Federal Law Enforcement Training Center
Capacity Planning and Management Oversight Need Improvement Gao ID: GAO-03-736 July 24, 2003The Federal Law Enforcement Training Center (FLETC) provides federal law enforcement training for 75 Partner Organizations (agencies) primarily at four domestic facilities located at Glynco, Ga; Artesia, N. Mex.; Charleston, S.C.; and Cheltenham, Md.. Given the post-terrorist attack security environment, coupled with the increased demand for training, concerns have been raised about FLETC's continued ability to meet this training demand. Because of these concerns, GAO was asked to issue a report on (1) how FLETC plans to meet the projected demand for training; (2) FLETC's ability to efficiently coordinate and schedule training activities; and (3) whether oversight and governance structures provide the guidance it needs to address its capacity and planning challenges.
FLETC's overall capacity to provide training at the Glynco and Charleston campuses is currently strained, while Artesia has been underutilized, and Cheltenham is being upgraded and cannot operate at full capacity. FLETC is developing a Master Plan to address how to overcome the long-term capacity challenges, but questions exist regarding the assumptions and methodologies used, contingency planning, cost estimation and budgeting, and the need to address capacity shortfalls sooner than planned. Department of Homeland Security officials intend to review the new department's training needs and capacities, and update the plan to reflect its vision for law enforcement training. Within the context of its strained training capacity, FLETC uses a predominantly manual scheduling process that does not ensure the efficient use of training resources and poses internal control risks due to potential loss of scheduling materials and the lack of backup documentation. Although FLETC has begun the process to acquire a fully automated scheduling system, FLETC officials have yet completed important risk management activities and are not using recognized best practices for acquiring commercial off-the-shelf-based systems associated with this type of acquisition. Furthermore, FLETC's solicitation activities have not adequately addressed security requirements. FLETC faces additional challenges regarding its governance structure in that the status of FLETC's Board of Directors is unclear, and its membership, roles and responsibilities, and past practices are not fully consistent with prevailing governance best practices.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-736, Federal Law Enforcement Training Center: Capacity Planning and Management Oversight Need Improvement
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Report to Congressional Requesters:
United States General Accounting Office:
GAO:
July 2003:
Federal Law Enforcement Training Center:
Capacity Planning and Management Oversight Need Improvement:
GAO-03-736:
GAO Highlights:
Highlights of GAO-03-736, a report to Congressional Requesters
Why GAO Did This Study:
The Federal Law Enforcement Training Center (FLETC) provides federal
law enforcement training for 75 Partner Organizations (agencies)
primarily at four domestic facilities located at Glynco, Ga; Artesia,
N. Mex.; Charleston, S.C.; and Cheltenham, Md.. Given the post-
terrorist attack security environment, coupled with the increased
demand for training, concerns have been raised about FLETC‘s continued
ability to meet this training demand. The visual below demonstrates
the sharp increase since the September 11, 2001, attacks. Because of
these concerns, GAO was asked to issue a report on (1) how FLETC plans
to meet the projected demand for training; (2) FLETC‘s ability to
efficiently coordinate and schedule training activities; and (3)
whether oversight and governance structures provide the guidance it
needs to address its capacity and planning challenges.
What GAO Found:
FLETC‘s overall capacity to provide training at the Glynco and
Charleston campuses is currently strained, while Artesia has been
underutilized, and Cheltenham is being upgraded and cannot operate at
full capacity. FLETC is developing a Master Plan to address how to
overcome the long-term capacity challenges, but questions exist
regarding the assumptions and methodologies used, contingency
planning, cost estimation and budgeting, and the need to address
capacity shortfalls sooner than planned. Department of Homeland
Security officials intend to review the new department‘s training
needs and capacities, and update the plan to reflect its vision for
law enforcement training. Within the context of its strained training
capacity, FLETC uses a predominantly manual scheduling process that
does not ensure the efficient use of training resources and poses
internal control risks due to potential loss of scheduling materials
and the lack of backup documentation. Although FLETC has begun the
process to acquire a fully automated scheduling system, FLETC
officials have yet completed important risk management activities and
are not using recognized best practices for acquiring commercial off-
the-shelf-based systems associated with this type of acquisition.
Furthermore, FLETC‘s solicitation activities have not adequately
addressed security requirements. FLETC faces additional challenges
regarding its governance structure in that the status of FLETC‘s Board
of Directors is unclear, and its membership, roles and
responsibilities, and past practices are not fully consistent with
prevailing governance best practices.
What GAO Recommends:
GAO recommends that the Secretary of the Department of Homeland
Security improve capacity planning, periodically assess the condition
of training facilities and infrastructure, improve the acquisition
process for an automated scheduling system, and enhance the governance
and oversight capabilities of FLETC‘s Board of Directors. The
department and FLETC generally concurred with GAO‘s recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-03-736.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Richard M. Stana, 202-
512-8777, Stanar@GAO.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
FLETC's Training Capacity is Strained, and Its Planning for Adding
Capacity Raises Concerns:
FLETC's Current Scheduling System Is at Risk and Its Acquisition of an
Automated System Raises Concerns:
The Status of FLETC's Board of Directors Is Unclear, and DHS Has Begun
to Provide Oversight and Guidance:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Capacity, Planning, and Coordination:
Scheduling and Coordination of Training Activities:
Governance and Oversight Structure and Guidance:
Appendix II: FLETC's 75 Partner Organizations:
Appendix III: Training Programs and Seminars Provided by FLETC:
Appendix IV: Comments from the Department of Homeland Security:
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgements:
Tables:
Table 1: Capacity and Demand at the FLETC Campuses (in student weeks):
Table 2: Potential Campus Capacities Following Completion of Phase I
Master Plan Projects (in student weeks):
Figures:
Figure 1: Various FLETC Training Activities:
Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004
Budget Request:
Figure 3: Partner Organization Training Projections Compared to Current
Combined Campus Optimum Capacity (in student weeks):
Figure 4: FLETC Campus at Artesia, New Mexico:
Abbreviations:
ACMS: Academy Class Management System:
ATF: Bureau of Alcohol, Tobacco, Firearms and Explosives:
COTS: commercial off-the-shelf-based systems:
DHS: Department of Homeland Security:
FAM: Federal Air Marshals:
FCI: Facility Condition Index:
FLETC: Federal Law Enforcement Training Center:
FTE: full-time equivalent:
INS: Immigration and Naturalization Service:
IT: information technology:
MOU: memorandum of understanding:
O&M: operation and maintenance:
OMB: Office of Management and Budget:
PO: Partner Organization:
RFP: request for proposals:
SASS: student administration and scheduling system:
SEI: Software Engineering Institute:
TSA: Transportation Security Administration:
United States General Accounting Office:
Washington, DC 20548:
July 24, 2003:
The Honorable Harold Rogers
Chairman, Subcommittee on Homeland Security
Committee on Appropriations
House of Representatives:
The Honorable Jack Kingston
The Honorable Ernest J. Istook, Jr.
House of Representatives:
Since its inception in the early 1970s, the Federal Law Enforcement
Training Center (FLETC), now a component of the Department of Homeland
Security (DHS),[Footnote 1] has played a vital role in training
personnel from federal, state and local, and foreign law enforcement
agencies. FLETC is responsible for providing basic, advanced,
specialized, and refresher training for law enforcement officers from
75 federal law enforcement agencies.[Footnote 2] Following the
September 11, 2001, terrorist attacks against the United States,
FLETC's role and continued ability to provide law enforcement training
in a timely manner is critical in the war against terrorism. For fiscal
year 2003, according to the Director of FLETC, 65 percent of its
projected training workload will come from 9 agencies transferred to
DHS.
The sudden influx of the large numbers of law enforcement personnel to
FLETC, coupled with the post-terrorist attack security environment, has
revived past concerns about the strain placed on its capacity to meet
the training demand.[Footnote 3] Most recently beginning in the mid-
1990s, these influxes were the result of increases in the personnel
levels of the U.S. Border Patrol;[Footnote 4] the increases were a
function of initiatives to control illegal immigration along U.S.
borders. FLETC, in cooperation with the Immigration and Naturalization
Service (INS), established a separate, temporary campus in Charleston,
South Carolina, in fiscal year 1996 to handle the demand for training
Border Patrol agents because the main FLETC campus at Glynco, Georgia,
could not accommodate this influx. The current influx has raised
concerns also about the relevance, quality, and timeliness of training
provided by FLETC. These concerns, in turn, have prompted some federal
law enforcement agencies that use FLETC for their basic training to
periodically consider establishing their own facilities, tailored to
their unique training needs and philosophy. At the same time, however,
Treasury and FLETC officials have said that the consolidated approach
to federal law enforcement training has provided economy-of-scale
savings annually, although these officials could not establish the
actual amount of recent savings. According to the FLETC officials, most
of the savings accrued from (1) achieving economies of scale that
enabled them to charge training participants lower per diem rates at
FLETC facilities than those participants would have incurred at their
own training facilities and (2) avoiding the need for maintaining
redundant or duplicate training facilities elsewhere.
The issue of consolidated federal law enforcement training is of
particular interest to you and the Appropriations Committee, which is
on record as being fully committed to the principle of such training.
This report responds to an April 2002 request by Representatives Istook
and Kingston; the House Appropriations Subcommittee on Homeland
Security joined the request when it assumed jurisdiction over FLETC in
Spring 2003. On the basis of discussions with your offices, we are
addressing the following objectives:
* Determine the extent to which FLETC is able to meet the current and
projected demand for training, how FLETC is planning to meet the
demand, and the associated costs; and the extent to which FLETC
coordinates or uses existing, non-FLETC government training assets, and
any associated costs.
* Examine FLETC's current organizational structures and processes for
coordinating and scheduling training activities and whether FLETC plans
any changes to these structures and processes.
* Review FLETC's oversight and governance structures and the extent to
which these structures are providing guidance to FLETC as it addresses
its capacity and planning challenges during a period of
transformational change.
You also asked us to review the final version of FLETC's Master Plan.
However, DHS did not give us the final plan for FLETC in time to be
included in this report, citing its need to review the plan.
Accordingly, we based our analysis of FLETC's planning for future
facilities on the final draft version of the plan, submitted to us in
April 2003, and the analyses of the other issues on the most recent
information available. As agreed with your offices, once the final
version of the Master Plan is provided to us (DHS estimated that it
might provide the plan in late summer 2003), and the status of the
training projections, system acquisition, and FLETC governance becomes
more apparent, we will complete our analyses and brief you on any
additional observations.
To develop our information, we visited the FLETC campuses in Glynn
County, Ga. (commonly referred to as "Glynco"); Charleston, S.C.;
Artesia, N. Mex.; and Cheltenham, Md. At the campuses, we observed
training activities; met with FLETC managers and officials in charge of
training, scheduling, information technology support, and
infrastructure facilities, and held meetings with officials from
various agencies, known as Partner Organizations (PO)--such as the
Border Patrol and the Bureau of Alcohol, Tobacco, Firearms, and
Explosives (ATF)--that use these campuses. We reviewed relevant
documents, including the 1970 memorandum of understanding (MOU) that
established FLETC's roles and responsibilities in providing training to
law enforcement agencies that are signatories to the MOU; FLETC budget
requests and related justifications; PO and FLETC historical training
statistics and projections for future training; FLETC's 1989 Master
Plan, the 1996 Master Plan update; the 2003 draft final Master Plan for
facilities assessment, construction, and renovation; and best practices
related to facilities and information technology acquisition and
governance and internal and management control. In addition to those we
interviewed at the FLETC campuses, we met with headquarters officials
at DHS; and the Departments of the Treasury, Justice, and
Transportation and their components; and with staff from the Office of
Management and Budget (OMB). We also met with a representative of the
architectural and engineering firm in Norfolk, Virginia, retained by
FLETC to help with its future planning.[Footnote 5] We conducted our
work from May 2002 through June 2003 in accordance with generally
accepted government auditing standards. Appendix I provides more
detailed information about the scope and methodology of our work.
Results in Brief:
Fueled initially by the growth in Border Patrol personnel that began in
the mid-1990s, and currently by the surge in overall federal law
enforcement personnel levels in response to the September 2001
terrorist attacks, the overall 5-day/8-hour capacity to provide
training at the Glynco and Charleston campuses is strained, while the
Artesia campus has been underutilized, and the Cheltenham campus is
being upgraded and is not fully operational (e.g., the U.S. Capitol
Police is conducting limited training using classrooms and several
physical venues). FLETC has been able to generally meet POs' needs for
basic training (the training provided to new recruits) by, among other
things, operating a 6-day schedule at the Glynco campus and deferring
POs' advanced classes (those provided to experienced personnel). POs
offered a variety of views about the effect of the strained capacity on
the training of their personnel--for example, former Justice
POs[Footnote 6] noted that the quality of the training had suffered;
other POs said that although their students and instructors were
fatigued and stressed, the quality of the training was still good.
FLETC officials disputed the view that capacity constraints had a
negative impact on PO training--these officials said that based on
FLETC's own data, student scores, for example, had not declined. The
strained capacity has had an adverse effect on the condition of FLETC
facilities and the infrastructure that supports them. Continued use of
these facilities at an accelerated rate without maintenance and
renovation would likely lead to further deterioration and exacerbate
capacity challenges.
FLETC has worked with an architectural and engineering firm to develop
a Master Plan to help address long-term capacity challenges. The
planning process raises several concerns about the assumptions and
methodologies used to develop the plan's recommendations, and the
extent to which they allow for contingencies, such as potential future
surges or declines in demand for training; cost estimating and
budgeting; and the extent to which the plan's recommendations would be
implemented in time to help alleviate the capacity constraints. DHS
officials told us they intend to review the plan, but might not adopt
substantial parts of it, as the department is formulating its vision
for federal law enforcement training in general and FLETC in
particular--these officials said that while useful in some respects
(e.g., it contains a comprehensive inventory of the condition of FLETC
training facilities), the plan was essentially dated in its
assumptions. FLETC does not have a formal contingency plan for
addressing its capacity challenges during the period up to when
facilities recommended by the Master Plan begin coming on line and, as
a practice, has not routinely utilized alternative training assets
(e.g., off-site training and e-learning) to provide basic training for
POs.
In addition to strained training capacity challenges, FLETC faces a
challenge to automate the scheduling of training for its POs.
Specifically, FLETC's scheduling process uses a predominantly manual
scheduling process that does not ensure the efficient use of training
resources and poses internal control risks due to potential loss of
scheduling materials and the lack of backup documentation. FLETC has
recognized these risks and is in the process of acquiring an automated
student administration and scheduling system (SASS) to address them.
Although FLETC's plans and activities for acquiring the SASS generally
include performance of certain key acquisition management functions,
FLETC has yet to address important risk management issues associated
with its SASS acquisition.[Footnote 7] Moreover, with the exception of
its SASS solicitation, FLETC's plans and activities do not incorporate
recognized best practices for acquiring commercial off-the-shelf-based
systems (COTS). Furthermore, FLETC's solicitation activities have not
adequately addressed SASS security requirements. Taken as a whole, this
means that FLETC's SASS acquisition is currently at risk of not
delivering a system solution to best meet its needs. Although FLETC
continues to develop documentation for the SASS proposal, at our
urging, it is also working with the Border Patrol to determine whether
its existing Academy Class Management System (ACMS), which is being
enhanced with a scheduling module, can be used instead of acquiring
SASS. According to FLETC officials, if it chooses ACMS, FLETC could
save the cost of the SASS solicitation and the system's estimated $10
million cost over 5 years, while spending considerably less to adopt
the ACMS scheduling module.
FLETC faces challenges in its governance structure because (1) the
status of its Board of Directors is unclear as FLETC, its individual
board members, and DHS consider the Board's future; and (2) the Board's
membership, roles and responsibilities, and past practices are not
fully consistent with prevailing governance and internal and management
control best practices. For example, according to a FLETC official the
Board did not meet for a period of 3-½ years, prior to its most recent
meeting in November 2002, even though it is required by its own charter
to meet at least quarterly; and, according to governance best
practices, the "typical" board of directors meets about eight times a
year.[Footnote 8] A DHS official said that DHS has recently assumed
responsibility for FLETC and recognizes the need to provide guidance
and oversight to FLETC; DHS has begun to work with FLETC to provide
guidance related to its demand and capacity challenges. In addition,
DHS recognizes the role an effective FLETC board could play in
enhancing governance. Without effective internal and external
governance and oversight, FLETC could be at risk of not effectively
addressing the transformational challenges it faces.
Because of the importance to FLETC's ability to meet its considerable
challenges, we are making recommendations to the Secretary of DHS to
improve capacity planning, periodically assess the condition of
training facilities and associated infrastructure through the use of
performance measures, improve the acquisition process for an automated
scheduling system, and enhance the governance and oversight
capabilities of FLETC's Board of Directors.
We provided a draft of this report to DHS and to the Department of
Justice for comment. In its response, from the Under Secretary for
Border and Transportation Security, DHS generally agreed with our
conclusions and recommendations and outlined actions it either had
taken or was planning to take to implement the recommendations. DHS
also provided technical comments and clarifications, including updated
information on FLETC's SASS acquisition; we have incorporated them in
this report where appropriate. Justice did not submit formal written
comments; the Associate Assistant Attorney General for Federal Law
Enforcement Training submitted an email with two general comments
related to the issues of FLETC training capacity and governance,
respectively.
Background:
The September 2001 attacks spurred a significant surge in the numbers
of federal law enforcement personnel to respond to the threat posed by
terrorism. This surge, in turn, resulted in an influx of a large number
of law enforcement personnel into FLETC's campuses around the country,
over and above their historical enrollment. Preceding the attacks, in
fiscal year 2001, over 21,000 students spent over 101,000 student
weeks[Footnote 9] training at FLETC's domestic campuses. In fiscal year
2002, primarily as a result of the post-attack surge, over 28,000
students spent about 157,000 weeks training at these campuses. Placing
the training statistics in historical context, the weeks spent by
students at FLETC in fiscal year 2002, for example, represented a 267-
percent increase over the level in fiscal year 1983 (the earliest year
for which complete data were available) and a 72-percent increase from
the level of as recently as fiscal year 1999. FLETC's most recent
adjusted domestic student training projections for fiscal year 2003
call for about 49,000 students to train for about 259,000 student
weeks, with PO projections rising to all-time highs of over 57,000
students and about 283,000 student weeks in fiscal year 2004.
FLETC was established as a consolidated interagency training facility
in the Department of the Treasury by a Treasury order dated March 2,
1970. Subsequent to the Treasury order, an MOU between FLETC and its
POs was established in September 1970. As of June 2003, FLETC was
working to revise its MOU with its POs to reflect the move to DHS,
which occurred in March 2003, according to a FLETC official. The
original MOU, which was revised in 1977 and again in 1984, states that
FLETC is responsible for, among other things, providing recruit
(basic), advanced, specialized, and refresher training for designated
criminal law enforcement personnel; specialized law enforcement
training for state and local government personnel if space is
available; facilities and student support services necessary for
specialized training conducted at FLETC by a PO; updated training
methods and curriculum content in response to the common needs of the
participating law enforcement agencies; and dormitory space, food
service, travel, and support services; and facilities for students
trained at FLETC. The original POs were the Departments of the
Interior, Justice, State, and Treasury; OMB; the U.S. Civil Service
Commission--now the Office of Personnel Management; the U.S. Postal
Service; and the Smithsonian Institution. FLETC's original MOU was
expanded over time to currently include the training of law enforcement
personnel from 75 POs. A list of these 75 POs appears in appendix II.
Figure 1: Various FLETC Training Activities:
[See PDF for image]
[End of figure]
As shown in figure 2, for fiscal year 2003, FLETC had an enacted budget
of about $172 million, about 79 percent of which was for salaries and
expenses and 21 percent for acquisition, construction, improvements,
and related expenses. That year, FLETC had 878 full-time equivalent
(FTE) permanent staff authorized. For fiscal year 2004, the budget
request totaled about $146 million, of which about 84 percent was for
operating expenses (formerly classified as "salaries and expenses") and
about 16 percent for capital acquisition (formerly classified as
"acquisition, construction, improvements, and related expenses"). For
fiscal year 2004, the budget request calls for 754 FTE permanent staff.
Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004
Budget Request:
[See PDF for image]
[A] "Facilities" refers to "acquisition, construction, improvements and
related expenses" in fiscal year 2003 and "capital acquisition" in
fiscal year 2004. No funding was requested for major construction in
fiscal year 2004.
[B] "Human capital" refers to "salaries and expenses" in fiscal year
2003 and "operating expenses" in fiscal year 2004.
[End of figure]
FLETC provides training at four domestic campuses.[Footnote 10]
Specifically, FLETC's largest campus, which also serves as its
headquarters, is located in Glynn County, Georgia (referred to as
"Glynco"), and was established in 1975. Most of FLETC's POs conduct
their law enforcement basic training at the Glynco campus. FLETC's
second campus, established in 1989, is located in Artesia, New Mexico.
The resident agencies at Artesia are the Border Patrol (for advanced
training only), the Bureau of Indian Affairs, Indian Police Academy
(basic and advanced), the INS Officers Academy, the Transportation
Security Administration's (TSA) Federal Air Marshals (FAM), and the
U.S. Secret Service Uniformed Division. FLETC's third campus is a
former naval base in Cheltenham, Maryland, that was transferred to
FLETC in May 2001. FLETC intends to use the Cheltenham campus primarily
as a driving and firearm re-qualification center for POs based in
Washington, D.C., and its metropolitan area. At the time of our review,
the campus was being upgraded and was not fully operational. According
to FLETC officials, the Cheltenham campus will have, among other
things, an indoor, 108-point, state-of-the-art firing range, and a
multiuse, topographically varied driving course. Currently, over 12
federal, including the U.S. Capitol Police, and state and local law
enforcement agencies are using the campus. FLETC officials at
Cheltenham anticipate that approximately 61 POs will use the campus'
firearms and driving re-qualification center. The fourth domestic
campus is the Border Patrol Academy in Charleston, South Carolina.
FLETC officials said that to date, this academy has not been placed
under FLETC's authority; however, FLETC provides technical support to
the campus for the Border Patrol training. The campus was established
in 1996 at a former naval base as a temporary facility to handle the
surge in the number of Border Patrol agent recruits that were the
result of a hiring initiative to control illegal immigration along U.S.
borders. The existing FLETC campuses could not accommodate the Border
Patrol's surge in the resulting demand for training. In October 2002,
Public Law 107-248 directed that the Secretary of the Navy transfer
administrative jurisdiction of Charleston, in effect, to DHS, although
it is not clear whether FLETC would control the facilities.[Footnote
11] In February 2003, Public Law 108-7 established the Charleston "law
enforcement training facility" as a permanent training
facility.[Footnote 12] The campus has been extensively remodeled and
outfitted to provide basic training to the Border Patrol's agent
recruits; while it was originally scheduled to close in fiscal year
2004, if control of the Charleston facility transfers to FLETC, it
intends to keep the campus open to help provide training capacity,
regardless of who receives training there. In addition to the training
provided directly by FLETC, a number of POs, such as the former Customs
and INS, the U.S. Marshals Service, and the Internal Revenue Service,
maintain their own "academies" at the FLETC campuses to provide agency-
specific instruction to their recruits.
FLETC offers predominantly four types of training programs--recruit
(basic), specialized, advanced, and refresher training. Appendix III
provides a detailed description of the variations of training programs
and seminars FLETC offers. Basic training (i.e., training provided to
new recruits) has represented the greatest demand for FLETC's resources
of all four types of programs given the increase in Border Patrol and
the surge in federal law enforcement hiring since the September 11
attacks. Basic training is mandatory for entry-level federal law
enforcement personnel, such as those hired by the Border Patrol, and is
usually provided during the first year of employment to familiarize
recruits with law enforcement skills and operations. Basic training
also extensively uses FLETC's training facilities, including firearm
and driver training facilities, in addition to classrooms and other
physical education facilities.
For specialized training programs, such as agency-specific basic
training programs (i.e., training provided by agencies immediately
following FLETC's basic training), FLETC has the responsibility for
providing instructors for the parts of the program that are standard to
FLETC's curriculum, while the agency provides the part of the
curriculum more specific to its mission. For example, FLETC provides
the instructors for the Courtroom Testimony Lecture and shares
responsibility with the Border Patrol for the Courtroom Testimony
Laboratory. ATF and the Environmental Protection Agency, in addition to
the Border Patrol are examples of agencies requiring specific programs
as part of their basic training program. For the sections of the
program that are not designated as a FLETC responsibility, the PO must
provide instructors. FLETC also evaluates these programs to ensure that
PO training objectives are being met.
Advanced training is usually provided to junior and senior-level law
enforcement personnel as part of their continuing professional
development. An agency that maintains its own academy at a FLETC
campus, such as the Border Patrol, will typically use its own
instructors for advanced training. If it has instructors available,
FLETC may sometimes assist an academy with advanced training. Advanced
training includes (1) training of inspectors or agents to be
instructors; (2) "follow-on basic" training, where skills particular to
an agency mission are taught; and (3) in-service training, which is
typically an intensive seminar on a current issue or the development of
a law enforcement or management skill.
FLETC also provides refresher training for its POs. For example, law
enforcement personnel in the Washington, D.C., area will be able to
receive refresher training in firearms and vehicle operation re-
qualification at FLETC's Cheltenham campus.
FLETC's Training Capacity is Strained, and Its Planning for Adding
Capacity Raises Concerns:
FLETC's overall 5-day/8-hour capacity to provide training at the Glynco
and Charleston campuses is currently strained, while the Artesia campus
has been underutilized. The Cheltenham campus is being upgraded and is
not fully operational, thus its contribution to FLETC's overall
capacity is limited. POs offered a variety of views about the effect of
the strained capacity on the training of their personnel--for example,
former Justice POs now in DHS believed that the quality of the training
had suffered, while other POs said that although their students and
instructors were fatigued and stressed, they believed that the quality
of the training was still good. The strained capacity has had an
adverse effect also on the condition of FLETC facilities and the
infrastructure that supports them; further deterioration could
exacerbate capacity challenges. FLETC has worked with an architectural
and engineering firm to develop a Master Plan to help overcome the
long-term capacity challenges, although DHS officials said that the
plan might no longer be germane to the department's vision for law
enforcement training. The planning process raises several concerns
about the assumptions and methodologies used to develop the plan's
recommendations, and the extent to which they allow for contingencies,
such as future surges or declines in demand; cost estimating and
budgeting; and the extent to which the plan's recommendations would be
implemented in time to help alleviate the capacity constraints. FLETC
does not have a formal contingency plan for addressing its capacity
challenges during the period up to when facilities recommended by the
Master Plan begin coming on line and, as a practice, has not routinely
utilized alternative training assets to provide basic training for POs.
FLETC's Training Capacity Is Strained at the Glynco and Charleston
Campuses:
Primarily as the collective result of the surge in Border Patrol
personnel levels begun in the mid-1990s and the surge in overall
federal law enforcement personnel following the September 2001
terrorist attacks, the overall capacity to provide basic training at
Glynco and Charleston is strained. As shown in table 1, the latest
available PO-projected demand[Footnote 13] exceeds the 5-day/8-hour
capacity for fiscal year 2003, at these two training campuses. The
combined capacity for a 5-day/8-hour workweek at the three FLETC
campuses is about 67,000 student weeks short of projected demand, and
for a 6-day/8-hour workweek about 28,000 student weeks short of the
projected demand.
Table 1: Capacity and Demand at the FLETC Campuses (in student weeks):
Campus: Glynco: Fiscal year 2003 projected demand: 192,494;
FLETC estimated actual attendance (as of 4/30/03): 148,311; Difference
between projected demand and estimated attendance: 44,183.
November 2002; Optimum 5-day/8-hour capacity: 120,000; Optimum
6-day/8-hour capacity: 144,000].
March 2003 (temporary increase in capacity); Optimum 5-day/8-
hour capacity: 135,000; Optimum 6-day/8-hour capacity: 162,000.
Campus: Charleston; Optimum 5-day/8-hour capacity: 37,000; Optimum 6-
day/8-hour capacity: 44,000; Fiscal year 2003 projected demand: 41,259;
FLETC estimated actual attendance (as of 4/30/03): 33,816; Difference
between projected demand and estimated attendance: 7,443.
Campus: Artesia; Optimum 5-day/8-hour capacity: 27,000; Optimum 6-day/
8-hour capacity: 32,000; Fiscal year 2003 projected demand: 32,095;
FLETC estimated actual attendance (as of 4/30/03): 18,556; Difference
between projected demand and estimated attendance: 13,539.
Campus: Total; Optimum 5-day/8-hour capacity: 199,000; Optimum 6-day/8-
hour capacity: 238,000; Fiscal year 2003 projected demand: 265,848;
FLETC estimated actual attendance (as of 4/30/03): 200,683; Difference
between projected demand and estimated attendance: 65,165.
Source: GAO analysis of FLETC data.
[End of table]
However, also as shown in table 1, FLETC is estimating (as of April 30,
2003) that the actual number of student weeks spent at the three
campuses will total 200,683 student weeks, or 25 percent less than the
fiscal year 2003 projected levels. A FLETC official said that it is not
unusual for actual attendance to fall short of projections because of
factors such as recruiting shortfalls, funding reallocations, and
classes that begin with less than their full complement. In fact,
actual attendance (in student weeks) fell short of projections as
recently as fiscal year 2001, when attendance was about 76 percent of
the projected level. In fiscal year 2002, actual attendance was about
112 percent of the projected level.
The FLETC official attributed the difference in fiscal year 2003 to
three principal factors. First, changes in TSA's projections--TSA
originally projected about 49,000 student weeks of training primarily
for airport security officers, and for "flight deck officers" (i.e.,
airline pilots trained to carry firearms in cockpits) and FAMs.
However, the TSA projections have not materialized to date, with the
estimated actual attendance totaling about 10,000 student weeks.
Second, changes to the Border Patrol's projections--the Border Patrol
originally projected about 46,000 student weeks of training for agents.
However, the estimated actual attendance totals about 33,000 student
weeks. Third, changes to the former INS's projections--INS originally
projected about 50,000 student weeks of training for inspectors and
agents. However, the estimated actual attendance totals about 40,000
student weeks. A FLETC official cautioned that the final actual
attendance for fiscal year 2003 might be different than the estimates
based on additional requests, DHS reorganization training guidelines,
attrition, and additional hiring budgets. For example, there is a
possibility that if funding is restored, TSA may yet end up needing a
number of the student weeks it originally projected.
Even if the fiscal year 2003 projections do not ultimately materialize,
FLETC's 5-day/8-hour capacity would still be strained. Specifically,
the total estimated actual attendance of 200,683 student weeks will
exceed the combined 5-day/8-hour capacity of 199,000 student weeks by
about 1,700 student weeks. In discussing the capacity strains facing
FLETC, we note that "student weeks" provides FLETC with a statistical
measure of optimum throughput, or best case, training capacity (see
footnote 3). This measure assumes that all of the requisite facilities,
instructors, and equipment will be available to provide training when
needed. However, capacity is ultimately a function of facilities,
instructors, and equipment that are actually available to provide
training at a point in time. Accordingly, while a number of student
weeks may appear to be "available" (for example, as in the case of the
Charleston campus, where estimated actual attendance is about 3,000
student weeks below the campus's 5-day/8-hour capacity); at any given
time, a number of physical and human "choke points," or training
obstacles, either individually or collectively result in capacity
constraints. Thus, the choke points essentially reduce the number of
available student weeks from the best-case level.
In this regard, a number of choke points are causing the capacity
strains that the Glynco and Charleston campuses are experiencing.
Specifically, according to FLETC, the principal choke points that are
collectively causing the capacity strain at Glynco are the firearms
ranges, driving ranges, practical exercise facilities, the dining hall,
classrooms, dormitories, and a shortage of instructors and support
staff. At Charleston, the choke points include the firearms ranges,
driving ranges, and a shortage of instructors--illustrating the effect
of choke points on capacity at Charleston, during fiscal year 2003, the
Border Patrol had to defer 3 classes of agent training because the
campus's emergency response driving range had to be taken off-line for
resurfacing. According to FLETC officials, had these classes actually
taken place, Charleston's 5-day/8-hour capacity would have been met or
exceeded.
On the basis of the latest PO projections for training demand, FLETC's
overall capacity strain is expected to continue for fiscal year 2004.
However, for fiscal years 2005 through 2008, PO projections show a
relatively stable decrease in demand from fiscal year 2004 peak levels,
but projected demand still exceeds FLETC's fiscal year 2003 5-day/8-
hour capacity and is approaching the current 6-day/8-hour capacity.
Figure 3 shows the difference between combined projected demand and
combined current capacity of FLETC facilities for fiscal years 1997
through 2008.
Figure 3: Partner Organization Training Projections Compared to Current
Combined Campus Optimum Capacity (in student weeks):
[See PDF for image]
Note: This graph includes the Glynco, Artesia, and Charleston campuses.
[End of figure]
Artesia Campus Has Been Underutilized:
While capacity at the Glynco and Charleston campuses has been strained,
the Artesia campus has been underutilized following the completion of
FAM's ramped-up training during fiscal year 2002. In this regard, as
shown in table 1, Artesia has an annual capacity of 27,000 student
weeks for a 5-day/8-hour schedule and 32,000 student weeks for a 6-day/
8-hour schedule. In fiscal year 2002, PO trainees spent 19,188 student
weeks at Artesia, well short of capacity. Although PO demand
projections of 32,095 student weeks initially suggested that the
Artesia campus would experience some minor capacity strains in fiscal
year 2003, it is not clear that the campus will be fully utilized.
Specifically, based on year-to-date attendance data through April 2003,
FLETC estimated that 18,556 student weeks will actually be spent at
Artesia, well short of the levels originally projected by POs. As
discussed earlier, according to FLETC officials, the shortfall is
primarily caused by TSA's original projections for training not
materializing--part of this training was to be held at the Artesia
campus. FLETC officials cautioned, however, that the final actual
attendance might be different than the April 2003 estimate, and could
be somewhat closer to the original projection based on additional PO
requests, DHS reorganization training guidelines, attrition, and
additional hiring budgets.
In addition to Artesia's underutilized housing and firearms ranges, the
live-fire shoot houses and three Boeing 727s, specially configured for
terrorism training, have not been used since the FAMs completed their
training (see figure 4). A FLETC official indicated that it is
conducting marketing and other types of activities to attract a number
of additional users to the campus. In this regard, several POs told us
that they considered Artesia to be too remote of a location to send
their recruits and, especially, their instructors for training. The
FLETC officials stressed that the Artesia campus could not, as
currently configured, and discussed later, handle the transfer of the
Border Patrol's basic training from the Charleston campus to Artesia,
as proposed in the Master Plan. If the transfer were to occur, the
Border Patrol's projected fiscal year 2003 demand for training would
exceed Artesia's 5-day/8-hour capacity by at least 6,000 student weeks
and up to 14,000 student weeks, depending on the schedule adopted.
Figure 4: FLETC Campus at Artesia, New Mexico:
[See PDF for image]
[End of figure]
FLETC Has Generally Met PO Needs for Basic Training:
Despite its strained capacity, FLETC has nevertheless been able to
generally meet its POs' demand for basic training principally by, among
other things,
* operating on a 6-day, multiple-shift training week at its Glynco
campus to overcome constrained resources;
* deferring some training programs for certain POs that were not
originally projected and that were made late in the year--for example,
the Secret Service, Customs, and the General Services Administration's
Federal Protective Service made such requests;
* canceling or deferring some of the POs' advanced training classes
following the September 2001 attacks--FLETC rescheduled about 5 percent
of these classes within the fiscal year;
* continuing to schedule and conduct Border Patrol's basic training at
the Charleston campus, in cooperation with the Bureau of Customs and
Border Protection/Border Patrol;
* rotating instructors to most needed areas of work; and:
* converting buildings and trailers that had been previously utilized
for office space into training facilities such as raid houses, mat
rooms, classrooms, and firearms simulations.
We note that while this approach may have helped mitigate the capacity
constraints in the short term, deferring or canceling training may
exacerbate any potential future strains on FLETC capacity--this
training would likely need to be made up sometime in the future--and
result in law enforcement personnel not being available for duty when
needed.
PO Views about the Effect of the Capacity Strains on Their Personnel:
POs offered a variety of views about the effect of FLETC's strained
capacity on their training, in terms of, among other things, trainee
attrition, the quality and timeliness of instruction, and instructor
morale and retention. For example, representing the views of Justice
POs (prior to their transition to DHS), a senior Justice official said
that the strained capacity--and especially the need to train 6 days a
week at Glynco--had resulted in higher attrition rates for trainees and
fatigue, burnout, and low morale for instructors. In addition,
according to this official, the quality of instruction, and thus that
of the training received, had suffered. Further, a May 2002 internal
Justice report on FLETC training issues noted that one of its component
agencies had to cancel all of its "badly needed" advanced training due
to the lack of space at FLETC. In commenting on a draft of this report,
FLETC said that the PO was actually asked to shift its training within
the fiscal year but declined to do so. The Justice report also noted
that the 6-day training arrangement caused additional problems for
Justice POs, including having to pay overtime and having difficulty in
attracting and retaining instructors. Separately, a former Treasury PO
reported that FLETC had to defer basic training for 168 agent recruits
because of capacity constraints--since they could not be trained, and
thus not deployed, these recruits were assigned nonagent, desk work.
Basic training for recruits hired by September 2002 was to be completed
in about 11 weeks. However, capacity strains caused FLETC to train the
recruits in stages, with some not completing their training until
February 2003. FLETC officials disputed the POs views that capacity
constraints had had a negative impact on training. These officials said
that based on FLETC's own data for the period of the capacity
constraints, overall student test scores had not declined in a
statistically significant manner over time, and student surveys
continued to show a high level of satisfaction with FLETC's training
services. Regarding the aforementioned example of the Treasury PO
deferral, FLETC said that the PO's request was for 240 students and was
not initially projected. FLETC also said that it was actually able to
accommodate immediately 72 of the students.
Other POs indicated that while their instructors and students generally
experienced greater fatigue and stress as a result of FLETC's capacity
constraints, the quality of the training had not suffered
significantly. For example, one PO said that although there was a
slight decline in student test scores, it was unclear whether this
decline could be attributed exclusively to the capacity strain. The
same PO reported that the extended hours resulting from the constraints
actually allowed its trainees to complete their training in 9 weeks
instead of 11, allowing them to be deployed to duty assignments sooner.
Capacity Strains Have Impacted the Condition of Facilities and
Supporting Infrastructure:
FLETC's implementation of 6-day, multiple-shift training at Glynco to
help alleviate the capacity constraints at that campus has led to the
intensive scheduling of its facilities. Such above-average usage of
facilities places additional loads and strains on their systems and
components, increasing the need for maintenance and repair.[Footnote
14] Maintenance programs and renovation projects are often deferred,
according to FLETC officials, due to the lack of funding or an ability
to only schedule facility "down time" for maintenance in the evenings
and on Sundays. Cheltenham, for example, has an electrical system that
is subject to failure at any time and a chlorination system that has
failed, resulting in the need to provide bottled water for drinking. At
the time of our site visits, utility upgrades were needed at Glynco,
Cheltenham, and Artesia, and road and parking upgrades were needed at
Glynco and Cheltenham; many facilities at Glynco are now only available
for maintenance during evening hours or on Sundays. Although not
quantifiable at this point, continued deterioration of facilities would
likely lead to increased capital requirements in the future and
adversely affect employee working conditions and retention.[Footnote
15]
FLETC has considered the degradation issue in some of its internal
reports; however, FLETC does not have any immediate contingency plans
to address facility degradation. Such planning would be vital to help
address the potential impact of facility degradation on FLETC's already
strained capacity. Many organizations use periodic facility condition
assessments to establish baseline facility data and to aid in planning
for short-and long-range facility maintenance and repair needs.
Currently, FLETC does not have detailed information about the condition
of its facilities. A "Facility Condition Index" (FCI) would help to
address the degradation issue by giving measurable performance data
about its facilities rather than relying on anecdotal information. An
FCI is the ratio of the cost of maintenance and repair deficiencies to
the facility's current replacement value. A FCI value of less than 0.05
is generally considered to represent a "good" facility condition.
The draft final version of the Master Plan concluded that although
FLETC had done a commendable job in handling the ever-increasing demand
for training, it had done so at a price. Part of this price has been
the degradation of its facilities--funding has been focused on building
new facilities to alleviate choke points, while maintenance and
renovation have been continuously deferred due to the lack of funding.
Echoing our own concerns about this issue, the firm that developed the
plan concluded that continuation of this cycle will eventually result
in building element or critical infrastructure failures and made
recommendations for renovations and expansion as part of its broader
three-phase approach for improving and expanding FLETC's capacity.
FLETC Master Plan Intended to Help Alleviate Capacity Constraints:
The Master Plan's recommendations for renovation and expansion of
existing, and the construction of new facilities are arrayed in three,
partly overlapping, 5-7 year construction phases for each of the
campuses (except Charleston, which FLETC had, at the time the Master
Plan was being developed, assumed would close by 2004). The first phase
of construction extends at maximum from 2006 to 2011, the second from
2009 to 2015, and the third from 2013 to 2019. Each phase includes a
mix of renovation and expansion projects, as well as the construction
of new facilities. According to FLETC, the extent of additional
capacity, in terms of student weeks, would depend on the completion of
the construction projects, the programmatic mix, and other factors
(e.g., the requisite staffing being available). As shown in table 2, if
the plan's prioritized list of construction projects for phase 1 were
to be completed, and the programmatic mix and other factors did not
change, the capacities of Glynco and Artesia would increase as follows:
for Glynco, 193,500 student weeks for the 5-day/8-hour schedule,
232,000 student weeks for the 6-day/8-hour schedule, and 278,000
student weeks for the 6-day/12-hour schedule; for Artesia, 55,000
student weeks for the 5-day/8-hour schedule, 66,000 student weeks for
the 6-day/8-hour schedule, and 79,000 student weeks for the 6-day/12-
hour schedule. The Cheltenham campus is not included since it is being
upgraded and FLETC currently does not intend to use the campus as a
residential facility.
Table 2: Potential Campus Capacities Following Completion of Phase I
Master Plan Projects (in student weeks):
Campus: Glynco; 5-day/8-hour: 193,500; 6-day/8-hour: 232,000; 6-day/
12-hour: 278,000.
Campus: Artesia; 5-day/8-hour: 55,000; 6-day/8-hour: 66,000; 6-day/12-
hour: 79,000.
Campus: Total; 5-day/8-hour: 248,500; 6-day/8-hour: 298,000; 6-day/12-
hour: 357,000.
Source: GAO analysis of FLETC data.
[End of table]
The April 2003 final draft of the plan estimates the combined cost of
the three phases to be about $907 million; the estimate includes costs
for construction and furnishings and fixtures but excludes operation
and maintenance (O&M) costs. O&M costs are estimated separately for the
period of 2008 through 2040 from the project costs and total about $269
million.
FLETC's Planning to Address Its Capacity Constraints Raises Concerns:
The FLETC Master Plan's assumptions and methodologies in particular,
and FLETC's plan to address its capacity constraints in general, raise
a number of concerns. First, the plan assumes that the Border Patrol
will shift its basic training from the Charleston campus to the Artesia
campus and that the Charleston campus will close.[Footnote 16] However,
as indicated earlier, the Consolidated Appropriations Resolution, 2003
(Public Law 108-7), established the Charleston "law enforcement
training facility" as a permanent training facility. While the
Department of Defense Appropriations Act, 2003 (Public Law 107-248)
directed the Secretary of the Navy to transfer administrative
jurisdiction of the Charleston law enforcement training facility to, in
effect, the DHS, it is not clear whether FLETC will be the entity
within the department to assume responsibility of the facility, and
which FLETC POs, if any, will receive training there.
Second, the Master Plan assumes that the training schedule at Glynco
will return to a 5-day/8-hour week, but a FLETC official acknowledged
that a return to such a shift for basic training is unlikely in at
least fiscal year 2004, given the current and projected demands for
training at the campus. Third, the plan assumes a set of baseline
projections of future demand for training for each of the campuses from
which future facility needs are generated. These Master Plan
projections are lower than the latest projected attendance levels that
FLETC is currently facing. Specifically, while several baseline
workload scenarios were originally considered, only one was actually
utilized to estimate the future need for facilities. Using a single
baseline is questionable because it excludes accounting for possible
future increases or decreases in the demand for training that would
render the original baseline obsolete.
Fourth, the plan assumes constant (or straight-line) growth rates in
projecting the need for additional facilities at each FLETC campus.
However, these growth rates are based on historical precedent and do
not fully take into account recent events such as today's new security
environment and the resulting surge in the demand for training of law
enforcement personnel, and do not take into account future events such
as potential further surges, or declines, in training demand, or
changes in the attrition of federal law enforcement personnel. Finally,
the plan does not assume potential efficiencies that might result from
FLETC's planned automation of its system for scheduling training
(discussed below). Use of such an automated system could result in more
efficient scheduling of facilities. The firm that developed the plan
acknowledges that if efficiencies were to be achieved through the
automation of scheduling, the plan would need to be revised.
Concerns about FLETC's planning also involve the Master Plan's cost
estimates and future budget requests for construction and the extent to
which the plan's phase 1 recommendations would be implemented in time
to begin alleviating the capacity constraints. Regarding the cost
estimates, the Master Plan's estimates should be treated with
considerable caution. Specifically, although we did not analyze the
plan's estimates in detail, we note two broad concerns. First, because
the plan's recommendations have not proceeded beyond the conceptual or
early design stage, the cost estimates are likely to be very "soft,"
with considerable potential upside tendency--at the conceptual stage;
costs are likely to vary by as much as 50 percent. Second, the plan's
recommendations and their design may be altered by DHS as part of its
ongoing review of the plan (discussed later), thus changing the
estimated costs. Further, a FLETC official said he identified a number
of cost errors as part of his review of the April 2003 version of the
final draft of the plan--these errors involved life cycle-costs, O&M
costs, and architectural and engineering fees. We also found, and
brought to FLETC's attention, cost discrepancies between the 90-percent
and final draft versions of the plan's phase 1 construction totaling
over $100 million. For the entire plan, the discrepancies totaled over
$200 million. A FLETC official concurred that there were discrepancies
and told us that FLETC was working to resolve them. In terms of future
budget requests for construction, the estimated costs for the first
phase of the Master Plan are more than five times the total
appropriated amounts for new facilities and renovations for fiscal
years 2001 through 2003 and the request for fiscal year 2004. A FLETC
budget official said that in terms of lead time to fund the plan's
recommendations, FLETC, in keeping with its past practice, would likely
request the entire amount up front for all approved projects. Based on
capital acquisition best practices, this approach is not unusual in the
construction field. In this regard, a DHS official said that a request
for construction expenditures for training facilities was not expected
until the fiscal year 2005 budget cycle.
In terms of the timely implementation of the Master Plan's
recommendations, construction of the projects recommended in the plan's
first phase would not begin to be completed until 2008 at the earliest,
leaving a gap of at least 5 years of continued strained capacity that
would need to be addressed through other means.
FLETC Does Not Have a Contingency Plan to Address Capacity Constraints
and Has Not Routinely Utilized Alternative Assets to Provide Basic
Training:
Adding to the long-term challenge of addressing its capacity
constraints, FLETC does not currently have a formal written training
contingency plan independent of the Master Plan for addressing its
immediate training capacity challenges, or the challenges leading up to
when the plan's recommendations are expected to come on line in 2008.
FLETC officials said that although they would like to have a written
training contingency plan, and had been developing a contingency
planning process, they were operating in an essentially reactive mode
to address the more immediate issue of responding to continuing surges
in the demand for training. In this regard, a FLETC official said that
in this regard it would consider adding more shifts to the Glynco
campus if needed.
Further, FLETC neither has, as a routine practice, utilized alternative
training assets to provide basic training for its federal POs
(including off-site training locations, e-linkages, and satellite
communications), nor does it have a formal plan for doing so. FLETC
officials indicated that these measures were to be given more
consideration in the future as a means of addressing campus capacity
strains. FLETC officials explained that they had been reluctant to
provide PO training in facilities they did not own because they could
not control the training schedule, given the absence of ongoing
arrangements with the owners of such facilities. Instead, according to
FLETC officials, on a limited and informal basis, FLETC facilitated the
use of alternative training facilities by some law enforcement agencies
when it could not immediately accommodate their training needs. A FLETC
working group initiated by DHS is currently reviewing the extent to
which training assets--in addition to the FLETC campuses--owned by DHS
component agencies can be used for training.
DHS Is Reviewing FLETC's Master Plan, but Considers It of Limited
Future Use:
DHS officials said that the department was in the process of reviewing
the Master Plan, to be followed by an OMB review. Without offering
details, they also said that although useful in some respects, the plan
might not be germane as the department develops its vision of law
enforcement training for FLETC. These officials said they considered
the plan useful as a tool in identifying the condition of existing
FLETC facilities and the need for expansion. However, they did not view
the plan as a roadmap for the future. A DHS official expected the
review process of the plan to be completed by mid July 2003.
In concert with its review of the Master Plan, DHS has tasked FLETC to
chair a working group--the Training Academy Charter Committee--
comprised of department component agencies to inventory their training
assets and develop a coordinated strategy so that these assets are used
effectively to provide training. FLETC's specific task is to develop a
survey instrument, collect and analyze the survey results, and play a
role in developing recommendations. A FLETC official expects the
committee's work to be completed by July 2003.
FLETC's Current Scheduling System Is at Risk and Its Acquisition of an
Automated System Raises Concerns:
Within the context of strained training capacity, FLETC's scheduling
process poses internal control risks. FLETC relies on a predominantly
manual scheduling process that does not ensure the efficient use of
training resources and poses internal control risks due to potential
loss of scheduling materials and the lack of backup documentation.
FLETC has recognized these risks and is in the process of acquiring an
automated system, SASS, to address them. Although FLETC's plans and
activities for acquiring SASS generally include performance of certain
key acquisition management functions, FLETC officials have yet to
address important risk management issues associated with its SASS
acquisition. Moreover, with the exception of its SASS solicitation,
FLETC's plans and activities do not incorporate recognized best
practices for acquiring commercial off-the-shelf-based systems.
FLETC's solicitation activities have not adequately addressed SASS
security requirements. Taken as a whole, this means that FLETC's SASS
acquisition is currently at risk of not delivering a system solution to
best meet its needs. While FLETC continues to develop the SASS request
for proposals (RFP)--at our urging, it is also working with the Border
Patrol to determine whether its existing ACMS can be used instead of
acquiring SASS.
Current Scheduling System Places the Delivery of Training Services at
Risk and Does Not Maximize Use of Existing Facilities:
FLETC's current system for scheduling training places efficient
delivery of training services at risk. FLETC's scheduling system is
predominantly manual and only partly automated. The manual part of the
system involves, among other things, the use of large desk calendars,
colored markers, and color-coded post-it notes to schedule things such
as student classes, student housing, classrooms, instructors, language
and computer laboratories, firing ranges, driving ranges, and mat
rooms. As schedules change, for example, the notes are moved on the
calendar to different dates; cut-and-pasting is also used to change
schedules. Markers are used to color blocks of dates for training by
particular POs. FLETC's scheduling subsystems at three of the
four[Footnote 17] campuses are also predominantly manual systems that
require labor-intensive corrections if even one course is changed. In
addition, the scheduling subsystems do not interface with one another,
thus requiring time-consuming efforts to communicate.
The paper-intensive nature of the system raises issues of internal
control. FLETC's ability to adequately schedule training for most of
its 75 POs at its campuses is further hampered by its reliance on
certain key schedulers to keep the system functioning. The campuses in
Charleston and Artesia each have a single scheduler to handle all of
the scheduling, without any backup. Further, at the Glynco campus, the
loss of key scheduling documents that are currently kept in a single
"master binder" without a backup could significantly hamper FLETC's
scheduling. FLETC schedulers said that if this binder were to be lost
or destroyed, they would have to undertake a time-consuming process to
manually recreate most of the training schedules by soliciting relevant
information from affected POs. In this regard, according to the
Comptroller General's standards for internal control,[Footnote 18]
vulnerable assets, in this case the master binder, should be subject to
secure physical control in order to be safeguarded against loss; in
addition, a disaster recovery plan helps recover from a loss. The
standards also call for the accurate and timely recording and
documentation of transactions and significant events, in this case the
scheduling of training. According to the standards, documentation of
transactions and events needs to be complete and accurate to facilitate
tracing from initiation to completion.
FLETC has acknowledged the manual scheduling system's shortcomings and
its implications for efficiency and risk management. FLETC officials
told us that its scheduling system does not provide for the optimal use
of existing facilities, especially for sequencing classes. For example,
only one class can use a 4-course driving range at any given time;
while the class completes one course, the other three remain idle. More
efficient scheduling would enable four classes to rotate through the
driving range's courses. The Master Plan's analysis also suggests that
automating the scheduling could help gain efficiencies in the use of
existing facilities.
FLETC officials have recognized the need for a fully automated system
that can address FLETC's vast scheduling needs, including quickly
incorporating any changes once a schedule has been prepared. In this
regard, FLETC listed in its draft SASS RFP the challenges, and their
effects, associated with its manual system. The draft RFP stated that
current business processes in support of FLETC's student administration
and scheduling were complex, not integrated, and were often performed
manually. Historically, according to the draft RFP, this has resulted
in (1) FLETC schedulers reacting to ever-changing training projections;
(2) a manual, paper-laden, and slow student scheduling and registration
process requiring student information to be entered into multiple data
systems; and (3) inconsistent student information processed throughout
the system and numerous changes caused by ever-changing projections in
the demand for training. A FLETC official also said that a manual
recalculation and distribution of class schedules each time a change is
made to a single class.
Background on the SASS Acquisition:
The SASS acquisition project began in 1999, when Congress provided
FLETC with $350,000 to begin planning for automating its scheduling
process. After completing requirements definition in December 2000 and
its market research activities in December 2001, FLETC decided to
expand the project to provide a training management system, rather than
just a scheduling system. In researching SASS alternatives, FLETC
officials determined that utilizing commercially available components
or products was its preferred alternative. Accordingly, FLETC decided
to pursue a COTS. FLETC began developing its request for vendor
proposals in 2001 and in May 2002 FLETC issued a request for proposals,
a solicitation package that included background on the project, project
objectives, system requirements, and other information. However,
according to FLETC officials, vendors were concerned about the time and
expense required to submit an adequate proposal as well as the criteria
proposed to evaluate potential solutions. As a result, FLETC withdrew
the solicitation and is currently revising it to address these
concerns. According to a FLETC official, issuance of the SASS RFP has
been delayed, pending the outcome of an effort to determine whether a
similar system being developed separately by the Border Patrol,
Customs, and INS can be used by FLETC. This effort is discussed in the
following sections.
FLETC plans to implement SASS within a 1-year period after signing a
contract, and officials estimate an approximate 5-year cost of $10
million (1 base-year and 4 option-years, including maintenance). SASS
is a subproject within an overall FLETC information technology (IT)
modernization project. Because FLETC intends to encourage vendors to be
innovative in offering possible solutions, the system requirements to
be included in the solicitation are for information purposes only. For
example, FLETC officials said that SASS may or may not be physically
located at FLETC's Glynco campus, depending on the selected solution,
but all four facilities should have access to the system.
FLETC Has Yet to Address Important SASS Acquisition Issues:
FLETC's plans and activities for acquiring SASS generally include the
performance of certain key acquisition management functions, such as
acquisition planning, solicitation, requirements management, and
project management. However, first, FLETC has yet to focus on another
key acquisition function--risk management. Second, with the exception
of solicitation, FLETC's attempt to obtain a COTS-based system lacks
some acquisition best practices. These practices call for continuous
tradeoff among such interdependent acquisition variables as system
requirements, commercially available system products and components,
cost and schedule constraints, and the architectural environment within
which the system will operate. Third, FLETC solicitation activities
have not adequately addressed SASS security requirements. Taken as a
whole, this means that FLETC's SASS acquisition is currently at risk of
not delivering a system solution to best meet FLETC's needs.
Certain Acquisition Functions Are Being Performed:
Carnegie Mellon University's Software Engineering Institute (SEI),
recognized for its expertise in acquiring software-intensive systems,
has published an acquisition management model that defines key
acquisition functions and assigns them to five incremental stages of
maturity.[Footnote 19] According to SEI, the following acquisition
functions are part of a minimum set that need to be practiced in order
for software-intensive systems to be acquired in a repeatable,
effective manner: acquisition planning, solicitation, requirements
management, and project management.
On its SASS acquisition, FLETC is performing these functions in a
manner that is generally consistent with SEI's maturity model, as
described later. According to FLETC officials, these functions are
being performed because they are following agency IT guidance that
specifies processes and procedures for acquiring and managing IT
investments. By performing them, FLETC is providing a margin of
assurance that SASS will be effectively acquired.
Acquisition planning. The purpose of acquisition planning is to ensure
that reasonable planning for the acquisition is conducted and that all
elements of the project are included. Among other things, this involves
assigning project responsibilities and documenting an acquisition
strategy that specifies, for example, acquisition objectives and
methods, project constraints, contract types and terms, and schedule
and cost estimates. For SASS, FLETC is performing these activities.
Responsibility for the acquisition has been assigned to IT and
contracting personnel. FLETC has also documented an acquisition
strategy that defines acquisition objectives and methods (e.g., maximum
use of commercial products) and project constraints (e.g., FLETC's
right to inspect all services provided). FLETC has also defined a
contract type and terms, (5-year, fixed cost with award fee), and it
estimates that the selected system will be implemented within 1 year of
contract award and cost about $10 million over the 5-year contract
period.
Solicitation. The purpose of solicitation is to prepare a documentation
package that identifies acquisition needs and selects the best provider
and solution to meet those needs. Examples of solicitation practices
include educating end users and others about the planned solicitation
and engaging them in developing a solicitation package that includes
objectives; technical and other product evaluation criteria; and
contract acceptance procedures, criteria, and payments. FLETC has done
this for the SASS acquisition. The SASS project office has engaged
FLETC's training divisions in developing the package and educated them
about business process changes that may need to accompany the system's
implementation. Further, the solicitation package[Footnote 20] (i.e.,
RFPs) contains FLETC's objectives for the overall acquisition;
evaluation criteria; and acceptance procedures, criteria, and payment
methods.
Requirements management. The purpose of requirements management is to
establish a common and unambiguous definition of requirements that is
understood by users, the project team, and suppliers. Requirements
management includes, among other things, establishing the project
scope, assigning specific responsibilities for managing the
requirements, collecting end-user input, and establishing a baseline
set of requirements before releasing the solicitation. FLETC has done
this. For example, FLETC has defined the project scope to be a total
system solution for student registration and scheduling. FLETC has also
assigned requirements management responsibilities to an integrated
process team, obtained user input by canvassing FLETC training
divisions and having them verify the system requirements, and
established a baseline requirements set in a December 2000 software
requirements specification.
Project Management. The purpose of project management is to manage
project office activities and support units to ensure a timely,
efficient, and effective acquisition. Examples of project management
practices are defining project responsibilities, engaging user
organizations, and identifying project costs and schedules. FLETC has
performed each of these. Namely, an IT project manager, supported by a
staff project office, is in place, training division heads are
participating in the project, and cost and schedule estimates have been
developed.
Acquisition Risk Management Is Not Being Performed:
SEI's acquisition model also recognizes the need to manage acquisition
risks. Moreover, many software acquisition experts consider risk
management to be one of the most important acquisition areas. The
purpose of risk management is to identify risks as early as possible,
manage those risks, and develop and implement a risk management
process. Risk management includes identifying risks and categorizing
them based on probability and impact, developing risk mitigation
strategies, implementing the strategies, and tracking and reporting on
progress.
During our review, FLETC officials told us they had yet to begin risk
management activities, or establish any type of risk management
function, and they did not plan to begin such activities until they
receive the vendors' proposals. Following our inquiry, officials told
us they (1) recognize that risk management is important to overall
project success; (2) have a rough draft of a risk management plan; and
(3) in May 2003, developed a project risk assessment plan for SASS.
FLETC has not provided us with these documents, and not having
completed these actions at this point is not consistent with SEI
guidance, which advocates early and continuous management of risks so
as to minimize the chances of risks becoming actual problems (i.e.,
system cost, schedule, and capability shortfalls). By waiting to manage
risks, FLETC is not proactively mitigating known SASS risks; such as
those that SEI reports to be inherent in a COTS-based acquisition
(e.g., volatility of the commercial market and organizational
resistance to business process changes required by a COTS-based
solution). The result is a reduced probability of delivering promised
SASS capabilities on time and within budget.
Approach to Performing Acquisition Functions Lacks Two Key Elements:
Notwithstanding the fact that FLETC is performing key SASS acquisition
functions, it is deficient in its performance of these functions in two
ways. First, its solicitation package does not adequately address
system security. Second, with the exception of solicitation, FLETC has
not adequately provided for the use of COTS-based system acquisition
best practices in performing these functions. According to FLETC
officials, the former is an oversight that they have hired a security
manager to address, and the latter is a byproduct of their focus to
date on solicitation activities. They added that they plan to
incorporate COTS-based system acquisition best practices in their
performance of other SASS acquisition function as soon as the
solicitation is released. Until they do, the SASS acquisition is at
risk of not delivering FLETC users with a secure, long-term, cost-
effective system to support FLETC's mission needs.
Security. Since 1997, we have designated information security as a
governmentwide, high-risk area because of significant and pervasive
agency weaknesses in controls over computerized operations, due, in
part, to the government's increasing reliance on commercially available
information technology.[Footnote 21] Addressing these risks requires
that agencies ensure that adequate security controls are part of every
new system acquisition and deployment. In the case of SASS, this means
that FLETC needs to, among other things, adequately specify its
security requirements in the SASS solicitation package. However, FLETC
has not done so. For example, the SASS security requirements reference
the Computer Security Act of 1987[Footnote 22] but do not specify
relevant National Institute of Standards and Technology
guidelines.[Footnote 23] These guidelines, for example, specify
authorization and access controls. After we brought this to the
attention of FLETC officials, they said that this was an oversight,
that they have hired a security manager to address this area of
concern, and that the revised solicitation package will include missing
security requirements. If it does not, FLETC risks acquiring and
deploying a system that will not be secure.
COTS-based System Acquisition Practices. SEI research shows that the
market-driven capabilities embedded in commercial products and
components necessitate that organizations not be overly requirements
focused when acquiring COTS-based systems. Rather, SEI advocates that
organizations plan and execute these acquisitions in a manner that
recognizes the competing interests--and necessary tradeoffs--among
four acquisition variables: system requirements, the organization's
architectural environment (current and future) that the system needs to
operate within, the cost and schedule constraints that limit the system
acquisition, and the commercially available system products and
components (current and future).[Footnote 24] According to SEI,
analyzing and understanding the tradeoffs among these variables are
vital to informed decision-making and thus should be addressed early
and continuously throughout a project's life cycle. As such, provision
for performing this fundamental tradeoff analysis and decision-making
should be embedded in each acquisition function, including the ones
that we reviewed for SASS.
To FLETC's credit, its solicitation plans and activities provide for
employing these COTS-based system practices. For example, the
solicitation does not prescribe a solution that is based upon
customized, "must-have" requirements. Rather, FLETC provided
"information-only" requirements, intended to provide an understanding
of the nature of its scheduling process needs and environment so as to
maximize the flexibility afforded vendors in proposing approaches to
meet these needs.[Footnote 25] However, FLETC's SASS acquisition
planning, requirements management, and project management efforts do
not similarly provide for performing these COTS-based system
acquisition practices. For example, the SASS acquisition strategy does
not describe how FLETC will evaluate the tradeoffs among the four
acquisition variables. Also, the SASS requirements document, although
specifying requirements in a manner to provide prospective offerors
flexibility, does not address the FLETC architectural environment
(current and future) that the SASS solution will need to operate
within. According to FLETC officials, they have not addressed this
variable because they want the proposed SASS solution to drive this
environment. Last, SASS project management planning does not include,
for example, designated resources or a specific analytical approach and
tool for performing the tradeoff analysis. Following our inquiries,
FLETC officials told us that they have yet to incorporate these COTS-
based system best practices into each SASS acquisition function because
they have focused on the solicitation function. However, they added
they recognize the need to address these issues and plan to complete
them after the solicitation package is released. They also noted that
while they had followed the best acquisition practices as defined by
the SEI's Software Acquisition Capability Maturity Model®, they had not
documented these efforts, but would do so in the future. We agree that
FLETC has followed some, but not all of these best practices. As we
stated earlier, FLETC has not followed software acquisition risk
management best practices. In addition, SEI has issued best practices
for acquiring COTS-based systems that FLETC is not following. Until
they do, the SASS acquisition will be at risk of not meeting its cost,
schedule, and performance commitments.
FLETC Is Exploring the Use of an Existing Automated Scheduling System:
During our work, we learned that the Border Patrol Academy, in
conjunction with INS's Immigration Officers Academy and the Customs
Academy, were in the process of adding an automated scheduling module
to their ACMS. The Border Patrol and Immigration Officer Academies
currently use this system for processing non scheduling-related class
management activities. We asked a Border Patrol Academy official, who
brought the acquisition of the ACMS scheduling module to our attention,
whether the module the academy was acquiring would potentially
duplicate the scheduling functions of the proposed SASS that FLETC was
about to acquire. The Border Patrol official said he did not know
whether there would be any duplication between the systems. He also
said that the Border Patrol Academy was acquiring its own system
because it did not want to wait until FLETC acquired its system,
suggesting that this process was moving too slowly. Furthermore, he
said that the three academies had found an economically feasible way to
add an automated scheduling module to ACMS.
We encouraged academy officials, and a FLETC official involved in
FLETC's SASS acquisition, to meet and discuss the feasibility of FLETC
using the ACMS scheduling module instead of acquiring its SASS.
Although FLETC stated that it evaluated ACMS two years ago, these
officials met and according to one FLETC official, agreed FLETC could,
instead of potentially spending over $10 million in the cost of
implementing SASS, invest considerably less to merge FLETC's
requirements into the ACMS automated scheduling module, which is still
under development. Separately, according to FLETC, as a result of a
request of the DHS Chief Information Officer, a FLETC-chaired working
group looking at capacity issues within DHS was tasked to seek input on
the SASS from its participants. That review was to obtain input toward
identifying an enterprise-wide solution to training scheduling for all
of the DHS. Another FLETC official said that the FLETC-chaired working
group was considering whether to recommend SASS as the standard
training scheduler, or, possibly, use ACMS as the standard.
As of late July 2003, FLETC was in the process of obtaining its
procurement and legal approvals to conduct a benchmark test on ACMS's
scheduling module, once it is completed and tested, to determine
whether ACMS's module could provide at least about 80 percent of the
functions that the proposed SASS system could provide.[Footnote 26] If
ACMS was able to provide the needed functionality, FLETC would cancel
its SASS RFP and merge into ACMS's automated scheduling system, thus
saving money while also meeting FLETC's considerable training
scheduling needs of its 75 POs.
The Status of FLETC's Board of Directors Is Unclear, and DHS Has Begun
to Provide Oversight and Guidance:
The status of FLETC's Board of Directors is unclear. Further, the
Board's membership, roles and responsibilities, and past practices are
not fully consistent with prevailing governance and management control
best practices. Moreover, given its recent transition into DHS, FLETC
needs guidance and oversight to address its transformational
challenges. A DHS official said that DHS has recently assumed
responsibility for FLETC and has begun to work with its officials on
ways to address these challenges. The official also said DHS also
recognizes the role an effective FLETC Board could play in enhancing
governance.
The Status of the FLETC Board of Directors Is Unclear:
Prior to its most recent meeting in November 2002, FLETC's Board of
Directors had not met for 3-½ years, according to a FLETC official.
However, according to our review of Board minutes, the Board had not
met for a period of 5 years prior to its November 2002 meeting (the
last recorded meeting was held in November 1997). According to the
agenda of its November 2002 meeting, the Board was to address, among
other things, its roles and responsibilities, the fiscal year 2003 and
2004 budgets, and FLETC's Master Plan. The draft minutes from that
meeting indicate that the Board discussed, in broad terms, Justice
Department concerns about FLETC's training services, including the
availability of on-campus dormitory space. The Board also discussed the
status of the FLETC MOU and the Master Plan, respectively, but did not
discuss budget matters. Subsequent to the November meeting, a FLETC
official who attended the meeting informed us that within the context
of debating the Board's roles and responsibilities, the matter of
whether the Board would continue as an ongoing entity became unclear.
In June 2003, a DHS official said an effective FLETC Board was
important to the overall governance of FLETC activities. He also
pointed out that DHS was in the process of determining how the training
mission was to be managed in the new department. Issues under
consideration include how PO training needs would be identified, where
training would be offered, and how capacity and demand issues would be
addressed. Determining the status, roles and responsibilities of the
FLETC Board will be done within this context. Nevertheless, the DHS
official acknowledged that having an effective Board would help FLETC
to address its challenges.
Board's Membership, Roles and Responsibilities, and Past Practices Are
Not Fully Consistent with Prevailing Governance and Management Control
Best Practices:
Notwithstanding the uncertainty surrounding its status, the Board's
membership, roles and responsibilities, and past practices are not
fully consistent with prevailing best practices for governance and
internal and management control.[Footnote 27]
Membership. Regarding the size of a board, prevailing governance best
practices consider smaller boards to be often more cohesive and to work
more effectively--in this regard, the FLETC Board is composed of eight
members. Specifically, FLETC's Board presently has five term-
representatives who are voting members (one of whom has a 2-year
rotational term) and three nonvoting members. FLETC's Director serves
as the nonvoting Executive Secretary of the Board. As of June 2003, the
Board's five voting members were DHS's Under Secretary for Border and
Transportation Security, Justice's Acting Assistant Attorney General
for Administration, the Department of the Interior's Deputy Assistant
Attorney for Law Enforcement, the General Services Administration's
Inspector General, and the Administrator of TSA. The three nonvoting
members of the Board are the Office of Personnel Management's Senior
Advisor for Learning and Knowledge, OMB's Associate Director for
General Government Programs, and the U.S. Capitol Police Board's
Chairman.
Regarding the composition of the Board's membership, there are two
departures from governance best practices. First, the Director of FLETC
is not a member of the Board, but, rather, its nonvoting Executive
Secretary. Under governance best practices, the head of the
organization being overseen by a board of directors is a full member of
that board and, in fact, in many cases also serves as the chair of the
board. There is currently a strong debate about this point. On the one
hand, the Business Roundtable best practices view this dual role as
serving as a bridge between an organization's management and its board,
ensuring that they both act with a common purpose. On the other hand,
the Conference Board Commission on the Public Trust and Private
Enterprise[Footnote 28] recommends splitting the role of chief
executive and chairman of the board to ensure an "appropriate balance"
between the board and chief executive.
Second, there is not a substantial degree of independence of FLETC
Board members from its operations. As currently configured, all Board
members are either related to a FLETC PO (e.g., TSA and Capitol Police)
and/or have a role in reviewing and/or setting its budget (OMB) or
policies (Office of Personnel Management). Governance best practices
stress that a substantial part--in most cases, a majority--of a board's
membership should be independent of the entity it is overseeing. Such
independence could help avoid, among other things, potential conflicts
of interest. Further, independent board members, knowledgeable of
information about the organization they are overseeing, can provide a
useful perspective on the significant risks and challenges facing that
organization and help ensure the exercise of independent judgment that
is at the core of a board's oversight function. The 1970 FLETC MOU that
established the Board allows for the expansion--and, implicitly, a
change in its composition--of its membership by a majority vote of its
members.
Roles and Responsibilities. The 1970 FLETC MOU, as amended, enumerates
the Board's "final authority" over training policy, programs, criteria,
and standards of FLETC for resolving matters of conflicting training
requirements. This authority includes (1) establishing priority systems
governing the scheduling of courses and use of training facilities; (2)
establishing policy as to student residence requirements, leave, and
other matters relating to student administration; (3) reviewing FLETC's
budget as to whether it meets its mission and making budget
recommendations to, now, the Secretary of DHS; and (4) evaluating the
effectiveness of the overall training program. The Board also has
authority to establish criteria for the selection of the FLETC Director
and to approve the selection; it may also recommend the removal of the
Director to, now, the Secretary of DHS.
Current FLETC officials have implemented the Board's roles and
responsibilities under the MOU as pertaining only to training issues,
and not operational issues concerning FLETC, such as the budget and the
selection of the FLETC Director. In this regard, the current FLETC
Director who was appointed by the Secretary of the Treasury was
selected independently of the Board because, at the time, it was
dormant. Under governance best practices, however, the selection and
oversight of an organization's head is a board's paramount duty to help
ensure competent and ethical operation. As discussed earlier, under the
FLETC MOU, the Board has the authority to establish criteria for the
selection of the FLETC Director and to approve the selection.
Additional oversight responsibilities for boards include reviewing and
monitoring the implementation of strategic plans; reviewing annual
operating plans and budgets; advising management on significant issues
facing the organization; reviewing and approving significant actions;
and nominating directors, and overseeing effective governance,
including the composition, structure, practices, and evaluation of the
Board.
Past Practices. As discussed earlier, our review of minutes from past
Board meetings showed that the Board did not meet for 5 years prior to
its November 2002 meeting. The Board has not met since November 2002,
pending a decision on its status.[Footnote 29] In this regard, FLETC's
own MOU stipulates that the Board shall meet quarterly, and at such
other times as may be determined by a majority of the Board or its
presiding officer. Further, governance best practices call for boards
to meet as frequently as needed in order for members to discharge
properly their responsibilities. In this regard, the "typical" board of
a large publicly traded corporation meets about eight times a year.
Other than what is broadly described in the FLETC MOU, the Board's
functions and processes implementing its roles and responsibilities are
not documented. According to the relevant governance best practices, it
is important that each board review its policies and practices on
governance matters--the standard defers the formalization of such
policies and practices in written form to the boards themselves,
depending on the circumstances they face. On one hand, the standard
points out that insufficient formalization often leads to a lack of
clarity, while on the other hand, it cautions that over-formalization
can lead to rigidity--emphasizing form over substance. GAO and OMB
standards for internal and management control respectively, stress the
need for written documentation. GAO's standards for internal control
require that an agency's policies, directives, and operating procedures
be clearly documented and available for examination. OMB's standards
for management control state that an organization's authority,
responsibility, and accountability should be defined and documented.
The Board did not periodically review its structure, functions, and
processes. According to governance best practices, boards should, from
time to time, review their own structure, governance principles,
composition, agenda, and processes to consider whether they are
functioning well in view of their responsibilities and help ensure
sound governance and oversight. GAO and OMB standards broadly suggest
that periodic external evaluations of, among other things, an
organization's structure and functions help ensure that they are
responsive to changing conditions. In this regard, FLETC is facing
significant changes in its environment--the post-September 11 surge in
demand for its services and its transition to DHS.
DHS Has Begun to Provide Oversight and Guidance to FLETC:
DHS has the opportunity to help FLETC face its challenges during the
current period of transformational change. DHS officials said that
other competing priorities, such as building the organizational
structure of the new department and addressing its role in the ongoing
war on terrorism, did not permit them to focus extensively on providing
policy or other guidance to FLETC about planning, scheduling, and
governance (e.g., oversight and accountability). A DHS official said
that the department had recently started focusing on specific FLETC
issues. In this regard, DHS plans to begin focusing on a broad range of
issues, including the Master Plan and the FLETC Board of Directors.
With respect to the Master Plan, the DHS officials said that in
general, they viewed the plan as a useful document but not as the
department's guiding plan for the future of FLETC and its facilities.
One official said that DHS was considering a new business plan for
FLETC, one that would make DHS "more than just a landlord" regarding
federal law enforcement training. This official further said--and a
FLETC official separately corroborated--that DHS's vision for FLETC
would include expanding its authority on decisions related to federal
law enforcement training.
Conclusions:
Overall, FLETC and DHS find themselves at a crossroads for defining and
planning for the future of federal law enforcement training. The
demands placed on FLETC and DHS by the new security environment facing
the country are considerable. Yet, we note that while demand for
training continues to surge, the fiscal year 2004 budget request for
FLETC is about $26 million less than the fiscal year 2003 enacted
level; the request for staffing calls for about 120 fewer permanent
positions than those enacted for fiscal year 2003. The decline in
resources risks exacerbating FLETC's already-strained capacity to
provide training.
To meet the demands placed upon them, collective planning and execution
by FLETC and its many stakeholders, and active and sustained oversight
and guidance by DHS, are necessary to:
* achieve a proper balance between the surging demand for training and
the necessary capacity to meet it;
* schedule vital training in an efficient and timely manner; and:
* provide for effective governance and oversight that ensures that all
stakeholders' interests are addressed.
Despite the capacity constraints, FLETC generally received good marks
from POs about its ability to meet their basic training needs. However,
FLETC is facing considerable challenges in responding to the demand for
training in a systematic manner. For example, FLETC's overall planning
effort is essentially reactive, rather than proactive. Specifically,
FLETC does not currently have a formal contingency plan to help guide
management decision-making with respect to capacity planning, although
it has developed some planning documents (i.e., its 1989 Master Plan
with updates and the current Master Plan). Although having an updated
Master Plan to guide short-and long-term planning is a step in the
right direction and may help provide some guidance to DHS, the final
draft of the plan has methodological limitations and inaccurate cost
estimates. In addition, FLETC has taken very limited action thus far in
planning for the use of alternative training such as off-site training
and e-learning.
FLETC's capacity challenges are likely to be compounded during its
transition into DHS. This transformational change for FLETC and a
number of its POs will likely bring considerable uncertainty, as the
new department is equally likely to redefine the POs' missions to focus
on homeland security. The redefined mission could result in the need
for updated training programs and modules that, in turn, would require
new or modified training facilities. A further uncertainty involves the
type and scale of future terrorist attacks and the response by the
federal government. A comprehensive planning process, encompassing,
among other things, sound methodologies and contingency planning, is
essential to help meet the current capacity challenges facing FLETC,
and also will help position it to meet future challenges.
FLETC faces a challenge to automate the scheduling of training for its
75 POs. Notwithstanding its performance of certain important system
acquisition functions, FLETC is not doing enough to ensure that it
acquires a system that will optimally support its current and future
mission needs. Without instituting a proactive risk management
function, FLETC increases the risk that avoidable potential problems
will become costly actual problems, meaning they would result in a less
capable system being delivered late and/or over budget. Further, and
equally important, delays in making both security and COTS-based
acquisition best practices integral to its SASS project could
exacerbate potential problems. Without adequately addressing both,
FLETC increases the risk of the system not being adequately protected
against unauthorized access and corruption, not being available when
needed, and not performing as intended. It is important that FLETC
address its SASS acquisition management weaknesses before the project
advances much farther. Although FLETC is in the initial stages of
acquiring SASS, we are encouraged that through in part our
intervention, it is also in consultation with the Border Patrol whether
its ACMS, with some modification, might serve FLETC scheduling needs,
thus saving an estimated $10 million cost over 5 years, while spending
considerably less to adopt the ACMS.
Reconvening the FLETC Board of Directors in November 2002, albeit
briefly, was a step in the right direction; however, the Board's status
is unclear. Given FLETC's recent transition into DHS, the Board,
consistent with its mandate under the FLETC MOU, needs to be retained
in order to offer sustained governance and oversight to ensure
transparency and accountability. In this regard, governance, in the
form of boards of directors, has the important role of overseeing
management performance and ensuring independent and objective decision-
making. As FLETC considers revising its MOU, it has an opportunity to
incorporate prevailing governance and internal and management control
best practices about the functioning of the Board to help FLETC address
its challenges and achieve transformational change.
Recommendations for Executive Action:
To address FLETC's capacity constraints and planning challenges, we
recommend that the Secretary of Homeland Security instruct the Director
of FLETC to:
* develop a formal contingency plan that incorporates both physical and
human resource solutions for at least the major potential constraints
or choke points that can impede the law enforcement training delivery
system;
* consider alternative approaches to estimating future facility
construction needs in its Master Plan, including (a) specification of a
range of training workload scenarios, and (b) after consultation with
experts, application of risk analysis techniques; and:
* develop plans for the use of alternative or additional law
enforcement training campuses should circumstances limit or prohibit
the use of available facilities.
To enable FLETC to monitor and reduce the risk associated with the
degradation of FLETC facilities and infrastructure, we recommend that
FLETC:
* closely monitor overall facility conditions through establishment of
periodic facility condition assessments of mission critical facilities
and infrastructure and use of a computerized backlog of maintenance and
repair and:
* adopt a performance measurement, such as FCI, to monitor the trend of
FLETC facilities condition and to also offer a benchmark indicator for
comparison to industry standards.
To increase the chances of SASS success, we recommend that the
Secretary of Homeland Security instruct the Director of FLETC to make
proceeding with the SASS acquisition conditional upon improvements in
SASS acquisition management activities. We further recommend that these
improvements, at a minimum, include adding risk management as a SASS
acquisition function and ensuring that this function provides for:
* the identification and documentation of risks;
* the categorization of risk severity based on probability of
occurrence and potential impact;
* the development and implementation of risk mitigation strategies;
and:
* the reporting of risk status, including progress in implementing
mitigation strategies.
We further recommend that the improvements in SASS acquisition
management activities should also:
* treat known risks in acquiring COTS-based systems as SASS-specific
risks, including volatility of the commercial market and an
organization's resistance to the business process changes introduced by
a COTS-based solution;
* ensure that security is made a clear, explicit, and visible component
of system requirements in the SASS solicitation package; and:
* ensure that COTS-based system acquisition best practices are made a
clear, explicit, and visible aspect of all acquisition functions,
particularly with respect to continuously assessing the tradeoffs among
system requirements, FLETC's architectural environment, the project's
cost and schedule constraints, and the commercially available system
products and components.
To help provide sustained oversight and enhance accountability, we
recommend that the Secretary of Homeland Security retain the FLETC
Board of Directors. We further recommend that working with FLETC's POs,
their parent departments and agencies, and the Board's current members,
the Secretary of Homeland Security review the Board's mission, roles
and responsibilities, and functions and practices to better align them
with prevailing standards of governance and internal and management
control.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Secretary of DHS and the
Attorney General for comment. We received comments from the Under
Secretary of DHS for Border and Transportation Security that are
reprinted in appendix IV and discussed later. In addition to DHS's
written comments, FLETC provided technical comments and clarifications,
including updates on its SASS acquisition, which are incorporated in
this report where appropriate. Justice did not provide formal written
comments; the Associate Assistant Attorney General for Federal Law
Enforcement Training submitted an email with two general comments about
the issues of FLETC training capacity and governance, respectively.
In their comments, DHS and FLETC generally agreed with the information
presented in the report and with our conclusions and recommendations,
and outlined actions they either had taken or were planning to take to
implement the recommendations. DHS noted, for example, that the issues
related to capacity, scheduling, and governance discussed in the report
were already being considered by the department and would be given its
full attention. Regarding specific actions to implement our
recommendations, FLETC said that it was developing a formal contingency
plan to respond to future capacity constraints and choke points and to
identify alternative or additional training assets that could help in
this response. Also, FLETC indicated that it had taken action to
reconstitute the Board of Directors; FLETC also indicated that it was
taking action to determine the prospective membership, and roles and
responsibilities of the reconstituted Board.
At the same time, FLETC expressed some concerns regarding the report.
In its general comments, FLETC said, first, that it "strongly
disagreed" with the report's title, asserting that it implied broader
concerns about capacity planning and management oversight than the
report's contents supported. We believe that the report clearly and
exhaustively describes the challenges FLETC faces in planning for
future capacity and articulates the importance of sustained management
oversight of, among other things, the planning effort to help ensure
its success, and that the report's title accurately reflects these
challenges. Second, FLETC said that the report did not point out that
the flow of federal law enforcement personnel was not constrained by
training capacity, but by the inability of POs to recruit such
personnel. We note that because it was beyond the scope of our work,
the report did not address recruitment as a distinct issue, but did
point out that shortfalls in POs' recruiting contributed to projected
demand for training not materializing. We also note that the core issue
is FLETC's ability to train those personnel who actually need to be
trained. In this regard, the report clearly describes how FLETC's 5-
day/8-hour capacity is strained; accordingly, additional recruits would
only serve to exacerbate FLETC's capacity challenges. Third, FLETC said
that the report did not adequately recognize the "extraordinary
success" of FLETC and the POs in meeting critical law enforcement
training requirements. We believe that the report clearly recognizes
that FLETC has been able to generally meet its POs' demands for basic
training during a time of constrained capacity and surging demand, and
highlights the actions FLETC has taken to accomplish this. Fourth,
FLETC said that projected workloads (i.e., demand for training) were so
dynamic that some of those cited in the report were already obsolete
and urged caution in their treatment. We note that during our work we
repeatedly corroborated--through interviews with FLETC officials and
related documentary verification--the currency and validity of the
projected workloads as presented in the report; further, FLETC did not
provide us with any updated workload projections as part of its written
comments. Fifth, FLETC said that the report implied that it was
accountable for variables beyond its control, such as the timeliness of
recruitment, operational needs, class cancellations, shifts in training
strategies, and funding, all of which impact capacity planning. We
believe that the report adequately describes these factors as
contributing to the level of training actual attendance, and does not
imply that FLETC is accountable for them.
In its technical comments, FLETC acknowledged that its predominantly
manual scheduling process was time-consuming and required
modernization. FLETC questioned, however, that automating the
scheduling process would result in significant increases in capacity.
We note that, first, FLETC's own Master Plan indicated that if the
scheduling process were to be automated, capacity efficiencies would
likely result and the plan would need to be revised, and second,
FLETC's documentation related to the SASS acquisition indicated that
automation would result in capacity efficiencies. In commenting on our
use of an example to illustrate the effect of choke points, FLETC said
that resurfacing the Charleston campus' emergency response driving
range did not result in the cancellation of any Border Patrol classes.
We note that a FLETC official cited the resurfacing as a specific
example of a capacity-constraining choke point that resulted in the
cancellation of three Border Patrol classes, which have not been
rescheduled. In commenting on the possible use of ACMS as an
alternative to its proposed acquisition of SASS, FLETC said, among
other things, that the evaluation of ACMS's scheduling component was in
the preliminary stages. Accordingly, it was too early to tell whether
ACMS's scheduling component would meet FLETC's requirements, and
whether significant cost savings would be realized. We note that a
FLETC official involved in the evaluation of ACMS, in responding to our
questions, provided a written response, stating that if ACMS provided
about 80 percent of the functionality sought by FLETC it could be
adopted as the scheduling system at considerably less cost than the
estimated $10 million cost of SASS.
In its comments, regarding training capacity, Justice stated that if
FLETC's Glynco campus (as well as the Charleston) campus were used to
provide basic training and the Artesia Campus was used to provide
advanced and specialized training, then FLETC would be able to achieve
a better balance in the utilization of its campuses and mitigate the
capacity strains it is experiencing. Regarding governance, Justice
stated that the FLETC Board of Directors would work well as currently
configured, if it were allowed to function under its original mandate
as defined in the MOU that created FLETC.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of the Senate and House Committees on Appropriations.
In addition, we are sending copies to the Secretaries of Homeland
Security and the Interior; the Attorney General of the United States;
and the Director of OMB. We will also make copies available to others
on request. In addition, the report will be available at no charge on
GAO's Web site at http://www.gao.gov.
If you have any questions about this report or wish to discuss it
further, please contact me at (202) 512-8777 or Seto J. Bagdoyan,
Assistant Director, at (202) 512-8658. Key contributors to this report
are listed in appendix V.
Richard M. Stana
Director, Homeland Security and Justice Issues:
Signed by Richard M. Stana:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Given concerns about whether the Federal Law Enforcement Training
Center (FLETC) can continue to meet the rising training demands of its
75 federal partner organizations (PO) following the September 11th
attacks, the House Appropriations Committee asked us to develop
information on the following topics:
* The extent to which FLETC is able to meet the current and projected
demand for training, how FLETC is planning to meet the demand, and the
associated costs and the extent to which FLETC coordinates or uses
existing, non-FLETC government training assets, and any associated
costs.
* FLETC's current organizational structures and processes for
coordinating and scheduling training activities and whether FLETC plans
any changes to these structures and processes.
* FLETC's oversight and governance structures and the extent to which
these structures are providing guidance to FLETC as it addresses its
capacity and planning challenges during a period of transformational
change.
Overall, to develop the information in this report, we conducted our
work at FLETC, the Office of Management and Budget (OMB), Clark Nexsen
(the architectural/engineering firm retained by FLETC to develop a
Master Plan for facilities development at FLETC-owned campuses), and at
the following selected departments and agencies engaged in federal law
enforcement training.
* The Department of Justice (the Immigration & Naturalization Service,
the Border Patrol, the Federal Bureau of Prisons, and the U.S. Marshals
Service),
* The Department of the Treasury (the Bureau of Alcohol, Tobacco,
Firearms, and Explosives, the Internal Revenue Service, the U.S.
Customs Service, and the U.S. Secret Service), and:
* The Department of Transportation (the Transportation Security
Administration, the Federal Air Marshals, and the U.S. Coast Guard).
The Department of Homeland Security (DHS) was created during our work.
Many of the FLETC POs--identified above as components of other
departments--moved to DHS' temporary headquarters after January 24,
2003--see appendix II for a listing of the POs now in DHS. We
interviewed officials from DHS, including the Director of Operations
for Border and Transportation Security. We also interviewed FLETC and
PO officials in Washington, D.C., and at each of the four domestic
training campuses where FLETC POs train: Brunswick, Ga. (commonly
referred to as "Glynco," for Glynn County); Artesia, N. Mex.;
Charleston, S.C.; and Cheltenham, Md. We reviewed applicable public
laws and regulations; memorandums of understanding (MOU); best
practices and guidelines related to facilities and information
technology acquisition, governance, and management and internal
control; various drafts of the Master Plan, and supporting
documentation; budget submissions and justifications; training
curriculum and accreditation documents; and various reports related to
FLETC and federal law enforcement training.
We conducted our work between May 2002 and June 2003 in accordance with
generally accepted government auditing standards. We requested comments
on a draft of this report from the Secretary of Homeland Security and
the Attorney General. (See appendix IV for DHS' comments.):
Capacity, Planning, and Coordination:
To determine the extent to which FLETC is able to meet the current and
projected demand for training, how FLETC is planning to meet the
demand, and the associated costs; and the extent to which FLETC
coordinates or uses existing, non-FLETC government training assets, and
any associated costs, we interviewed FLETC, OMB, Clark Nexsen, and
department and component agency officials regarding specific training
demand and availability issues, including agency training projections
and the factors influencing these projections, physical and human
resource "choke points" (or training obstacles) at the training
campuses, agency satisfaction levels with the current delivery of
training services, and the resources needed to meet future demands for
training. We did not evaluate the quality or the effectiveness of the
training programs nor reviewed how agencies assessed the training
provided. We also reviewed the following documents obtained from FLETC
and other officials:
* Aggregate agency training projections for both basic and advanced
courses for fiscal years 1997-2008 and FLETC's adjustments to some of
these projections.
* Agency training projections for FLETC participants interviewed during
our site visits.
* The actual student attendance statistics at the FLETC training
campuses for fiscal years 1983-2002.
* The 35-, 65-, 90-percent, and final draft submittals of FLETC's
Master Plan.
* The June 1989 Master Plan and its April 1996 update.
* The latest FLETC 5-year construction plan allocation.
* FLETC, Treasury, and DHS budget documents and related justifications.
* FLETC research and development studies on particular training issues.
In addition, we reviewed the extent to which FLETC's current
infrastructure was supporting the delivery of training at each of the
campuses and whether infrastructure (e.g., water supply, sewage, and
power grid) concerns were being addressed in FLETC's Master Plan. We
did this by reviewing relevant sections of the plan, conducting campus
visits and observing infrastructure, and interviewing facilities
management officials. We also determined whether Master Plan proposals
regarding infrastructure were aligned with FLETC's Strategic Plan and
recent budget enactments and requests. Further, we determined whether
FLETC has any contingency plans to address potential sudden surges in
demand for training (e.g., Border Patrol hiring in the mid-1990s and
the recent PO training ramp-up following the September 11th attacks).
Scheduling and Coordination of Training Activities:
To determine FLETC's current organizational structures and processes
for coordinating and scheduling training activities, and whether FLETC
plans any changes to these structures and processes, we interviewed
FLETC and PO officials in Washington, D.C., and at each of the four
training campuses regarding their perceptions of the training programs
and their views about FLETC's ability to schedule and coordinate
training activities. In addition, we interviewed FLETC officials about
the status of the computer automation process for scheduling training.
We observed how FLETC staff perform their scheduling activities. Also,
we reviewed the following documents:
* Provisions of the 1970 Treasury order creating FLETC.
* The Treasury and FLETC Strategic Plans of FY2000-2005, which identify
FLETC's latest mission statements, goals, and objectives.
* FLETC's organizational chart.
* FLETC's request for proposals on computer automation.
* Records of interviews conducted by Clark Nexsen regarding POs'
training needs.
Further, we reviewed FLETC's MOUs with several of the larger agencies
to obtain an understanding of FLETC's formal management and
coordination responsibilities with respect to the POs.
To determine whether FLETC has effective controls in place for
acquiring a new student administration and scheduling system (SASS) by
focusing on whether the center was performing five key acquisition
management functions: acquisition planning, solicitation, requirements
management, project management, and risk management. We reviewed these
areas because they are critical to successfully acquiring systems.
These practices were derived from the work and research of Carnegie
Mellon University's Software Engineering Institute (SEI).[Footnote 30]
In addition, we reviewed whether FLETC was incorporating SEI best
practices for acquiring COTS-based systems[Footnote 31] in these five
functions. In conducting our review, we interviewed SASS project
officials and other FLETC staff involved in the acquisition, including
staff from the information systems division, the procurement division,
legal counsel, and the training analysis and coordination division. We
also interviewed potential SASS users from two FLETC training
divisions.
To determine whether FLETC was performing these acquisition management
functions, we compared the center's actions to those defined by SEI as
key in establishing at least basic acquisition management controls for
the five functions. In addition, we compared the center's actions to
those SEI has redefined as being key to effectively leveraging the
COTS-based systems. To document FLETC's actions, in addition to
interviewing staff, we reviewed documentation including SASS program
documentation such as contractor reports; the SASS solicitation
package, including the SASS software and database requirements;
training model schedule templates; the 2002 master class schedule;
information technology modernization 2004 capital asset plan; National
Institute of Standards and Technology security publications; and fiscal
year 2000 congressional reports.
Governance and Oversight Structure and Guidance:
To determine FLETC's oversight and governance structures and the extent
to which these structures are providing guidance to FLETC as it
addresses its capacity and planning challenges during a period of
transformational change, we reviewed FLETC's 1970 MOU establishing,
among other things, its Board of Directors, and governance and
management and internal control best practices--these were the Business
Roundtable's 2002 Principles of Corporate Governance and a 2003 report
by the Conference Board's Commission on Public Trust and Private
Enterprise titled Findings and Recommendations; and GAO's 1999
Standards for Internal Control in the Federal Government and OMB's 1995
Circular No. A-123, Management Accountability and Control. We drew from
our August 2002 report on the governance of the U.S. Capitol Police,
"Information on Capitol Police Board Roles and Responsibilities,
Operations, and Alternative Structures." We discussed governance issues
in general and the Board in particular, including its mission, roles
and responsibilities, current and past practices, and its status with
cognizant FLETC and DHS officials. We compared the governance and
management and internal control best practices with those of the Board
to determine the extent to which they were consistent.
[End of section]
Appendix II: FLETC's 75 Partner Organizations:
Following is a listing of the current (as of June 2003) Federal Law
Enforcement Training Center (FLETC) partner organizations (PO).
Agriculture:
Forest Service Office of Inspector General:
Amtrak:
Northeast Corridor Police:
Central Intelligence Agency:
Office of Inspector General Office of Security:
Commerce:
National Institute of Standards and Technology National Marine
Fisheries Service Bureau of Industry and Security Office of Inspector
General Office of Security:
Defense:
Pentagon Force Protection Agency Naval Criminal Investigative Service
National Security Agency Defense Criminal Investigative Service Office
of Inspector General Air Force Office of Special Investigations:
Education:
Office of Inspector General:
Energy:
Office of Inspector General:
Environmental Protection Agency:
Office of Criminal Investigations:
Federal Deposit Insurance Corporation:
Office of Inspector General:
General Services Administration:
Office of Inspector General:
Health and Human Services:
Food and Drug Administration National Institutes of Health Office of
Inspector General:
Homeland Security:
Customs and Border Protection (includes Customs, INS, and Agriculture's
Animal and Plant Health Quarantine inspectors, and the Border Patrol, a
division of CBP)
Federal Emergency Management Agency
Immigration and Customs Enforcement (includes Federal Protective
Service)
Transportation Security Administration
U.S. Coast Guard
U.S. Secret Service
Office of Inspector General:
Housing and Urban Development:
Office of Inspector General:
Interior:
Bureau of Indian Affairs; Bureau of Land Management; Bureau of
Reclamation; National Park Service; U.S. Park Police; Office of
Inspector General; Office of Surface Mining, Reclamation and
Enforcement; U.S. Fish and Wildlife Service:
Justice:
Bureau of Alcohol, Tobacco, Firearms and Explosives; Bureau of Prisons;
Drug Enforcement Administration; Office of Inspector General; U.S.
Marshals Service:
Labor:
Office of Inspector General:
National Aeronautics and Space Administration:
Office of Inspector General:
Nuclear Regulatory Commission:
Office of Inspector General:
Office of Personnel Management:
Office of Inspector General:
Railroad Retirement Board:
Office of Inspector General:
Small Business Administration:
Office of Inspector General:
Smithsonian:
National Zoological Park Office of Protection Services:
Social Security Administration:
Office of Inspector General:
State:
Agency for International Development - Office of Inspector General;
Bureau of Diplomatic Security; Department of State--Office of Inspector
General:
Supreme Court:
Supreme Court Police:
Tennessee Valley Authority:
TVA Police Office of Inspector General:
Transportation:
Office of Inspector General:
Treasury:
Bureau of Engraving and Printing; Financial Crimes Enforcement Network;
Internal Revenue Service; Office of Inspector General; Treasury
Inspector General for Tax Administration; U.S. Mint:
U.S. Congress:
Government Printing Office--Office of Security; Library of Congress
Police; Government Printing Office--Office of Inspector General; U.S.
Capitol Police:
U.S. Postal Service:
Office of Inspector General Postal Inspection Service--Postal Police:
Veterans Affairs:
Office of Inspector General:
[End of section]
Appendix III: Training Programs and Seminars Provided by FLETC:
FLETC offers eight variations of training programs and seminars. A
priority system is employed to fund, schedule, and deliver these
training programs. FLETC basic training programs are delivered in two
formats: Center Basic followed by an Agency-Specific Basic either on or
off site, or a single Center Integrated Basic program that combines the
Center Basic and Agency-Specific Basic concepts into one program. A
Center Integrated Basic program is granted for those agencies that have
such a unique mission that their training requirements cannot be met in
a Center Basic program. The categories of training, in priority order,
are:
1. Center Basic--law enforcement entry-level recruit training designed
to meet the training needs for multiple agencies. The job tasks and
course content are identified and validated by the participating
agencies and 100 percent of the training is managed and delivered
through FLETC staffing resources. These staffing resources are
comprised of approximately 50 percent of FLETC's permanent staff and 50
percent of Partner Organization staff. The three Center Basic programs
offered by FLETC are the Criminal Investigator Training Program, the
Mixed Basic Police Training Program, and the Natural Resource Police
Training Program.
2. Center Integrated Basic---law enforcement entry-level training
designed to meet the mission-specific or unique requirements of a
single agency. The job tasks and course content are identified and
validated by the user agency and the training is managed and delivered
through the combined efforts of the agency and FLETC staffing
resources. Like the Center Basic and Agency-Specific Basic, the Center
Integrated Basic provides both the foundational knowledge, skills, and
abilities and the specific mission requirements for that agency. FLETC
is responsible for teaching the common basic recruit training and the
agency is responsible for teaching the mission-specific courses. FLETC
can and does provide instructional resources when the agency does not
have sufficient staffing. FLETC currently offers 10 Center Integrated
Basic programs. Some examples are the United States Border Patrol
Integrated, the United States Park Police Integrated, and the United
States Marshal Service Integrated.
3. Agency-Specific Basic--law enforcement entry-level training that
supplements and follows Center Basic training programs for individual
agencies. The job tasks and course content are identified by the user
agency and the training is managed and delivered by agency staffing
resources. However, FLETC does provide staffing resources as requested.
The program builds on the foundational knowledge, skills, and abilities
that were developed in the Center Basic program and focuses on the
specific mission requirements of that law enforcement agency.
4. Center Advanced--center advanced training is developed, managed, and
delivered through FLETC staffing resources by the individual training
divisions to meet a specific or specialized need for instructor or
mission-specific training. These programs address the specialized and
instructor needs of the various Partner Organizations. Some examples of
Center Advanced training include the Firearms Instructor Training
Program, the Technical Investigative Equipment Training Program, and
the Weapons of Mass Destruction Training Program.
5. Agency Advanced--agency advanced training is developed, managed, and
delivered by the user agency and addresses the specialized training
requirements for that agency. These training courses are generally
conducted for mid-and senior-level law enforcement personnel.
6. State, local, and international training--state, local, and
international training is primarily delivered on an off-site basis.
FLETC collaborates with these entities to deliver a variety of training
programs and in support of various law enforcement initiatives.
7. Agencies without Partner Organization status participate in training
in a space available basis. Training programs are developed and
delivered as appropriate.
8. Conferences, seminars, and non law enforcement training are also
provided.
[End of section]
Appendix IV: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
July 18, 2003:
Mr. Richard M. Stana:
Director, Homeland Security Justice Issues US Government Accounting
Office Washington, DC 20548:
Dear Mr. Stana:
Thank you for the opportunity to review the draft Government Accounting
Office (GAO) report 03-736, dated July 3, 2003, about capacity issues
and related matters at the Federal Law Enforcement Training Center
(FLETC) before it is issued in final form.
It is important to point out the U. S. Department of Homeland Security
(DHS) and, particularly, the Border Transportation and Security
Directorate (BTS), view FLETC as having a "flagship" role in the
training being provided to all law enforcement personnel of the
Department, and indeed, to other FLETC customer agencies of government.
Their role already has been a stabilizing force in marshalling the
entire law enforcement training efforts of the Department during a
highly active transition period and formation of a new training
approach to homeland security's daunting mission. To their credit,
FLETC has continued to provide training services to its interagency
customers during an extraordinary period of explosive growth and
dynamic change for federal law enforcement in the post September 11,
2001 period. The flexibility shown by FLETC in partnering with the
Transportation Security Administration (TSA) to quickly complete the
training of thousands of Federal Air Marshals to meet time sensitive
deadlines is but one demonstration of the positive impact FLETC has on
law enforcement training.
There are, to be certain, many issues to be addressed by this
Department in its stewardship of consolidated law enforcement training
under FLETC's auspices. The major questions of capacity, scheduling,
and governance of training raised in this GAO report are appropriate
and justified. Some of these issues already were being considered and
all areas discussed will be given our full attention.
While there is room for improvement, it is very satisfying to note that
the respected reputation of FLETC for providing quality training for
such a diverse federal law enforcement community is not disputed nor
seriously impaired by the issues mentioned in the report.
Enclosed are the specific comments to this report that have been
compiled by FLETC. The Department endorses these comments and pledges
to work with FLEW in carrying out the recommendations and responses
presented.
Sincerely,
Asa Hutchinson
Undersecretary for Border and Transportation:
Signed by Asa Hutchinson:
Enclosure:
THE FEDERAL LAW ENFORCEMENT TRAINING CENTER COMMENTS TO THE GOVERNMENT
ACCOUNTING OFFICE REPORT 03-736:
Listed below are the comments by the Federal Law Enforcement Training
Center (FLETC) regarding the draft Government Accounting Office (GAO)
report (03-736), dated July 3, 2003, and entitled "Capacity Planning
and Management Oversight Need Improvement." The FLETC's response is
divided into three sections: General Comments, Responses to
Recommendations for Executive Action, and Errata (specific suggested
content changes to accurately reflect descriptive portions of the
report from FLETC's standpoint). We appreciate the opportunity to
comment on the proposed report and extend our acknowledgement to the
GAO staff for their courteous efforts.
I. General Comments: FLETC does not disagree materially with the GAO
recommendations for executive action contained in the draft report. The
report and its findings are valued and will be afforded full
consideration and implementation as indicated in our comments.
- FLETC strongly disagrees with the styling of the report by GAO
entitled "Capacity Planning and Management Oversight Need Improvement."
This title implies a much broader based concern than is actually the
case or is supported in the report itself.
- FLETC believes the report fails to point out that the current
constraint to the flow of new federal law enforcement officers and
agents is not the training system. The constraint is recruitment. In a
typical fiscal year, the FLETC's Partner Organizations (PO) are able to
supply only about 75% of the trainees they project as requiring
training. Since its inception over 30 years ago, the FLETC has
successfully accommodated 100% of the actual basic law enforcement
training requirement presented by its partners-even in today's
challenging "surge" workload conditions.
- FLETC believes the study fails to adequately recognize the
extraordinary success of the FLETC and its partners in dealing with a
national exigency and meeting critical law enforcement training
requirements. From our perspective, the key measure is the number of
qualified officers and agents produced, and the timeliness of their
deployment.
- The FLETC has graduated over 100,000 officers and agents since
September 11, 2001; and the accelerated pace of training achieved via
the 6-day training week and other capacity enhancements have resulted
in the on-the-job presence of several thousand additional qualified law
enforcement personnel for America on a reliable, but quickened pace.
- FLETC is perplexed that laudatory information in earlier drafts of the
report (pertaining to law enforcement training accreditation activities
and counter-terrorism:
training, for example) has been excised from the final draft. These are
impressive leadership areas that reflect positively upon FLETC and its
partners.
- During the period that GAO studied FLETC, the organization and the
needs of its partners evolved continuously. Major changes in management
structure and leadership were made, the organization was transferred to
the U.S. Department of Homeland Security (DHS), and constant
adjustments in key processes (e.g. scheduling) were made to better meet
the partners' needs. Specific to scheduling and capacity utilization,
the processes described in the report have changed and the responsible
organization has been reconfigured. Projected workloads are so dynamic
that the information cited in the report in some instances will already
be obsolete when published. FLETC therefore urges caution to all
readers in relying on the specific numbers or process descriptions in
the report.
- This report implies FLETC is accountable for variables which are
beyond its control, such as timely recruitment, operational needs,
class cancellations, shifts in training strategies, and funding
considerations, all of which seriously impact capacity planning.
II. Responses to Recommendations for Executive Action:
Capacity Constraints and Planning:
- Develop a formal contingency plan that incorporates both physical and
human resource solutions for at least the major potential constraints
or choke points that can impede the law enforcement training delivery
system.
Concur. A contingency planning team is currently working to develop a
formal contingency plan.
- Consider alternative approaches to estimating future facility
construction needs (in the Master Plan), including (a) specification of
a range of training workload scenarios, and, (b) after consultation
with experts, application of risk analysis techniques.
FLETC will consider alternative approaches and will examine the
application of risk analysis techniques. Consultation with experts will
be conducted as needs and resources dictate/permit.
- Develop plans for the use of alternative or additional law enforcement
training campuses should circumstances limit or prohibit the use of
available facilities.
Concur. FLETC's Director is presently chairing a DHS/BTS working group
that is addressing this issue, as well as broader training facility
optimization issues. The contingency plan will also address the use of
alternative or additional law enforcement campuses. FLETC already
comprises a significant majority of the total federal facilities
capacity.
Student Administration and Scheduling System (SASS):
[NOTE: The Information Technology Modernization Plan (of which the SASS
is a component) has not yet been funded. Therefore, FLETC activities to
date in this context have been necessarily limited. The comments below
are offered with this reality in mind.]
* Identify and document risks.
* Categorize risk severity based on probability of occurrence and
potential impact.
* Develop and implement risk management strategies.
* Develop [reporting mechanism] on risk status, including progress in
implementing mitigation strategies.
* Treat known risks in acquiring COTS-based systems as SASS-specific
risks, including volatility of the commercial market and an
organization's resistance to the business process changes introduced by
a COTS-based solution.
The FLETC developed a Project Risk Assessment Plan for the SASS in May
2003. This plan is a "living" document and will be modified as needed.
* Ensure that security is made a clear, explicit, and visible component
of system requirements in the SASS solicitation package.
The FLETC is in the process of addressing the security concerns with
the SASS. FLETC is using the National Institute of Standards and
Technology Guidelines to ensure that adequate security is provided in
the SASS. FLETC has hired a Security Manager to address this area of
concern and who will be working with the project manager to ensure we
comply with all security requirements.
* Ensure that COTS-based system acquisition best practices are made a
clear, explicit, and visible aspect of all acquisition functions,
particularly with respect to continuously assessing the tradeoffs among
system requirements, FLETC's architectural environment, the project's
cost and schedule constraints, and commercially available system
products and components.
The FLETC followed the best practices in the software acquisition
process as defined by the Software Acquisition Capability Maturity
Model (SA-CMM). This process was not documented but will be in the
future.
Monitor and Reduce Risk-FLETC Facilities and Infrastructure:
- Closely monitor overall facility conditions through establishment of
periodic facility condition assessments of mission critical facilities
and infrastructure and use of a computerized backlog of maintenance and
repair.
FLETC conducts periodic facility assessments and tracks maintenance and
repair progress. However, in light of this recommendation, FLETC will
examine these processes/programs to identify required enhancements.
- Adopt a performance measurement, such as FCI, to monitor the trend of
FLEW facilities conditions and to also offer a benchmark indicator for
comparison to industry standards.
Concur. The Facilities Condition Index (FCI) will be examined as an
additional tool to monitor the condition of FLETC facilities.
Retain the FLEW Board of Directors.
Concur. A move is already underway to reconstitute the Board and a
meeting is projected for August 2003.
- Review the Board's mission, roles and responsibilities, and function
and practices to better align them with prevailing standards of
governance and management control. Concur. FLETC already has under
development an overview of prospective duties and responsibilities of a
reconstituted Board of Directors. This will include making the FLETC
director a voting Board member and drawing on the advice and expertise
of a wide group of Board members. The Board will be involved in the
discussions on its roles, responsibilities and membership.
[See PDF for image]
[End of figure]
Cheltenham Comments:
Pages(s) Highlights:
4, 10, etc.: Generally, all comments regarding the Cheltenham campus
being upgraded and not fully operational are correct. However, what is
not correct is the reference on page 4 "(the US Capitol Police is
conducting limited classroom training" when, in fact, the US Capitol
Police are using the Cheltenham facility for vehicle traffic stop
training, patrol practical exercises and physical training on several
Cheltenham campus venues.
A second GAO error was found on page 10; paragraph I, which states
"Currently, the US Capitol Police is the only PO using the campus." In
fact, there are over 12 federal, state and local law enforcement
agencies utilizing Cheltenham classroom space, the tactical village and
road system for agency specific training. As early as February 2002,
the renovation of several Cheltenham buildings enabled the FLETC to
provide an early return on the government's investment by making
available to area federal, state and local law enforcement agencies
classroom space and tactical areas concurrent with on-going master plan
construction.
Since then, Cheltenham has averaged 1,500 to 2,000 law enforcement
officers attending training at the Cheltenham site per month. During
FY02, Cheltenham provided training venues for over I2 law enforcement
agencies, which represented 1,193 student weeks. Thus far in FY 03, as
of June 30, 2003, Cheltenham has hosted I7,013 federal, state and local
law enforcement officers for a total of 547.2 student weeks of
training.
On page 26 of the report, footnote I7 is inaccurate. Although the US
Capitol Police conducts their agency specific and advanced training in
FLETC assigned buildings at the Cheltenham site, they have agreed in a
Memorandum of Agreement with the FLETC to report their daily student
throughput to the FLETC Cheltenham Scheduling Office, as well as
schedule use of the FLETC Cheltenham buildings and grounds.
19: Text cites Cheltenham infrastructure problems as evidence of the
effects of deferred maintenance driven by law enforcement training
workload. Not a valid example-FLETC inherited the Navy facilities in
200I, has not yet substantially trained there, and is developing the
site.
12: Text suggests that Cheltenham's contribution to FLETC's throughput
capacity is limited, while it is being developed. This is misleading.
Current Congressional restrictions on the use of that facility will
limit its predominate use to requalification activities.
That fact is salient in the context because the GAO report (and all of
the capacity figures contained within it) address only basic and
advanced training-not requalification activities.
Workload Projections:
13: Text asserts TSA projected 49,000 student Projections weeks of
flight deck officer training. Incorrect. The projections (and
subsequent cancellations) were predominantly for airport security
officer training:
13,16: The chart used to depict projected workload is misleading. It
needs to be balanced with actual workload data (with the exception of
a large amount of unprojected training conducted in 2002, actual
training conducted in a fiscal year typically amounts to
approximately 75% of the projection). The chart is also obsolete, using
inflated workload projections for FY's 2003 and 2004.
Consolidated Training Economics:
2: Text suggests that most "economies of scale" savings accruing
from FLEW operation are related to student per diem costs. Not true.
Per Office of Management and Budget, consolidated training drives
significant cost avoidance by negating the need for duplicative and
redundant training facilities and shared staff and expertise.
Training Quality; 2,12:
Text cites quotations and concerns about "relevance, quality, and
timeliness" of FLETC training in the current "surge" environment. All
available evidence (e.g. graduation rates and test scores) demonstrates
that there are no significant differences.
Deferral of Advanced; 4,18:
Text suggests that the FLETC cancelled
PO's advanced training to meet basic training needs. Substantially
untrue. A few (5%) advanced classes were rescheduled within the FY.
Use of Alternative Training Assets: 5, 12:
Text asserts that FLETC does not routinely employ alternative
training assets. Not true. The FLETC routinely conducts advanced
and state and local training at export sites around the country; and is
responsible for the development and provision of distributed learning
alternatives when appropriate.
Inefficient Scheduling Process: 5:
Text asserts that FLETC's current (partially manual) scheduling
process does not make efficient use of training facilities. Not true.
The process is laborious, time-consuming, and requires modernization.
However, it is injudicious to suggest that automation of the
process in itself will result in a significant increase in throughput
capacity.
27: Text asserts that three classes must sit idle while a fourth class
trains on the driving range. This is manifestly untrue. Neither the
FLETC nor its partners would tolerate this occurring on a regular
basis.
Contingency Planning:
12: Text implies that FLETC is unable to react to
mission exigencies because it lacks a formal contingency plan. While
the FLETC has not yet published a plan to cover all possible mission
contingencies, it must be observed that current (and successfully)
FLETC operations are being conducted to meet all PO requirements in a
highly dynamic environment.
Charleston:
15: Text appears to suggest (as an illustration of the effect
of choke points?) that the resurfacing of the Charleston emergency
response range negatively impacted FY 2003 USBP training throughput.
Not true. USBP training throughput (I00% of actual demand) would have
been the same whether or not the range was resurfaced.
Basic Training Needs:
18: Text (and the title of the section) says that
FLETC has "generally" met PO basic training needs. FLETC has meet I00%
of actual basic training needs since its inception, even throughout the
"surge" workload periods following the events of 9/11. No projected
basic training has been deferred or cancelled by FLETC.
18,19: Text asserts that a former Treasury PO was obliged to defer
basic training for 168 agents due to FLETC capacity constraints. The
actual last-minute (unprojected) agency request was for 240 students.
Some were accommodated immediately, and the remaining students were
provided training slots in the following fiscal quarter. This
performance is really a demonstration of
flexibility and responsiveness. The FLETC scheduled all of these I1
week programs (2,640 unprojected student weeks) to commence within 60
days of the unexpected request.
Advanced:
18: Text quotes a May 2002 internal Justice Department Training
Needs report that an agency was obliged to "cancel" all of its advanced
training due to lack of space at FLETC. Substantially untrue. The
agency was asked to shift its advanced training within the fiscal year,
which it declined to do. Adjustments for training requests are a matter
of routine business. In most instances, FLETC and the impacted partner
agency work collaboratively and satisfactorily to make adjustments.
SASS:
27,35: Text refers consistently to a
Statement of Work (SOW). FLETC is using a Statement of Objectives in
the acquisition of the Student Administration and Scheduling System
(SASS) not a SOW. As such we are asking industry to tell us what the
best system is and what technology to use.
Text asserts that FLETC has not evaluated the Academy Class Management
System (ACMS). FLETC examined the ACMS two years ago and again
evaluated for the present purpose in June 2003. This system is not
complete. The scheduling component is still in the development state.
An operating version of the system is not yet available. We are
requesting that USBP provide us copies of the project plan, risk
assessment, implementation plan, security plan and cost figures to
date. Once this information is furnished and the module is completed
and tested we can further evaluate this product. This product is a
proprietary system and may be costly and difficult to replace in the
future. The system:
will also be viewed in terms of whether it will accomplish other
desired deliverables specific to FLETC. It is far too early to suggest
what, if any, significant cost savings can be realized by using the
ACMS. However, FLETC will remain vigilant to determine if any other
automation approach is warranted consideration.
[End of section]
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Richard M. Stana (202) 512-8777 Seto J. Bagdoyan (202) 512-8658:
Staff Acknowledgments:
In addition to those named above, the following teams and individuals
contributed to this report: Wendy C. Simkalo, Jared Hermalin, Nettie
Richards, Elizabeth Lessmann, Grace A. Coleman, Brenda Rabinowitz, R.
Rochelle Burns, Kim Hutchens, Homeland Security and Justice; Terrell
Dorn, Physical Infrastructure; Carl L. Higginbotham, Dave Hinchman,
Information Technology; Susan Ragland, K. Scott Derrick, Trina Lewis,
Strategic Issues; Kenneth Bombara, Leo Barbour, Donna L. Miller, Evan
Gilman, Applied Research & Methodology; Jan B. Montgomery, Geoffrey
Hamilton, General Counsel; Susan Conlon, Shirley A. Perry, Product
Assistance Group.
FOOTNOTES
[1] FLETC transferred to DHS on March 1, 2003, pursuant to the Homeland
Security Act of 2002 (P.L. 107-296, 116 Stat. 2135). Previously, FLETC
was part of the Enforcement Division of the Department of the Treasury.
[2] It should be noted that not all federal law enforcement agencies
receive their training at FLETC. For example, the Federal Bureau of
Investigation and the Drug Enforcement Administration have their own
training facilities in Quantico, Va.
[3] For this report, capacity is defined as the resources required,
such as instructors, facilities, and equipment, to achieve the optimum
level of training. Its measurement depends upon the following factors:
type of operation schedule (e.g., 5-day/8-hour schedule), the campus
(e.g., Glynco), the time frame (e.g., a given fiscal year), and special
considerations (e.g., changes in training priority, mission, or
policy).
[4] On March 1, 2003, the border protection functions of the Border
Patrol, and the border protection responsibilities of certain other
agencies, such as the U.S. Customs Service and INS, were transferred to
the Bureau of Customs and Border Protection within DHS. Since they each
have their own training programs and academies at FLETC campuses, we
use the terms Border Patrol, Customs, and INS to identify these
agencies throughout this report.
[5] The firm, Clark Nexsen, Architecture and Engineering, was retained
to develop an updated Master Plan and assist in establishing a strategy
to analyze existing facilities and programs and handle future growth.
[6] The POs who expressed their opinions to us about the impact of the
capacity constraints on their personnel were, at the time of our
meetings, still part of the Department of Justice. On March 1, 2003,
most of these POs moved to DHS.
[7] Managing project risk means proactively identifying facts and
circumstances that increase the probability of failing to meet project
commitments and taking steps to prevent this from occurring.
[8] However, according to our review of Board minutes, the Board did
not meet for a period of 5 years (from November 1997 to November 2002).
[9] "Student week" is the statistical measure of capacity for training;
FLETC has defined a student week as 5 days of training for one student.
For example, if 100 students receive training during a fiscal year, of
which 25 receive 3 weeks of training, 40 receive 6 weeks of training,
and the remaining 35 receive 8 weeks of training, the campus would be
providing 595 student weeks of training during that fiscal year [(25 X
3) + (40 X 6) + (35 X 8) = 595].
[10] FLETC also has oversight responsibility on behalf of DHS for the
International Law Enforcement Academy at Gabarone, Botswana.
[11] Department of Defense Appropriations Act, 2003 (P.L 107-248, 116
Stat. 1519 (2002)).
[12] Consolidated Appropriations Resolution, 2003 (P.L. 108-7, 117
Stat. (2003)).
[13] FLETC uses PO projections of demand for training as part of its
capacity planning. In March/April of each year, POs submit to FLETC
their projections for training. These projections are generally a
function of the need for personnel and expected funding levels. In June
of each year, FLETC, in consultation with POs, adjusts the projections,
in recent years by less than 5 percent. In addition to the projections
they submit, throughout the year, POs may submit requests to add,
defer, or cancel classes.
[14] National Research Council, "Stewardship of Federal Facilities--A
Proactive Strategy for Managing the Nation's Public Assets,"
(Washington, D.C.: National Academy Press, 1998).
[15] Ibid.
[16] There were, in the past, some congressional committee expectations
that the temporary training facility at Charleston would close. In
1998, for example, a House Appropriations Committee report, citing a
commitment to the principle of consolidated federal law enforcement
training through FLETC, expressed an expectation that the
administration would strive to close the temporary training facility at
Charleston. H.R. Rep. No. 105-592 (1998). In March 2000, the then
Director of FLETC testified before the Senate Committee on
Appropriations, Treasury and General Government Subcommittee, that
plans, at that time, called for Charleston to be closed by the fiscal
year 2004 time frame, once the training requirements for the new Border
Patrol hires were completed and/or new facilities became available to
accommodate the training at FLETC's permanent locations. S.Hrg. 106-712
at 152 (March 30, 2000).
[17] At FLETC's fourth campus, in Cheltenham, Maryland, the Capitol
Police reports its daily student throughput to FLETC's Cheltenham
Scheduling Office and schedules use of buildings and grounds.
[18] See U.S. General Accounting Office, Internal Control Standards:
Internal Control Management and Evaluation Tool, GAO-01-1008G
(Washington, D.C.: Aug. 2001).
[19] Software Engineering Institute, Software Acquisition Capability
Maturity Model® Version 1.03, CMU/SEI-2002-TR-010 (Pittsburgh, PA:
March 2002).
[20] FLETC issued a SASS RFP in 2002. However, because of vendor
complaints about the potential costs involved in preparing their
respective proposals, FLETC withdrew the request and is now revising
it.
[21] U.S. General Accounting Office, High Risk Series: Protecting
Information Systems Supporting the Federal Government and the Nation's
Critical Infrastructures, GAO-03-121 (Washington, D.C.: Jan. 2003).
[22] The Computer Security Act of 1987, as amended, (P.L.100-235, 101
Stat. 1724 (1988) requires federal agencies with computer systems that
process sensitive information to identify and develop security plans
for the systems and to provide periodic computer security training to
personnel managing, using, and operating these systems. The Act defines
sensitive information as any information that if lost, misused, or
accessed or modified without proper authorization could adversely
affect either the national interest or conduct of federal programs, or
the privacy to which individuals are entitled under the Privacy Act of
1974 (P.L. 93-579).
[23] See, for example, National Institute of Standards and Technology,
Guidelines to Federal Organizations on Security Assurance and
Acquisition/Use of Tested/Evaluated Products: Recommendations of the
National Institute of Standards and Technology, NIST SP 800-23 (Aug.
2000) and Guide For Developing Security Plans for Information
Technology Systems, NIST SP 800-18 (Dec. 1998).
[24] Software Engineering Institute, Evolutionary Process for
Integrating COTS-Based Systems (EPIC): An Overview, CMU/SEI-2002-TR-
009 (Pittsburgh, PA: July 2002).
[25] FLETC's solicitation utilizes a performance-based statement of
objectives methodology that provides high-level business needs and
describes the objectives that prospective offerors will be expected to
achieve. FLETC officials said that this is intended to allow offerors
to prepare their own statements of work and to propose innovative and
cost-effective approaches.
[26] According to a FLETC official, ACMS's scheduling component does
not have two elements that SASS would provide; he also said that the
absence of these functions could either be overcome or were acceptable
to FLETC. The first element is a "conflict resolution" capability to
help resolve the sequencing of classes. According to the FLETC
official, this could be resolved by using ACMS's "priority" capability,
under which schedulers would be able to schedule classes and facilities
by placing them in priority order. For example, legal classroom
training would have a higher priority than the subsequent mock
courtroom training and, accordingly, would be scheduled before the
courtroom training. The second element is speed--ACMS is not as fast as
SASS would be. The FLETC official said that ACMS's slower speed was
acceptable because it was still faster than the current paper-intensive
process.
[27] To identify the relevant prevailing best practices, we relied
primarily on the May 2002 Principles of Corporate Governance by the
Business Roundtable, an association of chief executive officers of
leading U.S. corporations; GAO's 2001 Internal Control Standards:
Internal Control Management and Evaluation Tool, (GAO-01-1008G,
Washington, D.C.: Aug. 2001); and OMB's 1995 Circular No. A-123,
Management Accountability and Control. We also drew from our August
2002 report (unnumbered correspondence), on the governance of the U.S.
Capitol Police, titled Information on Capitol Police Board Roles and
Responsibilities, Operations, and Alternative Structures.
[28] See, for example, a report by The Conference Board Commission on
Public Trust and Private Enterprise titled Findings and
Recommendations, New York, New York, January 2003. The Conference Board
is a leading business network that creates and disseminates knowledge
about management and the marketplace. According to its report, the
Conference Board created the Commission to help address the causes of
declining public and investor trust in companies, their leaders, and
capital markets. The 12-member commission included a former Comptroller
General of the United States and the current Secretary of the Treasury.
[29] FLETC officials said that at the conclusion of the Board's
November 2002 meeting, a follow-up meeting was planned for January
2003. However, by early December 2002, the decision had been made to
transfer FLETC to the newly created DHS. They said that taskings
resulting from the transition delayed decisions regarding the Board.
FLETC officials, however, said they would review the duties and purview
of the Board.
[30] Software Engineering Institute, Software Acquisition Capability
Maturity Model ® Version 1.03, CMU/SEI-2002-TR-010 (Pittsburgh, PA:
March 2002).
[31] Software Engineering Institute, Evolutionary Process for
Integrating COTS-Based Systems (EPIC): An Overview, CMU/SEI-2002-TR-
009 (Pittsburgh, PA: July 2002).
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