Report to Congressional Committees

United States Government Accountability Office

GAO

March 2005 HOMELAND 

SECURITY 

Successes and 

Challenges in DHS’s 

Efforts to Create an 

Effective Acquisition 

Organization 

GAO-05-179 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-179.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Michael J. 

Sullivan at (937) 258-7915 or 

sullivanm@gao.gov. 

Highlights of GAO-05-179, a report to 

congressional requesters

March 2005

HOMELAND SECURITY

Successes and Challenges in DHS’s 

Efforts to Create an Effective Acquisition 

Organization 

DHS’s disparate organizations have quickly established collaborative 

relationships to leverage spending for various goods and services without 

losing focus on small businesses. DHS is using strategic sourcing, that is, 

formulating purchasing strategies to meet departmentwide requirements for 

specific commodities, such as office supplies, boats, energy, and weapons. 

By fostering collaboration, DHS has leveraged its buying power and savings 

are expected to grow. Also off to a good start is the small business program, 

whose reach is felt across DHS. Representatives have been designated in 

each DHS procurement office to help ensure that small businesses have 

opportunities to compete for DHS’s contract dollars. 

In contrast, lack of clear accountability is hampering DHS’s efforts to 

integrate the acquisition functions of its numerous organizations into an 

effective whole. DHS remains a collection of disparate organizations, many 

of which are performing functions with insufficient oversight, giving rise to 

an environment rife with challenges, as shown in the following table. 

Challenges Facing DHS’s Efforts to Integrate Acquisition Functions 

Problem areas Challenges 

Overall integration New policy emphasizes need for unified, integrated acquisition 

organization but allows U.S. Coast Guard and U.S. Secret Service to 

remain exempt from integration efforts. Possible workload imbalances 

have not been addressed, nor has the lack of enforcement of program 

managers’ training and certification. 

Dual accountability Some of the primary duties delegated to the Chief Procurement 

Officer have also been given to heads of DHS’s organizations, 

resulting in confusion over who is ultimately accountable for 

acquisition decisions. 

Chief Procurement 

Officer’s oversight staff 

Office has lacked sufficient staff to ensure compliance with DHS’s 

acquisition regulations and policies. 

Office of Procurement 

Operations’ use of 

interagency contracting 

Created almost 1 year after DHS was formed to support the 

organizations that lacked their own procurement support, 

Procurement Operations lacks sufficient staff and relies heavily on 

interagency contracting, but missing are management controls to 

properly oversee this activity, including fees paid to other agencies. 

Source: GAO analysis. 

Some of DHS’s organizations have major, complex acquisition programs that 

are subject to a multitiered investment review process to help reduce risk 

and increase chances for successful outcomes in terms of cost, schedule, 

and performance. Part of the review process features a knowledge-based 

acquisition approach pioneered by successful commercial firms. DHS’s 

adaptation of this best practices approach, however, does not require two 

critical management reviews and is missing some key information before 

decisions are made to invest additional resources. In addition, contractor 

tracking and oversight is not fully incorporated into DHS policy and 

guidance. Finally, some aspects of the review process—which has been 

under revision for many months—need clarification. 

Department of Homeland Security 

(DHS) organizations are expected 

to work together to protect the 

United States from terrorism. To 

support this primary mission, DHS 

has been acquiring billions of 

dollars worth of goods and 

services. DHS also has been 

working to integrate the disparate 

acquisition processes and systems 

that organizations brought with 

them when DHS was created 

2 years ago. 

GAO was asked to identify 

(1) areas where DHS has been 

successful in promoting 

collaboration among its various 

organizations and (2) areas where 

DHS still faces challenges in 

integrating the acquisition function 

across the department. GAO was 

also asked to assess DHS’s 

progress in implementing an 

effective review process for major, 

complex investments. 

What GAO Recommends

GAO recommends that the 

Secretary of Homeland Security 

consider adding resources to DHS’s 

strategic sourcing program, correct 

deficiencies in departmentwide 

oversight of acquisition policies 

and procedures, add resources for 

contracting, and shore up its 

review process for acquiring major, 

complex investments. In written 

comments on a draft of this report, 

DHS agreed with the 

recommendations. 
Page i GAO-05-179 Homeland Security 

Letter 1

Results in Brief 2 

Background 4 

Initiatives to Leverage Buying Power and Small Business Program 

Have Helped Foster Collaboration among DHS Organizations 7 

Goal of Creating an Integrated Acquisition Organization Is 

Hampered by Unclear Policy Decisions and Staffing Disparities 11 

Despite Adoption of Many Best Practices, Review Process for 

Major Investments Lacks Key Reviews and Some Management 

Controls 21 

Conclusions 28 

Recommendations for Executive Action 28 

Agency Comments and Our Evaluation 30 

Appendix I Scope and Methodology 32 

Appendix II Comments from the Department of Homeland 

Security 35 

Appendix III Office of Procurement Operations’ Customers 38 

Appendix IV Summary of Selected Commodity Council Strategic 

Sourcing Initiatives 39 

Appendix V Selected Acquisition Management Best Practices 40 

Appendix VI GAO Contacts and Staff Acknowledgments 41 

Contacts 41 

Staff Acknowledgments 41 

Contents 
Page ii GAO-05-179 Homeland Security 

Tables 

Table 1: DHS’s Principal Organizations and Their Missions 5 

Table 2: Sampling Error at the 95 Percent Confidence Level for the 

Sample of Interagency Agreements 34 

Table 3: Sampling Error at the 95 Percent Confidence Level for the 

Sample of Interagency Agreements Fee Payments 34 

Figures 

Figure 1: DHS’s Directorates and Other Principal Organizations and 

Sources of Contracting Support 6 

Figure 2: Reported Monthly Monetary Benefits Generated by DHS’s 

Strategic Sourcing Program 9 

Figure 3: Comparison of Fiscal Year 2004 Dollars Obligated per 

Contracting Staff within Each DHS Contracting Office 18 

Figure 4: General Depiction of DHS’s Investment Review Process 

for Major, Complex Investments 23 

Figure 5: Applying the Knowledge-Based Approach to DHS’s 

Acquisition Framework 25 

Abbreviations 

DHS Department of Homeland Security 

DOD Department of Defense 

MANPADS man-portable air defense systems 

US-VISIT U.S. Visitor and Immigrant Status Indicator Technology 

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Page 1 GAO-05-179 Homeland Security 

March 29, 2005 

The Honorable Tom Davis 

Chairman 

Committee on Government Reform 

House of Representatives 

The Honorable Susan M. Collins 

Chairman 

Committee on Homeland Security 

 and Governmental Affairs 

United States Senate 

Since it was established, in March 2003,1

 the Department of Homeland 

Security (DHS) has been faced with assembling 23 separate federal 

agencies and organizations with multiple missions, values, and cultures 

into one cabinet-level department.2

 This mammoth task—one of the 

biggest mergers ever to take place within the federal government—

involves a variety of transformational efforts, one of which is to design and 

implement the necessary management structure and processes for 

acquiring goods and services. In January 2003, we designated DHS’s 

implementation and transformation as high-risk because of the size and 

complexity of the effort and the existing challenges faced by the 

components being merged into the department.3

 As it progresses through 

the early stages of its merger and transformation, DHS has an opportunity 

to put into place the necessary elements to become a 21st century federal 

department with a high-quality acquisition organization that effectively 

supports its critically important missions. 

DHS has some of the most extensive acquisition needs within the U.S. 

government. In fiscal year 2004, the department obligated $9.8 billion to 

acquire a wide range of goods and services—such as information systems, 

new technologies, weapons, aircraft, ships, and professional services. At 

 1

The President signed legislation to create DHS on November 25, 2002. Homeland Security 

Act of 2002, Pub. L. No. 107-296, 116 stat. 2135, Nov. 25, 2002. 

2

When the department was established, 22 agencies and organizations were brought in; 

Plum Island Animal Disease Center joined DHS afterward. 

3

GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.: January 2003). 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-179 Homeland Security 

the same time, DHS is working to integrate the many acquisition processes 

and systems that the disparate agencies and organizations brought with 

them. 

Given DHS’s complex merger, you asked us to review the department’s 

progress in establishing an effective acquisition organization. In response 

to your request, we (1) identified areas where DHS has been successful in 

promoting collaboration among its various organizations and (2) identified 

areas where DHS still faces challenges in integrating the acquisition 

function across the department. We also assessed the department’s 

progress in implementing an effective review process for its major, 

complex investments. 

To conduct this work, we assessed information from DHS headquarters 

and the department’s principal organizations and compared the 

information against what our previous work has shown to be best 

acquisition practices. We reviewed agency directives, memorandums, and 

other documentation; interviewed agency officials; and analyzed agency 

systems and processes. For the purposes of this report, the term 

acquisition refers to the overall effort to acquire goods and services and 

involves a host of activities. Acquisition begins when an agency establishes 

its requirements and moves through a process that involves soliciting 

providers of goods and services, awarding contracts, monitoring 

performance, and handling various contract administration duties. In some 

cases, acquisition can include development of a new product, such as a 

weapon system or a database system. Acquisition also can be the simple 

purchase of existing products. The Federal Acquisition Regulation, which 

governs acquisitions within the federal government, defines the term 

procurement as being synonymous with acquisition.

4

 Appendix I presents 

our scope and methodology in more detail. We conducted our review from 

March 2004 through February 2005 in accordance with generally accepted 

government auditing standards. 

In the relatively short time since its inception, DHS has demonstrated 

some successes in implementing a strategic sourcing program to leverage 

the department’s buying power and in creating a small business program.5

 4

Federal Acquisition Regulation 2.1, Definitions. 

5

Strategic sourcing is a process used by leading commercial companies and a small number 

of federal agencies to establish an organizationwide approach to leveraging the 

organization’s buying power and fostering new ways of doing business. 

Results in Brief 
Page 3 GAO-05-179 Homeland Security 

Both of these efforts have fostered an environment in which DHS’s various 

organizations work collaboratively toward a common goal. The 

cornerstone of the strategic sourcing program is the use of commodity 

councils, each consisting of a cross-functional group of acquisition-related 

personnel and specialists from the various organizations. These councils 

are charged with formulating purchasing strategies to meet 

departmentwide requirements for specific commodities, such as office 

supplies and the department’s vehicle fleet. Even though the councils have 

faced challenges in gathering accurate spending data and in managing 

workload, they have helped spur collaboration and cooperation across the 

department. Moreover, DHS already has reported $14 million in dollar 

savings as a result of leveraging resources across DHS, and officials expect 

the savings to grow over time. Another area of early success is DHS’s small 

business program, which has been proactive in working with each 

organization in the department to ensure that small businesses have the 

opportunity to compete for DHS dollars. In fiscal year 2004, DHS reported 

that 35 percent of its prime contract dollars went to small businesses, 

exceeding its goal of 23 percent. 

Notwithstanding these initial successes, DHS’s progress in creating a 

unified acquisition organization has been slowed by policy decisions that 

create ambiguity and by procurement staffing disparities within the 

department. An October 2004 management directive emphasizes the need 

for a unified, integrated acquisition organization but relies on a system of 

dual accountability between the Chief Procurement Officer and the heads 

of the department’s organizations to make this happen. The Chief 

Procurement Officer has been delegated the responsibility to manage, 

administer, and oversee all acquisition activity across DHS, but in practice 

enforcement of these activities is spread throughout the department with 

unclear accountability. Further, the directive states that the U.S. Coast 

Guard and U.S. Secret Service are statutorily exempt from its application. 

Although the Homeland Security Act provides that both the Coast Guard 

and the Secret Service shall be maintained as distinct entities within the 

department, we found no reasonable basis to conclude that the directive 

could not be made applicable to them. Rather, it appears to be a policy 

decision that is likely to hamper efforts to effectively integrate the 

acquisition function in DHS. To a great extent, the various acquisition 

organizations within the department are still operating in a disparate 

manner, with oversight of acquisition activities left primarily up to each 

individual organization. Significant disparities in the dollar value of 

contracting staff’s workloads across DHS have only recently begun to be 

addressed. Staffing shortages have led one organization, which handles 

about $2 billion in obligations for various departmental organizations, to 
Page 4 GAO-05-179 Homeland Security 

rely extensively on outside agencies for contracting support—often for a 

fee. We found that this office lacked adequate internal controls to provide 

oversight of this interagency contracting activity. 

To protect its major, complex investments, DHS’s Office of the Chief 

Financial Officer has put in place a review process that adopts many best 

practices—that is, proven methods, processes, techniques, and activities—

to help the department reduce risk and increase the chances for successful 

outcomes in terms of cost, schedule, and performance. One best practice 

is an overarching, knowledge-based acquisition approach pioneered by 

successful commercial companies. A general principle of this approach is 

that program managers should provide sufficient knowledge about 

important aspects of their programs at key points in the acquisition 

process, so that senior leaders are prepared to make a well-informed 

investment decision before an acquisition moves forward. DHS’s 

framework includes key tenets of this approach but does not require two 

critical management reviews to ensure that resources match customer 

needs and that design performs as expected. Also missing is important 

information to help reduce risk and meet cost and delivery targets for 

major investments. In addition, DHS’s review process does not fully 

address how program managers will conduct effective contractor tracking 

and oversight. We also found that program managers lacked sufficient 

guidance about how to navigate investment reviews. The review process 

has been under revision for many months, and DHS officials could not tell 

us when the process would be finalized. 

In this report, we are making recommendations to the Secretary of 

Homeland Security to help ensure that the department’s strategic sourcing 

program maintains its current momentum, that acquisition integration 

efforts continue, and that DHS leadership has the information it needs to 

proactively manage risks that arise during the acquisition of major, 

complex systems. In written comments on a draft of this report, DHS 

concurred with the recommendations. DHS’s comments are included in 

their entirety in appendix II. 

The Homeland Security Act of 2002 created DHS, effective March 1, 2003, 

by merging agencies and organizations that specialize in one or more 

aspects of homeland security. Some of those specialties are intelligence 

analysis, law enforcement, border security, transportation security, 

biological research, critical infrastructure protection, and disaster 

recovery. The intent behind DHS’s merger and transformation was to 

improve coordination, communication, and information sharing among the 

Background 
Page 5 GAO-05-179 Homeland Security 

multiple federal agencies responsible for protecting the homeland. Critical 

to performing the homeland security mission is the effective interaction 

between and integration of these agencies and organizations. Table 1 

shows DHS’s eight principal organizations and their missions. 

Table 1: DHS’s Principal Organizations and Their Missions 

Principal organizationsa Missions 

Border and Transportation Security Directorate Ensures security of U.S. borders and transportation systems 

Enforces the nation’s immigration laws 

Manages and coordinates port-of-entry activities and oversees protection 

of government buildings 

Emergency Preparedness and Response Directorate Prepares for catastrophes 

Oversees federal government’s national response and recovery strategy 

Information Analysis and Infrastructure Protection 

Directorate 

Identifies and assesses threats 

Recommends measures necessary to protect key resources and critical 

infrastructure 

Science and Technology Directorate Coordinates DHS’s efforts in research and development 

Management Directorate Administers DHS’s budget, financial management systems, procurement 

activities, human resources functions, information technology systems, 

facilities management, and performance measurement efforts 

U.S. Secret Service Protects U.S. President and other designated personnel, as well as the 

country’s currency and financial infrastructure, and provides security for 

designated national events 

U.S. Coast Guard Protects the public, the environment and U.S. economic interests in the 

nation’s ports and waterways, coasts, international waters, or any 

maritime region as required to support national security; has terrorism, 

counternarcotics border protection roles; and prevents illegal incursion of 

U.S. exclusive economic zone 

U.S. Citizenship and Immigration Services Directs immigration benefit system and promotes citizenship values by 

providing immigration services, such as immigrant and nonimmigrant 

sponsorship; adjustment of status; work authorization and other permits; 

naturalization of qualified applicants; and asylum or refugee processing 

Sources: DHS (data); GAO (analysis). 

a

This table does not show the organizations that fall under each of the five directorates. This table 

also does not show all organizations that report directly to the DHS Secretary and Deputy Secretary, 

such as executive secretary, legislative affairs, public affairs, chief of staff, inspector general, and 

general counsel. 

Of the 23 entities that joined DHS from other agencies, only 7 came with 

their own procurement support. Providing support to the other entities—

as well as a number of newly created entities, such as the offices of the 

Chief Information Officer and Chief Financial Officer—is an eighth office, 

the Office of Procurement Operations (Procurement Operations). That 

office was not created until January 2004, almost a year after DHS came 
Page 6 GAO-05-179 Homeland Security 

into being. Appendix III lists all of the DHS organizations that receive 

contracting support from Procurement Operations. Figure 1 shows the 

sources of contracting support for DHS’s principal organizations. 

Figure 1: DHS’s Directorates and Other Principal Organizations and Sources of Contracting Support 

DHS Secretary

DHS Deputy Secretary

 Federal

Emergency

Management

Agency

 Nuclear Incident

Response Team

 Strategic 

National

Stockpile and

National Disaster

Medical System

 Domestic

Emergency 

Support

Team

 National

Domestic 

Preparedness

Office

 Transportation

Security 

Administration

 Federal Law

Enforcement

Training Center

 Customs and

Border

Protection

 Animal and Plant

Health Inspection

Service

 Immigration 

and Customs 

Enforcement

 Federal

Protective

Service

 U.S. Visitor

and Immigrant

Status Indicator

Technology

 Plum Island 

Animal Disease

Center

 National 

Biological

Warfare 

Defense

Analysis 

Center

 Chemical, 

Biological, 

Radiological, and

Nuclear 

Countermeasures

 Environmental

Measurements

Laboratory

 Critical

Infrastructure

Assurance

Office

 National

Communications

System

 Energy Security

and Assurance

Program

 Federal

Computer Incident

Response Center

 National

Infrastructure

Protection Center

 Chief Financial

Officer

 Chief Information

Officer

 Chief

Procurement

Officer

Office of

Procurement

Operations

Legend

Joined DHS with its own contracting support

Contracting support provided by one or more of the organizations within the same directorate

Contracting support provided by Office of Procurement Operations

Source: DHS (data); GAO (presentation).

Emergency

Preparedness

and Response

Directorate

Border and

Transportation

Security

Directorate

Science and

Technology

Directorate

Information

Analysis and

Infrastructure

Protection

Directorate

Management

Directorate

 Secret Service

 Coast Guard

 Bureau of 

Citizenship and

Immigration 

Services
Page 7 GAO-05-179 Homeland Security 

To carry out acquisition effectively across a large federal organization 

requires an integrated structure with standardized policies and processes, 

the appropriate placement of the acquisition function within the 

department, leadership that fosters good acquisition practices, and a 

general framework that delineates the key phases along the path for a 

major acquisition. An effective acquisition organization has in place 

knowledgeable personnel who work together to meet cost, quality, and 

timeliness goals while adhering to guidelines and standards for federal 

acquisition. 

In the 2 years since its creation, DHS has realized some successes in 

opening the lines of communication among the various organizations 

within the department through its strategic sourcing and small business 

programs. Both of these efforts have involved every principal organization 

in DHS, along with strong involvement from the Chief Procurement 

Officer, and both have yielded positive results. DHS already has begun to 

demonstrate that its strategic sourcing program can foster collaboration 

across the department and at the same time maximize the department’s 

overall buying power. DHS’s small business program has a presence 

departmentwide, and according to DHS officials, the department exceeded 

its 23 percent small business goal for fiscal year 2004.6

Under the authority of the Chief Procurement Officer, DHS created a 

strategic sourcing group in October 2003 to leverage departmentwide 

spending for various commodities. The group brought together diverse 

expertise from throughout DHS. To identify commodities with the most 

potential for savings, strategic sourcing officials conducted a spend 

analysis using available acquisition databases, such as the Federal 

Procurement Data System, and input from DHS senior management.7

 The 

 6

The Small Business Reauthorization Act of 1997 directed the President to establish a goal 

of not less than 23 percent of the federal government’s prime contracting dollars to be 

awarded to small businesses each fiscal year. The Small Business Administration is 

charged with ensuring that federal agencies’ goals, in the aggregate, meet or exceed the 

23 percent goal. Pub. L. No. 105-135, 111 stat. 2592, Dec. 2, 1997.

7

Spend analysis is a tool that organizations use to acquire knowledge about how much is 

being spent for what goods and services, who are the buyers, and who are the suppliers. 

GAO, Best Practices: Using Spend Analysis to Help Agencies Take a More Strategic 

Approach to Procurement, GAO-04-870 (Washington, D.C.: Sept. 16, 2004). 

Initiatives to Leverage 

Buying Power and 

Small Business 

Program Have Helped 

Foster Collaboration 

among DHS 

Organizations 

Strategic Sourcing 

Program Has Encouraged 

Partnerships across DHS 

and Begun to Realize 

Savings 
Page 8 GAO-05-179 Homeland Security 

following 15 commodities were identified as having potential to leverage 

the department’s buying power: 

• aviation, 

• boats, 

• business wireless communications, 

• copiers, 

• energy, 

• enterprise software agreements, 

• facilities, 

• facilities security, 

• vehicle fleets, 

• mail, 

• office supplies, 

• professional services, 

• training, 

• uniforms, and 

• weapons. 

Consistent with best practices, the strategic sourcing group then 

established commodity councils composed of representatives from across 

DHS. The commodity councils were assigned responsibility for further 

collection and refinement of historical procurement data in order to better 

assess future purchasing strategies. Typically, members from the strategic 

sourcing group and the DHS organization with the most expertise in a 

particular commodity serve as council cochairs. For example, a Coast 

Guard official is a cochair for the boats commodity council. 

Commodity council cochairs said they were willing to devote time to the 

strategic sourcing initiatives because they recognized the unique 

opportunity DHS had to move forward to leverage buying power across 

the department. Further, the cochairs were virtually unanimous in telling 

us that the councils enable stakeholders to build awareness of a particular 

commodity and develop strong relationships throughout DHS. They said 

the councils foster a sense of community in which the various 

organizations can share information, participate in forums, find 

commonalities, engage in open and productive communication, and make 

smarter and more collaborative business decisions. For example, the 

weapons commodity council routinely shares information on ammunition. 

When one DHS organization is low on ammunition, others help meet the 

need. Appendix IV contains more detail on initiatives that several 

commodity councils have undertaken. 
Page 9 GAO-05-179 Homeland Security 

In fiscal year 2004, 4 commodity councils—office supplies, boats, energy, 

and weapons—reported approximately $14.1 million in cost savings and 

cost avoidances, and department officials expect the savings to continue 

to grow.8

 The savings have resulted from DHS negotiating lower rates with 

suppliers and leveraging resources across the department. Figure 2 depicts 

the savings trend over a 12-month period. The September 2004 surge 

resulted when authorized DHS employees began purchasing pistols 

through two large contracts, a strategy spearheaded by the weapons 

commodity council. 

Figure 2: Reported Monthly Monetary Benefits Generated by DHS’s Strategic 

Sourcing Program 

0

1

2

3

4

5

6

Oct. 2003

Nov. 2003

Dec. 2003

Jan. 2004

Feb. 2004

Mar. 2004

Apr. 2004

May 2004

June 2004

July 2004

Aug. 2004

Sept. 2004

Dollars in millions

Source: DHS (data); GAO (presentation).

Some councils are encountering a problem faced by many federal 

departments and agencies, namely, a shortage of comprehensive data 

upon which to draw an accurate and detailed picture of what is being 

spent on certain commodities over time. Strategic sourcing officials and 

commodity council members told us that they cannot take full advantage 

of spend analyses, nor can they accurately chart historical spending, 

 8

Our review found that the department’s strategic sourcing cost savings methodologies 

appear reasonable. However, we did not verify the accuracy of any strategic procurement 

cost savings reported to us. 

Baseline Data and Workload 

Demands Have Presented 

Challenges 
Page 10 GAO-05-179 Homeland Security 

because DHS’s acquisition databases do not contain enough procurement 

data. The problem is compounded by the fact that when parts of existing 

agencies, such as the Immigration and Naturalization Service from the 

Department of Justice, joined DHS, detailed information on its spending 

history was not available. Without an accurate analysis of how DHS 

organizations historically purchased a commodity, council members will 

likely continue to rely on a patchwork of estimates, as well as information 

from suppliers, to glean information on spending history and develop 

purchasing strategies for the future. 

In addition, some commodity council members have found it challenging 

to balance council duties with the demands and responsibilities of their 

full-time positions within DHS. Officials told us that council meetings and 

activities sometimes stall because council members must shift attention to 

their full-time positions. Many commodity councils did not make much 

progress during the last month of fiscal year 2004, we were told, because 

council members’ time was diverted to year-end priorities. Our prior work 

on strategic sourcing shows that leading commercial companies often 

establish full-time commodity managers to more effectively manage 

commodities.9

 Commodity managers help commodity councils define 

requirements with internal clients, negotiate with potential vendors, and 

resolve performance or other issues arising after a contract is awarded 

and can help maintain consistency, stability, and a long-term strategic 

focus. 

DHS’s small business program has also had initial successes, reporting 

that 35 percent of fiscal year 2004 obligations were awarded to small 

business prime contractors, exceeding the department’s goal of 

23 percent. Although reporting directly to the Deputy Secretary of DHS, 

the Director of the Office of Small and Disadvantaged Business Utilization 

works closely with the Chief Procurement Officer to emphasize 

throughout the department the important public policy objective of small 

business inclusion in acquisition activities. The small business office, in 

conjunction with the procurement staff across the department, has created 

an outreach program that advises small businesses on ways to market 

goods and services to DHS. Small business representatives have been 

designated in each DHS procurement office, and each office is required to 

 9

GAO, Best Practices: Taking a Strategic Approach Could Improve DOD’s Acquisition of 

Services, GAO-02-230 (Washington, D.C.: Jan. 18, 2002). 

Small Business Program 

Off to Good Start 
Page 11 GAO-05-179 Homeland Security 

submit a forecast of upcoming contract opportunities above $100,000. DHS 

posts this information on a Web site so that small businesses can identify 

opportunities to do business with the department. The small business 

office has conducted extensive outreach to DHS’s business partners 

through regular seminars and has established a mentor-protégé program 

that is designed to motivate and encourage large businesses to provide 

mutually beneficial developmental assistance to small businesses. 

The Director of the Office of Small and Disadvantaged Business Utilization 

and his staff have also been directly involved in DHS’s strategic sourcing 

efforts to help ensure that, even as the department leverages its buying 

power, small businesses continue to have opportunities to compete for 

contracts. Several commodity councils have developed strategies to 

address this issue. The office supplies council has worked out an 

arrangement for DHS employees to purchase office supplies from the 

Department of Defense’s (DOD) Web-based Emall, where employees can 

easily identify and order from small businesses.10 The head of procurement 

in the Immigration and Customs Enforcement organization, working 

closely with the weapons commodity council, awarded a contract for half 

of the largest pistol procurement in the history of U.S. law enforcement to 

a small business. According to the chair of the boats council, the council 

plans to consult with the Coast Guard’s small business specialist to 

explore future possibilities for providing opportunities to small 

businesses. 

DHS’s goal of integrating the acquisition function more broadly across the 

department has not been accomplished, and the introduction of a new 

policy has been unsuccessful in breaking down barriers to effective 

departmentwide management. An integrated acquisition organization is 

essential to the department’s success in executing policies and processes 

to effectively obligate and administer billions of dollars in acquiring what 

DHS needs to accomplish its mission. An October 2004 DHS management 

directive emphasizes the need for an integrated acquisition organization 

and reiterates the Chief Procurement Officer’s responsibility to manage, 

administer, and oversee all acquisition activity across DHS and to establish 

a qualified acquisition workforce. In practice, these responsibilities are 

 10DOD Emall is an Internet-based marketplace that allows DOD and other federal 

purchasers to access DOD’s wide variety of vendors and catalogs and acquire off-the-shelf 

items from the commercial marketplace. 

Goal of Creating an 

Integrated Acquisition 

Organization Is 

Hampered by Unclear 

Policy Decisions and 

Staffing Disparities 
Page 12 GAO-05-179 Homeland Security 

spread throughout the department with unclear accountability. Further 

hampering efforts to effectively integrate the acquisition function, the 

directive provides that the Coast Guard and the Secret Service are 

statutorily exempt from its application. We found no reasonable basis to 

conclude that the directive could not be made applicable to them. The 

various organizations within DHS continue to operate in a largely 

disparate manner, with a lack of centralized oversight of compliance with 

the department’s acquisition regulation and policies. Staffing disparities 

across the procurement organizations have only recently begun to be 

addressed. We found that staffing shortfalls led Procurement Operations 

to rely extensively on outside agencies for contracting support—often for 

a fee—and that this office lacked adequate internal controls to properly 

manage this interagency contracting activity. Because of the risks 

associated with interagency contracting, we recently designated this 

approach as a high-risk issue.11

In October 2004, the Secretary of DHS signed a management directive 

entitled “Acquisition Line of Business Integration and Management.” This 

directive, the department’s principal guidance for “leading, governing, 

integrating, and managing” the acquisition function, states that DHS will 

standardize acquisition policies and procedures and continue to 

consolidate and integrate the number of systems supporting the 

acquisition function. It directs managers from each organization to commit 

resources to training, development, and certification of acquisition 

professionals. The directive also highlights the Chief Procurement 

Officer’s broad authority, including 

• management, administration, and oversight of departmentwide 

acquisition, financial assistance, strategic sourcing, and competitive 

sourcing programs; 

• promotion of career development and establishment of qualifications, 

training, and certification standards for the acquisition and financial 

assistance workforce; 

• development and publication of departmentwide acquisition and 

financial assistance regulations, directives, policies, and procedures; 

• designation of all heads of contracting activities; and 

 11GAO, High-Risk Series: An Update, GAO-05-207 (January 2005, Washington, D.C.). 

Not Clear How Recent 

Management Directive Will 

Drive Integration of the 

Acquisition Organization 
Page 13 GAO-05-179 Homeland Security 

• development and maintenance of contracting officer warrant and 

financial assistance officer programs, including designation of qualified 

persons as contracting officers and financial assistance officers. 

However, the directive may not achieve its goal of creating an integrated 

acquisition organization, because it creates unclear working relationships 

between the Chief Procurement Officer and heads of DHS’s principal 

organizations.12 For example, the Chief Procurement Officer and the 

director of Immigration and Customs Enforcement share responsibility for 

recruiting and selecting key acquisition officials, preparing performance 

ratings for the top manager of the contracting office, and providing 

appropriate resources to support the Chief Procurement Officer’s 

initiatives. The policy leaves unclear how the responsibilities will be 

implemented or what enforcement authority the Chief Procurement 

Officer has to ensure that initiatives are carried out. In addition, directors 

are only required to “consider” the allocation of resources to meet 

procurement staffing levels in accordance with the Chief Procurement 

Officer’s analysis. Agreements have not been developed on how the 

resources to train, develop, and certify acquisition professionals in the 

principal organizations will be identified or funded. In a relatively new 

department like DHS, which is still in the process of instituting 

procedures, developing a strong organizational culture, and establishing 

clear roles and missions, this concept of dual accountability—absent 

effective implementing guidance—may not accomplish the intended goals. 

The October 2004 management directive does not apply to the Coast 

Guard or the Secret Service, further hampering efforts to integrate the 

acquisition organization. The Coast Guard is one of the largest 

organizations within DHS, with obligations accounting for about $2.1 

billion in fiscal year 2004, nearly 23 percent of the department’s total. 

According to the directive, the Coast Guard is exempted by statute. We 

disagree. We are not aware of any explicit statutory exemption that would 

prevent the application of this directive. While several provisions in the 

Homeland Security Act would limit the range of management initiatives 

concerning the Coast Guard, none of them would appear to be applicable 

 12Two prior GAO reports, Transportation Security Administration: High-Level Attention 

Needed to Strengthen Acquisition Function, GAO-04-544 (Washington, D.C.: May 28, 2004), 

and Contract Management: INS Contracting Weaknesses Need Attention from the 

Department of Homeland Security, GAO-03-799 (Washington, D.C.: July 25, 2003), address 

the importance of having clear lines of authority to ensure that contracting activity is 

effective and enables the department to get best value on goods and services. 
Page 14 GAO-05-179 Homeland Security 

in this case. For example, the Homeland Security Act requires the Coast 

Guard to be maintained as a distinct entity within the department.13 Other 

limitations prevent the transfer of assets,14 alteration of missions,15 and 

changes in reporting relationships.16 The act also expressly provides that 

“the authorities, functions, and capabilities of the Coast Guard to perform 

its missions shall be maintained intact and without significant reduction 

after the transfer of the Coast Guard to the department.” We find nothing 

in the directive that contravenes these limitations. Nothing in the 

document would reasonably appear to threaten the status of the Coast 

Guard as a distinct entity or otherwise impair its ability to perform 

statutory missions. 

We raised the question of statutory exemption with the DHS General 

Counsel, who shared our assessment concerning the explicit statutory 

exemptions. He viewed the applicability of the management directive as a 

policy matter, noting that “the determination of whether the application of 

all or part of this [management directive] would impact the [Coast 

Guard’s] ability to perform its mission is not a legal matter and is more 

appropriately made by DHS policy officials.” We agree that DHS officials, 

with sufficient reasons, could make a policy decision that a particular 

management directive impacts the Coast Guard’s ability to perform its 

missions. In this instance, however, we found no evidence that such a 

decision had been made. 

The directive also provides that the Secret Service is exempted by statute. 

As with the Coast Guard, we are unaware of any specific statutory 

exemption that would prevent the application of the directive. The 

Homeland Security Act requires the Secret Service to be maintained as a 

distinct entity within the department.17 The 2005 Homeland Security 

Appropriations Act reiterates this requirement and imposes additional 

 13Pub. L. No. 107-296, § 888(b) November 25, 2002. 

14Id. at § 888(d). 

15Pub. L. No. 107-296, § 888(e), November 25, 2002. 

16Id. at §§104 and 888(g). 

17Pub. L. 107-296, § 521, November 25, 2002. 
Page 15 GAO-05-179 Homeland Security 

limitations on altering reporting relationships.18 Given the nature of the 

management directive, we also conclude that there is no apparent reason 

to exempt the Secret Service from its application.19

DHS’s principal organizations are, to a large extent, still functioning much 

as they did in premerger days with regard to acquisition-related functions. 

Embedded within seven of the procurement organizations are, for the 

most part, the same contracting staffs that joined DHS from their former 

agencies. The eighth organization, Procurement Operations, created to 

meet the needs of the many DHS organizations that do not have colocated 

procurement support, has a direct reporting chain to the Chief 

Procurement Officer. 

Until recently, the Chief Procurement Officer, whom DHS’s top leadership 

delegated with the key responsibility of ensuring compliance with the 

department’s acquisition regulation and policies, had only two staff 

members to carry out this duty. Consequently, the department’s 

acquisition oversight program relies extensively on self-assessments by 

personnel in each procurement organization. A component of the 

oversight program is a recent initiative to review DHS acquisition plans, 

according to dollar thresholds, and to perform on-site evaluations of each 

procurement organization. The fiscal year 2005 budget provided the Chief 

Procurement Officer with five additional staff, but it is too soon to tell 

whether this number will be adequate to effectively implement the 

oversight program. Further, it remains unclear what the result would be if 

an organization were found not to be in compliance with DHS’s acquisition 

regulation and policies. 

Our prior work shows that in a highly functioning acquisition organization, 

the chief procurement officer is in a position to oversee compliance with 

 18Pub. L. 108-334, § 528, October 18, 2004. “None of the funds available in this Act shall be 

available to maintain the United States Secret Service as anything but a distinct entity 

within the Department of Homeland Security and shall not be used to merge the United 

States Secret Service with any other department function, cause any personnel and 

operational elements of the United States Secret Service to report to an individual other 

than the Director of the United States Secret Service, or cause the Director to report 

directly to any individual other than the Secretary of Homeland Security.” Department of 

Homeland Security Appropriations Act, 2005, Pub. L. No. 108-334, § 521, 118 stat. 1298, Oct. 

18, 2004. 

19Given the similarity of the issue pertaining to the Coast Guard, we did not separately seek 

the view of the DHS General Counsel concerning the exemption of the Secret Service. 

In Environment of Largely 

Disparate Procurement 

Organizations, Oversight of 

Acquisition Activity 

Lacking 
Page 16 GAO-05-179 Homeland Security 

acquisition policies and processes by implementing strong oversight 

mechanisms.20 Adequate oversight of acquisition activities across DHS is 

imperative, in light of the department’s mission and the problems that have 

been reported by us and inspectors general for some of the large agencies 

and organizations within the department. These reports have highlighted 

the lack of important management controls for monitoring contractors and 

ensuring efficiencies and effectiveness in the acquisition process. For 

example, the Department of Homeland Security Inspector General 

reported that during its first year of operation, the Transportation Security 

Administration relied extensively on contractors to accomplish its 

mission. It also found that contracting officers wrote contracts without 

clearly defined deliverables, and on occasion, contractors themselves 

were permitted to determine requirements and define deliverables. As a 

result, the cost of those initial contracts ballooned.21 The Transportation 

Security Administration is in the process of devising policies and 

procedures that require adequate procurement planning, contract 

structure, and contract oversight. We have also reported that the former 

U.S. Immigration and Naturalization Service did not have the basic 

infrastructure—including oversight of procurement activities—to ensure 

that its contracting office was effective. DHS’s Inspector General recently 

reported that the Federal Emergency Management Agency discovered it 

has not been reporting or tracking procurements handled by its field 

offices.22

In July 2003, we recommended that DHS develop a data-driven assessment 

of the department’s acquisition personnel, resulting in a workforce plan 

that would identify the number, location, skills, and competencies of the 

workforce.23 DHS concurred with the recommendation and has drafted a 

plan, based on best practices, that defines the acquisition workforce, 

focuses on the need for continuous training, and implements a 

certification program for contracting officials, program managers, and 

 20GAO-02-230 and GAO-04-544. 

21DHS Office of the Inspector General, Semiannual Report to the Congress, (Washington, 

D.C.: April 30, 2003), and Review of the Status of Department of Homeland Security 

Efforts to Address Its Major Management Challenges, OIG-04-21 (Washington, D.C.: March 

2004). 

22OIG-04-21. 

23GAO-03-799. 

Challenges to Effective 

Implementation of 

Acquisition Workforce 

Plan 
Page 17 GAO-05-179 Homeland Security 

contracting officers’ technical representatives.24 However, the department 

faces challenges in implementing the plan. 

As part of its acquisition workforce planning efforts, the department has 

not conducted an assessment of whether contracting staff within DHS are 

appropriately distributed for the varying workloads in each procurement 

organization. Our analysis shows that some disparities may exist. We 

divided the obligated fiscal year 2004 dollars for each contracting office by 

the number of contracting staff. While this approach is limited in that it 

does not take into account the complexity of the acquisitions being 

performed, it can provide senior leadership with an indication of whether 

disparities may exist in the contracting workforce. Figure 3 shows the 

amount of contracting obligations per contracting staff within DHS 

contracting activities. 

 24Contracting officers’ technical representatives represent the contracting officer in 

monitoring the contractor’s performance. 
Page 18 GAO-05-179 Homeland Security 

Figure 3: Comparison of Fiscal Year 2004 Dollars Obligated per Contracting Staff 

within Each DHS Contracting Office 

As of September 2004, Procurement Operations had only 19 contracting 

staff to support a number of DHS organizations that, taken together, 

accounted for about 21 percent, or almost $2 billion, of DHS’s fiscal year 

2004 obligations. That year, Procurement Operations contracting staff on 

the average handled $101 million per employee, whereas the contracting 

staff for the Federal Law Enforcement Training Center on the average 

handled close to $2.7 million per employee. Disparities such as this may 

indicate the need to assess the numbers of contracting staff across the 

department to determine whether imbalances exist and whether actions 

are needed to correct the imbalances. 

Another challenge to effectively implementing the acquisition workforce 

plan pertains to the lack of enforcement of DHS’s certification program. 

While the plan calls for program managers responsible for acquisitions to 

be certified in accordance with DHS’s established training and experience 

requirements, in practice, the means to enforce compliance is lacking. In 

Dollars in millions

U.S. Coast Guard

U.S. Secret Service

Source: DHS (data); GAO (analysis and presentation).

Procurement Operations

Undersecretary for 

Management — Office of 

Security Administration

and Response

Transportation

Emergency Preparedness 

Border Protection

Customs and

Customs Enforcement

Immigration and

Training Center

Federal La

Enforcement

w 

0

10

20

30

40

50

60

70

80

90

100

110
Page 19 GAO-05-179 Homeland Security 

January 2005, the Director for the Acquisition Workforce Program, within 

the Office of the Chief Procurement Officer, determined that only 

22 percent of the identified programs in the department had program 

managers that had documented that they had the training and experience 

requirements for certification. While the Office of the Chief Procurement 

Officer has issued a management directive requiring program mangers to 

meet the department’s certification and training requirements—and the 

number of certified program managers has been increasing—

accountability for complying with the certification program rests with the 

principal organizations to whom the program managers report. At present, 

according to DHS officials, no mechanism is in place to ensure that 

program managers take the required training and obtain certification from 

the Chief Procurement Officer. 

Established almost 1 year after DHS was formed and tasked with 

providing contracting support to the department organizations that did not 

have their own contracting support, Procurement Operations has 

struggled to manage its almost $2 billion workload because of staffing 

shortfalls. Lacking in-house capability, Procurement Operations has 

turned extensively to interagency contracting, and we found that 

management controls were not in place to effectively oversee this activity. 

Interagency contracting occurs when a federal agency obtains supplies or 

services through another federal agency, either by placing orders on 

existing contracts that have already been awarded by the other agency, or 

by asking the other agency to award and administer contracts or issue and 

administer task orders on its behalf. Use of these contracts demands a 

high degree of business acumen and flexibility on the part of the federal 

acquisition workforce. 

We found that Procurement Operations had transferred almost 90 percent 

of its obligations to other federal agencies through interagency agreements 

in fiscal year 2004. For example, DHS transferred $12 million to the 

Department of the Interior’s National Business Center to obtain contractor 

operations and maintenance services at the Plum Island Animal Disease 

Center. Interior charged DHS $62,000 for this assistance. While some of 

the interagency agreements were for contracting support, others were for 

program support, such as sending funds to Department of Energy 

laboratories for providing a threat and capability assessment. 

DHS has issued a management directive that sets forth a number of 

requirements meant to ensure that internal controls are in place when 

using interagency contracting. Based on a random sample of 

Struggling with Staffing 

Shortfalls, Procurement 

Operations Has Relied on 

Interagency Agreements 

but Failed to Follow DHS 

Guidance in Doing So 
Page 20 GAO-05-179 Homeland Security 

136 interagency agreements between Procurement Operations and outside 

agencies, we found that the office had not complied with the requirements 

in the directive.25 We can project, for example, that in fiscal year 2004: 

• 94 percent of Procurement Operations’ files did not document that the 

contracting staff had conducted the required analysis of alternatives to 

justify the decision to pay an outside agency for contracting support; 

• 47 percent of the files did not identify the contracting officer’s 

technical representative, although this information is required to be in 

the files; 

• 35 percent of the files did not contain the required determination and 

findings;26 and 

• 96 percent of the files lacked an indication that contractor oversight 

had been performed. 

Further, we found that Procurement Operations was not tracking how 

much it is paying in fees to other agencies for contracting support. On the 

basis of our sample, we found that the office had spent $12.9 million in 

fees in fiscal year 2004. 

While the oversight problems we identified are in large part due to the 

staffing shortages in the office, we also found evidence that contracting 

staff lacked basic information on how to use interagency contracting. For 

example, a memo from Procurement Operations to DHS’s Director of 

Acquisition Policy and Oversight requested clarification on what 

documentation is required in order to use another agency for contracting 

support. In September 2004, DHS’s Office of General Counsel reviewed 

20 of Procurement Operations’ interagency agreements and found that 

16 were not legally sufficient. For example, 13 agreements appeared to 

require performance by a contractor, but appropriate documentation was 

not included in the contract files. Three were insufficient because it was 

unclear whether the servicing agency would perform cost/price analysis 

and trade-off, or whether Procurement Operations had conducted a 

technical competition and expected the servicing agency to award without 

a trade-off. According to a Procurement Operations official, a fiscal year 

 25See appendix I for details on our methodology and sampling error rates. 

26Determination and findings is a written approval by an authorized official to take certain 

contract actions. The determination is a conclusion or decision supported by the findings. 

The findings are statements of fact or rationale essential to support the determination. 
Page 21 GAO-05-179 Homeland Security 

2005 initiative for the office is to establish a policy for processing 

interagency agreements that provides clear guidance to staff. 

Since January 2004, Procurement Operations has increased its staffing 

level from 7 to 42 employees, and it plans to build to 127 staff in fiscal year 

2005. Rather than use direct appropriations to fund the additional 

positions, the office plans to require the DHS organizations that rely on its 

contracting services to contribute to a working capital fund, to be 

replenished on a no-profit basis with payments based on the extent to 

which the various organizations use the office’s support. Although the 

DHS budget for fiscal year 2005 includes $8.9 million to add contracting 

staff through the fund, we found that the mechanics of making the fund 

viable have not been worked out. Currently, Procurement Operations is 

negotiating agreements with each organization it supports to determine 

the terms and conditions of support and the dollar level to be contributed 

to the fund. According to DHS officials, this negotiation process has been 

problematic. For example, at the time of our review, the Science and 

Technology Directorate and Procurement Operations were having 

difficulty reaching a decision about who would be responsible for hiring 

the contracting staff that would support the directorate. As of January 

2005, no agreements had been reached. 

Some DHS organizations have large, complex, and high-cost acquisition 

programs that need to be closely managed. For example, the Bureau of 

Customs and Border Protection’s Automated Commercial Environment 

system, which is a new trade processing system intended to improve the 

movement of goods imported into the United States, is projected to cost 

$5 billion, and the Coast Guard’s Deepwater Program is expected to cost 

$17 billion and take 2 to 3 decades to complete.27 To review major, 

complex investments such as these (referred to as level 1 investments), 

DHS’s Office of the Chief Financial Officer has put in place a multitiered 

process. DHS has taken positive steps in creating a knowledge-based 

framework, or philosophy, for managing major investments; however, it 

still lacks key reviews and deliverables—both best practices—within this 

framework to ensure that cost and schedule estimates for major 

investments are as accurate as possible. These reviews take place at 

 27At the time of our review, the Coast Guard had revised its requirements for the Deepwater 

program based on the new homeland security mission. We did not have information on the 

new cost of the program. 

Procurement Operations to Use 

Working Capital Fund to 

Increase Staffing Levels 

Despite Adoption of 

Many Best Practices, 

Review Process for 

Major Investments 

Lacks Key Reviews 

and Some 

Management Controls 
Page 22 GAO-05-179 Homeland Security 

critical junctures in the process and include demonstrating knowledge 

about technologies, design, and manufacturing processes. In addition, we 

found that contractor oversight, an important tool for managing programs, 

is not receiving high-level attention in the review process. Finally, we 

identified several areas of confusion surrounding the mechanics of 

implementing the process from a program manager’s perspective. The 

management directive on the review process has been under revision for 

many months, and DHS officials could not tell us when the directive would 

be finalized. 

DHS’s investment review process involves several different levels of 

review, depending on the dollar threshold and risk level of the program. 

The Investment Review Board makes decisions on level 1 investments 

with prior review and input from the Joint Requirements Council, which in 

turn seeks input from other DHS specialists who have expertise in such 

areas as asset management and information technology. In classifying 

investments as level 1, DHS considers the following criteria: contract 

costs; importance to DHS strategic and performance plans; high 

development, operating, or maintenance costs; high risk; high return; and 

significance in resource administration. Investments classified as levels 

2, 3, or 4 are considered lower-level acquisitions and follow different 

investment review processes. In addition, many of the major DHS 

organizations, such as the Transportation Security Administration and the 

Coast Guard, have their own review processes, which occur prior to 

higher-level review in the department. Figure 4 illustrates who is involved 

in the decision-making process and the levels of review. 

Key Elements of DHS’s 

Investment Review 

Process 
Page 23 GAO-05-179 Homeland Security 

Figure 4: General Depiction of DHS’s Investment Review Process for Major, 

Complex Investments 

Source: DHS (data); GAO (analysis and presentation).

Other advisors

Joint Requirements Council 

seeks input from other DHS 

managers who have expertise 

in such areas as asset 

management, information 

technology, and commodities

DHS’s principal organizations and their program offices

Investment Review Board

Members: DHS’s Deputy Secretary and Under Secretary for Management, top managers of 

each principal organization, Chief Procurement Officer, Chief Information Officer, 

Chief Financial Officer, General Counsel, and the Privacy Officer

Primary function: Provide senior management with proper visibility, oversight, and accountability 

for major, complex investments; make major budgeting decisions; and approve key decisions 

made at varying points along an investment’s acquisition path

Members: Chaired by a high-level manager from the principal organizations on a rotating basis; 

senior managers from DHS’s principal organizations who have broad operating background and 

understand the requirements and capabilities of their organizations

Primary function: Conduct primary program reviews to oversee the requirements-generation 

process, validate mission needs statements, review cross-functional needs, and make 

recommendations to the Investment Review Board on proposed new programs

Joint Requirements Council
Page 24 GAO-05-179 Homeland Security 

DHS has adopted several best practices from lessons learned from leading 

commercial companies and successful federal programs that, if applied 

consistently, could refine its ability to reduce risk to meet cost and 

delivery targets for major investments. One of the best practices is a 

knowledge-based approach, or framework, for managers to hold reviews 

at key decision points in order to reduce risk before investing resources in 

the next phase of a program’s development. The investment review policy 

provides guidance to program managers to provide knowledge about 

important aspects of a product at key points in the acquisition process and 

encourages them to reduce technology risk through demonstration prior 

to beginning a project. The policy also encourages program managers to 

demonstrate a product’s design with critical design reviews and reduce 

manufacturing risk prior to a production decision. However, we found, 

based on our extensive body of work on this knowledge-based approach, 

that additional program reviews and knowledge deliverables could be 

incorporated into the process as internal controls to better position DHS 

to make well-informed decisions on its major, complex investments. 

Figure 5 generally depicts the major phases of the knowledge-based 

approach and the positioning of three knowledge points, or gates, when 

key reviews are scheduled. The figure applies the knowledge-based 

approach to DHS’s investment review framework and displays an 

exclamation mark where key reviews or information are missing. 

Although Policy Governing 

the Review Process Has 

Established a Solid Risk 

Management Framework, 

Additional Best Practices 

Would Benefit DHS 
Page 25 GAO-05-179 Homeland Security 

Figure 5: Applying the Knowledge-Based Approach to DHS’s Acquisition Framework 

As shown in figure 5, DHS review points do not fully align with the 

knowledge-based approach. For example, DHS does not require a review 

to ensure that an investment’s design performs as expected before 

investing in a prototype. In addition, DHS’s mandatory review to proceed 

to production does not occur until after low-rate initial production is well 

under way. DHS does have a review for low-rate initial production; 

however, it is at the discretion of the Investment Review Board. Our past 

work has shown that successful investments reduce risk by ensuring that 

high levels of knowledge are achieved at these key points of development. 

We found that investments that were not reviewed at the appropriate 

points faced problems—such as redesign—that resulted in cost increases 

and schedule delays. 

Start of

program

Start of

production

Product development Concept and technology development Production

Integration Demonstration

Knowledge-based framework

Knowledge point 1

Technologies,

schedule, funding,

and other resources

match customer 

needs

Knowledge point 2

Design performs

as expected

Knowledge point 3

Product must be producible within cost, schedule, 

and quality targets and demonstrated to be reliable 

before production begins 

DHS’s framework Start of

program

Start of

production

Concept and technology development

!

Knowledge point 1

Aligns with 

knowledge-based

approach but some

key information for

matching resources

to customer needs

is missing

!

Knowledge point 2

Missing is the 

knowledge point that

ensures design 

performs as

expected; also 

missing is some of the

information needed

before deciding to 

proceed to production

!

Knowledge point 3

Knowledge point is discretionary;

a required review does not occur

until after low-rate production

is well underway

Low-rate

production

Capability development and demonstration

Prototype Production and deployment

Source: DHS (data); GAO (analysis and presentation).
Page 26 GAO-05-179 Homeland Security 

We also found that some critical information is not addressed in DHS’s 

investment review policy or the guidance provided to program managers. 

In other cases, it is made optional. For example, before program start 

(knowledge point 1) is approved, DHS policy requires program managers 

to identify an acquisition’s key performance requirements and to have 

technical solutions in place. This information is then used to form cost and 

schedule estimates for the product’s development to ensure that a match 

exists between requirements and resources. However, DHS policy does 

not establish cost and schedule estimates for the acquisition based on 

knowledge from preliminary designs. At knowledge point 2, while DHS 

policy requires program managers to identify and resolve critical 

operational issues before proceeding to production, initial reviews—such 

as the system and subsystem reviews—are not mandatory. 

Not all investments require the use of every piece of information included 

under a knowledge-based approach. Many of DHS’s major investments use 

commercial, off-the-shelf products that do not require the same level of 

review as a complex, developmental investment would. However, DHS is 

investing in a number of major, complex systems, such as the Coast 

Guard’s Deepwater Program and the U.S. Visitor and Immigrant Status 

Indicator Technology (US-VISIT),28 which incorporate new technology and 

therefore require greater adherence to the knowledge-based approach in 

order to ensure risk is reduced before committing to the next phase of the 

investment. In addition, the added reviews and information included in the 

knowledge-based approach may still be required for programs that use 

existing technology, such as the Counter-MANPADS program, which 

involves placing military technology on commercial aircraft.29

In addition to the knowledge-based approach and its associated controls, 

DHS’s investment review policy and guidance adopt a number of other 

important acquisition management practices, such as requiring program 

 28US-VISIT is a governmentwide program to collect, maintain, and share information on 

foreign nationals. The program’s goals are to enhance national security, facilitate legitimate 

trade and travel, contribute to the integrity of the U.S. immigration system, and adhere to 

U.S. privacy laws and policies. 

29Counter-MANPADS (man-portable air defense systems) is a protective system for U.S. 

commercial aircraft against shoulder-fired missiles. We recently issued a report that 

recommended additional information be provided at key decision points. See GAO, The 

Department of Homeland Security Needs to Fully Adopt a Knowledge-based Approach to 

Its Counter-MANPADS Development Program, GAO-04-341R (Washington, D.C.: Jan. 30, 

2004). 
Page 27 GAO-05-179 Homeland Security 

managers to submit acquisition plans and project management plans. 

However, a key practice, contractor tracking and oversight, is not fully 

incorporated in the policy and guidance. We have cited the need for 

increased contractor tracking and oversight for several large DHS 

programs. For example, we previously reported that the Coast Guard’s 

Deepwater program needed increased management and contractor 

oversight. One activity of contract tracking and oversight requires that a 

quantitative set of software and system metrics are used to define and 

measure product quality and contractor performance. The Coast Guard 

had not developed measurable performance goals or adhered to effective 

procedures for holding the contractor accountable for its ongoing 

performance. In addition, we previously recommended that the US-VISIT 

program should improve attention to implementing acquisition best 

practices. While DHS agreed, and the US-VISIT program office has 

assigned responsibility for implementing the recommended management 

controls, the department has not yet developed explicit plans or time 

frames for defining and implementing acquisition best practices. A list of 

selected acquisition management practices and required activities is in 

appendix V. 

The investment review process has been under revision for many months. 

According to DHS officials, the changes will include shifting 

responsibilities of some tiers in the review process and increasing the 

dollar threshold for level 1 investments. To date, the new process has not 

been finalized, and officials could not provide us with a time frame for 

completion. In the meantime, we found unclear guidance and confusion 

about several aspects of the process. In some cases, the confusion has 

resulted in key stakeholders, such as the Chief Procurement Officer, not 

receiving materials in time to conduct a thorough review and provide 

meaningful feedback prior to investment review meetings. 

The issues we found include the following: 

• Program managers have been provided with only draft guidance 

regarding the information they are required to submit and the time 

frames for submissions. This draft guidance is, in some cases, unclear. 

• Some DHS officials noted that their submissions to the review board 

had been rejected on an inconsistent basis with no explanation. 

• Program managers have not received formal training on the investment 

review process. Officials told us that some program managers have 

been unaware of when to submit information about their programs for 

review. 

As Review Process 

Matures, Some Mechanics 

Still to Be Worked Out 
Page 28 GAO-05-179 Homeland Security 

• In practice, major investments in services are exempt from the review 

process and are only reviewed when done as part of a capital 

investment. Officials from the Office of the Chief Financial Officer who 

are in charge of the process told us that services investments are 

reviewed only when they are part of a capital investment because these 

acquisitions are not complex and therefore do not need the same level 

of scrutiny reserved for the acquisition of goods. 

Currently, program managers receive assistance in developing their review 

board submissions from a small number of staff in the Chief Financial 

Officer’s Office of Program Analysis and Evaluation at the beginning of a 

program and at DHS’s key decision points. However, because of limited 

resources, the office has only been able to provide limited support to 

programs to assist them in completing their submissions. 

In the 2 years since its merger, DHS has taken strides toward putting in 

place an acquisition organization that contains many promising elements, 

but the steps taken so far are not enough to ensure that the department is 

effectively managing the acquisition of the multitude of goods and services 

it needs to meet its mission. More needs to be done to fully integrate the 

department’s acquisition function, to pave the way for the Chief 

Procurement Officer to fully carry out his responsibilities in a modern-day 

acquisition organization, and to put in place the strong internal controls 

needed to effectively manage interagency contracting activity and large, 

complex investments. Unless DHS’s top leaders address these challenges, 

the department is at risk of continuing to exist with a fragmented 

acquisition organization that provides stopgap, ad hoc solutions. DHS has 

an opportunity, while it is still involved in transformational efforts, to 

avoid the complications that plague acquisition efforts in other longestablished federal departments. 

To help ensure that DHS receives the goods and services it needs at the 

best value to the government, we recommend that the Secretary of 

Homeland Security take the following six actions: 

• establish a structure to ensure continued support for commodity 

councils, such as appointing full-time dedicated commodity managers, 

to ensure that the commodity councils develop long-term strategies, 

maintain momentum, and continue to realize savings; 

Conclusions 

Recommendations for 

Executive Action 
Page 29 GAO-05-179 Homeland Security 

• provide the Office of the Chief Procurement Officer with sufficient 

resources and enforcement authority to enable effective, 

departmentwide oversight of acquisition policies and procedures; 

• conduct a departmentwide assessment of the number of contracting 

staff and, if a workload imbalance is found, take steps to correct it by 

re-aligning resources; 

• direct higher-level management attention to the implementation of the 

working capital fund (which is to be used to fund contracting staff for 

the Office of Procurement Operations) by, for example, determining 

the level of contracting support needed by the organizations relying on 

this office, ensuring that appropriate funds are committed to hire 

needed contracting staff, and ensuring that funds are available on an 

ongoing basis for continuity; 

• revise the October 2004 management directive “Acquisition Line of 

Business Integration and Management” to eliminate reference to the 

Coast Guard and Secret Service being statutorily exempt from 

complying; and 

• ensure that DHS’s management directive on interagency agreements is 

followed and that fees paid to other agencies are tracked. 

To help ensure that DHS leadership is aware of risks as they arise during 

the acquisition of major, complex systems, we recommend that the 

Secretary of Homeland Security take the following seven actions: 

• in making revisions to the investment review policy: 

• require for all complex, developmental investments a formal design 

review between the integration and demonstration of a program to 

ensure that the design is stable and has been demonstrated through 

prototype testing; 

• require for all complex, developmental investments a review before 

initial production; 

• require that program managers supply additional information—such as 

cost and schedule estimates based on results of a preliminary design 

review and critical design review—when their major, complex 

programs are reviewed; and 

• require program managers to specifically address contractor oversight 

in their submissions to investment review boards. 

• ensure that stakeholders, including acquisition officials in the Office of the 

Chief Procurement Officer, have adequate time to review investment 

submissions and provide formal input to decision-making review boards; 
Page 30 GAO-05-179 Homeland Security 

• implement training for program managers on the investment review 

process that emphasizes the importance of a knowledge-based approach; 

and 

• require that major acquisitions of services be subject to oversight by the 

investment review board. 

We provided a draft of this report to DHS for review and comment. In 

written comments, DHS generally agreed with our facts and conclusions 

and concurred with all of our recommendations. Regarding three of our 

recommendations on the investment review process, DHS stated that the 

actions exist in current directives and are already being done. We disagree. 

Our work demonstrated that DHS’s review points do not fully align with 

the knowledge-based approach. For example, DHS’s mandatory review to 

proceed into production does not occur until after low-rate initial 

production is well under way, and the review for starting low-rate initial 

production only occurs at the discretion of the Investment Review Board. 

Also, DHS's framework lacks the knowledge deliverables necessary at 

each key review to ensure that cost and schedule estimates for major 

investments are as predictable as possible. Our past work has shown that 

investments that were not reviewed at the appropriate points faced 

problems that resulted in cost increases and schedule delays. 

The department’s comments are reprinted in appendix II. 

As arranged with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from its 

issue date. We are sending copies of this report to other interested 

congressional committees, the Secretary of the Department of Homeland 

Security, and the Director of the Office of Management and Budget. In 

addition, the report will be available on GAO’s Web site at 

http://www.gao.gov.

Agency Comments 

and Our Evaluation 
Page 31 GAO-05-179 Homeland Security 

If you or your staff have any questions concerning this report, please 

contact me at (937) 258-7915. Staff making major contributions to this 

report are listed in appendix VI. 

Michael J. Sullivan, Director 

Acquisition and Sourcing Management 
Appendix I: Scope and Methodology 

Page 32 GAO-05-179 Homeland Security 

To identify the areas where the Department of Homeland Security (DHS) 

has been successful in promoting collaboration among its various 

organizations, we interviewed senior acquisition officials at DHS 

headquarters and analyzed pertinent documents. We obtained information 

from the Office of Strategic Sourcing and Acquisition Systems to analyze 

how DHS has used strategic sourcing to leverage the department’s buying 

power. We interviewed senior strategic sourcing officials at DHS 

headquarters to obtain information on how they identified the 

commodities with potential for savings. We reviewed studies, policies, 

guidance, and other documents related to ongoing or proposed strategic 

sourcing initiatives that leveraged buying power, cut costs, or achieved 

other performance benefits. Our review found that the department’s 

strategic sourcing cost savings methodologies appear reasonable; 

however, we did not verify the accuracy of any strategic procurement 

costs savings reported to us. We asked senior strategic sourcing and 

commodity council participants about potential barriers to employing 

strategic sourcing at DHS. We interviewed the Director, Office of Small 

and Disadvantaged Business Utilization, and procurement officials within 

the department. We obtained policies, memorandums, and other 

documents from the small business office, procurement organizations, and 

the U.S. Small Business Administration. 

To determine areas where DHS faces challenges in integrating the 

acquisition function, we reviewed DHS organizational charts to gain 

insight into where the procurement offices fall in the hierarchy and to 

determine the lines of responsibility and authority between the various 

stakeholders in the acquisition process. We reviewed DHS policies, 

guidance, and procedures governing acquisition and analyzed internal 

audit reports, when available, to determine if those policies and 

procedures were being followed. We obtained statistics from DHS’s Office 

of the Chief Procurement Officer on the department’s procurements and 

the acquisition workforce. We interviewed procurement policy officials at 

headquarters and conducted interviews with personnel in each of the 

procurement organizations. To assess DHS’s effectiveness in managing its 

acquisition workforce, we interviewed contracting and human resource 

officials at DHS headquarters. We analyzed DHS’s processes and 

procedures for certifying program managers, warranting contracting 

officers, and tracking the acquisition workforce training. Lastly, we 

reviewed previous GAO work regarding best acquisition practices for 

organizational alignment and oversight. 

Because the Office of Procurement Operations has, by far, the highest 

level of interagency contracting activity in the department, we examined 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 33 GAO-05-179 Homeland Security 

the office’s database of contracts to gain an understanding of the general 

scope of activity involving interagency agreements. We randomly selected 

and then reviewed 136 interagency agreement contract files. We 

interviewed officials responsible for the data to ensure that the system 

they use to track procurement activity was adequate for identifying the 

sample population. We reviewed the interagency agreement contract files 

to assess key aspects of the acquisition process—such as a signed 

determination and findings in accordance with the Federal Acquisition 

Regulation, acquisition planning, and interagency agreement contract 

administration, including contractor oversight. We held follow-on 

discussions with the Office of Procurement Operations to discuss 

discrepancies noted in the files. Further information on our methodology 

and sampling error rates is as follows: 

• In fiscal year 2004, the Office of Procurement Operations predominately 

obtained contracting services for its customers through the issuance of 

interagency agreements with other government agencies. We drew our 

sample from an original population of 984 agreements. Of the 150 items we 

initially sampled, the department deleted 14 of these agreements and 

withdrew them from the data. As a result, we adjusted the population of 

agreements to which we are making estimates to 892 agreements. All 

estimates are to these 892 agreements based upon a sample size of 

136 agreements. In addition, 4 files were missing and were not able to be 

reviewed, and one agreement was a duplicate. This resulted in only 131 

files being reviewed. As we conducted our reviews, the agency became 

better at recording the agreements that should be included in its database. 

Currently, Procurement Operations reports that 1,104 agreements are 

contained in its records and total $1.8 billion. 

• We reviewed the files and documents for these 131 agreements, using as 

our criteria the department’s directive on interagency agreements. The 

following projections are made from our sample of 136 agreements. The 

estimates from a statistical sample are always subject to some uncertainty 

because the entire collection is not reviewed. This uncertainty is called 

sampling error. Tables 2 and 3 show the sampling errors for certain factors 

relating to the issuance of interagency agreements. 
Appendix I: Scope and Methodology 

Page 34 GAO-05-179 Homeland Security 

Table 2: Sampling Error at the 95 Percent Confidence Level for the Sample of Interagency Agreements 

Number Percentage 

Observation Estimate

Sampling 

error Estimate

Sampling 

error

Analysis of alternatives not conducted 840 36 94.1 4

Contracting officer’s technical representatives not identified 420 76 47.1 8.5

Determination and findings not prepared 308 72 34.6 8.1

No indication that contractor oversight performed 853 31 95.6 3.5

Source: GAO (data and analysis). 

Table 3: Sampling Error at the 95 Percent Confidence Level for the Sample of Interagency Agreements Fee Payments 

Number Dollars 

Observation Estimate Sampling error Estimate Sampling error

Fees paid on use of interagency agreements 433 76 $12,991,079 $2,280,189

Source: GAO (data and analysis). 

To assess the department’s progress in implementing a review process for 

major, complex systems, we compared DHS’s acquisition policies for 

major acquisitions to our knowledge-based approach. We used 

information from several of our prior reports that examine how 

commercial best practices can improve outcomes for acquisition 

programs. Specifically, we compared and contrasted DHS’s investment 

review process with the best practices for commercial acquisitions 

identified in our past reports. Our analysis focused on whether DHS’s 

policies contained the measurable criteria and management controls 

necessary for minimizing cost, schedule, and performance risks. To clarify 

the content of the investment review process, we met with various DHS 

officials from the Office of the Chief Procurement Officer and the Office of 

Program Evaluation and Analysis within the Office of the Chief Financial 

Officer. We also discussed the review process with officials from DHS 

procurement organizations and collected reports and analyzed available 

program data on the current status of major acquisitions being carried out 

by DHS. 

We conducted our review from March 2004 through February 2005 in 

accordance with generally accepted government auditing standards. 
Appendix II: Comments from the Department 

of Homeland Security 

Page 35 GAO-05-179 Homeland Security 

Appendix II: Comments from the Department 

of Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 36 GAO-05-179 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 37 GAO-05-179 Homeland Security 
Appendix III: Office of Procurement 

Operations’ Customers 

Page 38 GAO-05-179 Homeland Security 

Chief Financial Officer 

Chief Human Capital Officer 

Chief Information Officer 

Chief Procurement Officer 

Chief of Administrative Services 

Chief of Staff 

Citizenship and Immigration Services 

Citizenship and Immigration Services Ombudsman 

Civil Rights and Civil Liberties 

Communications Director 

Counter Narcotics Officer 

Deputy Secretary 

Executive Secretary 

General Counsel 

Headquarters Operational Integration Staff 

Homeland Security Advisory Council 

Homeland Security Operations Center 

Immigration Statistics 

Information Analysis and Infrastructure Protection 

International Affairs 

Office of the Secretary 

Legislative Affairs 

National Capital Region 

Office of the Under Secretary--Border and Transportation Security 

Press Secretary 

Privacy Officer 

Private Sector 

Public Affairs 

Science and Technology 

Security 

State and Local Government Coordination (includes Office of 

 Domestic Preparedness) 

Under Secretary for Management 

White House Liaison 

Appendix III: Office of Procurement 

Operations’ Customers 
Appendix IV: Summary of Selected 

Commodity Council Strategic Sourcing 

Initiatives 

Page 39 GAO-05-179 Homeland Security 

Commodity council Strategic sourcing actions taken 

Office Supplies Leverages DHS’s purchasing power and reduces amount spent on office supplies: 

• For its main strategic sourcing initiative, this council partnered with the Department of Defense’s 

Electronic Mall (DOD Emall). DOD Emall is an Internet-based catalog ordering system that provides 24-

hour-a-day, 7-day-a-week access to over 200 small and large office supply vendors. 

• Because many military services also purchase office supplies through DOD Emall, DHS can take 

advantage of large volume discounts to increase its buying power. 

• As of June 1, 2004, DHS mandated all of its purchase cardholders to exclusively use DOD Emall to buy 

office supplies. As a result, DHS has already become the third-largest federal government user of DOD 

Emall. For the 4-month period starting June 1, 2004, DHS spent over $14.5 million on DOD Emall, 

representing 16.7 percent of the total dollars spent on Emall. 

• Before the full implementation of DOD Emall, the council also generated savings by using an office 

supplies blanket purchase agreement that the Transportation Security Administration had in place to 

provide office supplies to other DHS principal organizations. 

• Through September 30, 2004, the council estimated cost savings of $8 million. 

Boats Establishes standard boat procurements to decrease life cycle costs, facilitate interoperability, reduce 

training burden, and provide immediate cost savings: 

• For example, Customs and Border Patrol needed six boats in fiscal year 2004. Instead of creating a 

new contract, the council explored whether there were any existing contract vehicles within DHS that 

could satisfy the need. 

• The council purchased the six boats through an existing Coast Guard contract and took advantage of 

large volume discounts. 

• As a result of these strategic sourcing efforts, the council was able to acquire each boat for $50,000 

less than anticipated, resulting in a total of $300,000 in cost savings. 

Weapons Identifies and consolidates emerging firearms and ammunition requirements for DHS: 

• In fiscal year 2004, the council planned to acquire pistols for DHS organizations to meet critical, 

mission-driven requirements. 

• The council surveyed all DHS organizations interested in weapons, factored in the end users’ 

requirements, and established a list of potential vendors that could provide best value for pistols and 

satisfy requirements. 

• As a result, DHS awarded contracts to two vendors for 65,000 pistols each over 5 years—the largest 

pistol acquisition in the history of U.S. law enforcement. 

• As of September 20, 2004, the council has reported cost savings of over $4.1 million and $915,000 in 

cost avoidance. 

Energy Identifies strategies for aggregating and centralizing DHS’s energy procurements to take advantage of 

economies of scale and negotiate more competitive prices with suppliers: 

• Although DHS spent approximately $58 million for electricity in fiscal year 2003, only $9 million of the 

spending was for negotiable energy services in states with deregulated electricity industries. 

Nevertheless, the council estimates more than $705,000 in cost savings through September 30, 2004. 

Source: DHS (data); GAO (presentation). 

Appendix IV: Summary of Selected 

Commodity Council Strategic Sourcing 

Initiatives 
Appendix V: Selected Acquisition 

Management Best Practices 

Page 40 GAO-05-179 Homeland Security 

Best practices Activity 

Acquisition planning 

To ensure that 

reasonable planning for 

all parts of the 

acquisition is conducted 

Plans are prepared during acquisition planning and 

maintained throughout the acquisition. 

Planning addresses the entire acquisition process, as well as 

life cycle support of the products being acquired. 

The acquisition organization has a written policy for planning 

the acquisition. 

Responsibility for acquisition planning activities is designated.

Contract tracking and 

oversight 

To ensure that contract 

activities are performed 

in accordance with 

contractual requirements 

The acquiring organization has sufficient insight into the 

contractor’s activities to manage and control the contractor 

and ensure that contract requirements are met. 

The acquiring organization and contractor maintain ongoing 

communication; commitments are agreed to and implemented 

by both parties. 

All contract changes are managed throughout the life of the 

contract. 

The acquisition organization has a written policy for contract 

tracking and oversight. 

Responsibility for contract tracking and oversight activities is 

designated. 

The acquiring organization involves contracting specialists in 

the execution of the contract. 

A quantitative set of software and system metrics is used to 

define and measure product quality and contractor 

performance. 

In addition to incentives for meeting cost and schedule 

estimates, measurable, metrics-based product quality 

incentives are explicitly stated in the contract. 

Risk management 

To ensure that risks are 

proactively identified and 

systematically mitigated 

Projectwide participation in the identification and mitigation of 

risks is encouraged. 

The defined acquisition process provides for the identification, 

analysis, and mitigation of risks. 

Milestone reviews include the status of identified risks. 

The acquisition organization has a written policy for managing 

acquisition risk. 

Responsibility for acquisition risk management activities is 

designated. 

Source: GAO (data); GAO (presentation). 

Note: See GAO, Information Technology: DoD’s Acquisition Policies and Guidance Need to Incorporate Additional Best Practices and 

Controls, GAO-04-722 (Washington, D.C.: July 30, 2004) for a complete list of the acquisition management practices and required 

activities.

Appendix V: Selected Acquisition 

Management Best Practices 
Appendix VI: GAO Contacts and Staff 

Acknowledgments 

Page 41 GAO-05-179 Homeland Security 

Michael J. Sullivan, (937) 258-7915 

Michele Mackin, (202) 512-4309 

In addition to those named above, Daniel Chen, Lily Chin, Benjamin 

Federlein, Arthur James Jr., John Krump, Jose Ramos, and Russell Reiter 

made key contributions to this report. 

Appendix VI: GAO Contacts and Staff 

Acknowledgments 

Contacts 

Staff 

Acknowledgments 

(120328) 
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