Federal Protective Service
Progress Made but Improved Schedule and Cost Estimate Needed to Complete Transititon Gao ID: GAO-11-554 July 15, 2011Events such as the February 2010 attack on the Internal Revenue Service offices in Texas, and the shooting in the lobby of the Nevada federal courthouse, demonstrate the vulnerabilities of federal facilities and the safety of the federal employees who occupy them. The Federal Protective Service (FPS) is the primary agency responsible for the security of over 9,000 federal government facilities across the country. The fiscal year 2010 DHS appropriations act transferred FPS from Immigration and Customs Enforcement (ICE) to the National Protection and Programs Directorate (NPPD), within the Department of Homeland Security (DHS). This report addresses (1) the extent to which the FPS transition has been implemented and any remaining related challenges, and (2) the extent to which the transition will help address previously identified challenges to protecting federal facilities. GAO reviewed the 2009 FPS-NPPD transition plan; agreements between FPS, NPPD, and ICE, and best practices for scheduling and cost estimating; and interviewed DHS officials.
Since October 2009, FPS's facility protection mission and 13 of 18 mission-support functions have transferred from ICE to NPPD; however, the transition schedule for the 5 remaining mission-support functions has been delayed. For example, while functions such as human capital and budget formulation have been transferred, information technology (IT) services, business continuity and emergency preparedness, facilities, personnel security, and equal employment opportunity have not. In August 2009, DHS reported to Congress that the transition of these functions would be completed by October 2010. DHS now reports that it plans to complete the transfer of 4 of the 5 remaining mission-support functions by September or October 2011, and estimates that the transfer of IT services will not be complete until October 2012. DHS developed a transition plan to guide the planning and execution of the transfer. Among other things, the plan called for schedules with detailed tasks and end dates to be developed for all mission-support functions to ensure critical path activities were identified, managed, and resourced. DHS also developed a detailed schedule to manage the transfer of IT services, as called for in the transition plan. However, GAO's analysis of the schedule found that it did not reflect GAO's best practices for scheduling such as capturing, sequencing, and assigning resources to all activities necessary to accomplish the work. When a schedule does not accurately reflect the project, it will not serve as an appropriate basis for analysis and may result in unreliable completion dates and delays. As of May 2011, DHS estimated that it would cost $6.2 million to complete the IT transition. GAO's analysis of this cost estimate found it did not meet all the characteristics of a reliable cost estimate. For example, the estimate was not well documented because it was not supported by detailed explanation describing how the estimate was derived and did not include sufficient detail so that GAO could corroborate it. By incorporating cost estimation best practices for the IT transition cost estimate, DHS could enhance the estimate's reliability and better inform decisions about the cost to complete the transition. The transfer of FPS to NPPD could provide DHS the opportunity to better advance progress towards addressing FPS's challenges to protecting federal facilities that have been previously identified by GAO. Since 2007, GAO has reported that FPS faces significant challenges with protecting federal facilities. The transition plan noted that the transfer of FPS to NPPD would improve the mission effectiveness of both agencies. NPPD officials explained that the agency has undertaken actions that serve as a foundation for integrating FPS into NPPD. For example, FPS has begun to develop a new strategic plan to align FPS's activities and resources to support NPPD mission-related outcomes. Additionally, NPPD is assisting FPS in developing a human capital strategic plan, as recommended by GAO in July 2009. These steps are encouraging, but it is too early to tell if these planned actions will help address challenges previously identified by GAO. GAO recommends that DHS improve the schedule for transferring IT services to reflect scheduling best practices, and update the IT transition cost estimate, in accordance with cost-estimating best practices. DHS concurred with GAO's recommendations.
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: David C. Maurer Team: Government Accountability Office: Homeland Security and Justice Phone: (202) 512-9627GAO-11-554, Federal Protective Service: Progress Made but Improved Schedule and Cost Estimate Needed to Complete Transititon
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United States Government Accountability Office:
GAO:
Report to the Ranking Member, Committee on Homeland Security, House of
Representatives:
July 2011:
Federal Protective Service:
Progress Made but Improved Schedule and Cost Estimate Needed to
Complete Transition:
GAO-11-554:
GAO Highlights:
Highlights of GAO-11-554, a report to the Ranking Member, Committee on
Homeland Security, House of Representatives.
Why GAO Did This Study:
Events such as the February 2010 attack on the Internal Revenue
Service offices in Texas, and the shooting in the lobby of the Nevada
federal courthouse, demonstrate the vulnerabilities of federal
facilities and the safety of the federal employees who occupy them.
The Federal Protective Service (FPS) is the primary agency responsible
for the security of over 9,000 federal government facilities across
the country. The fiscal year 2010 DHS appropriations act transferred
FPS from Immigration and Customs Enforcement (ICE) to the National
Protection and Programs Directorate (NPPD), within the Department of
Homeland Security (DHS). This report addresses (1) the extent to which
the FPS transition has been implemented and any remaining related
challenges, and (2) the extent to which the transition will help
address previously identified challenges to protecting federal
facilities. GAO reviewed the 2009 FPS-NPPD transition plan; agreements
between FPS, NPPD, and ICE, and best practices for scheduling and cost
estimating; and interviewed DHS officials.
What GAO Found:
Since October 2009, FPS‘s facility protection mission and 13 of 18
mission-support functions have transferred from ICE to NPPD; however,
the transition schedule for the 5 remaining mission-support functions
has been delayed. For example, while functions such as human capital
and budget formulation have been transferred, information technology
(IT) services, business continuity and emergency preparedness,
facilities, personnel security, and equal employment opportunity have
not. In August 2009, DHS reported to Congress that the transition of
these functions would be completed by October 2010. DHS now reports
that it plans to complete the transfer of 4 of the 5 remaining mission-
support functions by September or October 2011, and estimates that the
transfer of IT services will not be complete until October 2012. DHS
developed a transition plan to guide the planning and execution of the
transfer. Among other things, the plan called for schedules with
detailed tasks and end dates to be developed for all mission-support
functions to ensure critical path activities were identified, managed,
and resourced. DHS also developed a detailed schedule to manage the
transfer of IT services, as called for in the transition plan.
However, GAO‘s analysis of the schedule found that it did not reflect
GAO‘s best practices for scheduling such as capturing, sequencing, and
assigning resources to all activities necessary to accomplish the
work. When a schedule does not accurately reflect the project, it will
not serve as an appropriate basis for analysis and may result in
unreliable completion dates and delays. As of May 2011, DHS estimated
that it would cost $6.2 million to complete the IT transition. GAO‘s
analysis of this cost estimate found it did not meet all the
characteristics of a reliable cost estimate. For example, the estimate
was not well documented because it was not supported by detailed
explanation describing how the estimate was derived and did not
include sufficient detail so that GAO could corroborate it. By
incorporating cost estimation best practices for the IT transition
cost estimate, DHS could enhance the estimate‘s reliability and better
inform decisions about the cost to complete the transition.
The transfer of FPS to NPPD could provide DHS the opportunity to
better advance progress towards addressing FPS‘s challenges to
protecting federal facilities that have been previously identified by
GAO. Since 2007, GAO has reported that FPS faces significant
challenges with protecting federal facilities. The transition plan
noted that the transfer of FPS to NPPD would improve the mission
effectiveness of both agencies. NPPD officials explained that the
agency has undertaken actions that serve as a foundation for
integrating FPS into NPPD. For example, FPS has begun to develop a new
strategic plan to align FPS‘s activities and resources to support NPPD
mission-related outcomes. Additionally, NPPD is assisting FPS in
developing a human capital strategic plan, as recommended by GAO in
July 2009. These steps are encouraging, but it is too early to tell if
these planned actions will help address challenges previously
identified by GAO.
What GAO Recommends:
GAO recommends that DHS improve the schedule for transferring IT
services to reflect scheduling best practices, and update the IT
transition cost estimate, in accordance with cost-estimating best
practices. DHS concurred with GAO‘s recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-11-554] or key
components. For more information, contact David C. Maurer at (202) 512-
9627 or maurerd@gao.gov.
[End of section]
Contents:
Letter:
Background:
DHS Transferred FPS's Mission and Most Support Functions to NPPD, but
Could Benefit from a Revised Schedule and Cost Estimate for
Transferring IT Services:
Transition May Provide Opportunity to Address Previously Identified
FPS Challenges, but It Is Too Early to Tell Its Impact:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Extent to Which FPS Mission-Support Functions Have
Transferred to NPPD or Other DHS Components as of May 2011:
Table 2: FPS Mission-Support Functions That Have Experienced Delays as
of May 2011:
Table 3: Description of GAO Scheduling Best Practices:
Table 4: DHS's Incorporation of Best Practices into the FPS IT
Transition Schedule:
Table 5: Original and Revised FPS Transition Cost Estimates and Actual
Costs Incurred:
Table 6: DHS's Incorporation of Best Practices into the FPS IT
Transition Cost Estimate:
Figures:
Figure 1: DHS Organizational Chart Showing FPS's Movement from ICE to
NPPD:
Figure 2: FPS Transition Implementation Team Organization:
Figure 3: Location of FPS within NPPD's Organizational Structure:
Abbreviations:
CIO: Chief Information Officer:
COMSEC: Communication Security:
DHS: Department of Homeland Security:
EEO: Equal Employment Opportunity:
FOIA: Freedom of Information Act:
FPS: Federal Protective Service:
GSA: General Services Administration:
ICE: Immigration and Customs Enforcement:
IPAC: Intra-Governmental Payment and Collection:
IT: Information Technology:
MOA: Memorandum of Agreement:
MOU: Memorandum of Understanding:
NPPD: National Protection and Programs Directorate:
OGC: Office of the General Counsel:
OMB: Office of Management and Budget:
OPLA: Office of the Principal Legal Advisor:
PBS: Public Buildings Service:
SES: Senior Executive Service:
SLA: Service Level Agreement:
US-VISIT: United States Visitor and Immigrant Status Indicator
Technology:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 15, 2011:
The Honorable Bennie G. Thompson:
Ranking Member:
Committee on Homeland Security:
House of Representatives:
Dear Mr. Thompson:
Events such as the February 2010 attack on the Internal Revenue
Service offices in Texas, and the January 2010 shooting in the lobby
of the Nevada federal courthouse, demonstrate the vulnerability of
federal facilities and the threat to the safety of federal employees
who occupy them. These events also highlight the continued challenges
involved in protecting the over 1 million government employees who
work in federal facilities, and members of the public who visit such
facilities each year. The Federal Protective Service (FPS),
established in 1971 as the uniformed protection force of the General
Services Administration (GSA), is the primary agency responsible for
the security of over 9,000 federal government facilities across the
country, including buildings; grounds; and property owned, occupied,
or secured by the federal government.[Footnote 1]
FPS was transferred from GSA's Public Buildings Service to the
Department of Homeland Security (DHS), with enactment of the Homeland
Security Act of 2002.[Footnote 2] Within DHS, FPS was originally a
part of Immigration and Customs Enforcement (ICE).[Footnote 3]
However, the fiscal year 2010 DHS appropriations act transferred FPS
from ICE to the National Protection and Programs Directorate (NPPD),
within DHS, and the transfer became effective when the act was signed
into law on October 28, 2009.[Footnote 4] DHS proposed this transfer
to better align FPS's facility protection mission with NPPD's broader
critical infrastructure protection mission.
In light of FPS's critical role of protecting federal facilities
against the threat of terrorism and other criminal activity, it is
important that FPS's transfer to NPPD be successful. In addition to
the inherent challenges any organization would face in becoming part
of another agency, our prior work reviewing the operations of FPS and
its ability to protect federal facilities has shown that FPS brings a
set of unique operational, management, and funding challenges to NPPD
that have a bearing on its ability to accomplish its mission.[Footnote
5] The challenges include managing its contract guard force,
establishing a comprehensive human capital strategy, evaluating its
funding structure, and developing a risk management framework that
links threats and vulnerabilities to resource requirements. Over the
past 5 years, we have made numerous recommendations to address these
challenges. For example, we recommended FPS improve its long-term
human capital planning, develop and implement performance measures in
various aspects of its operations, and improve its data collection and
quality across its operations. While FPS has generally agreed with all
of our recommendations, it has not completed many related corrective
actions. If not properly planned and effectively implemented, the
transition could not only hamper FPS's ability to carry out its
mission, but impede its progress in addressing its long-standing
challenges.
DHS prepared a transition plan for the realignment of FPS that
describes the department's ongoing planning efforts, cost estimates,
and a timeline for the planning and execution process, but members of
Congress raised questions about whether the plan provided sufficient
information about how the department would address FPS's
challenges.[Footnote 6] You requested that we review the department's
transition efforts. This report addresses (1) the extent to which the
FPS transition has been implemented and any challenges FPS and NPPD
face in implementing the transition; and (2) the extent to which the
transition will help address previously identified challenges to
protecting federal facilities.
To answer the first objective, we reviewed relevant documents,
including the August 2009 FPS-NPPD Transition Plan, transition plan
updates, the Memorandum of Agreement (MOA), the Memorandum of
Understanding (MOU), and all service level agreements (SLA)[Footnote
7] signed among FPS, NPPD, and ICE.[Footnote 8] We interviewed members
of the senior-level working group, as well as members of all working
groups that were established to carry out the transition in 18 mission-
support functions, to discuss the extent to which the mission-support
functions had transferred from ICE to NPPD.[Footnote 9] In addition,
we interviewed the FPS Deputy Director, Chief of Staff, regional and
deputy regional directors, and mission support chiefs from 6 of the 11
FPS regions around the country on a range of issues related to the
transition of FPS to NPPD. We compared the FPS information technology
(IT) transition schedule, the IT transition cost estimate, and related
documents to the practices in our Cost Estimating and Assessment
Guide.[Footnote 10] We did a detailed analysis of the IT services
mission-support function because it required a significant commitment
of resources, oversight, and time by DHS to complete the transition.
We also obtained and analyzed financial documentation from the
components' accounting systems to identify transition costs.[Footnote
11] To assess the reliability of this documentation, we (1) performed
electronic testing for obvious errors in accuracy and completeness,
(2) compared the data with other sources of information, such as cost
data from the ICE Office of Financial Management and documentation
from the Intra-Governmental Payment and Collection (IPAC) system, and
(3) interviewed agency officials knowledgeable about financial
management and budgeting at all three agencies to understand the data
and to identify any data problems.[Footnote 12] When we found
discrepancies (such as data entry errors) we brought them to the
officials' attention and worked with them to correct discrepancies
before concluding our analysis. We determined that the data were
sufficiently reliable for the purposes of this report.
To answer the second objective, we reviewed our prior work on
challenges facing FPS in its efforts to protect federal facilities. We
also reviewed and analyzed documentation, such as the transition plan,
testimony from key senior leaders in FPS and NPPD provided for a
hearing on the FPS transition, FPS's strategic plan, and NPPD's
strategic activities report. Finally, we interviewed the Senior
Counselor to the Under Secretary of NPPD, and FPS Deputy Director for
Operations and Chief of Staff and discussed actions underway or
planned to further address FPS's challenges.
We conducted this performance audit from October 2010 through July
2011 in accordance with generally accepted auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe the
evidence provides a reasonable basis for our findings and conclusions
based on our audit objectives. Appendix I contains more details on our
scope and methodology.
Background:
FPS was established in 1971 as the uniformed protection force of GSA
government-occupied facilities. The mission of FPS is to render
federal properties safe and secure for federal employees, officials,
and visitors in a professional and cost-effective manner by deploying
a highly trained and multi-disciplined police force. FPS was
originally located within GSA's Public Buildings Service (PBS). As
part of PBS, FPS was responsible for providing law enforcement and
security services to GSA's tenants and the public at federal buildings
nationwide.
The Homeland Security Act of 2002 established DHS to prevent and
mitigate the damage from terrorist attacks within the United States,
which includes terrorism directed at federal facilities. Under the
act, FPS was transferred from the GSA to DHS. DHS later placed it
within ICE. The President's fiscal year 2010 budget requested the
transfer of FPS from ICE to NPPD. Language in the budget request
stated that FPS responsibilities, such as providing physical security
and policing of federal buildings, establishing building security
policy, and ensuring compliance, are outside the scope of ICE's
immigration and customs enforcement mission and are better aligned
with NPPD's mission. The transfer of FPS to NPPD became effective when
the fiscal year 2010 DHS appropriations act was signed into law on
October 28, 2009. Figure 1 shows FPS's move within DHS from ICE to
NPPD.
Figure 1: DHS Organizational Chart Showing FPS's Movement from ICE to
NPPD:
[Refer to PDF for image: Organizational Chart]
Department of Homeland Security:
Top level:
Secretary/Deputy Secretary:
Chief of Staff:
* Executive Secretariat;
* Military Advisor.
Second level, reporting to Secretary/Deputy Secretary:
* Management:
- Chief Financial Officer;
* Science & Technology;
* National Protection & Programs [Refer to Figure 3];
* Policy;
* General Counsel;
* Legislative Affairs;
* Public Affairs;
* Inspector General;
Third level, reporting to Secretary/Deputy Secretary:
* Health Affairs;
* Intelligence & Analysis;
* Operations Coordination & Planning;
* Citizenship & Immigration Services Ombusman;
* Civil Rights & Civil Liberties;
* Chief Privacy Officer;
* Counter-Narcotics Enforcement.
Fourth level, reporting to Secretary/Deputy Secretary:
* Intergovernmental Affairs;
* Federal law Enforcement Training Center;
* Domestic Nuclear Detection Office.
Fifth level, reporting to Secretary/Deputy Secretary:
* Transportation Security Administration;
* U.S. Customs & Border Protection;
* U.S. Citizenship & Immigration Services;
* U.S. Immigration & Customs Enforcement [Move your computer mouse
pointer over the …Highlighted‘ organizations in the chart to see more
information];
* U.S. Secret Service;
* Federal Emergency Management Agency;
* U.S. Coast Guard.
Source: DHS.
[End of figure]
To accomplish its mission, in 2011 FPS has a total budget authority of
about $1 billion, currently employs 1,225 federal staff, and about
13,000 contract guard staff to secure over 9,000 GSA owned or leased
facilities. FPS conducts law enforcement activities as well as risk
assessments to reduce facility vulnerability to criminal and terrorist
threats and helps to ensure that facilities are secure and occupants
are safe.
For the transition, FPS, NPPD, ICE, and DHS headquarters components
formed a Senior Working Group, co-chaired by the Senior Counselor to
the Under Secretary of NPPD, the ICE Deputy Assistant Secretary for
Management, and the FPS Director.[Footnote 13] DHS developed a
transition plan, the August 2009 FPS-NPPD Transition Plan, which
describes DHS's overall transition planning process and milestones for
completing the transition, among other things. The plan shifted FPS's
mission and responsibility for all of its mission-support functions,
with the exception of financial accounting services and firearms and
tactical training, from ICE to NPPD or other DHS components. While FPS
has its own law enforcement personnel to perform its mission
responsibilities, it does not perform all of its mission-support
functions such as payroll, travel services, and contracting. For this
reason, FPS has traditionally relied on GSA and ICE to carry out these
functions. For example, while under GSA, FPS's contracting functions
were handled by the contracting component of GSA's Public Buildings
Service, and under ICE, by its Office of Acquisition.
The transition plan noted that most transition tasks would be
completed by October 2010. In addition, the transition plan noted
staff-level working groups were formed that consisted of subject
matter experts from each of the agencies, FPS, NPPD, and ICE, to plan
in detail the transfer of FPS's mission and each mission-support
function. The working groups were tasked with planning, tracking
issues related to the FPS transition, and reporting progress on the
transition. Initially, 16 working groups were formed to carry out the
transition in 18 mission-support functions, as reflected in figure 2.
[Footnote 14]
Figure 2: FPS Transition Implementation Team Organization:
[Refer to PDF for image: illustration]
Senior Working Group:
* Senior Working Group Co-Chairs:
- Senior Counselor to the Under Secretary of NPPD;
- ICE Deputy Assistant Secretary for Management;
- FPS Director.
Staff Level Working Groups (18 mission-support functions):
Human Capital;
Procurement Management and Operations;
Security Integrity and Personnel Security;
Facilities;
Employee and Labor Relations;
Equal Employment Opportunity;
Budget Formulation and Performance;
Information Operations;
Training, Professional Development and Education;
Operations;
Public Affairs;
Legislative Affairs;
Legal Services;
Logistics and Asset Management;
Business Continuity and Emergency Preparedness;
Financial Management;
Acquisitions;
Information Management.
Source: GAO analysis of NPPD data.
[End of figure]
According to the transition plan, until the transition is complete,
ICE is to continue to provide necessary management and operational
services through continued agreements in support of FPS or until
individual MOAs, MOUs, or SLAs are concluded with NPPD and other DHS
headquarters components. For example, for fiscal year 2010, FPS and
NPPD signed 12 SLAs with ICE, covering services such as training and
development, security management, and IT services, 1 MOA for legal
services, and 1 MOU for financial services. These agreements were
meant to ensure that there were no lapses in services while mission-
support functions were being transferred to either NPPD or DHS
headquarters components.
DHS Transferred FPS's Mission and Most Support Functions to NPPD, but
Could Benefit from a Revised Schedule and Cost Estimate for
Transferring IT Services:
FPS's Facility Protection Mission Has Transferred to NPPD without
Disruption:
In October 2009, FPS's facility protection mission transferred and its
reporting channels were shifted from ICE to NPPD. The Under Secretary
of NPPD--through delegation from the Secretary of Homeland Security--
assumed operational control of FPS and its mission from ICE with the
enactment of the fiscal year 2010 DHS appropriations act.[Footnote 15]
Similarly, the Under Secretary delegated the authority and
responsibility to the Director of FPS to continue FPS's physical
security and law enforcement services mission,[Footnote 16] consistent
with the law enforcement authority for the protection of federal
property.[Footnote 17] Upon its transition to NPPD, FPS became a
component within the directorate.[Footnote 18] Figure 3 shows the
location of FPS within NPPD's organizational structure.
Figure 3: Location of FPS within NPPD's Organizational Structure:
[Refer to PDF for image: Organizational Structure]
National Protection and Programs Directorate (NPPD):
Top level:
Under Secretary/Deputy Under Secretary:
* Office of the Chief of Staff:
- Information Management(ExecSec/FOIA/GAO/Records Mgmt);
* Office of Cyber+Strategy (Senior Counselor);
* Senior Counselor (NPPD Integration + FPS Transition).
Second level: Reporting to Under Secretary/Deputy Under Secretary:
* Office of Resource Administration;
* Office of Budget, Finance and Acquisition;
* Office of the Chief Information Officer;
* Office of Communications and Public Affairs;
* Office of Privacy.
Third level: Reporting to Under Secretary/Deputy Under Secretary:
* Office of Infrastructure Protection;
* Office of Cybersecurity and Communications;
* United States Visitor and Immigrant Status Indicator Technology;
* Office of Risk Management and Analysis;
* Federal Protective Service.
Source: DHS.
Note: FOIA refers to the Freedom of Information Act.
[End of figure]
According to FPS headquarters and regional officials we interviewed,
the transition of FPS's mission from ICE to NPPD occurred without
degradation to the mission, and there has been minimal, if any,
disruption to FPS's field operations. Moreover, the regional officials
said that the transition has not had an impact on the way FPS performs
its mission on a daily basis. FPS officials stated that FPS continued
to lead DHS's security and law enforcement services at more than 9,000
GSA facilities nationwide, and its operational activities, such as
conducting facility security assessments, conducting criminal
investigations, and responding to critical incidents, continued
uninterrupted during and after the transition.[Footnote 19]
NPPD Has Experienced Delays in Assuming Some FPS Mission-Support
Functions:
Since taking operational control of FPS in October 2009, NPPD and
other DHS components have assumed responsibility for 13 of 18 FPS
mission-support functions, but the transfer of the remaining 5 mission-
support functions from ICE to NPPD or other DHS components has been
delayed. In August 2009, DHS reported to Congress that the transition
would be completed by October 2010 and estimated it would cost $14.6
million.[Footnote 20] However, DHS now reports that the transfer of 4
functions will not be completed until the end of fiscal year 2011 or
start of fiscal year 2012 and one of these functions will not be
transferred until October 2012. For the delayed functions, ICE
continues to provide mission support to FPS, and new or revised SLAs
were developed to articulate the continuing time frames and services
that ICE would provide to FPS. The 18 mission-support functions and
their transfer status are presented in table 1.
Table 1: Extent to Which FPS Mission-Support Functions Have
Transferred to NPPD or Other DHS Components as of May 2011:
FPS mission-support function: Operations;
Status: Completed;
Description: Information on critical incidents is passed directly to
the NPPD Under Secretary, concurrent with notification to the DHS
National Operations Center.
FPS mission-support function: Human Capital;
Status: Completed;
Description: NPPD and FPS human capital management staffing and
functions have been consolidated. NPPD human resources conducts
personnel services functions in support of FPS[A].
FPS mission-support function: Employee and Labor Relations;
Status: Completed;
Description: A new Employee and Labor Relations Office was established
at NPPD and a new director was hired. All FPS disciplinary, adverse,
and performance-based actions have been transferred to the NPPD
Employee and Labor Relations Office.
FPS mission-support function: Training, Professional Development, and
Education;
Status: Completed;
Description: All non-law enforcement training for FPS employees is
being managed through NPPD's Office of Professional Development and
Training, in coordination with FPS's regional training coordinators.
NPPD also has an agreement with ICE and the Federal Law Enforcement
Training Center for transfer of Academic Course Management System
database records.
FPS mission-support function: Budget Formulation and Performance;
Status: Completed;
Description: NPPD coordinated the FPS fiscal year 2011 budget
submission and plans to coordinate all future year budget formulation
and submissions.
FPS mission-support function: Financial Management;
Status: Completed;
Description: ICE will provide financial management services to FPS
indefinitely as there is no economical or efficient way for NPPD to
replicate these services. However, NPPD has assumed financial
management reporting responsibilities, internal controls, and audit
response and coordination responsibilities.
FPS mission-support function: Procurement Management and Operations;
Status: Completed;
Description: DHS Office of Procurement Operations has assumed
contracting authority and oversight of FPS procurement activities.
FPS mission-support function: Logistics and Asset Management;
Status: Completed;
Description: NPPD has migrated and currently manages the NPPD motor
fleet within FPS management operations, and FPS asset management and
logistics have fully transferred from ICE to NPPD.
FPS mission-support function: Acquisitions;
Status: Completed;
Description: All acquisition support services have been transferred to
DHS Office of Procurement Operations. NPPD also assumed component
acquisition executive oversight of FPS investment programs.
FPS mission-support function: Legislative Affairs;
Status: Completed;
Description: FPS legislative affairs are coordinated through the NPPD
Legislative Affairs Director and DHS Office of Legislative Affairs.
FPS mission-support function: Public Affairs;
Status: Completed;
Description: The DHS Office of Public Affairs has detailed a senior
public affairs staffer to FPS to manage and facilitate public affairs
activities.
FPS mission-support function: Information Management;
Status: Completed;
Description: FPS executive correspondence and reports have been
integrated with the NPPD Office of the Executive Secretariat.
Management of the FPS Freedom of Information Act (FOIA) caseload
transferred to NPPD's FOIA Office. Additionally, coordination of GAO
and DHS Office of the Inspector General audit work transferred to
NPPD's Audit Liaison Office.
FPS mission-support function: Legal Services;
Status: Completed;
Description: DHS officials indicated that the DHS Office of the
General Counsel (OGC) has completed the transition of legal services
from ICE Office of the Principal Legal Advisor (OPLA) to OGC in early
fiscal year 2011. OGC currently has nine attorneys dedicated to
providing legal services to FPS and anticipates having the remaining
two attorneys in place by the end of fiscal year 2011. According to
DHS officials, for continuity purposes, OPLA continues to manage legal
actions that were ongoing at the time of transition, primarily in the
areas of employment and tort litigation.
FPS mission-support function: Information Operations (IT services);
Status: Not completed;
Description: Although FPS's Communication Security (COMSEC) function
has transferred to NPPD COMSEC networks and related oversight of
tactical communications systems has transferred to NPPD Office of the
Chief Information Officer, DHS headquarters and NPPD are in the
process of establishing the IT infrastructure and field support
necessary to support FPS's geographically dispersed IT business needs
and requirements. In the meantime, the ICE Office of Chief Information
Officer continues to provide IT services such as engineering and
operations. DHS and NPPD plan to complete the transfer of IT services
by October 2012.
FPS mission-support function: Business Continuity and Emergency
Preparedness;
Status: Not completed;
Description: FPS is fully integrated with NPPD with respect to
Business Continuity and Emergency Preparedness planning and operations;
however, FPS plans to continue to use an ICE Continuity of Operations
Emergency Relocation Site until NPPD completes the building of another
relocation site. NPPD officials stated this would be complete by
October 2011.
FPS mission-support function: Security Integrity and Personnel
Security;
Status: Not completed;
Description: New DHS-level badges and credential cards for law
enforcement personnel were issued to the FPS workforce early in the
transition process. According to an NPPD official, a personnel
security function has not yet been built-out at the NPPD level due to
delegation of authorities issues, overarching resource requirements,
and the detailed coordination required as NPPD evolves into a more
operationally focused organization. NPPD is in the process of
establishing an Office of Compliance and Security, which NPPD
officials hope to complete by October 2011;
however, until the programs within the office are established, the ICE
Office of Professional Responsibility, Personnel Security Unit
continues to provide personnel security services to FPS.
FPS mission-support function: Facilities;
Status: Not completed;
Description: FPS continues to rely on the ICE Office of Asset
Management for facilities management services such as planning,
design, and construction activities. According to DHS officials, NPPD
has hired three of the five positions that were created to support FPS
facilities management. The existing personnel are working with ICE to
transfer projects and expect that all projects will transfer by the
end of fiscal year 2011.
FPS mission-support function: Equal Employment Opportunity (EEO);
Status: Not completed;
Description: The ICE Office of Equal Employment Opportunity (EEO)
continues to perform all the FPS EEO program responsibilities to
include counseling and advisory services, processing complaints,
alternative dispute resolution, and compliance oversight for
settlement actions. According to DHS officials, ICE will continue to
provide EEO services through September 2011.
Source: GAO analysis of NPPD transition information.
Note: For the purposes of this report, the transfer of a mission-
support function is complete when SLAs or MOUs among FPS, NPPD, and
ICE have expired and services have been transferred to NPPD or other
DHS components.
[A] FPS receives medical and lab services such as medical,
psychological, and fitness exams, and pre-employment drug screening
through a third party vendor.
[End of table]
According to DHS officials responsible for executing the FPS
transition, the transfer of the 5 mission-support functions will take
longer than originally reported to Congress due to a number of
factors, including unanticipated costs associated with building the
infrastructure within NPPD and other DHS components to support areas
such as IT services. As reflected in table 2, the delays in the
transition schedule for the delayed mission-support functions range
from almost 1 to 2 years. DHS officials explained that the transfer of
four mission-support functions--business continuity and emergency
preparedness, personnel security, facilities, and Equal Employment
Opportunity (EEO)--are on track to transfer by the end of fiscal year
2011 or start of fiscal year 2012. Specifically, DHS officials
explained the following:
* All activities for the transfer of business continuity and emergency
preparedness have been completed but are waiting on NPPD to complete
the building of a continuity of operations site, which according to
NPPD officials, will be complete by October 2011.
* NPPD has moved a Senior Executive Service (SES)-level director into
position, and is in the process of establishing an Office of
Compliance and Security, which will provide compliance investigations,
program review, personnel security, interior physical security,
information security, and special security program services throughout
NPPD. According to the Acting Director of the Office of Compliance and
Security, the goal is to establish this office by October 2011.
* NPPD has hired three of the five positions that were created to
support FPS facilities management. These personnel, according to the
officials, are working with ICE to transfer projects and all of them
are expected to transfer by the end of fiscal year 2011.
* The only activity required for the transfer of EEO services is to
hire staff needed to support FPS within NPPD, which should be
completed by the end of fiscal year 2011.
Table 2: FPS Mission-Support Functions That Have Experienced Delays as
of May 2011:
Mission support services: IT Services;
Initial estimated transition date as reported in the August 2009
transition plan: October 2010;
Estimated transition date as of May 2011: October 2012;
Delay in months: 24.
Mission support services: Business Continuity and Emergency
Preparedness;
Initial estimated transition date as reported in the August 2009
transition plan: November 2009;
Estimated transition date as of May 2011: October 2011;
Delay in months: 23.
Mission support services: Personnel Security;
Initial estimated transition date as reported in the August 2009
transition plan: January 2010;
Estimated transition date as of May 2011: October 2011;
Delay in months: 21.
Mission support services: Facilities;
Initial estimated transition date as reported in the August 2009
transition plan: April 2010;
Estimated transition date as of May 2011: September 2011;
Delay in months: 17.
Mission support services: Equal Employment Opportunity;
Initial estimated transition date as reported in the August 2009
transition plan: October 2010;
Estimated transition date as of May 2011: September 2011;
Delay in months: 11.
Source: GAO analysis of NPPD transition documents.
[End of table]
FPS's Transition Schedule for the Transfer of the IT Services Function
Could Be Enhanced:
While DHS has successfully transferred FPS's mission and the majority
of its mission-support functions, deficiencies in the transition
schedule for the transfer of IT services could limit DHS's ability to
ensure the timely transition of this important function. DHS's
transition plan called for working groups to develop comprehensive
project management plans (i.e., detailed schedules) with detailed
tasks and end dates for the individual mission-support functions to
ensure critical path activities were identified, managed, and
resourced. DHS did not develop these schedules for all the mission-
support functions since, according to DHS officials, in some cases the
transfer of a function was relatively easy and did not need a
schedule, such as public affairs and legislative affairs. However, the
transfer of FPS's nationwide IT infrastructure and field support is
more complex. Because of the complexity of transferring IT services,
DHS developed a detailed schedule to manage the transfer of IT
services, as called for in the transition plan.
As we have previously reported, the success of fielding any program
depends in part on having a reliable schedule that defines, among
other things, when work activities will occur, how long they will
take, and how they are related to one another.[Footnote 21] As such,
the schedule not only provides a road map for systematic execution of
a program, but also provides a means by which to gauge progress,
identify and address potential problems, and promote accountability.
Among other things, best practices and related federal guidance cited
in our cost estimation guide call for a program schedule to be program-
wide in scope, meaning that it should include the integrated breakdown
of the work to be performed, and expressly identify and define
relationships and dependencies among work elements and the constraints
affecting the start and completion of work elements. Table 3 presents
a summary of best practices we have identified for applying a schedule
as part of program management.
Table 3: Description of GAO Scheduling Best Practices:
Scheduling best practice: Capturing all activities;
Explanation: The schedule should reflect all activities (steps,
events, outcomes, etc.) as defined in the program's work breakdown
structure to include activities to be performed by both the government
and its contractors.
Scheduling best practice: Sequencing all activities;
Explanation: The schedule should sequence activities in the order that
they are to be implemented. In particular, activities that must finish
prior to the start of other activities (i.e., predecessor activities),
as well as activities that cannot begin until other activities are
completed (i.e., successor activities) should be identified.
Scheduling best practice: Assigning resources to all activities;
Explanation: The schedule should reflect who will do the work
activities, whether all required resources will be available when they
are needed, and whether any funding or time constraints exist.
Scheduling best practice: Establishing the duration of all activities;
Explanation: The schedule should reflect the duration of each
activity. These durations should be as short as possible and have
specific start and end dates.
Scheduling best practice: Integrating schedule activities horizontally
and vertically;
Explanation: The schedule should be horizontally integrated, meaning
that it should link the products and outcomes associated with
sequenced activities. The schedule should also be vertically
integrated, meaning that traceability exists among varying levels of
activities and supporting tasks and subtasks.
Scheduling best practice: Establishing the critical path for all
activities;
Explanation: The critical path represents the chain of dependent
activities with the longest total duration in the schedule.
Scheduling best practice: Identifying float between activities;
Explanation: The schedule should identify a reasonable amount of
float--the time that a predecessor activity can slip before the delay
affects successor activities--so that schedule flexibility can be
determined. As a general rule, activities along the critical path
typically have the least amount of float.
Scheduling best practice: Conducting a schedule risk analysis;
Explanation: A schedule risk analysis is used to predict the level of
confidence in the schedule, determine the amount of time contingency
needed, and identify high-priority schedule risks.
Scheduling best practice: Updating the schedule using logic and
durations to determine the dates for all key activities;
Explanation: The schedule should use logic and durations in order to
reflect realistic start and completion dates, be continually monitored
to determine differences between forecasted completion dates and
planned dates, and avoid logic overrides and artificial constraint
dates.
Source: GAO, GAO Cost Estimating and Assessment Guide: Best Practices
for Developing and Managing Capital Program Costs, GAO-09-3SP
(Washington, D.C.: March 2009).
[End of table]
Our analysis of the IT schedule found that it did not reflect our best
practices for scheduling, as seen in table 4.
Table 4: DHS's Incorporation of Best Practices into the FPS IT
Transition Schedule:
Schedule best practice: Capturing all activities;
Extent best practice met: Partially met;
Assessment: Twenty-two percent of all activities in the schedule were
missing resource assignments, therefore it was unclear from the
schedule if all activities were included and who should perform the
work. Further, the schedule does not reflect a valid work breakdown
structure, which is a valuable communication tool because it provides
a clear picture of how the work will be done, and is therefore an
essential element in identifying activities in a schedule.
Schedule best practice: Sequencing all activities;
Extent best practice met: Not met;
Assessment: Almost all (99 percent) of the activities identified in
the schedule were not sequenced;
that is, activities that needed to finish prior to the start of other
activities (i.e., predecessor activities), and activities that could
not begin until other activities were completed (i.e., successor
activities), were not identified. In addition, the activities were not
logically sequenced--that is, logically linked in the order in which
they are to be carried out. Sequencing all activities in a schedule
helps ensure that interdependencies among such activities can be
established in such a way that when changes occur, the
interdependencies among the activities can be used as a basis for
guiding the work. Without such interdependencies, the credibility of
the calculated dates in the schedule is questionable.
Schedule best practice: Assigning resources to all activities;
Extent best practice met: Minimally met;
Assessment: The schedule did not fully identify the resources needed
to do the work or their availability. In regard to labor resources,
the schedule identifies 31 resources (i.e., individuals and agencies)
needed to do the work. Of the 31 resources, 19 are over allocated.
Over allocation means that more people are needed to do the work than
assigned to activities, which means that the work will not be done in
the time allocated and the schedule will most likely slip. In regard
to material resources, the schedule did not identify material or
equipment costs needed to do the work.
Schedule best practice: Establishing the duration of all activities;
Extent best practice met: Partially met;
Assessment: The schedule included duration figures (i.e., information
on how long each activity is expected to take to execute);
however, 46 percent of the activities identified in the schedule are 1-
day tasks. According to scheduling best practices, if there are a
large number of 1-day duration activities, planners should recognize
that these tasks typically take longer than 1 day to complete as
people rarely complete 8 hours of work in a typical work day. In
addition, the schedule identified 19 activities with durations ranging
from 66 to 242 days. Best practices in scheduling note that, in
general, estimated activity durations should be less than 2 working
months or approximately 44 working days because activities that are
too long in duration make it difficult for management to gauge
progress. Activities identified in the schedule were based on a
standard 40 hour work week that does not account for holidays. This
assumes resources for conducting IT transition activities are
available to work every day of the year. Since FPS is a federal
agency, the schedule should reflect a calendar that accounts for
federal holidays.
Schedule best practice: Integrating schedule activities horizontally
and vertically;
Extent best practice met: Minimally met;
Assessment: The schedule was generally vertically integrated, meaning
that some dates for starting and completing activities were aligned
with the dates for supporting tasks and subtasks. However, the
schedule is not horizontally integrated because it does not reflect
links to other sequenced activities. Therefore, any activity whose
duration is extended beyond the planned duration will simply extend
indefinitely with no effect on other sequenced activities or the
project end date.
Schedule best practice: Establishing the critical path for all
activities;
Extent best practice met: Not met;
Assessment: The schedule did not sequence all activities;
therefore, it is not possible to calculate a valid critical path.
Without a valid critical path, management cannot determine the effects
of what any activity slipping will have on the project finish date.
Schedule best practice: Identifying reasonable float between
activities;
Extent best practice met: Not met;
Assessment: The amount of float, which is an indicator of the amount
of flexibility in the schedule, cannot be determined because 99
percent of activities did not identify predecessor or successor
activities.
Schedule best practice: Conducting a schedule risk analysis;
Extent best practice met: Not met;
Assessment: We found no evidence that DHS officials performed a
schedule risk analysis. Because a schedule risk analysis was not
conducted, DHS cannot determine: the likelihood of the project
completion date, how much schedule risk contingency is needed to
provide an acceptable level of certainty by a specific date, which
risks are most likely to delay the project, how much contingency
reserve each of these risks require, and which paths are most likely
to delay the project.
Schedule best practice: Updating the schedule using logic and
durations to determine dates;
Extent best practice met: Minimally met;
Assessment: According to the schedule, 6 milestones and 10 detail
activities are marked as 100% complete. However, while the program
began in June 2010, only 4 percent of the activities scheduled to
occur in 2010 have been completed. This means that 96 percent of all
detail activities in 2010 are either still in-progress or have yet to
start. In addition, the schedule has no status date, which represents
the status of the completed work as of the current day and denotes
completed versus remaining effort. Because no effort has been made
within the schedule to status actual progress, it is impossible to
tell what activities have been completed, what activities are in
progress, what activities are late, and what activities are planned to
start on time.
Source: GAO analysis of FPS IT transition schedule.
Note: Not met--DHS provided no evidence that satisfies any of the
criterion; Minimally met--DHS provided evidence that satisfies a small
portion of the criterion; Partially met--DHS provided evidence that
satisfies about half of the criterion; Substantially met--DHS provided
evidence that satisfies a large portion of the criterion; and Met--DHS
provided complete evidence that satisfies the entire criterion.
[End of table]
We shared the results of our analysis with responsible DHS IT
transition officials, who stated that they have taken note of the
deficiencies and are taking steps to improve the schedule using the
scheduling practices. According to these officials, they plan to work
closely with staff in another NPPD component agency with the expertise
necessary to improve the IT transition schedule. Nevertheless, if the
schedule does not fully and accurately reflect the project, it will
not serve as an appropriate basis for analysis and may result in
unreliable completion dates, time extension requests, and delays. With
regard to the transfer of the IT services function, it would be
difficult for DHS to accurately predict the completion date for the IT
transition without a more reliable schedule. Moreover, completing
projects within projected time frames helps ensure agencies do not
incur additional costs, which is especially important in a fiscally
constrained environment. Ultimately, incorporating scheduling best
practices into the IT transition schedule could help DHS better manage
the completion of the transition and help provide reasonable assurance
that the transfer is complete within its projected timeframe.
Incorporating Cost Estimating Best Practices in the IT Transition Cost
Estimate Could Enhance the Reliability of, and Better Inform,
Decisions about the Cost to Complete the Transition:
According to best practices for cost estimates, in addition to a
reliable schedule, a reliable cost estimate is critical to the success
of any program.[Footnote 22] A reliable cost estimate provides the
basis for informed investment decision making, realistic budget
formulation and program resourcing, meaningful progress measurement,
proactive course correction when warranted, and accountability for
results. Such an estimate is important for any agency, but especially
an agency like FPS that is solely fee funded[Footnote 23] and has
faced projected shortfalls in fee collections to cover operational
costs.[Footnote 24]
Federal financial accounting standards state that reliable information
on the costs of federal programs and activities is crucial for
effective management of government operations and recommend that full
costs of programs or activities be reported so that decision makers
have information necessary to make informed decisions on resources for
programs, activities, and outputs, and to help ensure that they get
expected and efficient results.[Footnote 25] Drawing from federal cost-
estimating organizations and industry, our cost estimation best
practices list four characteristics of a high-quality and reliable
cost estimate that management can use for making informed decisions--
comprehensive, well-documented, accurate, and credible.[Footnote 26]
In July 2008, the DHS Under Secretary for Management signed a
memorandum stating DHS will standardize its cost-estimating process by
using the best practices we identified.
To implement the FPS transition, DHS, in 2009, estimated it would cost
$14.6 million to complete the transition of FPS from ICE to NPPD.
DHS's estimate provided for costs into three categories--personnel,
financial management, and IT services. In 2011, the department revised
the estimate for each of the three categories, which totaled $18.5
million. At the time of our review, FPS had spent about $1.9 million
of its operating revenue for transition-related expenses. Table 5
reflects estimated and actual costs for personnel, financial
management services, and IT services associated with the FPS
transition.
Table 5: Original and Revised FPS Transition Cost Estimates and Actual
Costs Incurred:
Cost category: Personnel:
Original estimate in August 2009: $6.6 million;
Revised estimate as of May 2011: $10.1 million;
Amount spent at the time of our review: $0.6 million[A].
Cost category: Financial management services;
Original estimate in August 2009: $2.4 million;
Revised estimate as of May 2011: $2.2 million;
Amount spent at the time of our review: $1.3 million[B].
Cost category: IT services;
Original estimate in August 2009: $5.6 million;
Revised estimate as of May 2011: $6.2 million;
Amount spent at the time of our review: $0.0[C].
Cost category: Total;
Original estimate in August 2009: $14.6 million;
Revised estimate as of May 2011: $18.5 million;
Amount spent at the time of our review: $1.9 million.
Source: GAO analysis of DHS data.
[A] FPS paid $630,000 to fund salaries and benefits for 25 new
personnel hired to provide services previously provided by ICE.
[B] FPS expects to incur $950,000 more in additional financial
management services costs for fiscal year 2010. According to DHS
officials, the transfer of FPS prompted ICE to assign financial
management services costs to FPS in a manner consistent with other
external customers. As a result, FPS's financial management services
costs increased by $2.2 million between fiscal years 2009 and 2010.
According to DHS officials, a bill for the remaining balance will be
submitted to FPS when NPPD signs a modified MOU, which was under
review as of May 2011.
[C] According to DHS officials, FPS has not yet incurred costs for the
IT transition.
[End of table]
DHS has successfully transferred the majority of mission-support
functions, which includes oversight of financial management services,
and, according to DHS officials, is on track to hire most of the
remaining new personnel by the beginning of fiscal year 2012 to
provide services previously provided by ICE. However, DHS has not yet
transferred IT services and does not expect to complete the transfer
until October 2012. Having a reliable and valid cost estimate is
important for enabling managers to make informed decisions and
facilitate tracking progress against estimates to effectively manage
the transfer of IT services. While DHS committed to using GAO's best
practices in preparing cost estimates in July 2008, our analysis of
the cost estimate for the transfer of IT services found that it only
partially met one of the four characteristics of a reliable cost
estimate and minimally met the other three, as table 6 illustrates.
Table 6: DHS's Incorporation of Best Practices into the FPS IT
Transition Cost Estimate:
Best practice: Comprehensive;
Explanation: The cost estimate should include all costs. It should
also provide an appropriate level of detail to ensure that cost
elements are neither omitted nor double-counted and include
documentation of all cost-influencing ground rules and assumptions;
Extent best practice met: Partially met;
Assessment: DHS estimated aggregate costs of $6.2 million for
hardware, labor, and travel for the IT services transfer--$3.4 million
for hardware and $2.8 million for labor and travel costs. However, the
estimate does not detail costs for the scope of activities identified
in the IT transition schedule. For example, the estimate does not
detail possible costs for a pilot project at one representative FPS
office and 26 other sample sites. In its report to the Office of
Management and Budget (OMB) in January 2011, DHS noted that FPS has
nearly 160 locations ranging from small remote sites to large mega-
centers, each with different IT configurations and needs potentially
requiring different solutions and that a pilot project was needed to
test whether initial technical solutions to these challenges will
actually work. DHS further noted that one of the significant items was
the transition of on-site technical support from ICE to a DHS Field
Support contract; however, the estimate did not detail costs for the
transition. Including such level of detail helps to ensure that no
cost elements are omitted or double counted.
Best practice: Well documented;
Explanation: The cost estimates should capture in writing such things
as source data used and their significance, the calculations performed
and their results, and the rationale for choosing a particular
estimating method. Moreover, this information should be captured in
such a way that the data used to derive the estimate can be traced
back to, and verified against, their sources. The final cost estimate
should be reviewed and accepted by management;
Extent best practice met: Minimally met;
Assessment: The cost estimate is not supported by detailed
documentation that describes how it was derived and how the expected
funding will be spent in order to achieve the IT transfer. DHS did not;
* document the formulas it used to calculate costs for the IT
transition or prepare a summary explaining the sources and methods
used to create the estimate;
* clearly outline the cost estimate results, including information
about cost drivers and high-risk areas, or;
* include in the estimate the underlying data on which the estimate
was based, which can cause an estimate's credibility to suffer because
the rational supporting the specific costs is not clear.
As a result, documentation was insufficient to allow us to corroborate
the estimate. Providing such detail serves as an audit trail for clear
tracking of cost estimates over time. Without a well-documented cost
estimate, DHS will have difficulty presenting a convincing argument of
the estimate's validity, and answering decision makers' and oversight
groups' questions.
Best practice: Accurate;
Explanation: The cost estimate results should be unbiased, and not
overly conservative or optimistic and based on an assessment of most
likely costs. Further, the estimate should be regularly updated to
reflect significant changes in the program so that it always reflects
current status. Moreover, variances between planned and actual costs
should be documented, explained, and reviewed;
Extent best practice met: Minimally met;
Assessment: An uncertainty analysis was not performed on the revised
estimate; therefore, we cannot assess whether the cost estimate is
unbiased, overly conservative, or optimistic based on an assessment of
most likely costs. In addition, while the IT transition cost estimate
has been revised from $5.6 million to $6.2 million, the cost estimate
is not regularly updated according to program officials. Moreover, the
revised estimate did not provide a track back to the original estimate
of $5.6 million and did not discuss any reasons for why there was a
variance. Although we found no mistakes in the costs that were
presented, the estimate was prepared at such a high level that we were
unable to confirm that the calculations were accurate.
Best practice: Credible;
Explanation: The cost estimate should discuss any limitations in the
analysis performed due to uncertainty surrounding data or assumptions.
Further, the estimate's derivation should provide for varying any
major assumptions and recalculating outcomes based on sensitivity
analyses, and their associated risks/uncertainty should be disclosed;
Extent best practice met: Minimally met;
Assessment: In December 2010, OMB expressed concerns to DHS about the
practicality of the FPS IT transition plan, including whether DHS's IT
system (DHS ONENet) was capable of supporting FPS operations across
the country. OMB also expressed concern to DHS about the dramatic
increase for IT services associated with the transition. In its
January 2011 response to OMB, DHS indicated that in order to reduce
risk, a pilot project would be performed at one of FPS's
representative offices. The results of the pilot may not provide
enough information for estimating risks related to the IT transition
at the remaining offices that range from small remote sites to large
mega-centers and have different configuration requirements. However,
DHS did not conduct a risk and sensitivity analysis to examine the
effects of changing assumptions and ground rules on the cost and
schedule of the transition. The IT transfer requires technical
decisions on changes in physical hardware and software, and system
configurations in the routers and switches, along with decisions on
any needs for new data circuits and routings. As DHS noted in its
response to OMB, these decisions are numerous in the presence of FPS
offices across the continent and are not currently matched by NPPD
service locations. To be considered credible, cost estimates should
discuss limitations in the analysis performed due to risk,
uncertainty, or biases surrounding the data or assumptions.
Source: GAO analysis of FPS IT transition cost data.
Note: Not met--DHS provided no evidence that satisfies any of the
criterion; Minimally met--DHS provided evidence that satisfies a small
portion of the criterion; Partially met--DHS provided evidence that
satisfies about half of the criterion; Substantially met--DHS provided
evidence that satisfies a large portion of the criterion; and Met--DHS
provided complete evidence that satisfies the entire criterion.
[End of table]
DHS officials stated that there are no plans to revise the IT
transition estimate. According to DHS officials, rather than revising
the estimate, the department plans to report actual costs once the
transition is complete. However, incorporating cost estimating best
practices into the IT transition cost estimate could provide an
improved basis for remaining IT transition investment decisions and
could facilitate tracking of actual costs against estimates, both of
which are fundamental to effectively managing the transfer of IT
services.
Transition May Provide Opportunity to Address Previously Identified
FPS Challenges, but It Is Too Early to Tell Its Impact:
Since 2007, we have reported that FPS faces significant challenges
with protecting federal facilities, and in response, FPS has started
to take steps to address some of them. For example, our July 2009 and
April 2010 reports on FPS's contract guard program identified a number
of challenges that the agency faces in managing its contract guard
program, including ensuring that the 15,000 guards that are
responsible for helping to protect federal facilities have the
required training and certification to be deployed at a federal
facility.[Footnote 27] In response to our July 2009 report, FPS took a
number of immediate actions with respect to contract guard management,
including increasing the number of guard inspections it conducts at
federal facilities in some metropolitan areas and revising its guard
training. Further, in our April 2010 report, we recommended, among
other things, that the Secretary of Homeland Security direct the Under
Secretary of NPPD and the Director of FPS to develop a mechanism to
routinely monitor guards at federal facilities outside metropolitan
areas and provide building-specific and scenario-based training and
guidance to its contract guards. As of August 2010, FPS was in the
process of implementing this recommendation.
Additionally, in July 2009 we reported that FPS did not have a
strategic human capital plan to guide its current and future workforce
planning efforts.[Footnote 28] Among other things, we recommended that
FPS develop and implement a long-term strategic human capital plan
that will enable the agency to recruit, develop, and retain a
qualified workforce. DHS concurred with our recommendation and is
taking action to address it. In June 2008, we reported on FPS's
funding challenges, and the adverse implications its actions taken to
address them had on its staff, such as low morale among staff,
increased attrition, and the loss of institutional knowledge.[Footnote
29] We recommended that FPS evaluate whether its use of a fee-based
system or alternative funding mechanism was the most appropriate
manner to fund the agency. FPS concurred with our recommendation;
however, as of May 2011, FPS had not begun such an analysis. Finally,
in our 2009 High-Risk Series, and again in 2011, we designated federal
real property as a high-risk area, in part, because FPS has made
limited progress and continues to face challenges in securing real
property.[Footnote 30]
If successfully managed, the transfer of FPS to NPPD could provide DHS
the opportunity to better advance progress towards addressing FPS's
challenges. The Under Secretary of NPPD and the former FPS Director,
in written statements for the November 2009 congressional hearing on
the FPS transfer, noted that the transition to NPPD would better
leverage and align infrastructure protection resources and
competencies to maximize their value. Further, the transition plan
noted that the transfer would improve the mission effectiveness of
both FPS and NPPD. According to NPPD officials, the agency has
undertaken actions that serve as a foundation for integrating FPS into
NPPD.
First, NPPD officials explained that efforts undertaken by the senior
working group and the staff working groups have served to move the
transition forward, and integrate the FPS organization into the larger
NPPD structure. These officials explained that FPS has been
established as a component within NPPD, thereby aligning FPS's
infrastructure protection mission within NPPD's critical
infrastructure protection mission. As noted in the transition plan,
NPPD chairs the operations of the Interagency Security Committee, a
group that includes the physical security leads for all major federal
agencies and whose key responsibility is the establishment of
governmentwide security policies for federal facilities. As further
noted in the transition plan, these missions are complementary and
mutually supportive, and the alignment resulting from the transfer
improves and advances the mission effectiveness of both FPS and NPPD.
Second, NPPD officials stated that FPS has begun to develop a new
strategic plan to align FPS's activities and resources to support NPPD
mission-related outcomes. Our work has shown that in successful
organizations, strategic planning is used to determine and reach
agreement on the fundamental results the organization seeks to
achieve, the goals and measures it will set to assess programs, and
the resources and strategies needed to achieve its goals. Third, NPPD
officials noted that NPPD has monthly meetings with FPS to review open
GAO recommendations and is assisting FPS in closing out these
recommendations. For example, in consultation with NPPD, FPS is
developing a human capital strategic plan. A human capital strategic
plan, flowing out of a new strategic plan, could help facilitate
efforts to address previously identified challenges. Further, as we
have previously reported, strategic human capital planning that is
integrated with broader organizational strategic planning is critical
to ensuring agencies have the talent they need for future challenges.
[Footnote 31]
Finally, according to the Senior Counselor to the Under Secretary of
NPPD, NPPD has established a Field Force Integration Working Group
among a set of five other integration working groups to pursue
integration activities across the new and larger NPPD, and across DHS
as a whole. In addition, the Senior Counselor noted that the purpose
of the group is to examine capabilities and resources from across the
NPPD components to gain efficiencies and economies of scale in support
of all NPPD field operations. The official further noted that the
FPS's workforce and regional structure is by far the largest and most
established of the NPPD components. FPS's field structure and
capabilities will be used as comparative models and resources as NPPD
works toward continued integration of its operating entities. While
these are encouraging steps, it is too early to tell if these planned
actions will help address the challenges we have previously identified.
Conclusions:
With its critical role in protecting federal facilities against the
threat of terrorism and other criminal activity, it is important that
FPS's transfer to NPPD and its related integration are successful. DHS
has implemented a number of scheduling and cost estimating best
practices in the FPS transition and has successfully transferred 13 of
the 18 mission support functions. Nevertheless, DHS could better
manage the transfer of the IT services mission-support function, and
help inform DHS, NPPD, FPS, and congressional investment decision
making. Establishing a reliable schedule and incorporating cost
estimation best practices in the estimate for the transfer of IT
services could help provide DHS enhanced assurance that this delayed
function will be transferred in accordance with its projected time
frames.
Recommendations for Executive Action:
To help ensure that DHS and Congress have reliable, accurate
information on the timeframes and costs of transferring FPS from ICE
to NPPD, we recommend that the Secretary of Homeland Security direct
the Under Secretary for NPPD, in consultation with the Director of FPS
and the Director of ICE, to:
* improve the schedule for transferring IT services, in accordance
with the transition plan, and to reflect scheduling best practices,
and:
* update the IT transition cost estimate, in accordance with cost-
estimating best practices.
Agency Comments:
We received written comments on a draft of this report from DHS. DHS
concurred with our recommendations and stated that it is currently
taking actions to implement them. With respect to improving the
schedule for transferring IT services, DHS indicated that NPPD held
working sessions with subject matter experts from DHS, ICE, and FPS
Chief Information Officer (CIO) teams to capture all transition
activities in greater detail and identify areas for implementation of
best practices into schedule updates. DHS also noted that NPPD
consulted with NPPD/United States Visitor and Immigrant Status
Indicator Technology (US-VISIT) and adopted recommendations for
schedule improvements, leveraging US-VISIT's lessons learned toward
better alignment with GAO best practices, acquisition of scheduling
expertise, and acquisition of specific software tools, among other
things. Regarding updating the IT transition cost estimate, DHS noted
that NPPD is researching and resolving cost-estimating deficiencies
identified in the GAO report in collaboration with the DHS CIO. The
department also noted that NPPD plans to identify an alternative
network design solution that may reduce transition cost, and will
refine the cost estimate after discussing network design discussions
with subject matter experts and incorporating cost-estimating best
practices. Written comments from DHS are reprinted in appendix II.
As agreed with your office, unless you publicly announce the contents
of the report, we plan no further distribution for 30 days from the
report date. At that time, we will send copies of this report to the
Secretary of Homeland Security, the Under Secretary of the National
Protection and Programs Directorate, the Director of the Federal
Protective Service, the Director of the Immigration and Customs
Enforcement, and appropriate congressional committees. In addition,
this report will be available at no charge on the GAO web site at
[hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact David C. Maurer at (202) 512-9627 or maurerd@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Key contributors to this
report are listed in appendix III.
Sincerely yours,
Signed by:
David C. Maurer, Director:
Homeland Security and Justice Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
We examined the transition of the Federal Protective Service (FPS)
from Immigration and Customs Enforcement (ICE) to the National
Protection and Programs Directorate (NPPD). We address the following
questions: (1) to what extent has the FPS transition been implemented
and what related challenges, if any, did FPS and NPPD face in
implementing the transition and (2) to what extent will the transition
help address previously identified challenges to protecting federal
facilities?
To determine the extent to which the FPS transition has been
implemented and what challenges, if any, FPS and NPPD faced in
implementing the transition, we reviewed documents related to the
transition, including the August 2009 FPS-NPPD Transition Plan, all
transition plan updates, DHS delegations of authority related to the
execution and administration of FPS, and Memorandum of Agreement,
Memorandum of Understanding, and all service level agreements signed
among FPS, NPPD, and ICE. We interviewed FPS officials directly
affected by the transition--including the FPS Deputy Director and
Chief of Staff headquartered in Washington, D.C., and in each of 6 of
FPS's 11 regional offices, the Regional Director, Deputy Director for
Operations, and Mission Support Chief. We chose these offices on the
basis of geographical dispersion. They included: the Northwest/Arctic
Region (Federal Way, Washington); the Greater Southwest Region (Grand
Prairie, Texas); the Heartland Region (Kansas City, Missouri); the
Great Lakes Region (Chicago, Illinois); the National Capital Region
(Washington, D.C.); and the New England Region (Boston,
Massachusetts). Among other things, we asked questions about their
experiences regarding the transition of FPS's mission and mission-
support functions from ICE to NPPD. While the results of these
interviews provided examples of FPS officials' experiences and
perspectives, they cannot be generalized beyond those we interviewed
because we did not use statistical sampling techniques in selecting
the regional offices, headquarters officials, and regional staff.
Additionally, we met with members of the transition senior working
group, including the NPPD Senior Counselor to the Under Secretary and
the FPS Director, as well as interviewed members of all 16 staff-level
working groups to discuss the extent to which FPS's 18 mission-support
functions had transferred from ICE to NPPD. The working groups
included officials from FPS, NPPD, ICE, and in some groups, DHS
headquarters. We compared the FPS information technology (IT)
transition schedule, the IT transition cost estimate, and related
documents to the practices in our Cost Estimating and Assessment
Guide.[Footnote 32] We focused on the IT mission-support function
because it required a significant commitment of resources, oversight,
and time by DHS to complete the transition. For the IT transition
schedule and the cost estimate, we scored each best practice as either
being Not met--DHS provided no evidence that satisfies any of the
criterion; Minimally met--DHS provided evidence that satisfies a small
portion of the criterion; Partially met--DHS provided evidence that
satisfies about half of the criterion; Substantially met--DHS provided
evidence that satisfies a large portion of the criterion; and Met--DHS
provided complete evidence that satisfies the entire criterion. We
provided the results of our schedule and cost analyses to DHS
officials and met with them to confirm the results. Based on the
interviews and additional documentation provided by DHS officials, we
updated the results of our analyses, as needed.
We reviewed financial documentation provided by all three components
reflecting transition costs such as salaries, benefits, and expenses
for new personnel hired to support the FPS transition, financial
management services provided by ICE, and IT deployment. To assess the
reliability of this documentation, we (1) performed electronic testing
for obvious errors in accuracy and completeness; (2) compared the data
with other sources of information, such as payroll reports to payroll
data, cost data from the ICE Office of Financial Management and
documentation from the Intra-Governmental Payment and Collection
(IPAC) system; and (3) interviewed agency officials knowledgeable
about financial management and budgeting at all three agencies to
discuss transition-related expenses incurred at the time of our
review, and to identify any data problems. When we found discrepancies
(such as data entry errors) we brought them to the officials'
attention and worked with them to correct discrepancies before
concluding our analysis. We found the cost data to be sufficiently
reliable for the purposes of this review.
To determine the extent to which the transition will help address
previously identified challenges to protect federal facilities, we
reviewed prior GAO reports and testimonies related to FPS's facility
protection efforts, and spoke with NPPD officials about FPS's ongoing
challenges in this regard.[Footnote 33] We also reviewed and analyzed
documentation, such as the transition plan, testimony from key senior
leaders in NPPD and FPS provided for a hearing on the FPS transition,
FPS's strategic plan, and NPPD's strategic activities report. Finally,
we interviewed the Senior Counselor to the Under Secretary of NPPD,
and FPS Deputy Director for Operations and Chief of Staff, and
discussed actions underway or planned to further integrate FPS into
NPPD.
We conducted this performance audit from October 2010 through July
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
July 8, 2011:
Mr. David C. Maurer:
Director, Homeland Security and Justice:
U.S. Government Accountability Office:
4441 G Street, NW:
Washington, DC 20548:
Re: Draft Report GAO 11-554, "Federal Protective Service: Progress
Made but Improved Schedule and Cost Estimate Needed to Complete
Transition"
Dear Mr. Maurer:
Thank you for the opportunity to review and comment on this draft
report. The U.S. Department of Homeland Security (DHS) appreciates the
U.S. Government Accountability Office's (GAO's) work in planning and
conducting its review and issuing this report.
The Department is pleased to note the report's positive acknowledgment
that DHS has successfully transferred the majority of the Federal
Protective Service's (FPS's) mission support functions to the National
Protection and Programs Directorate (NPPD) or other DHS
Components. The report also recognizes that DHS has implemented a
number of scheduling and cost estimating best practices during the
transition. To accomplish this, senior representatives and subject
matter experts (SMEs) from NPPD, U.S. Immigration and Customs
Enforcement (ICE), and FPS built a comprehensive transition plan that
was flexible enough to be adjusted when necessary as new hurdles or
roadblocks to the transition became apparent. For example, NPPD senior
leadership made deliberate decisions to delay the build-out of NPPD-
level capacity in Facilities Management, Security Integrity and
Personnel Security, and Equal Employment Opportunity support. With the
exception of the Information Technology (IT) transition, on which work
is continuing, the FPS transition to NPPD has been implemented on
time, under projected budget, and with no adverse impact on the field
operations of FPS's law enforcement and security personnel as they
work to secure federal facilities and federal workers across the
United States.
The draft report contained two recommendations with which DHS concurs,
as discussed below. Specifically, to help ensure that DHS and Congress
have reliable, accurate information on the timeframes and costs of
transferring FPS from ICE to NPPD. GAO recommended that the Secretary
of Homeland Security direct the Director of FPS, in consultation with
the Assistant Secretary of ICE and the Undersecretary for NPPD to:
Recommendation 1: Improve the schedule for transferring IT services,
in accordance with the transition plan, and to reflect scheduling best
practices.
Response: Concur. NPPD is currently taking steps to implement this
recommendation. Details on actions taken to date follow:
* Using the March 2009 GAO Cost Estimating and Assessment Guide (GAO-
09-3SP), NPPD in June 2011 held working sessions with SMEs from the
DHS, ICE, and FPS Chief Information Officer (CIO) teams to capture all
transition activities in greater detail and to identify areas for
implementation of best practices into schedule updates. These working
sessions allowed NPPD to provide logical sequencing and establish
durations and dependencies for all transition activities, allowing the
organization to generate a critical path for all activities.
The NPPD CIO consulted with NPPD/United States Visitor and Immigrant
Status Indicator Technology (US-VISIT) and adopted recommendations for
schedule improvements, leveraging US-VISIT's lessons learned toward
better alignment with the GAO best practices, acquisition of
scheduling expertise, and acquisition of specific software tools. An
updated draft of the schedule was distributed to the FPS IT Transition
Integrated Project Team (IPT) and SMEs for review and confirmation of
the resource assignments. An SME IPT was also established as a sub-
group of the FPS IT Transition IPT to evaluate alternative technical
methods that could increase automation and reduce cost.
* Over the last 2 months, NPPD has also updated the schedule by
holding working sessions with SMEs from the DIIS, ICE, and FPS CIO
teams to capture all transition activities in greater detail and
identify the current IT services provided by ICE CIO. NPPD is
conducting periodic schedule reviews during weekly FPS IT Transition
IPT meetings to provide visibility to all major stakeholders.
The working sessions separated functions and services into the areas
of business applications project management and system development, IT
infrastructure support, IT field operations support, applications
hosting environments, enterprise architecture, and telecommunications.
The primary intent of this ongoing effort is to find alternative
methods that will allow increased automation and deflect non-required
activities from the critical path.
* NPPD also plans to take action to hire additional SMEs to guide
these scheduling efforts. In particular, NPPD plans to acquire the
services of a Master Scheduler to provide ongoing scheduling expertise
to the NPPD CIO organization and augment FPS IT branch staff. The
Master Scheduler will be responsible for managing and monitoring all
NPPD IT initiatives, including the FPS IT Transition. This need will
be met by a government full-time employee, detailee, or contractor
support. Additionally, the August 2009 FPS-NPPD Transition Plan
identified eight additional staff required for FPS IT branch support
in the areas of IT, cost estimation, logistics, information security,
and mission support. Hiring actions are underway, and three of the
eight positions have already been filled.
Recommendation 2: Update the IT transition cost estimate, in
accordance with cost-estimating best practices.
Response: Concur. NPPD is taking steps to update and improve the cost
estimate using best practices, To accomplish this, NPPD is researching
and resolving cost-estimating deficiencies identified in the GAO
report in collaboration with the DHS CIO. The original cost estimate
was based on worst case transition and considered full replacement
costs and customized migrations.Consultation with other groups that
have been transitioned by ICE (namely U.S. Citizenship and Immigration
Services) and detailed technical discussions suggest a new transition
scenario in which only selective replacement of infrastructure may be
required and the labor-intensive customized migration of individual
users and their workstations would likely be minimal. This in turn as
has resulted in an ongoing refinement of the cost basis; however, some
regional and site differences would still exist and are being
categorized. The results of the detailed analysis of the technical
alternative will likely establish a new basis for the cost estimation.
NPPD also plans to identify an alternate network design solution that
may reduce transition cost. Alternative network designs, based on the
evolution of the DHS network infrastructure (ONENET) and the
introduction and establishment of trusted network zones within DHS, are
likely available. These designs could reduce the complexity of the
network migration as well as the need for additional network equipment
to support the previous requirements of the ONENET infrastructure.
NPPD will also refine the cost estimate after discussing network
design discussions with SMEs and incorporating cost-estimating best
practices.
Again, thank you for the opportunity to review and comment on this
draft report. We look forward to working with you on future Homeland
Security issues.
Sincerely,
Signed by:
Jim H. Crumpacker:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
David C. Maurer at (202) 512-9627 or at maurerd@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Sandra Burrell, Assistant
Director, and Valerie Kasindi, Analyst-in-Charge, managed this
assignment. Don Kiggins made significant contributions to the work.
Gary Mountjoy provided expertise on IT issues and Jack Warner provided
expertise on financial management issues. Tracey King provided legal
support. Michele Fejfar assisted with design and methodology and Karen
Richey provided expertise on cost estimation and scheduling best
practices. Katherine Davis provided assistance in report preparation
and Robert Robinson developed the report's graphics.
[End of section]
Footnotes:
[1] The GSA Administrator established FPS in January 1971 through an
administrative order.
[2] Pub. L. No. 107-296, § 403, 116 Stat. 2135, 2178 (2002) (codified
at 6 U.S.C. § 203).
[3] ICE is the principle investigative arm of DHS and the second
largest investigative agency in the federal government. ICE's primary
mission is to promote homeland security and public safety through the
criminal and civil enforcement of federal laws governing border
control, customs, trade, and immigration.
[4] Pub. L. No. 111-83, 123 Stat. 2142, 2156-57 (2009). NPPD was
formed by the Secretary of Homeland Security after enactment of the
Post-Katrina Emergency Management Reform Act of 2006, and its goal is
to advance DHS's risk-reduction mission. NPPD works to reduce risks to
the nation through five mission areas: protect the nation's citizens
and visitors against dangerous people and goods; protect the nation's
physical infrastructure; protect and strengthen the nation's cyber and
communications infrastructure; strengthen DHS's risk management
platform; and strengthen partnerships and foster collaboration and
interoperability.
[5] See for example, GAO, Budget Issues: Better Fee Design Would
Improve Federal Protective Service's and Federal Agencies' Planning
and Budgeting for Security, [hyperlink,
http://www.gao.gov/products/GAO-11-492] (Washington, D.C.: May 20,
2011); Homeland Security: Addressing Weaknesses with Facility Security
Committees Would Enhance Protection of Federal Facilities, [hyperlink,
http://www.gao.gov/products/GAO-10-901] (Washington, D.C.: Aug. 5,
2010); and Homeland Security: Federal Protective Service's Contract
Guard Program Requires More Oversight and Reassessment of Use of
Contract Guards, [hyperlink, http://www.gao.gov/products/GAO-10-341]
(Washington, D.C.: Apr. 13, 2010).
[6] Department of Homeland Security. FPS-NPPD Transition Plan: A
Proposed Organizational Transition Fiscal Year 2009 Report to Congress
(Aug. 21, 2009).
[7] The MOU is a document that describes broad concepts of mutual
understanding, goals and plans shared by the parties. The MOA is a
document describing in detail the specific responsibilities of, and
actions to be taken by, each of the parties so that their goals may be
accomplished. The SLAs are agreements that define customer service
expectations and responsibilities between two or more parties and are
used to communicate baseline mission service requirements.
[8] The SLAs established the scope of services ICE would provide to
FPS during the transition period of October 2009 to September 2010,
and in some cases into fiscal year 2011.
[9] The 18 mission-support functions are: operations; human capital;
employee and labor; training, professional development, and education;
budget formulation and performance; financial management; procurement
management and operations; logistics and asset management;
acquisitions; legislative affairs; public affairs; information
management; legal services; information operations (information
technology services); business continuity and emergency preparedness;
security integrity and personnel security; facilities; and equal
employment opportunity.
[10] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for
Developing and Managing Capital Program Costs, [hyperlink,
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: Mar. 2009).
[11] DHS officials define transition cost as the increase in the cost
of mission-support functions as a result of FPS's transfer.
[12] The IPAC system is designed to transfer funds between government
agencies and provide the capability to include descriptive information
related to each transaction.
[13] The DHS headquarters organization includes Departmental
Management and Operations, which provides leadership, direction and
management to DHS and is comprised of separate appropriations
including: the Office of the Secretary and Executive Management
(OSEM); the Under Secretary for Management (USM); the Office of the
Chief Financial Officer (OCFO); and the Office of Chief Information
Officer (OCIO) and DHS Headquarters (HQ) Consolidation.
[14] The August 2009 FPS-NPPD Transition Plan initially identified 17
mission support functional areas. However, in the July 15, 2010
Transition Update, acquisitions was separated from the procurement
management and operations mission support functional area and became
the 18TH mission support function.
[15] Department of Homeland Security, Delegation Number: 17007,
Delegation for Administration of the Federal Protective Service (Dec.
18, 2009).
[16] Department of Homeland Security, Delegation Number: 17001.001,
Delegation to the Director for the Federal Protective Service (Dec.
24, 2009).
[17] 40 U.S.C. § 1315(e).
[18] The other NPPD component offices include the Office of
Cybersecurity, the Office of Infrastructure Protection, the Office of
Risk Management and Analysis, and the Office of U.S. Visitor and
Immigrant Status Indicator Technology.
[19] A building security assessment is a comprehensive risk assessment
that examines credible threats to federal buildings and the
vulnerabilities and consequences associated with those threats.
Credible threats include things such as crime activity or potential
terrorism acts.
[20] To implement the FPS transition, DHS estimated $14.6 million in
three cost categories. These categories were (1) $6.6 million for
salaries, benefits, and expenses for additional staff DHS plans to
hire as a result of FPS's transfer, (2) $ 2.4 million for various
costs associated with financial management services, and (3) $5.6
million for IT requirements.
[21] See, for example, GAO, Nuclear Waste: Actions Needed to Address
Persistent Concerns with Efforts to Close Underground Radioactive
Waste Tanks at DOE's Savannah River Site, [hyperlink,
http://www.gao.gov/products/GAO-10-816] (Washington, D.C.: Sept. 14,
2010); Transportation Worker Identification Credential: Progress Made
in Enrolling Workers and Activating Credentials but Evaluation Plan
Needed to Help Inform the Implementation of Card Readers, [hyperlink,
http://www.gao.gov/products/GAO-10-43] (Washington, D.C.: Nov. 18,
2009); and Nuclear Weapons: National Nuclear Security Administration
Needs to Better Manage Risk Associated with Modernization of Its
Kansas City Plant, [hyperlink, http://www.gao.gov/products/GAO-10-115]
(Washington, D.C.: Oct. 23, 2009).
[22] [hyperlink, http://www.gao.gov/products/GAO-09-3SP].
[23] FPS is a reimbursable organization and is fully funded by
collecting security fees from tenant agencies. To fund its operations,
FPS charges each tenant agency a basic security fee per square foot of
space occupied in a GSA facility. In 2010, the basic security fee was
66 cents per square foot and covered services such as patrolling,
monitoring of building perimeter alarms, and dispatching of law
enforcement response through its control centers. FPS also collects an
administrative fee it charges tenant agencies for building specific
security services such as access control to facilities' entrances and
exists; employee and visitor checks; and the purchase, installation,
and maintenance of security equipment. In addition to these security
fees, FPS provides agencies with additional services upon request,
which are funded through reimbursable Security Work Authorizations,
for which FPS charges an administrative fee.
[24] See for example, GAO, Homeland Security: The Federal Protective
Service Faces Several Challenges That Hamper Its Ability to Protect
Federal Facilities, [hyperlink,
http://www.gao.gov/products/GAO-08-683] (Washington, D.C.: June 11,
2008).
[25] Statement of Federal Financial Accounting Standards No. 4,
Managerial Cost Accounting Concepts and Standards for the Federal
Government, establishes standards for managerial cost accounting
information at federal agencies.
[26] [hyperlink, http://www.gao.gov/products/GAO-09-3SP].
[27] [hyperlink, http://www.gao.gov/products/GAO-10-341] and GAO,
Homeland Security: Preliminary Results Show Federal Protective
Service's Ability to Protect Federal Facilities Is Hampered By
Weaknesses in Its Contract Security Guard Program, [hyperlink,
http://www.gao.gov/products/GAO-09-859T] (Washington, D.C.: July 8,
2009).
[28] GAO, Homeland Security: Federal Protective Service Should Improve
Human Capital Planning and Better Communicate with Tenants,
[hyperlink, http://www.gao.gov/products/GAO-09-749] (Washington, D.C.:
July 30, 2009).
[29] [hyperlink, http://www.gao.gov/products/GAO-08-683].
[30] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February
2011); and High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[31] GAO, Interagency Collaboration: Key Issues for Congressional
Oversight of National Security Strategies, Organizations, Workforce,
and Information Sharing, [hyperlink,
http://www.gao.gov/products/GAO-09-904SP] (Washington, D.C.: Sept. 25,
2009).
[32] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for
Developing and Managing Capital Program Costs, [hyperlink,
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009).
[33] See, for example, GAO, Homeland Security: Addressing Weaknesses
with Facility Security Committees Would Enhance Protection of Federal
Facilities, [hyperlink, http://www.gao.gov/products/GAO-10-901]
(Washington, D.C.: Aug. 5, 2010); Homeland Security: Federal
Protective Service's Contract Guard Program Requires More Oversight
and Reassessment of Use of Contract Guards, [hyperlink,
http://www.gao.gov/products/GAO-10-341] (Washington, D.C.: Apr. 13,
2010); Homeland Security: Ongoing Challenges Impact the Federal
Protective Service's Ability to Protect Federal Facilities,
[hyperlink, http://www.gao.gov/products/GAO-10-506T] (Washington,
D.C.: Mar. 16, 2010); Homeland Security: Federal Protective Service
Has Taken Some Initial Steps to Address Its Challenges, but
Vulnerabilities Still Exist, [hyperlink,
http://www.gao.gov/products/GAO-09-1047T] (Washington, D.C.: Sept. 23,
2009); Homeland security: Preliminary Results Show Federal Protective
Service's Ability to Protect Federal Facilities Is Hampered by
Weaknesses in Its Contract Security Guard Program, [hyperlink,
http://www.gao.gov/products/GAO-09-859T] (Washington, D.C.: July 8,
2009); and Homeland Security: Federal Protective Service Should
Improve Human Capital Planning and Better Communicate with Tenants,
[hyperlink, http://www.gao.gov/products/GAO-09-749] (Washington, D.C.:
July 30, 2009).
[End of section]
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Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548:
