviewed DHS’s Performance and Accountability Report for the 7 months ending September 30, 2003. We reviewed prior-period component agency annual financial statement audit reports when available; Immigration and Naturalization Service’s (INS) financial statement audit report for the 5 months ending February 28, 2003; and Performance and Accountability Reports for the Federal Emergency Management Agency (FEMA) and the Departments of Transportation, Justice, and Treasury. We reviewed testimony of DHS’s current and former Chief Financial Officer (CFO) and DHS’s OIG reports related to financial management at the department. Finally, we interviewed officials from the OIG and the Office of the Chief Financial Officer (OCFO).

To determine whether DHS was addressing the problems that existed in the financial management systems DHS acquired from its component agencies, we met with officials from the OCFO’s Office of Financial Management and OIG staff. In addition to items already mentioned, we reviewed planned corrective actions developed by the department to address its fiscal years 2002 and 2003 material weaknesses and reportable conditions. We also reviewed testimony of DHS’s CFO related to this issue. Further, we conducted a walk-through to review the system DHS is developing to track planned corrective actions.

To determine what plans DHS has to integrate its financial management systems, we met with the Director of the Resource Management Transformation Office (RMTO) and other staff in this office. We also reviewed testimony of DHS’s current and former CFO and DHS’s OIG related to financial management at the department. We reviewed documentation detailing the reduction of financial service providers, but we did not complete audit procedures to determine if these reductions were positive or negative for the department. Finally, we reviewed the RMTO’s strategic framework. However, substantial documentation related to the eMerge initiative was not provided to us until after we completed our fieldwork. Thus, we did not include analysis or evaluation of such information in this report.

To determine whether the planned systems that DHS is developing will be able to meet the requirements of relevant financial management improvement laws, we reviewed relevant laws and regulations, and relevant guidance related to financial management, financial reporting, systems implementation, and requirements. We also interviewed the Director of the RMTO and other officials. Further, we reviewed testimony relevant to this issue by DHS’s current and former CFO and DHS’s OIG. We have not reviewed system requirements or other recently developed plans because these were completed and obtained after our fieldwork was completed.

We requested comments on this report from the Secretary of Homeland Security or his designee. Written comments were received from the department’s Chief Financial Officer and are reprinted in appendix IV.

We performed our review from October 2003 through June 2004 in Washington, D.C., in accordance with U.S. generally accepted government auditing standards.

Material Weaknesses and Reportable Conditions at DHS for Fiscal Year 2003

Financial management and personnel: DHS’s OCFO needs to establish financial reporting roles and responsibilities, assess critical needs, and establish standard operating procedures (SOP) for the department. These conditions were not unexpected for a newly created organization, especially one as large and complex as DHS. The Coast Guard and the Strategic National Stockpile had weaknesses in financial oversight that have led to reporting problems.

Financial reporting: Key controls to ensure reporting integrity were not in place, and inefficiencies made the process more error prone. At the Coast Guard, the financial reporting process was complex and labor-intensive. Several DHS bureaus lacked clearly documented procedures, making them vulnerable if key people leave the organization.

Financial systems functionality and technology: The auditors found weaknesses across DHS in its entitywide security program management and in controls over system access, application software development, system software, segregation of duties, and service continuity. Many bureau systems lacked certain functionality to support the financial reporting requirements.

Property, plant, and equipment (PP&E): The Coast Guard was unable to support the recorded value of $2.9 billion in PP&E due to insufficient documentation provided prior to the completion of audit procedures, including documentation to support its estimation methodology. The Transportation Security Administration (TSA) lacked a comprehensive property management system and adequate policies and procedures to ensure the accuracy of its PP&E records.

Operating materials and supplies (OM&S): Internal controls over physical counts of OM&S were not effective at the Coast Guard. As a result, the auditors were unable to verify the recorded value of $497 million in OM&S. The Coast Guard also had not recently reviewed its OM&S capitalization policy, leading to a material adjustment to its records when an analysis was performed.

Actuarial liabilities: The Secret Service did not record the pension liability for certain of its employees and retirees, and when corrected, the auditors had insufficient time to audit the amount recorded. The Coast Guard also was unable to provide, prior to the completion of audit procedures, sufficient documentation to support the recorded value of $201 million in post-service benefit liabilities.

Transfers of funds, assets, and liabilities to DHS: DHS lacked controls to verify that monthly financial reports and transferred balances from legacy agencies were accurate and complete.

Drawback claims on duties, taxes, and fees: The Bureau of Customs and Border Protection’s (CBP) accounting system lacked automated controls to detect and prevent excessive drawback claims and payments.

Import entry in-bond: CBP did not have a reliable process of monitoring the movement of “in-bond” shipments—i.e., merchandise traveling through the U.S. that is not subject to duties, taxes, and fees until it reaches a port of destination. CBP lacked an effective compliance measurement program to compute an estimate of underpayment of related duties, taxes, and fees.

Acceptance and adjudication of immigration and naturalization applications: The Bureau of Citizenship and Immigration Services’ (CIS) process for tracking and reporting the status of applications and related information was inconsistent and inefficient. Also, CIS did not perform cycle counts of its work in process that would facilitate the accurate calculation of deferred revenue and reporting of related operational information.

Fund balance with Treasury (FBWT): The Coast Guard did not perform required reconciliations for FBWT accounts and lacked written standard operating procedures (SOP) to guide the process, primarily as the result of a new financial system that substantially increased the number of reconciling differences.

Intragovernmental balances: Several large DHS bureaus had not developed and adopted effective SOPs or established systems to track, confirm, and reconcile intragovernmental balances and transactions with their trading partners.

Strategic National Stockpile (SNS): The SNS accounting process was fragmented and disconnected, largely due to operational challenges caused by the laws governing SNS. A $485 million upwards adjustment had to be made to value SNS in DHS’s records properly.

Accounts payable and undelivered orders: CIS and the Bureau of Immigration and Customs Enforcement (ICE), TSA, and the Coast Guard had weaknesses in their processes for accruing accounts payable or reporting accurate balances for undelivered orders.

Disposition of Reported Internal Control Weaknesses by Component

Reportable Condition (Drawback Claims on Duties, Taxes, and Fees)

Material Weakness (Financial Systems Functionality and Technology)

Material Weakness (Financial Systems Functionality and Technology)

Observation & Recommendations to Management Reportable Condition (In-bond Movement of Imported Goods)

Observation & Recommendations to Management Material Weakness (Financial Systems Functionality and Technology)

Immigration and Naturalization Service (as of February 28, 2003)

Reportable Condition (Acceptance and Adjudication of Immigration and Naturalization Applications)

Reportable Condition (Accounts Payable and Undelivered Orders)

Observation & Recommendations to Management Material Weakness (Financial Systems Functionality and Technology)

Material Weakness (Financial Systems Functionality and Technology)

Material Weakness (Financial Systems Functionality and Technology)

Material Weakness (Financial Reporting)

Observation & Recommendations to Management Reportable Condition (Intragovernmental Balances)

Agency and Condition Reported in 2002 Federal Law Enforcement Training Center 22. Laws and Regulations (OMB Circular A-127) 24. Laws and Regulations (OMB Circular A-11)

Material Weaknesses (Financial Reporting; Financial Systems Functionality and Technology)

Material Weakness (Property, Plant, and Equipment)

Comments from the Department of Homeland Security

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