CBP Posts its Report to Congress on ACE for Fourth Quarter FY 2008, Says M1 Delay to Impact All Subsequent Releases

CBP's report provides an update on ACE accomplishments, challenges, fiscal status, and upcoming program milestones. According to CBP, this report demonstrates how ACE is helping CBP achieve Department of Homeland Security (DHS) strategic objectives and how ACE is providing CBP personnel in the field with enhanced capabilities to better accomplish the CBP mission of preventing terrorism and facilitating legitimate trade and travel.

ACE Program Assessment

CBP provides the following ACE program assessment for the fourth quarter of FY 2008 (see report for details):

M1 Delay to Impact All Subsequent ACE Releases, Overrun of $30 to $40 Million

As mentioned in the FY 2008 third quarter report to Congress, CBP continues to predict an overrun of $30 to $40 million in support of the scheduled deployment of M1 capabilities.

The deployment of M1 was delayed six months and is scheduled for April 2009. CBP notes that this delay will impact all subsequent ACE releases.

CBP states that it is working diligently to address these schedule and budget challenges through the execution of an independent program assessment "red team" review, development of a functionality management process, and development of ACE cargo release functionality sooner than originally planned.

(See ITT's Online Archives or 07/28/08 news, 08072805, for BP summary on the schedule slip of the M1 release, which also delayed the deployment of ESAR A2.2.)

CSPO Anticipated to Release New Cost & Schedule Projections, Develop M2.3 Earlier Than Planned

The independent "red team" review of ACE began on September 1, 2008 and was anticipated to take 90 to 120 days to complete. Once the review ended and findings were assessed, the Cargo Systems Program Office (CSPO) anticipated releasing new cost and schedule projections incorporating the impact of the M1 slip on future releases, "red team" review recommendations, and the development of the Cargo Release (M2.3) portion of ACE earlier than originally planned. CBP adds that the cargo release functionality is critical to many of the Participating Government Agencies (PGAs) working with CBP, and as such, development of these capabilities has been moved to a higher priority.

(See ITT's Online Archives or 11/03/08 news, 08110305, for BP summary of CBP Commissioner Basham ordering an independent review of ACE, etc.)

CSPO is Leveraging Lessons Learned from M1 Delay

CSPO is leveraging lessons learned from the recent M1 delay and developing strategies for avoiding cost overruns and schedule delays in the future, one of which is a new process for managing the scope of future ACE releases. This process will include the identification of functionality as it relates to deployment priorities, with the goal of focusing on the deployment functionality that will efficiently transition users away from the use of the Automated Commercial System (ACS) to ACE. CBP intends to ensure resources are directed to the development of these capabilities, thereby facilitating timely and on-budget deployment.

Selected Accomplishments

CBP provides the following ACE accomplishments for the fourth quarter of FY 2008 (partial list):

Performed M1 Cutover Testing

Testing was done to confirm the steps needed to deploy M1 (e-Manifest: Ocean and Rail) capabilities to the production environment in support of initial Production Readiness Review (PRR) efforts.

Conducted Review of ESAR A2.2 User Interface Screens

Trade representatives from the importer, broker, and software vendor communities were able to view and comment on the initial entry summary capabilities (ESAR A2.2) screens for the automated CBP Form 28, Request for Information; CBP Form 29, Notice of Action; and CBP Form 4647, Notice to Mark and/or Notice to Redeliver (imported cargo).

(See ITT's Online Archives or 03/06/09 news, 09030605, for BP summary of CBP announcing the deployment schedule for ESAR A2.2.)

Achieved Planned Target for Four Key Performance Parameters

As of September 2008, CBP achieved the planned target for the ACE Key Performance Parameters (KPPs) that track the number of ACE accounts (15,211), the percentage of duties and fees paid via the ACE periodic monthly statement process (42%), the national percentage of e-Manifests filed (99.7%), and the percent of reduction in truck processing time due to e-Manifest filing (37%).

Hosted Integrated Process Teams in Support of ESAR AD/CVD Functionality

CSPO convened Integrated Process Teams (IPT) to define the scope for Antidumping/Countervailing Duty (AD/CVD) functionality, which CBP anticipates will be deployed as part of the first ESAR: Remaining Entry Types (A2.3) sub-drop, referred to as A2.3.1. The team also collaborated with PGAs, including the U.S. Census Bureau, Import Administration, and the Defense Contract Management Agency.

Deployed Advanced Targeting/S3 Mission-Critical Capabilities

In July and September 2008, CBP successfully completed development and deployed Advanced Targeting/S3 enhancements to modernize and improve the current Automated Targeting System (ATS) operations to facilitate greater risk management.

(S3 combines the Screening Foundation (S1) and ATS targeting capabilities into a single platform.)

Efforts to Address Open GAO Recommendations

In the fourth quarter of FY 2008, CBP made the following efforts to address Government Accountability Office (GAO) open recommendations (partial list):

Minimize Degree of Overlap and Concurrency Across ACE Releases

The GAO has recommended that CBP minimize the degree of overlap and concurrency across ongoing and future ACE releases. GAO added that CBP should also capture and mitigate the associated risks of any residual concurrency. CBP has taken the following actions to reduce potential resource conflicts across ACE releases:

ACE releases have been divided into smaller groups of capabilities or "drops." Task orders for ACE drops will include not only development of the drop but also the key activities that are indispensable to fielding new ACE capabilities. A single manager will be appointed as the drop manager with overall responsibility for delivery of the drop.

Program managers have conducted planning to ensure that development milestones eliminate contention for computer hardware environments needed for development, integration, testing, and training activities.

CBP is centrally managing underlying ACE shared software services to maximize the efficient use of resources, enhance responsiveness to workload peaks, and provide consistent technical management approaches across releases.

In view of these efforts, CBP continues to recommend that the GAO consider closing this recommendation, and is awaiting a reply.

Program Risks and Mitigation Strategies

The GAO has recommended that CBP report on the program's plan and actions for improving ACE risk management and its current inventory of program risks, including their associated mitigation strategies and the status of the strategies' implementation.

According to CBP, a new round of risk identification efforts began in September 2007 to align with the finalization of the FY 2008 program and expenditure plans.

Additional rounds of risk identification were conducted between December 2007 and February 2008 in alignment with FY 2008 Integrated Baseline Reviews (IBRs). These continued as additional FY 2008 IBRs were conducted March through May 2008. For FY 2009, risk identification is again part of the ACE program and expenditure planning cycles, as well as part of FY 2009 IBRs. Risks are being reviewed on a continuous basis in various forums including monthly Contract Performance Reviews.

(See ITT's Online Archives or 03/06/09 news, 09030645 1, for BP summary announcing the release of this report.)

ACE quarterly report (posted 03/04/09) available at http://www.cbp.gov/linkhandler/cgov/trade/automated/modernization/ace/quarterly_reports/ace_4thqtr_08.ctt/ace_4thqtr_08.pdf