DHS data-migration guidance falls short as modernization project nears

The Department of Homeland Security has a couple of units readying plans for an overhaul of its financial management systems, but lagging best practices are putting the project at risk, according to a report published Monday by the Government Accountability Office. 

DHS has already migrated the Coast Guard’s systems and plans to use lessons learned to inform what’s up next: the Federal Emergency Management Agency and Immigration and Customs Enforcement. Despite the goals and prior experience, the watchdog’s audit found that DHS guidance and planning documents “varied in consistency.”

Notably, financial management systems are at the intersection of the two remaining high-risk areas for DHS — IT and financial management — as designated by GAO after the watchdog narrowed its focus in 2023 following “substantial progress” by the agency in other functions. 

To conduct the audit, GAO members met with DHS officials and compared guidance and plans — with leading practices from October 2024 to May 2026 — for the report. “Leading practices” included the General Services Administration’s Modernization and Migration Management Playbook and a white paper from 2002 on financial systems data-conversion considerations. 

“We found that DHS’s guidance was partially consistent with pre-conversion and cutover activities but not consistent with post-installation activities,” GAO said of the agency’s data migration guidance. 

Some of the missing pieces included a lack of information on risk management processes, criteria for cleansing data, data governance documentation and archival processes. 

“DHS’s FSM programs using DHS guidance to develop data migration plans are at increased risk of data errors, time needed to resolve errors, potential delays, and potential increased costs,” GAO said in the report. 

The clock is ticking for DHS to ameliorate the situation. FEMA is planning a midyear conversion to the new system in an attempt to mitigate disruption during the emergency management season cycles. The timeline will also help DHS detect and correct errors in the system before the end of the year, according to the report. A mock conversion will begin this quarter. GAO did not include a start date for ICE’s migration. 

Both FEMA and ICE plan to have their system integrators conduct early and consistent hands-on testing, per the report. GAO still has concerns, however, about how the components plan to follow through on what’s uncovered during the testing process. 

“We previously reported that DHS risked not fully achieving its goal of deploying systems that produce reliable data for management decision-making and financial reporting if it did not remediate serious issues identified by testing,” GAO said. “At the time of issuing this report, similar recommendations are still open for FEMA and ICE.”

GAO recommended that DHS leaders work to update agencywide data migration guidance and documentation, among other measures to increase the likelihood of success. DHS concurred with the recommendations.