ML20203M635

Informs Commission of Plans to Implement Revised Capital Planning & Investment Control (Cpic) Process.Proposed New Cpic Process Encl

ML20203M635
Person / Time
Issue date:	02/27/1998
From:	Galante A NRC
To:
References
SECY-98-032, SECY-98-032-R, SECY-98-32, SECY-98-32-R, NUDOCS 9803090186
Download: ML20203M635 (14)

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POLICY 'SSUli February 27. 1998 SECY-98-032 Thc Commis(onersnformation)

EQR FROM.

A.J. Galante Chief Information Officer

SUBJECT:

REVISED PROCESS FOR INFORMATION TECHNOLOGY CAPITAL PLANNING ANDINVESTMENTCONTROL PURPOSE:

The purpose of this paper is to inform the Commission of our plans to implement a revised Capital Planning and Investment Control (CPIC) process. The proposed new CPIC process is

attached, BACKGROUND:

The Clinger Cohen Act (formerly the Information Technology Management Reform Act or ITMRA) of 1996 required each Federal agency head to design and implement a CPIC process for evaluating information technology (IT) projects.

A proposed prototype process for the fiscal year (FY) 1999 budget cycle was detailed in a memorandum dated November 21,1996, from the Executive Director for Operations to Chairman Jackson. The prototype was approved in a memorandum dated January 8,1997, from Chairman Jackson to the Acting Chief Iniormation Officer.

DISCUSSION:

During the FY 1999 budget cycle, three major proposed IT projects (the Reactor Program l

System - RPS, PC Replacement, and the Agencywide Document Access and Management System ADAMS) were reviewed using the prototype CPIC process. Subsequently, the Office of the Chief Information Officer (OClO) staff solicited comments from participants in that process. And, in July 1997, OClO staff attended a Best Practices Workshcp in which 23 agencies shared their CPIC experiences.

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Contact:

NOTE:

TO BE MADE PUBLICLY AVAILABLE Francine F. Goldberg, OClO/PRMD IN 5 WORKING DAYS FROM THE DATE OF 301-415-7545 THIS PAPER

The Commissioners 2

Lessons Learned From NRC and Other Aaencies' Exoeriences From NRC experience, we learned the following:

Preparation of the CPlc analyses and reports was resource intensive and time e

consuming. Therefore, resources devoted to CPIC analysis should be scaled to the size and complexity of the proposed IT investment.

E The CPIC rev!aw period was lengthy, partially because each successive reviewing body e

asked for new alternatives to be evaluated.

The rJes and focus of reviewing bodies need to be better defined (e.g., both the IT Council and the Budget Review Group reviewed technical alternatives and budget issues).

in addition to forcing more discipline into the review of proposed projects, the process e

helped identify the true scope of proposed projects, required identification and comparison of alternatives, clarified interrelationships between IT systems, provided detailed information that allowed more accurate cost estimates, and assessed return on investment, project management, and technology risk, it is impractical to backfit, generate, or re-create CPlc analyses for IT investments that e

were begun before the NRC adopted a CPIC process. (Therefore, formal CPIC analyses will be required only for proposed attw IT investments with defined functional requirements, i.e., the selection phase in Office of Management'and Budget and General Accounting Office [OMB/GAO) guidance.)

Proposed IT investments in the concept phase need ' seed money' to define the scope e

and requirements of the project in order to prepare a CPIC analysis and to make a refined business case, Unless a proposed project has obtained a budget " placeholder" (e.g., STARFIRE, the o

new financial management system) or unless approved budget is reallocated, new projects receiving approval would normally wait up to 2 years for funds to begin design and development because of the budget cycle.

From the Best Practices Workshop, we leamed the following:

The maturity of NRC's CPlc process appears to be comparable to that at other agencies.

1 Nearly every agency and organization reported success in implementing portions of the o

CPIC ' Selection' or project concept phase.

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The Commissioners 3

Fewer agencies have made significant progress in the other two CPlc phases, that is, the ' Control" or project phase and the

• Evaluation" or operations phase.

Four of the seven major Government agencies making formal presentations stated that IT investment evaluations and comparisons were made at the program office levelin their respective agencies, that is, IT investments in one business area were not ranked against those in another area to generate an agency level prioritized list of IT investments.

Among the barriers to the successfulimplementation of a CPlc process, three were particularly noteworthy:

- Adopting overly complicated processes and reporting procedures

- Tendency to adopt a one s'ze fits-all process (lack of flexibility)

-- Failure to take decisive action on projects exceeding planned budget Princioles Underivina the Proposed New CPIC Process The proposed new CPIC process is based on the following principles:

Business / program requirements will drive IT investment decisions.

Business / program area leaders (i.e., project sponsors) will establish the priorities for the use of IT resources in their business areas.

Prior to entering into the CPIC process, proposed projects will be screened to ensure that the sponsor has considered ways to optimize efficiency and effectiveness of agency operations (i.e., process optimization).

Management review of a sponsor's proposed IT investment will focus on the business case (need), effective integration with other IT projects that support the same or related business processes throughout the NRC, and potential overlaps or interfaces with other users' requirements.

OClO review of a proposed IT investment will primarily focus on conformance with data and systems architectures, standards, costing, timing, systems integration, technology selection, redundancy, infrastrur 1re, and project management. OClO review will also ensure that business process op. liization and overlapping requirements are addressed by the sponsor before approval of the IT project.

The CPIC process will promote more discipline and accountability in the IT investment process without imposing an undue burden on the NRC program staff.

The Commissioners 4

Each project will have a Project Management Plan, which is an agreement between the e

ClO and the project's business sponsor on the scope, staffing, schedule (with milestones and deliverables), the budget, the use of dandards, the acquisition vehicle, and the performance goals of the project.

The business project sponsor will be empowered to manage the project within its Project Management Plan.

Summary of Chanaes in the Prooosed CPIC Process Based on Lessons Learned and Underivina Princiolet The proposed nev process continues to satisfy the law, addresses OMB guidance, and improves on the prototype process by Integrating the CPIC process with the NRC's planning framework by receiving e

information from and providing it to that framework at appropriate junctures, Streamlining the process and the documentation required.

e Replacing the IT Council with an information Technology Business Council (ITBC) having authority to make binding decisions on proposed IT investments to

- Eliminate overlap of multiple review bodies, and

- Place review authority with individucts knowledgeable about NRC's business needs, and IT systems and architecture Using the project or control phase cost rather than life cycle cost as the criteria for e

determining the amount of documentation and the level of review

- Project phase is where cost overruns, due to changes in requirements and schedule slippages (factors which can be managed), typically occur, and

- Life cycle cost estimates are difficult to estimate at the project screening phase (however life cycle costs will be estimated in the CPIC analysis of alternatives)

Using an estimated project cost of $500K as a threshold e

-- CIO initial review and abbreviated CPIC analysis if less than $500K

- lTBC Initial review and indepth CPIC analysis if $500K or greater Defining the following three steps for the selection phase of the process if estimated e

project phase cost is $500K or greater. (See Figure 1 for project cost less than $500K)

Steo 1 - Project Ccreenina

- The ITBC screens the proposed project and either rejects it or gives the sponsor the go-ahead to scope the project and to begin the CPIC analysis

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The Commissioners 5

Sten 2 - CPIC Rayimt The ITBC and the ClO review the CPIC analysis and Project Management Plan to determine whether the proposed project is ready for Executive Council (EC) review or the project is rejected due to a weak business case, and/or too high a risk level with little or no offsetting benefit to the NRC Steo 3 EC Review

- If approved by the EC, the pro. lect funding is requested through the normal budget process Placing accountability with the business project manager during the control or project e

phase. (An IT investment proposal becomes a.pfpkqt when its functional requirements are identified and it has been approved to proceed, is funded with a project team in place and a project workplan riefined. It remains a project until al! work is completed and the system is operational.)

Requiring that if at any point in its development, in the view of the business or technical e

project managers, the project cost is going to exceed 5 percent (as opposed to OMB's reporting requiiement for a variance of 10 percent) of the cost estimated at project initiation, the project enters the variance category.

Requiring that lower cost projects be stopped pending consideration of the need for an e

indepth CPIC analysis if the variance would put them over the $500K threshold.

Requiring that business sponsors of projects in the variance category ask the EC (or CIO if project is less than 5500K) for approval to continue and additional furids from the Chief Financial Officer (CFO), before the anticipated cost overrun occurs.

Establishing an IT application systems investment fund to provide interim funding for high priority projects with an approved business case (requirements analysis, CPIC l

alternatives analysis, and project management plan). The fund will provide startup l

funding for s'1 approved project to begin development during the period when sponsor.

provided seed money is exhausted and money is not yet available through the budget process. The ClO in consultation with the CFO will make a recommendation for the amount of the fund. The recommendation will be based on proposed projects identified in the IT planning call and historical experience at the agency and will be reviewed during the normal budget process. We anticipate that the size of the fund would be on the order of $2 3M. Monies from the fund will not be released for use until a project is approved via the CPIC process.

CoordinatioD The Chief Financial Officer has reviewed this Commission Paper for resource implications and has no objections. This paper has been coordinated with the Executive Director for Operations who has no objections. The Office of the General Counsel (OGC) has reviewed this paper and has no legal objections (see Enclosure 3, which reflects OGC guidance).

b The Commissioners 6

Next Steos We plan to proceed to modify the CPIC guidance and to implement the new process within 10 working days of tho date of this caper. We plan to have the NRC CPIC process peer review by the ClO Council's Capital Planning subcommittee as part of its planned assessment of agency implementation of capital planning guidancs. The CPIC procedures will be refined to reflect feedback from this peer review, if appropriate.

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. lfde:@

A.J.

at te Chief n ormation Officer

Enclosures:

1, The Proposed NRC Capital Planning and Investment Control Process (CPIC)

2. IT Project Proposal Screening Form

3. Specific Procedures Addressing Clinger Cohen Act Section on

• Content of Process' DISTRIBUTION Commisaioners OGC OCAA 01G OPA OCA CIO CFO EDO REGIONS SECY

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Encl:sure 1 The Proposed NRC Capital Planning and Investment Control Process (CPIC)

This documerit describes the Capital Planning and Investment Control (CPIC) process for a proposed new project. Figure 1 is a graphical representation of the pmcess, 1

i PROCESS TRIGGERING ACTION -IT PROJECT PROPOSAL SCREEWG FORM SUBMISSION A sponsoring organization identifies a business need for a proposed information technology (IT)investroent and completes and submits to the Office of the Chief Information Officer (OClO) an IT Project Proposal Screening Form (see Enclosure 2).

Initial Screenina by OClO The OClO uses the Screening Form to make a preliminary determination as to whether the sponsor has compared NRC business practices and operations with *best practices' 5 other agencies and consiciered ways to change agency operations to improve efficiency and effectiveness. If these background activities have not been accomplished, the OClO returns the proposal to the sponsor.

The OClO uses the Screening Form to determine whether the proposalis reviewed by the information Technology Business Council (ITBC) or the OClO and whether a more in-depth or an abbreviated CPIC analysis is required. This determination is based on a preliminary cost estimate of the proposed investment's project phase. (An IT investment proposal becomes a project (i.e., enters the project phase) when its functional requirements are identified, it has been approved to proceed, is funded, with a project team in place and a project workplan defined, it remains a project until all work has been corrpleted and the system is operational.)

NEXT STEPS IF PROJECT COST GREATER THAN $500,000 Concent/ Selection Phang Steo 1 - Review of Screenina Form The ITBC reviews the ScreeninD Form to verify that the sponsor has compared the NRC business process with best practices and considered process reengineering. If so, the ITBC continues the review of the form to evaluate the business case for the concept. The ITBC reviews the proposed investment from an overall agency perspective, including agency operations and process optimization, the business need, and overlap, duplication, and integration with other existing or planned application systems supporting related business processes throughout the agency. (The ITBC review is basically at a conceptual level.)

if the ITBC determines the proposed investment has value for the NRC, the sponsor e

allocates money from its budget (seed money) to scope the project and begin the CPIC process. The CPIC process inc!udes defining requirements; identifying alternatives; identifying appropriate commercial off the-shuf application software (if available);

estimating the life cycle costs (based on 5 years of operations), benefits, and risks of

a project under all alternatives' and developing (in conjunction with the OClO) a i coject Management Plan. (The Project Management Plan includes staffing, the schedule (with m!!estones and deliverables), the budget, the use of standards, the acquisition vehicle, and the performance goals of the project.)

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2 St% -CPIC Analy115 2

The final CPIC cn: lysis is revtw;d by the ITBC cnd the OClO. OClO revi:w of a proposed IT investment will primarily focus on conformance with data and systems e

architectun,s, standards, costing, timing, systems integration, technology selection, redundancy, infrastructure, and project management. OClO review will also ensure that business process optimization and overlapping requirements are addressed by the sponsor.

If the ITBC supports the CPIC analysis and alternative recommended, and the ClO agrees that the alternative is consistent with data and systems architectures, standards, etc., the project (via the CPIC analysis) is presented by the business sponsor to the Executive Council (EC) to request the go ahead to " benin" the project phase.

SLco 3 EC Acoroval If approved by the EC, a project is given the go ahead and funding is requested through the normal budget process Appropriate output measures and targets for the project are identified Project / Control Phase Once an IT investment receives funding, the CIO determines whether to recommend to the Chairman and the Commission that it be reported to the Office of Management and Budget (OMB) as a major system in the annual NRC Performance Plan Criteria for determining whether the IT investment should be reported include the magnitude of the project phase cost, the estimated life cycle cost, risks, whether the resulting system would be critical to the NRC mission, and whether the resulting system would have a significant role in the administration of agency programs, finances, property, or other resources.

Once a project is underway, the business project manager will report progress on project performance goals (cost, schedule, and capability to meet specified requirements)in the appropriate program operating plan and provide periodic reviews to the EC. (This effort is supported by the Office of the CIO.)

if at any point in its development, in the view of the business and the technical project e

managers, the project development cost is going to exceed 5 percent of the cost estimated at project initiation, the project enters the variance category. Sponsors of projc ts in that category must explain the issues involved causing the expected overrun to the EC, request approval from the EC to continue, and request additional funds from the Chief Financial Officer, befre the cost overrun occurs.

Qagrational/ Evaluation Phalt Once an IT investment leaves the project phase and becomes operational, the CPIC project sponsor will begin to measure program improvements.

Within six months after the system becomes operational, the sponsor will compare onginal project goals (costs, schedule, and capability to meet specified requirements),

projected program benefits, and risks against the actual project experience and prepare a sumrr ary of lessons leamed. Lessens learned will be used to improve the CPIC

3 process and as guidance for managers of future projects.

PROJECT COST LESS THAN $500.000 Proposed IT investments with estimated project costs of less than $500,000 would need the CIO's approval. The CIO has the discretion te :isk the ITBC to review these proposed IT investments. As shown in Figure 1, such projects would require less documentation and fewer reviews. Sponsnrs of projects in the variance category must ask the CIO for approval to continue (pending additional funds being made available by the sponsoring office), before the cost overrun occurs. These projects will be stopped pending the consideration of the need for ar. r-depth CPIC analysis if the variance would put them over the $500K threshold.

e Role and Resoonsibilities of the Chairrnan and the Commission in the CPIC Process The Chairman, in eccordance with the Clinger-Cohen Act, reports yearly to OMB any significant variance from project cost, performance, or schedule goals established for major IT investments. (OMB's Circular A -11 defines significant variance as 10 percent or more deviation from the baseline project phase costs initially reported.)

The Cc' mission would review and approve the major projects reportable to OMB as part of its review os the annual NRC Performance Plan.

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4 Proposed IT Project Review Framework Triggering Action-Sponsor prepares and submits IT Project Proposal Screening Form to OClO for initial screening. Review path then determined by the estimated project cost.

l Y

Y Project Cost (less than $500.000)

Project Cost (areater than $500.00.Q)

OClO reviews project outline ccntained in ITBC reviews project outline contained in Proposal Screening Form Proposal Screening Form V

V Sponsor allocates seed money Sponsor allocates seed money Sponsor scopes project Sponsor scopes project Sponsor and OClO develop Project sponsor and OClO develop Project Management Plan Management Plan Sporisor prepares abbreviatec1 CPIC Sponsor prepares CPIC analysis analysis Y

Y OClO reviews CPIC analysis ITBC reviews CPIC analysis Y

Y OClO provides input on CPIC analysis Y

Sponsor presente project (CPIC) to the EC Y

CIO approves project or, may EC reviews project request ITBC review Y

Y If approved, project funding is requested if approved, project funding is requested through nc,rmal budget process through normal budget process Y

Y Business project manager manages project Busi%ss project manager manages project within Project Management Plaa within Project Management Plan Y

Y Exceptions to plan or 5 percent ce=+

Exceptions to plan or 5 percent cost I

overrun require OClO approval to overrun require EC approval to continue continue & funds provided by spon.

& additional funds from CFO

o Encl sure 2 (Februiry 9,1998)

IT PROJECT PROPOSAL SCREENIN'3 FORM s-Purpose of this form: To provW information to the CIO and the Information Technolcgy Business Council (ITBC) for screening proposed information technology projects to determine whether tney merit further analysis to develop a business case (i e., requirements identification, attematives analysis, and Project Management Plan) Proposals with estimated project phase costs of less than $500K will be reviewed by the ClO. Those with estimated costs greater than $500K will be reviewed by the ITBC.

Projects covered by this procer s include new application systems, major modification to existing application systems, and modifications to local and agencywioe IT infrastructure. Single-user personal productivity applications, scientific codes, and any associated high-performance computing equipment are not included. Sponsors of proposed IT projects should submit completed forms via memorandum from their Office Director to the CIO at any time during the year. (An electronic copy of the submission to the ClO should be sent to John Sullivan (JAS2).) Assistance in completing this form is available ' rom John Sullivan (415-5857, e-mail JAS2).

Sponsoring' Office:7 Contact Name/ Phone::

Project TitleE N

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MISSION NEED:

What are the business needs, both internai and extemal, that are driving this project? How do they relate to the Commission's mission, strategic plan and performance plan? What specific goals and measures will this project support? List the primary benefits of the project. How is it expected to improve mission / program / operational performance?

PROJECT OBJECTIVES:

What are the principal objectives of the project?

PROCESS BENCHMARKING AND REDESIGN:

Describe background and project preparato y activities conducted to date. Which of the following have been accomplished: (a) Benchmarking - comparison of NRC business practice and operations with "best practices" in other organizations? (b) Process optimization -

consideration of ways to change agency operations to improve efficiency and effectiveness?

INTEGRATION WITH BUSINESS AREA PLANS:

What business areas, functions, and processes does the proposed projset support? (Please identify on page 3.) What is the relationship of the project to current plans for the business arca as a whole, i.e., what is the relationship of the proposed project to other existing or planned applications systems? What existing systems, if any, will the new system replace? What are the plans for integration and data sharing with other systems? What involvement is needed by other offices, including both offices that will create data for the system as well as offices that will use the system to conduct their business?

USERS:

If the project would create an application system, which offices would use the system? Would the regions use the system? Ww many of the agency's staff would have access to the system? Would the public have access to the system?

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INFRASTRUCTURE IMPACT:

What IT infrastructure needs (PC capabilities, telecommunications, etc.) are associated with this project and when are these capabilities needed? Highlight any needs for infrastructure i

upgrades (e.g., telecommunications upgrades, software not currently on the LAN) that exceed currently planned and scheduled infrastructure capabilities.

STAFFING:

If a proposed IT project is approved and funded, is the office prepared to manage it on a full-time basis? What office plans have been made for providing a project manager and recessary staffing for detailed requirements analysis, prototyping, testing, etc.? What staff support is needed from OClO and when?

ACQUISITION PLANS:

What IT equipment, software, and development service purchases are anticipated and what general acquisition approach is planned? Have you explored whether a commercially available "off-the-shelf" application might satisfy your requirements or do you intend to develop a customized application? If acquisition vehicles other than those tvailable through OClO are anticipated, the office should highlight these.

SECURITY REQUIREMENTS:

Would the project create an application system that processes classified or sensitive data?

(See definition in the glossary of Management Directive, Volume 12, Security)

PRELIMINARY ESTIMATED COST FOR PROJECT PHASE:

What is the estimated cost category of the Project Phase of the proposed IT investment? (An IT investment proposal becomes a project when its functional requirements are identified, has been approved to proceed, is funded, has a project team in place, and has a project workplan defined, it remains a project until it becomes an installed operational system). Cost categories are (1) Less than $500K, (2) $500K to $1M, (3) Over $1M but less than $3M, and (4) $3M or more.

ESTIMATED SEED MONEY:

Assuming the proposed project is approved to proceed, what is the estimated amount of seed money that will be required to prepare the business case for the project? Primary elements of the business case are (a) identify and define requirements, (b) identify potential solution together with several alternatives (including the status quo), (c) estimate the life cycle costs, benefits, and risks of each attemative, and (d) prepare, together with the OCIO, a detailed Project Management Plan with staffing, budget, schedule, milestones, and performance goals.

Note that projects with estimated development costs of less than $500K will require an abbreviated business case, appropriately scaled to the size of the project.

3 DEFINITIONS:

4 A? PLICATION SYSTEM: Computer hardware, software and procedures designed to capture, store, manipulate, retrieve and report data!information. (excludes scientific codes and single-user personal productivity applications),

NEW APPLICATION SYSTEM: Automation of a manual process or changes to an existing applicaticn significent enough to require a complete system rewrite.

MAJOR MODIFICATION TO AN APPLICATION SYSTEM: Chariges to an existing application system, hardware or software, that go far beyond slight adjustments to the functionality. Adjustments including significant equipment and/or hardware changes or many data element 9, reports, queries and process changes would be considered major.

Adding, deleting or changing a few data elements or a few reports / queries would be considered a minor enhancement or maintenance.

INFRASTRUCTURE: Includes hardware, software, services, equipment, and components necessary to support local and enterprise-wide information technology requirements. This includes desktop systems, customer service, network components and services, telecommunications components and services, operational support, and maintenance.

PLEASE CIFICLE THE BUSINESS FUNCTION (S) THE PROPOSED PROJECT SUPPORTS Extemal Assistance MISSION-RELATED BUSINESS AREAS Coordination with Extemal Organizations MANAGEMENT DIRECTION AND OVERSIGHT SUPPORT BUSINESS AREAS Providing Direction FINANCIAL MANAGEMENT

• "" "9 Program Direction Mon t ring and Evaluation Budget Planning Management p

COMPLIANCE MANAGEMENT Accounting Program Direction Review / Audit Planning Inspections and Investigations Performing Inspections and Investigations HUMAN RESOURCES MANAGEIGNT Documenting Inspections and Investigations frogram Management Performing Enforcement deemiting, Hiring, Selection Managing Compensation LICENSING / APPROVAL Managing Staff Utilization Program Direction Providing Organization Management Receiving Application Manag!ng Workplace Environment Performing Technical Review Managing Labor-Management Relations Performing Legal / Adjudicatory Review Providing Staff Tra:ning and Development

• "

• 9 INFORMATION RESOURCES MANAGEMENT IDENTIFYING AND ASSESSING SAFETY Program Direction CONCERNS IT Infrastructure Program Direction information Systems Scoping Concems Infowlon Management Obtaining / Communicating information Re anagement Ta n ion FACILITIES AND PROPERTY MANAGEMENT Program Direction RULEMAKING Facility Operations Program Direction Property Operations Dev op Rulemaking/ regulatory ACQUISITION MANAGEMENT Formulating Initial Package Program Direction Formulating Subsequent Packages Planning Acquisitions Pre-Award Process EXTERNAL AFFAIRS Award Process Program Direction Post-Award Administration Information Collection Information Transmis fon/ Notification Representation

4 Specific Procedures Addressing Clinger-Cohen Act Section on " Content of Process" This enclosure addresses elements of the Clinger-Cohen Act identified by the Office of the General Council as not being explicitly covered in the Commission Paper or Enclosure 1. Note that the references are to th? Steps identified in Enclosure 1, "The Proposed NRC Capital Planning and Investment Control Process."

Procedures to be included in the document providing detailed guidance for implementing the Capital Planning and Investmera Control process are as follows:

The CPIC process for a proposad investment as identified in Step 1 - Proje..:t Screening. shall include a determination by the project sponsor as to whether the investment would result in shared benefits or costs for other Federal agencies or State or local governments.

The CPIC process for a proposed investment shall identify quantifiable measurements including costs, staff resources, and risks. When feasible and meaningful, the CPIC process shallidentify quantifiable measurements of benefits. The CPIC process shall also identify qualitative benefits.

The CPIC process for a proposed investment shall identify minimum evaluative criteria e

for consideration, including projected net, risk-adjusted return on investment, to the extent to which it is deemed practical, feasible, and could be meaningfully applied.

Procedure to be included in a Charter for the Information Technology Business Council:

in Step 2 - CPIC Analysis, the information Technology Business Council (ITBC) shall e

apply any criteria developed during Step 1 of the initial phase of the CPIC process, including the quantifiable and qualitative measures, when considering whether to recommend the undertaking of a particular information technology investment. To the extent to which it is deemed practical, feasible and they can be meaningfully applied, the ITBC shall consider these same criteria when comparing attemative information technology investments in a specific businees or proqram area.

(Note that prioritization of information technology investments will occur during the budget formulation process when all proposed expenditures are evaluated in terms of their contribution to meeting NRC's mission subject to tha availability of funds).