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Status of IDENT/IAFIS Integration
Report No. I-2003-005
June 2003


APPENDIX I

JMD MANAGEMENT'S RESPONSE

  U.S. Department of Justice

May 22, 2003   Washington, DC 20530

MEMORANDUM FOR GLENN A. FINE
Inspector General
 
FROM: [original signed]
Paul R. Corts
Assistant Attorney General for Administration
 
SUBJECT: Comments on OIG Draft Report on the status of IDENT/IAFIS Integration

[Page 1 is not available electronically.]

Version 1.1 was a stand-alone workstation with no capacity for future upgrades as an integrated IDENT/IAFIS client. Version 1.1.1 allowed further site deployments with workstation hardware components that could later be updated with a software upgrade. In fact, all pre-existing version 1.1 workstations have now been replaced by version 1.1.1 workstations, and the old hardware is being re-deployed to Detention and Removal operational locations where an integrated workstation is not critical. If version 1.1.1 had not been developed and deployed in the past year, only 10 sites would have access to lAPIS today in contrast to the more than 50 sites that now have access. This five-fold increase in sites with access seems worthy of recognition as significant progress toward the ultimate goal.

Version 1.1+, currently in testing and scheduled for deployment this summer, for all intents and purposes will give us much of what we need from version 1.2. Most importantly, it will be the version that enables each apprehendee to be processed once, not twice (once in each system, using separate workstations). The elimination of dual processing, and the ability to clearly connect responses from both systems, will enable us to collect the data we need to measure the effect on the Department of Homeland Security's (DHS) Border Patrol and Inspections operations, accurately project other downstream impacts, and determine the most cost effective way to integrate the two systems.

The primary benefit version 1.2 will offer over version 1.1 + is full Joint Automated Booking System (JABS) functionality, specifically JABS-compliant mug shots. This capability, while important in fully extending the JABS program into these DHS functional areas, is not critical to the eventual integration of IDE NT and lAFIS. Furthermore, creating an environment to take JABS-compliant mug shots will involve some significant degree of business process re- engineering in the deployed sites, a time-consuming process that would slow down other tasks more critical to the core project. While we admit that deployment of version 1.1 + has been delayed approximately 6 months, it is scheduled to be deployed this summer and its delay is largely attributable to the high priority given to the development and deployment of another powerful tool in our war on terror, the National Security Entry Exit Registration System (NSEERS).

NSEERS DELAYS

With respect to the NSEERS-related delays, your report indicates that the Immigration and Naturalization Service (INS) and the Justice Management Division (JMD) recognized immediately in July 2002 that NSEERS would cause delays, yet the Acting Assistant Attorney General for Administration (AAG/ A) did not raise the issue with senior Departmental managers despite frequent opportunities to do so. You report that NSEERS was scheduled to be deployed in September 2002 but was still being worked on in March 2003. You also report that five upgrades were made to NSEERS over this time period. This suggests that each delay to upgrade NSEERS averaged 4-6 weeks. From the perspective of JMD, it was clear that NSEERS was a high priority for the Attorney General. Given that, and the fact that the duration of the conflict with NSEERS development was always less than 2 months at anyone time, it never seemed that any prospective delays to IDENT/IAFIS would be significant. Looking backward, given the eventual number of NSEERS upgrades, the cumulative delay was significant.

If we knew in July 2002 what we now know, alternative arrangements possibly could have been made. However, since it appeared that each delay would be of short duration, adding more resources to the project was not reasonable given the time it would take new staff and contract programmers to get up to speed. Further, the suggestion that coordinating the development of NSEERS upgrades with the integration project so that both projects could proceed is contrary to basic principles of system development. Both projects involved changes to the same two operational systems: IDENT and ENFORCE. To make simultaneous changes to the baselines of these systems would have jeopardized both projects as well as the existing operational systems.

Finally, your report states "JMD recommended that IDENT/IAFIS support NSEERS because JMD believed that it would benefit the IDENT/IAFIS project." The INS therefore directed the contractors and staff working on IDENT/IAFIS to instead work on the NSEERS project" (emphasis added). As indicated to your review team, INS worked on NSEERS at the direction of senior Departmental management. The only NSEERS-related support for the IDENT/IAFIS project was supplemental appropriation funding to deploy IDENT/IAFIS workstations to additional ports of entry to provide further identification capabilities to back-up and benefit NSEERS activities. Those added deployments did nothing to advance system integration efforts.

TRANSITION PLANNING

The report states that JMD has failed to address the serious management challenges created by the INS transfer to DHS and identifies two important consequences of JMD's lack of transition planning: lack of consensus among project participants regarding who should manage the future development and deployment, and potential loss of expertise of INS staff working on the project. With respect to the consensus issue, you report that JMD officials, the Counsel to the Attorney General, and FBI officials believe that project management should remain in DOJ while one INS/DHS official indicated that role should be transferred to DHS. It is not surprising that another agency's official would prefer that control over a project affecting that agency's information systems be located in his agency. I don't believe that position would change regardless of the amount of transition planning that is done. Clearly, Congress originally gave JMD the lead on this project and congressional staff have recently stated that they remain pleased with that decision. The fact that FY 2004 funding for the project was placed in the Department of Justice budget suggests that the Office of Management and Budget (OMB) and the President are satisfied with the current arrangement.

With respect to the potential loss of expertise, we can report that planning, development and deployment activities continue despite initial disruptions caused by the creation of DHS. We continue to work with the same personnel we dealt with when INS still existed, and we continue to make progress. As DHS personnel have settled in, we are making contacts with other officials that should be involved in the project, briefing them on the history of the project, and engaging them in planning its future directions.

JUNE 2003 REPORT TO CONGRESS

The draft report states, "We question JMD's approach to the congressional requirement because, according to JMD's own reasoning, the data it plans to use to prepare the cost projections for Congress will be of limited value." We informed the review team that the report to Congress will not contain cost projections for the precise reasons stated in your report. We plan to report some illustrative data gleaned from the initial deployment that underscore the need to continue this project, but we will point out that this data is not suitable for drawing national conclusions or making projections. As your report states, data suitable for those purposes will not become available until the version 1.1 + workstation has been deployed. The report to Congress will describe our plans for collecting such data and making those conclusions and projections in future follow-up reports.

RESPONSES TO RECOMMENDATIONS

As previously mentioned, I concur with the recommendations contained in the report. They propose a number of actions that are underway or planned and that would help ensure further progress in integrating the two systems. Our response to each is noted below.

  1. Coordinate with the DHS to identify the management, deployment, and operational issues raised by the INS transfer to the DHS.

    As stated previously, much planning and deployment activity has continued despite the INS transfer to DHS. Management and operational issues arise on occasion are being dealt with as they emerge. JMD has begun to meet with DHS officials who were not previously with INS in order to engage them in these activities and to respond to the Congressional question as to whether other DHS law enforcement components should be involved in the integration project. We anticipate these efforts will be on-going for the foreseeable future.

  2. Prepare a revised deployment plan with short- and long-range milestones to guide the integration project to the soonest possible completion.

    Now that conflicts with NSEERS development have ended and version 1.1 + is nearing deployment, we can develop a revised plan addressing further deployment and development activities. That revised plan is being prepared along with the FY 2005 budget submission and will be finalized after a Departmental review and budget decisions are made. This is anticipated by August 8, 2003. Of course, any subsequent revisions to the budget request by OMB could result in changes to that plan.

  3. Brief the Deputy Attorney General's Office often on the revised deployment plan, and identify management controls and resources for the integration project.

    We anticipate briefing the Deputy Attorney General and other senior Departmental managers as part of the FY 2005 budget process. At this time no date has been set, but it should occur this summer. Further briefings for those officials will be scheduled at their convenience.

  4. Produce quarterly reports on the progress and interim results of the Metric Study.

    Quarterly reports on the project's progress and interim results of the Metric Study will begin October 31, 2003 (30 days following the completion of the quarter ending on September 30), and will follow every 3 months thereafter.