U.S. Department of Labor
Office of Inspector General
Audit Report
STREAMLINING THE ERISA FILING ACCEPTANCE SYSTEM
(EFAST) AND DEVELOPMENT OF THE ENFORCEMENT
MANAGEMENT SYSTEM (EMS)
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Report Title: Streamlining the ERISA Filing Acceptance
System and Development of the Enforcement Management System
Report Number: 17-98-001-12-001
Issue Date: March 27, 1998
The OIG continues to provide PWBA with audit assistance on the following
two system development initiatives:
1.
the Employee Retirement Income Security Act (ERISA) Filing Acceptance System
(EFAST) and
the associated task to redesign/revise the Form 5500 series for annual
reporting; and
2.
the Enforcement Management System (EMS) development to improve information
collection and
reporting on enforcement outcomes.
At the conclusion of our fieldwork, PWBA and OIG agreed on a number
of actions that PWBA must take to ensure the overall success of the
streamlining effort including:
-
evaluating the proposals submitted by contractors for the design and development
of EFAST and award contracts by June 1, 1998, so that the system can be
operational in time to handle the first Form 5500s that will be received
July 1, 2000. PWBA also needs to develop an EFAST contingency plan in order
to be prepared for the possibility that the EFAST system may not be completed
on time or fail to meet system requirements.
-
reviewing the oral and written comments provided by the public and announce
by mid-May the data elements of the new Form 5500 so that plan administrators
and service providers can make necessary adjustments to their management
information systems. Publish in the Federal Register, the final
computer-scannable Form 5500 with the electronic filing option by November
1998.
-
asking the Department's Solicitor to make a top priority of issuing
an opinion on the legality of mandating electronic filing of Form 5500s
under current ERISA legislation. PWBA requested the opinion on October
6, 1997. The OIG suggested that PWBA consult with its stakeholders
to learn the cost and potential impact that phasing in electronic filing
over a 5-year period and mandated electronic filing of Form 5500 would
have on the regulated community. OIG has previously expressed concerns
on this issue.
Because of additional programming requirements, the cost of EMS has risen
by $483,905 from $1.21 million to $1.69 million. In order to minimize risk
of cost overruns and maximize design efficiency, PWBA needs to:
-
Establish a new time table and provide appropriate individuals with information
outlining when EMS will be operational, including a schedule for designing,
developing and testing the new system.
-
Carry out system integration testing from March through May 1998. End user
testing will occur from June through August 1998.
-
Establish as a priority for the development team the requirement that test
plans be completed by the end of April 1998.
-
Ensure that all EMS data elements will be available for retrieval in the
new system and the EMS will be fully capable of generating reports to meet
GPRA requirements.
The OIG will continue to work with PWBA on its design, development and
implementation of the EFAST, the revisions to the Form 5500 series, and
the EMS. OIG will provide independent insight and expertise in the
assessment of PWBA's information technology plans and investments.
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