A Government Accountability Office report shows that the Federal Bureau of Investigation still has not adopted practices to develop an enterprise architecture for its information technology systems.

Two years ago the GAO recommended 31 best practices (GAO-03-959, PDF) for developing and enforcing an enterprise architecture to integrate the FBI’s diverse IT systems. The current report (GAO-05-363, PDF) states the FBI has only implemented 15 of the 31 recommendations.

The FBI is managing its EA program in accordance with many best practices, but other such practices have yet to be adopted. These best practices, which are described in GAO’s EA management maturity framework, are those necessary for an organization to have an effective architecture program. Examples of practices that the bureau has implemented include establishing a program office that is responsible for developing the architecture, having a written and approved policy governing architecture development, and continuing efforts to develop descriptions of the FBI’s “as is” and “to be” environments and sequencing plan. The establishment of these and other practices represents important progress from the bureau’s status 2 years ago, when GAO reported that the FBI lacked both an EA and the means to develop and enforce one. Notwithstanding this progress, much remains to be accomplished before the FBI will have an effective EA program. For example, the EA program office does not yet have adequate resources, and the architecture products needed to adequately describe either the current or the future architectural environments have not been completed. Until the bureau has a complete and enforceable EA, it remains at risk of developing systems that do not effectively and efficiently support mission operations and performance.

The FBI is relying heavily on contractor support to develop its EA; however, it has not employed effective contract management controls in doing so. Specifically, the bureau has not used performance-based contracting, an approach that is required by federal acquisition regulations whenever practicable. Further, the bureau is not employing the kind of effective contractor tracking and oversight practices specified in relevant acquisition management guidance. According to FBI officials, the agency’s approach to managing its EA contractor is based on its long-standing approach to managing IT contractors: that is, working with the contractor on iterations of each deliverable until the bureau deems it acceptable. This approach, in GAO’s view, is not effective and efficient. According to FBI officials, as soon as the bureau completes an ongoing effort to redefine its policies and procedures for managing IT programs (including, for example, the use of performance-based contracting methods and the tracking and oversight of contractor performance), it will adopt these new policies and procedures. Until effective contractor management policies and procedures are defined and implemented on the EA program, the likelihood of the FBI effectively and efficiently producing a complete and enforceable architecture is diminished. — GAO-05-363 (PDF)

Currently, the FBI has many computer systems which duplicate the functionality of other systems, with little centralized management. Though the FBI has begun to upgrade, modernize and integrate its systems, it hasn’t met with a whole lot of success. Consider the Virtual Case File System, which was abandoned after $170 million spent on the project.

In response, Zalmai Azmi, the FBI’s chief information officer, wrote that the bureau has been successful in using fixed-price contracting, rather than the performance-based contracting, because the approach gives contractors an incentive to stay on schedule. But, he said, the FBI would take steps to encourage performance-based contracting. — GovExec.com

Performance-based contracting looks like a good idea. Consider these case studies:

Conversion to performance-based contracting for Navy aircraft maintenance resulted in immediate savings of $25 million. Additional savings are anticipated through the positive and negative incentives contained in the contract. The proposal, evaluation and award process took 30 days less than was needed for the previous non-performance based competition. Working with industry as a team, to meet Navy aircraft maintenance requirements, resulted in dollars and time savings. So far, performance is surpassing the contract’s minimum required standards.

The National Aeronautics and Space Administration (NASA) saved enough money from converting a janitorial services contract to PBSC to reinstate several tasks previously cut due to a lack of sufficient funds.

The Environmental Protection Agency (EPA) saved enough money from its first PBSC Superfund task order to fully fund the next task order.

Anyone out there know more about performance-based contracting, and why the FBI hasn’t been using it?