MEMORANDUM
TO: Jeff Trandahl
Clerk of the House
FROM: Robert B. Frey III
Deputy Inspector General
DATE: May 17, 1999
SUBJECT: Management Advisory Report - Legislative
Information Systems Evaluation
(Report No. 99-CLK-02)
This is our final report on Legislative Information Systems
Evaluation. The objective of this
evaluation was to analyze the system alternatives for replacing the Clerk’s Financial
Disclosure and Lobby Disclosure Act applications. In this report, we discussed areas where safeguards could be
implemented to mitigate the risk to the current applications. We also discussed a number of information
technology solutions that could replace the current Financial Disclosure and
Lobby Disclosure Act applications.
Accordingly, we recommended actions with respect to the maintenance and
replacement of these current applications.
In response to our February 9, 1999 draft report, your office
generally agreed with our findings and recommended actions. The March 1, 1999 management response is
incorporated in this final report and included in its entirety as an
appendix. The corrective actions taken
and planned by your office are appropriate and, when fully implemented, should
adequately respond to the recommended actions.
We appreciate the courtesy and cooperation extended to us by
your staff. If you have any questions
or require additional information regarding this report, please call me or
Christian Hendricks at (202)
226-1250.
cc: Speaker of the House
Majority Leader
of the House
Minority Leader
of the House
Chairman,
Committee on House Administration
Ranking
Minority Member, Committee on House Administration
Members,
Committee on House Administration
TABLE OF CONTENTS
I. INTRODUCTION........................................................................................................ 1
Background.................................................................................................................. 1
Objective, Scope, And Methodology........................................................................... 2
II. RESULTS OF
STUDY................................................................................................ 3
Needs Statement........................................................................................................... 3
Risk Assessment.......................................................................................................... 4
Feasibility Study.......................................................................................................... 7
Cost-Benefit Analysis.................................................................................................. 8
III. RECOMMENDED
ACTIONS........................................................................................ 12
Immediate.................................................................................................................. 12
System Planning, Development, and Implementation................................................. 13
Management Response............................................................................................... 14
Office of Inspector General Comments...................................................................... 15
IV. EXHIBITS
Exhibit 1: Application Overviews
Exhibit 2: Needs Statement
Exhibit 3: Risk Assessment
Exhibit 4: Feasibility Study
Exhibit 5: Cost-Benefit Analysis
V. APPENDIX
Clerk's Management Response to The Draft Report
LEGISLATIVE
INFORMATION SYSTEMS EVALUATION
This report presents the results
of the evaluation of the system options for replacing the Financial Disclosure (FD) and Lobby
Disclosure Act (LDA) applications in the Office of the Clerk (Clerk) with
electronic filing, document imaging, data encryption, and/or electronic
signature technologies. The report
includes the following: (1) a needs statement that presents the high-level
business needs for a replacement
system, (2) an assessment of the system risks associated with the FD and LDA
applications, (3) a feasibility study of viable options for replacing the
systems, (4) a cost-benefit analysis of implementing viable options to replace
the FD and LDA applications, and (5) a recommended course of action for
utilizing the results of the evaluation.
The
evaluation was conducted by the Office of Inspector General (OIG) utilizing the
services of PricewaterhouseCoopers (PwC).
The Clerk’s Office assisted the OIG by providing information to
facilitate the completion and validate the results of the evaluation.
The
Clerk tracks documents submitted to the U.S. House of Representatives (House)
under the Ethics in Government Act (EIGA) and LDA. For the EIGA, Representatives and Delegates of the House, House
Officers, certain employees, and candidates running for election to the House
must file financial disclosure statements with the Clerk. Disclosure statements are tracked and made
available to the public using the FD application. The LDA requires lobbyists to register and provide semi-annual
lobbying reports to the Clerk. The
registrations and reports are required to be common between the House and the
U.S. Senate (meaning the rules, regulations, forms, and collection periods must
match). The Clerk tracks and makes these
reports publicly available using the LDA application. In both cases, the Clerk is charged with a legal responsibility
for public disclosure of all reports filed under the respective acts.
The FD and LDA applications utilize a document capture system
called FileNet to capture and index paper generated source data. FileNet is a commercially available software
application operated and maintained by the Clerk. The system uses an Oracle database management system, UNIX
operating system, and RS-6000 hardware. Documents are scanned into FileNet using
Kodak Imagelink and Bell & Howell scanners that allow the images to be
stored on optical disk. The documents
are indexed on the House mainframe and captured by FileNet using a workflow
program. The general public can view
the documents by entering query criteria via a FileNet screen at the public
workstations in the Legislative Resource Center. Neither of these applications supports electronic filing of
documents, data encryption, or electronic signature.
The Clerk desires to replace both the FD and LDA
applications with modern hardware and software that allow for electronic
filing, document imaging, data encryption, and electronic signature
functionality. In addition, the Clerk
desires to implement a solution that can be maintained and operated solely by
Clerk resources.
The
detailed overview of the FD and LDA applications can be found in Exhibit 1, Applications Overviews.
The objective of the evaluation
was to analyze the system alternatives for replacing the Clerk’s FD and LDA
applications. The system alternatives
focused on the functional and technical feasibility, costs-benefits, and risks
of utilizing electronic filing, document imaging, data encryption, and electronic
signature technologies to meet the needs and deficiencies of the existing FD
and LDA applications. The evaluation of
the FD and LDA applications included the performance of the tasks listed below.
These tasks were completed in accordance with the House’s System Development
Life Cycle (SDLC) dated June 28, 1996, which implements procedures detailed in
the U.S. Department of Commerce, National Bureau of Standards, Special
Publication 500-153, Guide to Auditing
for Controls and Security: A System Development Life Cycle Approach. Our evaluation approach was to do the
following:
·
Gain
Understanding of Applications. Data
was collected to gain an understanding of the legislation that the applications
support, the functionality, business processes, and the organizations that use
and support the applications. The
detailed methodology and results of this task can be found in Exhibit 1, Application Overviews.
· Prepare a Needs Statement. Data was collected to identify
deficiencies in existing application capabilities, new or changed program
needs, and overall high-level business needs of the two applications as they
relate to the Clerk’s mission. The
detailed methodology and results of this task can be found in Exhibit 2, Needs Statement.
· Conduct a Risk Assessment. Data was collected to identify the
threats to data and assets, the potential impact of those threats, system
vulnerabilities, and existing safeguards of the current internal control and
security environment of the applications.
The detailed methodology and results of this task can be found in
Exhibit 3, Risk Assessment.
· Prepare a Feasibility Study. Based on the analysis of the data
collected in the needs statement and risk assessment tasks, a feasibility study
was performed. The feasibility study
included analyzing the needs, defining evaluation criteria, identifying a range
of potential alternatives, and selecting and developing system
alternatives. The detailed methodology
and results of this task can be found in Exhibit 4, Feasibility Study.
· Conduct a Cost-Benefit Analysis. The scope of this evaluation included a
cost-benefit analysis of the system alternatives identified in the feasibility
study. The detailed methodology and
results of this task can be found in Exhibit 5, Cost-Benefit Analysis.
The
work completed in the evaluation of the Clerk’s applications was based on the
following overall assumptions and constraints:
· Scalability. Any potential alternative must be scalable to meet all
needs. The scope of this evaluation was
the FD and LDA applications, but any potential system alternative must be able
to be scaled to meet the needs of other applications within the Clerk’s domain
or other areas of the House.
· Use of Commercial-off-the-Shelf
Applications. The House’s
Information Systems Program Plan, Management Policy for SDLC, states the desire
to move towards commercial-off-the-shelf (COTS) applications. For this evaluation, commercially available
software was considered for use as the infrastructure for the replacement
system. However, in order to meet the
unique needs of the Clerk’s Office, some customization may be required.
· Implementation Time Frame. Plans are currently underway to allow for a migration of all
mission critical applications from the House’s mainframe operated by the House
Information Resources’ (HIR) by the third quarter of Calendar Year (CY)
1999. Any potential alternative to
replace the current FD and LDA applications should consider that migration plan
when planning for the procurement or the implementation process.
· Economies of Scale. The alternatives should allow for economies
of scale, such as implementing technology that supports both the FD and LDA
applications.
· No Significant Changes to Existing
Laws. The alternatives should not
require significant changes to the EIGA or LDA.
The evaluation was initiated in July 1998 and commenced in
November 1998.
In this
section, the results of the Legislative Information
Systems evaluation are presented.
The summary includes: (1) a needs statement that presents the high-level
business needs for a replacement system, (2) a risk assessment associated with
the FD and LDA applications, (3) a feasibility study of viable options for
replacing the applications, and (4) a cost-benefit analysis for implementing
viable options to replace the FD and LDA applications. Lastly, recommendations for utilizing the
results of this evaluation are also presented.
The purpose of the needs statement was to identify the
high-level deficiencies in existing capabilities, new or changed program needs,
and overall high-level business needs of the two
applications as they relate to the Clerk’s mission. The needs statement also identifies
opportunities for increased economy and efficiency and provides justification
for exploring alternative solutions.
The needs statement was
developed based on the analysis of data collected from staff of the Clerk. The results of the needs statement included:
· Deficiencies. Deficiencies were identified across both applications as a
whole and each individual application.
These deficiencies can be summarized as substantial manual data entry,
general dissatisfaction with the current FileNet system (i.e., increasing costs to maintain and
enhance the current system, as well as the level of vendor support provided), lack
of automated interfaces, no automated tracking capabilities, and manual
reconciliation.
·
Program Needs.
The system should be flexible enough to allow efficient response to
changes in system needs or general duties of the Clerk, without considerable
rework of the system and associated business processes.
·
High-Level Business Needs. The system should provide for the capabilities identified in Figure
1: High-Level Business Needs. The
functionality is divided into categories, with a corresponding description of
each category.
|
Category
|
Description
|
|
|
· Ability
to minimize the amount of manual data entry during forms processing and
database compilation.
|
|
Processing
|
· Ability
to allow for the automation of processing tasks (i.e., reporting
non-responses and image destruction).
|
|
Output
|
· Ability
to provide flexible printing capabilities.
|
|
Query
|
· Ability
to provide for flexible record query and reporting capabilities for both
public and administrative use.
|
|
Storage
|
· Ability
to store images in commonly used and available media.
|
|
Technology
|
· Ability
to allow for document imaging, electronic filing and/or signature
capabilities via the Internet, as well as provide a network centric platform
(client-server) that can be maintained within the confines of the Clerk.
|
|
Application Controls and Security
|
· Ability
to authenticate users of the system, to protect data during electronic
filing, to provide restricted access to data within the system, and provide
for system availability on a timely and consistent basis.
|
|
Data Integrity Control
|
· Ability
to provide integrity and control, as noted in the risk assessment.
|
Figure 1: High-Level Business Needs
The detailed methodology
and results of this task can be found in Exhibit 2, Needs Statement.
The purpose of the risk
assessment was to identify threats to data and assets, the potential impact of
those threats, system impacts and vulnerabilities to the FD and LDA
applications, and recommend safeguards
to mitigate the potential threats.
Using an internal control and security diagnostic tool, we gained an
understanding of the current vulnerabilities and related safeguards. Information for the diagnostic tool was
gathered through observations made during walkthroughs of the systems and
facilities, and from interviews with staff of the Clerk and HIR.
The results of the risk assessment indicated that nine
high-level threats were pertinent to the FD and LDA applications where the
associated data may be vulnerable.
These threats originate from events or people internal or external to
the House. Figure 2: Summary of Risk Assessment Results on the
following page presents these nine threats, the potential impacts and
vulnerabilities, and recommended safeguards to minimize or eliminate the
threats.
The detailed methodology
and results of this task can be found in Exhibit 3, Risk Assessment.
|
Threat
|
Vulnerabilities
|
Recommended Safeguards
|
|
Acts
of nature
|
·
No
business continuity plan (BCP) within the Clerk.
|
·
Develop,
test, and implement a BCP and document image backup procedures.
·
Use
an off-site storage facility consistent with the practices of HIR, to store
and maintain tape and/or image
backups.
|
|
Acts
of terrorism
|
·
No
BCP within the Clerk.
·
Weak
physical access controls for Legislative Computer Systems (LCS) data center.
|
·
Develop,
test, and implement a BCP and document image backup procedures.
·
Use
an off-site storage facility consistent with the practices of HIR, to store
and maintain tape and/or image backups.
·
Strengthen
physical access controls (e.g., implement card key, guest sign-in and
double-door access).
|
|
Data
center environmental compromise (facilities)
|
·
No
BCP within the Clerk.
|
·
Develop,
test, and implement a BCP and document image backup procedures.
·
Use
an off-site storage facility consistent with the practices of HIR, to store
and maintain tape and/or image
backups.
|
|
Hardware
failure
|
·
No
BCP within the Clerk.
|
·
Develop,
test, and implement a BCP and document image backup procedures.
·
Use
an off-site storage facility consistent with the practices of HIR, to store
and maintain tape and/or image
backups.
|
|
Intentional
acts by House staff
|
·
Lack
of application and system software change control.
·
Lack
of integrated security administration.
·
No
quality controls present.
|
·
Grant
access to users based upon job duties.
·
Provide
for segregation of duties through workflow functionality.
·
Improve
application change control procedures using change control tools.
·
Appoint
a security officer to monitor and manage security.
|
|
Fraudulent
filings
|
·
No
validation procedures in effect.
|
·
No
improvements recommended. Inherent
safeguard is present. The filer who
has been impersonated would likely detect fraud.
|
|
Misrepresentation
of identity of public users
|
·
No
manual or automated authentication of application users.
|
·
Implement
manual or automated authentication procedures that are consistent with the
spirit of the EIGA and LDA laws.
Example includes increased staff intervention with users that reduce
the chance of misrepresentation of the identity of public users.
|
|
Human
error by staff
|
·
Lack
of application and system software change controls.
·
No
segregation of incompatible duties.
·
Application
edits and validations need improvement.
·
The
FD and LDA applications do not have strong query capabilities.
|
·
Grant
access to users based upon job duties.
·
Provide
for segregation of duties through workflow functionality.
·
Improve
application change control procedures using change control tools.
·
Reduce
redundant data entry.
·
Provide
for strong application edits and validations.
·
Implement
stronger and more precise query capabilities.
|
|
Logical/physical
penetration to data center by unauthorized public users
|
·
Lack
of integrated security administration; weak physical access security to data
center.
|
·
Appoint
a security officer to monitor and manage security.
|
Figure 2: Summary of Risk Assessment Results
The purpose of the
feasibility study was to identify viable alternatives to the existing
system. The feasibility study was
intended to provide management with adequate information to make decisions to
analyze and evaluate alternative systems to satisfy mission needs.
The results of the
feasibility study indicated that four specific alternatives would serve as
implementation scenarios for further evaluation. The rationale used to group the viable alternatives was to
provide the Clerk with a range of viable alternatives to consider,
and analysis of viable
technologies. The four alternatives
selected for further evaluation in Exhibit 4, Feasibility Study include the following:
Alternative 2: Imaging/Workflow
System and Electronic Filing with Basic Encryption. Implement a new imaging/workflow system, and add
functionality that would allow browser-based submission of FD and LDA forms via
the Internet. The system would
incorporate Secure Socket Layer (SSL) and Challenge Response
security/authentication measures. This
alternative meets the evaluation criteria.
Primary implementation issues include: (1) increased responsibility for
the Clerk to manage and maintain a new system; (2) changes to business process
as a result of the implementation of OCR/ICR and workflow technologies; and (3)
the use of electronic filing without the ability to guarantee non-repudiation.
Alternative 3: Imaging/Workflow
System and Electronic Filing with an Outsourced Public Key Infrastructure. Implement a new imaging system, with
added functionality that allows for browser based submission of LDA and FD
forms via the Internet. The system
would incorporate the use of Public Key Infrastructure (PKI)
administered by an outsourcing provider.
This alternative meets the evaluation criteria and provides additional
assurances for non-repudiation.
Primary implementation issues include: (1) limited management control
over the issuance of digital certificates; (2) changes to business processes as
a result of the implementation of OCR/ICR and workflow technologies; and (3)
the appropriateness of implementing a PKI infrastructure specifically for the
FD and LDA applications while a need for a House-wide PKI infrastructure may
exist in the future.
Alternative 4: Imaging/Workflow
System and Electronic Filing with an In-house Public Key Infrastructure. Implement a new imaging system, with
added functionality that allows for browser based submission of FD and LDA
forms via the Internet. The system would
incorporate the use of PKI administered by the Clerk. This alternative meets the evaluation criteria and provides
additional assurances for non-repudiation.
Primary implementation issues include: (1) increased responsibility for
the Clerk to manage and maintain a new system/technology; (2) changes to
business process as a result of the implementation of OCR/ICR and workflow
technologies; and (3) the appropriateness of implementing a PKI infrastructure
specifically for the FD and LDA applications while a need for a House-wide PKI
infrastructure may exist in the future.
The detailed methodology
and results of this task can be found in Exhibit 4, Feasibility Study.
The purpose of the cost-benefit analysis was to analyze the
viable system alternatives detailed in the feasibility study and examine the
costs and benefits for implementing each alternative. The cost-benefit analysis included: (1) a cost analysis of the existing system and each alternative;
(2) a cost sensitivity analysis to analyze the impact of changes in assumptions
on the cost differences of the alternatives; and (3) an analysis of qualitative
(or non-quantitative) factors.
Figure 3: Existing System and Alternative Cost Analysis on
the following page presents a summary of the non-recurring and recurring cost
estimates for the existing system and the four viable system alternatives. The figure presents five-year total cost
estimates discounted using a present value calculation to provide overall five-year
lifecycle cost estimates of the existing system and each alternative.
As described in Exhibit 4, Feasibility Study, the alternatives build upon each other in terms
of functionality and cost. For example,
the estimated costs and functionality of the Imaging/Workflow alternative are
included in all four alternatives. Additionally, the estimated costs and
functionality for electronic filing in the Imaging/Workflow with Electronic
Filing with Basic Encryption alternative are included in all remaining alternatives. The alternatives with PKI functionality
differ only in terms of the estimated costs of outsourcing the PKI function
versus maintaining the function in-house (by the Clerk).
Figure 3: Existing System and Alternative Cost Analysis
The results of the cost
analysis indicate that the estimated costs to implement each of the alternative
systems are more expensive than maintaining the existing system over the next
five year period. However, the alternatives do provide additional functionality
over the existing system and better meet the criteria defined in this
evaluation, as presented in Exhibit 4, Feasibility
Study.
The total estimated costs
for Alternative 1: Imaging/Workflow System are slightly
higher than the existing system over the five-year period, primarily because of
the non-recurring implementation costs.
The recurring costs of the Imaging/Workflow System are less than the
existing system recurring costs. For
this alternative, we estimated that benefits would be achieved through lower
recurring hardware and software maintenance costs.
The estimated costs for Alternative 2: Imaging/Workflow System with
Electronic Filing with Basic Encryption are higher than the existing
system, primarily because of the non-recurring implementation costs and the
slightly higher recurring costs. For
this alternative, we estimated that benefits would be achieved through lower
labor costs (in terms of salaries and fringe benefits) for forms processing. However, we estimated that additional labor
costs would be incurred for computer support due to the additional electronic
filing functionality.
The estimated costs for
both Alternative 3: Imaging/Workflow
System with Electronic Filing and an Outsourced PKI and Alternative 4: Imaging/Workflow System with
Electronic Filing and an In-House PKI are significantly higher than the
existing system. Both alternatives
require significant non-recurring implementation costs and the recurring costs
are higher than the existing system.
The cost estimates for the in-house PKI alternative are significantly
higher than the outsourced PKI alternative due to the additional staff
resources, and software license and maintenance costs required.
We conducted a sensitivity analysis on the estimated costs
(non-recurring and recurring) for the four viable alternatives analyzed in this
evaluation. The objective of the
sensitivity analysis was to analyze changes to assumptions to determine the
impact on the overall cost of the alternatives. We developed the following two
scenarios:
Electronic Filing
Efficiency Gains. With the introduction of electronic filing capabilities,
efficiencies may be realized with regards to the processing of the FD and LDA
submissions. These efficiencies would occur primarily because of a reduction in
hard copy form submissions. The extent
of the efficiencies would primarily depend on the number of filers that choose
to file electronically. To analyze the
potential impact of efficiencies from electronic filing on the cost of the
alternatives, we decreased the personnel salaries and fringe benefits cost
factor associated with forms processing (LRC) for the electronic filing
alternatives. The LRC salaries and
fringe benefits cost factor was reduced by a range of percentages based on the
corresponding percentage of filers who submit FD and LDA forms
electronically. For the purposes of
this analysis, we assumed a straight-line decrease in LRC forms processing
staff costs, proportional to the percentage of respondents who submit electronically. Figure 4: Cost Sensitivity Analysis - Range
of Electronic Filing Efficiency Gains below depicts the impact of the range of
electronic filing percentages on the LRC forms processing staff costs of $2,078,000
if electronic filing was not an alternative.
|
Percent of Electronic Filers
|
100%
|
75%
|
50%
|
25%
|
0%
|
|
Estimated Reduction in LRC Personnel Costs
|
50%
|
37.5%
|
25%
|
12.5%
|
0%
|
|
Total LRC Personnel Costs
|
$1,039,000
|
$1,319,530
|
$1,558,500
|
$1,818,250
|
$2,078,000
|
|
(Cost Savings) Based on Electronic Filing
|
$1,039,000
|
$758,470
|
$519,500
|
$259,750
|
$0
|
Figure 4: Cost Sensitivity Analysis - Range
of Electronic Filing Efficiency Gains
· Increased Transition Costs. We gathered costs information from
vendors based on the high-level business needs associated with the four viable
alternatives noted in this evaluation.
However, these costs may differ from actual implementation costs due to
the specific vendor chosen and the detailed requirements of the alternative. Therefore, we developed a scenario to
examine the impacts of significantly higher implementation costs on each
alternative. We increased the total
transition costs associated with the four alternatives by 50 percent to
represent a scenario in which the up-front costs to implement the alternatives
are significantly more expensive.
Figure 5: Cost Sensitivity Analysis - Transition Cost Increases details
the impact of the cost increases on the alternatives.
|
Total Non-Recurring
Cost Factor
|
Existing System
|
Alternative 1
Imaging/
Workflow System
|
Alternative 2
Imaging/
Workflow System w/ Electronic Filing with Basic Encryption
|
Alternative 3
Imaging/
Workflow System w/ Electronic Filing with Outsourced PKI
|
Alternative 4
Imaging/
Workflow System w/ Electronic Filing with
In-house PKI
|
|
Baseline Study Results*
|
$0
|
$388,000
|
$582,000
|
$725,000
|
$1,549,000
|
|
Transition Cost Increase Scenario
|
$0
|
$582,000
|
$873,000
|
$1,087,500
|
$2,323,500
|
|
Difference
|
$0
|
$194,000
|
$291,000
|
$362,000
|
$774,500
|
Figure 5: Cost
Sensitivity Analysis - Transition Cost Increases
*
From Figure 3: Existing System and
Alternative Cost Analysis
In addition to the cost analysis and sensitivity analysis,
we performed an assessment of qualitative, or non-quantifiable, factors for the
system alternatives. The qualitative
analysis was intended to provide additional evaluation criteria to analyze the
alternatives. The qualitative factors
analyzed were: (1) stakeholder needs and constraints, (2) management control, (3) security risk, (4)
commercial acceptance, (5) organizational impact, and (6) filing community
impact. The primary results of the
qualitative analysis are:
·
Stakeholder
Needs and Constraints. The
Imaging/Workflow alternative achieves all of the identified stakeholder needs
and constraints, with the exception of electronic filing. The remaining three alternatives satisfy all
user needs and constraints.
·
Management
Control. The outsourcing of PKI
would result in the Clerk relinquishing some control over the issuance of
digital certificate to respondents. However,
the in-house PKI alternative keeps management control over the issuance of
certificates within the ultimate control of the Clerk.
·
Security Risk. The use of electronic filing introduces new needs to protect the
confidentiality, integrity, availability, and authentication of the data for
filers.
·
Commercial
Acceptance. The use of electronic
filing and PKI technology has limited commercial acceptance because the
technology is still relatively immature.
·
Organizational
Impact. All of the alternatives would
require significant changes to the Clerk’s business processes with regard to
the processing of FD and LDA forms.
·
Filer Community
Impact. The use of electronic
filing would allow filers to avoid the completion of hard copy forms. However, the use of PKI would require
additional steps on the part of filers to apply and use certificates and keys.
The detailed methodology
and results of this task can be found in Exhibit 5, Cost-Benefit Analysis.
The results of this study indicate that each of the
alternatives examined in the evaluation are functionally and technically viable
and justify the Clerk initiating a project to replace the existing
systems. Because each alternative is
viable and the cost differentiation across the alternatives are minor in
comparison to improved efficiencies and services to stakeholders, a
recommendation to implement a specific alternative is not provided. However, recommended steps for utilizing the
results of the evaluation are provided.
The recommended steps are categorized as:
· Immediate. Recommended actions that should be implemented or commenced as
soon as possible, prior to initiating actions to replace the existing system.
· System Planning, Development, and
Implementation. Recommended actions
that should be taken or considered during the system planning, development, and
implementation process.
The following discussion presents the specific recommendations
for each of the above categories:
The following recommendations should be implemented
immediately.
· Implement Recommended Safeguards. As indicated in Exhibit 3, Risk Assessment, there are potential
threats to the FD and LDA applications that could be resolved with the
implementation of security safeguards.
The Clerk should examine the recommended safeguards presented in the
risk assessment to identify ones that can be implemented immediately to
mitigate potential threats to the data and related assets of the FD and LDA
applications.
· Organize a FD/LDA Project Team. The success of implementing a new system
would greatly depend on the individuals identified and dedicated to this
project. A project manager should be
assigned who would be directly responsible and accountable for the success of
the project.
·
Develop a Work
Plan. The success of managing
and executing large-scale projects greatly relies on a sound work plan. To assist the project manager in managing
and executing the migration of the mainframe applications, we suggest that a
comprehensive work plan be developed. The
work plan should serve as a master plan that allows the project manager to
monitor progress and facilitate the reporting to the Clerk and Committee on
House Administration (CHA). The work
plan should identify planning, implementation, and post-implementation tasks,
including the phases of the SDLC policy.
The time frames for the completion of the tasks should be based on the
level of effort required to complete the tasks and the available resources.
· Establish a Project Budget. In order to ensure the system solution
and implementation resources can be procured in a timely manner, the Clerk’s
Office should develop a project budget.
The cost estimates in this evaluation can be used as a basis for budget
planning for assessing the potential costs of the implementation of the system
solution. However, the Clerk should be
prepared to include additional costs once the system application and components
have been chosen subsequent to developing the detailed requirements for the
system. In addition, the Clerk may need
to factor additional costs due any requirements for contractor support in
implementing the solution in the event Clerk resources are not available to
support the project.
The following recommendations should be considered during
planning, development, and implementation of the replacement system for the FD
and LDA applications:
· Conduct a Business Process Analysis to
Determine Benefits of OCR/ICR Technologies. Although the use of OCR/ICR
technologies is feasible, the Clerk should analyze the specific uses of the
technologies, and the impact on the business processes. It is critical to determine how these
technologies would be specifically used prior to investment.
· Assess Legal Implications and Acceptability
of Electronic Filing. The legal
issues surrounding the use of electronic filing of FD and LDA submissions
involve non-repudiation and the acceptability of digital information in a court
of law. Research should be undertaken
to derive conclusions of the appropriateness of using electronic filing prior
to investment in this technology.
· Determine Use and Acceptance of Electronic
Filing by FD and LDA Filers. The
use and acceptance of electronic filing by FD and LDA filers is currently
unclear. In Canada, approximately 90
percent of lobbyists submit information electronically. However, the Canadian Government assesses
significant user fees to lobbyists who submit paper forms. Although Internet
technologies have gained wide acceptance within the U.S., it is unclear to what
extent FD and LDA filers would file using electronic methods. The Clerk should, at a minimum, survey FD
and LDA filers to gauge acceptance and usage prior to investing in electronic
filing technologies.
·
Determine
House-Wide Requirements for Public Key Infrastructure. This evaluation includes an alternative for
implementing PKI within the Clerk specifically for the FD and LDA
applications. However, the House should
consider its requirements for PKI for other uses within the House prior to
implementing this technology solely within the Clerk. The PKI model presented in this evaluation could be used
House-wide, with appropriate changes.
For example, if a House-wide PKI is implemented, the Clerk may not be
the appropriate office to manage the public and private key distribution. However, the implementation of a system
solution that utilizes electronic filing with PKI could serve as a pilot for a
House-wide assessment of the use of such technologies in other areas of the
House.
· Make Decisions Regarding Implementation of
Alternatives. Although the
alternatives presented in this evaluation could be implemented in phases, the
Clerk should make decisions regarding which alternatives to implement prior to
beginning systems development.
· Use the House’s Systems Development
Lifecycle Methodology. The Clerk
should follow the House’s SDLC policy during systems planning, development, and
implementation. This step is critical
to ensuring a successful implementation.
On March 1, 1999, the Clerk agreed that the Legislative
Systems Evaluation establishes reasonable parameters for determining
information technology solutions for the high-level business needs associated
with the FD and LDA applications (see Appendix). The Clerk agreed that the current application systems should be
replaced as recommended and stated that the Office of the Clerk would follow
the House SDLC Methodology. The
response also included comments regarding: (1) implementing the recommended
safeguards to mitigate the potential threats to FD and LDA applications, (2)
the development of a FD/LDA project team, (3) the need to review the legal
implications and acceptability of electronic filing, and (4) the need to select
the most cost-effective and practical alternative at the earliest possible
time.
Office of Inspector General Comments
The
Clerk’s commitment to follow the SDLC policies adopted by the House is
responsive to the issues discussed in this evaluation. Following the SDLC policy will minimize the
developmental risk and provide the basis for an efficient and effective
replacement for the FD and LDA applications.
Furthermore, the Clerk’s planned and completed actions, which address
the potential threats identified during the risk assessment of the current FD
and LDA operating environments will also mitigate the risks identified in this
report.
Exhibit 1
Application Overviews
Application Overviews
Table of Contents
1.1. Financial Disclosure (FD)........................................................................................... 1
1.1.1 Input................................................................................................................ 3
1.1.2 Process........................................................................................................... 3
1.1.3 Output............................................................................................................. 4
1.1.4 Technical
Information..................................................................................... 4
1.2. Lobby
Disclosure Act (LDA)...................................................................................... 6
1.2.1 Input................................................................................................................ 7
1.2.2 Process........................................................................................................... 7
1.2.3 Output............................................................................................................. 8
1.2.4 Technical
Information..................................................................................... 8
Application Overviews
This exhibit presents an
overview of the Financial Disclosure (FD) and Lobby Disclosure Act (LDA) applications. The overview provides a brief description of
the application’s background and functionality. Specifically, the overview includes:
· A
description of the legislation that the applications support.
· A
description of the applications which identify the developer, the U.S. House of
Representatives (House) office responsible for operating and maintaining the
application, and the primary users of the applications.
· A
description of the functionality of the applications which presents information
on inputs, processes, and outputs.
· A
table listing details for each application including the:
-
Application metrics.
-
Users/Customers.
-
Key inputs.
-
Key interfaces.
-
Key outputs.
In compiling the application
overviews, a two step approach was followed to collect information. The two
steps involved include:
· Interviewing
House staff to collect information on the applications.
· Reviewing
House documentation.
The Clerk manages the flow of FD submissions, using the FD
application to manage the documents and relevant filer correspondence. The application consists of two components ľ
FileNet, a commercially available software application operated and maintained
by the Clerk, and a mainframe-based application developed, operated, and maintained
by the House Information Resource (HIR) office. The FileNet software is used to scan hard-copy reports, accept
querying criteria for viewing by the general public, and display the report
images. The mainframe-based application
is used to generate queries and record dates for image indexing and
processing. The primary user of the
application is the Clerk’s Legislative Resource Center (LRC).
Figure 1.1: FD Application
Overview below presents an overview of the inputs, business processes, and outputs
associated with the FD application.
This figure depicts the flow of information from the input of data on
the left, to application processing in the center, to outputs on the far right. A brief description of the inputs,
processes, and outputs are presented following the figure.
Figure 1.1: FD Application
Overview
The inputs to the FD application
include the following:
· Financial Disclosure Form (Form A and Form
B). Form A, used for submissions by
Members of the House and House Officers,
and Form B, submitted by House staff and potential candidates for the
House, are mailed or delivered in person to the LRC by filers and subsequently
scanned into the FD application. Forms
A and B are mailed to filers upon request or are available to filers in
downloadable format on the Clerk’s website.
· Candidacy Data. The Federal Election Commission (FEC) reports to the Clerk, a
list of all candidates who have reached the $5,000 income and spending
threshold. This information is manually
keyed into the FD application from the hardcopy reports received from the
FEC. The entry of this information into
the FD application facilitates the tracking of all individuals subject to
filings under the Ethics in Government Act.
· Payroll Data. The House Office of Human Resources (OHR) reports to the Clerk, a
list of all House employees who met or exceeded the specified salary
requirements as noted by the Ethics in Government Act. This information is manually keyed into the
FD application from the hardcopy reports received from the OHR. The entry of this information into the FD
application facilitates the tracking and compliance of all individuals subject
to the Ethics in Government Act.
· Correspondence. Various letters of correspondence are received by the LRC
from filers. The correspondence is
scanned into the FD application.
· Filer Account Updates. Filer account updates (e.g., change of
address or name) are received from filers.
The updates are manually entered into FD to update master records
requested by filers.
Listed below are the processes
of the FD application.
· Scanning.
Incoming FD forms and miscellaneous filer correspondence is scanned
by the Clerk’s FileNet application.
Once the document is scanned, FileNet displays the document to the
operator for quality control inspection.
If the document is scanned properly, the document image is committed to
permanent storage.
· Indexing.
The operator who reads the information from the scanned image
manually inputs information from the FD forms into the mainframe database
index. Specific index information
entered into FileNet during the scanning phase is automatically passed to the
mainframe database.
· Compliance Processing. Compliance processing is not automated
in the FD application. The LRC’s role
in compliance processing is to determine the response/non-response status of
those required to file FD submissions.
This is done by querying the FD application database on-line to review FEC and OHR data to
determine filing compliance. All other
compliance processing with regards to the information contained in the FD
submissions is performed by the Committee on Standards of Official Conduct.
· Master Data Maintenance. Master data maintenance involves the
management of all data associated with the FD application. Data includes FD form images, form index
information and information provided from external sources (i.e., FEC and OHR).
· On-line Public Query. The general public and other application
stakeholders may query FD documents and associated information on-line in the
LRC public area. A number of
workstations with large screen monitors and printing capability are available
during LRC business hours for public on-line querying.
The outputs of the FD
application include the following:
· Committee on Standards of Official Conduct
Reports. Various ad-hoc reports are
generated for use by the Committee on Standards of Official Conduct when
reviewing FD submissions.
· Compliance Reports. Response/non-response reports are
generated using the data contained in the FD database. The reports assist LRC administrators in
their efforts in identifying those filers not meeting the requirements of the
Act.
· Audit Log Reports. Audit log reports are generated that detail
relevant FD system usage.
· Letters and other correspondence. Form letters are generated via a word
processing mail merge file. They are
subsequently mailed to those filers not in compliance.
Technical
Information
Figure 1.2: FD Application Technical Information on the
following page presents additional technical and application metric information
for the FD application.
Application Metrics
|
|
|
Element
|
Description
|
|
Technology Platform
|
IBM CMOS mainframe; FileNet
Imaging system maintained on (2)RS-6000s; and OSAR Optical Disk storage
system
|
|
Processing Mode
|
On-line transaction
processing
|
|
Number of Lines of Code
|
FileNet – 22 files
comprised of 28,688 lines Mainframe – 225 modules comprised of 22,500 lines
|
|
Data Storage
|
Mainframe – Approximately
151 MB;
OSAR – Approximately 15 GB
in use (2.3 and 7 GB disks available)
|
|
Number of records in
database
|
Approximately 53,000
|
|
Documents scanned per year
|
Approximately 3,000
|
|
Handwritten documents
received (66.5% of total)
|
9%
|
Members of Congress
|
|
23%
|
Congressional Candidates
|
|
17%
|
Principal Assistants
|
|
24%
|
House Employees
|
|
27%
|
Library of Congress
|
|
Typewritten documents
received (33.5% of total)
|
45%
|
Members of Congress
|
|
|
15%
|
Congressional Candidates
|
|
|
17%
|
Principal Assistants
|
|
|
15%
|
House Employees
|
|
|
8%
|
Library of Congress
|
Users/Customers
|
|
|
Element
|
Description
|
|
Number of Filers
|
2,990
|
|
Key application users
|
House Members, House
Employees, Candidates, Library of Congress Employees, Botanical Gardens
Employees, Government Printing Office Employees, Congressional Budget Office,
Architect of the Capitol Employees, General Public, Public Interest Groups,
Press Corp.
|
Key Inputs
|
|
|
Input
|
Source
|
|
FileNet Images
|
Financial Disclosure-Form A
and Form B.
|
|
Document index data
|
Via manual key entry from
information contained in the hardcopy document.
|
Key Interfaces
|
|
|
System
|
Description
|
|
FileNet
|
FileNet sends query
criteria to the mainframe and the mainframe application sends back the query
results.
|
Key Outputs
|
|
|
Output
|
Description
|
|
Letters
|
Letters sent to non-filers.
|
Figure 1.2: FD Application Technical Information
1.2. Lobby
Disclosure Act (LDA)
The Clerk is responsible for
managing the flow of paperwork generated by LDA registrants for the House and
enforcing registrant compliance with the Act.
The Clerk uses the LDA application to manage the Lobby Act documents and
track compliance. The application
consists of two components: FileNet, a commercially available software
application operated and maintained by the Clerk; and the mainframe-based
application developed, operated, and maintained by HIR. FileNet software is used to scan hard-copy
reports, accept querying criteria for viewing by the general public, and
display the report images. The
mainframe-based application is used to generate queries and record dates for
image indexing and processing. The
primary user of the application is the Clerk’s LRC.
Figure 1.3: Lobby Disclosure Act
Application Overview on the following page presents an overview of the inputs,
processes, and outputs associated with the LDA application. This figure depicts the flow of information
from the input of data on the left, to application processing in the center, to
outputs on the far right. A brief
description of the inputs, processes, and outputs are presented following the
figure.
Figure 1.3: Lobby Disclosure Act Application Overview
1.2.1 Input
The inputs to the LDA
application include the following:
· Lobbying Registration and Report Forms
(Form LD-1 and LD-2). Form LD-1
(for initial registration) and LD-2 (for semi-annual reporting) are sent to
filers upon request or are available to filers in downloadable format on the
Clerk’s website. Registrants send their
completed forms to the Clerk via mail on a semi-annual basis. Form LD-1 and LD-2 are subsequently scanned
into the LDA application.
· Correspondence. Various letters of correspondence are received by the LRC
from registrants. The correspondence is
scanned into the LDA application.
· Filer Account Updates. Filer account updates (e.g., change of
address or name) are received from registrants. The updates are manually entered into the LDA application to
update master records requested by registrants.
Listed below are the processes
of the Lobby Act application.
· Scanning.
Incoming LDA forms and miscellaneous registrant correspondence are
scanned into the Clerk’s FileNet application.
Once the document is scanned, FileNet displays the document to the
operator for quality control inspection.
If the document is scanned properly, the document image is committed to
permanent storage.
· Indexing.
The operator who reads the information from the scanned image
manually inputs information from the LDA forms into the mainframe database
index. Specific index information
entered into FileNet during the scanning phase is automatically passed to the
mainframe database.
· Compliance Processing. Compliance processing is not automated
in the LDA application. However, LRC
administrators use the LDA query function to evaluate registrant
information. If there are errors or
omissions such as missing figures for lobbying expenses or erroneous lobbying
topic codes, a letter is generated and mailed to the registrant.
· Master Data Maintenance. Master data maintenance involves the
management of all data associated with the LDA application. Data includes LDA form images and form index
information.
· On-line Public Query. The general public and other application
stakeholders may query LDA documents and associated information on-line in the
public area of the LRC. A number of
workstations with large screen monitors and printing capability are available
during LRC business hours for public on-line querying.
1.2.3
Output
The outputs to the LDA
application include the following:
· Compliance Reports. Various compliance reports are generated
using the data contained in the LDA database.
The reports assist LRC administrators in their efforts in identifying
those registrants not meeting the requirements of the Act.
· Audit Log Reports. Audit log reports are generated that detail
relevant LDA system usage.
· Letters and other correspondence. Form letters are generated via a word
processing mail merge file. They are
subsequently mailed to those registrants not in compliance or filers who
submitted forms with errors or omissions.
1.2.4 Technical Information
Figure 1.4: LDA Application Technical Information on the
following page presents additional technical and application metric information
for the LDA application.
Application Metrics
|
|
|
Element
|
Description
|
|
Technology Platform
|
IBM CMOS mainframe; FileNet
Imaging system maintained on (2)RS-6000s; OSAR Optical Disk storage system
|
|
Processing Mode
|
On-line transaction
processing
|
|
Number of Lines of Code
|
FileNet – 22 files
comprised of 28,688 lines of code
Mainframe – 300 modules
comprised of 65,000 lines
|
|
Data Storage
|
Mainframe – Approximately
147.5 MB;
OSAR – Approximately 82.5
GB in use (2.3 and 7 GB disks available)
|
|
Number of records in each
database
|
Registrants – 24, 655 Lobby Table – 3,924 Employees – 52,458 Directory – 5,616
|
Clients – 68,284 Reports- 451,924
Letters – 75,015
|
|
Documents scanned per year
|
Approximately 35,000 pages
|
|
Percentage of handwritten
documents received
|
12%
|
|
Percentage of typewritten
documents received
|
88%
|
Users/Customers
|
|
|
Element
|
Description
|
|
Number of Filers
|
Active Registrants – 3,727;
Active Clients – 11,616
|
|
Key application users
|
Lobbyists, LRC, General
Public, Public Interest Groups, Press Corp.
|
Key Inputs
|
|
|
Input
|
Source
|
|
FileNet Images
|
Submitted registration
documents and reports.
|
|
Document index data
|
Via manual key entry from
information contained in the hardcopy document.
|
Key Interfaces
|
|
|
Interface
|
Description
|
|
FileNet/LDA link
|
Data is scraped after
FileNet document scanning and loaded into the LDA database residing on the
mainframe.
|
Key Outputs
|
|
|
Output
|
Description
|
|
Letters
|
Letters of errors or omissions
sent to registrants.
|
|
Reports
|
List all lobbyists and
their clients.
|
Figure 1.4: LDA
Application Technical Information
Exhibit 2
Needs Statement
Needs Statement
Table of Contents
2.1. The Clerk's Mission..................................................................................................... 1
2.2. Deficiencies................................................................................................................. 1
2.3. New or Changed
Program Needs................................................................................. 4
2.4. High-Level
Business Needs......................................................................................... 4
2.5. Opportunities
for Increased Economy and Efficiency.................................................. 4
Needs Statement
This
exhibit presents the high-level business needs of the Financial Disclosure (FD)
and Lobby Disclosure Act (LDA) applications. The purpose of this needs statement is to
identify deficiencies in existing capabilities, new or changed program needs,
and overall needs of these two applications as they relate to the Office of the
Clerk’s (Clerk) mission. The
needs statement also identifies opportunities for increased economy and
efficiency and provides justification for exploring alternative solutions.
The Clerk is responsible for preserving, and
making available to the public, records of the U.S. House of Representatives
(House). The Clerk is the official
depository for various published documents originated and produced by the House
and its committees, for the historical records of the House, and for public
disclosure of documents made available under various House Rules and Public
Laws. The mission of the Clerk was used
as a framework for defining the high-level needs for the purpose of identifying
alternative system solutions to the FD and LDA applications. As presented in Exhibit 1, Application Overview, the FD and LDA
applications support the Clerk’s mission by providing public access to the
disclosures submitted by various parties, as mandated by law.
Through
discussion with the Clerk users and work performed in developing Exhibit 3, Risk Assessment, deficiencies in the
current FD and LDA applications were identified. These deficiencies were later used as a basis for defining
high-level needs used to identify alternative solutions. The deficiencies that affect both systems,
and deficiencies specific to the FD and LDA applications are listed below.
Both Systems
·
Substantial
amount of manual entry and reconciliation during forms processing. Extensive effort is expended re-keying
information that already resides in the system (i.e., annual FD database
recompilation effort).
· General dissatisfaction with the
current FileNet imaging system due to the increasing costs to maintain and
enhance the current system, as well as the level of vendor support provided.
Financial Disclosure Act (FD)
· No automated data interfaces with
external entities for the FD application.
Interfaces with external agencies (i.e., Federal Elections Commission)
would eliminate the need to manually key information currently provided in hard
copy reports and would improve data integrity.
Lobby Disclosure Act (LDA)
·
Inefficient
methods to delete, edit, and manipulate LDA data, which leads to an increase in
manual reconciliation and the risk of human error. For example, redundant tasks are performed during the current LDA
indexing process.
· LDA reminder notices are sent based
upon lobbyist and client combinations.
Therefore, if a lobbyist has 100 clients, the lobbyist receives 100 post
card sized notices.
2.3. New or
Changed Program Needs
During
discussions with the Clerk users, no foreseen new or changed program needs
associated with the LDA and FD applications were identified. However, any new system alternatives must be
flexible enough to allow efficient response to changes in system needs or
general duties of the Clerk, without considerable rework of the system and
associated business processes.
2.4. High-Level
Business Needs
This section details the high-level needs
identified by the Clerk users and administrators to support the LDA and FD
applications. Although many of the
needs are expressed in terms of the current LDA and FD applications,
consideration has been given to the future computing needs of the Clerk. The following list summarizes primary user’s
needs and the context of their importance as noted by Clerk management and
administrators:
Input
·
Ability to minimize the amount of manual data entry
during both forms processing and the annual FD database compilation.
· Ability to receive information on
individuals subject to FD reporting requirements through automated interfaces
(e.g., Federal Elections Commission, Finance Office).
Processing
·
Ability
to automate the method through which reporting compliance is determined.
· Provide for the capability to destroy
existing images within a specified time period, as required by law.
Output
·
Ability
to print reminder notices to non-filers in an efficient manner.
·
Ability
to generate letter of inquiry for LDA errors or omissions.
·
Allow
for high-speed printing from images using a user defined sort order.
· Ability to use commonly used
graphical file formats that are compatible with various printers (e.g., LRC’s
high speed printer).
Query and Reports
· Provide for flexible record query and
reporting capabilities for both public and LRC staff use.
Storage
·
Ability
to track forms from initial receipt to archive. Ability to link:
-
Individual
hardcopy or electronic submissions.
-
System
generated document and batch identification number.
-
Archive
box storage ID.
·
Ability
to back up images and indices.
· Ability to maintain images in a
non-proprietary format.
Technology
·
Provide
for a network centric platform (client/server) for FD and LDA system and
maintain hardware, software, and data within the Clerk’s office.
·
Ability
to use Internet technologies.
·
Allow
for potential public access via the Internet.
· Allow for electronic filing and
signature verification.
Application
Controls and Security
·
Provide
for system availability on a timely and consistent basis.
·
Ability
to prevent unauthorized access.
·
Ability
to restrict access to FD information before the official release to the general
public.
·
Ability
to protect data during electronic filing, processing, and storage.
· Ability to authenticate the users of
the FD application, including the identification of general public users, as
mandated by law.
After review of the current state of the FD and
LDA applications, several areas were identified that could provide
opportunities for increased economy and efficiency to the Clerk’s Office. The following have been identified as the
key areas where economy and efficiency could be achieved:
·
Improve level of
service provided from the existing imaging system.
·
Reduce labor
expense through more efficient data input and forms processing methods.
·
Improve ability to
respond to changes in FD and LDA filing requirements in a more timely manner.
Exhibit 3
Risk Assessment
Risk Assessment
Table of Contents
3.1 Methodology..................................................................................................................... 1
3.1.1 Threats............................................................................................................... 2
3.1.2 Data and Assets................................................................................................. 2
3.1.3 Vulnerability...................................................................................................... 4
3.1.4 Risk Impact........................................................................................................ 4
3.1.5 Recommended Safeguards................................................................................. 4
3.2. Risk Assessment Results.................................................................................................. 5
3.3. Risk Considerations for Alternate Solutions.................................................................. 12
3.3.1 Network Centric
Platform................................................................................ 12
3.3.2 Electronic Filing and Digital Signature............................................................ 12
Risk Assessment
This exhibit presents the risk
assessment for the Financial Disclosure (FD) and Lobby Disclosure Act (LDA)
applications. The risk assessment
identifies threats to data and assets, the potential impact of those threats,
system vulnerabilities and existing safeguards, and the current internal
control and security environment of the systems. Specifically, the risk assessment includes:
·
A description of the methodology used to perform the
risk assessment.
·
The identification of the threats to data and assets,
the vulnerabilities related to the threats, the risk impact of the threats, and
recommended safeguards to mitigate the threats.
·
A brief discussion of risk considerations for potential
alternative system solutions for the application.
The results presented in this exhibit also served as input
to Exhibit 2, Needs Statement in
identifying the current deficiencies of the FD and LDA applications and new
needs for potential replacement systems.
The purpose of the risk
assessment was to identify threats to data and assets, the potential impact of
those threats, system vulnerabilities, and existing safeguards. Using an internal control and security diagnostic
tool, we gained an understanding of the current vulnerabilities and related
safeguards. Information for the
diagnostic tool was gathered through observations made during walkthroughs of the systems and
facilities, and from interviews with the Office of the Clerk (Clerk) and the
House Information Resources (HIR) office.
Due to the scope and purpose of the risk assessment, we have not
conducted any detailed testing and validation typically completed during a
detailed internal controls and security review or audit. The diagnostic tool used was comprised of
questions covering the following areas listed below:
· Information
security policies and procedures.
· Security
administration and management.
· Business
continuity planning.
· Application
level controls.
· System
level controls.
· Network
level controls.
· Internet
security.
The data collected from the
diagnostic tool was analyzed with respect to the following risk assessment
components:
· Threats.
· Data
and assets.
· Vulnerabilities.
· Risk
impact.
· Potential
safeguards.
The following sections describe each risk assessment
component.
A threat can be defined as a
person or event that can potentially cause destruction or loss to something
valuable. For example, an unauthorized
user who attempts to access information they are not privy to is a threat. Threats may be categorized as follows:
·
Events. Events, such as natural disasters, that can
often have severe consequence on the data.
·
External
threats. People who may attempt to
access data from outside the system.
· Internal threats. People who may attempt to access data from
inside the system. These people are
authorized to access the system and may even have access to valuable data.
The following page lists the critical data and assets
related to the FD and LDA applications that were examined in the risk
assessment. Included in the listing is
a qualitative value of the data.
Data
·
FD and LDA
Forms
The FD and LDA
applications allow filed FD and LDA forms to be made available for viewing by
the general public. Physical forms
submitted to the Clerk are scanned and indexed. The FD hardcopies are maintained and destroyed after six years,
whereas the LDA hardcopies are archived first at the Cannon Building, then
moved to the National Archives for storage.
Value of data
– Both the physical forms and form images are mission critical in order to
adhere with the spirit of the FD and LDA laws.
· FD and LDA Application Indices
Both the mainframe and
FileNet components contain index data through which the FD and LDA digital
images are accessible. The index
uniquely identifies each filer’s record and contains location information that
is used by FileNet to retrieve document images. The FD application index includes Social Security Numbers for
some House employees.
Value of data – Mission
critical to locate images and archived physical documents. Social Security Numbers are extremely
valuable to individual filers.
· FD Query Activity Log
The Ethics in
Government Act requires that all individuals who access FD documents to
identify themselves prior to viewing.
The FD query activity log captures this information along with other
user activities.
Value of data – Not
mission critical, but required.
· User Account Information
ACF2
user account information, consisting of user ID and password combinations,
allows users access to the mainframe component of FD and LDA. The account information is the primary means
used to authenticate Clerk users and administrators. In addition to the mainframe accounts, there are accounts for the
FileNet system, the Windows NT network, and the AIX operating system for the
RS-6000 platform.
Value of data – Mission
critical to protect the confidentiality, integrity, availability, and
authentication of data.
Equipment
· Mainframe (located in HIR)
The indices of both the
FD and LDA digital images are located on the mainframe.
· The Enterprise Network
The current processing
environment is located in facilities in the Cannon, Rayburn, and Ford House
office buildings. The House’s
enterprise network (BUDnet) is the communications medium for the FD and LDA
system.
· Image Server (located in Legislative
Computer Systems (LCS))
After the FD and LDA
forms are scanned into the workstation, they are transmitted to the FileNet
Image Server for storage. Once digital
images are on the FileNet Server, they must be indexed before they can be
viewed via public access computers.
Subsets of the mainframe index are also duplicated on the FileNet
Server.
·
Personal
Computers, Printers, and Scanners (located in Legislative Resource Center
(LRC))
The public uses workstations to retrieve and view
FD and LDA documents. The document
scanning process also relies upon workstations to run the FileNet client.
A vulnerability is defined as a weakness that can be
exploited by a threat. For example, a
flaw or deficiency in the system design, weak administrative policies and
procedures, or weak physical security may increase the likelihood of a threat
by permitting easier access to data.
The more secure a computer system, the less vulnerable its data is to
threats, or the less likely the threats can penetrate the computer system. Therefore, the magnitude of the threats is
directly related to the vulnerabilities of the computer system. From a risk perspective, the greater the
vulnerabilities, the greater the risks.
Four fundamental areas of risk
related to data were examined in the risk assessment of the FD and LDA systems:
confidentiality, integrity, availability, and authentication. The security fundamentals, consequences of
compromises to the security fundamentals, and the related risk type of each are
identified below.
·
Confidentiality. Ensures that sensitive information is
available only for the intended audience and that sensitive information is not
disclosed to unauthorized individuals.
The consequence of compromise includes public embarrassment or legal
liability from unauthorized disclosure of sensitive and critical information.
RISK TYPE: Disclosure of confidential information.
·
Integrity. Ensures that information is modified or
changed only in a specified and authorized manner. The consequence of compromise includes loss of information or the
creation of false information if critical data is accidentally or intentionally
manipulated.
RISK TYPE: Modification of data.
·
Availability. Ensures that systems operate promptly and
service is not denied to authorized users.
The consequence of compromise includes a disruption of operations due to
inaccessible information.
RISK TYPE: Disruption of operations.
·
Authentication. Ensures that only authorized users have
access to the system. The consequence
of compromise includes unauthorized access to sensitive information.
RISK TYPE:
Impersonation of an individual’s identity.
Recommended
safeguards are actions that can be implemented to minimize or eliminate
potential security threats. The
safeguards can be categorized as technical, administrative, and physical. The technical safeguards are system related
and can be used as criteria when evaluating system alternatives. Administrative and physical safeguards are
independent of any system solution.
Therefore, the administrative and physical safeguards are ones that can be
implemented as soon as possible to minimize security risk.
Nine high-level threats were identified in the risk
assessment to which the FD and LDA applications and their data may be
vulnerable. These threats originate
from events or people internal or external to the House. Listed below is a description of the
threats.
Events
·
Acts of Nature. Includes acts of nature such as flood,
hurricane, tornado, earthquake, or lightning strike that have the potential to
physically destroy documents or the House data centers located in the Cannon,
Rayburn, or Ford buildings.
·
Acts of
terrorism. Includes various acts of
violence against the House such as a bombing attack.
·
Data center
environmental compromise. Includes
events affecting power supply, communications capabilities, or other
environmental incidents, such as water leakage, within the building.
· Software/hardware failure. Includes the failure of system components.
People
·
Intentional acts
by House staff. Includes the
threats posed by disgruntled or malicious House staff, including physical
destruction of property, compromise of document integrity (to cause
embarrassment to filer) or the insertion of malicious object code (to cause
processing disruption).
·
Fraudulent
filing. Includes the threats of
fraudulent filing by an authorized filer or someone masquerading as an
authorized filer.
·
Misrepresentation
of identity. Includes general
public users who do not accurately identify themselves while accessing imaged
forms.
·
Human error. Includes accidental acts by staff, including
erroneous data entry or improper system or security administration (causing
third party compromise of data).
·
Logical/physical
penetration. Includes system access
(physical or logical) by unauthorized public users.
Figure 3.1: Summary of Risk
Assessment Results on the following page provides a summary of the risk
assessment results. It includes a
detailed description of the threats, vulnerabilities, potential impact, and
potential safeguards to minimize or eliminate the threats.
|
Threat
|
Data and
Assets Affected
|
Vulnerabilities
|
Risk
Impact
|
Recommended
Safeguards
|
|
Acts of nature
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account
Information
Equipment:
·
LCS
·
LRC
·
HIR
|
No business continuity plan (BCP) within the
Clerk.
Observations:
·
There is no
comprehensive HIR/LCS BCP plan for the FD and LDA applications that has been
circulated to staff in LCS or LRC.
The LCS is currently drafting a BCP document. Testing of the BCP plan however, has never
been performed. Additionally, there
are no backups made of the FileNet document images.
|
Disruption -
Images and indices not
available for period of time. The
permanent destruction of the FileNet images is possible.
|
·
Develop, test, and
implement a BCP.
·
Develop, test, and
implement document image backup procedures.
·
Use an off-site
storage facility consistent with the practices of HIR, to store and maintain
tape and/or image platter backups.
|
|
Acts of terrorism
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account Info.
Equipment:
·
LCS
·
LRC
·
HIR
|
·
There is no
comprehensive HIR/LCS BCP plan for the FD and LDA applications that has been
circulated to staff in LCS or LRC.
The LCS is currently drafting a BCP document. Testing of the BCP plan however, has never
been performed.
·
Weak physical access
controls for LCS data center.
|
Disruption -
Images and indices not
available for period of time. The permanent destruction of the FileNet images
is possible.
|
·
Develop, test, and
implement a BCP.
·
Develop, test, and
implement document image backup procedures.
|
|
Figure
3.1: Summary of Risk Assessment
Results
|
Threat
|
Data and
Assets Affected
|
Vulnerabilities
|
Risk
Impact
|
Recommended
Safeguards
|
|
Acts of terrorism
(continued)
|
|
|
|
·
Use an off-site
storage facility consistent with the practices of HIR, to store and maintain
tape and/or image platter backups.
·
Strengthen physical
access controls (e.g., implement card key, guest sign-in and double-door
access).
|
|
Data center compromise-facilities
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account Info.
Equipment:
·
LCS
·
LRC
·
HIR
|
·
There is no
comprehensive HIR/LCS BCP plan for the FD and LDA applications that has been
circulated to staff in LCS or LRC.
The LCS is currently drafting a BCP document. Testing of the BCP plan however, has never
been performed.
|
Disruption -
Images and indices not
available for period of time.
|
·
Develop, test, and
implement a BCP.
·
Develop, test, and
implement document image backup procedures.
·
Use an off-site
storage facility consistent with the practices of HIR, to store and maintain
tape and/or image platter backups.
|
|
Figure
3.1: Summary of Risk Assessment
Results
|
|
Threat
|
Data and
Assets Affected
|
Vulnerabilities
|
Risk
Impact
|
Recommended
Safeguards
|
|
Software/Hardware failure
|
Data:
·
Form images
·
Index
|
No BCP within the Clerk.
Observations:
·
There is no
comprehensive HIR/LCS BCP plan for the FD and LDA applications that has been
circulated to staff in LCS or LRC. The LCS is currently drafting a BCP document. Testing of the BCP plan however, has never
been performed.
|
Disruption -
Images and indices not
available for period of time.
|
·
Develop, test, and
implement a BCP.
·
Develop, test, and
implement document image backup procedures.
·
Use an off-site
storage facility consistent with the practices of HIR, to store and maintain
tape and/or image platter backups.
|
|
Intentional acts by House
staff
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account Info.
|
Lack of application and system software change
control.
Observations:
·
FileNet application
administrators have direct access to the production environment. Changes to FileNet run-scripts or changes
to source code are not formally documented or approved.
|
Modification-
Unauthorized add, change,
or delete of list data may have adverse ramifications that affect data
integrity.
Disruption –
Staff my disable
system if the BCP plan is not effective.
|
·
Grant access to users
based upon job duties, where applicable.
·
Provide for
segregation of duties through workflow functionality.
|
Figure 3.1: Summary of Risk Assessment Results
|
Threat
|
Data and
Assets Affected
|
Vulnerabilities
|
Risk
Impact
|
Recommended
Safeguards
|
|
Intentional acts by House
staff (continued)
|
|
Lack of integrated security administration.
Observations:
·
A coordinated approach
to application access security has not been implemented. Currently, HIR and LCS have overlapping
security responsibilities. Also,
there is no security officer to monitor and manage security.
No quality controls present. Observations:
·
An individual who
scans and indexes a document may also verify its correctness.
|
Impersonation
–
Staff may impersonate
system administrator.
|
· Improve application change control procedures using
change control tools.
· Appoint a security officer to monitor and manage
security.
|
|
Fraudulent filings
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
|
No validation procedures in effect.
Observations:
|
Impersonation –
Incorrect or fraudulent
information may embarrass the Clerk or original filer.
|
·
No improvements
recommended. Inherent safeguard is present.
The filer who has been impersonated would likely detect fraud.
|
|
Misrepresentation of
identity of public users
|
Data:
·
FD Query Activity Log
|
No manual or automated authentication of application
users.
Observations:
·
There are no manual
procedures to check the identification of FD or LDA users. Neither application has the functionality
to authenticate end users.
|
Impersonation –
The identity of the user
may be fraudulent.
|
·
Implement manual or
automated authentication procedures that are consistent with the spirit of
the EIGA and LDA. Example includes
increased staff intervention with users that reduce the users ability to
falsify their identity.
|
|
Human error by staff
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account Info.
|
Lack of application and
system software change control. Observations:
·
FileNet application
administrators have direct access to the production environment. Changes to FileNet run-scripts or changes
to source code are not formally documented or approved.
No segregation of incompatible duties.
Observations:
·
An individual who
scans a document may also verify its correctness.
Application edits and validations need
improvement. Observations:
·
The FD application
requires excessive manual data entry.
·
The application edits
and validations need improvement to reduce inadvertent errors and to improve
data integrity (e.g., pull down menus, strong error detection controls).
.
The FD and LDA applications do not have strong query
capabilities. Observations:
|
Modification – Unintentional changes to data are possible.
Disruption –
Denial of service possible
by unintentional act.
|
·
Grant access to users
based upon job duties.
·
Provide for segregation
of duties through workflow functionality.
·
Improve application
change control procedures using change control tools.
·
Reduce redundant data
entry.
·
Provide for strong application edits and
validations.
·
Implement stronger and
more precise query capabilities.
|
Figure 3.1: Summary of Risk Assessment Results
|
Threat
|
Data and
Assets Affected
|
Vulnerabilities
|
Risk
Impact
|
Recommended
Safeguards
|
|
Logical/physical
penetration to data center by unauthorized public users
|
Data:
·
Form images
·
Index
·
FD Query Activity Log
·
User Account Info.
Equipment
·
LCS
·
LRC
·
HIR
|
Observations:
·
A coordinated approach
to application access security has not been implemented. Currently, HIR and LCS have overlapping
security responsibilities. Also, there is no security officer to monitor and
manage security.
·
Observed no card key
access control or locks to LCS data center.
Direct access door to hallway is alarmed but not activated (observed
staff exiting door to hallway).
·
No physical access
controls to registration and filings processing areas. These areas provide access to forms in
both physical and electronic formats.
|
Disclosure -
Viewing of document images
prior to release.
Modification -
Unauthorized add, change,
or delete of list data may have adverse ramifications that affect data
integrity.
Disruption -
Images and indices not
available for period of time.
|
·
Appoint a security
officer to monitor and manage security.
|
Using the recommended safeguards contained in Figure 3.1:
Summary of Risk Assessment Results, future needs were identified and included in Exhibit 2, Needs Statement. These future needs may have significant
impact on the internal controls and security environment of any new
system. These needs are:
· Provide for a network centric
platform for FD and LDA system and maintain hardware, software, and data within
the Clerk office.
· Ability to use Internet technologies
for document distribution, potential public disclosure, and allow electronic
filing and signature verification.
The impact
of these needs on the internal controls and security environment is described
below.
The need for
a network centric platform, which is located and operated entirely within the
Clerk office, increases the Clerk’s responsibility and accountability. HIR has physical and logical controls that
provide reasonable protection from vulnerabilities. When evaluating the system alternatives, the Clerk should
consider adopting the equivalent security standards as those implemented by
HIR.
3.3.2
Electronic Filing and Digital Signature
Implementing electronic filing and digital
signature functionality adds complexity to the management of the internal
controls and security environment.
Enabling electronic filing capabilities, with the need to verify
signature, introduces new needs to protect the confidentiality, integrity,
availability, and authentication of the data for filers. However, these security needs are addressed
through specific technologies that are discussed below.
·
Confidentiality and Integrity.
Data encryption may be used to protect data during transmission of forms
from either a Web site or e-mail source.
·
Authentication.
Electronic signature provides assurance that the file is truly from the
sender. This provides non-repudiation
(e.g., the filer cannot deny sending the file).
· Availability. Postal mail is continuously available. Electronic filing must be consistently available, particularly
during the filing time window. Denial
of service is a risk of electronic filing, and additional controls to address
this risk would be needed.
Exhibit 4
Feasibility Study
Feasibility Study
Table of Contents
4.1. Methodology.................................................................................................................. 1
4.1.1 Analyze Needs
and Define Evaluation Criteria................................................. 1
4.1.1.1 Needs-Based
Criteria............................................................................ 1
4.1.1.2 Assumptions
and Constraints................................................................. 2
4.1.2 Identify and
Assess Range of Potential Alternatives.......................................... 3
4.1.2.1 Identification
of Alternatives................................................................. 3
4.1.2.2 Analysis of
Potential Alternatives......................................................... 4
4.1.3 Select and
Develop Feasible Alternatives........................................................ 6
4.2. Overview of
Existing System....................................................................................... 6
4.2.1 Stakeholder
Analysis......................................................................................... 7
4.2.2 Technology
Description..................................................................................... 9
4.3. Alternative
Systems.................................................................................................. 10
4.3.1 Alternative
1: Imaging/Workflow System...................................................... 10
4.3.1.1 Stakeholder
Analysis........................................................................... 11
4.3.1.2 Technology
Description...................................................................... 13
4.3.1.3 High-Level
Business Needs Evaluation.............................................. 15
4.3.1.4 Implementation
Issues......................................................................... 16
4.3.2 Alternative
2: Imaging/Workflow System, with
Electronic Filing and Basic Encryption....................................................................................................... 17
4.3.2.1 Stakeholder
Analysis........................................................................... 17
4.3.2.2 Technology
Description...................................................................... 19
4.3.2.3 High-Level
Business Needs Evaluation.............................................. 22
4.3.2.4 Implementation
Issues......................................................................... 23
4.3.3 Alternative
3: Imaging/Workflow System with
Electronic Filing and an Outsourced PKI............................................................................................... 24
4.3.3.1 Stakeholder
Analysis........................................................................... 24
4.3.3.2 Technology
Description...................................................................... 27
4.3.3.3 High-Level
Business Needs Evaluation.............................................. 30
4.3.3.4 Implementation
Issues......................................................................... 31
4.3.4 Alternative
4: Imaging/Workflow System with
Electronic Filing and an In-house PKI........................................................................................................ 32
4.3.4.1 Stakeholder
Analysis........................................................................... 32
4.3.4.2 Technology
Description...................................................................... 34
4.3.4.3 High-Level
Business Needs Evaluation.............................................. 37
4.3.4.4 Implementation
Issues......................................................................... 38
Feasibility Study
This exhibit presents the feasibility study of the Financial
Disclosure (FD) and Lobby Disclosure
Act (LDA) applications is presented. The purpose of the feasibility study is to
identify and analyze alternative system approaches to meet the needs identified
in Exhibit 2, Needs Statement and
Exhibit 3, Risk Assessment. This exhibit, in conjunction with the
cost-benefit analysis document, will provide the Office of the Clerk (Clerk)
adequate information to make decisions to analyze and evaluate alternative
systems to satisfy mission needs.
The feasibility study was
developed using the following steps:
·
Analyze Needs and Define Evaluation Criteria.
· Identify
Range of Potential Alternatives.
·
Select and Develop System Alternatives.
Listed below is a description of processes followed in
completing each step.
The needs and risks of both applications were analyzed
using the findings detailed in Exhibit 2,
Needs Statement and Exhibit 3, Risk
Assessment. The needs and risks
formed the basis of the evaluation criteria that viable application
alternatives should meet in order to be considered for implementation. The evaluation criteria is composed of:
needs-based criteria, and assumptions and constraints identified in our
analysis.
The eight areas of functionality listed in Figure 4.1:
Needs-Based Criteria Summary denote the needs-based criteria that were used to
evaluate the system alternatives.
|
Criterion
Capability
|
Description
|
|
|
Ability to minimize the
amount of manual data entry during forms processing and database compilation.
|
|
Processing
|
Allow
for the automation of processing tasks (i.e., reporting non-responses and
image destruction).
|
|
Output
|
Allow
for flexible printing capabilities.
|
|
Query
|
Provide
for flexible record query and reporting capabilities for both public and
administrative use.
|
|
Storage
|
Ability to store images in
commonly used and available media.
|
|
Technology
|
Allow
document imaging and/or electronic filing with signature capabilities via the
Internet. The alternatives should
also provide a network centric platform (client-server) that can be
maintained within the confines of the Clerk’s office.
|
|
Application Controls and
Security
|
Ability
to authenticate users of the system, to protect data during electronic
filing, to provide restricted access to data within the system, and provide
for system availability on a timely and consistent basis.
|
|
Data Integrity Control
|
Ability to provide
integrity and control, as noted in the risk assessment.
|
Figure
4.1: Needs-Based Criteria Summary
(Note: Refer to Exhibit 2, Needs Statement for detailed information.)
In addition to the needs-based criteria used for evaluation,
assumptions and constraints were identified that should be considered when
evaluating the system alternatives. The
assumptions and constraints are:
· Scalability. Any potential alternative must be scalable to meet all
needs. For the purposes of this
evaluation, the FD and LDA applications were examined, but any potential system
alternative must be scalable to meet the other business needs within the
Clerk’s domain or other areas of the U.S. House of Representatives (House).
· Use of Commercial-off-the-Shelf
Applications. The House’s Information Systems Program Plan, Management
Policy for Systems Development Life Cycle (SDLC), dated June 28, 1996,
states the desire to move towards Commercial-Off-The-Shelf (COTS)
applications. For this analysis, COTS
applications include solutions that may require significant customization to
the needs of the House using commercially available software and development
tools.
· Implementation Time Frame. Plans are currently underway to allow for a migration of all
mission critical applications from the House’s mainframe operated by the House
Information Resources’ (HIR) by the third quarter of Calendar Year (CY)
1999. Any potential alternative to
replace the current FD and LDA applications should consider that migration plan
when planning for the procurement or the implementation process.
· Economies of Scale. The alternatives should allow for economies
of scale, such as implementing technology that supports both the FD and LDA
applications.
· No Significant Changes to Existing
Laws. The alternatives should not
require significant changes to the Ethics in Government Act or LDA.
To determine the various system alternatives for
replacing the current FD and LDA applications, numerous sources were contacted
to aid in the selection and evaluation.
The approach used to research, identify, and analyze potential system
alternatives is also included.
Our approach to researching alternatives included:
·
Interviewed
Subject Matter Experts. Several
subject matter experts familiar with imaging systems and electronic filing
technologies were interviewed. Areas of
emphasis included imaging system technologies (e.g., Optical Character
Recognition (OCR), Intelligent Character Recognition (ICR), workflow) and
relevant cryptographic technologies (i.e., digital signature, Secure Socket
Layer (SSL), Public Key Infrastructure (PKI), electronic filing functionality).
·
Reviewed
Technology Literature. A variety of
sources were used to research potential COTS software, such as industry trade
journals, the Internet, and vendor and product databases. Faulkner, Gartner Group, and Forrester
proprietary information databases were used for information pertinent to
imaging and electronic filing technologies, and various Internet searches were
also performed to gather vendor information.
·
Interviewed
Stakeholders and Other Government/Legislative Bodies. Stakeholder opinions and preferences were gathered through
interviews with key stakeholders of the FD and LDA applications. Key stakeholders (i.e., Legislative Computer
Services (LCS), Legislative Resource Center (LRC)) were interviewed for
technology and functionality preferences, limitations of current technical
environment, and information pertaining to the current FileNet imaging
system. Interviews with other
government/legislative bodies (i.e., U.S. Senate, Canadian Lobby Registration
Branch) were performed to gather information about electronic filing methods
and efficiencies associated with the implementation of similar systems.
·
Contacted
Vendors to Identify Feasible Technologies.
Interviews with potential vendors that develop and distribute
software and technologies that could potentially address the high-level
business needs of the FD and LDA applications were performed. Information collected included data
associated with product performance and functionality metrics. The identity of the House or Clerk was not
disclosed, nor were vendors provided with Clerk-specific information. This was done to preserve vendor
independence for any potential procurement in the future.
Using the criteria, assumptions, and constraints
identified, an analysis of the system alternatives for replacing the current FD
and LDA applications was performed. The
selection of system alternatives included the identification of potential
alternatives for the FD and LDA applications and the assessment of the
feasibility of the alternatives. As a
result of the feasibility assessment, some alternatives were found to be not
viable because their functionality is inconsistent with the identified FD and
LDA needs and constraints.
Figure 4.2: Summary Assessment of Potential Alternatives
presents a description of the system alternatives that were identified and the
assessment of the viability of each alternative highlighting the primary ways
the alternative meets or does not meet the criteria.
|
Alternative
|
Description
|
|
|
Retain Existing
FileNet/Mainframe Applications
|
Keep the applications on
the current HIR mainframe and RS-6000 platform.
|
Not Viable primarily
because the alternative does not meet the needs criteria as noted in Figure
4.1 Needs-Based Criteria Summary in the following areas: (1) does not utilize client-server COTS
technology, (2) is functionally not scalable, and (3) does not maintain hardware, software, and
data within the Clerk’s office.
|
|
Re-Platform Mainframe
Index Applications to
RS-6000 OS/390
|
The FD and LDA mainframe
index applications could be re-platformed to an RS/6000 environment within
the confines of the Clerk.
|
Not Viable primarily
because the alternative does not meet the needs criteria in Figure 4.1
Needs-Based Criteria Summary in the following areas: (1) does not utilize client-server COTS
technology, (2) is not functionally scalable. Also, the Clerk does not intend to build the skill base to
operate a mainframe operating system.
|
Figure
4.2: Summary Assessment of Potential Alternatives
Alternative
|
Description
|
|
|
Replace
mainframe index application with client-server application
|
Replace the
current mainframe index application with a new client-server index
application that would reside within the confines of the Clerk’s office.
|
Not Viable primarily because the alternative does not meet the
needs criteria in Figure 4.1 Needs-Based Criteria Summary in the following areas: (1) does not utilize client-server COTS
technology and (2) is functionally not scalable.
|
|
Client-Server
imaging/workflow system, with advanced
forms processing functionality
|
Implementation
of a new client-server, COTS imaging system with advanced functionality that
provides improved controls and processing techniques. This system would reside within the
confines of the Clerk’s office.
|
Viable because it partially meets the high-level business
needs and utilizes client-server technology.
Although this alternative does not have electronic filing
capabilities, the system could be developed to allow for future use of
electronic filing and therefore is considered viable because it could be
implemented to be scalable to incorporate electronic filing.
|
|
Electronic filing functionality with basic encryption techniques
|
Electronically
file FD and LDA forms through a browser-based Internet application with SSL
encryption techniques and challenge/response functionality.
|
Viable because the alternative:
(1) meets
the high-level business needs, (2)
utilizes client-server COTS technology, and (3) is functionally scalable.
|
|
Electronic filing functionality with an outsourced PKI
|
Electronically
file FD and LDA forms through a browser-based Internet application using an
external vendor to administer a PKI environment to provide enhanced
encryption and digital signature measures.
|
Viable because the alternative:
(1) meets the high-level business
needs, (2) utilizes client-server
COTS technology, and (3) is functionally scalable.
|
|
Electronic filing functionality with an
in-house PKI implementation
|
Electronically
file FD and LDA forms through a browser-based Internet application and the
implementation of PKI to provide enhanced encryption and digital signature
measures.
|
Viable because the alternative:
(1) meets
the high-level business needs, (2)
utilizes client-server COTS technology, and (3) is functionally scalable.
|
|
Outsource
all aspects of FD and LDA applications
|
Outsource
the FD and LDA applications to a vendor outside of the Clerk’s domain.
|
Not Viable because the alternative does not meet the needs
criteria as noted in Figure 4.1 Needs-Based Criteria Summary associated with maintaining hardware, software, and data within the
Clerk’s office. The Ethics in
Government Act and the Lobby Disclosure Act mandates that the Clerk process
FD and LDA submissions.
|
· Imaging/Workflow System represents the
implementation of a new, client-server based imaging system that includes
advanced forms processing functionality (i.e., OCR/ICR, workflow technologies).
· Imaging/Workflow System and Electronic
Filing with Basic Encryption represents the implementation of a new imaging
system, and adds functionality that would allow browser-based submission of FD
and LDA forms via the Internet. The
alternative includes the use of SSL and challenge/response authentication
measures.
· Imaging/Workflow System and Electronic
Filing with an Outsourced Public Key Infrastructure represents the
implementation of a new imaging system, and adds functionality that allows for
browser-based submission of FD and LDA forms via the Internet. The alternative
includes the use of PKI encryption technology administered by an external
service provider.
· Imaging/Workflow System and Electronic
Filing with an In-house Public Key Infrastructure represents the
implementation of a new imaging system, and adds functionality that allows for
browser-based submission of FD and LDA forms via the Internet. The alternative
includes the use of PKI encryption technology administered in-house by the
Clerk.
In this exhibit, high-level implementation scenarios were
developed for the alternatives identified above to represent the potential
changes to the Clerk’s organization and technology infrastructure.
In this section, an overview of the existing system for the
FD and LDA applications used by the Clerk is provided. An overview of the primary stakeholders and
a description of the technology infrastructure is also included. As discussed in Figure 4.2: Summary
Assessment of Potential Alternatives, the existing system was not considered a
viable alternative because it does not meet the identified needs of the Clerk.
4.2.1 Stakeholder Analysis
Figure 4.3: Overview of Stakeholders for Existing System
presents an overview of the stakeholders of the FD and LDA applications. In the following discussion, each of the
stakeholders and their primary relationship to the FD and LDA applications is
described.
Figure
4.3: Overview of Stakeholders for Existing System
Filing
Community
·
Financial
Disclosure Filers: Members,
Officers, certain employees, and candidates of the House manually submit FD
Statements. The FD Statements are
submitted on an annual basis. To date
there are approximately 5,500 filers.
Filers may download FD forms from the House Internet web site or may
call the LRC directly to obtain the forms by mail. For the most recent processing year, the LRC received
approximately 3,000 documents from the entire FD filing community.
·
Lobby Act Filers: Individual lobbyists and lobbying firms
manually register and file reports of their lobbying activities. The lobbying activity reports are manually
submitted semi-annually no later than 45 days after the end of the first day of
January and the first day of July.
Filers call the LRC to request the LD-1 Form if they are new registrants
or the LD-2 form if they are submitting their semi-annual report. These forms are also
conveniently available on the Clerk’s Internet web
site in a downloadable format. There
are currently a total of 3,727 active registrants who submit a total of 35,000
document pages per year.
Legislative Resource Center
Federal Election
Commission and Office of Human Resources
The Federal Election Commission (FEC) and the House’s Office
of Human Resources (OHR) submit information to the Clerk periodically, which is
used by the LRC in processing the FD submissions. Information from the FEC and House OHR is provided in hard-copy
report format, and the LRC uses this information to determine the expected
filing community for the FD submissions.
Committee
on Standards of Official Conduct
After scanning the FD submissions into the FileNet system,
the LRC forwards all FD forms to the Committee on Standards of Official Conduct
for review. The LRC also forwards
various adhoc reports (i.e., non-respondent reports) regarding FD submissions
to the Committee.
Figure 4.4: Overview of Existing System Technology
Infrastructure presents an overview of the technology infrastructure associated
with the existing system. The following
discussion provides a high-level overview of the information technology
components of the existing FD and LDA system.
Figure 4.4: Overview of Existing System Technology
Infrastructure
The primary components of the existing systems technology
infrastructure are:
· Application File Server. The FileNet application resides on two
RS/6000 file servers using a UNIX operating system. The application is located in the LCS data center in the Rayburn
Building. Print servers using OS/2 are
housed in the LRC document process area.
· Optical Image Storage. Documents scanned and processed by
FileNet are stored directly to a Write-One-Read-Many (WORM) optical
platter. Images are stored in a
standard TIFF format and may not be altered once they are written to disk. Currently, there is no mechanism for backing
up the optical images.
· Workstations. There are two categories of workstations related to the FD
and LDA applications. Workstations used
by staff in the LCS for document scanning, indexing and routine data entry are
appropriately equipped to handle the FileNet and mainframe terminal emulation
clients. In addition, workstations are
located in the public area of the LCS and are freely accessible for on-line
document query.
· Mainframe Images Index. The FD and LDA indexes are maintained on
an IBM Multiprise CMOS mainframe. LRC
staff who process FD and LDA documents access the images index on the mainframe
through a 3270 emulation client installed on their workstations. The mainframe is managed by HIR and is
located in the Ford Building.
In this section, the
viable alternatives to the existing system are presented, as noted in Figure
4.2: Summary Assessment of Potential
Alternatives. The discussion of each
alternative presents the following information:
·
Stakeholder Analysis shows how the alternative would affect the
primary FD and LDA stakeholders.
·
Technology Description presents a high-level overview of the technology
components, and relevant vendors, associated with the alternative.
·
High-Level Business Needs Evaluation presents a summary of the evaluation of the
alternative’s ability to meet the high-level business needs as identified in
Section D.1.1.1.
· Implementation
Issues details any issues that
need to be considered when evaluating the alternative.
In this section, the stakeholder analysis, technology
description, high-level business needs evaluation, and implementation issues of
the Imaging/Workflow System alternative are presented. The functionality of the Imaging/Workflow
System alternative includes:
· Imaging Application that provides the
functionality to maintain hard-copy submissions of FD and LDA forms in an
optical format. The images maintained
by the application are available for public view in the LCS.
· Workflow Capabilities that provide
functionality for managing the processing of FD and LDA submissions in an
automated fashion.
· Optical Character Recognition/Intelligent
Character Recognition that provides the functionality to greatly reduce
manual data entry of indexing information by providing the ability to optically
recognize FD and LDA submission data as a form is being scanned into the
imaging application.
Figure 4.5:
Alternative 1: Stakeholder Overview presents an overview of the
stakeholders of the FD and LDA applications.
In the discussion, each of the stakeholders and their primary
relationship to the FD and LDA applications is described.
Figure 4.5: Alternative 1: Stakeholder
Overview
Filing Community
For this alternative, the filing community for the FD and
LDA applications is largely unaffected in the manner in which they interact
with the Clerk. Under this scenario,
hard-copy forms continue to be submitted by mail and in-person and are
subsequently processed by the LRC.
Legislative Computer
Systems
The migration of the FD and LDA indexes off of the HIR
mainframe shifts the custody and management of all remaining hardware and
software components to the LCS. Under
this scenario, the LCS would need to assume greater responsibilities in the
areas of security and data center management. The LCS would also be required to
support the new imaging/workflow application and coordinate application
maintenance with the chosen software vendor.
Legislative Resource
Center
Under this alternative, the relationship the LRC has with
other stakeholders would remain essentially the same. However, it is likely the LRC would experience changes to their
business processes as a result of using a new imaging application with workflow
and OCR/ICR capabilities. These changes
to business processes would likely result in efficiencies in the processing
function of the FD and LDA applications.
House Information
Resources
All information systems processing and custody
responsibilities for the index databases currently under the management of HIR
would be eliminated.
The general public is unaffected by this alternative in that
they would continue to obtain FD and LDA information in person at the LRC or in
printed format from GPO.
Federal Election
Commission and Office of Human Resources
This alternative would require cooperation from the FEC and
the House’s OHR in the development of an automated interface with the FD
application to replace the existing manual interfaces. Automated interfaces would help improve the
data integrity and the accuracy of incoming candidate and payroll
information. Currently, the LRC staff
receives hard-copy reports from the FEC and OHR that denote the expected filing
community for the FD submissions. This
automated interface would alleviate the need for manual data entry by providing
a technical mechanism where the data from the FEC or OHR could be uploaded to
the FD database with little or no manual intervention.
Committee
on Standards of Official Conduct
After scanning the FD submissions into the new system, the
LRC would continue to forward all FD forms to the Committee on Standards of
Official Conduct for review. The LRC
would also continue to forward various adhoc reports (i.e., non-respondent
reports) regarding FD submissions to the Committee.
Figure 4.6: Alternative 1: Technology Overview presents an
overview of the technology infrastructure associated with this
alternative. The discussion following
provides a high-level overview of the information technology components.
Figure 4.6:
Alternative 1: Technology Overview
The primary components of this alternative’s technology
infrastructure are:
· Imaging/Workflow Application. The imaging application is the engine that
drives the scanning, indexing and report writing process. It executes the core functions of any
document management system in an integrated manner. Most significant of the possible improvements to the core
document imaging functionality is the workflow management and OCR/ICR
features. Workflow functions manage the
flow of documents among administrators to ensure both accountability and
quality assurance in the processing of information. Ideally, the application and the associated database engine
should reside on separate servers for performance considerations. Modules added to the core application could
provide a standardized (open) interface to minimize the amount of customized
Application Program Interface (API) development necessary.
· Storage Media and Backup. Given the age and reliability of the Clerk’s
existing WORM drive, an upgrade to newer WORM technology should occur. A typical WORM 5.25-inch optical disk
holds up to 4.6G bytes of information, the equivalent of about one million
pages or over 1800 standard 3.5-inch
diskettes. The use of a digital-linear
tape system used for backing up images from the WORM storage system should also
be considered, at a minimum.
· Scanning and Printing Peripherals. To plan for future processing workloads, it
may be necessary to upgrade the scanner and printing peripherals. The Clerk has made progress in this area by
procuring high speed Xerox Docutech printers capable of on-demand
printing. This should reduce the
Clerk’s reliance on the GPO for specific publicly disseminated reports.
· Federal Election Commission and Office of
Human Resources Interfaces. The
automation of data that has been previously entered by hand is critical to
improving data integrity and accuracy.
Telecommunication links could be established with the FEC and the OHR to
allow for the timely upload of candidate and payroll data into the FD
application. Although a high-speed
telecommunication link is preferable, loading the information via tape could
also be a viable alternative.
This alternative eliminates the need for the mainframe
platform by shifting the image index database to a client-server
architecture. The client-server model
allows for specialized servers to distribute processing workloads. For example, separate file servers could
handle such tasks as image processing, indexing, and printing. To maintain the functionality now processed on
the mainframe component of the FD and LDA applications, it is likely that significant
application customization to a COTS product would be needed to tailor the
functionality to the specific needs of the FD and LDA system.
This alternative was evaluated based on its ability to meet
the high-level business needs as presented in Section 1.1.1 Needs Based
Criteria. Figure 4.7: Alternative 1: Evaluation of High-Level
Business Needs presents a summary of the evaluation of the high-level business needs.
|
Criteria
|
Criteria
Rating
|
Assessment
|
|
Input Capabilities
|
Fully
|
·
This alternative
reduces the inefficiencies and errors associated with data input. Automated interfaces for files received
from the FEC and the OHR would eliminate the need for manual keying of hard
copy reports.
·
OCR/ICR functionality
speeds the input and creation of document index information.
|
|
Processing Capabilities
|
Partially
|
·
Workflow functionality
would improve quality assurance by proving the mechanism to administer
controls associated with the FD and LDA processing cycle.
·
The core imaging
system would incorporate logic to automate filer compliance.
|
|
Output Capabilities
|
Fully
|
·
Standard report
writing would be a component of the core imaging system.
·
The Xerox Docutech
printer would be supported and allow for on-demand printing.
|
|
Query Capabilities
|
Fully
|
·
Core system would
include flexible, easy to use record query capabilities.
|
|
Storage Capabilities
|
Fully
|
·
Image storage would be
in a non-proprietary format.
|
|
Technology Capabilities
|
Partially
|
·
The alternative does
not include web-based file submission.
·
The alternative does
not provide for potential public disclosure via the Internet.
·
Platform is
network-centric in keeping with the House’s desire to migrate from HIR’s
mainframe.
|
|
Application Controls and
Security Capabilities
|
Partially
|
·
The alternative does
not provide web-based file submission, and thus the ability to protect data
during electronic filing is not available.
·
Issues of
authentication, confidentiality and data integrity are addressed in the core
system functionality.
|
|
Data Integrity Control
Capabilities
|
Fully
|
·
Data integrity
controls are improved through the use of workflow functionality and automated
interfaces.
·
Field edits and error
checking logic would be enhanced for all alternatives under consideration.
|
|
Key: Partially-Partially
meets criteria Fully-Fully meets criteria
|
Figure
4.7: Alternative 1: Evaluation of High-Level Business Needs
The following implementation issues should be considered for
this alternative:
· Increased Information System Management
Responsibility. As a consequence of
shifting portions of the FD and LDA process from HIR, the LCS would need to
increase the scale of their security operations and data center
management. Access to the imaging and
database servers would need to be controlled both physically and
logically. Additionally, administration
workload would increase with the demands of supporting a larger production
environment.
· Impact of Workflow and OCR/ICR technology
on LRC Business Processes. Careful
consideration would need to be given to the reengineering of the LRC’s
processes to accommodate workflow and OCR/ICR features of the new system.
· Coordination Needed for Interface
Development. To develop automated
interfaces with FEC and OHR systems, coordination with these organizations
would be needed.
In this section, the stakeholder analysis, technology
description, high-level business needs evaluation, and implementation issues of
the Imaging/Workflow System, with Electronic Filing and Basic Encryption
alternative are presented. The
functionality of the Imaging/Workflow System with Electronic Filing and Basic
Encryption alternative includes:
· Imaging/Workflow System that was
described in the Imaging/Workflow alternative presented in Section 4.3.1,
Alternative 1: Imaging/Workflow System.
· Electronic Filing with Basic Encryption
that provides the functionality for electronic filing using basic encryption
techniques and challenge/response security mechanisms. Electronic filing provides the FD and LDA
user community the ability to file via the Internet using a user ID and
password.
Figure 4.8: Alternative 2: Stakeholder Overview presents an
overview of the primary stakeholders of the FD and LDA applications and their
relationships. In the following discussion, each of the stakeholders and
their primary relationship to the FD and LDA applications under this alternative
are described.
Figure 4.8:
Alternative 2: Stakeholder Overview
Legislative Computer
Service
LCS would be responsible for managing and maintaining all of
the technology components associated with the data center and Clerk information
system components. Specifically, the
LCS would now maintain the Internet technology components associated with the
electronic filing functionality.
Legislative Resource Center
The advent
of electronic filing functionality would not preclude filers from submitting FD
and LDA forms in hard copy format. The
LRC would now be responsible for processing both hard copy and electronic
submissions of FD and LDA information.
FD and LDA data received via the Internet would be routed to the LRC for
processing. The LRC processing staff
would use the character-based data instead of the image of the hardcopy form to
perform various edit checks and indexing processes. This change would presumably lead to processing efficiencies, but
the extent of these efficiencies is unclear. The potential efficiencies that could be
achieved with electronic filing are presented in Exhibit 5, Cost-Benefit Analysis, Section 5.3 Cost Sensitivity Analysis. The LRC would continue to ensure legislative
compliance and administer policies associated with the FD and LDA laws.
FD and LDA Filing
Community
Filers of the FD and LDA forms would now have the ability to
submit FD and LDA forms electronically via the Internet. The filer could connect to the Clerk’s web
site through a local Internet service provider and standard web browser or
through the House intranet (for Members and House employees only) to submit
their FD and LDA information for processing.
General Public
The
general public would still have access to all FD and LDA information submitted
to the Clerk through the LRC. Hardcopy
filings would be viewed as an image of the actual form (with signature) and
electronic submissions would be viewed as the submitted data superimposed on an
image of a blank form.
Federal Election
Commission and Office of Human Resources
This alternative would require cooperation from the FEC and
the House’s OHR in the development of automated interfaces with the FD
application to replace the existing manual interface. Automated interfaces would help improve the data integrity and
the accuracy of incoming candidate and payroll information.
Committee
on Standards of Official Conduct
After receiving the FD submissions, the LRC would continue
to forward all FD forms to the Committee on Standards of Official Conduct for
review. The LRC would also continue to
forward various adhoc reports (i.e., non-respondent reports) regarding FD
submissions to the Committee.
Figure 4.9: Alternative 2: Technology Description presents
an overview of the technology infrastructure associated with this
alternative. The following discussion
provides a high-level overview of the information technology components.
Figure 4.9: Alternative 2: Technology
Description
This alternative includes the technology components
indicated in the previous alternative described in Section 3.1, Alternative 1:
Imaging/Workflow System. Those
technology components are summarized as followed:
· Imaging/Workflow Application. The imaging application is the engine that
drives the scanning, indexing and report writing process. Most significant of the possible
improvements to the core document imaging functionality is the workflow
management and OCR/ICR features.
Workflow functions manage the flow of documents among administrators to
ensure both accountability and quality assurance in the processing of
information.
· Storage Media and Backup. Given the age and unreliable state of the
existing WORM drive, upgrading to newer WORM technology and implementing a
digital-linear tape backup system should be considered, at a minimum.
· Scanning and Printing Peripherals. To plan for future processing loads, it may
be necessary to upgrade the scanner and printing peripherals. The Clerk has made progress in this area by
procuring high speed Xerox Docutech printers capable of on-demand
printing. This should reduce the
Clerk’s reliance on the GPO for specific publicly disseminated reports.
· Federal Election Commission and Office of
Human Resources Interfaces. The
automation of data that has been previously entered by hand is critical to
improving data integrity and accuracy.
Telecommunication links could be established with the FEC and the OHR to
allow for the timely upload of candidate and payroll data into the FD
application. Although a high-speed
telecommunication link is preferable, loading the information via tape could
also be a viable alternative.
Electronic Filing
Components
Providing
an environment for electronic filing requires that various technology
components be employed. The use of
secure Internet web servers for this purpose is a widely used and accepted
practice. A web-based forms application
that uses SSL encryption and challenge/response (user ID and password) measures
to provide basic levels of confidentiality, data integrity, and authentication
is also a widely used method for capturing information via the Internet. Although there are many benefits that can be
achieved by allowing electronic submission of the FD and LDA forms, electronic
submission of information introduces many vulnerabilities and security risks
such as public viewing of FD or LDA information before the LRC staff processing
cycle is completed.
Technology
components that address this security are:
· Web-based Forms Application. A web-based forms application would be
developed that would allow filers to dynamically fill out their FD and LDA
forms. The web pages would resemble the
actual paper forms, and would capture all the information normally submitted on
the hardcopy documents. These web-based
forms could employ inherent intelligence that performs routine edit checks
while the respondent inputs data. If
the respondent somehow fills out a cell with incorrect information (i.e.,
enters a wrong date or invalid state code) the web application could be enabled
to reject the submission and guide the respondent to a correct/acceptable
response. After submitting the forms,
the data could be automatically indexed and stored based on the information
provided by the respondent.
· Web Server Hardware/Software (SSL). The web-based forms application detailed
above would physically reside on a Internet web server within the confines of
the LCS. This web server would have the
capability to support encrypted connections initiated by the web clients (i.e.,
FD and LDA submission population) and through use of a SSL connection. SSL functions in a paired environment, where
a secure client (e.g., FD or LDA submitter) connects with a secure server. SSL uses public encryption technology that
would render the FD and LDA submissions routable but unreadable by intermediate
hosts. The SSL technology authenticates
servers, preventing an intermediate interception of data on the network from
others posing as the destination server (in this case, the House). This method of encryption protects Internet
communications and ensures data integrity associated with electronic
submissions. SSL is used by developers
to add security within TCP/IP applications and has become a de facto standard
for encryption between browsers and servers.
· Challenge/Response Mechanism. Access to the FD and LDA web-based
applications would be granted through a password and account ID mechanism. This challenge/response mechanism would
authenticate users who choose to submit FD and LDA forms via the Internet. Included with this alternative is the
necessity to issue user IDs/passwords to filers in some way, prior to being
granted access to the system (i.e., mail, email, in person). SSL combined with account ID and passwords
would provide the basic levels of confidentiality, integrity, and
authentication needed to support FD and LDA electronic submission.
· Proxy Server and Firewall. A proxy server and firewall are required
to protect the web server and web-based forms application from unauthorized
uses such as those wishing to infiltrate and disrupt the system.
This alternative was evaluated based on the evaluation
criteria derived from the high-level business needs, constraints, and
assumptions. Figure 4.10: Alternative
2: Evaluation of High-Level Business Needs presents a summary assessment of the
how this alternative satisfies the business needs.
Criteria
|
|
Assessment
|
|
Input Capabilities
|
Fully
|
·
This alternative
reduces the inefficiencies and errors associated with data input. Automated interfaces for files received
from the FEC and OHR would eliminate the need for manual keying of hard copy
reports.
·
OCR/ICR functionality
speeds the input of document index information.
|
|
Processing Capabilities
|
Fully
|
·
Workflow functionality
would improve quality assurance by providing the mechanism to administer
controls associated with the FD and LDA processing cycle.
·
The core imaging
system would incorporate logic to automate filer compliance.
|
|
Output Capabilities
|
Fully
|
·
Standard report
writing would be a component of the core imaging system.
·
The Xerox Docutech
printer would be supported and allow for on-demand printing.
|
|
Query Capabilities
|
Fully
|
·
Core system would
include flexible, easy to use record query capabilities.
|
|
Storage Capabilities
|
Fully
|
·
Image storage would be
in a non-proprietary format.
|
|
Technology Capabilities
|
Partially
|
·
This alternative does
provide functionality that allows for electronic filing of FD and LDA
submissions, but does not provide the non-repudiation of submissions.
|
|
Application Controls and
Security Capabilities
|
Partially
|
·
This alternative does
provide basic protection of data during electronic submission by use of SSL
encryption, but does not provide for non-repudiation.
|
|
Data Integrity Control
Capabilities
|
Fully
|
·
Data integrity
controls are improved through the use of workflow functionality and automated
interfaces.
·
Field edits and error
checking logic would be enhanced for all alternatives under consideration.
|
|
Key: Partially-Partially
meets criteria Fully-Fully
meets criteria
|
There are a number of implementation issues that need to be
considered when evaluating whether to use electronic filing of FD and LDA submissions
with the use of basic encryption and challenge/response security
techniques. The primary implementation
issues are:
· Non-Repudiation. The legal issues surrounding the use of
electronic filing of FD and LDA submissions involve non-repudiation and the
acceptability of digital information in a court of law. Research should be undertaken to derive
conclusions of the appropriateness of using electronic filing prior to
investment in this technology.
· Acceptance of Electronic Filing by the User
Community. The use and acceptance
of electronic filing by FD and LDA filers is currently unclear. In Canada, approximately 95 percent of lobbyists submit
information electronically. However,
the Canadian Government assesses significant user fees to lobbyists who submit
paper forms. Although Internet
technologies have gained wide acceptance within the U.S., it is unclear to what
extent FD and LDA filers would file using electronic methods. The Clerk should, at a minimum, survey FD
and LDA filers to gauge acceptance and usage prior to investing in electronic
filing technologies.
In this section, the stakeholder analysis, technology
description, high-level business needs evaluation, and implementation issues of
the Imaging/Workflow System, with Electronic Filing and an outsourced PKI
alternative are presented. The
functionality of the Imaging/Workflow System with Electronic Filing and an
Outsourced PKI system alternative includes:
· Imaging/Workflow System that was
described in the Imaging/Workflow alternative presented in Section 4.3.1,
Alternative 1: Imaging/Workflow System.
· Electronic Filing that provides the
functionality for electronic filing.
Electronic filing provides the FD and LDA user community the ability to
file via the Internet using a user ID and password that was described in the
alternative described in Section 4.3.2, Alternative 2: Imaging/Workflow System
with Electronic Filing with Basic Encryption.
· Public Key Infrastructure that provides
the functionality for electronic filing with the use of a PKI. The implementation of PKI could provide
increased levels of confidentiality, integrity, and authentication of
electronic submissions of FD and LDA forms and could address the
non-repudiation evaluation criterion.
For this alternative, the PKI system would be administered by a PKI
outsourcing agent.
Figure 4.11: Alternative
3: Stakeholder Overview presents an overview of the primary stakeholders of the
FD and LDA applications and their relationships. In the following discussion, each of the stakeholders and their
primary relationship to the FD and LDA applications under this alternative are
described.
Figure 4.11: Alternative 3: Stakeholder
Overview
PKI
Outsourcing Vendor
The PKI outsourcing vendor would serve as
the management (i.e., storing, revoking, updating) of the electronic signatures
that filers would use to authenticate submissions of the FD and LDA forms. The outsourcing agent would also be
responsible for the distribution of these electronic signatures. The electronic submission would be done
through the use of a House branded web site maintained and operated by the
outsourcing agent.
Filing
Community
To sustain the
integrity of the PKI environment, the FD and LDA filing community would face
additional scrutiny with regards to proof of identification. Verifying the identity of users of a PKI is
paramount to the security that the PKI provides. Filers would need to provide proof of identification before they
would be allowed to submit electronically.
Filers could provide proof of identity and sign an agreement for
authorized use in person at the LRC.
Another method could involve submitting a request through the mail by
providing a notarized letter using official letterhead.
Legislative Computer Services
The implementation of a PKI would require the LCS to develop
an understanding and a competency of a number of additional technical
areas. In addition to the basic
Internet components associated with electronic filing detailed in Section
4.3.2, Imaging/Workflow System with Electronic Filing with Basic Encryption, the LCS would need to have an interface
with the PKI outsourcing agent. This
interface would serve as the means by which the Clerk notifies the outsourcing
agent of new users of the system. The
LCS would also be responsible for developing and deploying new policies and
procedures that address sustaining a PKI environment.
Legislative
Resource Center
In addition to the duties of processing the hardcopy and
electronic submissions of the FD and LDA forms, the LRC would also be involved
in the development of policies and procedures associated with the management of
the PKI environment. The LRC would also
be involved with administering those policies and procedures within the FD and
LDA user community.
General Public
The general public would still have access to all FD and
LDA information submitted to the Clerk through the LRC public access
terminals. Hardcopy filings would be
viewed as an image of the actual form (with signature) and electronic
submissions would be viewed as the submitted data superimposed on an image of a
blank form.
Federal Election
Commission and Office of Human Resources
This alternative would require cooperation from the FEC and
the House’s OHR in the development of automated interfaces with the FD
application to replace the existing manual interfaces. Automated interfaces would help improve the
data integrity and the accuracy of incoming candidate and payroll information.
Committee
on Standards of Official Conduct
After receiving the FD submissions, the LRC would continue
to forward all FD forms to the Committee on Standards of Official Conduct for
review. The LRC would also continue to
forward various adhoc reports (i.e., non-respondent reports) regarding FD
submissions to the Committee.
Figure 4.12: Alternative 3: Technology Overview presents an
overview of the technology infrastructure associated with this
alternative. The following discussion
provides a high-level overview of the information technology components.
Figure 4.12:
Alternative 3: Technology Overview
This alternative includes the technology components
indicated in the previous alternative described in Section 3.1, Alternative 1:
Imaging/Workflow System. Those
technology components are summarized as followed:
· Imaging/Workflow Application. The imaging application is the engine that
drives the scanning, indexing and report writing process. It executes the core functions of any
document management system in an integrated manner. Most significant of the possible improvements to the core
document imaging functionality is the workflow management and OCR/ICR
features. Workflow functions manage the
flow of documents among administrators to ensure both accountability and
quality assurance in the processing of information.
· Storage Media and Backup. Given the age and unreliable state of the
existing WORM drive, upgrading to newer WORM technology implementing a
digital-linear tape backup system should be considered, at a minimum.
· Scanning and Printing Peripherals. To plan for future processing loads, it may
be necessary to upgrade the scanner and printing peripherals. The Clerk has made progress in this area by
procuring high speed Xerox Docutech printers capable of on-demand printing. This should reduce the Clerk’s reliance on
the GPO for specific publicly disseminated reports.
· Federal Election Commission and Office of
Human Resources Interfaces. The
automation of data that has been previously entered by hand is critical to
improving data integrity and accuracy.
Telecommunication links could be established with the FEC and OHR to
allow for the timely upload of candidate and payroll data into the FD
application. Although a high-speed
telecommunication link is preferable, loading the information via tape could
also be a viable alternative.
Electronic Filing
Components
This alternative includes the technology components
indicated in the previous alternative described in Section 3.2, Alternative 2:
Imaging/Workflow System with Electronic Filing and Basic Encryption. Those technology components are summarized
as followed:
· Web-based Forms Application. A web-based forms application would be
developed that would allow filers to dynamically fill out their FD and LDA
forms.
· Web Server Hardware/Software (SSL). The web-based forms application detailed
above would physically reside on a Internet web server within the confines of
the LCS. This web server would have the
capability to support encrypted connections initiated by the web clients (i.e.,
FD and LDA submission population) and through the use of a SSL connection.
· Challenge/Response Mechanism. Access to the FD and LDA web-based
applications would be granted through a password and account ID mechanism. This challenge/response mechanism would
authenticate users who choose to submit FD and LDA forms via the Internet using
user IDs and passwords.
· Proxy Server and Firewall. A proxy server and firewall are required
to protect the web server and web-based forms application from unauthorized
uses by those wishing to infiltrate and disrupt the system.
Public Key Infrastructure Components
A PKI environment is implemented using a mix of hardware and
software components, combined with related policies and procedures, to provide
a set of security services that enable secure electronic computing in a
distributed environment. The
outsourcing agent would be responsible for the technology components of the
PKI, and the Clerk would be responsible for developing and implementing the
policies and procedures that govern the PKI.
To provide
an electronic filing functionality with a PKI environment, the following
technology components would need to be employed:
·
Certificates. After providing proof of identification, a
filer wishing to submit FD or LDA forms electronically in a PKI environment
would receive an unique digital certificate (from the outsourcing agent, after
receiving notification from the Clerk) that would be used to authenticate their
submission. Certificates are the
mechanism by which a person’s identity associated with an electronic submission
can be authenticated. These unique
certificates serve as electronic signatures, thereby authenticating the
identity of an electronic filer. The
digital certificate could be physically stored as a plug-in to the senders web
browser that resides on their PC. This
unique certificate, when provided with an electronic submission of the FD or
LDA forms, would provide non-repudiation of identity of the filer.
· Certificate Authority (CA). The primary function of the CA is to
generate and manage the public key certificates that bind the user’s identity
with the user’s public key. In order to
perform this function, a CA must provide various services
to the users of the certificates. Major
services performed by a CA are detailed as followed:
-
Certificate
Generation: One of the most
important services provided by a CA is the generation of certificates. It is through certificate generation that
the binding of a user’s identity and a user’s public key is made which, in
turn, is based on the appropriate user identification methods.
-
Certificate
Authorization: When a certificate
is presented, the CA verifies that the certificate is valid and is authorized
for the given use.
-
Certificate
Maintenance: The CA must perform a
number of maintenance activities associated with certificates. Common maintenance activities include
certificate back-up and revocation.
The functions listed above are
generally performed using a combination of CA software and accompanying CA
policy and procedures. Some popular PKI
vendors that perform this function include products such as Spryus/Signet CA,
Entrust WebCA, and IBM Registry.
· Directory Servers. The directory server is responsible for
maintaining the actual certificates and user identification pairs for future
authentication purposes.
· Root Authority (RA). The RA is the single point of trust at
the top of a certification hierarchy of a PKI.
What separates this CA from other CAs is that it signs its own
certificate. Because of this, its
private key must be highly protected.
The RA usually issues certificates for subordinate CAs. A number of RAs are currently in use in the
Internet. For example, Netscape offers
RA certificates from 16 organizations including, but not limited to Verisign,
GTE, and AT&T.
This alternative was evaluated based on its ability to meet
the high-level business needs as presented in Section 1.1.1 Needs Based
Criteria. Figure 4.13: Alternative 3:
Evaluation of High-Level Business Needs presents a summary of the evaluation of the high-level business needs.
|
Criteria
|
Criteria
Rating
|
Comment
|
|
Input Capabilities
|
Fully
|
·
This alternative
reduces the inefficiencies and errors associated with data input. Automated interfaces for files received
from the FEC and the OHR would eliminate the need for manual keying of hard
copy reports.
·
OCR/ICR functionality
speeds the input of document index information.
|
|
Processing Capabilities
|
Fully
|
·
Workflow functionality
would improve quality assurance by proving the mechanism to administer
controls associated with the FD and LDA processing cycle.
·
The core imaging
system would incorporate logic to automate filer compliance.
|
|
Output Capabilities
|
Fully
|
·
Standard report
writing would be a component of the core imaging system.
·
The Xerox Docutech
printer would be supported and allow for on-demand printing.
|
|
Query Capabilities
|
Fully
|
·
Core system would
include flexible, easy to use record query capabilities.
|
|
Storage Capabilities
|
Fully
|
·
Image storage would be
in a non-proprietary format.
|
|
Technology Capabilities
|
Fully
|
·
This alternative
provides enhanced capabilities for electronic filing and signature
verification. Implementation of PKI provides non-repudiation of electronic FD
and LDA submissions. This
functionality is not included in the Imaging/Workflow System, with Electronic
Filing and Basic Encryption alternative.
|
|
Application Controls and
Security Capabilities
|
Fully
|
·
This alternative
provides increased protection of data submitted electronically, along with
non-repudiation assurances.
|
|
Data Integrity Control
Capabilities
|
Fully
|
·
Data integrity
controls are improved through the use of workflow functionality and automated
interfaces.
·
Field edits and error
checking logic would be enhanced for all alternatives under consideration.
|
|
Key: Partially-Partially
meets criteria Fully-Fully meets
criteria
|
Figure
4.13: Alternative 3: Evaluation of High-Level Business Needs
There are number of implementation issues that need to be
considered when evaluating whether to implement an outsourced PKI. The primary implementation issues are:
·
Clerk-Wide vs.
House-Wide Implementation of PKI. The model detailed above shows the PKI
residing within the LRC, under the direction of the Clerk. This PKI model could serve as a pilot to
assess its viability to other scenarios that fit within the mission of the
entire House. For example, one use of
the PKI technology’s digital
certificates involves the use of physical “smart cards”. These cards can be designed to carry a
physically embedded digital certificates that, when swiped through a card
reader, provide a unique digital signature.
Applications that would fit this model could include House Member vote
casting, House employee parking validation or substantiation of a FD and LDA
hardcopy submission.
·
Outsource Agent Issues. The Clerk must be cognizant that the overall security of the
environment would depend somewhat on the security practices of the outsourcing
agent. The Clerk would have less
control of the security aspect of this application.
In this section, the stakeholder analysis, technology
description, high-level business needs evaluation, and implementation issues of
the Imaging/Workflow System, with Electronic Filing and an In-house PKI
alternative are presented. The
functionality of the Imaging/Workflow System with Electronic Filing and
In-house PKI system alternative includes:
· Imaging/Workflow System that was
described in the Imaging/Workflow alternative presented in Section 4.3.1,
Alternative 1: Imaging/Workflow System.
· Electronic Filing that provides the
functionality for electronic filing.
Electronic filing provides the FD and LDA user community the ability to
file via the Internet using a user ID and password that was described in the
alternative described in Section 4.3.2, Alternative 2: Imaging/Workflow System
with Electronic Filing and Basic Encryption.
· Public Key Infrastructure that provides
the functionality for electronic filing with the use of a PKI. The implementation of PKI could provide
increased levels of confidentiality, integrity, and authentication of
electronic submissions of FD and LDA forms and could address the
non-repudiation evaluation criterion.
For this alternative, the PKI system would be administered in-house by
the Clerk.
Figure 4.14: Alternative 4: Stakeholder Overview presents an
overview of the primary stakeholders of the FD and LDA applications and their
relationships. In the following
discussion, each of the stakeholders and their primary relationship to the FD
and LDA applications under this alternative are described.
Figure 4.14: Alternative 4: Stakeholder
Overview
Filing Community
To sustain the integrity of the PKI environment, the FD and
LDA filing community would face additional scrutiny with regards to proof of
identification. Verifying the identity
of users of a PKI is paramount to the health of the security that the PKI
provides. Filers would need to provide
proof of identification before they would be allowed to submit
electronically. Filers could provide
proof of identity and sign an agreement for authorized use in person at the
LRC. Another method could involve
submitting a request through the mail by providing a notarized letter using
official letterhead.
Legislative Computer Services
The implementation of a PKI would require the LCS to develop
an understanding and a competency of a number of additional technical
areas. In addition to the basic Internet
components associated with electronic filing detailed in Section 4.3.2,
Alternative 2: Imaging/Workflow System with Electronic Filing with Basic
Encryption, the LCS would be
responsible for the operation of the PKI and the technology components if operated
in-house. The technology components
include new software and hardware, as well as new policies and procedures that
address sustaining a PKI environment.
Legislative
Resource Center
In addition to the duties of processing the hardcopy and
electronic submissions of the FD and LDA forms, the LRC would also be involved
in the development of policies and procedures associated with the management of
the PKI environment. The LRC would also
be involved with administering those policies and procedures within the FD and
LDA user community.
General Public
The
general public would still have access to all FD and LDA information submitted
to the Clerk through the LRC public access terminals. Hardcopy filings would be viewed as an image of the actual form (with
signature) and electronic submissions would be viewed as the submitted data
superimposed on an image of a blank form.
Federal Election
Commission and Office of Human Resources
This alternative would require cooperation from the FEC and
the House’s OHR in the development of automated interfaces with the FD
application to replace the existing manual interface. Automated interfaces would help improve the data integrity and
the accuracy of incoming candidate and payroll information.
Committee
on Standards of Official Conduct
After receiving the FD submissions, the LRC would continue
to forward all FD forms to the Committee on Standards of Official Conduct for
review. The LRC would also continue to
forward various adhoc reports (i.e., non-respondent reports) regarding FD
submissions to the Committee.
Figure 4.15: Alternative 4: Technology Overview presents an
overview of the technology infrastructure associated with this
alternative. The following discussion
provides a high-level overview of the information technology components.
Figure 4.15:
Alternative 4: Technology Overview
This alternative includes the technology components
indicated in the previous alternative described in Section 3.1, Alternative 1:
Imaging/Workflow System. Those
technology components are summarized as the following:
· Imaging/Workflow Application. The imaging application is the engine that
drives the scanning, indexing and report writing process. It executes the core functions of any
document management system in an integrated manner. Most significant of the possible improvements to the core
document imaging functionality is the workflow management and optical character
features. Workflow functions manage a
controlled flow of documents among administrators to ensure both accountability
and quality assurance in the processing of information.
· Storage Media and Backup. Given the age and unreliable state of the
existing WORM drive, upgrading to newer WORM technology implementing a
digital-linear tape backup system should be considered, at a minimum.
· Scanning and Printing Peripherals. To plan for future processing loads, it may
be necessary to upgrade the scanner and printing peripherals. The Clerk has made progress in this area by
procuring high speed Xerox Docutech printers capable of on-demand
printing. This should reduce the
Clerk’s reliance on the GPO for specific publicly disseminated reports.
· FEC and OHR Interfaces. The automation of data that has been
previously entered by hand is critical to improving data integrity and
accuracy. Telecommunication links could
be established with the FEC to allow for the timely upload of candidate data
into the FD application. Although a
high-speed telecommunication link is preferable, the alternative of loading the
information via tape is a viable alternative.
Automated interfaces could also be developed to accept payroll data from
OHR for subsequent input into the FD application.
Electronic Filing Components
This alternative includes the technology components
indicated in the previous alternative described in Section 3.2, Alternative 2:
Imaging/Workflow System with Electronic Filing and Basic Encryption. Those technology components are summarized
as the following:
· Web-based Forms Application. A web-based forms application would be
developed that would allow filers to dynamically fill out their FD and LDA
forms.
· Web Server Hardware/Software (SSL). The web-based forms application detailed
above would physically reside on a Internet web server within the confines of
the LCS. This web server would have the
capability to support encrypted connections initiated by the web clients (i.e.,
FD and LDA submission population) and through the use of a SSL connection.
· Challenge/Response Mechanism. Access to the FD and LDA web-based
applications would be granted through a password and account ID mechanism. This challenge/response mechanism would
authenticate users who choose to submit FD and LDA forms via the Internet using
user IDs and passwords.
· Proxy Server and Firewall. A proxy server and firewall are required
to protect the web server and web-based forms application from unauthorized
uses by those wishing to infiltrate and disrupt the system.
Public Key Infrastructure Components
If the
Clerk develops and operates an in-house PKI, the PKI technology components
described in Section 3.3, Alternative
3: Imaging/Workflow System with Electronic Filing and Outsourced PKI, would still be needed. Those technology components are summarized
as the following:
·
Certificates. This unique certificate, when provided with
an electronic submission of the FD or LDA forms, would provide non-repudiation
of identity of the filer.
· Certificate Authority. The primary function of the CA is to
generate and manage the public key certificates that bind the user’s identity
with the user’s public key. In order to
perform this function, a CA must provide various services to the users of the
certificates. Major services performed
by a CA include certificate generation, authorization, and maintenance. CA products include GTE Cybertrust,
Spyrus/Signet CA, Entrust WebCA, IBM Registry, and VeriSign On-Site.
· Directory Servers. The directory server is responsible for
maintaining the actual certificates and user identification pairs for future
authentication purposes.
· Root Authority. A Root Authority is the single point of trust at the top of a
certification hierarchy of a PKI.
This alternative was evaluated based on its ability to meet
the high-level business needs as presented in Section 1.1.1 Needs Based
Criteria. Figure 4.16: Alternative 4:
Evaluation of High-Level Business Needs presents a summary of the evaluation of the high-level business needs.
|
Criteria
|
Criteria
Rating
|
Comment
|
|
Input Capabilities
|
Fully
|
·
This alternative
reduces the inefficiencies and errors associated with data input. Automated interfaces for files received
from the FEC and the OHR would eliminate the need for manual keying of hard
copy reports.
·
OCR/ICR functionality
speeds the input of document index information.
·
|
|
Processing Capabilities
|
Fully
|
·
Workflow functionality
would improve quality assurance by proving the mechanism to administer
controls associated with the FD and LDA processing cycle.
·
The core imaging
system would incorporate logic to automate filer compliance.
|
|
Output Capabilities
|
Fully
|
·
Standard report
writing would be a component of the core imaging system.
·
The Xerox Docutech
printer would be supported and allow for on-demand printing.
|
|
Query Capabilities
|
Fully
|
·
Core system would
include flexible, easy to use record query capabilities.
|
|
Storage Capabilities
|
Fully
|
·
Image storage would be
in a non-proprietary format.
|
|
Technology Capabilities
|
Fully
|
·
This alternative
provides enhanced capabilities for electronic filing and signature
verification. Implementation of PKI provides non-repudiation of electronic
LDA and FD submissions. This
functionality is not in the Imaging/Workflow System, with Electronic Filing
and Basic Encryption alternative.
|
|
Application Controls and
Security Capabilities
|
Fully
|
·
This alternative
provides increased protection of data submitted electronically, along with
non-repudiation assurances.
|
|
Data Integrity Control
Capabilities
|
Fully
|
·
Data integrity
controls are improved through the use of workflow functionality and automated
interfaces.
·
Field edits and error
checking logic would be enhanced for all alternatives under consideration.
|
|
Key: Partially-Partially
meets criteria Fully-Fully meets criteria
|
There are number of implementation issues that need to be
considered when evaluating whether to implement an in-house PKI. The primary implementation issues are:
· In-House PKI Implementation Issues. The Clerk has the option of operating its
own CA in-house or outsourcing some or most of the CA functions to a service
provider, as described in the previous alternative. To operate the CA in-house, certificate management software is
purchased from a vendor and used within the Clerk. The Clerk would operate the Registration Authority function, CA
function, and all repository functions as well. A vendor could potentially provide training, installation and
software support. Maintaining the PKI
in-house would introduce many new
areas of responsibility for the Clerk.
· Clerk-Wide vs. House-Wide Implementation of
PKI. As described in the previous
alternative, the Clerk should assess the investment costs associated with
implementing a PKI infrastructure specific to the Clerk if House-wide
Exhibit 5
Cost-Benefit Analysis
Cost-Benefit
Analysis
Table
of Contents
5.1. Methodology................................................................................................................ 1
5.1.1 System
Alternative Cost Analysis..................................................................... 1
5.1.1.1 Development of Assumptions............................................................. 2
5.1.1.2 Identification of Cost Factors.............................................................. 2
5.1.1.3 Cost-Benefit Estimation of Alternatives............................................. 3
5.1.2 Cost Sensitivity
Analysis.................................................................................. 3
5.1.3 Qualitative
Analysis.......................................................................................... 4
5.2. System
Alternative Cost Analysis................................................................................ 4
5.2.1 Cost Analysis Summary.................................................................................... 5
5.2.2 Existing System................................................................................................. 7
5.2.2.1 Non-Recurring Costs.......................................................................... 8
5.2.2.2 Recurring Costs.................................................................................. 8
5.2.3 Alternative 1:
Imaging/Workflow System........................................................ 11
5.2.3.1 Non-Recurring Costs........................................................................ 11
5.2.3.2 Recurring Costs................................................................................ 13
5.2.4 Alternative 2:
Imaging/Workflow System, with Electronic Filing and Basic Encryption...................................................................................................... 15
5.2.4.1 Non-Recurring Costs........................................................................ 16
5.2.4.2 Recurring Costs................................................................................ 17
5.2.5 Alternative 3:
Imaging/Workflow, with Electronic Filing and an
Outsourced PKI............................................................................................... 19
5.2.5.1 Non-Recurring Costs........................................................................ 20
5.2.5.2 Recurring Costs................................................................................ 21
5.2.6 Alternative 4: Imaging/Workflow, with
Electronic Filing and an In-house PKI 23
5.2.6.1 Non-Recurring Costs........................................................................ 24
5.2.6.2 Recurring Costs................................................................................ 25
5.3. Cost
Sensitivity Analysis........................................................................................... 27
5.3.1 Electronic Filing Efficiency Gains........................................................ 26
5.3.2 Transition Cost Increases...................................................................... 28
5.4. Qualitative
Analysis.................................................................................................. 30
Cost-Benefit
Analysis of Viable System Alternatives
This
exhibit presents the cost-benefit analysis for the four system alternatives
that were identified as viable solutions for replacing the current Financial
Disclosure (FD) and Lobby Disclosure
Act (LDA)
applications. This cost-benefit
analysis includes a methodology section that identifies the resources used to
collect information to identify cost factors, as well as the steps followed to
analyze the costs and benefits of the viable system alternatives. The results presented include a cost
comparison of the existing system and the four system alternatives. A cost sensitivity analysis and a
qualitative analysis are also included.
The objective of the cost-benefit analysis was to analyze
the viable system alternatives detailed in the Exhibit 4, Feasibility Study and to examine the costs and benefits for
implementing each alternative. The
cost-benefit analysis presents cost estimates for the existing system and the
four viable system alternatives.
The
cost-benefit analysis was based on a multi-step process that began with the
development of assumptions and identification of cost factors, and resulted in
a cost summary for the existing system and the four viable system
alternatives. The multi-step process
was composed of three steps listed below, followed by a description of each
step:
· System
Alternative Cost-Benefit Analysis.
· Cost
Sensitivity Analysis.
· Qualitative
Analysis.
In Exhibit 4,
Feasibility Study, information was presented on the viable system options
for replacing the current FD and LDA system.
For the cost-benefit analysis presented in this exhibit, estimated or
preliminary cost data was collected and cost estimates were developed for
inclusion in a cost model.
The cost
model was used to analyze the costs of the existing system and the viable
system alternatives. The cost data was
collected from a variety of sources, including interviews with House personnel,
software and hardware vendors, subject matter experts, and other legislative
bodies. The cost analysis for the
existing system and the four system alternatives comprised the following steps:
·
Development of Assumptions.
·
Identification of Cost Factors.
·
Cost Comparison Analysis of Alternatives.
Each of
the cost analysis steps is included below.
The system alternatives cost analysis used the following
general assumptions:
·
Salary and
Fringe Benefits. Actual salaries
and an average fringe benefit rate of 29.55 percent for the personnel costs
were used for salary and fringe benefit calculations for the existing system.
For personnel changes (additions or reductions), a salary of $62,000 based on a
Grade 10, Step 6 position as of January 1, 1998 was used.
·
Cost Factor
Escalation. Personnel costs (salary
and fringe benefits) were escalated by
4 percent per year to represent cost-of-living increases.
·
Time Period of
Analysis. A five-year time period
was used in this evaluation.
·
Net Present
Value and Discount Factor. The net
present value calculation was used to discount future costs using a discount
rate of 7 percent.
The applicable cost factors
listed below were identified by using the House’s
System Development Life Cycle (SDLC) procedures for performing a cost-benefit
analysis and by using guidelines from the General Services
Administration (GSA) Information Technology Planning and Investment Guide.
· Non-recurring costs are costs that
occur in the first year of the analysis and are primarily costs for
installation of software, software purchases and customization, hardware
purchases, conversion/testing charges, training, and certificate management
related charges.
Non-recurring costs are assumed to
be incurred during the first year of the analysis time period and are not
discounted.
· Recurring costs are costs that are
incurred on an annual basis throughout the time period of the analysis,
including the first year. The recurring
costs include personnel salaries and fringe benefits, computer hardware (lease
and maintenance), computer software (licenses and maintenance), and external
vendor services. The recurring costs
for each year are discounted using net present value.
The cost
estimates presented in this analysis are based on the following:
· Vendor Quotes. Vendors were contacted and the high-level
requirements of the alternative systems were discussed to obtain software,
hardware, and implementation costs. At
least two vendor quotes were obtained for all estimates.
· Independent Research Organizations. Cost and product data from organizations
such as Gartner Group, Faulkner, and Forrestor were also collected.
· Technology Specialists. Specialists in imaging, electronic filing,
and Public Key Infrastructure (PKI) technology were interviewed to develop and
refine costs estimates for the alternatives.
The cost
factors included in this evaluation represent the high-level “primary” costs to
support the system alternatives. Cost
factors not included in the evaluation include facilities and utility cost,
personnel overhead, and supplies. The
actual costs to implement the alternatives could vary significantly from these
cost estimates during implementation due to the specific applications and
requirements chosen by the Clerk. All
cost estimates presented in this evaluation are rounded to the nearest
thousand.
For this
evaluation, benefits are defined as cost savings resulting from implementing
the alternatives instead of continuing operation of the existing system. These benefits occur due to cost savings
primarily from labor costs savings and reduced hardware and software maintenance
costs. Benefits are included, where
applicable, in the cost analysis of the alternatives and are represented as
costs that are lower than the existing system.
The next
step after performing the cost analysis was to perform a sensitivity
analysis. This sensitivity analysis was
performed to determine the impact of changes to the cost factors and
assumptions used in this evaluation.
The cost sensitivity analysis will provide management with additional
information when analyzing the alternatives discussed in this evaluation.
5.1.3 Qualitative
Analysis
A qualitative, or non-quantifiable, factor analysis was
performed for each alternative.
Qualitative factors were identified and assessed for each system
alternative. The purpose of this
analysis was to identify additional criteria factors to analyze the
alternatives. The qualitative analysis
methodology was composed of the following steps:
·
Identification
of Qualitative Factors. Six
qualitative categories to assess the system alternatives were identified and
defined: stakeholder needs and
constraints, management control, security risk, commercial acceptance, Office
of the Clerk (Clerk) organizational impact, and filing community impact. These categories represent qualitative, or
non-quantifiable, attributes of the system alternatives.
·
Analysis of
Qualitative Factors. The six
qualitative factors were analyzed for each alternative, and an assessment was
developed that presented the issues associated with each factor.
The system
alternative cost analysis section presents the results of the cost analysis for
the existing system and each system alternative. The cost analysis presentation is organized as follows:
· Cost
Analysis Summary.
· Existing
System.
· Imaging/Workflow
System.
· Imaging/Workflow,
with Electronic Filing and Basic Encryption.
·
Imaging/Workflow, with Electronic Filing and an
Outsourced
PKI.
·
Imaging/Workflow, with Electronic Filing and an
In-house PKI.
In each section, the non-recurring and recurring cost
factors are discussed.
5.2.1 Cost
Analysis Summary
Figure 5.1: Existing System and Alternative Costs Analysis
on the following page presents a summary of the non-recurring and recurring
cost estimates for the existing system and the four viable system
alternatives. The figure presents
five-year total cost estimates discounted using a present value
calculation. This was done to provide
an overall five-year lifecycle cost estimate of the existing system and each alternative.
As described in Exhibit 4, Feasibility Study, the alternatives build upon each other in terms
of functionality and cost. For example,
the estimated costs and functionality of the Imaging/Workflow alternative are
included in all four alternatives. Additionally, the estimated costs and
functionality for electronic filing in the Imaging/Workflow with Electronic
Filing and Basic Encryption alternative are included in the remaining
alternatives. The alternatives with PKI
functionality differ only in terms of the estimated costs of outsourcing the
PKI function versus maintaining the function in-house (by the Clerk).
Figure 5.1: Existing
System and Alternative Cost Analysis
The results of the cost
analysis indicate that the estimated costs to implement each of the alternative
systems are more expensive than the existing system over the five-year period.
However, the alternatives do provide additional functionality over the existing
system and better meet the evaluation criteria defined in this evaluation, as
presented in Exhibit 4, Feasibility Study.
The total estimated costs
for the Imaging/Workflow System are
slightly higher than the existing system over the five-year period, primarily
because of the non-recurring implementation costs. The recurring costs of the Imaging/Workflow System are less than
the existing system recurring costs.
For this alternative, we estimated that benefits would be achieved
through lower recurring hardware and software maintenance costs.
The estimated costs for
the Imaging/Workflow System with
Electronic Filing and Basic Encryption are higher than the existing system,
primarily because of the
non-recurring
implementation costs and the slightly higher recurring costs. For this alternative, it was estimated that
benefits would be achieved through lower labor costs (in terms of salaries and
fringe benefits) for forms processing.
However, it was estimated that additional labor costs would be incurred
for computer support due to the additional electronic filing functionality.
The estimated costs for
both the Imaging/Workflow System with
Electronic Filing and an Outsourced PKI and Imaging/Workflow System with Electronic Filing and an In-House PKI are
significantly higher than the existing system.
Both alternatives require significant non-recurring implementation costs
and the recurring costs are higher than the existing system. The cost estimates for the In-House PKI
alternative are significantly higher than the Outsourced PKI alternative due to
the additional staff resources and software license and maintenance costs
required.
The following discussion
presents the cost analysis for the existing system and each of the four viable
alternatives. The cost estimates
presented are preliminary cost estimates and can be considered minimum costs
that would be incurred in implementing the alternatives. Additionally, actual implementation of the
alternatives may result in varied functionality and different technical
components than those presented in this evaluation and would therefore differ
in costs.
5.2.2 Existing System
In the discussion below, the non-recurring and recurring
cost estimates for this existing system are presented. Figure 5.2: Summary of Imaging/Workflow
System Costs below summarizes the non-recurring and recurring cost estimates.
|
Category
|
Estimated Costs
|
|
Non-Recurring Costs
|
$0
|
|
Recurring Costs
|
$2,978,000
|
|
Total Estimated
Costs
|
$2,978,000
|
5.2.2.1 Non-Recurring Costs
There are no non-recurring costs for the existing
system. Costs associated with
conversion/testing, software customization, hardware and software purchase, and
training had been previously incurred when the existing system was originally
developed. Thus, the non-recurring
costs to develop the existing system are considered sunk costs and not included
in the analysis of this existing system.
Figure
5.3: Existing System - Recurring Cost Estimates on the following page presents the
recurring cost estimates for the existing system. The recurring costs for the existing system were determined by
reviewing current vendor invoices and by interviews with Legislative Resource
Center (LRC) and Legislative Computer Systems (LCS) staff. The figure presents: the annual recurring
cost estimates, and a five-year total of recurring costs discounted using the
net present value calculation. These
recurring costs are incurred on an annual basis throughout the five-year period
of the analysis.
Figure
5.3: Existing System - Recurring Cost Estimates
Personnel Salaries and Fringe Benefits
The
recurring personnel salaries and fringe benefits for the existing system
include the staff to support the current FD and LDA applications. Personnel from the LRC, LCS, and House
Information Resources (HIR) currently support the existing system. Listed below is a description of the staff
resources dedicated to supporting the FD and LDA applications from the associated
House office.
·
Legislative
Resource Center staff dedicated to processing the FD and LDA submissions
include seven full-time staff and approximately 50 percent of the efforts of
another four full-time staff.
·
Legislative
Computer Systems staff dedicated to maintaining the computer systems associated
with the FD and LDA applications include 40 percent of the efforts of one full-time staff member.
·
House
Information Resources staff dedicated to maintaining the mainframe
component of the FD and LDA system includes approximately 20 percent of the
efforts of one full-time staff member.
Hardware (Lease
and Maintenance)
The
recurring hardware lease and maintenance costs for the existing system include
the costs associated with operating the mainframe system, maintaining the OSAR
optical disc storage system, and licensing and maintaining two scanners used
for forms processing. The specific cost
factors for the existing system and the four alternatives include:
·
Mainframe Costs includes
the lease and maintenance costs associated with the mainframe hardware.
·
OSAR Optical
Disk Storage Maintenance includes the maintenance costs for the optical
disk storage system.
·
Other Hardware
Maintenance includes any other related peripheral hardware.
·
Scanner License
and Maintenance includes the license and maintenance fees associated with
the current scanners.
·
New Scanner
License and Maintenance includes the license and maintenance costs for the
new scanners, where pertinent.
·
New Optical Disk
Storage Maintenance includes the license and maintenance costs for the new
optical storage system, where pertinent.
Software (License
and Maintenance)
The
recurring software license and maintenance costs for the existing system
include the costs associated with the current image system software and RS-6000
license and maintenance fees. This cost
category also includes maintenance and license fees for other software
associated with the existing system (i.e., database management software and
printer servers). The specific cost
factors for the existing system and the four alternatives include:
·
Image System
Software License and Maintenance includes the license and maintenance costs
associated with the current imaging system.
·
RS-6000 Server
License and Operating System includes the license and maintenance fees
associated with the current RS-6000 servers and operating system.
·
Other Software
License and Maintenance includes the license and maintenance fees for other
system software components.
·
PKI Annual
License and Maintenance includes the annual license and maintenance fees
associated with a PKI. The existing
system does not include these functions.
·
New Imaging
System Maintenance includes the maintenance fees associated with the new
imaging system software.
External
Vendor Services
External vendor services are not used in the existing
system.
In the discussion below, the non-recurring and recurring
cost estimates for this alternative are presented. Figure 5.4: Summary of Imaging/Workflow Costs below summarizes
the non-recurring and recurring cost estimates.
|
Category
|
Estimated Costs
|
|
Non-Recurring Costs
|
$388,000
|
|
Recurring Costs
|
$2,663,000
|
|
Total Estimated
Costs
|
$3,051,000
|
Figure 5.4: Summary of
Imaging/Workflow System Costs
5.2.3.1 Non-Recurring Costs
Figure
5.5: Imaging/Workflow System - Non-Recurring Cost Estimates below presents the
non-recurring cost estimates for the Imaging/Workflow System alternative. The figure presents cost estimates that
would be incurred to support a new imaging/workflow system for the FD and LDA
applications. These non-recurring costs
are incurred during the first year of the alternative. Each of the cost factors is discussed below.
Figure 5.5: Imaging/Workflow System - Non-Recurring
Cost Estimates
Conversion/Testing
This cost
category includes the estimated costs to convert the approximately 157
gigabytes of image data stored on 12’’ Write-One-Read-Many (WORM) optical
storage platters to the 5.2GB WORM optical storage disks. This cost factor was estimated based on a
vendor quote for data conversion services.
Software
Integration/Customization
This cost category includes the estimated costs to customize
the workflow scripts and document capture processes associated with the
application workflow module, to develop programs for supporting the OCR/ICR
processing module, and also to develop the automated interfaces with the
Federal Election Commission (FEC) and the Office of Human Resources (OHR). Costs for software integration/customization
for this alternative was based on estimates derived from knowledge obtained
from similarly scoped projects.
Hardware Purchase
This cost
category includes the estimated costs associated with purchasing the
magneto-optical disc storage unit and one additional external magneto-optical
disk drive. Also included are 5.2GB
optical storage disks, two peripheral scanners and two workstations for the
imaging system. This cost category also
includes the estimated costs for the purchase of a digital-linear tape backup
system. The estimated costs for the
hardware components for this alternative were obtained from vendor quotes.
Software Purchases
This cost
category includes the estimated cost to purchase the software utilities
required for the imaging/workflow system.
This includes software used for the optical disk storage unit, the
imaging system, the scanners, and the OCR/ICR processing engine. The cost estimates were based on vendor
quotes.
Training
This cost category includes the estimated cost for a vendor
administered imaging system and OCR/ICR forms processing training course for
two staff members. The estimated costs
for the hardware components for this alternative were obtained from vendor
quotes.
Certificate Authority (CA) Set-Up/Initialization
This cost category refers to establishing an external
certificate authority and is applicable only in Alternative 3.
Figure 5.6: Imaging/Workflow System - Recurring Cost
Estimates below presents the recurring cost estimates for this
alternative. The figure presents the
annual recurring cost estimates, and a five-year total of recurring costs
discounted using the net present value calculation. These recurring costs are incurred on an annual basis throughout
the five-year period of the analysis.
Figure 5.6:
Imaging/Workflow System - Recurring Cost Estimates
Personnel Salaries
and Fringe
The
recurring personnel salaries and fringe benefits for this alternative include
the staff to support the new FD and LDA applications from the LRC and LCS. Listed below is a description of the staff
resources dedicated to supporting this alternative.
·
Legislative
Resource Center staff dedicated to processing the FD and LDA submissions
for this alternative include a reduction of 20 percent in forms processing
labor resources from the existing system due to the estimated efficiencies
gained by this technology.
·
Legislative
Computer Systems staff dedicated to maintaining the computer systems
associated with the FD and LDA applications include the addition of one
full-time System Administrator position to the LCS staff. The additional System Administration
position is being created to assist with maintaining the additional system
complexities associated with this alternative.
·
House
Information Resources staff resources are eliminated because the mainframe
component of the existing system is no longer necessary.
Hardware (Lease and
Maintenance)
The primary difference in the recurring hardware costs from
the existing system is the elimination of the lease and maintenance costs for
the current FileNet optical storage system and the costs associated with the
Bell & Howell and the Kodak scanners
currently used in the LRC. These three
components would be replaced with a new optical storage system and two new
scanners that have less recurring costs for license and maintenance. Lease and maintenance costs for other
hardware components, such as servers and a tape backup system, are also
included in this cost category.
Software (License and
Maintenance)
The
recurring software costs for this alternative would include the elimination of
the costs associated with the FileNet imaging system and the RS-6000 server and
operating system license/maintenance.
Software lease and maintenance fees for a new imaging system and for
other related software programs are included in this cost category.
External Vendor
Services
External vendor services are not pertinent since the use of
external vendors is not part of this alternative.
In the
discussion below, non-recurring and recurring cost estimates for this
alternative are presented. These
estimates include both the cost and functionality as described in Section
E.2.3, Imaging/Workflow System of this evaluation. Figure 5.7: Summary of Imaging/Workflow System, with Electronic
Filing and Basic Encryption Costs below summarizes these estimated costs.
|
Category
|
Estimated Costs
|
|
Non-Recurring Costs
|
$582,000
|
|
Recurring Costs
|
$3,073,000
|
|
Total Estimated
Costs
|
$3,655,000
|
Figure 5.7: Summary of Imaging/Workflow
System, with Electronic Filing and Basic Encryption Costs
Figure
5.8: Imaging/Workflow System, with Electronic Filing and Basic Encryption–
Non-Recurring
Costs Estimates below presents the non-recurring cost estimates for this
alternative. The figure presents cost
estimates that would be incurred to support a new imaging/workflow system and
electronic filing with basic encryption for the FD and LDA applications. These non-recurring costs are incurred
during the first year of the alternative.
Figure 5.8: Imaging/Workflow System, with Electronic
Filing and Basic Encryption–Non-Recurring Cost Estimates
Conversion/Testing
This cost
category does not introduce any new conversion/testing costs, but does include
those noted in the previous alternative: conversion of image data from optical
storage platters to optical storage disks.
Software
Integration/Customization
This cost category includes the estimated costs to customize
the web-based forms application used for electronic submission of FD and LDA
forms. The customization costs were
determined by a vendor estimate based on projects of similar scope. The software integration/customization cost
category also contains the following costs as noted in the previous
alternative: customization of the
workflow scripts and document capture processes associated with the workflow
application, programs for OCR/ICR processing, and the development of an
automated interface with FEC and OHR.
Hardware Purchase
This cost
category includes the estimated costs associated with the purchase of a web and
firewall server, and an index database management server. The estimated costs for the hardware
components for this alternative were obtained from vendor quotes. The hardware purchase category for this
alternative also contains the following costs as noted in the previous
alternative: magneto-optical disc storage unit, one
additional external magneto-optical disk drive, optical storage disks, two
peripheral scanners and two workstations for the imaging system, and a
digital-linear tape backup system.
Software Purchases
This cost category includes the estimated costs for the
index database management system, the Internet firewall, and the web-based
forms authoring software. The estimated
costs for the software components for this alternative were obtained from
vendor quotes. The software purchase
category for this alternative also contains the following costs as noted in the
previous alternative: software utilities for the imaging/workflow, the optical
disk storage unit, the scanners, and the OCR/ICR processing engine.
Training
This cost category includes the estimated cost for three
staff members to attend a
vendor-administered course for web-based forms
authoring. The estimated costs for the
training associated with this alternative were obtained from vendor
quotes. This cost category also contains
the cost for an OCR/ICR forms processing training course for two staff members
as noted in the previous alternative.
CA
Set-Up/Initialization
This cost category refers to establishing an external
certificate authority and is applicable only in Alternative 3.
Figure 5.9: Imaging/Workflow System, with Electronic
Filing and Basic Encryption - Recurring Costs Estimates below presents the
recurring cost estimates for this alternative.
The figure presents the annual recurring cost estimates, and a five-year
total of recurring costs discounted using the net present value
calculation. These recurring costs are
incurred on an annual basis throughout the five-year period of the
analysis. Discussion of the recurring
cost components associated with this alternative is included on the following
page.
Figure 5.9: Imaging/Workflow
System, with Electronic Filing and Basic Encryption-
Recurring Cost Estimates
Personnel Salaries
and Fringe Benefits
The
recurring personnel salaries and fringe benefits for this alternative include
the staff to support the current FD and LDA applications from the LRC and
LCS. Listed below is a description of
the staff resources dedicated to supporting this alternative.
·
Legislative
Resource Center staff dedicated to processing the FD and LDA submissions
for this alternative include a reduction of 20 percent in forms processing
labor resources from the existing system due to the estimated efficiencies
gained by the imaging/workflow technology.
The electronic filing functionality introduced by this alternative may
also present efficiencies.
·
Legislative
Computer Systems staff dedicated to maintaining the computer systems
associated with the FD and LDA applications include 40 percent of the efforts
of one full-time staff member and
the addition of two System Administrator positions to the LCS staff. The additional System Administration
positions are being created to assist with maintaining the additional system
complexities associated with this alternative.
·
House
Information Resources staff resources are eliminated because the mainframe
component of the existing system is no longer necessary.
Hardware
(Lease and Maintenance)
Estimated lease and maintenance costs for other hardware
components, such as servers, are included in this cost category. Also included in this cost category are
costs noted in the previous alternative for the following: hardware
license/maintenance costs for the new optical storage system, two new scanners,
and a tape backup system.
Software (License and
Maintenance)
Estimated
license and maintenance costs for the software components associated with the
web-based forms application are included in this cost category. Also included in this category are costs
noted in the previous alternative for the following: software maintenance fees
for a new imaging system and other related software.
External Vendor
Services
External vendor services are not
pertinent since the use of external vendors is not part of this alternative.
5.2.5 Alternative 3: Imaging/Workflow, with
Electronic Filing and an Outsourced PKI
The
non-recurring and recurring cost estimates for this alternative are presented
in the discussion below. Figure 5.10:
Summary of Imaging/Workflow with Electronic Filing and an Outsourced PKI Costs
below summarizes these estimated costs for this alternative. These estimated costs also include both the
cost and functionality as described in Section 5.2.4, Imaging/Workflow System, with Electronic Filing and Basic
Encryption, of this evaluation.
|
Category
|
Estimated Costs
|
|
Non-Recurring Costs
|
$725,000
|
|
Recurring Costs
|
$3,385,000
|
|
Total Estimated
Costs
|
$4,110,000
|
Figure 5.10: Summary of Imaging/Workflow
with Electronic Filing and an Outsourced
PKI Costs
Figure
5.11: Imaging/Workflow System with Electronic Filing and an Outsourced PKI –
Non-Recurring Cost Estimates below presents the
non-recurring cost estimates for this alternative. The figure below presents cost estimates that would be incurred
to support a new imaging/workflow with electronic filing and an outsourced PKI
for the LDA and FD applications. These
non-recurring costs are incurred during the first year of the alternative.
Figure 5.11: Imaging/Workflow System with Electronic Filing and an
Outsourced PKI –
Non-Recurring Cost Estimates
Conversion/Testing
This cost category includes the estimated costs associated
with systems testing. The conversion/testing costs factor for this
alternative also contains the following cost as noted in the previous
alternative: the conversion of image data from optical storage platters to
optical storage disks.
Software
Integration/Customization
This cost category does not introduce any new
software/customization costs, but does include costs that were presented in the
previous alternative for the following: customization of the workflow scripts,
integration of the document capture processes associated with the workflow
application, and customization of web-based forms application.
Hardware Purchase
This cost category includes costs for the purchase of two
servers to house the PKI related certificate management and directory
functions. The hardware purchase costs
category factor for this alternative also contains the following costs as noted
in the previous alternative: a
magneto-optical disc storage unit, one additional external magneto-optical disk
drive, optical storage disks, two peripheral scanners, two workstations for the
imaging system, a digital-linear tape backup system, web and firewall servers,
and an index database management server.
Software Purchase
There are no new software purchase costs associated with an
outsourced PKI. The software purchase
cost category for this alternative contains the following costs as noted in the
previous alternative: software utilities for the imaging/workflow, the optical
disk storage unit, the scanners, OCR/ICR processing engine, an index database
management system, the Internet firewall, and the web-based forms authoring
software.
Training
This cost
category includes the estimated costs for a two-day PKI orientation class for
two staff members. The estimated
training costs for this alternative were obtained from vendor quotes. This cost category for this alternative also
contains the following costs as noted in the previous alternative: OCR/ICR forms processing training course for
two staff members, and web-based forms authoring training course for three
staff members.
CA
Set-Up/Initialization
This costs
category includes the estimated costs associated with establishing the PKI
service with an outsourcing vendor.
Figure
5.12: Imaging/Workflow System with Electronic Filing and an Outsourced PKI -
Recurring Cost Estimates below presents the recurring cost estimates for this
alternative. The figure presents the
annual recurring cost estimates, and a five-year total of recurring costs
discounted using the net present value calculation. These recurring costs are incurred on an annual basis throughout
the five-year period of the analysis.
Figure 5.12:
Imaging/Workflow System with Electronic Filing and an Outsourced PKI -
Recurring Cost Estimates
Personnel Salaries
and Fringe Benefits
The recurring personnel salaries and fringe benefits for
this alternative include the staff to support the current FD and LDA
applications from the LRC and LCS. Listed
below is a description of the staff resources dedicated to supporting this
alternative.
·
Legislative
Resource Center staff dedicated to processing the FD and LDA submissions
for this alternative include a reduction of resources by 20 percent due to the
efficiencies gained by the imaging technology.
The functionality introduced by this alternative may also present other
efficiencies associated with electronic filing.
·
Legislative
Computer Systems staff dedicated to maintaining the FD and LDA computer
systems includes 40 percent of the efforts of one full-time staff member, and
the addition of one System Administrator position and one staff member
dedicated to certificate management functions.
The additional positions for this alternative are being created to
assist with maintaining the additional system complexities associated with this
alternative.
·
House
Information Resources staff resources are eliminated because the mainframe
component of the existing system is no longer necessary.
Hardware (Lease and
Maintenance)
Estimated lease and maintenance costs for other hardware
components, such as servers, are included in this cost category. Also included in this cost category are
costs noted in the previous alternative for the following: the hardware license/maintenance costs for
the new optical storage system and the two new scanners.
Software (License
and Maintenance)
This cost
category does not introduce any new costs, but does include the software
maintenance fees for a new imaging system cost as noted in the previous
alternative.
External Vendor
Services
Estimated
costs for PKI vendor hosting services under this alternative is included in
this cost category.
In the
discussion below, the non-recurring and recurring cost estimates for this
alternative are presented. Figure 5.13:
Summary of the Imaging/Workflow with Electronic Filing and an In-house PKI
Costs below summarizes these estimated costs for this alternative. These estimated costs also include both the
cost and functionality as described in Section 5.2.4, Imaging/Workflow System, with Electronic Filing and Basic
Encryption, of this evaluation.
|
Category
|
Estimated Costs
|
|
Non-Recurring Costs
|
$1,549,000
|
|
Recurring Costs
|
$4,326,000
|
|
Total Estimated
Costs
|
$5,875,000
|
Figure 5.13: Summary of the Imaging/Workflow
with Electronic Filing and an In-house PKI Costs
Figure
5.14: Imaging/Workflow System with Electronic Filing and an In-house PKI –
Non-Recurring Cost Estimates below presents the
non-recurring cost estimates for this alternative. The figure below presents cost estimates that would be incurred
to support a new imaging/workflow with electronic filing and an in-house PKI environment
for the LDA and FD applications. These
non-recurring costs are incurred during the first year of the alternative.
Figure 5.14: Imaging/Workflow System with Electronic Filing and an
In-house PKI –
Non-Recurring Cost Estimates
Conversion/Testing
This cost category includes the estimated costs for systems
testing for the PKI environment. These estimated costs for conversion/testing
were obtained from vendor quotes. The
conversion/testing cost category also includes the following costs as presented
in the previous alternative: conversion
of image data from optical storage platters to optical storage disks.
Software
Integration/Customization
This cost category includes the estimated costs to install
and integrate the software modules for the PKI environment. The software integration/customization cost
category also includes the following costs as presented in the previous
alternative: customization of the
workflow scripts, integration of the document capture processes associated with
the workflow application, and customization of web-based forms application.
Hardware Purchase
This cost category includes the estimated costs to purchase
two servers dedicated to the in-house PKI environment. The estimated costs for the hardware
purchase for this alternative was obtained from vendor quotes. The hardware purchase cost category also
includes the following costs as presented in the previous alternative: a
magneto-optical disc storage unit, one additional external magneto-optical disk
drive, optical storage disks, two peripheral scanners, two workstations for the
imaging system, a digital-linear tape backup system, web and firewall servers,
and an index database management server.
Software Purchase
This cost category includes the estimated costs to purchase
the software components to perform the PKI certificate management and directory
functions. The estimated costs for the
software purchase for this alternative were obtained from vendor quotes. The software purchase costs category also
includes the following costs as presented in the previous alternative: purchase of software utilities for the
imaging/workflow, the optical disk storage unit, the scanners, and the OCR/ICR
processing engine, an index database management system, the Internet firewall,
and the web-based forms authoring software.
Training
This cost category includes the estimated costs for a
five-day PKI orientation course for six staff members. The estimated training costs for this
alternative were obtained from vendor quotes.
This cost
category also includes the following costs as presented in the previous
alternative: OCR/ICR forms processing
training course for two staff members, and web-based forms authoring training
course for three staff members.
CA Set-Up/Initialization
This cost category refers to
establishing an external certificate authority and is applicable only in
Alternative 3.
5.2.6.2 Recurring
Costs
Figure 5.15: Imaging/Workflow System with Electronic
Filing and an In-house PKI –Recurring Cost Estimates on the following page
presents the recurring cost estimates for this alternative. The figure presents the annual recurring
cost estimates, and a five-year total of recurring costs discounted using the
net present value calculation. These
recurring costs are incurred on an annual basis throughout the five-year period
of the analysis.
Figure 5.15:
Imaging/Workflow System with Electronic Filing and an In-house PKI –
Recurring Cost Estimates
Personnel
Salaries and Fringe Benefits
The
recurring personnel salaries and fringe benefits for this alternative include
the staff to support the current FD and LDA applications from the LRC and
LCS. Listed below is a description of
the staff resources dedicated to supporting this alternative.
·
Legislative
Resource Center staff dedicated to processing the FD and LDA submissions
for this alternative include a reduction of resources by 20 percent due to the
efficiencies gained by the imaging/workflow technology. The functionality introduced by this
alternative may also present other efficiencies associated with electronic
filing.
·
Legislative
Computer Systems staff dedicated to maintaining the FD and LDA computer
system includes 40 percent of the efforts of one full-time staff member, and
the addition of two System Administrator positions and one staff member
dedicated to certificate management functions for the in-house PKI scenario.
·
House
Information Resources staff resources are eliminated because the mainframe
component of the existing system is no longer necessary.
Hardware (Lease and
Maintenance)
This cost
category includes estimated costs associated with hardware lease and
maintenance costs for the servers associated with this alternative. The hardware lease and maintenance costs
category also includes costs noted in the previous alternative for the
following: the hardware
license/maintenance costs for the new optical storage system, and the two new
scanners.
Software (License
and Maintenance)
The
software license and maintenance costs for this alternative includes estimated
annual charges for the in-house PKI related software. This estimated cost includes charges for the certificate
management software and digital certificate license fees. This alternative also includes the software
lease and maintenance costs noted in the previous alternative for the software
maintenance fees for a new imaging system.
External Vendor
Services
External vendor services are not pertinent since the use of
external vendors is not part of this alternative.
5.3 Cost Sensitivity Analysis
A sensitivity analysis was conducted on the estimated costs
(non-recurring and recurring) for the four viable alternatives analyzed in this
exhibit. The objective of the
sensitivity analysis was to analyze changes to assumptions to determine the
impact on the overall cost of the alternatives. Two scenarios for the
sensitivity analysis were developed:
Electronic Filing Efficiency Gains, and Increased Transition Costs which
are presented below.
5.3.1 Electronic
Filing Efficiency Gains
With the introduction of electronic filing capabilities,
efficiencies may be realized with regards to the processing of the FD and LDA
submissions. These efficiencies would
occur primarily because of a reduction in hard copy form submissions. Areas where the greatest efficiencies could
occur include the elimination of the scan and index functions associated with
the current
forms processing.
However, the exact extent of the efficiencies would depend on the number
of filers that choose to file electronically.
In order to analyze the potential impact of efficiencies
from electronic filing on the cost of the alternatives, the personnel salaries
and fringe benefits cost factor associated with forms processing (LRC) for the
three electronic filing alternatives were decreased by 25 percent.
Figure 5.16: Sensitivity Analysis - Electronic vs. Hardcopy
Submission Efficiency Gains on the following page presents the results of the
sensitivity analysis for this scenario.
The results indicate that the total estimated costs for two alternatives
ľ
Imaging/Workflow with Electronic Filing and Basic Encryption and
Imaging/Workflow with Electronic Filing and an Outsourced PKI ľ are
now only slightly higher than the existing system and the Image/Workflow
System.
Figure 5.16: Sensitivity Analysis - Electronic vs. Hardcopy
Submission Efficiency Gains
A range of estimated reductions in LRC personnel salary
and fringe benefit costs were also considered based on the corresponding
percent of filers who submit FD and LDA forms electronically. For the purposes of this analysis, a
straight-line decrease in LRC forms processing staff costs was assumed,
proportional to the percentage of respondents who submit electronically. For example, 75 percent of filers submitting electronically would equate to a
reduction of 37.5 percent decrease in LRC personnel costs. Figure 5.17: Sensitivity Analysis - Range of
Electronic Filing Efficiency Gains on the following page represents the
potential impact electronic filing submissions could have on the LRC forms
processing staff costs.
Percent of
Electronic Filers
|
100%
|
75%
|
50%
|
25%
|
0%
|
|
Estimated
Reduction in LRC Personnel Costs
|
50%
|
37.5%
|
25%
|
12.5%
|
0%
|
|
Total LRC
Personnel Costs
|
$1,039,000
|
$1,319,530
|
$1,558,500
|
$1,818,250
|
$2,078,000
|
|
Difference from Alternatives
(Cost Savings)
|
$1,039,000
|
$758,470
|
$519,500
|
$259,750
|
$0
|
5.3.2 Transition Cost Increases
Cost information was gathered from vendors based on the
high-level business needs associated with the four viable alternatives noted in
this evaluation. However, these
estimated costs may differ from actual implementation costs due to the specific
vendor chosen and the detailed requirements of the alternative. Therefore, a scenario was developed to
examine the impacts of significantly higher implementation costs on each
alternative.
The total transition costs associated with the four
alternatives were increased by 50 percent to represent a scenario in which the
up-front costs to implement the alternatives are significantly more
expensive. Although software
integration/testing, hardware purchase and software purchase have the greatest
likelihood for increase, to reflect the possible increases in all categories,
the 50 percent factor was applied to the overall non-recurring charge for each
alternative. Figure 5.18: Sensitivity
Analysis - Transition Cost Increases on the following page demonstrates the
impact of the cost increases on the alternatives.
Figure
5.18: Sensitivity Analysis - Transition Cost Increases
In addition to the cost analysis and sensitivity analysis,
an assessment of qualitative, or non-quantifiable, factors for the system
alternatives was performed. The
qualitative analysis was intended to provide additional evaluation criteria to
analyze the alternatives.
Six qualitative factors were identified for use in
analyzing the alternatives. A
description of each of these factors is listed below.
· Stakeholder Needs and Constraints represent
the extent to which each alternative satisfies the stakeholder needs and other
constraints of the evaluation.
· Management Control represents the level
of control that Clerk management has upon the outcomes, processes, schedules,
and costs associated with an alternative.
· Security Risk represents the risks associated with application,
network, and physical security for the implementation of an alternative.
· Commercial Acceptance represents the
availability of knowledgeable customer support, upgrades, documentation, and
proven success in the marketplace of an alternative.
· Clerk Organizational Impact represents
the extent to which each alternative would impact the Clerk’s business
processes associated with the FD and LDA applications.
· Filer Community Impact represents the extent to which the FD/LDA respondent
community is impacted by the alternative.
Figure 5.19: Overall Results of Qualitative Analysis on
the following page presents an assessment of the qualitative factors for each
alternative.
|
Qualitative Factor
|
Image/
Workflow
System
|
Image/Workflow
System,
w/
Electronic Filing and Basic Encryption
|
Image/Workflow
System,
w/
Electronic Filing and an Outsourced PKI
|
Image/Workflow
System,
w/
Electronic Filing and
an
In-house PKI
|
|
Stakeholder Needs and Constraints
|
|
|
|
|
|
Management Control
|
Due to the mature nature of the vendor markets associated with this
alternative, the Clerk should have extensive management control over the
outcomes, processes, schedule and costs.
|
|
|
Over the next two years, the PKI market would experience enhanced
pricing competition due to market entrants.
This pricing competition would enhance the Clerk’s ability for
management control.
|
|
Security Risk
|
|
|
|
|
Figure 5.19: Overall
Results of Qualitative Analysis
|
Qualitative
Factor
|
Image/
Workflow
System
|
Image/Workflow
System,
w/
Electronic Filing and Basic Encryption
|
Image/Workflow
System,
w/
Electronic Filing and an Outsourced PKI
|
Image/Workflow
System,
w/
Electronic Filing and
an
In-house PKI
|
|
Commercial Acceptance
|
|
|
|
|
|
Clerk Organizational Impact
|
The current processing
method used for the FD and LDA applications would be impacted by this
alternative due to changes to a portion of the current business processes
(i.e., scanning, indexing methods).
|
|
|
|
|
Filing Community Impact
|
The LDA and FD respondent
community would experience little impact as a result of this alternative.
|
|
|
|
Figure 5.19: Overall
Results of Qualitative Analysis (continued)
