FBI Response to the DOJ/OIG Working Draft Report
The Federal Bureau of Investigation's Pre-Acquisition Planning for and Controls
Over the SENTINEL Case Management System
Recommendation # 1: Ensure that the system security and Independent Verification and Validation plans are completed as soon as possible after the contract is signed.
FBI Response: Concur. The SENTINEL Program Manager has assigned an Information Officer (ISSO) and Information System Security Manager (ISSM) to coordinate system security requirements with the prime developer. As the system security plan is dependent on the system design, the system security plan will not be finalized until the program's Critical Design Review (CDR), which will be determined when the schedule for the Phase 1 is finalized with the selected prime contractor.
Plans to obtain Independent Verification and Validation (IV&V) services from an independent contractor to support SENTINEL and other FBI projects are nearing completion. It is anticipated that an IV&V plan will be established during the design phase of development.
Recommendation # 2: Ensure that the SENTINEL Program Management Office is staffed to a level that will support SENTINEL's aggressive delivery schedule.
FBI Response: Concur. The Program Management Office (PMO) has an approved Staffing Plan (provided to the IG). The Program Manager (PM) continues hiring critical government employees and support service contractors as authorized by the staffing plan. As of February, more than two thirds of the program staff was in place, including all necessary staff to initiate contract award and commence Phase 1 development. Staffing of some of the SENTINEL transition and operations and maintenance positions was deferred until after commencement of development. PMO staffing is projected to be completed by June 2006.
Recommendation # 3: Obtain a tool that will allow for the effective implementation of an Earned Value Management process and fully implement this process.
FBI Response: Concur. The SENTINEL PMO is procuring a tool to effectively implement the Earned Value Management process, wInsight. wInsight provides ANSI compliant data transfer, analysis and reporting, enhance analysis, security, and reporting of EVMS data. SENTINEL PMO has already been providing EVM reports to DOJ/OMB concerning PMO contracts through the well-established IT Governance process including the DOJ Dashboard monthly reporting. The SENTINEL tool will be fully compliant with the enterprise IT Portfolio Tool, Metier Worklenz and Ms. Project Server. The Metier Worklenz and MS Project Server 2003 enterprise IT tool is in the final stages of being successfully certified and accredited with an Authority to Operate (ATO) by June 2006.
Recommendation # 4: Discuss with other intelligence community and law enforcement agencies their information sharing requirement to ensure compatibility with those systems in the requirements and design of SENTINEL.
FBI Response: Concur. We recognize the importance of information sharing and are working to ensure SENTINEL provides that capability. The PMO has a dedicated data architect working closely on this matter with the intelligence and law enforcement communities. We also participate-on a regular basis-with the FBI's Information Sharing Policy Board.
Recommendation # 5: Ensure that an effective system is in place to accurately track and control SENTINEL's development costs.
FBI Response: Concur. The FBI has already implemented steps to ensure that all costs are authorized in advance, verified when delivered, and validated when invoiced. The SENTINEL PMO has a dedicated Business Management Unit (BMU) to track, monitor and control all program and development costs, consisting of a government Business Manager, Budget Analyst, EVM Analyst, and is obtaining the services of a Cost Estimator. Additionally, the BMU has developed detailing invoicing procedures to validate all internal and external costs. A separate, dedicated cost code has been set up by the Chief Financial Officer (CFO) for SENTINEL within the OCIO (a first), which allows for SENTINEL, OCIO budget administration, and CFO teams to jointly track and control SENTINEL costs through a Budgetary Evaluation and Analysis Reporting System (BEARS) tool and oversight process.
Recommendation # 6: Complete a comprehensive SENTINEL training plan with realistic schedule and cost estimates and include these training estimates in the estimates of overall project costs.
FBI Response: Concur. SENTINEL has included extensive requirements in the Statement of Work for Organizational Change Management which includes training to all FBI staff at all locations including Legats. The development contractor is required to develop a SENTINEL training plan as part of their tasking. The FBI's cost estimates for SENTINEL already include funding for this activity.
Recommendation # 7: Establish a method to monitor the operational impact of a potential second reprogramming and identify for resolution any degrading of the FBI's mission-critical functions due to the diversion of funds to the SENTINEL project.
FBI Response: Concur. The FBI routinely evaluates the operational impact of any reprogramming. Those evaluations are included in the FBI's decision whether to submit a request to Congress for the necessary approval to reprogram resources. All reprogramming proposals include statements summarizing the impact on current operations, and the FBI provides additional detail to the Department of Justice, Office of Management and Budget, and Congress.