Audit of the Management and Administration of the Consular Systems Modernization Program

AUD-CGI-23-20
    Report Contents
    Unclassified
    Unclassified

    What OIG Audited

    The Bureau of Consular Affairs (CA) is responsible for issuing passports, visas, and other documents to citizens and foreign nationals to  facilitate travel to and from the United States. To achieve its mission, CA needs modern, reliable, and secure IT systems. Toward that effort, CA initiated the Consular Systems Modernization (CSM) program to modernize and consolidate approximately 90 discrete consular legacy IT  systems into a common technology framework. 

    The Office of Inspector General (OIG) conducted this audit to determine whether the Department of State (Department) applied project management principles governing the management and administration of IT investments to realize the goals of the CSM program. OIG  reviewed four task orders under the primary CSM contract awarded in 2018.

    What OIG Recommends
    OIG made 20 recommendations to improve CA’s program and project management and its administration of task orders. On the basis of the Department’s responses to a draft of this report, OIG considers 9 recommendations resolved, pending further action, and 11 recommendations unresolved. A synopsis of management’s responses to the recommendations offered and OIG’s replies follow each recommendation in the Audit Results section of this report. Responses received from the Under Secretary for Management, CA, the Bureau of Budget and Planning, and the Bureau of Information Resource Management are included in their entirety in Appendices D through G, respectively.

    What OIG Found
    The Department did not consistently apply program management principles when executing the CSM program. Specifically, OIG found that CA did not properly design the CSM program, develop a monitoring plan that complied with Department guidance, evaluate the CSM program, or perform required IT governance reviews. These actions are essential for the proper management of IT investments. The deficiencies occurred, at least in part, because of insufficient management oversight from key Department bureaus and the appointment of unqualified project managers. As the organization that provides passport services and support to U.S. citizens, it is critically important that CA, in coordination with other key Department bureaus, address the identified deficiencies to advance and realize the goals of the CSM program.

    OIG also found that the Contracting Officer’s Representatives (COR) assigned to the CSM program did not administer task orders in accordance with requirements. Specifically, invoice reviews were not properly documented, contractor reports were missing, performance-based fees may have been improperly awarded, and assessment reports were not completed in a timely manner. These deficiencies occurred because CA and the Bureau of Administration did not enforce the Department’s policies for invoice reviews, ensure that CORs were maintaining contract files in the Department’s eFiling system, or provide sufficient guidance to fully assess contractor performance. As a result, OIG is questioning $14,291,001 in unsupported costs related to the invoices reviewed.

    Lastly, CA did not develop and execute an acquisition plan for the CSM program in a timely manner. The deficiency occurred in part because CA’s guidance did not contain all requirements specified in the Federal Acquisition Regulation, and leadership did not provide sufficient oversight. As a result, CA’s original procurement package lacked technical specifications, and the acquisition process had to be started over, delaying implementation of the CSM program by approximately 58 months.

     

    Recommendation Number
    1
    Open Resolved

    OIG recommends that the Bureau of Consular Affairs (CA), in coordination with the Bureau of Budget and Planning, develop and implement a risk-based methodology to select programs for evaluation. CA should include the amount of funds invested and the risk to its portfolio as factors considered in the methodology.

    Recommendation Number
    2
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Information Resource Management, develop and implement a process to annually ensure that all IT projects related to the Consular Systems Modernization program are registered in the Integrated Management, Analytics, and Technology Resource for Information Exchange system, in accordance with 5 Foreign Affairs Manual 611.

    Recommendation Number
    3
    Open Resolved

    OIG recommends that the Bureau of Budget and Planning update 18 Foreign Affairs Manual 300 to specify which requirements (including what documentation is required) apply to Department of State bureaus and offices using Agile (or Agile-related) program or project management methodologies.

    Recommendation Number
    4
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning, map control gates for the program management methodology used for the Consular Systems Modernization program to the Department of State’s Managing State Projects guidance, as required by 5 Foreign Affairs Handbook-5 H-211.

    Recommendation Number
    5
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning, develop and implement a plan to create documentation required by Department of State program and project management guidance (including 18 Foreign Affairs Manual 300) for the overall Consular Systems Modernization program and discrete projects related to the program. This documentation would include, but not be limited to, a program monitoring plan, a logic model, and a situational analysis.

    Recommendation Number
    6
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning, reassess the current program management methodology used to manage and monitor the Consular Systems Modernization program to determine whether it is the most effective option.

    Recommendation Number
    7
    Open Started

    OIG recommends that if, following implementation of Recommendation 6, the Bureau of Consular Affairs (CA) determines that its current program management methodology is not optimal, CA should develop and implement a plan of action, in coordination with the Bureau of Budget and Planning, to adopt a different program and project management methodology that aligns with Department of State program and project management guidance.

    Recommendation Number
    8
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning, perform an internal control gap analysis related to program and project management of the Consular Systems Modernization program to identify key controls that are needed to comply with Government Accountability Office requirements for maintaining a sufficient internal control environment.

    Recommendation Number
    9
    Open Resolved

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Information Resource Management, develop and implement a mechanism to track required IT governance reviews to ensure that all governance reviews of IT systems have been completed.

    Recommendation Number
    10
    Open Resolved

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning, develop and implement a process to periodically assess program and project management activities related to the Consular Systems Modernization program.

    Recommendation Number
    11
    Open Started

    OIG recommends that the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning and the Bureau of Information Resource Management, develop and implement a process to annually verify that designated project managers assigned to the Consular Systems Modernization program meet qualification requirements specified in 5 Foreign Affairs Manual 623.2 and the “Federal IT Project Manager Guidance Matrix.”

    Recommendation Number
    12
    Open Started

    OIG recommends that if project managers as described in Recommendation 11 are identified as not meeting qualification requirements, the Bureau of Consular Affairs, in coordination with the Bureau of Budget and Planning and the Bureau of Information Resource Management, develop and implement a plan of action to provide training and guidance to the project managers so that they comply with 5 Foreign Affairs Manual 623.2 and the “Federal IT Project Manager Guidance Matrix.”

    Recommendation Number
    13
    Open Resolved

    OIG recommends that the Under Secretary for Management establish and oversee a working group with officials from key Department of State bureaus, including the Bureau of Budget and Planning, the Bureau of Information Resource Management, and the Bureau of Administration, to assist the Bureau of Consular Affairs in executing the Consular Systems Modernization program and its efforts to modernize and consolidate consular legacy IT systems into a common technology framework.

    Recommendation Number
    14
    Closed Implemented $511,249

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, take the following actions: (a) determine whether the questioned costs of $511,249, which were considered unsupported for 3 of 10 invoices selected for testing from Task Order 19AQMM18F3629, were supported and allowable, and (b) recover any costs determined to be unallowable, as shown in Table B.1.

    Recommendation Number
    15
    Closed Implemented $13,779,756

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, take the following actions: (a) determine whether the questioned costs of $13,779,756, which were considered to be unsupported for the 10 invoices selected for testing from Task Order 19AQMM19F1686, were supported and allowable and (b) recover any costs determined to be unallowable, as shown in Table B.1.

    Recommendation Number
    16
    Open Resolved

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, develop and implement bureau-specific procedures requiring CA’s assigned Contracting Officer’s Representatives to (a) maintain documentation of their invoice review that demonstrates that costs and supporting documentation were verified and (b) confirm that labor hours billed had supporting documentation that was sufficient to support the approval for payments.

    Recommendation Number
    17
    Open Resolved

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, develop and implement procedures to ensure that the Contracting Officer’s Representatives (COR) administering contracts related to Consular Systems Modernization maintain files in the mandated eFiling module of the Integrated Logistics Management System in accordance with 14 Foreign Affairs Handbook-2 H-142(b)(16)(b) and that the files include all required reports from contractors.

    Recommendation Number
    18
    Open Resolved

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, develop and implement guidance related to the proper use and development of cost-plus-award-fee contractor performance reports.

    Recommendation Number
    19
    Open Resolved

    OIG recommends that the Bureau of Administration, in coordination with the Bureau of Consular Affairs, develop and implement procedures to ensure that Contracting Officer’s Representatives who oversee Consular Systems Modernization program task orders complete and submit reports in the Contractor Performance Assessment Reporting System within the required 120 days.

    Recommendation Number
    20
    Open Resolved

    OIG recommends that the Bureau of Consular Affairs update the Consular Systems and Technology Procurement Guide to add requirements for acquisition planning, including the contents of written acquisition plans, as specified in Federal Acquisition Regulation 7.103 and 7.105.