Status of IDENT/IAFIS Integration
Report No. I-2003-005
On May 1, 2003, the Office of Inspector General (OIG) provided a draft of this report to the Assistant Attorney General for Administration for comment. His response, dated May 22, 2003, is included in Appendix I. The response concurred with our four recommendations and commented on four issues identified in our report: the progress of the project, the role of the National Security Entry-Exit Registration System (NSEERS) in causing project delays, the planning for the transition of the Immigration and Naturalization Service (INS) to the Department of Homeland Security (DHS), and the data that the Justice Management Division (JMD) plans to use to prepare the June 2003 report to Congress. Our analysis of the comments on each of the four issues and each of the four recommendations follows.
With regard to our finding that the integration project was two years behind schedule, the response stated that we "imply that the project has been in limbo" and that little or nothing was accomplished since the OIG's December 2001 report. Further, the response stated that our not mentioning in the Executive Summary that JMD deployed two interim versions was "an omission that leaves an inappropriate implication" that no progress has been made.
The Assistant Attorney General also stated that we gave little mention to the deployment of Version 1.1.1 to 50 sites, an increase beyond the originally planned 10 sites. Finally, the response criticized our focus on the failed deployment of the originally planned integrated Version 1.2, because it stated that another planned interim version (Version 1.1+) would provide "much of what we need" from Version 1.2.
OIG Analysis: We do not agree that our report characterized the IDENT/IAFIS integration project as being "in limbo" since December 2001. Rather, we acknowledged the progress cited by the response. Specifically, we described the expanded deployment of Version 1.1.1 to support the NSEERS project on page 14 of the report. We also described the development of Version 1.1+ on page 12, including explaining the functionality Version 1.1+ will provide and noting that it will enable JMD to proceed with the Metric Study. Nonetheless, those interim versions do not equate to the integrated version (Version 1.2) that JMD originally planned to deploy by December 2001. (See Table 2, page 12 for a functional description of each version.) In December 2001, we reported that the next major milestone for the project, deployment of Version 1.2, had been delayed until December 2002. That schedule was not met, and the deployment of Version 1.2 is now planned for December 2003. Consequently, the primary finding in our report was that the integration project has continued to experience delays and has fallen further behind schedule.
Further, although the expanded deployment of Version 1.1.1 provided additional equipment that will support later deployments of the integration project, the response stated that deploying additional Version 1.1.1 workstations "did nothing to advance the system integration efforts." Also, we note that the deployment of Version 1.1+ continues to slip further behind schedule. Originally scheduled for deployment in December 2002, JMD now plans to deploy Version 1.1+ in August 2003, at least eight months later than planned. Therefore, while we believe it is appropriate to recognize JMD's interim actions in the body of the report, we conclude that the Executive Summary should address our finding that the integration project is now at least two years behind schedule.
Regarding our finding that the reassignment of integration project resources to the NSEERS project delayed the integration project, the response stated that NSEERS was a high priority project for the Attorney General. Further, the response stated that the interruption was actually a series of short delays, none of which seemed significant taken individually. Therefore, JMD could not foresee that these short delays would ultimately accumulate to become the significant delay that has occurred. The response also stated that because each delay was short, JMD did not believe that it was feasible to assign additional resources to the project. The response also asserted that technical difficulties would have prevented both projects from being developed at the same time. Finally, the response conceded that, had JMD known from the outset that the delays would become significant "alternative arrangements possibly could have been made."
OIG Analysis: We acknowledged the importance of the NSEERS project in the report. However, we continue to believe that JMD did not sufficiently recognize and advise senior Department officials of the integration project delays. That was especially true after the initial September 2002 NSEERS completion date passed and more integration project delays were expected. Because the cumulative effects of the integration project delays were not recognized and reported, senior Department officials were precluded from making "alternative arrangements."
Regarding our finding that JMD did not plan for the transition of the INS to the DHS, the response stated that our concerns regarding the lack of consensus about which agency should continue to manage the integration and the loss of integration project expertise were unfounded. The response stated that the lack of consensus was not surprising. Further, notwithstanding the lack of consensus, JMD has assumed that, based on congressional feedback and the inclusion of project funding in JMD's budget, it will continue to manage the integration project. The response further stated that there has been no loss of project expertise; stated that JMD continues to interact with the same individuals formerly from the INS who are now part of the DHS; and described efforts by JMD to reach out to DHS officials to keep the integration project moving forward.
OIG Analysis: The response's focus on the lack of consensus and the potential loss of project expertise misses our point that, as the integration project manager, JMD failed to exercise its responsibilities to plan and manage the integration project during the transfer of the INS to the DHS. Further, we are concerned that the response implied that transition planning was not required. We strongly disagree. The integration of IDENT and IAFIS is a complex project with significant national security implications. To allow the project to move forward into the new multi-agency environment without adequate planning and agreement about roles and responsibilities is risky. If JMD believed that it had a mandate to continue to manage the integration project, then it was incumbent on JMD to take full responsibility for leading the planning and execution of the transition.
June 2003 Report to Congress
Regarding our finding that the June 2003 report to Congress will not contain the required data to project operational costs, the response stated that JMD was fully aware of the limitations of the data it was collecting. The Assistant Attorney General also stated that the report will contain "some illustrative data gleaned from initial deployment" and that JMD will advise Congress that the "data is not suitable for drawing national conclusions or making projections."
OIG Analysis: In response to the statement that JMD will advise Congress on the limitations of the data presented in the June 2003 report, we added a sentence in the appropriate section of the final report acknowledging that planned action.
Recommendation 1 - Resolved - Open.
The response agreed with our recommendation to coordinate with DHS officials concerning the integration project. The response stated that "management and operational issues arise on occasion [and] are being dealt with as they emerge."
OIG Analysis: JMD's meeting with DHS officials to manage the day-to-day operations of the integration project is a positive step. However, JMD does not describe how it plans to identify the management, deployment, and operational issues associated with the integration, and does not discuss how it plans to resolve the issues. Further, managing issues as they arise is an example of the reactive approach that we criticize in our report and that we believe has contributed to growing delays in the integration project. Effective project management and planning depends on a rigorous examination of the challenges that must be addressed to complete the project. As the integration project lead, JMD should proactively identify the management, deployment, and operational issues facing the integration project, including those that result from the INS moving to the DHS. To close this recommendation, please provide us with a copy of the transition issues and a plan to address them by August 15, 2003.
Recommendation 2 - Resolved - Open.
The response agreed with our recommendation to revise the integration project development and deployment plan.
OIG Analysis: Please provide us with a copy of the revised integration project development and deployment plan by August 15, 2003.
Recommendation 3 - Resolved - Open.
The response agreed with our recommendation that JMD brief the Deputy Attorney General and other senior Department officials on the revised development and deployment plan. The response stated that this briefing will be part of the fiscal year 2005 budget process with further briefings to "be scheduled at their convenience."
OIG Analysis: Briefing the Deputy Attorney General and other senior Department officials as a part of the budget process is responsive to this recommendation if the briefing clearly identifies how the issues associated with the INS's move to the DHS will be addressed and describes JMD's plan to keep the integration project on schedule. Please provide us with a copy of the briefing materials by August 15, 2003.
Recommendation 4 - Resolved - Open.
The response agreed with our recommendation to produce quarterly reports on the progress of the integration project and interim results of the Metric Study. The first report will be issued on October 31, 2003, with results from the quarter ending September 30, 2003.
OIG Analysis: Please provide us with a copy of the first report provided to the Deputy Attorney General and other senior Department officials by October 31, 2003.