Oversight of the Business Systems Modernization Contractor
Needs Improvement
January 2004
Reference Number: 2004-20-034
This report has cleared the Treasury
Inspector General for Tax Administration disclosure review process and
information determined to be restricted from public release has been redacted
from this document.
January
28, 2004
MEMORANDUM FOR CHIEF INFORMATION OFFICER
FROM: Gordon C.
Milbourn III /s/ Gordon C. Milbourn III
Assistant
Inspector General for Audit (Small Business and Corporate Programs)
SUBJECT: Final Audit Report - Oversight of the
Business Systems Modernization Contractor Needs Improvement (Audit # 200320028)
This report presents the results of our
review of the Internal Revenue Service’s (IRS) oversight of the Business Systems
Modernization (BSM) Contractor. The
overall objective of our review was to determine whether the Business Systems
Modernization Office (BSMO) implemented effective processes to ensure the BSM
contractor, Computer Sciences Corporation (CSC), addressed and improved the
areas of concern identified by the IRS in April 2002.
In summary, the BSM program is progressing
slowly and continues to face many challenges.
Four major modernization projects are experiencing significant cost
increases and missing proposed completion dates. Over the past several years, we have provided the BSMO with
recommendations and corrective actions that would strengthen controls and
improve processes to help reduce some of the concerns.
In April 2002, the IRS issued a letter to the
CSC that identified concerns and improvements that were needed in the BSM
program. The first IRS concern involved
the CSC’s responsibility to ensure all essential business requirements for the
proposed new computer systems were defined by the CSC and its major
subcontractors. The IRS emphasized that
the requirements must be defined before the projects’ development phase of
work. The IRS also required written
assurance from the CSC that its major subcontractors had identified all
significant business requirements and performed their work with adequate
diligence.
The second IRS concern involved the
qualifications needed by key personnel from the CSC and its
subcontractors. The qualifications were
listed and key personnel were defined as project managers, team leaders,
systems or project architects, lead analysts and designers, project planners,
and cost estimators who have significant responsibility for technical or
management decision making.
The first concern raised by the IRS has been
addressed. The CSC timely notifies IRS
management of proposed changes to the business requirements of the
modernization projects. However, the
projects are still experiencing a significant number of changes related to
business requirements subsequent to the design phase.
In addition, the IRS continues to approve
the development of the new computer systems without obtaining written assurance
from the CSC that the new computer systems will meet the needs of the IRS. The BSMO officials informed us that they did
not believe obtaining written assurance from the CSC would solve any problems. For the Customer Account Data Engine (CADE) project, the IRS is currently
spending additional funds to have the Software
Engineering Institute at Carnegie Mellon University conduct an
independent technical assessment.
The second concern, involving qualifications
needed by key personnel from the CSC and its major subcontractors, has not been
addressed. The BSMO has not established
an effective process to ensure the CSC selects and assigns qualified key
personnel to the BSM program. We found
inconsistencies in how the IRS project managers approve key personnel proposed
by the CSC. Several of the IRS project
managers were unaware of the qualifications required by the IRS’ April 2002 letter
because the contents of the letter were never provided as guidance to the BSMO
staff.
Concerns similar to the ones that
necessitated the IRS’ letter to the CSC have continued to occur in the BSM
program. Examples include:
·
The CADE
project, originally estimated to cost
$50 million and scheduled to be released in January 2002, has been
delayed. A new release date has not
been set. CSC officials admitted that
one of the reasons for the latest delay was because the staff from one of the
CSC’s major subcontractors did not have experience with large projects.
·
The e-Services
project, a $60 million project originally promised for June 2002, delayed its
initial release until August 2003 at an estimated cost of over $135 million.
·
The Integrated
Financial System project, originally estimated to cost $36 million and
scheduled to be released in October 2003, has been delayed. The new release date is scheduled for early
2004. A new cost estimate has not been
set.
To more clearly
define the CSC’s responsibility to fully document the business requirements
prior to beginning system development, we recommended that the Chief
Information Officer (CIO) ensure future task orders include the requirement
that the CSC provide written assurance
that it and its subcontractors performed adequate diligence in defining all
significant business requirements and that the proposed new systems will
deliver all of the essential functional and operational capabilities needed by
the systems’ users. We also recommended
that the CIO require the BSMO to conduct an analysis of future change requests
to determine whether the change should have been part of the contractor’s
normal requirements gathering.
To ensure all CSC and subcontractor
personnel have the necessary qualifications and expertise, we recommended that
the CIO require the BSMO to adopt the definition of key personnel from the IRS’
April 2002 letter and incorporate all key personnel and their required
qualifications into the task orders.
The CIO should also require the contractor to submit a plan to assure
the IRS that all currently assigned key CSC and subcontractor personnel have
the necessary expertise.
Management’s Response: Management
fully agreed with three of our recommendations, partially agreed with one
recommendation, and disagreed with the final recommendation. IRS management plans to take the following
actions: formally institute a
checkpoint in the development process where detailed specifications will be
established, require the CSC to formally give its written assurance at this
checkpoint under fixed-price contracts for all systems development and
implementation projects, include contracting language to hold the CSC
accountable for any material requirements under the agreed contract price, and
monitor accepted corrective actions on a monthly basis until completion.
IRS management also plans to
standardize procedures to identify and review the qualifications of key CSC
personnel and subcontractor personnel and establish an Education and Experience
Matrix that identifies education requirements, experience, and responsibilities
for key personnel. The Office of
Procurement will develop template language to be included in each task order,
excluding fixed-price contracts. Management’s
complete response to the draft report is included as Appendix IV.
Office
of Audit Comment: Management is
implementing an alternate corrective action for our first recommendation, which
requires written assurance from the CSC to perform adequate diligence in
defining all significant business requirements. We agree with their corrective action because, under the new CIO
directive, the CSC will provide its written assurance at a new checkpoint.
Management partially
disagreed with our recommendation to review key personnel proposed by the CSC
under fixed-price contracts. For
fixed-priced contracts, management does not believe they should be in a
position of vetting the PRIME team and will not perform any special personnel
reviews.
Management also disagreed
with our recommendation that the CIO require the CSC to submit a plan assuring
the IRS that all currently assigned key CSC and subcontractor personnel either
(1) have the necessary expertise, (2) can acquire the necessary expertise, or
(3) will be replaced in a reasonable time period. They stated it is not feasible or cost effective at this time, and
key personnel should be retained unless their performance is
unsatisfactory.
Based
on the history of the BSM projects being delayed and over budget, we believe
our recommendations could help avoid future project delays and cost increases
for existing and future contracts, regardless of the type of contract, by
assuring qualified personnel are assigned to projects. While we still believe our recommendations
are worthwhile, we do not intend to elevate our disagreement concerning it to
the Department of the Treasury for resolution.
Copies
of this report are also being sent to the IRS managers who are affected by the
report recommendations. Please contact
me at (202) 622-6510 if you have questions or Margaret E. Begg, Assistant
Inspector General for Audit (Information Systems Programs), at (202) 622-8510.
The Internal Revenue Service Is Timely Notified of Changes to Business Requirements
Appendix
I – Detailed Objective, Scope, and Methodology
Appendix
II – Major Contributors to This Report
Appendix
III – Report Distribution List
Appendix
IV – Management’s Response to the Draft Report
The Internal Revenue Service (IRS) is currently in the midst of a multiyear, multibillion dollar effort to modernize its information technology and business systems. The IRS Business Systems Modernization Office (BSMO) manages the modernization efforts and oversees the work of the PRIME contractor, Computer Sciences Corporation (CSC), which the IRS hired in December 1998. The CSC heads an alliance, the PRIME Alliance, of leading technology companies to help modernize the IRS business and computer systems.
The Business Systems Modernization (BSM) program continues
to face many challenges, such as continued project cost increases and
deployment delays. We previously
reported areas of concern and recommended actions that would enable the IRS to
strengthen its oversight of the PRIME contractor. For example, in a previous report on the use of performance-based
contracting in the BSMO, we discussed how performance standards often focused
on the production of documentation rather than the development of the business
systems. We reported that the plans for
monitoring contractor performance were subjective and not always consistent
among projects and that the use of recommended firm fixed-price task orders had
decreased. We recommended improvements
in the use of performance-based contracting to address these issues.
In another report, we discussed how significant changes to the e-Services project’s business requirements and setbacks in other development efforts resulted in increased costs and delays in completing the project. The IRS estimated, in April 2000, that the project would require $3.8 million to complete its design phase by September 2000. However, by March 2001, the estimated costs to complete this phase increased to over $17 million and the expected date of completion had been delayed until June 2001. Much of this increased cost and delay in project development was due to significant changes to the project’s requirements. Therefore, we recommended the BSMO ensure the e-Services project team identify, evaluate, and monitor all significant dependencies on the other modernization projects.
The IRS has also identified concerns with the results of the BSM program. In April 2002, the IRS issued a letter to the CSC addressing significant concerns that were being encountered in the BSM program and the CSC’s responsibilities in relation to those concerns. The IRS presented two main issues and the corrective actions needed to ensure future success.
The first concern the IRS identified involved the CSC’s
responsibility to ensure all essential business requirements were defined by
the CSC and its major subcontractors.
The letter stated:
When CSC proposes that the IRS approve [the] exit of milestone 3 for any project, we will require written assurance from CSC that its major subcontractors have done adequate diligence concerning the relevant scope of IRS operations (i.e., operations directly affected by the project) to assure that all essential functional and operational capabilities will be provided by the proposed new systems and business processes. These capabilities should be documented in the form of the business requirements that are called for in the life cycle methodology at the exit of milestone 3.
The life cycle methodology the IRS adopted presumes all significant business requirements are defined before a BSM project completes the design phase at milestone 3. Defining these business requirements is the CSC’s responsibility. The IRS required that all necessary changes to business requirements that arise after a project exits milestone 3 be called to the attention of IRS management on a timely basis.
The second concern raised by the IRS involved the qualifications needed by key personnel from the PRIME Alliance. The IRS required all key CSC and subcontractor personnel to have three capabilities:
1. Demonstrated track record of successful projects that include business process reengineering and business systems implementation in financial services organizations in the private and/or governmental sectors.
The IRS defined key personnel as persons such as project managers, team leaders, systems or project architects, lead analysts and designers, project planners, and cost estimators who have significant responsibility for technical or management decision making.
The IRS requested the CSC to submit a plan to assure that all currently assigned key personnel either (1) have the necessary expertise in the above three areas, (2) can rapidly acquire that expertise at the CSC’s expense, or (3) will be replaced in a reasonable time period with individuals who have the necessary expertise.
Our audit was conducted in the BSMO facilities in Lanham, Maryland, between May and September 2003 in accordance with Government Auditing Standards. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
The IRS required the CSC to timely notify IRS management of any significant changes to business requirements that arise after a project exits milestone 3 so that informed decisions could be made at the appropriate level. IRS management could then decide whether to modify the new computer system being built or incorporate the newly identified business requirement(s) into a subsequent release of the project.
This requirement has been met. IRS management is timely notified of proposed changes to the business requirements of modernization projects. The BSMO project managers of the four projects we reviewed are adequately involved with the ongoing development and deployment activities and are fully aware of changes to the projects’ business requirements.
Although the concern of the IRS receiving timely notification of changes to business requirements has been addressed, the projects are still experiencing a significant number of changes after they complete milestone 3, referred to as the design phase. As the IRS emphasized in its April 2002 letter, the CSC is responsible for identifying all significant business requirements for the projects prior to the exit of milestone 3.
Changes to the requirements of computer systems that have already entered the development phase have contributed to delays in completing the projects. The extent of these changes and the delays experienced by the modernization projects are discussed in the next section of this report.
As stated in the Background section of this report, we previously reported that significant changes to a project’s requirements resulted in increased costs and delays in completing the new computer system. The IRS also recognized this concern.
To help alleviate
the concern, the IRS informed the CSC that the IRS would require written
assurance from the CSC that its major subcontractors had conducted their work
with adequate diligence. The IRS wanted
written assurance from the CSC that major subcontractors considered all IRS
operations affected by the proposed new systems and that all essential
capabilities would be provided by the new systems. These capabilities should be documented in the form of the
business requirements that are called for in the Enterprise Life Cycle (ELC)
methodology when the system exits the design phase and begins the development
phase.
The ELC presumes
all significant business requirements have been defined in a Systems
Requirements Report (SRR) before a project moves into development. The SRR is a formal contract deliverable due
at the end of the design phase.
The Filing and
Payment Compliance and the Integrated Financial System (IFS) projects both
received approval to exit the design phase after the IRS issued its April 2002
letter to the CSC. However, the BSMO
did not obtain written assurance from the CSC that all significant business
requirements were defined for these two projects and that the new systems would
deliver all of the essential functional and operational capabilities needed by
the systems’ users.
Key BSMO officials informed us they did not believe obtaining written assurance from the CSC would solve any problems or reduce the volume of requirements changes. They stated that although a complete analysis of change requests has not been performed, a large majority of the changes to requirements are unavoidable due to changes in the tax laws. While this may be true, we believe that written assurance would help reduce the excessive number of changes to the business requirements. Changes to tax laws do add a degree of complexity to the design of computer systems; however, tax law changes are not unforeseeable. Computer systems should be designed to accommodate these variables.
The Filing and Payment Compliance project was postponed in December 2002 shortly after completing its design phase. Therefore, there have been no changes to the business requirements for this project. However, the IFS project, originally estimated to cost $36 million and scheduled to be released in October 2003, has been delayed. The new release date is April 2004. A new cost estimate has not been set. The IFS project is currently experiencing changes to its originally proposed requirements.
Table 1 presents the effect of extensive
changes to the business requirements of four key modernization projects that
completed milestone 3 and began the development phase.
Table 1: Project Change
Requests as of July 7, 2003
|
|
|
Approved Change
Requests |
|
|---|---|---|---|
|
Security and
Technology Infrastructure Release (STIR) |
1/2001 |
48 |
Delayed |
|
Customer Account Data
Engine (CADE) |
6/2001 |
38 |
Delayed since
1/2002. No release date has been set. |
|
IFS |
2/2003 |
7 |
Delayed |
|
e-Services |
7/2001 |
56 |
Delayed |
Sources: Data summarized from the IRS Change Request
Tracking system and our audit results.
For the CADE project, the IRS is currently spending additional funds to have the Software Engineering Institute at Carnegie Mellon University conduct an independent technical assessment.
The e-Services project, a $60 million project originally promised in June 2002, was delayed until August 2003 at an estimated cost of over $135 million.
To more clearly define the CSC’s responsibility to fully document the business requirements prior to beginning system development, we recommend that the Chief Information Officer (CIO):
1.
Ensure future task orders include the requirement that
the CSC provide written assurance that it and its major subcontractors
performed adequate diligence in
defining all significant business requirements and that the proposed new
systems will deliver all of the essential functional and operational capabilities
needed by the systems’ users.
Management’s Response: The CIO has issued a directive that requires fixed-price contracting for all systems development and implementation projects. Fixed-price contracting requires mutually agreed detailed specifications, which will be addressed at a new checkpoint. The CSC will be required to provide its written assurance at this checkpoint.
Office of Audit Comment: We agree with management’s alternate corrective actions because the new CIO directive will hold the CSC accountable for performing adequate diligence in defining all significant business requirements by providing its written assurance at the new checkpoint.
2. Require the BSMO to conduct an analysis of future change requests to determine whether the change should have been part of the contractor’s normal requirements gathering. Task orders to define business requirements should be written to hold the CSC responsible for making such changes at no additional cost to the IRS.
Management’s Response: Management agreed to include contracting language to the effect that failure to identify any material requirement is the CSC’s responsibility and any work to include such a requirement is included under the agreed price.
The BSMO has not established an effective
process to ensure the CSC selects and assigns qualified key personnel to the
modernization program. We found
inconsistencies in how the IRS project managers approve key personnel proposed
by the CSC. Some IRS project managers
interview personnel that are proposed by the CSC, while other IRS officials do
not believe they have this authority.
Several of the IRS project managers were unaware of the three
qualifications outlined by the IRS’ April 2002 letter. In fact, some IRS officials had never seen
the qualification requirements prior to our audit.
The IRS project staffs are not
consistently requiring key personnel to be listed on the task orders because
the BSMO has not issued clear guidance to its project managers or directors
regarding who should be considered a key person. Not having guidance on how to define a key person and what
qualifications are required has resulted in inconsistencies among the projects’
task orders. For example, the current
task order for the Infrastructure Shared Services (ISS) project lists 12
individuals as key personnel, while the task order for the e-Services project
lists only 5 key personnel. On both
projects, several additional individuals should be listed as key personnel, if
the definition provided by the IRS is used.
By listing these individuals in the contract, the CSC must provide
resumés to indicate their qualifications, and the IRS Contracting Officer is
authorized to approve or disapprove of any replacement of or substitution for
these individuals.
We also noted the three qualifications
were not incorporated into the current task orders for the four projects we reviewed. When we inquired as to why these
qualification requirements were not included in the task orders, one project
team informed us they had never seen the qualification requirements prior to
our audit. They also informed us the
qualification requirements were not included in the Program Management Plan
(PMP). Our review of the PMP and
interviews with other BSMO officials confirmed this explanation. The BSMO did not attempt to improve or
establish processes at the project level to ensure key personnel from the PRIME
Alliance met the three qualifications required by the IRS.
BSMO officials informed us they did not
implement a process to ensure key personnel from the PRIME Alliance met the
qualifications because they believed the qualifications and experience of key
personnel had improved. They also
informed us that selecting and assigning qualified personnel is the CSC’s
responsibility. The BSMO believed no
formal changes were needed regarding how IRS project managers approved key
personnel assigned to their projects.
The CSC provided us with an Action Plan,
which reports it completed an assessment of all key PRIME Alliance personnel
currently assigned to the modernization program. The Action Plan indicates the CSC completed an assessment of the
credentials of the key PRIME Alliance personnel, and, as appropriate, training
plans were developed to increase the expertise of the key personnel. We requested the assessment or any
documentation that would verify this critical action was taken. However, the CSC did not provide this
documentation for our review.
To determine whether key personnel from
the PRIME Alliance met the qualifications and expertise requirements, we
requested 83 resumés from the IRS project managers on the 4 projects we
reviewed. However, the IRS does not
always retain these documents.
Therefore, we were able to obtain only 13 of the resumés, and our review
of this small sample was inconclusive.
We also requested resumés from the CSC, but the CSC did not provide
these documents.
The IRS National Background Investigation
Center provided academic and employment histories for many key individuals from
the PRIME Alliance. We reviewed this
documentation for the same 83 key personnel working in the IRS modernization
program at the project and program levels.
Although we were unable to determine whether the key personnel met the
specific qualification requirements listed in the IRS’ letter, we found two
managers who did not have a successful track record as a project manager.
The effect of not having qualified
personnel contributed to the latest delay in the CADE project. The rollout of the new CADE system was
originally estimated to cost $50 million and be released in January 2002. The project was delayed, and in July 2003
the IRS announced that the first release of the CADE system would not occur on
August 31, 2003, as planned. A new
release date has not yet been set. The
PRIME contractor admitted the subcontractor personnel responsible for
developing the new system did not have experience with large projects. The PRIME contractor also admitted that it
did not provide adequate oversight of the subcontractor to ensure the
subcontractor was on track.
The candor demonstrated by the CSC in
this case was appreciated by the IRS.
However, the concern of not having qualified experienced personnel from
the PRIME Alliance has been ongoing for over a year. The IRS’ selection of the CSC in December 1998 was intended to
bring commercial best practices and technical, consulting, and managerial expertise
to the program. The success of the BSM
program depends on obtaining qualified, experienced personnel from the CSC and
its PRIME Alliance subcontractors.
Management Actions:
The BSMO and the CSC have been working to improve the qualifications of
PRIME contractor staff at the highest levels of the program. Several individuals were hired by the PRIME
contractor and assigned to the IRS modernization program, after BSMO officials
interviewed them and approved their qualifications.
To ensure the CSC is selecting and assigning qualified key personnel to the BSM program, we recommend the CIO require:
3. The BSMO to establish procedures to ensure a formal, consistent review of the qualifications of key CSC and subcontractor personnel that are selected and proposed by the CSC to work in the IRS modernization program. These procedures should include guidance on how to define those individuals from the PRIME Alliance who should be classified as key personnel at both the program and project levels. The definition of a key person provided in the IRS’ April 2002 letter to the CSC should be adopted by the BSMO.
Management’s Response: Management agreed to establish standard and uniform procedures across the program to identify key personnel and to ensure consistent review of the qualifications of key CSC and subcontractor personnel who are proposed by the CSC to work in any of the key roles. However, for fixed-priced contracts, management does not believe they should be in a position of vetting the PRIME team and will not perform any special personnel reviews.
Office of Audit Comment: We continue to believe the standard and uniform procedures for reviewing key personnel proposed by the CSC should be implemented at the program level for all projects regardless of the type of contract. Delays in fixed-price contracts (e.g., the CADE) can have an adverse effect on the BSM program even though costs may be capped on specific items. The BSMO could help prevent these delays by assuring qualified personnel are assigned to projects.
4. The BSMO to incorporate all key personnel and the three qualifications required in the IRS’ April 2002 letter into the key personnel section of the task orders.
Management’s Response: Management agreed to work with the Office of Procurement to establish an Education and Experience Matrix that identifies and provides a correlation of the minimum education, experience (in years), and responsibilities of the labor categories identified as key personnel. The Office of Procurement will add this language in each task order, excluding fixed-price contracts.
5. The PRIME contractor to submit a plan to assure the IRS that all currently assigned key CSC and subcontractor personnel at the program and project levels either (1) have the necessary expertise in the three areas required by the IRS’ April 2002 letter, (2) can rapidly acquire that expertise at the CSC’s expense, or (3) will be replaced in a reasonable time period with individuals who have the necessary expertise.
Management’s Response: Management
disagreed with our recommendation. They
stated that it was not feasible or cost effective at this time.
Office of Audit Comment: Based on the
history of BSMO projects being delayed and over budget, we believe the BSMO
should assure qualified personnel are assigned to projects to prevent future
project delays and cost increases.
Appendix I
Detailed Objective, Scope, and
Methodology
The objective of this review was to determine whether the
Business Systems Modernization Office (BSMO) implemented effective processes to
ensure the Business Systems Modernization (BSM) contractor, Computer Sciences
Corporation (CSC), addressed and improved the areas of concern identified by
the Internal Revenue Service (IRS) in April 2002.
To accomplish this objective, we:
I.
Determined how the BSMO
gained assurance from the CSC that all functional and operational requirements
and/or capabilities had been defined at a modernization project’s milestone 3
exit. (Only two projects managed by the
CSC have exited milestone 3 since the IRS issued its letter of concern to the
CSC in April 2002. The Filing and
Payment Compliance and Integrated Financial System (IFS) projects were included
in the scope of this test.)
II.
Determined what process the
BSMO followed to ensure changes to the business requirements, identified
subsequent to a project’s milestone 3, were timely reported to IRS
management. (Audit tests II, III, and
IV were focused around four main projects because significant work was
conducted on these projects subsequent to their milestone 3 exit. These four projects were the Customer
Account Data Engine, e-Services, IFS, and Security and Technology
Infrastructure Release (STIR) projects.
The STIR is a subproject of the Infrastructure Shared Services (ISS)
project.)
III.
For modernization projects
requiring the use of subcontractors that are part of the CSC’s PRIME Alliance,
determined how the BSMO ensured the CSC selected and assigned subcontractors
from the PRIME Alliance that have:
· A track record of working on successful projects that include business process reengineering and business systems implementation in financial services organizations in the private and/or public sector.
· Expertise in the more specific business functional areas covered by the project, such as collection or customer service.
· Either a track record of successful work with the IRS that demonstrates an in-depth understanding of IRS operations and the IRS enterprise architecture, or a clear plan to acquire such expertise in a manner that is not at the expense of the IRS.
IV.
Determined how the BSMO
ensured CSC personnel assigned at the program or project level met the above
three experience and expertise requirements.
(We requested 83 resumés but received
only 13 from the IRS. We reviewed
academic and employment histories at the IRS National Background Investigation
Center for the 83 key PRIME Alliance personnel that we identified.)
V.
Determined whether the BSMO obtained a written plan
from the CSC to assure the IRS that all key CSC personnel assigned to the IRS
modernization program, prior to the IRS’ April 2002 letter, had the requested
qualifications.
Appendix II
Major Contributors to This Report
Margaret E. Begg, Assistant Inspector General for Audit
(Information Systems Programs)
Gary V. Hinkle, Director
Scott A. Macfarlane, Director
Tammy Whitcomb, Audit Manager
Cari Fogle, Senior Auditor
Michael Garcia, Senior Auditor
Allen Gray, Senior Auditor
Phung-Son Nguyen, Senior Auditor
Appendix III
Commissioner C
Office of the Commissioner – Attn: Chief of Staff C
Deputy Commissioner for Operations Support OS
Associate Commissioner, Business Systems Modernization OS:CIO:B
Chief, Information
Technology Services OS:CIO:I
Deputy
Associate Commissioner, Business Integration
OS:CIO:B:BI
Deputy Associate
Commissioner, Program Management
OS:CIO:B:PM
Deputy
Associate Commissioner, Systems Integration
OS:CIO:B:SI
Director, Tax Administration
Modernization OS:CIO:B:PM:TAM
Acting Director, Portfolio
Management Division OS:CIO:R:PM
Chief Counsel CC
National Taxpayer Advocate TA
Director, Office of Legislative
Affairs CL:LA
Director, Office of Program
Evaluation and Risk Analysis RAS:O
Office of Management
Controls OS:CFO:AR:M
Audit Liaisons:
Associate
Commissioner, Business Systems Modernization
OS:CIO:B
Chief, Information Technology Services OS:CIO:I
Appendix IV
Management’s Response
to the Draft Report
The response
was removed due to its size. To see the
response, please go to the Adobe PDF version of the report on the TIGTA Public
Web Page.