By GAO named the 11 federal legacy systems most in need of modernization in July 2025 and found that plans for 8 of them were not fully documented. Seven agencies, DoW and HHS among them, now hold recommendations to write plans with milestones, the work, and the legacy system's disposition.
In July 2025, GAO published Information Technology: Agencies Need to Plan for Modernizing Critical Decades-Old Legacy Systems (opens in a new tab) (GAO-25-107795). It reviewed 69 legacy systems and named the 11 most critical, held by 10 agencies. GAO withheld the system names for sensitivity and used numbers instead.
Drawing on GSA's Modernization and Migration Management (M3) Playbook, GAO said a documented plan should include, at a minimum, milestones to complete the modernization, a description of the work, and details on the disposition of the legacy system. Plans for 8 of the 11 weren't fully documented. Two systems, at DoW (formerly DoD) and Energy, had no plan at all.
| Plan status (milestones, work description, legacy disposition) | Agency (system) |
|---|---|
| All three documented | DHS (6), Interior (7), EPA (11) |
| No plan | DoW (3), Energy (4) |
| Partial on all three | Commerce (2), HHS (5) |
| Mixed | Agriculture (1), Transportation (8), Treasury (9, 10) |
In the mixed group, Agriculture and Transportation documented milestones but not the work, and only partly addressed the legacy system's disposition. Treasury's System 9 had no disposition at all, and System 10 was partial on milestones and disposition.
In the sensitive version, GAO made eight recommendations to seven agencies: Agriculture, Commerce, Defense, Energy, HHS, Transportation, and Treasury. Each asks for a plan that covers all three elements.
GAO asked for the same thing six years earlier. Its 2019 review, GAO-19-471 (opens in a new tab), found that only Interior's and Defense's plans for that year's 10 most critical systems contained all three elements. Of those 2019 systems, only 3 were modernized by February 2025.
Plans go stale. DoW had a 2015 plan for System 3, a 60-year-old contract management system, that was never implemented. Energy said its October 2023 proposal was no longer viable. HHS had no updated plan reflecting System 5's new 2035 completion date.
Seven of the eight systems with incomplete or missing plans reportedly have modernizations underway anyway. The 11 systems range from about 23 to 60 years old and together cost about $754 million a year to operate and maintain.
GAO warns that undocumented plans raise the likelihood of cost overruns, schedule delays, and project failure. Any program office holding one of the eight recommendations has to produce a plan GAO will accept, and the contractors around that system feed it.
A sustainment recompete will ask how the offeror keeps the system running while the agency plans its exit, and a modernization already in flight needs the missing milestones and disposition written down. The incumbent sustainment contractor usually holds the dependency maps, batch schedules, and interface knowledge that the plan has to draw on.
DoW concurred with its recommendation; HHS neither agreed nor disagreed. Either way, a technical volume that shows how the three elements get documented, and who signs off on each, answers the finding directly.
This is the assessment-and-roadmap work in Avalon's Application Modernization service, described at the methodology level. It runs in the agency's own repositories and tooling, in unclassified environments, and produces the three elements GAO checks.
For COBOL and Assembly stacks like Treasury's, the plan names the disposition and milestones; transforming mainframe code is specialist work outside this scope.
GAO's own table shows the standard. DHS, Interior, and EPA documented all three elements for Systems 6, 7, and 11, with planned completion dates of September 2026, August 2027, and December 2028.
For the eight recommendations, these are targets:
GAO's Matter for Congressional Consideration, to require major agencies to develop modernization plans for these systems, was open as of GAO's last update, February 2026, with no legislative action yet. The eight agency recommendations sit in the sensitive version, and gao.gov does not publish their status.
| Field | Detail |
|---|---|
| NAICS | 541512, 541511 |
| Avalon's sub role | Legacy system assessment, evidence-scored disposition, milestone roadmap with reauthorization checkpoints, and decommission plan under the prime's sustainment or modernization task order |
| Small-business status | Small business; HUBZone (in progress) |
| Likely vehicles | GSA MAS (SIN 54151S IT Professional Services); GSA Alliant 3; GSA OASIS+ |
If sustainment or modernization of a DoW or HHS legacy system is in your capture plan, Avalon teams as the sub that writes the milestones, work description, and disposition GAO says the plan is missing.
