FEDERAL LAW 

ENFORCEMENT

DHS and DOJ Are 

Working to Enhance 

Responses to 

Incidents Involving 

Individuals with 

Mental Illness

Report to Congressional Committees

February 2018

GAO-18-229

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-229, a report to 

congressional committees

February 2018

FEDERAL LAW ENFORCEMENT

DHS and DOJ Are Working to Enhance Responses to 

Incidents Involving Individuals with Mental Illness

What GAO Found

Law enforcement officers and agents from the Departments of Homeland 

Security (DHS) and Justice (DOJ) cited a number of challenges in our discussion 

groups related to their response to incidents involving individuals with a mental 

illness. 

Challenges Identified in Law Enforcement Officer and Agent Discussion Groups

All of the federal law enforcement components in GAO’s review either offer, 

receive, or are developing some form of training to their law enforcement officers

and agents that addresses responding to incidents involving individuals with a 

mental illness. Further, all components have relevant policies or guidance in 

place, and all are undertaking efforts to enhance their practices in accordance 

with departmental guidance. Since DHS and DOJ components have varying 

missions and operational needs and interact with the public in different 

capacities, the nature and scope of training, as well as the number and duration 

of courses offered in response to individuals with mental illness varies; however, 

they generally include elements focusing on de-escalation and communication. 

In addition, DHS and DOJ both have efforts underway to have components 

review their training and policies under departmental guidance and plan to begin 

implementing any changes by 2018.

Stakeholders cited leading practices and tools for effective law enforcement 

responses, and DHS and DOJ components have generally leveraged information 

from other knowledgeable parties. For example, the Crisis Intervention Team 

approach involves training selected law enforcement officers on mental health 

topics and dispatching those officers on mental-health related calls. While 

models like this are typically used by state and local law enforcement agencies, 

their benefits could be considered in other settings such as federal law 

enforcement. DHS and DOJ officials are also using collaborative mechanisms 

within their departments, such as conference calls and working groups with 

officials, that have helped them leverage information from knowledgeable 

parties. In addition, DOJ’s Bureau of Justice Assistance (BJA), which supports 

programs and initiatives in the areas of law enforcement, among other activities, 

has developed and makes publicly available resources such as its Police-Mental 

Health Collaboration Toolkit. BJA also is working to stand up a national training 

and technical assistance center to improve law enforcement responses to people 

with mental illness. While aimed at state, local, and tribal law enforcement, a BJA 

official also acknowledged that the center could serve as an additional resource 

for federal law enforcement agencies to consult as they review relevant trainings, 

View GAO-18-229. For more information, policies, and guidance on this topic.

contact Diana Maurer at (202) 512-8777 or 

MaurerD@gao.gov.

Why GAO Did This Study

Law enforcement encounters with

individuals with mental illness may

require special training and skills and 

can sometimes involve volatile 

situations, risking tragic injuries or 

even death.

The 21st Century Cures Act includes a 

provision for GAO to review the 

practices that federal first responders, 

tactical units, and corrections officers 

(for the purposes of this study, “law 

enforcement officers and agents”) are 

trained to use in responding to

incidents involving individuals with 

mental illness. This report addresses 

(1) challenges that federal law 

enforcement officers and agents face; 

(2) applicable training, policies, and 

guidance; and (3) existing leading 

practices, relevant tools, and efforts to 

leverage information.

GAO selected the five DHS and five 

DOJ law enforcement components 

(e.g., Secret Service, Federal Bureau 

of Investigation) that represent the 

largest concentration of law 

enforcement officers within the two 

departments. GAO reviewed the 

training, policies, and guidance in 

place, as well as efforts to enhance 

them, and discussed these matters 

with knowledgeable officials. In 

addition, GAO held discussion groups 

with a nongeneralizable sample of law 

enforcement officers and agents, 

selected through component contacts,

to discuss their perspectives. GAO 

also reviewed studies on law 

enforcement responses to individuals 

with mental illness to help identify 

leading practices and tools and 

interviewed stakeholders, selected 

through a structured process, to obtain 

their perspectives.
Page i GAO-18-229 Federal Law Enforcement

Letter 1

Background 6

Discussion Groups Identified Several Challenges that Officers and 

Agents Encounter When Responding to Incidents Involving 

Individuals with Mental Illness 12

Components Have Some Type of Training, Policies, and 

Guidance Related to Mental Illness, and Reviews to Enhance 

Practices are Underway 16

Stakeholders Cited Leading Practices and Tools for Effective Law 

Enforcement Responses, and Components Have Generally 

Leveraged Information from Other Knowledgeable Parties 25

Agency Comments 29

Appendix I Objectives, Scope and Methodology 32

Appendix II Description of the Federal Law Enforcement Training Centers 

(FLETC) Basic Training Programs 39

Appendix III GAO Contact and Staff Acknowledgments 41

Tables

Table 1: Department of Homeland Security and Department of 

Justice Federal Law Enforcement Components Selected 

for GAO’s Review and Their Missions 3

Table 2: Examples of Department of Homeland Security (DHS) 

Operational Components’ Training Content Related to 

Officers’ Response to Incidents Involving Individuals with 

Mental Illness, as of October 2017 18

Table 3: Examples of Department of Justice (DOJ) Components’ 

Training Content Related to Officers’ Response to 

Incidents Involving Individuals with Mental Illness, as of 

October 2017 19

Table 4: Examples of Policies and Guidance at Departments of 

Homeland Security (DHS) and Justice (DOJ) Components 

Related to Officers’ Response to Incidents Involving 

Individuals with Mental Illness, as of October 2017 20

Contents
Page ii GAO-18-229 Federal Law Enforcement

Table 5: Stakeholder-Cited Tools that May Enhance Law 

Enforcement Responses to Incidents Involving Individuals 

with Mental Illness 27

Table 6: Department of Homeland Security and Department of 

Justice Federal Law Enforcement Components Selected 

for Review and Their Missions 32

Figures

Figure 1: Illustrative Example of an Incident at a Federal Facility 

Involving Federal Law Enforcement and an Individual 

Displaying Signs of a Mental Illness 10

Figure 2: Stakeholder-Cited Leading Practices for Effective Law 

Enforcement Responses to Incidents Involving 

Individuals with Mental Illness 26
Page iii GAO-18-229 Federal Law Enforcement

Abbreviations

ATF Bureau of Alcohol, Tobacco, Firearms and Explosives

BJA Bureau of Justice Assistance

BOP Federal Bureau of Prisons

CBP U.S. Customs and Border Protection

CIT Crisis Intervention Team

CRCL Office for Civil Rights and Civil Liberties

CSG JC Council of State Governments Justice Center

DEA U.S. Drug Enforcement Administration

DHS Department of Homeland Security

DOJ Department of Justice

DSM-IV Diagnostic and Statistical Manual of Mental Disorders, 

4th edition

FBI Federal Bureau of Investigation

FLETC Federal Law Enforcement Training Centers

FPS Federal Protective Service

IACP International Association of Chiefs of Police

ICE U.S. Immigration and Customs Enforcement

ODAG Office of the Deputy Attorney General

PERF Police Executive Research Forum

Section 504 Section 504 of the Rehabilitation Act of 1973, as amended

TSA Transportation Security Administration

USMS U.S. Marshals Service

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-229 Federal Law Enforcement

441 G St. N.W.

Washington, DC 20548

February 8, 2018

Congressional Committees:

According to the International Association of Chiefs of Police (IACP), law 

enforcement officers nationwide are increasingly called upon to respond 

to and intervene on behalf of people affected by mental illness.1 Based on 

estimates from the Substance Abuse and Mental Health Services 

Administration—an agency within the Department of Health and Human 

Services—44.7 million adults in the United States had a mental illness in 

2016.2 Since law enforcement officers can encounter individuals affected 

by mental illness in the course of their duties, the nature of their 

interaction has become an issue of national concern. In particular, 

research has demonstrated that such encounters:

• may require special training and skills to address;

• may depend on the availability of community and mental health 

resources for a positive outcome;

• are often time-consuming and difficult for law enforcement officers to 

resolve;

• typically involve repeat contacts with individuals who have unmet 

mental health needs; and

 1

IACP, Improving Police Response to Persons Affected by Mental Illness, Report from the 

March 2016 IACP Symposium, Alexandria, Virginia (2016). IACP is a professional 

association for law enforcement that aims to advance the law enforcement profession 

through advocacy, outreach, education and programs. For the purpose of our review, we 

used the definition of mental illness that the National Alliance on Mental Illness developed, 

which is: “a condition that affects a person’s thinking, feeling or mood. Such conditions

may affect someone’s ability to relate to others and function each day.” The National 

Alliance on Mental Illness is an association of local affiliates, state organizations and 

volunteers who work to raise awareness and provide support and education on various 

issues related to mental illness.

2

Substance Abuse and Mental Health Services Administration (2017). Key substance use 

and mental health indicators in the United States: Results from the 2016 National Survey 

on Drug Use and Health (HHS Publication No. SMA 17-5044, NSDUH Series H-52). 

Rockville, MD: Center for Behavioral Health Statistics and Quality, Substance Abuse and 

Mental Health Services Administration. Retrieved from https://www.samhsa.gov/data/. In 

that report, adults with a mental illness were defined as having any mental, behavioral, or 

emotional disorder in the past year that met criteria from the American Psychiatric 

Association’s Diagnostic and Statistical Manual of Mental Disorders, 4th edition (DSM-IV), 

excluding developmental disorders and substance use disorders.

Letter
Page 2 GAO-18-229 Federal Law Enforcement

• can involve volatile situations, risking tragic injuries or even death. 

Such concerns and potential safety issues underscore the importance of 

developing tailored approaches, training, and policies to help guide police 

departments and law enforcement officials.

To date, most efforts to promote such training or policies have been 

focused on state and local law enforcement agencies, such as police 

departments. While federal law enforcement agencies typically do not 

serve as first responders to emergency calls, they do interact with the 

public in the course of their duties and can encounter individuals with 

mental illness. At the federal level, the Department of Homeland Security 

(DHS) and Department of Justice (DOJ) are responsible for enforcing 

many laws regarding the safety and security of the United States, and 

these two departments house the majority of federal law enforcement 

officers nationwide.3

The 21st Century Cures Act4 includes a provision for us to review, among 

other things, practices that federal first responders, tactical units, and 

corrections officers are trained to use in responding to incidents involving 

individuals with mental illness.5 This report addresses the following key 

questions: (1) What challenges, if any, do federal law enforcement 

officers and agents at selected DHS and DOJ components face when 

responding to incidents involving individuals with mental illness? (2) What 

type of training, policies, and guidance, if any, are in place at selected 

DHS and DOJ components to prepare federal law enforcement officers 

and agents for responding to incidents involving individuals with mental 

illness? (3) What leading practices or tools have relevant stakeholders 

cited for effective responses to incidents involving individuals with mental 

 3

Specifically, DHS’s mission includes preventing terrorism and enhancing security; 

managing and securing the nations’ borders; administering and enforcing immigration 

laws; and securing cyberspace. DOJ’s mission includes enforcing the law and defending 

the interests of the United States according to the law, ensuring public safety against 

threats foreign and domestic, providing federal leadership in preventing and controlling 

crime, and ensuring fair and impartial administration of justice for all Americans.

4

Pub. L. No. 114-255, div. B., tit. XIV, subtit. B, § 14026, 130 Stat. 1033, 1310-11 (2016). 

The provision for our study is contained in Division B—the Helping Families in Mental 

Health Crisis Reform Act of 2016. 

5

For the purposes of our review, we focused on federal law enforcement officers, tactical 

units, and correctional officers, referring to all under the general term “law enforcement 

officers” from here forward. We use the terminology “officers and/or agents” to reflect the 

varying job titles and responsibilities that individuals within these components have. We 

did not include contractors in the scope of our review.
Page 3 GAO-18-229 Federal Law Enforcement

illness, and how have DHS and DOJ components leveraged information 

from other knowledgeable parties?

We focused our review on the training, policies, and guidance put forth by 

the DHS and DOJ components listed in table 1 below because they 

comprise nearly all of the federal law enforcement officers in these 

departments.

Table 1: Department of Homeland Security and Department of Justice Federal Law Enforcement Components Selected for 

GAO’s Review and Their Missions

Component Mission

Department of Homeland Security

Federal Law Enforcement 

Training Centers (FLETC)a Provides career-long training to law enforcement professionals to help them fulfill their responsibilities safely and proficiently. Under a collaborative training model, FLETC’s federal partner 

organizations deliver training unique to their missions, while FLETC provides training in areas 

common to all law enforcement officers, such as firearms, driving, tactics, investigations, and legal 

training.

Federal Protective Service

(FPS)

Provides integrated security and law enforcement services, such as conducting facility security 

assessments; responding to crimes and other incidents to protect life and property; and detecting, 

investigating, and mitigating threats to more than 9,500 federal facilities nationwide.

Transportation Security 

Administration (TSA)

Protects the nation’s transportation systems to ensure freedom of movement for people and 

commerce. TSA does this by, among other things, deploying Federal Air Marshals on U.S. aircraft 

worldwide. Our review focuses on TSA’s Federal Air Marshals, who are to detect, deter, and defeat 

criminal and terrorist activity targeting transportation systems. 

U.S. Customs and Border 

Protection (CBP)

Protects the borders of the United States from dangerous people and materials, while facilitating 

lawful international travel and trade.

U.S. Immigration and Customs 

Enforcement (ICE)

Protects the United States from cross-border crime and illegal immigration that threaten national 

security and public safety. ICE executes this mission through enforcement of federal statutes and 

focuses on immigration enforcement, preventing terrorism, and combating the illegal movement of 

people and goods. Our review focuses on ICE’s Homeland Security Investigations office, which 

investigates cross-border criminal activity, and ICE’s Enforcement and Removal Operations unit, 

which identifies and apprehends removable aliens, detains them when necessary, and removes 

illegal aliens from the United States.

U.S. Secret Service Provides physical protection to the nation’s highest elected leaders and visiting foreign dignitaries, as 

well as for facilities and major events, and safeguards the payment and financial systems of the 

United States from a wide range of financial and computer-based crimes. 

Department of Justice

Bureau of Alcohol, Tobacco, 

Firearms and Explosives (ATF)

Investigates and seeks to prevent federal offenses involving the unlawful use, manufacture, and 

possession of firearms and explosives, acts of arson and bombings, and illegal trafficking of alcohol 

and tobacco products.

Federal Bureau of Prisons 

(BOP)

Confines offenders in the controlled environments of prisons and community-based facilities that are 

safe, humane, cost-efficient, and appropriately secure, and that provide work and other selfimprovement opportunities to assist offenders in becoming law-abiding citizens. As part of its duties, 

BOP is responsible for delivering medically necessary health care to inmates in accordance with 

proven standards of care, including medical, dental and mental health.
Page 4 GAO-18-229 Federal Law Enforcement

Component Mission

Federal Bureau of Investigation 

(FBI)

Protects the nation from terrorism, espionage, cyber-attacks, and major criminal threats through 

intelligence-gathering and law enforcement responsibilities. Our review focuses on the FBI’s Special 

Agents, who are primarily responsible for executing this mission, as well as FBI Police Officers, who 

provide security at FBI facilities.

U.S. Drug Enforcement 

Administration (DEA)

Enforces the controlled substances laws and regulations of the United States and brings to the 

criminal and civil justice system of the United States, or any other competent jurisdiction, those 

organizations and principal members of organizations involved in the growing, manufacture, or 

distribution of controlled substances appearing in or destined for illicit traffic in the United States.

U.S. Marshals Service (USMS) Provides federal judicial security, apprehends fugitives and non-compliant sex offenders, secures 

and transports federal prisoners from arrest to incarceration, executes federal court orders, seizes 

and manages assets acquired through illegal means, and assures the safety of endangered 

government witnesses and their families.

Source: GAO summary of information from components. | GAO-18-229

Note: According to data the departments provided to us, as of the end of fiscal year 2016, the DHS 

components above—excluding FLETC—employed 42,823 of 43,222 law enforcement officers within 

DHS, and the DOJ components above employed 43,502 of 43,639 law enforcement officers within 

DOJ.

a

FLETC information is presented in this table as the component provides various types of training to a 

number of federal law enforcement agencies. However, we do not consider it an operational law 

enforcement component for our subsequent discussions of training in place across DHS components.

To identify the challenges that federal law enforcement officers and 

agents at our selected DOJ and DHS components face when responding 

to incidents involving individuals with mental illness, we held discussion 

groups with six to eleven agents or officers within each selected 

component to ask about their experiences. We worked with officials at 

each component to identify officers and agents with varied tenures and 

experiences. We then summarized the information collected from the 

discussion groups and identified common themes across the selected 

components. We worked closely with the departments to organize these 

discussion groups; however, these officers’ and agents’ perspectives 

cannot be generalized to their entire components or to all federal law 

enforcement components. Nevertheless, their views provided valuable 

insights into the challenges they face on the job.

To identify the training, policies, and guidance in place, we reviewed 

documents from each of our selected law enforcement components, 

when available, and conducted interviews with officials at the selected 

components responsible for the development or delivery of training or 

policies. We also reviewed fiscal year 2018 budget justifications for each 

of our selected components to identify changes in staffing levels or 

training plans that may be related to officers’ and agents’ response to 

incidents involving individuals with mental illness. In addition, since 

section 504 of the Rehabilitation Act of 1973, as amended (section 504) 

prohibits discrimination on the basis of disability, which includes mental 
Page 5 GAO-18-229 Federal Law Enforcement

illness, in federally funded and federally conducted programs and 

activities,6 we took steps to understand the section’s applicability to 

federal law enforcement operations.7 Specifically, we reviewed 

departmental guidance related to section 504 and reviewed the selected 

components’ documentation of efforts to review their training, policies, 

and procedures in accordance with that guidance. We also interviewed 

department and component officials familiar with the review efforts.

To identify leading practices stakeholders cited for effective law 

enforcement responses to incidents involving individuals with mental 

illness, we used a multi-stage process. We first conducted a search of 

databases and organizational websites to identify published work related 

to law enforcement responses to individuals with mental illness that had 

been published on or after January 1, 2007. We then narrowed our 

search and reviewed only literature review articles, meta-analyses, and 

summary papers published by academics, think tanks and advocacy 

groups, or government agencies to identify any potential leading 

practices.8 Through our review, we identified two potentially leading 

practices in the field of law enforcement responses to incidents involving 

individuals with mental illness.

Next, we identified potential stakeholders through a search of literature 

review articles, meta-analyses, and organizational websites related to law 

enforcement responses to incidents involving individuals with mental 

illness. Through our review of these documents and websites, we 

selected six stakeholders in the field of law enforcement-mental health to 

 6

29 U.S.C. § 794. A person with a disability includes anyone who has a physical or mental 

impairment that substantially limits one or more major life activities, has a record of such 

impairment, or is regarded as having such an impairment. The definition of disability for 

purposes of § 504 of the Rehabilitation Act is derived from the Americans with Disabilities 

Act. 29 U.S.C. § 705(9); 42 U.S.C. § 12102.

7

Regulations and guidance issued by both DOJ and DHS provide that section 504 

generally applies to all programs and activities of each department. For example, DOJ 

guidance states that DOJ’s obligations under section 504 and implementing regulations 

“apply to all members of the public with disabilities whom the Department serves or 

encounters as part of the Department’s traditional law enforcement programs and 

activities.” However, according to this same guidance, “[e]xigencies, dangers, and safety 

considerations, however, play a significant role in determining whether and to what extent 

an accommodation [for a member of the public with a disability] is reasonable.”

8

By using the term “leading practices,” we refer to practices that are generally effective 

when officers or agents apply them when responding to incidents involving individuals with 

mental illness even if robust evaluations of such practices’ effectiveness have not been 

conducted or have shown mixed results.
Page 6 GAO-18-229 Federal Law Enforcement

solicit their opinions on leading practices. These stakeholders consisted 

of four organizations and two independent researchers who have either 

published research or implemented programs, among other criteria, 

related to law enforcement responses to incidents involving individuals 

with mental illness. Specifically, we asked stakeholders to validate that 

the two practices that we had initially identified were in fact leading 

practices, and to provide any additional leading practices.9

To determine if DOJ and DHS components leverage information from 

other knowledgeable parties, we conducted interviews with or gathered 

written information from agency officials from the selected components 

who are responsible for training and policy development. Further details 

about our scope and methodology can be found in Appendix I.

We conducted this performance audit from February 2017 through 

February 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform an 

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.

Since the 1960s, the percentage of individuals with mental illness being 

treated in a hospitalized setting has decreased dramatically in an effort to 

move care away from institutional settings into a wider range of 

community-based treatment. This process, known as 

“deinstitutionalization,” has been driven in part by limited funding available 

for mental health services, changes in treatment philosophy, and medical 

advancements. According to a 2015 Federal Bureau of Investigation (FBI) 

publication, one result from this shift is that local police departments have 

had to meet the growing needs of individuals suffering mental health 

emergencies (e.g., a schizophrenic episode), and are often the first 

 9

For the purposes of our report, stakeholders are either academic or independent 

researchers or advocacy groups who are known to have substantial knowledge or 

expertise in the area of law enforcement responses to incidents involving individuals with 

mental illness.

Background

Law Enforcement 

Interaction with Individuals 

with Mental Illness
Page 7 GAO-18-229 Federal Law Enforcement

source of assistance in helping to arrange treatment for these 

individuals.10

Similarly, the IACP reports that police officers often have to “manage 

situations that result from a history of mental health policy and legislative 

decisions made by federal and state governments.”11 According to the 

IACP, law enforcement officers—generally local police—may then find 

themselves serving in a role similar to that of a social worker in attempting 

to locate treatment services for such individuals. The IACP also reports 

that such increasing interactions may result in individuals with mental 

illness being arrested and placed in jail, rather than receiving treatment 

from mental health facilities. This can result in a cycle of arrest, 

imprisonment, and recidivism for such individuals.12 In addition, 

interactions between law enforcement officers and individuals with mental 

illness have the potential to escalate into violence.

In recent years, a number of professional organizations and advocacy 

groups such as IACP, the Police Executive Research Forum (PERF), the 

National Alliance on Mental Illness, and Council of State Governments 

Justice Center (CSG JC) have researched and advocated for different 

approaches that may reduce the likelihood of violent encounters or help 

officers connect the individuals they encounter with proper treatment 

services.13 In addition, DOJ’s Bureau of Justice Assistance (BJA), within 

its Office of Justice Programs, has created a compendium of existing 

 10Wilcox, Nicolas, M.S., “The Importance of Mental Health Training in Law Enforcement”, 

FBI Law Enforcement Bulletin, July 8, 2015.

11IACP, Improving Police Response to Persons Affected by Mental Illness, Report from

the March 2016 IACP Symposium, Alexandria, Virginia (2016).

12We have related work reviewing the incarceration of offenders with mental illness and 

strategies for reducing recidivism among such offenders that will be issued in early 2018.

21st Century Cures Act, Pub. L. No. 114-255, § 14016, 130 Stat. at 1306-07.

13PERF is an independent research organization that seeks to identify best practices on 

issues such as reducing police use of force; developing community and problem-oriented 

policing; and evaluating crime reduction strategies. CSG JC is a national nonprofit 

organization that serves policymakers at the local, state, and federal levels from all 

branches of government. It aims to provide practical, nonpartisan advice and consensusdriven strategies, informed by available evidence, to increase public safety and strengthen 

communities.
Page 8 GAO-18-229 Federal Law Enforcement

information and research in the field of state and local law enforcement 

responses to individuals with mental illness.14

Federal law enforcement officers and agents may interact with individuals 

displaying signs of mental illness in a number of different types of 

incidents while performing their various missions, such as protecting 

federal property or officials or when apprehending subjects of an 

investigation. Figure 1 provides one example of a possible incident an 

officer or agent might experience and the response options available. 

Generally, when federal officers and agents encounter individuals 

displaying signs of mental illness—and there is no evidence of a federal 

crime—they may refer them to local law enforcement or health care 

providers to assess their mental health and determine whether they need 

further health care.15 If local providers determine that such care is 

needed, it is generally provided through a voluntary or involuntary 

commitment to a local mental health services provider. One exception to 

this is for correctional officers and other staff within BOP, as these staff 

interact with individuals with a diagnosed mental illness as part of their 

daily duties in ensuring a secure prison environment.16 BOP predesignates all inmates entering its institutions and assigns initial mental 

 14BJA aims to provide leadership and services in grant administration and criminal justice 

policy development to support local, state, and tribal justice strategies to achieve safer 

communities. BJA supports programs and initiatives in the areas of law enforcement, 

justice information sharing, managing offenders, combating drug crime and abuse, crime 

prevention, and protecting vulnerable populations, among other things.

15The nature of these interactions by federal law enforcement officers and agents may 

vary greatly depending on the nature of each component’s mission. For example, 

according to FBI officials, FBI Special Agents apprehending a subject displaying signs of 

mental illness do not refer that individual to local law enforcement or health care providers, 

but would carry out the arrest warrant or arrest on probable cause.

16By statute, BOP is required to provide for suitable housing and the safekeeping, care, 

and subsistence of all persons charged with or convicted of offenses against the United 

States. See 18 U.S.C. § 4042(a)(2).
Page 9 GAO-18-229 Federal Law Enforcement

health and medical screen assignments.17 Throughout an inmate’s 

incarceration, BOP’s psychologists, psychiatrists, and qualified mid-level 

practitioners can determine a new mental health care level following a 

review of records and a face-to-face clinical interview.

 17After inmates enter an institution, and within timeframes dependent upon the mental 

health screen assignment, BOP completes a psychology intake screening and assigns 

inmates a mental health care level ranging from 1 to 4, depending on the inmates’ level of 

mental health care needs. Mental health care level 1 inmates show no significant level of 

functional impairment associated with mental illness and demonstrate no need for regular 

mental health interventions, while mental health care level 4 inmates are those requiring 

acute care in a psychiatric hospital. We have previously reported on mental health care 

and general medical care in BOP. See GAO, Bureau of Prisons: Timelier Reviews, Plans 

for Evaluations, and Updated Policies Could Improve Inmate Mental Health Services 

Oversight, GAO-13-1 (Washington, D.C.: July 17, 2013), and Bureau of Prisons: Better 

Planning and Evaluation Needed to Understand and Control Rising Inmate Health Care 

Costs, GAO-17-379 (Washington, D.C.: June 29, 2017).
Page 10 GAO-18-229 Federal Law Enforcement

Figure 1: Illustrative Example of an Incident at a Federal Facility Involving Federal 

Law Enforcement and an Individual Displaying Signs of a Mental Illness

Note: The figure above is a general illustration of how a federal law enforcement officer or agent 

might respond to and resolve a disturbance at or near a federal facility. It is not intended to address a 

“typical” incident for any of the components in our review because the missions and activities of each 

component vary significantly and officers and agents interact with the public in different capacities. 

For example, Federal Protective Service or Secret Service officers and agents might be more likely to 

experience this type of incident when protecting federal facilities than Bureau of Prisons correctional 

officers operating within prisons or than Federal Bureau of Investigations agents conducting 

investigations would be.
Page 11 GAO-18-229 Federal Law Enforcement

Under section 504 of the Rehabilitation Act of 1973, as amended, 

discrimination on the basis of disability in federally funded and federally 

conducted programs and activities is prohibited.18 A person with a 

disability includes anyone who has a physical or mental impairment that 

substantially limits one or more major life activities, has a record of such 

impairment, or is regarded as having such an impairment.

DHS and DOJ both currently have efforts underway, in various stages of 

development, to have their components review their existing policies, 

guidance, and training in response to departmental guidance on 

addressing individuals with disabilities and obligations under section 504. 

Pursuant to departmental guidance, after completing their reviews, 

components are to determine areas that could be enhanced. Within DHS, 

components have been asked to report on the status of their efforts to 

DHS’ Office for Civil Rights and Civil Liberties (CRCL).19 Within DOJ, the 

Office of the Deputy Attorney General (ODAG) is overseeing components’

efforts.20

In addition, the 21st Century Cures Act requires the Attorney General to 

provide direction and guidance for the following by December 13, 2017:

• “Programs that offer specialized and comprehensive training, in 

procedures to identify and appropriately respond to incidents in which 

the unique needs of individuals who have a mental illness are 

involved, to first responders and tactical units of—(A) Federal law 

enforcement agencies; and (B) other Federal criminal justice 

agencies, such as [BOP] and the Administrative Office of the United 

States Courts, and other agencies that the Attorney General 

determines appropriate.”

• “The establishment of, or improvement of existing, computerized 

information systems to provide timely information to employees of 

Federal law enforcement agencies, and Federal criminal justice 

 1829 U.S.C. § 794. “Federally conducted programs and activities” include those of federal 

law enforcement agencies. 

19DHS CRCL promotes civil rights and civil liberties in policy creation and implementation 

by advising DHS leadership and personnel, communicates with individuals and 

communities whose civil rights and civil liberties may be affected by DHS activities, and 

leads DHS equal employment opportunity programs, among other things.

20DOJ ODAG advises and assists the Attorney General in formulating and implementing 

DOJ policies and programs and in providing supervision and direction to all organizational 

units of DOJ.

Relevant Legislation and 

Departmental Efforts
Page 12 GAO-18-229 Federal Law Enforcement

agencies to improve the response of such employees to situations

involving individuals who have a mental illness.” 21

According to the DHS and DOJ law enforcement officers and agents we 

interviewed, they are not positioned to diagnose any specific mental 

health condition that an individual might have, as they are not trained 

mental health professionals.22 However, responding to incidents involving 

individuals with mental illness can be challenging for multiple reasons, 

including determining whether the person is suffering from a mental 

illness or from another issue, such as drug addiction, and communicating 

with the person, for example, when a person may be suffering from 

delusions. These officers and agents face these challenges while also 

being responsible for ensuring their own safety and that of others in the 

area. Some of the common challenges officers and agents identified 

during our discussion groups follow.

Identifying Whether an Individual Has a Mental Illness

Some officers and agents in our group discussions stated that when 

encountering individuals displaying erratic behavior (e.g., rapid or 

nonsensical speech, paranoid or delusional statements), it can be difficult 

to determine if that behavior is attributable to a mental illness or the 

influence of drugs. Specifically, Border Patrol agents—who are broadly 

responsible for preventing the illegal entry or exit of people and goods at 

places other than ports of entry—stated that determining whether 

someone has a mental illness or is experiencing other issues is 

challenging and may be complicated by language barriers. Border Patrol 

agents may at times encounter large groups of people attempting to cross 

the border at one time and thus have limited time to make that 

determination. ATF officers—who may encounter individuals with a 

mental illness who are targets of an investigation—commented that 

incidents may involve an individual who could suffer a mental illness 

(treated or untreated), or be under the influence of alcohol or drugs.

Unless the individual discloses his or her condition, or family or friends 

are there to explain the condition, officers would not know the cause of 

 21Pub. L. No. 114-255, § 14025, 130 Stat. at 1310.

22BOP employs mental health professionals such as psychologists or psychiatrists at each 

of its institutions. These staff are trained to diagnose mental illness and share their 

assessments with correctional officers and other staff. In addition, each institution has 

medical and mental health profiles of each inmate in its care.

Discussion Groups 

Identified Several 

Challenges that 

Officers and Agents 

Encounter When 

Responding to 

Incidents Involving 

Individuals with 

Mental Illness
Page 13 GAO-18-229 Federal Law Enforcement

the individual’s behavior. They explained that if mental health information 

about a suspect is known in advance of an operation, officers can adjust 

their approach; however, they told us that most of the time they do not 

know if someone has a mental health condition and how it might present 

itself.

Similarly, an FBI police officer—who may encounter individuals displaying 

signs of mental illness if those individuals enter an FBI office—told us that 

it can be challenging to deal with an individual who is acting erratically, 

not knowing precisely whether the behavior is attributable to a mental 

illness, and there may be limited time available to address an individual 

posing a safety risk. BOP corrections officers also echoed this challenge. 

They said that despite having back-up mental health staff on call, their 

initial reaction to an inmate exhibiting some type of erratic behavior has to 

be fairly quick to secure the safety of the staff and other inmates. Officers 

and agents across components and departments made clear that they 

are not mental health professionals or psychologists and, as such, are 

charged with responding to the behaviors that are exhibited to secure the 

scene.

Communicating with Individuals with a Mental Illness

Some of the officers and agents in our discussion groups stated that 

communicating effectively with someone exhibiting signs of a mental 

illness and understanding what he or she may be going through or how 

he or she sees reality can be challenging. One officer told us that trying to 

make individuals who may have a mental illness understand that their 

reality is not everyone else’s reality is particularly challenging. This was 

very difficult, for example, for Secret Service Uniformed Division officers 

who explained that they encounter individuals when providing security 

along the White House fence and for FPS officers, who often encounter 

individuals displaying signs of mental illness near or in federal buildings 

that they are assigned to protect. As the Secret Service officers 

explained, even if individuals exhibit delusional behavior, so long as they 

have not broken any laws, then they are free to be near protected federal 

venues and the officers are limited in any actions they can take. 

Officers and agents who we met with in CBP reported that they rely on 

common sense to dictate appropriate action and use reasonable efforts to 

protect themselves and others. They noted that additional training on 

communicating effectively with individuals suffering from mental illness 

could be beneficial.

One officer, discussing the challenges in 

speaking with someone with a mental illness 

who may be experiencing delusions, stated 

that the person is “wholeheartedly convinced 

that what he or she perceives is the true 

reality.”

Source: GAO observation. | GAO-18-229
Page 14 GAO-18-229 Federal Law Enforcement

The challenges noted above in identifying causes of erratic behavior or 

effectively communicating with individuals with a mental illness can make 

it difficult for officers to resolve a tense situation or apprehend an 

individual (if necessary) as securely or peacefully as possible. For 

example, Border Patrol agents stated that ensuring that such encounters 

are resolved safely for the individuals involved and other members of the 

public is their biggest challenge. It might require removing someone in 

distress from a group of individuals that he or she may be traveling with or 

keeping him or her calm. When someone is in an extreme state of panic, 

emotional distress, or anger, officers try to remove the person from the 

group to prevent a potential incident from escalating quickly. 

Operating with Limited Access to Mental Health Resources

Officers and agents also stated that a limited number of mental health 

professionals available within their components or through local agencies 

can pose a challenge in helping persons with mental illness receive 

necessary treatment. As such, they must rely on state and local entities in 

the area (e.g., law enforcement, hospitals) to provide assistance for 

individuals. Federal Air Marshals—who provide protection at airports and 

other transportation modes—we spoke with explained that since they do 

not have holding facilities to secure individuals with mental illness, they 

are reliant on local law enforcement and mental health professionals to 

manage an incident.23 Officers and agents highlighted the importance of 

maintaining close relationships with state and local partners and added 

that trained mental health professionals provide an excellent resource.

In addition, officers and agents in some discussion groups noted there 

may be training offered by state or local agencies related to 

understanding and responding to individuals with mental illness that could 

be leveraged by federal agencies.24 Officers and agents reported, 

however, that it can be difficult for the components to find the time and 

 23The Federal Air Marshals instructors with whom we met largely train Visible Intermodal 

Prevention and Response teams that consist of Federal Air Marshals, Behavioral 

Detection Officers, Transportation Security Specialists-Explosives, Transportation Security 

Inspectors, and Canine teams who work closely with federal, state, and local law 

enforcement partners and stakeholders in the aviation and surface transportation sectors.

24Training courses that focus on mental health awareness offered by other entities, such 

as state and local law enforcement agencies, may be available to federal officers and 

agents. Generally, federal officers and agents are made aware of internal and external 

training opportunities through their internal component learning systems and email 

notifications.
Page 15 GAO-18-229 Federal Law Enforcement

resources to send officers to the trainings. According to USMS officers—

who provide security at federal courthouses and oversee transport of 

federal prisoners—this is particularly challenging in small offices where 

there may be very few staff.

Frequently Encountering the Same Individuals

Another common challenge noted in discussion groups was that officers 

and agents repeatedly encounter the same individuals with mental illness. 

Officers and agents explained that they can sometimes apprehend 

individuals who are creating a disturbance, but these individuals often 

cannot be charged with a federal crime. As such, following the 

apprehension, the officers and agents release these individuals to local or 

state authorities who may transport them to local providers for a mental 

health evaluation. Typically, if the local providers determine a 

commitment is necessary, they will hold these individuals at a hospital or 

clinic for up to 72 hours. According to the officers and agents in our 

discussion groups, many of these individuals return after they are 

released and the officers and agents encounter them time and again, with 

very little that they can do to provide these individuals with assistance. 

According to the officers and agents, incidents involving frequent 

encounters with the same individuals can take time away from performing 

other important activities.

Secret Service Uniformed Division officers told us they repeatedly 

encounter the same individuals with mental illness and know some of 

these individuals very well. For example, Secret Service officers stated 

that when performing their duties in patrolling the grounds of the White 

House, they have had frequent encounters with a woman who believes 

she has family members living in the White House. The officers have 

turned her away from the scene on multiple occasions, but she continues 

to return.
Page 16 GAO-18-229 Federal Law Enforcement

All of the law enforcement components in our scope offer training directly, 

receive training through FLETC, or are developing some training on 

responding to incidents involving individuals with mental illness. Agency 

and FLETC training includes courses on communication, de-escalation, 

and suicide prevention (related to federal inmates). Since these 

components have varying missions and operational needs and interact 

with the public in different capacities, the nature and scope of this 

training, as well as the number of courses and the duration of courses 

offered varies. For example, BOP’s staff—including food service workers 

and nurses, as well as correctional officers—have daily contact with 

inmates with mental illness and can act as “first responders” when 

situations merit. According to BOP officials, training is offered to all staff in 

all of its institutions on mental health and working with the mentally ill, 

along with courses on communication, de-escalation, suicide prevention, 

and use of force. As another example, ATF’s agents told us they have 

less routine contact with individuals with mental illness, but ATF offers a 

course to its agents on de-escalation concepts and tactics, which 

addresses responding to incidents involving individuals with mental 

illness, as well as crisis intervention training to its cadre of crisis 

negotiators. Further, some of the components’ training is mandatory and 

offered annually through class instruction or online portals. These courses 

may be offered to new hires or available to tenured officers. In addition, 

some components’ training courses are delivered as stand-alone 

sessions, while others may be modules within a larger course exploring 

other law enforcement topics.

Training DHS Components Offer

Three DHS operational components in our scope, in addition to FLETC, 

offered some type of training specifically for their officers and agents. 

Components Have 

Some Type of 

Training, Policies, and 

Guidance Related to 

Mental Illness, and 

Reviews to Enhance 

Practices are 

Underway

DHS and DOJ 

Components Offer, 

Receive, or Are 

Developing Some Type of 

Training Related to Mental 

Illness
Page 17 GAO-18-229 Federal Law Enforcement

Another one (TSA) has training in development as of October 2017, on 

topics related to responding to incidents involving individuals with mental 

illness.

FLETC explained that it provides basic training to all DHS law 

enforcement officers through one of three basic program categories—

Center Basic, Center Integrated Basic, and Agency Specific Basic—which 

vary in length.25 Two Center Basic training programs include a 2-hour 

module titled Managing Abnormal Behavior, which covers how to identify 

common signs of mental disorders (among other things) and how to 

handle people exhibiting abnormal behavior. Specifically, this module 

examines basic human behavior that may be classified as abnormal, 

differentiates between mental disorders, and also covers physical and 

organic causes that may be related to abnormal behavior with the 

appropriate officer responses. In addition, FLETC informed us that it has 

developed scenario-based training in these programs, allowing the 

officers or agents to develop decision-making skills in situations involving 

people exhibiting abnormal behavior. See appendix II for more 

information on FLETC’s training programs.

In addition to this module provided to all DHS agents and officers, the 

components in our review also offer or are preparing component-specific 

training courses. Table 2 lists illustrative examples of DHS training.

 25According to DHS officials, one exception would be for training provided to Border Patrol 

agents. While this training takes place at FLETC venues, according to CBP, the Border 

Patrol itself conducts nearly all of the training provided to its agents.

U.S. Secret Service Training

We observed Secret Service training on 

Protective Intelligence Questioning for First 

Line Officers, which is offered to Uniformed 

Division Officers. The course instructor played 

the role of three different individuals with 

schizophrenia, bipolar disorder, and 

sociopathic personality disorder and trained 

agents on interacting and interviewing 

subjects who attempt to breach the White 

House fence.

Source: GAO observation. | GAO-18-229
Page 18 GAO-18-229 Federal Law Enforcement

Table 2: Examples of Department of Homeland Security (DHS) Operational Components’ Training Content Related to Officers’

Response to Incidents Involving Individuals with Mental Illness, as of October 2017

DHS component Name of course Officers taking course General description Format / duration

Federal 

Protective 

Service (FPS)a

Mentally Ill Persons Law Enforcement Officers Covers characteristics of mental illness, 

emotionally disturbed persons (EDP), and 

excited delirium syndrome;b how to 

manage EDPs; steps needed for subjects 

to be committed voluntarily or involuntarily 

for a mental health evaluation; and 

becoming familiar with various cases 

regarding EDPs.

Class/1 hour

U.S. Customs 

and Border 

Protection (CBP)

Detecting Excited 

Delirium Syndrome

Customs and Border 

Protection Agents and 

Officers

Covers how to identify excited delirium 

syndrome and the implications for a 

sudden in-custody death.

Online/1 hour

U. S. Secret 

Service (Secret 

Service)

Protective 

Intelligence 

Questioning for 

First Line Officers

Uniformed Division Provides approaches and strategies to use 

when interviewing subjects who may be 

mentally ill, including symptoms that may 

be commonly exhibited, and how to obtain 

useful and actionable information. This is 

followed up with a practical exercise in 

which officers conduct three separate 

interviews of role players who act as if they 

are suffering from schizophrenia, bipolar 

disorder, and paranoid personality disorder 

respectively.

Class/5 hours

Source: GAO analysis of documentation provided by components | GAO-18-229

Note: Officials reported that in addition to the training courses above, some components, such as 

CBP, have officers who are also trained as emergency medical technicians. Part of basic emergency 

medical technician training addresses how to respond to individuals who may be displaying signs of 

mental illness. Also, U.S. Immigration and Customs Enforcement, which does not provide mental 

health training generally to all of its agents or officers, employs health services medics who screen 

apprehended individuals for medical conditions to include mental illness and provides those health 

services medics with suicide prevention training.

a

In addition, FPS officials informed us that they are developing further training on familiarizing officers 

with local resources available and anticipate offering this training beginning in March 2018.

b

Excited delirium syndrome is a set of symptoms such as disorientation, violent or bizarre behavior, 

insensitivity to pain, elevated body temperature, or superhuman strength that results in a temporary 

state of wild excitement or mental confusion.

In addition, TSA has developed a mandatory course entitled Awareness 

Training on Mental Health Conditions to be delivered in the classroom 

and through scenarios and exercises during fiscal year 2018. This course 

is designed to introduce Federal Air Marshals to the fundamentals of 

predominant mental disorders, such as schizophrenia or psychosis.
Page 19 GAO-18-229 Federal Law Enforcement

Training DOJ Components Offer

All of the DOJ components in our review provide some type of training to 

their officers on topics related to responding to incidents involving 

individuals with mental illness—as illustrated in Table 3.

Table 3: Examples of Department of Justice (DOJ) Components’ Training Content Related to Officers’ Response to Incidents 

Involving Individuals with Mental Illness, as of October 2017

Source: GAO analysis of documentation provided by components | GAO-18-229

a

This course is currently offered at only one FBI field office; FBI has no component-wide training 

specific to mental illness.

b

Protective Intelligence Investigators are Senior Criminal Investigators who conduct protective 

investigations to identify and mitigate potential threats to USMS protectees. District Threat 

Investigators are Deputy U.S. Marshals who, as a collateral duty, identify security threats or incidents 

and assist Protective Intelligence Investigators with developing a strategy to mitigate the threat. 

DOJ components Name of course Officers taking 

course

General description Format / 

duration

Alcohol, Tobacco, 

Firearms and 

Explosives (ATF)

Understanding DeEscalation Concepts and 

Tactics

Agents Addresses the importance and 

process of de-escalation, 

communication, and use of force and 

response to resistance, including 

practical exercise scenarios and 

video demonstrations.

Class/8 hours

Drug Enforcement 

Administration (DEA)

Use of Force Agents Covers one scenario based on a 

court case pertaining to the 

reasonableness of the use of force 

during a situation involving a 

mentally ill suspect.

Class/20 

minutes

Federal Bureau of 

Prisons (BOP)

Mental Health Annual 

Training

All Staff Covers stigma associated with 

mental illness, characteristics and 

symptoms of serious mental illness, 

and inmates who have been 

diagnosed with a mental 

illness/disorder.

Class/1 hour

Federal Bureau of 

Investigation (FBI)

Mental Health First Aid for 

Public Safety Officersa Agents Covers abnormal behavior, communication, intellectual and 

developmental disabilities, deescalation, mental health awareness, 

suicide prevention, trauma crisis 

response, use of force, and practical 

exercises and simulations.

Virtual/8 hours

U.S. Marshals Service 

(USMS)

Mental Illness and Human 

Behavior

Protective Intelligence

Investigators, District 

Threat Investigatorsb

Covers mental illness and abnormal 

behavior; cause of serious mental 

illness; mental health statistics; 

stress; common mental, mood, 

anxiety, and personality disorders; 

post-traumatic stress disorder 

(PTSD); and substance abuse.

Class/2 hours
Page 20 GAO-18-229 Federal Law Enforcement

The law enforcement components within our scope at DHS and DOJ 

have policies or guidance in place that addresses responding to incidents 

involving individuals with mental illness. Some components’ policies or 

guidance specifically addresses mental illness, while others touch on the 

issue as part of larger policies on other topics (such as use of force)—as 

illustrated in Table 4.

Table 4: Examples of Policies and Guidance at Departments of Homeland Security (DHS) and Justice (DOJ) Components 

Related to Officers’ Response to Incidents Involving Individuals with Mental Illness, as of October 2017

Policy/Guidance Name General Description

DHS component

Federal Protective Service 

(FPS)

Incidents Involving Mentally

Ill Persons 

This policy provides official guidance on responding to incidents involving 

individuals with mental illness. It covers communication, use-of-force, 

interviews, excited delirium syndrome,a voluntary and involuntary mental 

health evaluations, as well as suicide prevention.

Transportation Security 

Administration (TSA) 

Access and Communication 

for Individuals with 

Disabilities

This guidance is designed to help ensure that interactions with the public 

are accessible to individuals with a disability, which includes mental 

illness.

U.S. Customs and Border 

Protection (CBP)

National Standards on 

Transport, Escort, Detention, 

and Search

Prior to transporting or escorting an individual, officers and agents are to 

conduct an assessment of the individual’s safety and known or reported 

medical or mental health issues, among other things, and provide 

reasonable accommodations for such issues.

U.S. Immigration and 

Customs Enforcement 

(ICE), Enforcement and 

Removal Operations

Identification of Detainees 

with Serious Mental 

Disorders or Conditions

This policy memo assists ICE and detention facility personnel in 

identifying detainees with serious mental disorders or conditions in order 

to assess appropriate facility placement and treatment.

U. S. Secret Service 

(Secret Service)

Use of Force Policy This policy mentions that officers and agents may take into account the 

mental health history of the subjects to determine a reasonable level of 

force necessary to control them. 

DOJ Components 

Alcohol, Tobacco, Firearms 

and Explosives (ATF)

Memo on Resources for 

Dealing with Persons in 

Crisis

Instructs all special agents in charge to identify and be familiar with local 

resources (e.g., crisis intervention teams)b that can provide assistance 

when they encounter a member of the public who may suffer from mental 

illness or may be in crisis. 

Federal Bureau of Prisons 

(BOP)

Suicide Prevention Program 

Statement

One of several policies in place that addresses interaction with inmates 

with a mental illness, this policy directs each prison warden to implement 

a prison-specific suicide prevention program detailing what the program 

must contain, including but not limited to, training for all staff on suicide 

prevention, suicide risk assessments, suicide watch procedures, and 

identification of at-risk inmates.

DHS and DOJ 

Components Have 

Existing Policies or 

Guidance That Addresses 

Responding to Individuals 

with Mental Illness
Page 21 GAO-18-229 Federal Law Enforcement

Policy/Guidance Name General Description

Federal Bureau of 

Investigation (FBI)

FBI Police Manual for Police 

Operations, Section 31-

Unsolicited Contact/Mentally 

Ill

Provides general safety and communication guidelines for FBI police 

officers when responding to an incident involving individuals with mental 

illness.

Drug Enforcement 

Administration (DEA)

Use of Force, Section S. 

Deadly Force Against 

Mentally Ill Subject

Provides federal case law regarding police conduct in responding to 

individuals with a mental illness, particularly use of deadly force.

U.S. Marshals Service 

(USMS)

Procedures for Movement of 

Prisoners w/ Psychological 

or Medical Conditions

Includes a medical guide that the transportation specialist, Justice 

Prisoner and Alien Transportation System staff,c or Public Health Services 

nurse can use to determine the proper mode of transportation, 

coordination with the holdover facility, and the provision of medicines, if 

applicable, to detainees or prisoners during transport.

Source: GAO analysis of documentation provided by components | GAO-18-229

a

Excited delirium syndrome is a physiological and mental state often characterized by extreme 

physical and mental agitation, bizarre behavior, hyperthermia, hostility, exceptional strength, and 

endurance without apparent fatigue.

b

Crisis intervention teams are used in community policing efforts and bring together law enforcement, 

mental health providers, hospital emergency departments and individuals with mental illness and their 

families to improve responses to people in crisis.

c

USMS’s Justice Prisoner and Alien Transportation System transports prisoners in federal custody 

between federal judicial districts to hearings, court appearances and detention facilities. USMS 

houses and transports all federal prisoners from the time they enter federal custody until they are 

either acquitted or convicted and delivered to their designated federal Bureau of Prisons facility.

DHS Efforts to Review Policies, Guidance, and Training

DHS has guidance in place to help ensure that its components have 

policies and training that ensure their alignment with section 504 of the 

Rehabilitation Act. In 2013 and 2015, respectively, DHS issued a 

directive26 and implementing instruction27 to its components intended to 

strengthen compliance with section 504. These documents required DHS 

components to conduct a self-evaluation and prepare a component plan 

identifying any policies or practices that may result in a qualified individual 

with a disability being excluded from participation in, or being denied the 

benefits of, a program or activity.

 26DHS, Nondiscrimination for Individuals with Disabilities in DHS-Conducted Programs 

and Activities (Non-Employment), DHS Directive Number 065-01, September 25, 2013.

27DHS, Instruction on Nondiscrimination for Individuals with Disabilities in DHS-Conducted 

Programs and Activities (Non-Employment), DHS Directive Number 065-01-001, March 

13, 2015.

All DHS and DOJ 

Components Are 

Reviewing Policies, 

Guidance, and Training to 

Align with Departmental 

Guidance
Page 22 GAO-18-229 Federal Law Enforcement

In 2016, DHS’s CRCL office issued guidance and a self-evaluation tool to 

DHS components on the steps to take in performing the self-evaluation of 

their facilities, programs, policies, and practices (to include training). The 

guidance also addresses the development and execution of the 

components’ plans intended to remedy any areas deemed insufficient in 

permitting individuals with disabilities—including mental illness—to 

participate fully in the components’ programs and activities.28

Disability Access Coordinators, who are representatives from each 

component charged with overseeing their components’ responses to DHS 

Rehabilitation Act guidance, are leading the components’ efforts in 

conducting the self-evaluations. CRCL set a deadline for components to 

submit all self-evaluations to CRCL for review by the end of August 2017. 

As of September 2017, all five components had submitted selfevaluations.29 CRCL officials explained that as they review selfevaluations, they are looking to see if policies or training for law 

enforcement officers’ and agents’ responses to individuals with mental 

illness have been identified or otherwise addressed. If not, the officials 

indicated that they will request the components identify and address this 

topic in their plans for aligning with Rehabilitation Act guidance. The 

remaining steps in CRCL’s effort to review and comment on component 

plans as of September follow:

• December 31, 2017: CRCL provides comments to components on the 

content of their self-evaluations.

• February 28, 2018: the components develop and submit their draft 

plans for aligning with the Rehabilitation Act guidance.

• April 30, 2018: CRCL reviews and provides comments on the 

components’ draft plans.

• May 31, 2018: the components address CRCL’s comments and 

submit their final plans for alignment with Rehabilitation Act guidance 

for approval.

 28DHS Office for Civil Rights and Civil Liberties, Component Self-Evaluation and Planning 

Reference Guide, Guide 065-01-001-01, June 6, 2016.

29FPS’s efforts were included in the submission of the plan for the National Protection and 

Programs Directorate, which houses FPS.

Department of Homeland Security (DHS) 

Component Self-Evaluation Tool

The self-evaluation tool that DHS’s Office of 

Civil Rights and Civil Liberties developed 

requires components to—among other 

things—describe whether there is an 

established policy ensuring equal treatment 

for individuals with disabilities, how the 

component’s personnel and procedures 

ensure that individuals with disabilities are 

treated in a nondiscriminatory manner, and 

the component’s process for providing 

auxiliary aids and services to ensure effective 

communication. The tool also provides 

examples of interactions in the areas of 

customer service, security, and custody 

activities that would likely be compliant, or 

possibly noncompliant, with section 504 of the 

Rehabilitation Act.

Source: DHS. | GAO-18-229
Page 23 GAO-18-229 Federal Law Enforcement

DOJ Efforts to Review Policies, Guidance, and Training

DOJ has directed components to review and implement guidance on 

addressing individuals with disabilities—including mental illness—and 

obligations under section 504. Specifically, in January 2017, DOJ’s thenDeputy Attorney General issued a memo with attached guidance directing 

components to review their policies and training and, where necessary, 

modify or develop policies and training to implement legal requirements 

and principles related to section 504.30 This guidance identified, among 

other things, DOJ’s law enforcement components’ legal obligations under 

section 504 as well as the policies and procedures that components must 

have so that officers and agents can anticipate and plan for encounters 

with members of the public with disabilities. For example, the guidance 

states that law enforcement components must train officers and agents 

on different types of commonly encountered disabilities; how to identify, 

without medical or psychological training, analysis, or diagnosis, common 

characteristics and behaviors most often associated with disabilities; and 

appropriate responses to the challenges that an encounter with a member 

of the public with a disability may present. Training for officers and agents 

in effective communication with members of the public with a mental 

illness is explicitly referenced in the guidance as well.

To date, officials from DOJ’s Office of the Deputy Attorney General 

(ODAG)—who are overseeing the components’ efforts—have maintained 

communication with the components to confirm that they have begun 

reviewing their policies and training to identify any deficiencies or 

necessary enhancements pursuant to the January 2017 guidance. During 

the course of our review and in part due to our inquiries, in the fall of 

2017, ODAG notified the components that they should complete their 

reviews by December 2017. ODAG also notified the components that 

they should begin implementing any new policies or training identified by 

September 2018.

In addition, a provision of the 21st Century Cures Act—section 14025—

requires DOJ to provide direction and guidance to federal law 

enforcement agencies and federal criminal justice agencies on training 

programs and improved technologies related to responding to individuals 

with mental illness, by December 13, 2017. ODAG officials told us that 

 30DOJ Memorandum from the Deputy Attorney General, “Department Guidance in 

Interactions with Members of the Public with Disabilities in Traditional Law Enforcement 

Programs and Activities,” January 6, 2017. 
Page 24 GAO-18-229 Federal Law Enforcement

the January 2017 guidance addresses the requirement to provide 

direction and guidance on training for the DOJ components, but 

acknowledged that it does not respond to all of the requirements for the 

Attorney General under section 14025 of the 21st Century Cures Act. In 

particular, section 14025 requires the Attorney General to provide 

direction and guidance to federal law enforcement agencies and federal 

criminal justice agencies beyond DOJ in the areas of specialized and 

comprehensive training programs to identify and respond to individuals 

with mental illness. Section 14025 also calls for direction and guidance on 

the establishment and improvement of computerized information systems 

to provide timely information related to situations involving individuals with 

mental illness.

As a result of our questions about whether such efforts would be 

developed, on December 7, 2017, DOJ sent a letter from the Principal 

Deputy Assistant Attorney General for the Office of Justice Programs to 

federal law enforcement partners outlining resources available for federal 

law enforcement when considering training or procedures appropriate for 

their missions. Specifically, DOJ sent the letter to executive officers within 

DOJ, DHS, the Administrative Office of the United States Courts, and 

other executive departments that DOJ deemed appropriate. Some 

examples of resources that the letter highlights include (1) the PoliceMental Health Collaboration Toolkit, which provides resources to assist 

law enforcement agencies in partnering with mental health providers (and 

is discussed later in this report) and (2) a forthcoming “roadmap” planned 

for release in 2018 that the Office of Justice Programs and BJA are 

developing that will help law enforcement agencies as they plan for 

engagement with mental health entities.
Page 25 GAO-18-229 Federal Law Enforcement

Of the six stakeholders in the field of law enforcement-mental health we 

interviewed, all six considered the Crisis Intervention Team Model to be a 

leading practice and five considered the Co-responder Model to be a 

leading practice—see Figure 2. These practices are typically 

implemented at local and state law enforcement agencies. Nevertheless,

certain aspects and associated benefits could be considered in other 

settings, such as federal law enforcement operations.

Stakeholders Cited 

Leading Practices 

and Tools for Effective 

Law Enforcement 

Responses, and 

Components Have 

Generally Leveraged 

Information from 

Other Knowledgeable 

Parties

Two Leading Practices 

and Four Tools Can 

Enhance Officer 

Responses to Individuals 

with Mental Illness
Page 26 GAO-18-229 Federal Law Enforcement

Figure 2: Stakeholder-Cited Leading Practicesa for Effective Law Enforcement Responses to Incidents Involving Individuals 

with Mental Illness

a

For the purposes of our review, a “leading” practice is one that is generally effective when officers 

apply it to their interactions with individuals with mental illness, (for example, it helps the officers deescalate a given situation or better positions them to assist the individuals in receiving care) even if 

robust evaluations of such a practice’s effectiveness have not been conducted or have shown mixed 

results.

b

CSG JC through a cooperative agreement with the BJA, selected six police departments to act as 

national law enforcement-mental health learning sites. Located across the country, these learning 

sites are dedicated to helping other jurisdictions improve their responses to people with mental 

illness.

In addition, stakeholders cited four key tools that may assist law 

enforcement agencies in responding to individuals with mental illness. 

These tools can include training guides, summary reports, or model 

policies, among other things, as shown in table 5.
Page 27 GAO-18-229 Federal Law Enforcement

Table 5: Stakeholder-Cited Tools that May Enhance Law Enforcement Responses to Incidents Involving Individuals with 

Mental Illness

Tools Description

Police Executive Research Forum’s 

(PERF)a Integrating Communications, 

Assessment, and Tactics Training Guide

PERF developed this guide in October 2016 to help officers assess situations, make safe 

and effective decisions, and learn from their actions. The training guide aims to provide 

police officers with additional tools, skills, and options for handling different types of 

critical incidents, especially those that involve subjects who act erratically due to a 

mental illness and who are unarmed or armed with a weapon other than a firearm.

The Bureau of Justice Assistance’s (BJA)b

Police-Mental Health Collaboration Toolkit

BJA developed the toolkit in fiscal year 2017 in partnership with Council of State 

Governments, Justice Center (CSG JC). The toolkit provides resources to assist law 

enforcement agencies in establishing partnerships with mental health providers to 

effectively respond to calls for service and improve outcomes for people with mental 

illness.

Council of State Governments Justice 

Center’s (CSG JC)c reports

These reports, such as Law Enforcement Responses to People with Mental Illnesses: A 

Guide to Research-Informed Policy and Practice (2009)—produced with BJA funding 

and guidance—summarize available research on law enforcement encounters with 

people with mental illness and describe strategies to improve these interactions.

International Association of Chiefs of 

Police’s (IACP)d One Mind Campaign

IACP began this campaign in October 2016 to promote successful interactions between 

police officers and persons affected by mental illness. The campaign highlights four 

practices that IACP has labeled as promising: establishing a partnership with local 

mental health organization(s), developing a model policy, training officers in mental 

health first aid,e and providing crisis intervention team training to 20 percent of an 

agency’s officers.

Source: GAO review of available documents | GAO-18-229

a

PERF is an independent research organization that seeks to identify best practices on issues such 

as reducing police use of force, developing community and problem-oriented policing, and evaluating 

crime reduction strategies.

b

BJA, within the Department of Justice’s Office of Justice Programs, aims to provide leadership and 

services in grant administration and criminal justice policy development to support local, state, and 

tribal justice strategies to achieve safer communities. BJA supports programs and initiatives in the 

areas of law enforcement, justice information sharing, managing offenders, combating drug crime and 

abuse, crime prevention, and protecting vulnerable populations, among other things.

c

CSG JC is a national nonprofit organization that serves policymakers at the local, state, and federal 

levels from all branches of government. It aims to provide practical, nonpartisan advice and 

consensus-driven strategies, informed by available evidence, to increase public safety and strengthen 

communities.

d

IACP is a professional association for law enforcement, representing more than 30,000 members in 

more than 150 countries. IACP aims to advance the law enforcement profession through advocacy, 

outreach, education, and programs.

e

According to IACP, Mental Health First Aid for Public Safety is an eight-hour course focused on 

mental illness and addictions as well as providing law enforcement with effective response options in 

order to de-escalate incidents without compromising safety.
Page 28 GAO-18-229 Federal Law Enforcement

DHS and DOJ law enforcement components generally leveraged 

information from knowledgeable parties within their departments on 

efforts to respond to incidents involving individuals with mental illness. To 

enhance information sharing among DHS components, CRCL has 

implemented an interagency collaboration mechanism.31 Specifically, 

CRCL officials reported that since June 2016 they have led monthly 

coordination conference calls with component Disability Access 

Coordinators to collaborate on their respective efforts to complete their 

self-evaluations. According to the Disability Access Coordinators, these 

sessions have provided a forum to share ideas and lessons learned 

across the DHS components. In addition, according to CRCL officials, 

once their office receives the components’ self-evaluations and plans, it 

aims to disseminate information on lessons learned and effective 

practices to all the components.

Coordination efforts to leverage information also exist within DOJ. 

Specifically, through the efforts to review policies and training under the 

January 2017 guidance and provisions of the 21st Century Cures Act 

discussed earlier, DOJ’s components have reported taking efforts to 

collaborate with one another and share information on training, best 

practices and lessons learned. For example, officials from ATF reported 

holding meetings with other components to discuss their efforts to 

implement the January 2017 guidance.

Additionally, BJA officials told us they took part in the ODAG’s working 

group in early 2016 when the then-Deputy Attorney General’s January 

2017 guidance was in development. Along with BJA, this ODAG working 

group included DOJ’s law enforcement components and other offices 

within the department. The working group provided a forum to advise 

ODAG in developing the January 2017 guidance and discuss issues 

surrounding disabilities, which involved responses to individuals with 

mental illness. BJA officials told us that they provided to components a 

compendium of all its resources available to assist law enforcement’s 

response to incidents involving individuals with mental illness. BJA 

officials said they later took the most promising of these and folded them 

into its Police-Mental Health Collaboration Toolkit. Further, BJA officials 

told us that they make all of the resources it develops, including the 

 31GAO has previously reported on different mechanisms used by federal agencies to 

implement interagency collaborative efforts. See Managing for Results: Key 

Considerations for Implementing Interagency Collaborative Mechanisms, GAO-12-1022 

(Washington, D.C.: September 27, 2012).

Components Have 

Generally Leveraged 

Information from Other 

Knowledgeable Parties, 

and BJA Is Standing Up a 

Training and Technical 

Assistance Center
Page 29 GAO-18-229 Federal Law Enforcement

Toolkit, publicly available on the BJA website. According to the officials, 

these resources are available for all law enforcement agencies, including 

federal entities, to review and consider implementing as they deem 

appropriate.

In addition to these online resources, which facilitate information sharing, 

BJA is also planning to release a national CIT curriculum in 2018 that will 

serve as a resource that can be tailored to reflect mental health training 

and collaboration under development or underway at the local level. The 

Office of Justice Programs is supporting a partnership between the IACP 

and a research organization to deliver the curriculum to law enforcement 

agencies. In addition, BJA—as one of DOJ’s grant-making entities—is 

standing up the National Training and Technical Assistance Center to 

Improve Law Enforcement Responses to Individuals with Mental Health 

Disorders and Intellectual and Developmental Disabilities.32 BJA officials 

reported that in September 2017, BJA selected the awardee to design 

and operate the center. Once the center is operational, it will benefit state, 

local, and tribal law enforcement entities. In addition, BJA envisions that 

the center will facilitate better collaboration between law enforcement 

agencies and their mental health partners. A BJA official also 

acknowledged that the center could serve as an additional resource for 

federal law enforcement agencies to consult as they review their 

trainings, policies, and guidance relevant to responding to incidents 

involving individuals with mental illness.

We provided a draft of this report to DOJ and DHS for their review and 

comment. The departments did not provide us with formal written 

comments, but did provide technical comments, which we incorporated as 

appropriate.

We are also sending this report to the appropriate congressional 

committees and members. In addition, this report is available at no 

charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions, please contact Diana Maurer at 

(202) 512-8777 or maurerd@gao.gov. Contact points for our Offices of 

 32The Consolidated Appropriations Act, 2017, Pub. L. No. 115-31, provided $2,500,000 to 

DOJ/Office of Justice Programs “for a national training initiative to improve police-based 

responses to people with mental illness or developmental disabilities.” 

Agency Comments
Page 30 GAO-18-229 Federal Law Enforcement

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff that made significant contributions to this report 

are listed in appendix III.

Diana Maurer

Director, Homeland Security and Justice Issues
Page 31 GAO-18-229 Federal Law Enforcement

List of Committees

The Honorable Charles E. Grassley

Chairman

The Honorable Dianne Feinstein

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Lamar Alexander

Chairman

The Honorable Patty Murray

Ranking Member

Committee on Health, Education, Labor and Pensions

United States Senate

The Honorable Bob Goodlatte

Chairman

The Honorable Jerrold Nadler

Ranking Member

Committee on the Judiciary

House of Representatives

The Honorable Michael McCaul

Chairman

The Honorable Bennie Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Greg Walden

Chairman

The Honorable Frank Pallone, Jr.

Ranking Member

Committee on Energy and Commerce

House of Representatives
Appendix I: Objectives, Scope and 

Methodology

Page 32 GAO-18-229 Federal Law Enforcement

This report addresses the following key questions: (1) What challenges, if 

any, do federal law enforcement officers at selected Department of 

Homeland Security (DHS) and Department of Justice (DOJ) components 

face when responding to incidents involving individuals with mental 

illness? (2) What type of training, policies, and guidance, if any, are in 

place at selected DHS and DOJ components to prepare federal law 

enforcement officers for responding to incidents involving individuals with 

mental illness? (3) What leading practices or tools have relevant 

stakeholders cited for effective responses to incidents involving 

individuals with mental illness, and how have DHS and DOJ components 

leveraged information from other knowledgeable parties?

We focused our review on the training, policies, and guidance put forth by 

the DHS and DOJ components listed in table 6 below because they 

comprise nearly all of the federal law enforcement officers in these 

agencies.

Table 6: Department of Homeland Security and Department of Justice Federal Law Enforcement Components Selected for 

Review and Their Missions

Component Mission

Department of Homeland Security

Federal Law Enforcement 

Training Centers (FLETC)a Provides career-long training to law enforcement professionals to help them fulfill their responsibilities safely and proficiently. Under a collaborative training model, FLETC’s federal partner 

organizations deliver training unique to their missions, while FLETC provides training in areas 

common to all law enforcement officers, such as firearms, driving, tactics, investigations, and legal 

training.

Federal Protective Service 

(FPS)

Provides integrated security and law enforcement services, such as conducting facility security 

assessments; responding to crimes and other incidents to protect life and property; and detecting, 

investigating, and mitigating threats to more than 9,500 federal facilities nationwide.

Transportation Security 

Administration (TSA)

Protects the nation’s transportation systems to ensure freedom of movement for people and 

commerce. TSA does this by, among other things, deploying Federal Air Marshals on U.S. aircraft 

worldwide. Our review focuses on TSA’s Federal Air Marshals, who are to detect, deter, and defeat 

criminal and terrorist activity targeting transportation systems. 

U.S. Customs and Border 

Protection (CBP)

Protects the borders of the United States from dangerous people and materials, while facilitating 

lawful international travel and trade.

U.S. Immigration and Customs 

Enforcement (ICE)

Protects the United States from cross-border crime and illegal immigration that threaten national 

security and public safety. ICE executes this mission through enforcement of federal statutes and 

focuses on immigration enforcement, preventing terrorism, and combating the illegal movement of 

people and goods. Our review focuses on ICE’s Homeland Security Investigations office, which 

investigates cross-border criminal activity, and Enforcement and Removal Operations, which 

identifies and apprehends removable aliens, detains them when necessary, and removes illegal 

aliens from the United States.

U.S. Secret Service Provides physical protection to the nation’s highest elected leaders, visiting foreign dignitaries, 

facilities and major events, and safeguards the payment and financial systems of the United States 

from a wide range of financial and computer-based crimes. 

Appendix I: Objectives, Scope and 

Methodology
Appendix I: Objectives, Scope and 

Methodology

Page 33 GAO-18-229 Federal Law Enforcement

Component Mission

Department of Justice

Bureau of Alcohol, Tobacco, 

Firearms and Explosives (ATF)

Responsibilities include the investigation and prevention of federal offenses involving the unlawful 

use, manufacture, and possession of firearms and explosives; acts of arson and bombings; and 

illegal trafficking of alcohol and tobacco products.

Federal Bureau of Prisons 

(BOP)

Confines offenders in the controlled environments of prisons and community-based facilities that are 

safe, humane, cost-efficient, and appropriately secure, and that provide work and other selfimprovement opportunities to assist offenders in becoming law-abiding citizens. As part of its duties, 

BOP is responsible for delivering medically necessary health care to inmates in accordance with 

proven standards of care, including medical, dental and mental health.

Federal Bureau of Investigation 

(FBI)

Protects the nation from terrorism, espionage, cyber attacks, and major criminal threats through 

intelligence-gathering and law enforcement responsibilities. Our review focuses on the FBI’s Special 

Agents, who are primarily responsible for executing this mission, as well as FBI Police Officers, who 

provide security at FBI facilities.

U.S. Drug Enforcement 

Administration (DEA)

Enforces the controlled substances laws and regulations of the United States and brings to the 

criminal and civil justice system of the United States, or any other competent jurisdiction, those 

organizations and principal members of organizations involved in the growing, manufacture, or 

distribution of controlled substances appearing in or destined for illicit traffic in the United States.

U.S. Marshals Service (USMS) Provides federal judicial security; apprehends fugitives and non-compliant sex offenders; secures 

and transports federal prisoners from arrest to incarceration; executes federal court orders; seizes 

and manages assets acquired through illegal means; and assures the safety of endangered 

government witnesses and their families.

Source: GAO summary of information from components. | GAO-18-229

Note: According to data the departments provided to us, as of the end of fiscal year 2016, the DHS 

components above—excluding FLETC—employed 42,823 of 43,222 law enforcement officers within 

DHS, and the DOJ components above employed 43,502 of 43,639 law enforcement officers within 

DOJ.

a

FLETC information is presented in this table as they provide various types of training to a number of 

federal law enforcement agencies. However, we do not consider them an operational law 

enforcement component for our subsequent discussions of training in place at components.

To identify challenges that federal law enforcement officers and agents at 

our selected DHS and DOJ components face when responding to 

incidents involving individuals with mental illness, we held discussion 

groups of six to eleven agents or officers within each component in our 

scope. We worked with officials at each component to identify officers and 

agents with varied tenures and experiences. We held semi-structured inperson and telephone discussion groups using a script and set of 

questions. Discussion groups are not designed to provide generalizable 

or statistically reliable results; they are instead intended to generate indepth information about the reasons for the discussion group participants’

attitudes on specific topics and to offer insight into their concerns. During 

the discussion groups, we asked officers and agents what challenges 

they face when responding to incidents involving individuals with mental 

illness, among other topics. We moderated each discussion to keep 

participants focused on the specified issues within discussion time 

frames. Participants identified challenges when we explicitly asked them 
Appendix I: Objectives, Scope and 

Methodology

Page 34 GAO-18-229 Federal Law Enforcement

to do so, or during the course of the discussion. We took detailed notes 

on each discussion and documented the perspectives participants raised 

in each discussion group. We then summarized the information collected 

and identified common themes. Because our questions were open-ended 

and designed to allow participants to discuss any challenges they may 

have experienced, we cannot determine whether the absence of a 

particular concern or challenge by a group of officers or agents is an 

indication that they did not experience the concern or that they did not 

raise it when asked broadly about the topic.

While these participants’ perspectives cannot be generalized to their 

entire component or all law enforcement components, their views 

provided insights into the challenges federal law enforcement officers and 

agents face when responding to incidents involving individuals with 

mental illness. We have relied on the observations gathered during these 

discussion groups to answer this reporting objective as the officers and 

agents are uniquely positioned to speak to their experiences, and any 

challenges they face, responding to incidents involving individuals with 

mental illness.

To identify the training, policies, and guidance in place, we reviewed 

documents from each of our selected law enforcement components, 

when available, to examine their nature and scope. We further reviewed 

information on the duration, requirements, and delivery mechanism of the 

training. We then summarized and verified this training information with 

each component through email documentation. For the policies, we 

reviewed the documentation to determine whether it was specific to 

responding to incidents involving individuals with mental illness or 

whether mental illness was contained within a larger directive. We also 

reviewed 2018 budget justification documents for each component in 

order to identify changes in staffing levels or training plans that might be 

related to officers’ and agents’ response to incidents involving individuals 

with mental illness. We also interviewed officials responsible for the 

development or delivery of training, policies, or guidance from the 

components in our scope to gather additional information that could help 

prepare federal law enforcement officers and agents to respond to 

incidents involving individuals with mental illness. In addition, since 

section 504 of the Rehabilitation Act of 1973, as amended, prohibits 

discrimination on the basis of disability, which includes mental illness, in 
Appendix I: Objectives, Scope and 

Methodology

Page 35 GAO-18-229 Federal Law Enforcement

federally funded and federally conducted programs and activities,1 we 

took steps to understand the section’s applicability to federal law 

enforcement operations.2 Specifically, we reviewed departmental 

guidance related to section 504 and reviewed the selected components’

documentation of efforts to review their training, policies, and procedures 

in accordance with that guidance. We also interviewed officials from the 

departmental offices overseeing these component efforts—DHS’s Office 

of Civil Rights and Civil Liberties (CRCL) and DOJ’s Office of the Deputy 

Attorney General (ODAG).

To identify leading practices or tools stakeholders cited for effective law 

enforcement responses to incidents involving individuals with mental 

illness, we used a multi-stage process3 Specifically, we:

1. conducted a search of databases, such as ProQuest and Scopus, and 

organizational websites, such as those from the Council of State 

Governments, Justice Center (CSG JC) and Police Executive 

Research Forum (PERF), to identify published work related to law 

enforcement responses to individuals with mental illness that had 

been published on or after January 1, 2007 (the last 10 years).

2. reviewed the 96 published research papers and articles that our initial 

search yielded and then refined our selection criteria to include only 

those that were literature reviews, meta-analyses, or summary papers 

published by academics, think tanks and advocacy groups, or 

government agencies. We reviewed summary articles rather than all 

the primary research articles to balance breadth, depth, and 

 1

29 U.S.C. § 794. A person with a disability includes anyone who has a physical or mental 

impairment that substantially limits one or more major life activities, has a record of such 

impairment, or is regarded as having such an impairment. The definition of disability for 

purposes of § 504 of the Rehabilitation Act is derived from the Americans with Disabilities 

Act. 29 U.S.C. § 705(9); 42 U.S.C. § 12102.

2

DOJ and DHS regulations and guidance provide that section 504 applies to all programs 

and activities of the department. For example, DOJ guidance states that DOJ’s obligations 

under section 504 and implementing regulations “apply to all members of the public with 

disabilities whom the Department serves or encounters as part of the Department’s 

traditional law enforcement programs and activities.” However, according to this same 

guidance, “[e]xigencies, dangers, and safety considerations, however, play a significant 

role in determining whether and to what extent an accommodation [for a member of the 

public with a disability] is reasonable.”

3

For the purposes of our report, stakeholders are either academic or independent 

researchers or advocacy groups that are known to have substantial knowledge or 

expertise in the area of law enforcement responses to individuals with mental illness.
Appendix I: Objectives, Scope and 

Methodology

Page 36 GAO-18-229 Federal Law Enforcement

efficiency. After refining our search, there were 16 documents that 

met our selection criteria.

3. reviewed the 16 to identify any potential leading practices. We 

determined that a practice was potentially leading if it was found in at 

least one of the remaining 16 articles and was a law enforcement –

mental health program. Using these criteria, we identified two 

potential leading practices.4

4. asked individual and organizational stakeholders to validate whether 

these were leading practices and to identify any additional leading 

practices that we might have missed. In order for us to consider an 

independent researcher as a stakeholder, the individual needed to 

have (a) authored or co-authored at least 2 of the 16 documents that 

met our search criteria as outlined earlier and (b) been recommended 

by another stakeholder. These criteria yielded two independent 

researchers from whom to solicit views. In order for us to consider an 

organization as a stakeholder, the organizations needed to have 

either (a) conducted research on law enforcement responses to 

individuals with mental illness; (b) administered law enforcementmental health collaborative programs; or (c) launched a national 

campaign on law enforcement responses to individuals with mental 

illness. After reviewing the websites of organizations that potentially 

met these criteria, we selected four organizations from which to solicit 

views. In addition, we selected individuals within the organizations as 

knowledgeable stakeholders if they were either (1) recommended by 

another stakeholder; or (2) managed a law enforcement-mental health 

program or national campaign. As a result of these steps, we 

identified and interviewed six stakeholders (two independent 

researchers and four organizations) to gather their broad views of the 

dynamic between law enforcement and individuals with mental illness; 

to obtain their observations of any practices or tools, such as training 

guides or reports that have been used to enhance officer response; 

and to provide feedback on leading practices. The six selected 

stakeholders were:

Amy Watson, Ph.D.: Professor at the Jane Addams College of 

Social Work, University of Illinois at Chicago.

 4

By using the term “leading practices,” we refer to practices that are generally effective 

when officers or agents apply them when responding to interactions with individuals with 

mental illness even if robust evaluations of such practices’ effectiveness have not been 

conducted or have shown mixed results.
Appendix I: Objectives, Scope and 

Methodology

Page 37 GAO-18-229 Federal Law Enforcement

Melissa Reuland, M.S.: Research Fellow at the Police Foundation 

and Senior Research Program Manager at Johns Hopkins School 

of Medicine, Department of Psychiatry.

Council of State Governments, Justice Center (CSG JC): a 

national nonprofit organization that serves policymakers at the 

local, state, and federal levels from all branches of government. It 

aims to provide practical, nonpartisan advice and consensusdriven strategies, informed by available evidence, to increase 

public safety and strengthen communities.

International Association of Chiefs of Police (IACP): a professional 

association for law enforcement, representing more than 30,000 

members in more than 150 countries. IACP aims to advance the 

law enforcement profession through advocacy, outreach, 

education, and programs.

National Alliance on Mental Illness: a national grassroots mental 

health organization dedicated to building better lives for the 

millions of Americans affected by mental illness.

Police Executive Research Forum (PERF): an independent 

research organization that seeks to identify best practices on 

issues such as reducing police use of force; developing 

community and problem-oriented policing; and evaluating crime 

reduction strategies.

After reaching out to each researcher and organization, we then sent a 

follow up written request to each of them to attempt to achieve consensus 

on whether or not the two practices we identified through our search—the 

Crisis Intervention Team (CIT) Model and the Co-responder Model—

should be considered leading. We also took note of any tools they 

mentioned and probed further to understand their origins and intent. We 

confirmed with all six of the selected stakeholders that the CIT Model met 

our definition of leading practice and confirmed with five out of the six 

stakeholders that the Co-responder Model met our definition. Some 

stakeholders also identified other practices as leading; however, none of 

those practices had at least two other stakeholders confirm it as a leading 

practice.

In addition, to determine how DOJ and DHS components leverage 

information from other knowledgeable parties, such as experts, 

associations, or colleagues in other components, we reviewed relevant 

documentation on these efforts, as available. We also interviewed agency 

officials from the components in our scope who are responsible for the 

development or delivery of training or policies.
Appendix I: Objectives, Scope and 

Methodology

Page 38 GAO-18-229 Federal Law Enforcement

We conducted this performance audit from February 2017 through 

February 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform an 

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.
Appendix II: Description of the Federal Law 

Enforcement Training Centers (FLETC) Basic 

Training Programs

Page 39 GAO-18-229 Federal Law Enforcement

FLETC provides basic training to all Department of Homeland Security 

(DHS) law enforcement officers through one of three basic program

categories, which vary in length, described as follows:1

• Center Basic is a FLETC training program category in which 

personnel from various agencies are provided with the critical 

competencies of a specific job, job series, or a group of closely related 

job series. FLETC provides all instruction. Training is offered in three 

basic training programs: Criminal Investigator Training Program, 

Uniformed Police Training Program and the Land Management Police 

Training Program.2

• Center Integrated Basic is a FLETC training program category that 

provides entry-level law enforcement officers or direct law 

enforcement support personnel from a single partner organization with 

the core competencies of a specific job series or a group of closely 

related job series. FLETC provides all common and basic core 

foundational instruction (i.e., firearms, physical techniques, etc.). This

category of training includes eight specific programs.3

• Agency-Specific Basic is a training program category designed to 

provide entry-level law enforcement officers or direct law enforcement 

support personnel with instruction necessary to meet a single 

agency’s mission-specific basic training needs. Generally, AgencySpecific Basic courses precede or follow a Center Basic training 

program, with partner organizations providing the majority of the 

 1

One exception would be for training provided to Border Patrol agents. While this training 

takes place at FLETC venues, according to U.S. Customs and Border Protection (CBP), 

the U.S. Border Patrol itself conducts nearly all of the training provided to its agents.

2

The Criminal Investigator Training Program provides, on an interagency basis, a program 

of instruction for all basic criminal investigative training requirements necessary for all 

investigators. The Land Management Police Training Program is designed to meet the 

entry level training needs of law enforcement officers responsible for protecting natural 

resources and public lands. The Uniformed Police Training Program provides a study of 

the basic law enforcement concepts that a new officer should understand and/or be able 

to perform upon employment in a federal law enforcement organization. According to 

FLETC, it maintains contact with partner organizations to keep abreast of their changing 

needs and to provide current information to students concerning federal laws, jurisdiction, 

policies, procedures and basic operations. 

3

Of the eight Center Integrated Basic programs, five are specific to the components in our 

review: CBP Air and Marine basic training, CBP Officer basic training, Federal Air Marshal 

training, Immigration and Customs Enforcement basic immigration enforcement training, 

and U.S. Border Patrol basic police training.

Appendix II: Description of the Federal Law 

Enforcement Training Centers (FLETC) 

Basic Training Programs
Appendix II: Description of the Federal Law 

Enforcement Training Centers (FLETC) Basic 

Training Programs

Page 40 GAO-18-229 Federal Law Enforcement

instruction. Agency-Specific Basic covers an additional 59 training 

programs.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 41 GAO-18-229 Federal Law Enforcement

Diana Maurer, (202) 512-8777 or MaurerD@gao.gov

In addition to the contact named above, Joy A. Booth (Assistant Director) 

and Adam Couvillion (Analyst-in-Charge) managed this assignment. 

Kisha Clark, Eric Hauswirth, Gina Hoover, Susan Hsu, Candace SilvaMartin, Michael Silver, Janet Temko-Blinder, and Adam Vogt made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101677)
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