The OIG provided a draft of this audit report to the FBI on April 28, 2006, for its review and comment. The FBI provided a written response, dated May 31, 2006, which we included as Appendix 5 of this final report. The FBI concurred with the three recommendations in the audit report and also provided comments regarding three general issues in the report. Our analysis of the FBI’s response follows.
FBI’s General Comments
- In its response, the FBI states that the purpose of LIMS was to enhance the processes and procedures currently in place in the laboratory by improving efficiencies and automation. Although we agree with this statement, it does not reflect the full impact that the implementation of the LIMS project would have had on the laboratory. As noted in the report, laboratory officials stated that the paper-based system currently being used by the laboratory is very limited in what information it can provide to enhance the management of evidence as it passes through the laboratory. LIMS would have allowed the FBI to electronically trace evidence as it passes through the lab and provide workflow data needed to better manage the laboratory.
The FBI’s response also states that our report implies the laboratory’s operations are not effective or adequate and points out that the FBI’s laboratory is one of the largest and most comprehensive forensic laboratories in the world. Our audit report recognizes the significant amount of work performed at the FBI laboratory and does not question the work that is performed on evidence within the laboratory. However, the size and scope of the laboratory do not demonstrate the effectiveness or adequacy of the management of the evidence held within the laboratory. Our audit concludes that the management of evidence as it passes through the laboratory would have been significantly enhanced had a laboratory information management system been fully and effectively implemented.
The FBI’s response also states that improvements to the laboratory’s information management system are required, rather than the establishment of a new system. The FBI is currently utilizing a Microsoft Access database to document when a piece of evidence is received, when a test has been completed on the evidence, and when it is released from the laboratory. However as pointed out in the report, the release of a piece of evidence is not always documented adequately. As a result, laboratory management cannot determine what evidence is contained within the laboratory at any given point in time. Additionally, the database system utilized by the laboratory also cannot reasonably pinpoint where a piece of evidence is at any given point in time. While we agree that the laboratory has an information management system in place, the system has limited functionality. This limited functionality led the FBI to enter into the LIMS contact to acquire a more effective system. We believe that the FBI either needs to make significant improvements to the existing information management system or acquire a new system that provides laboratory management the ability to more effectively manage laboratory operations.
- The FBI response states that our report implies the FBI had singular control over the system development and process, although the report acknowledges that the vendor also bears some responsibility for the project’s difficulties. As the response suggests, our audit found that both the FBI and the contractor were responsible for the outcome of the LIMS project. However, the FBI was solely responsible for establishing the system requirements and ensuring that the contractor met those requirements. We noted in the report that the FBI has recently made significant strides in the development and management of information technology projects. However, the LIMS project did not benefit from these new management practices.
The FBI’s response also notes that the contract termination settlement is far less than the full contract amount. We agree. However, the FBI incurred costs in addition to the settlement amount, such as the personnel involved in the development, management, and termination of the project. More important is the fact that despite having worked on the development of an information management system since 1998 and reprogramming funds from other Laboratory Division programs in order to pay for the project, the FBI’s laboratory remains without a modern system.
- The FBI requests that the vendor’s name and specific dollar amounts of the project be redacted from the report to protect the future business opportunities of the vendor and future requests for proposal issued by the FBI on similar projects. After careful review and consideration of the FBI’s request, we have decided to not redact the information for the following reasons: (1) the contractor’s name and the dollar amounts paid to JusticeTrax are public information;(2) the public has a right to know the name of the system contractor; and (3) our report is clear that both the FBI and JusticeTrax were responsible for contributing to LIMS’ failed implementation. For example, we fault the FBI for not adequately documenting system security requirements and for its overall poor project management, and we fault JusticeTrax for not meeting the FBI's security requirements once they were established and for not providing the web-enablement capabilities for the LIMS software as required by the contract. Therefore, we believe that our report is accurate as to which party was responsible for the various system implementation failures. Finally, because the name of the contractor and the dollar amounts paid to it are public information, we do not agree that disclosing the information in this report is inappropriate or will have an effect on future FBI request for proposals.
Status of Recommendations
- Resolved. The FBI agrees with this recommendation. In its response to the draft report, the FBI states that the Laboratory, in conjunction with the Office of the Chief Information Officer (OCIO) began a Business Process Management initiative to focus on the development, improvement, and reengineering of processes that govern the way laboratory services are provided. This recommendation can be closed when we receive documentation demonstrating that the FBI has considered whether a COTS workflow system or laboratory information management system in use or under development within the federal government will meet the needs of the FBI’s laboratory.
- Resolved. The FBI agrees with this recommendation. In its response to the draft report, the FBI states that it is committed to ensuring all current and future Laboratory Division information technology (IT) projects comply with OCIO IT management processes, including the Life Cycle Management Directive (LCMD). Additionally, the FBI Laboratory Division has established a Project and Account Management System (PAMS), which provides managers and users with real-time, online financial information. PAMS is a centralized, remotely accessed, web-based system that captures, tracks, and manages the laboratory’s investments. This recommendation can be closed when we receive documentation demonstrating that any project to provide a laboratory information management system not only follows the FBI’s LCMD but is overseen by an experienced IT project manager.
- Resolved. The FBI agrees with this recommendation. In its response to the draft report, the FBI states that the Laboratory Division is committed to ensuring that all current and future IT projects comply with the FBI’s OCIO IT management processes, including the LCMD. Additionally, the Laboratory Division established a Major Acquisition Review Committee (MARC), comprised of the Division’s Deputy Assistant Directors, Section Chiefs, and the Unit Chief of the Planning and Budget Unit. The MARC serves as the review entity for Live Cycle Phased Reviews, and reviews will be performed on all laboratory acquisition requests totaling $250,000 or more, all IT requests totaling $50,000 or more, and all Laboratory Division projects totaling $100,000 or more. This recommendation can be closed when we receive documentation demonstrating that the FBI has established cost controls to ensure that training or other expenses are not incurred prematurely in the development of a successor to the LIMS project.