The goals of the Transformation Program are to modernize the paper- based immigration benefits process, enhance national security and system integrity, and improve customer service and operational efficiency. Established in 2006, the program comprises many systems, each of which provides a service to facilitate operations, such as identity management and risk and fraud analytics. The objectives of the Transformation Program are to allow applicants to establish an account with USCIS to file and track the status of the application, petition, or request online; the USCIS Electronic Immigration System (USCIS ELIS), which is the main component of the program, to apply risk-based rules automatically to incoming applications, petitions, and requests to identify potentially fraudulent applications and national security risks; adjudicators to have electronic access to applications, petitions, and requests, relevant policies and procedures, and external databases; USCIS to have management information to track and allocate USCIS ELIS to have electronic linkages to other agencies, such as the Departments of Justice and State, for data sharing and security purposes. As the main component of the program, USCIS ELIS is to provide case management for adjudicating immigration benefits. USCIS ELIS relies on and interfaces with other systems that provide additional capabilities, such as user authentication and scheduling, to deliver end-to-end processing. In particular, as of July 2016, the system was expected to interface with at least 30 other systems, ranging in function from fraud detection to law enforcement and to online payment. The program expects to achieve its goals and objectives through the delivery of five core operating requirements. These core requirements, which are expected to collectively deliver the program’s mission needs, are (1) intake and account management; (2) benefits case management; (3) electronic content management; (4) agency and knowledge management; and (5) risk and fraud management. Table 1 describes the five core operational requirements. The USCIS Transformation Program is governed by multiple bodies within DHS and the program. Specifically, DHS governance bodies, such as the Acquisition Review Board and Executive Steering Committee, evaluate cost, schedule, and performance of a program and provide corrective actions when needed. In addition, the department’s Office of the Chief Information Officer and Office of Program Accountability and Risk Management conduct oversight of individual programs, which in turn, informs congressional and Office of Management and Budget oversight. For example, the Office of Program Accountability and Risk Management develops periodic reports to ensure that various DHS programs and their components within the agency satisfy compliance-related mandates and improve investment management. In addition, the Office of the Chief Information Officer performs periodic reviews that serve as the basis for publicly reported program ratings. Within USCIS, directorates govern divisions and program offices govern specific functions, such as the Transformation Program. One program office, the Office of Transformation Coordination, has managed and overseen the development of USCIS ELIS. Other USCIS directorates and program offices, including the Office of Information Technology and the Customer Service and Public Engagement directorate, have supported the management and oversight of the larger USCIS Transformation Program. In April 2015, USCIS officially changed its software development approach. In particular, USCIS transitioned from a waterfall approach to develop, test, and deliver USCIS ELIS functionality to an incremental approach. In an incremental approach, software is developed, tested, and delivered in smaller components or phases, rather than in the typically long, sequential phases of a traditional waterfall approach. Incremental software development is consistent with the Office of Management and Budget’s IT Reform Plan and the law commonly referred to as the Federal Information Technology Acquisition Reform Act (FITARA). The incremental approach chosen by USCIS, called Agile, is intended to allow subject matter experts to validate requirements, processes, and system functionality in increments, and deliver the functionality to users in short cycles. Since USCIS began implementation of the Transformation Program in 2006, the effort has experienced significant cost increases and schedule delays. In particular, the program’s most recent baseline, approved in April 2015, indicates that the Transformation Program will cost up to $3.1 billion and be fully deployed no later than March 2019.This is an increase of approximately $1 billion with a delay of more than 4 years from its initial July 2011 acquisition program baseline. In November 2008, USCIS awarded a solutions architect contract for approximately $500 million over a 5-year period to design, develop, test, deploy, and sustain the Transformation Program by November 2013. In July 2011, DHS officially approved the Transformation Program’s acquisition program baseline and supporting operational requirements. This baseline estimate was for about $2.1 billion and the program was projected to reach full operating capability no later than June 2014. In May 2012, USCIS launched the first release of USCIS ELIS. This release included capabilities associated with all of the system’s core operational requirements, such as online account setup, case management, case acceptance, applicant evidence intake, and notice generation. Subsequent to this first release, USCIS deployed additional releases to add functionality. This initial USCIS ELIS was used to process nonimmigrant requests to change or extend their status, USCIS immigrant fees, and immigrant petitions for foreign nationals who make investments in U.S. commercial enterprises. Beginning in 2013, the program was operating beyond its approved baseline, a situation DHS referred to as being “in breach.” As a result, we reported in 2015 that the program was not in compliance with DHS acquisition policies and procedures. To address the breach, DHS acquisition policies and procedures required that, within 90 days, a new baseline be approved or a program review be conducted to review the proposed baseline revisions. We reported that neither of these actions had taken place since 2013. However, despite exceeding its approved baseline and operating without a DHS-approved revised acquisition strategy and baseline, the Transformation program continued with its system development efforts. As part of the continued development, USCIS pursued a new acquisition approach. As we reported in May 2015, changes in its approach included changes to the software development methodology, contracting approach, and program architecture and were intended to help address concerns about delays and cost overruns. See table 2 for a description of these changes. The shift in acquisition approach also resulted in the proposed development of a new USCIS ELIS system. The new system was to be a separate and distinct system from the previously-developed USCIS ELIS. In November 2014, after a year and a half of planning and development, USCIS deployed an initial version of the new USCIS ELIS system to allow for limited processing of permanent resident card renewals and replacements. This initial deployment also tested all core processing capabilities, such as the ability to electronically file or schedule appointments for collecting biometric information. Between November 2014 and February 2015, the functionality of the new USCIS ELIS was enhanced to allow full processing of permanent resident card renewals and replacements. Nevertheless, during this time, the Transformation Program continued to operate in breach status, without a DHS-approved revised acquisition strategy and baseline. In 2015, we reported that this breach had impacted DHS’ ability to effectively oversee and govern the program because oversight was no longer being conducted relative to a current and approved program schedule. The program’s revised acquisition baseline and strategy were formally approved in April 2015, over 2 years after the breach. Under its new acquisition baseline, USCIS estimated the program to cost up to $3.1 billion and to be fully deployed no later than March 2019. This was an increase of approximately $1 billion and a delay of over 4 years from the program’s initial approved baseline in July 2011. The new acquisition strategy represented official DHS approval of the program’s updated acquisition approach and also formally required that the old USCIS ELIS be decommissioned and that USCIS continue to pursue the new USCIS ELIS. In May 2015, we reported that changes in the Transformation Program acquisition strategy intended, in part, to address the breach had contributed to significant delays in the program’s planned schedule. In July 2016, we once again expressed concerns over program performance, focusing on the reliability of the program’s cost, schedule, and scope measurements. For example, we reported that delays in the schedule could increase the risk that the program would proceed with future USCIS ELIS development or deployment before it was ready in order to meet committed dates. In addition, we reported that the program was at risk of future schedule delays in later USCIS ELIS releases, which might result in the program exceeding its revised cost or schedule thresholds. We made twelve recommendations to improve the ability of USCIS to manage the program. USCIS concurred with our recommendations and has initiated work to implement them. USCIS continues to expand the ability of the new USCIS ELIS to process citizenship and immigration benefits. Specifically, after April 2016, USCIS deployed the additional capability to process applications for temporary protected status and additional naturalization forms. However, in August 2016, the program reverted back to the legacy system, called the Computer-Linked Application Information Management System 4, for processing the same naturalization form that had been deployed in the new USCIS ELIS only 4 months earlier. As a result of the switchover and other technical issues with the new system, the program did not complete deployment of system functionality associated with its Citizenship line of business by its September 2016 deadline, resulting in another schedule breach. In November 2016, USCIS submitted a breach remediation plan to the Deputy Under Secretary for Management that identified several root causes for the breach. These causes included that: the program’s schedule did not allow time to gather user feedback or address complexities discovered during development; new requirements were added; and, USCIS leadership did not provide any consistent performance requirements on what the program was supposed to accomplish for specific business lines. USCIS had planned to re-baseline the program in February 2017 to account for the September 2016 breach.