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Systems and Data Conversion for the New Financial EnvironmentJune 2005
DOF appreciates the ongoing review work performed by the OIG and its recommendations to enhance the success of our New Financial Environment (NFE) implementation effort. In addition, we welcome the opportunity to provide comments to this draft report on NFE data conversion even though no specific audit recommendations were provided. We are pleased to note that the NFE core financials component (consisting of 14 PeopleSoft modules/tools of functionality and 23 legacy systems renovated to accommodate changes brought about by NFE) of our overall project went into production on May 2, 2005. With a full month of operations now behind us, we are beginning to settle into normal operational routines in most business areas as users become more familiar with the new system and its accompanying business processes. Recognizing from the project’s beginning the critical importance of data conversion to the successful operation of NFE and its supporting systems, the NFE project placed a high priority on ensuring that our data conversion approach was methodical and disciplined, and that our intended data conversion results were achieved. Our conversion activity planning and execution, coupled with the active involvement of data owners from the impacted business areas in planning, testing, and validation, provided us with a high degree of confidence that the conversion of identified data from legacy systems into the NFE environment would result in minimal and manageable operational disruption and conversion errors. We also recognized that no conversion effort, especially one of this magnitude (not just with the number of systems involved, but in the dramatic changes to the FDIC’s accounting control codes and expanded cost management codes), should be expected to be error-free, and that some post-conversion clean-up work would be needed. The draft report identified several reservations associated with the NFE data conversion activities and further identified all but one of these reservations as high risk. As noted above, we believe our conversion approach was well-planned and well-executed. Post-implementation, as expected, we are addressing pockets of data clean-up and negative operational impacts, but these cases are isolated to specific data components. Where known data conversion weaknesses existed, such as with the purchase order conversion, manual controls and actions were put in place to minimize the risks these weaknesses posed to the Corporation. OIG also included in this draft report a reservation associated with NFE’s performance testing. NFE performance testing was planned and executed after taking into account several critical factors, including the performance requirements from the statement of work, known PeopleSoft performance concerns, prior experience of Accenture with other PeopleSoft financials installations, and the distinct business and technical characteristics of the FDIC PeopleSoft installation. Additionally, performance testing was conducted after a full month of user acceptance testing and six months of systems integration and independent testing, in which actual system performance was observed and monitored to further assist the NFE team in focusing its test approach on higher risk areas. Tuning of some functions has continued during the period immediately following implementation in those few situations where on-line response time or batch throughput was found to need improvement. Such post-implementation adjustments are typical and were anticipated by the NFE team. Nevertheless, after several weeks of operation, NFE has been used successfully to conduct FDIC’s financial operations without experiencing major or persistent performance problems. As with any major new implementation, this process is expected to continue for several months, but no interruptions or delays in service are anticipated. As evidenced by the ultimate termination of this planned audit on April 6, 2005, the timing of the OIG audit of NFE’s data conversion efforts was such that our implementation team could not devote the time and attention needed to sufficiently guide the audit team through our planning, execution, and validation work. This audit began in late January/early February of 2005; the OIG’s audit of NFE testing, which began in mid-November 2004, was still underway (OIG Assignment No. 2005-008), and the draft report/recommendation from the OIG’s audit of NFE’s management controls (OIG Audit Report No. 05-007) was still outstanding with management for response. The timing of this additional review of NFE conversion work was less than optimal as the entire NFE project team was necessarily focused on completing User Acceptance Testing, executing and validating the final pre-implementation conversion testing, and planning for, and executing, our implementation tasks in anticipation of our May 2, 2005 go-live date. We appreciate that OIG recognized the burden that this data conversion audit was imposing on the project, and in light of the circumstances, OIG’s decision to terminate the audit in order to allow higher priority work to continue uninterrupted was appropriate. Thank you for the opportunity to comment on your draft report. If you have any questions regarding our response, please contact Karen Hughes at (202) 416-7201.
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