However, GAO has reported that agencies that have implemented these “certified” packages still had significant problems.
Has the OMB process for certifying financial management systems or
packages improved agencies ability to successfully implement these systems?
In your view, have these “certified” systems helped the Department?
The certification process has been helpful but it is just one part of the equation. First, the certification process covers a subset of the financial management requirements needed to meet the requirements called for in the Federal Financial Management Improvement Act (FFMIA) of 1996.18 Agencies must be mindful of this distinction. Second, agencies must fully understand that these packages are extremely complex and the user does not simply open a box, install the software, and turn it on. Agencies must make many decisions when installing these complex systems, and these decisions will affect the ultimate success of a project. An agency has little assurance that even though the package is certified, its implementation of a new system will also be compliant with FFMIA. This is due to (1) configuration decisions made during system implementation and (2) manual and non-COTS processes that are needed for successful implementation. While the certification tests are useful, federal agencies need to perform a great deal of their own testing to ensure that the system as ultimately implemented meets their needs and complies with FFMIA requirements. For example, although the COTS products adopted by DHS were tested and certified by JFMIP,19 DHS still needs to test whether the products were implemented in a manner that ensured the packages continued to comply with the federal financial management systems requirements.
Further, the certification testing by necessity focuses on the technology portion of the equation. As noted in our report, each of the two financial management systems selected by DHS has significant material weaknesses, some of which were caused by factors outside the COTS package technology, such as people and process problems. Accordingly, DHS will also need to focus on these areas and correct these weaknesses before it can have reasonable assurance that its consolidation efforts will result in compliant systems.
18Pub. L. No. 104-208, div. A., §101(f), title VIII, 110 Stat. 3009, 3009-389 (Sept. 30, 1996). FFMIA requires the heads of the 24 major departments and agencies (“Chief Financial Officer (CFO) Act agencies”) to maintain systems that comply substantially with three requirements: (1) federal financial management systems requirements, (2) federal accounting standards, and (3) the U.S. Standard General Ledger (SGL) at the transaction level.
19The former Joint Financial Management Improvement Program (JFMIP) was formed under the Budget and Accounting Procedures Act of 1950, Pub. L. No. 81-784, § 111 (f), 64 Stat. 832, 835 (Sept. 12, 1950) (codified at 31 U.S.C. § 3511), as a joint and cooperative undertaking of GAO, the U.S. Department of the Treasury, OMB, and Office of Personnel Management (OPM), working in cooperation to improve financial management practices in the federal government. In an effort to eliminate duplicative roles and streamline financial management improvement efforts, some of the former responsibilities of the JFMIP were placed under the Financial Systems Integration Office. (See OMB, Realignment of Responsibilities for Federal Financial Management Policy and Oversight, Memorandum (Washington, D.C.: Dec. 2, 2004)). As a result of the realignment, JFMIP ceased to exist as a separate organization, although the principals will continue to meet at their discretion.
GAO-07-1157R DHS Posthearing Questions