HUD Information Technology: More Work Remains to Implement Necessary Management Controls

Published by the Government Accountability Office on 2012-03-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                             United States Government Accountability Office

GAO                          Testimony
                             Before the Subcommittee on Transportation,
                             Housing and Urban Development, and Related
                             Agencies, Committee on Appropriations,
                             House of Representatives

                             HUD INFORMATION
For Release on Delivery
Expected at 10:00 a.m. EDT
Thursday, March 29, 2012

                             More Work Remains to
                             Implement Necessary
                             Management Controls
                             Statement of Valerie C. Melvin, Director
                             Information Management and Technology
                             Resources Issues

                                                 March 29, 2012

                                                 HUD INFORMATION TECHNOLOGY
                                                 More Work Remains to Implement Necessary
                                                 Management Controls
Highlights of GAO-12-580T, a testimony
before the Subcommittee on Transportation,
Housing and Urban Development, and
Related Agencies, Committee on
Appropriations, House of Representatives

Why GAO Did This Study                           What GAO Found
The Department of Housing and Urban              HUD has made progress in implementing prior GAO recommendations on
Development (HUD) performs a range               modernizing its IT environment; however more actions are needed. In 2009,
of significant home ownership and                GAO reported that HUD lacked key IT management controls; which are essential
community development missions that              to achieving successful outcomes. Specifically,
are integral to the U.S. economy. In
doing so, HUD relies extensively on              •   Although the department had established an IT strategic plan that outlined
information technology (IT). However,                goals and performance measures, it had not assessed its performance
HUD’s IT environment has not                         against established goals. As a result, HUD did not know how well it was
effectively supported its business                   achieving its goals and where it needed to improve.
operations, and as a result, the                 •   While the department had established policies and procedures for developing
department has been working to                       a complete portfolio of its investments, it had not established policies and
modernize its IT infrastructure. To                  procedures for evaluating that portfolio. This meant that it was limited in its
provide oversight and inform decision-               ability to control risks and achieve benefits associated with the mix of legacy
making, Congress required that HUD                   systems and modernization investments it selected.
develop and submit plans describing
                                                 •   HUD’s Office of the Chief Information Officer had not adequately assessed
how it intends to use its expenditures
                                                     its IT workforce needs, inventoried existing staff knowledge and skills, and
to support its modernization efforts. In
addition, Congress required GAO to
                                                     identified gaps between needs and existing capabilities. As a result, the
review these expenditure plans to                    department was not well positioned to acquire the skill sets it needed.
determine if they meet statutory                 •   The department had not fully developed its enterprise architecture (EA)—
conditions.                                          which provides a blueprint for investing that connects strategic plans with
                                                     individual programs and system solutions. This meant that HUD lacked a
GAO was asked to testify on HUD’s                    sufficient basis for guiding and directing its modernization projects.
progress in implementing its prior
recommendations on (1) modernizing               GAO made a number of recommendations to HUD aimed at strengthening its
its IT systems and (2) improving its             management capabilities, and while progress has been made in addressing
expenditure plans. In preparing this             them, work remains. For example, HUD issued a department-wide strategic plan
statement, GAO relied on previous                with associated goals that aligned with new IT strategic goals. However, the
work at HUD.                                     department had not developed criteria for assessing the performance of its
                                                 portfolios, finalized its plan to address its IT workforce needs, or established an
What GAO Recommends                              approved policy for its enterprise architecture.
GAO is not making new
                                                 HUD’s modernization expenditure plans, which are to describe how the agency
recommendations. As noted, GAO has
previously made recommendations
                                                 plans to spend IT modernization funding, have improved in response to GAO’s
aimed at assisting HUD in fully                  recommendations. These plans are to meet statutory conditions that include
implementing key IT management                   identifying, for each modernization project, capabilities to be delivered, expected
controls.                                        benefits, estimated costs, and key milestones; and showing that each project is
                                                 supported by adequate staff, conforms to capital planning and investment control
                                                 requirements, complies with the department’s EA, and is being managed in
                                                 accordance with department lifecycle management policies. GAO found that
                                                 HUD’s 2010 expenditure plan contained weaknesses and thus was limited as a
                                                 congressional oversight and decision-making mechanism. Accordingly, GAO
                                                 recommended, among other things, that the department ensure future plans
                                                 satisfied each element of the statutory conditions. In response, subsequent
                                                 expenditure plans submitted in 2011 and 2012 satisfied the conditions. As a
                                                 result, these more recent plans have provided key information needed for
                                                 continued oversight of the modernization projects.
View GAO-12-580T. For more information,
contact Valerie C. Melvin at (202) 512-6304 or

                                                                                          United States Government Accountability Office
Chairman Latham, Ranking Member Olver, and Members of the

I am pleased to participate in today’s hearing to discuss the Department
of Housing and Urban Development’s (HUD) management challenges.
HUD performs a range of significant home ownership and community
development missions that are integral to our nation’s economic well-
being, and it relies extensively on information technology (IT) to carry out
these missions. Moreover, legislation enacted since 2008 to stimulate the
economy, in part through strengthening the housing market, has
continued to expand the department’s responsibilities and thus its need
for IT support. For example, the department’s increased responsibilities
under the Housing and Economic Recovery Act of 2008 introduced
greater processing requirements for Federal Housing Administration
(FHA) mortgage insurance programs, which further increased its reliance
on information systems and other IT services. 1

Nevertheless, HUD has long experienced shortcomings in its IT
capability. As we reported in 2009, the department’s IT environment did
not effectively support its business operations. 2 The department’s
operating plans and budget submissions indicated, for example, that its
information systems were overlapping and duplicative, were not
integrated, necessitated manual workloads, and employed antiquated
technologies that were costly to maintain. Since our report, the
department has been working to modernize its IT infrastructure.

To provide oversight and inform decision-making, Congress established
limitations on funding for HUD’s IT modernization efforts through
appropriations acts in fiscal years 2010 and 2011. 3 In addition, these acts
required us to review and provide an assessment of HUD’s IT
modernization expenditure plans. To this end, we issued two reports—in

 Housing and Economic Recovery Act, 2008, Pub L. No. 110-289, § 2126, 122 Stat. 2654,
2840-41 (July 30, 2008).
 GAO, Information Technology: HUD Needs to Strengthen Its Capacity to Manage and
Modernize Its Environment, GAO-09-675 (Washington, D.C.: July 31, 2009).
 Department of Housing and Urban Development Appropriations Act, 2010, Pub. L. No.
111-117, div. A, tit. II, 123 Stat. 3074, 3093-3094 (Dec. 16, 2009); and Department of
Defense and Full-Year Continuing Appropriations Act, 2011, Pub. L. No. 112-10, § 2259,
125 Stat. 38, 197-98 (April 15, 2011).

Page 1                                         GAO-12-580T HUD Information Technology
             November 2010 and September 2011—that documented the results of
             our fiscal year 2010 expenditure plan review. 4 Further, earlier this week,
             we briefed the Committees’ staff on a just-completed third review which
             examined the department’s fiscal year 2011 expenditure plan.

             At your request, my testimony today summarizes HUD’s progress in
             implementing our prior recommendations on (1) modernizing its IT
             systems and (2) improving its expenditure plans.

             The information in my testimony is based on our previous reports on
             HUD. All work on which this testimony is based was conducted in
             accordance with generally accepted government auditing standards.

             HUD’s mission to create strong, sustainable, and inclusive communities
Background   and quality and affordable homes for all has significantly evolved due to
             the current economic and housing crisis. Accordingly, the department has
             increased its reliance on IT. In particular, legislation enacted over the past
             several years has given the department new responsibilities for, among
             other things, strengthening the housing market. For example, the Housing
             and Economic Recovery Act of 2008 5 established a program intended to
             help families avoid home foreclosure by refinancing them into mortgages
             insured by FHA. 6 As a result, the number of mortgage loans insured by
             FHA more than tripled between 2006 and 2010, from almost half a million
             loans to 1.7 million loans. This in turn resulted in the need for much
             greater system processing capabilities to accommodate the increased
             demand. 7

             IT plays a critical role in the department’s ability to carry out its growing
             mission by supporting data collection and dissemination throughout the

              GAO, Information Technology: HUD Needs to Better Define Commitments and Disclose
             Risks for Modernization Projects in Future Expenditure Plans, GAO-11-72 (Washington,
             D.C.: Nov. 23, 2010); and Information Technology: HUD’s Expenditure Plan Satisfies
             Statutory Conditions, and Implementation of Management Controls Is Under Way,
             GAO-11-762 (Washington, D.C.: Sept. 7, 2011).
             Pub. L. No. 110-289, § 2126.
             FHA provides mortgage insurance on loans made by approved lenders.
              GAO, Federal Housing Administration: Improvements Needed in Risk Assessment and
             Human Capital Management, GAO-12-15 (Washington, D.C.: Nov. 7, 2011).

             Page 2                                        GAO-12-580T HUD Information Technology
                       department and to external parties. For instance, the department reports
                       that its business areas rely on IT to process over 50,000 loan requests
                       per week, over 12,000 service calls per month, and more than 7,000
                       grant requests annually for each of its major grant programs.

HUD’s IT Environment   Despite its growing mission, HUD’s IT environment has not effectively
                       supported its business operations. In 2009, we reported that the
                       department’s IT had consisted of:

                       •   over 200 information systems, many of which performed the same
                           functions and, thus, were duplicative;
                       •   stove-piped, nonintegrated systems that could not share related data;
                       •   manual processing for key business processes; and
                       •   systems that were nearly 15 years old (on average), including several
                           different operating systems and using 35 different programming

                       A factor that had contributed to the state of HUD’s IT environment was
                       the department’s focus, primarily, on the maintenance of its existing
                       systems and infrastructure, rather than on the modernization needed to
                       meet its expanding mission needs. For example, in fiscal year 2008,
                       about 2 percent of the department’s IT obligations were for new
                       development, whereas the remaining 98 percent were obligated for
                       operating and maintaining legacy systems.

                       HUD’s Office of the Chief Information Officer (OCIO) is responsible for
                       supporting the department’s programs, services, and management
                       processes by providing IT solutions and services. Additionally, the OCIO
                       is responsible for developing, modernizing, and enhancing the IT
                       environment. To this end, in 2010, the OCIO established four
                       management goals, which aligned with the department’s 2010-2015
                       Strategic Plan: (1) enhance the quality, availability, and delivery of HUD
                       information to citizens, business partners, and government; (2) promote
                       an enterprise approach to IT that will foster innovation and collaboration;
                       (3) achieve excellence in IT management practice; and (4) transform the
                       OCIO to a culture of operational excellence that can achieve current and
                       future departmental goals. 8

                       HUD Strategic Plan Fiscal Year 2010-2015 (May 2010).

                       Page 3                                      GAO-12-580T HUD Information Technology
                       To assist HUD in its modernization efforts, Congress has authorized and
                       appropriated funding for the department in multiple statutes. For example,
                       in recognizing the need to modernize the department’s IT environment,
                       the Housing and Economic Recovery Act of 2008 authorized $25 million
                       for each fiscal year, from 2009 through 2013, for improvements to FHA’s
                       IT, among other things. In addition, according to department officials,
                       HUD used approximately $1.5 million of the funding provided in the
                       American Recovery and Reinvestment Act of 2009 for improving IT
                       capabilities across a range of programs. More recently, the appropriations
                       acts for fiscal years 2010 and 2011 9 made available to HUD for
                       expenditure $180 million and $71 million, respectively, for IT
                       modernization to support its Transformation Initiative. 10

                       While HUD has been working to modernize its IT systems, we reported in
Progress Has Been      2009 that the department lacked sound management controls that are
Made in Implementing   essential to achieving successful outcomes. These controls included IT
                       strategic planning, investment management, enterprise architecture, and
Recommendations on     human capital planning. We recommended that the department make
HUD’s IT               improvements in these areas, and while it has taken a number of
Modernization, but     important steps, additional actions are still needed by the department to
                       respond to remaining concerns. 11
More Work Remains
                       •     Strategic planning and performance management: Effective IT
                             strategic planning and performance management are intended to
                             ensure that an organization’s IT strategic goals are aligned with its
                             overall mission goals and outcomes and that these goals are
                             supported by clearly defined (1) activities aimed at accomplishing the
                             goals and (2) measures for determining performance in accomplishing
                             the activities and goals.

                             In 2009, we found that although HUD had established an IT strategic
                             plan that outlined goals and performance measures, it had not
                             assessed its IT performance against established goals since fiscal

                       Pub. L. No. 111-117 and Pub. L. No. 112-10.
                         HUD’s Transformation Initiative consists of four components: (1) research, evaluation,
                       and program metrics; (2) program demonstrations; (3) technical assistance and capacity
                       building; and (4) information technology.
                           GAO-09-675 and GAO-11-762.

                       Page 4                                          GAO-12-580T HUD Information Technology
      year 2007. By not regularly assessing and reporting progress against
      its strategic IT performance measures and activities, HUD did not
      know how well it was achieving its strategic goals and where it
      needed to improve. We recommended that HUD establish a plan for
      developing and implementing the department’s performance
      management framework, including an implementation schedule of key
      activities and related resource needs, and ensure that this plan
      provides for annually reporting progress in achieving IT strategic

      In September 2011, we reported that HUD had fully implemented this
      recommendation by issuing a new department-wide strategic plan
      with associated goals that aligned with new IT strategic goals that the
      OCIO developed.

•     IT investment management: Investment management is aimed at
      selecting, controlling, and evaluating IT investments in a manner that
      better ensures that they produce business value, reduce investment-
      related risks, and increase accountability and transparency in the
      investment decision-making process. As we have previously reported,
      moving away from project-centric investment management and
      toward a portfolio-based approach, is considered a best practice. By
      managing investments as a portfolio, an organization can consider
      new investment proposals, along with previously funded investments,
      and identify the appropriate mix and synergies of these investments to
      best meet mission needs, technology needs, and priorities for

      In 2009, we reported that while HUD had established a range of
      policies and procedures for developing a complete investment
      portfolio, it had not established policies and procedures for evaluating
      the portfolio. 12 Without having defined and implemented practices for
      evaluating the performance of its portfolios, HUD was limited in its
      ability to control the risks and achieve the benefits associated with the
      mix of legacy system and modernization investments selected.
      Accordingly, we recommended that HUD develop a plan for instituting
      policies and procedures for reviewing, evaluating, and improving the
      performance of the department’s portfolio of investments; developing
      criteria for assessing portfolio performance and reviewing and


Page 5                                     GAO-12-580T HUD Information Technology
    modifying them at regular intervals; defining and collecting IT portfolio
    performance measurement data consistent with the portfolio
    performance criteria; and executing adjustments to the IT investment
    portfolio in reaction to actual portfolio performance.

    In September 2011, we reported that, in response to our
    recommendations, the department had begun establishing a new
    investment management governance structure and had applied it to
    its portfolio for IT modernization projects. However, HUD had not yet
    developed criteria for assessing portfolio performance, or defined and
    collected data consistent with the criteria. In the absence of taking
    these key steps, the department has continued to be challenged in
    implementing proper investment management practices.

•   Human capital: As we have previously reported, IT human capital
    management is intended to ensure that an organization has the
    employees with the appropriate knowledge and skills to effectively
    execute critical IT functions. Human capital management involves
    assessing IT workforce needs, inventorying existing staff’s knowledge
    and skills and identifying any gaps between needs and existing
    capabilities, and developing strategies and plans to fill any gaps.

    In 2009, we reported that HUD’s OCIO had not adequately performed
    most of these activities. For example, while the office had analyzed
    skill gaps in its IT workforce and had developed a strategy for closing
    those skills gaps, OCIO officials did not know when implementation of
    this strategy would begin or be completed. Additionally, the gap
    analysis was based on an incomplete and outdated inventory of
    human capital skill levels, thus rendering its strategy unreliable. We
    noted that without effective human capital management, HUD’s ability
    to have the right people to effectively operate and maintain existing
    systems was impaired. Therefore, we recommended that HUD
    establish and execute IT human capital gap closure strategies that are
    based on a complete and current inventory of its existing IT workforce

    In September 2011, we reported that HUD had made progress in this
    area. Specifically, HUD began working to establish a human capital
    plan that included tasks such as identifying challenges, developing
    performance metrics and strategies, and addressing the identified IT
    skill gaps. HUD anticipated finalizing this plan by December 2011;
    however, as of this month, the plan has not yet been completed. Until
    HUD finalizes its IT human capital management plan, implementation
    of this management control will continue to be a challenge.

Page 6                                    GAO-12-580T HUD Information Technology
•   Enterprise architecture: EA development and use is aimed at
    establishing a corporate blueprint for investing that connects strategic
    plans with individual programs and system solutions. As such, this
    blueprint provides the information needed to guide and constrain
    investments in a consistent, coordinated, and integrated fashion—
    thereby improving interoperability, reducing duplicative efforts, and
    optimizing mission operations. Developing an enterprise architecture
    with associated system solutions for portions, or segments (referred to
    as segment architectures), is an important aspect of this activity.

    In 2009 we reported that, while HUD had established an enterprise
    architecture program that met key aspects of related best practices,
    its efforts to develop segment architectures were not sufficient. For
    example, HUD had identified and prioritized segments to be
    modernized; however, it did not adhere to these priorities, the
    segments developed did not reflect important elements of federal
    guidance, and most were out of date. We found that HUD had
    developed eight segment architectures; however, these segments
    were not the department’s eight highest priorities. As a result, HUD’s
    segment architectures did not provide a sufficient basis for guiding
    and directing segment projects in a manner to ensure that both,
    system enhancements and new development efforts were properly
    sequenced, well integrated, and not duplicative. We recommended
    that HUD develop a plan for reexamining segment priorities and
    updating and developing segment architectures in accordance with
    these priorities and relevant guidance.

    We subsequently reported in September 2011, that the department
    had made progress toward implementing our recommendation, by, for
    example, creating a conceptual enterprise architecture. However, it
    had not yet established a policy to guide the development,
    maintenance, and use of this architecture. Thus, we further
    recommended that HUD establish and approve a policy to govern the
    EA prior to further developing its segment architectures. In response,
    HUD officials did not explicitly agree or disagree with our
    recommendation, but noted that the department was working to draft
    an enterprise architecture policy. As of this month, the department
    had not yet finalized its EA policy. To this end, establishing a
    commitment to its new EA direction remains a challenge for the

Page 7                                   GAO-12-580T HUD Information Technology
                      Out of concern about HUD’s capacity to manage its IT modernization
HUD’s                 efforts, Congress established limitations on the funding provided to the
Implementation of     department for this purpose. Specifically, the appropriations acts stated
                      that the department could not obligate more than 25 percent of fiscal year
Recommendations to    2010 funds and 35 percent of fiscal year 2011 funds until the Secretary of
Improve Expenditure   HUD submitted to the appropriations committees in each year an
Plans Enables More    expenditure plan that satisfied two sets of statutory conditions and had
                      been reviewed by GAO. To address the first set of statutory conditions,
Oversight             for each modernization project, HUD was required to identify in the plan
                      (1) functional and performance capabilities to be delivered, (2) expected
                      mission benefits, (3) estimated lifecycle costs, and (4) planned key
                      milestones. To address the second set of statutory conditions, the plan
                      had to demonstrate that each project (1) was supported by an adequately
                      staffed project office, (2) conformed to capital planning and investment
                      control requirements, (3) complied with the department’s enterprise
                      architecture, and (4) was being managed in accordance with applicable
                      lifecycle management policies and guidance. 13

                      Our assessment found that the department’s first expenditure plan,
                      submitted in April 2010, did not adequately satisfy the two sets of
                      statutory conditions. 14 In particular, we found that the plan did not
                      describe specific and measureable mission benefits for all of HUD’s IT
                      modernization projects. In addition, the plan did not include information
                      that demonstrated compliance with regard to the department’s enterprise
                      architecture and capital planning for IT investments. For example, the
                      modernization projects could not show how they aligned to the
                      department’s EA because the existing EA was no longer operative. In the
                      absence of this information, the plan was limited as a congressional
                      oversight and decision-making mechanism. As a result, we recommended
                      that HUD ensure that future expenditure plans satisfied each element of
                      both sets of statutory conditions and describe the status of HUD’s efforts
                      to establish and implement modernization management controls.

                      In response, HUD submitted a revised 2010 expenditure plan in February
                      2011, which we found satisfied both sets of statutory conditions. For
                      example, the plan identified key milestones by project phase and
                      deliverable timeframes for the development of requirements and software

                       Pub. L. No. 111-117 and Pub. L. No. 112-10.

                      Page 8                                         GAO-12-580T HUD Information Technology
releases. The plan also described how each of seven identified
modernization projects complied with the department’s evolving
enterprise architecture. Additionally, the plan clearly described the status
of the department’s efforts to implement the management controls.

Further, in January 2012, HUD submitted its 2011 expenditure plan for
our review, which also satisfied both sets of statutory conditions. For
example, the plan described specific and measureable mission benefits
for each of the identified IT modernization projects. In addition, it
described costs associated with the lifecycle of each project, providing
details on funds needed for major work activities and deliverables.
Further, the plan categorized each project relative to HUD’s evolving

As a result of the measures that HUD has taken to respond to our
recommendations and improve the content of each subsequent
expenditure plan, it has rendered these plans more useful. In turn, the
plans should facilitate continued and more effective oversight of the
department’s IT modernization projects.

Going forward, the fiscal year 2012 appropriations act has directed us to
evaluate HUD’s 2012 expenditure plan. 15 Additionally, the 2012
conference report directed us to evaluate implementation of project
management practices, including contractor oversight and cost estimation
for selected IT modernization projects. 16 We have also been directed to
assess the department’s institutionalization of IT governance. We
anticipate initiating aspects of this work in spring 2012.

In summary, HUD has made progress in addressing certain weaknesses
that we identified in its IT management capabilities. However, it is
important to note that more actions are still needed. In particular, fully
addressing the recommendations that we have made is vital to helping

  Consolidated and Further Continuing Appropriations Act, 2012, Pub. L. No. 112-55, 125
Stat. 552, 691-92 (Nov. 18, 2011).
  This direction is contained in the Senate Appropriations Committee report, S. Rep. No.
112-83, at 141-42 (2011), as approved by the conference committee in the Explanatory
Statement, H.R. Conf. Rep. No. 112-284, at 286 (2001), accompanying the Consolidated
and Further Continuing Appropriations Act, 2012, Pub. L. No. 112-55, 125 Stat. 552, 691-
92 (Nov. 18, 2011).

Page 9                                          GAO-12-580T HUD Information Technology
                  the department implement sound management controls and, ultimately, to
                  overcome the challenges it has faced in improving its IT management
                  capabilities. HUD has demonstrated progress in improving the content of
                  its IT expenditure plans. As a result, these plans should be more useful
                  as an oversight tool and thus should better help to demonstrate the extent
                  to which the department takes the important steps that are essential to
                  strengthening its capacity to manage and modernize its IT environment.

                  Chairman Latham, Ranking Member Olver, and Members of the
                  Subcommittee, this concludes my statement today. I would be pleased to
                  respond to any questions that you may have.

                  If you have any questions concerning this statement, please contact
Contact and       Valerie C. Melvin, Director, Information Management and Technology
Acknowledgments   Resources Issues, at (202) 512-6304 or melvinv@gao.gov. Other
                  individuals who made key contributions include Shannin G. O’Neill,
                  Assistant Director; Kami J. Corbett; Lee A. McCracken; and Teresa M.

                  Page 10                                 GAO-12-580T HUD Information Technology
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