Department of Homeland Security

Office of Inspector General 

Use of American Recovery and 
 

Reinvestment Act Funds by the 
 

Transportation Security Administration 
 

for the Electronic Baggage 
 

Screening Program
 


American Recovery and Reinvestment Act of 2009
 


OIG-11-07 November 2010 
Offce of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Securi ty
 

NOV 9 - 2010 

Preface 

Homeland Security Offce ofInspector General was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of augits, inspections, and special reports 

prepared as part of our oversight responsibilities for programs, grants, and projects 

administered by the department under the American Recovery and Reinvestment Act of 

The Department of 


2009 (Recovery Act). 

This report presents information on the status of Recovery Act funds used by the 

Transportation Security Administration for the Electronic Baggage Screening Program 

and on whether (1) the agency selected airports for federal support based on risk and 

prudent use of funds, (2) acquisition and deployment of explosive detection equipment 

funds, and (3) the agency's performance and 

monitoring metrics are adequately designed and properly functioning. 

allow for timely and effective use of 


The recommendations herein have been developed to the best knowledge available to our 

offce, and have been discussed in draft with those responsible for implementation. We 

trust this report wil result in more effective, effcient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

~~ 

Anne L. Richards 

Assistant Inspector General for Audits 
 

 

Table of Contents/Abbreviations 

Executive Summary .............................................................................................................1 
 

Background..........................................................................................................................2 
 

Results of Review ................................................................................................................4 
 

Use and Status of Funds ..................................................................................................4 
 

Selection of Airports .......................................................................................................6 
 

Acquisition and Deployment of Reduced-Size Explosive Detection Systems ...............6 
 

Recommendation.............................................................................................................7 
 

Management Comments and OIG Analysis ....................................................................7 
 

Accounting and Management Oversight Controls ..........................................................8 
 

Recommendations .........................................................................................................12 
 

Management Comments and OIG Analysis ..................................................................12 
 

Appendixes 

Appendix A: Purpose, Scope, and Methodology...........................................................16 
 

Appendix B: Management Comments to the Draft Report ...........................................17 
 

Appendix C: Recovery Act Funds by DHS Component ...............................................22 
 

Appendix D: Automated Checked Baggage Inspection System ....................................23 
 

Appendix E: Stand-Alone Reduced Size Explosives Detection System .......................24 
 

Appendix F: Stand-Alone Explosive Trace Detector System........................................25 
 

Appendix G: Facility Modification Projects and Timelines as of June 2010 ................26 

Appendix H: Locations and Funding for the Advanced Surveillance Program

 as of June 2010.........................................................................................27 
 

Appendix I: TSA Allocation of the Cost of Financing the Deloitte Consulting 
 

 Contract, Fiscal Year 2009 .......................................................................28 
 

Appendix J: Major Contributors ....................................................................................29 
 

Appendix K: Report Distribution...................................................................................30 
 

Abbreviations 

DHS Department of Homeland Security 
 

EBSP Electronic Baggage Screening Program 
 

EDS Explosive Detection System 
 

ETD Explosive Trace Detector
 

OIG Office of Inspector General 
 

OMB Office of Management and Budget 
 

RSEDS Reduced Size Explosive Detection Systems
 

TSA Transportation Security Administration 
 
OIG
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The American Recovery and Reinvestment Act of 2009 (Recovery 

Act) provided $1 billion to the Transportation Security 

Administration for the “procurement and installation of checked 

baggage explosives detection systems and checkpoint [passenger 

screening] explosives detection equipment.” The agency allocated 

$734 million to its checked baggage explosives detection system 

program and $266 million to the passenger screening program. 

This review covers the $734 million that the agency is using for (1) 

modifying airport facilities to deploy in-line explosive detection 

equipment systems, (2) purchasing and installing reduced size 

explosive detection equipment, and (3) managing and operating the 

program. 

Our objectives were to determine (1) the status of funds in relation 

to Recovery Act timeframes and whether the agency selected 

airports for federal support based on risk and prudent use of funds, 

(2) whether acquisition and deployment of explosive detection 

equipment allow for timely and effective use of funds, and (3) 

whether performance and monitoring metrics are properly 

designed and functioning. 

As of June 30, 2010, the agency had obligated approximately $643 

million and had reasonable plans to obligate the remaining $90.6 

million by September 30, 2010. The agency prudently selected 

airports for facility modifications according to Recovery Act 

guidance to accelerate the deployment of explosive detection 

systems at facilities with completed designs. Since the agency 

funded all airports with submitted applications, risk was not a 

factor in selecting projects. We determined that the agency needs 

to strengthen controls over (1) installing reduced size explosive 

detection equipment, (2) allocating and charging costs to its 

management support contract, (3) monitoring status of projects, 

and (4) ensuring recipient compliance with the Buy American Act. 

We are making seven recommendations to improve controls in 

these areas. The Transportation Security Administration has 

instituted or completed corrective actions on six recommendations 

and did not agree with one recommendation. 

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Background 

The American Recovery and Reinvestment Act of 2009 (Recovery 

Act) made available approximately $787 billion to federal agencies 

to preserve and stimulate economic growth in the United States. 

Department of Homeland Security (DHS) components received 

$2.75 billion for Recovery Act projects (Appendix C). The 

Recovery Act required DHS to obligate all funds by September 30, 

2010. The Transportation Security Administration (TSA) received 

$1 billion for “procurement and installation of checked baggage 

explosives detection systems and checkpoint [passenger screening] 

explosives detection equipment.” TSA is currently allocating $734 

million to baggage screening and $266 million to passenger 

screening. 

The objective of the Electronic Baggage Screening Program 

(EBSP) is to deter, detect, mitigate, and prevent transportation of 

explosives or other prohibited items in checked baggage on 

commercial aircraft. Under the program, TSA tests, buys, deploys, 

integrates, and provides full life cycle support for security 

technology equipment at approximately 450 of the Nation’s 

airports. The primary security technologies used are explosive 

detection system (EDS) equipment and explosive trace detector 

(ETD) devices. According to TSA, EDS equipment uses 

computer-aided tomography x rays adapted from the medical field 

to examine the objects inside the baggage for characteristic 

signatures of threat explosives. ETD devices analyze a swab of the 

baggage to determine whether the baggage contains explosives. 

TSA is using Recovery Act funds principally for modification of 

airport facilities to prepare for later deployment of optimal1 

checked baggage inspection systems. These systems use a 

conveyor to rapidly transport checked baggage from the ticket 

counter to a secure screening area where baggage automatically 

flows through the EDS for screening and then onto departing 

aircraft. Baggage requiring additional screening is tested manually 

with the ETD. (See appendixes D through F for schematic designs 

of EBSP technologies.) 

1

 To meet congressional deadlines after September 11, 2001, to screen checked baggage for explosives, 

TSA deployed approximately 1,000 EDS machines and 6,000 tabletop ETD devices in airports, most of 

which were installed in lobby areas. Optimal systems will modify airport facilities and baggage handling 

systems into automated checked baggage inspection systems that will fully integrate with the airports’ 

behind-the-scenes baggage handling system. 

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TSA initiates the facility modification projects by awarding funds 

to airport authorities. Similar to a grant, TSA executes an “Other 

Transactional Agreement” with airport authorities to deliver 

federal funds for the facility modification project and to specify 

terms and conditions, including matching fund requirements. 

TSA will also use Recovery Act funds to purchase and install 

Reduced Size Explosive Detection Systems (RSEDS) equipment 

and for program management and operations. RSEDS are smaller 

stand-alone EDS machines that are commonly located in terminal 

lobbies and usually screen fewer than 200 bags per hour. 

In its April 3, 2009, EDS and Checkpoint Expenditure Plan and its 

May 15, 2009, Electronic Baggage Screening Program: Program 

Specific Recovery Act Plan, TSA originally allocated $700 million 

for EBSP, of which it distributed $600 million to facility 

modification projects at 16 airports. With regard to these projects, 

the Recovery Act specified that TSA “shall prioritize the award of 

these funds to accelerate the installations at locations with 

completed design plans.” The remaining $100 million was for the 

purchase and installation of RSEDS and for operational activities 

to support equipment installation and program management. On 

August 4, 2009, TSA updated its expenditure plan to add 11 more 

facility modification projects. 

TSA reports quarterly to Congress on the status of and 

modifications to its plans for use of Recovery Act funds for 

explosive detection systems. These reports present information on 

both baggage and passenger screening projects and on Recovery 

Act and appropriated funds. In addition, TSA submits weekly 

updates on the status of its Recovery Act projects to DHS. The 

weekly report for the period ending June 30, 2010, identified 29 

facility modification projects and $734 million allocated to the 

baggage screening program. 

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Results of Review 

TSA obligated $643 million of the $734 million as of June 30, 2010, and has 

reasonable plans to obligate the balance of funds by September 30, 2010.2 

Regarding stimulation of the economy, recipients of Recovery Act funds for 

baggage screening reported the creation or retention of 589 jobs.3 In using these 

funds, TSA prudently selected airports for facility modification projects and for 

installation of RSEDS in accordance with appropriate guidance. However, we 

determined that the agency does not have a process to ensure the timely 

installation of RSEDS equipment. We also identified a need to improve controls 

over allocating and charging costs to TSA’s management support contract, 

assigning travel costs, ensuring recipient compliance with the Buy American Act, 

and monitoring project status. 

Use and Status of Funds 

While most of the $734 million allocated to the baggage screening 

program will still be used for facility modification projects, TSA has made 

considerable changes to its Recovery Act expenditure plans since August 

4, 2009. The changes resulted from cost savings of approximately $327 

million due to TSA validating project cost estimates and negotiating with 

airport authorities ($310 million) and from cost reductions to planned 

spending for management and operations ($17 million). 

Principal changes include the increase in the number of facility 

modification projects from 16 to 29 (appendix G) and RSEDS locations 

from 50 to 91 airports; the use of $32.6 million to purchase ETD 

equipment; and an increase of $41 million for closed-circuit TV 

equipment under the Advanced Surveillance Program. Table 1 compares 

initial spending plans with project status as of June 30, 2010. See 

appendix H for locations and funding for the Advanced Surveillance 

Program. 

2

 According to an October 4, 2010, status report filed with the department, TSA reported obligations of
 


$741,363,745 for the baggage screening program and obligations of $258,413,748 for passenger screening, 
 

as of September 30, 2010. Total obligations for both programs amounted to $999,777,493.
 
 3

 Recipients of Recovery Act funds file quarterly reports to the federal government on the status of funds and 
 

projects and on jobs created or retained. According to Office of Management and Budget Memorandum 09-

15, jobs created are positions that are both created and filled or were existing unfilled positions that are filled. 
 

Memorandum 09-15 also says that retained positions are existing filled positions that are retained as a result of
 


Recovery Act funding. The 589 jobs are based on the quarterly reports for the period ending March 31, 2010.
 


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TABLE 1. COMPARISON OF INITIAL SPENDING PLANS WITH 

PLANNED SPENDING AS OF JUNE 30, 2010 

Activity 

Per April and May 2009 

Spending Plans 

Per Plan Updates and 

June 30, 2010, Weekly 

Status Report 

No. of 

Projects 

Amount 

(millions) 

No. of 

Projects 

Amount 

(millions) 

Airport Facility Modifications 16 $598.1 29 $566.5 

Reduced Size Explosive Detection 

Systems 50 $64.2 91 $77.4 

Advanced Surveillance Program 

Not 

Identified $2.2 15 $43.4 

Explosive Trace Detector Equipment None None 

Not 

Identified $32.6 

Program Operation, Management, 

Technology, and Engineering N/A $35.5 N/A $14.1 

Total $700.0 $734.0 

According to information provided by TSA, approximately 88% or $643 

million of the $734 million allocated to the baggage screening program 

has been obligated as of June 30, 2010. In contrast, only 17% or $106.9 

million of funds obligated have been reported as expended, and 589 jobs 

reported as created or retained. Table 2 presents financial and jobs 

information for baggage screening program activities. 

TABLE 2. FUNDING AND JOBS INFORMATION FOR ACTIVITES UNDER THE 

BAGGAGE SCREENING PROGRAM, AS OF JUNE 30, 2010 

Activity 

Funding 

Planned Obligations Expended Jobs

Airport Facility 

Modification Projects $566,512,652 $476,488,436 $40,608,015 211.16 

Reduced Size Explosive 

Detection Systems $77,365,398 $77,367,469 $60,508,419 345.00 

Advanced Surveillance 

Program $43,402,464 $43,403,464 $96,526 13.54 

Explosive Trace Detector 

Equipment $32,632,500 $32,632,500 $0 0.00 

Program Operation, 

Management, 

Technology, and 

Engineering $14,086,986 $13,515,434 $5,713,407 19.00 

Total $734,000,000 $643,407,303 $106,926,367 588.70 

TSA has unobligated funds of $90.6 million, which it plans to use in the 

following ways: 

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•	 Complete negotiations and finalize agreements with three airport 

authorities for $90 million by the end of September 2010.4  

•	 Accrue approximately $600,000 in personnel compensation and 

benefits by September 2010.4 

This action plan for the additional funds provides a reasonable approach 

for obligating the Recovery Act funds by September 30, 2010. 

Selection of Airports 

TSA selected airports for facility modifications based on (1) compliance 

with guidance in the Recovery Act to give preference to projects that can 

be started and completed expeditiously and (2) the quality and 

completeness of the airport’s application and cost estimate. We 

determined that risk5

 was not a factor in the selection of facility 

modernization projects because all airports with submitted applications 

were selected. For RSEDS equipment, TSA chose airports with obsolete 

EDS technology it had already approved for replacement and smaller 

airports that lacked EDS. TSA’s methodology for the RSEDS site 

selection gave preference to locations where installation could be 

completed expeditiously. 

Acquisition and Deployment of Reduced Size Explosive Detection 

Systems 

TSA ordered and received new RSEDS and set up schedules with the 

airports to install the systems before it learned of installation limitations 

due to a delay in the execution of the systems integrator contract. TSA 

subsequently determined that the manufacturer could install only five units 

per week, which resulted in a delay of RSEDS deployments. 

Holding new RSEDS in storage for extended periods is costly. As of June 

7, 2010, the TSA Logistics Center held 78 new and 14 used but 

redeployable RSEDS. For the new RSEDS, the manufacturer’s warranty 

period begins approximately 120 days after delivery to the Logistics 

Center. During the warranty period, the manufacturer provides 

maintenance services for the RSEDS at no cost to TSA. After the 

warranty expires, the yearly charge for the services and related training, 

according to the contract with the manufacturer, runs from $64,750 to 

$70,700 per unit. 

4

 TSA subsequently reported that it obligated $97 million for three more airport improvement projects and 
 

accrued an additional $421,000 for personnel compensation by September 30, 2010. 
 5

 According to the “DHS Risk Lexicon,” September 2008, which defines a single language for DHS risk
 


management, risk is “a potential for an adverse outcome assessed as a function of threats, vulnerabilities, 
 

and consequences associated with an incident, event, of occurrence.”
 


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For every day an RSEDS under warranty remains warehoused (over 120 

days), TSA loses about $1866

 in warranty benefits per unit. As of June 7, 

2010, the TSA Logistic Center held seven such units. The seven units 

were under warranty a total of 790 days, resulting in a loss of 

approximately $147,000 in warranty benefits. 

To maximize the efficient use of its RSEDS assets, TSA should minimize 

the period between manufacturer delivery and airport installation. The 

need for TSA to plan for the deployment of EDS was identified by the 

DHS OIG in its November 13, 2009, report Management of the 

Transportation Security Administration’s Logistics Center, No. OIG-10-

14. While TSA has taken measures to reduce the volume and duration of 

EDS equipment stored in its warehouses, additional corrective actions are 

warranted to ensure that equipment is not delivered before it can be 

installed. 

Recommendation 

We recommend that the Deputy Administrator, Transportation Security 

Administration: 

Recommendation #1: Modify RSEDS delivery scheduling procedures to 

ensure that manufacturer/integrator installation capabilities are taken into 

account for future deliveries, and delay, to the extent possible, RSEDS 

deliveries when installation delays greater than 120 days from date of 

delivery are forecasted. 

Management Comments and OIG Analysis 

TSA Comments to Recommendation: 

Concur. TSA modified its RSEDS deployment plan “to fully utilize the 

manufacturer/integrator installation capabilities and airport readiness for 

installation.” According to TSA, the modified plan accounted for 

installation of 34 units at 23 airports, “increased operational capability, 

reduced installation delays, and ensured that these units, on average, have 

less than 120 days in the warehouse.” 

OIG Analysis: 

The response from TSA is sufficient for us to consider this 

recommendation resolved and closed. 

6

 To compute a daily warranty benefit, we added $64,750 and $70,700 and divided by 2 to compute an 

average annual warranty value of $67,725. We divided the $67,725 by 365 days to determine the daily 

warranty benefit. 

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In responding to this recommendation, TSA also commented that the 

charge for yearly maintenance services for RSEDS is $42,150 as opposed 

to the $67,725 we cited in our report. Based on this comment, we have 

modified our report to indicate that the $67,725 includes charges for 

maintenance services and training, which accounts for the difference in 

amounts. 

Accounting and Management Oversight Controls 

While TSA’s May 15, 2009, EBSP expenditure plan described overall 

processes for monitoring and evaluation of program performance, TSA 

also needs to strengthen controls over the following activities: 

•	 Determining the amount of Recovery Act funds that should be 

used to finance contractor support of the EBSP related to the 

Recovery Act 

•	 Assigning travel costs of TSA employees between Recovery Act 

and non-Recovery Act funds 

•	 Ensuring that recipients of Recovery Act funds comply with the 

Buy American Act requirements 

Office of Management and Budget (OMB) Circular A-123 contains 

overall federal agency guidance for management controls. Circular A-123 

requires federal managers to establish an organization, policies, and 

procedures to ensure that resources are used efficiently and effectively to 

achieve program results in accordance with laws and regulations and that 

reliable and timely information is obtained, maintained, reported, and used 

for decision making. OMB Memorandum M-09-15 presents specific 

guidance on implementing the Recovery Act. M-09-15 requires agencies 

to report on the overall obligation and outlay of Recovery Act funds and 

for program-specific plans to incorporate sufficient oversight capacity to 

ensure that funds are used for eligible activities. 

TSA initially identified $3.8 million of the $700 million for EBSP for 

personnel compensation and benefits for 30 additional positions. As of 

January 28, 2010, TSA had filled only 9 of the 30 positions and reduced 

the $3.8 million allocation to $1.8 million. The increase in facility 

modification projects funded by the Recovery Act and the delay in hiring 

additional staff has affected TSA’s monitoring of facility modification 

projects. 

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Determining the Amount of Recovery Act Funding for 

Contractor Support of EBSP 

TSA did not have sufficient support for a $4.86 million obligation 

of Recovery Act funds that it used to finance contractor support for 

EBSP. In 2008, TSA awarded a fixed-price contract to Deloitte 

Consulting for program management support for TSA’s Office of 

Security Technology, which oversees five programs, including 

EBSP and the Passenger Screening Program. The contract scope 

of work for EBSP calls for Deloitte Consulting to provide day-today support to program and deputy program managers in all their 

areas of responsibility. Support activities include project 

management, budget and finance management, test and evaluation, 

assistance to contracting officer’s technical representatives, 

deployment support, scheduling support, and outreach. Out of a 

$25,363,491 fixed annual amount for option year one of the 

contract, TSA obligated Recovery Act funds of $4,860,351. 

TSA provided a one-page analysis of all activities performed by 

Deloitte Consulting to estimate the amount of the latter’s effort 

allocable to the Recovery Act portion of the EBSP. The 

percentages that TSA used to allocate effort to the various 

activities performed under the contract were not supported. TSA 

used the unsupported allocation as the basis for charging costs to 

the Recovery Act funds obligated to support the contract. For 

example, Deloitte Consulting submits monthly invoices for the 

same fixed amount each month. In conjunction with the payment 

of the invoices, TSA charges $405,029 (one-twelfth of $4,860,351) 

to the Recovery Act obligation. 

While it is appropriate to finance the contract with Deloitte 

Consulting with Recovery Act funds for the contractor’s Recovery 

Act activities, procedures to identify the amounts applicable to the 

Recovery Act are insufficient. The principal reason for this 

condition is that the contract with Deloitte Consulting is fixed price 

and does not require the contractor to track costs by program or 

group. However, it would not be economical or appropriate to 

revise the contract to require Deloitte Consulting to track costs 

associated with Recovery Act work. Consequently, TSA should 

perform further analysis of the contractor’s activities to ensure that 

the amounts allocated to EBSP and the Passenger Screening 

Program are sufficiently justified, and, in turn, that invoiced costs 

are accurately charged to the Recovery Act obligation on the basis 

of any revised allocations. 

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Assigning Travel Costs 

Cost of travel by TSA employees on non-Recovery Act work was 

incorrectly financed with Recovery Act funds. We examined 

travel costs of $35,281 out of $123,994 paid for with Recovery Act 

funds as of December 31, 2009. We identified expenditures of 

$4,635 (13% of amounts examined) that were not related to 

Recovery Act work. 

Accounting personnel incorrectly entered the expenditures into the 

accounting system even though supporting documentation for the 

expenditures included the correct accounting codes. TSA needs to 

instruct accounting personnel to ensure that costs are charged to 

the proper accounts and examine the balance of travel charged to 

Recovery Act funds to determine whether there are additional 

errors. 

Monitoring Buy American Act Compliance 

TSA has not developed sufficient processes to ensure that airport 

authorities comply with the Buy American Act. Section 1605 of 

the Recovery Act requires that iron, steel, and manufactured goods 

used in Recovery Act projects be produced in the United States. 

On October 13, 2009, the DHS Acting Administrator published in 

the Federal Register a notice of waiver for the Section 1605 

requirement. The basis for the waiver was that full application of 

the requirement was inconsistent with the public interest. Under 

the waiver, airport authorities may use up to 5% of total project 

funds for non-American covered products. 

TSA relies on the airport authorities and their construction 

contractors to notify TSA if a project requires foreign-produced 

iron, steel, or manufactured goods. TSA requires airport 

authorities that have been granted a waiver to submit monthly 

reports listing the non-American products. While these actions 

may provide some assurance of compliance, more proactive efforts 

should be taken. TSA should implement independent monitoring 

of recipient compliance with the Buy American provisions of the 

Recovery Act. 

Hiring of Additional Staff 

TSA’s hiring of additional staff with Recovery Act funds is behind 

schedule. As of April 2, 2010, TSA had obligated only $485,249 

of the $1,799,000 currently identified for personnel compensation 

and benefits. The May 15, 2009, EBSP Recovery Act Plan 

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indicated that full-time employees are needed to support a surge in 

program activities. The plan also said that “TSA intends to retain 

these new Federal employees by fully offsetting their costs through 

the elimination of full-time contractor positions, thus reducing 

TSA reliance on contractor resources.” 

TSA’s need for additional staff was also noted in the DHS OIG 

December 3, 2009 report Survey of the Number, Qualifications, 

and Training of DHS Personnel Responsible for Recovery Act 

Contracts and Grants, No. OIG-10-21. In response to survey 

questions, TSA said that it needs an additional 15 program 

management acquisition staff and that “its Recovery Act work will 

be hindered by the lack of acquisition staff.” TSA also said, 

COTRs [contracting officer’s technical representatives] are 

performing their regular duties in addition to their 

Recovery Act responsibilities. This means that our 

resources are heavily overburdened. This situation has the 

potential to cause increased errors and difficulty with 

timely reporting as our staff is focused on performing 

multiple duties concurrently. 

The Budget Manager for the Office of Security and Technology 

said that TSA still plans to hire 30 additional staff. To help ensure 

that additional qualified staff are hired expeditiously, TSA should 

develop and implement a hiring plan that identifies the 

professional series, grade, number, and cost of needed staff and a 

schedule for bringing them on board. 

Obtaining Monthly Status Reports 

Monthly status reports were not being submitted by airport 

authorities or were not being controlled by TSA upon submission. 

The Other Transaction Agreements with airport authorities for 

EBSP facility modifications require the submission of monthly 

reports. Among other things, the reports show the construction 

critical path, baseline and actual date information, and costs. The 

construction schedule provides the basis for TSA planning of its 

contracted activities to install and test the EDS equipment. TSA 

applies Earned Value Management systems to costs incurred to 

report risk that could impact the cost or schedule. The timely and 

effective use of Recovery Act funds could be adversely impacted if 

TSA deployment management is not actively reviewing project 

status and milestone information. 

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As of December 2009, TSA could furnish us with reports from 

only 3 of 16 recipients with active projects. In June 2010, we 

followed up on this matter and determined that only two recipients 

had not submitted monthly status reports. We attributed the 

decline in overdue reports to new procedures that TSA 

implemented based on a preliminary notice of this finding and a 

recommendation to track and pursue overdue reports. As a result, 

we consider recommendation six closed, and no further reply to 

this matter is required. 

Recommendations 

We recommend that the Deputy Administrator, Transportation Security 

Administration: 

Recommendation # 2: Conduct further analysis of Deloitte Consulting’s 

performance under the activities covered by the contract to determine the 

appropriate amount allocable to the Recovery Act and adjust charges 

against Recovery Act funds as appropriate. 

Recommendation # 3: Communicate accounting codes used to charge 

costs to Recovery Act project activities to the accounting office; and, 

instruct accounting personnel to charge costs to the identified accounting 

codes. 

Recommendation # 4: Review travel costs not tested and correct any 

identified errors. 

Recommendation # 5: Implement procedures to ensure that EBSP 

projects using Recovery Act funds are compliant with the Section 1605 

Buy American requirements. 

Recommendation # 6: Implement a hiring plan to bring on additional 

staff to administer Recovery Act projects. 

Recommendation # 7: Implement a process to track the status of 

monthly milestone reports and to follow up on overdue reports. 

Management Comments and OIG Analysis 

TSA Comments to Recommendation # 2: 

Non concur. TSA said that it believes that the methodology it used to 

“allocate Recovery Act funds and non-Recovery Act funds to its fixedUse of American Recovery and Reinvestment Act Funds by the Transportation Security
 

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price management support contact was reasonable and not prohibited by 

the Recovery Act or applicable guidance.” 

OIG Analysis: 

We do not agree with TSA that its allocation method was reasonable 

because TSA did not provide support for how it computed the allocation 

(Appendix I). Therefore, we could not determine whether it was 

reasonable. In addition, the issue of how to allocate costs to different 

appropriations or activities is not addressed by the Recovery Act or M-09-

15, Updated Implementing Guidance for the American Recovery and 

Reinvestment Act of 2009. 

TSA determined that $8.6 million was allocable to the Recovery Act out 

of a set annual payment of approximate $25 million under a fixed-price 

contract and the balance allocable to a different appropriation. In effect, 

TSA is allocating costs between two activities. Guidance to federal 

agencies on cost accounting is contained in Statement of Federal Financial 

Accounting Standards 4: Managerial Cost Accounting Standards and 

Concepts. Also, the U.S. Government Accountability Office provides 

guidance on this matter in Volume II of the Principles of Federal 

Appropriations Law. Chapter 7, page 9, in discussing the criteria for 

recording obligations, says 

A related concept is the allocation of obligations for 

administrative expenses (utility costs, computer 

services, etc.) between or among programs funded 

under separate appropriations. There is no rule or 

formula for this allocation apart from the general 

prescription that the agency must use a supportable 

methodology. 

Our recommendation is merely asking for some basis of support for the 

allocation. This recommendation is unresolved and we request that TSA 

reconsider the recommendation. 

TSA Comments to Recommendation # 3: 

Concur. TSA said that it ensured that the accounting codes used to charge 

costs to Recovery Act project activities “were clearly communicated to the 

accounting office and that accounting personnel were instructed to 

properly charge costs to the identified accounting codes.” 

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OIG Analysis: 

The response from TSA is sufficient for us to consider this 

recommendation resolved and closed. 

TSA Comments to Recommendation # 4: 

Concur: TSA replied that it is reviewing travel costs and that it will make 

any necessary adjustments on the basis of the review. 

OIG Analysis: 

The actions taken by TSA are sufficient to resolve this recommendation. 

We will keep the recommendations in an open status, however, until we 

receive the results of the TSA examination of travel costs charged to the 

Recovery Act. 

TSA Comments to Recommendation # 5: 

Concur. TSA said that the funding agreements with recipients of 

Recovery Act funds allow TSA to conduct audits to determine recipient 

compliance with agreement provisions, including complying with the Buy 

American Act. TSA also said that it “has surveillance plans in place to 

sample OTAs established under the Recovery Act for Buy American 

compliance.” 

OIG Analysis: 

TSA’s response is sufficient for us to consider the recommendation 

resolved. However, we will keep the recommendation open until TSA 

provides us with a plan or schedule for conducting compliance audits of a 

sample of the funding agreements. 

. 

TSA Comments to Recommendation # 6: 

Concur. TSA responded that 14 of 15 positions authorized to support 

activities associated with the explosive detection system program had been 

hired as of August 12, 2010, and that the remaining position will be filled 

by September 26, 2010. 

OIG Analysis: 

The response from TSA is sufficient for us to consider this 

recommendation resolved and closed. 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 

Administration for the Electronic Baggage Screening Program
 

Page 14 
TSA Comments to Recommendation # 7: 

Concur. TSA noted that it had implemented corrective action during the 

course of the audit and the OIG had closed the recommendation on the 

basis of that action. 

 

OIG Analysis: 

As mentioned in our report, we previously resolved and closed this 

recommendation on the basis of procedures implemented during our audit 

by TSA to monitor recipient reporting. 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 15 
Appendix A 

Purpose, Scope, and Methodology 

We audited TSA’s use of Recovery Act funds to support the 

Electronic Baggage Screening Program. The objectives of the 

review were to determine: (1) the status of funds in relation to 

Recovery Act timeframes and whether TSA selected airports for 

federal support based on risk and prudent use of funds; (2) whether 

acquisition and deployment of explosive detection equipment 

allow for timely and effective use of funds; and (3) whether the 

agency’s performance and monitoring metrics are properly 

designed and functioning. 

We examined applicable laws, policies, procedures, and internal 

directives TSA uses to administer and monitor the EBSP. We 

reviewed status reports and expenditure plans for the EBSP. We 

interviewed TSA officials responsible for administering, 

managing, and overseeing the EBSP. Additionally, we 

interviewed various airport authority officials to obtain information 

on the status of their facility modification projects. We reviewed 

acquisition, deployment, and airport site preparation schedules and 

tested various expenditures to determine whether they allow for 

timely and effective use of Recovery Act funds. We did not, 

however, evaluate TSA’s external reporting processes for accuracy 

and timeliness. Our fieldwork was conducted at TSA and DHS 

headquarters from December 2009 through June 2010. 

We conducted this audit under the authority of the Inspector 

General Act of 1978, as amended, and according to generally 

accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for the findings and 

conclusions based on our audit objectives. 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 16 
A

 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 17 

SEP 24 2010

U.S. Department oCHomelaud Se.urily

601 South 12th SlTeet

rlington. VA 20598

Transportation

Security

Administration

MEMORANDUM FOR: Anne L. Richards

Assistant Inspector General for Audits

. FROM: ( L~hn.S:PistoI/ulLg~ \lr~drnimstr?j\"- .- . SUBJECT: Response to the U.S. Department ofHomeland Security Office of

Inspector General Draft Report OIG-l 0-022, "Use ofAmerican

Recovery and Reinvestment Act Foods by the Transportation

Security Administration for the Electronic Baggage Screening

Program"

This memorandum responds to thl:< Draft Report OIG-1O-022, "Use ofAmerican Recovery and

Reinvestment Act Foods by the Transportation Security Administration for the Electronic

Baggage Screening Program," dated August 2010.

Backgroood

The Recovery Act provided $1 billion to the Transportation Security Administration (TSA) for

the "procurement and installation of checked baggage explosives detection systems and

checkpoint [passenger screening] explosives detection equipment." The Agency allocated

$734 million to its checked baggage explosives detection system program. The Office of

. Inspector General (OIG) conducted a review ofthe $734 million that the Agency is using for

modifYing airport facilities to deploy in-line explosives detection equipment systems, purchasing

and installing reduced size explosives detection equipment, and managing and operating the

program.

The OIG's stated objectives were to determine the status offunds in relation to Recovery Act

timeframes and whether (1) the Agency selected airports for Federal support based on risk and

prudent use offunds, (2) the acquisition and deployment of explosives detection equipment

allow for timely and effective use offunds, and (3) the Agency's performance and monitoring

metrics are properly designed and functioning.

Appendix B 

Management Comments to the Draft Report 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 18 

2

Discussion

TSA expresses its appreciation to the aIG for acknowledging TSA's progress in obligating the

$1 billion in American Recovery and ReinvestmentAct 0/2009 (Recovery Act) funds for the

Electronic Baggage Screening Program. In particular, Ihe 010 found thaI TSA had obligated

$643 million ofRecovery Acl funds and that TSA had reasonable plans 10 obligate Ihe remaining

$90.6 million. The 010 also acknowledged that TSA prodenUy selected airports for facility

modification projects and accelerated the deployment ofexplosives detection systems according

to Recovery Act guidance. The 010 did find, however, that TSA could improve in certain

limited areas involving its acCounting and administrative oversight controls. With the exception

ofone recommendation. TSA concurs with the draft report's recommendations on bow to

strengthen controls over (1) installing reduced size explosives deteclion equipmen~ (2) a1iocating

and charging costs 10 TSA's management support contrae~ (3) monitoring the status ofprojects,

and (4) ensuring compliance with the Buy American Act.

Attachment:

Transportation Security Administration (TSA) Response to the Office ofInspector General

(OIG) Draft Report, "Use ofAmerican Recovery and Reinvestment Act Funds by the

Transportation Security Administration for the Electronic Baggage Screening Program"

August 2010

Appendix B 

Management Comments to the Draft Report 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 19 

Transportation Security AdmlnlltratloD (TSA) Response to tbe Office ofInspector General

(OIG) Draft Report, "Use ofAmerican Recovery andRelnvestmtntAct Funds by the

TramportatioD Security Adlllioistntioo Cor the Electronic Baggage Screening Program"

Augwl2010

Acquisition .ndDeploymento!ReducedSize ExploslYes Detecdon Systems (RSEW)

Recommendation ODe: Modify RSEDS delivery scheduling procedures to ensure that

manufacturer/integrator installation capabilities are taken into account for future deliveries, and

delay, to the ~xtent possible, RSEDS deliveries when installation delays are greater than 120

days from date ofdelivery are forecasted.

TSA Concu." TSA bas modified its RSEDS deployment plan to fully utilize the

manufacturerlintegratoT installation capabilities and airport readiness for installation. Simple

installation "drop and go" sites were indentified, and TSA established a process to accelerate

deployment at "drop and go" sites ifan airport reported it would nol be ready. This modified

plan bas accounled for 34 units installed at 23 airports. This bas increased operational cap2bility.

reduced installation delays, and ensured these units, on average, have less than 120 days in the

warehouse.

Clarification: Page 6, Acquisition and Deployment o/Reduced,Size Explosives Detection

Systems sec/ion, paragraph one. Installation limitations were caused by a delay in the execution

ofthe systems integrator contract, not the manufacturer. The integrator supports the complex

installations that required some degree offacility/infrastructure work at the airports.

Correction: Page 7. Acquisition and Deployment ofReducedSize Explosives Detection Systems

section, second line, the yearly charge for maintenance services for Reveal RSEDS is $42,150.

Accounting and Manflgement Ovenight Controls

Recommendation One: Conduct further analysis of Deloitte Consulting's performance under

the activities covered by tbe contract to determine the appropriate amount allocable to the

Recovery Act and adjust charges against Recovery Act funds as appropriate.

TSA Non~Concurs: TSA believes the methodology it chose·to allocate Recovery Act funds and

non~ Recovery Act funds to its fixed-price management support contract was reasonable and not

prohibited by the Recovery Act 0. applicable guidance. The Final Report sbould reflcot that OIG

did not suggest that the method selected by TSA for allocating Recovery Act funds across a

fixed-price contract violated (1) the Recovery Act or any associated guidance (2) Office of

Management and Budget (OMB) Circular A-l23. 0. (3) OMB Memorandum M-09-15.

Appendix B 

Management Comments to the Draft Report 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 20 

2

Recommendation Two: Communicate accounting codes used to charge costs to Recovery Act

project activities to the accounting office; and, instruct accounting personnel to charge costs to

the identified accounting codes.

TSA Concurs: TSA believes the accounting errors noted by OIG were isolated errors and not a

systemic problem. The accounting office bas reclassified the few incorrect charges the OIG

identified. TSA ensured the: acx:ounting codes used to charge costs to Recovery Act project

activities were clearly communicated to the accounting office and that aecounting pcrsotUlel

were instructed to properly charge costs to the ideotified accounting codes. In February 2009,

OMB issued guidance to all Recover Act recipients to "ensure all funds provided by the

Recovery Act are clearly distinguishable from non·Recovery Act funds in all agency financial

systems" and "establish unique Treasury Appropriation Fund Symbols in their financial systems

for all Recovery Act funding." TSA's distinct Recovery Act accounting codes were created in

accordance with OMB guidance along with the Agency's own account code structure using the

account code request application, which includes a field for a detailed description ofthe codes.

When a new code is added and approved, the application triggers an e-mail notification to the

Office of Financial Management (OFM) and the Office ofBudget and Performance (OBP)

personnel. OFM then entersthe code in the financial system and establishes funds control limits.

OBP, OFM and program office persormel are notified via e-mail when the codes are ready for

use. The codes are alBo visible and available for reference in the account code database, which is

accessible by all persormel on the OFM Web site.

Retommendation Tbree: Review travel costs not tested and correct any identified errors.

TSA Conturs: TSA believes incorrect travel charges were isolated clerical errors and not

evidence ofa systemic problem. TSA is currently reviewing travel costs to ensure that all

Recovery Act travel costs and transactions are properly charged. Ifany discrepancies are

indentified during the review. TSA will correct them. TSA also provided further training to

ensure travel costs are coded properly.

Retommendation Four: Implement procedures·to ensure that EBSP projects using Recovery

Act funds are compliant with the Section 1605 Buy American requirements.

TSA Coneya: TSA understands OIG's concerns and the importance ofBuy American

compliance. Given that the bulk ofTSA's Recovery Act spending is on construction projects,

the Buy American Act is an important component ofthese projects. The Other Transaction

Agreements(OTAs) for the Recovery Act include provisions that ailow TSA to conduct audits to

ensure compliance, and TSA has contractual remedies for any non~mp1iance. TSA has

surveillance plans in place to sample OTAs established under the Recovery Act for Buy

American compliance.

Recommendation Five: Implement a hiring plan to bring on additional staffto administer

Recovery Act projects.

Appendix B 

Management Comments to the Draft Report 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 21 

3

TSA CODCun: Ofthe 15 additional positions authorized to support activities associated with the

explosives dectection system program, 14 have been filled as ofAugust 12. 2010. The

remaining position is expected to be filled as ofSeptember 26, 2010.

RecommeDdation Sil:: Implement a process to track the status ofmonthly milestone reports and

to follow up on overdue reports.

TSA CODCU!]: The oro report noted that corrective action has been taken, and they consider

this recommendation closed.

Appendix B 

Management Comments to the Draft Report 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 22 

AMOUNT

COMPONENT ACTIVITY (in millions) 

 

Office of the Under 

Secretary for 

Management 

• DHS Headquarters Building 

Consolidation 

$200 

 

U.S. Customs and 

Border Protection 

• Land Ports of Entry $420 

• Non-Intrusive Inspection 

Technology 

$100 

• Southwest Border Technology $100 

• Tactical Communications $60 

 

U.S. Immigration and 

Customs Enforcement 

• Tactical Communications $20 

 

Transportation Security 

Administration 

• Baggage and Passenger 

Screening Equipment 

$1,000 

 

Coast Guard •

•

Alteration of Bridges 

Shore Facilities and Aids to 

$142 

$98 

Navigation 

 

Federal Emergency 

Management Agency 

• Assistance to Firefighter 

Grants 

$210 

• Emergency Food and Shelter 

Grants 

$100 

• Transit and Rail Security 

Grants 

$150 

• Port Security Grants $150

 Total $2,750 

Appendix C 

Recovery Act Funds by DHS Component 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 23 

Appendix D 

Automated Checked Baggage Inspection System 

Source: TSA Electronic Baggage Screening Program, Program Specific Recovery Act 

Plan dated May 15, 2009 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 24 

Appendix E 

Stand-Alone Reduced Size Explosive Detection System 

Source: Planning Guidelines and Design Standards for Checked Baggage Inspection 

Systems 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 25 

Appendix F 

Stand-Alone Explosives Trace Detector System 

Source: Planning Guidelines and Design Standards for Checked Baggage Inspection 

Systems 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


Administration for the Electronic Baggage Screening Program
 


Page 26 

Facility Modification Project 2009 2010 2011 2012 2013 2014

1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4

1.     San Francisco Intl. (SFO)

Delayed, Awaiting State Funding 

2.     Jackson Hole (JAC)

3a.  Orlando Intl. (MCO)  East

3b.  Orlando Intl. (MCO)  West

4.    Orlando Intl. (MCO) Remote‐Design

5.    Orlando Intl. (MCO) Remote

6.     San Jose Intl. (SJC)

7.     Portland Intl. Jetport (PWM)

8.     Washington Dulles Intl. (IAD)  

9.     San Antonio Intl. (SAT)

10a.Kahului (OGG) North

10b.Kahului (OGG) South

11.  Philadelphia Intl (PHL) A‐E6

12a.Philadelphia Intl (PHL) S23 Phase 1

12b.Philadelphia Intl (PHL) S23 Phase 2

13.  Honolulu Intl. (HNL)

14.  Sacramento, Intl. (SMF)

15a.Port Columbus Intl. (CMH) North

15b.Port Columbus Intl. (CMH) South

16.  James M. Cox Dayton Intl. (DAY)

17.  Hartsfield‐Jackson Atlanta Intl. (ATL)

18.  Yellowstone Regional (COD)

19.  Bozeman (BZN)

20.  St. Petersburg (PIE)

21.  Minneapolis‐St. Paul (MSP)

22.  Little Rock (LIT)

23.  San Diego (SAN)

24.  Charlotte (CLT)

25.  Colorado Springs (COS) Design

26.  Phoenix (PHX)

27.  Huntsville Intl. (HSV) Design

28.  St. Louis Lambert Field (STL) Design

29.  St. Louis Lambert Field (STL)

     

   

Appendix G 

Facility Modification Projects and Timelines as of June 2010 

Construction Period:
 


Integrated System Acceptance Test:
 
 Award Date:
 


Anticipated Award Date:
 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


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Page 27 

Funding 

Planned Actual 

Locations Obligation Obligation 

Boise Airport (BOI) $ 452,545 $ 452,545 

Ronald Reagan Washington National (DCA) $ 1,139,400 $ 1,139,400 

Ronald Reagan Washington National (DCA) Modification $ 634,356 $ 634,356 

Cincinnati / Northern Kentucky International Airport (CVG) $ 141,813 $ 141,813 

Spokane International Airport (GEG) $ 427,999 $ 427,999 

Gerald R. Ford International Airport (GRR) $ 169,423 $ 169,423 

Washington Dulles International Airport (IAD) $ 5,488,818 $ 5,488,818 

Will Rogers World Airport (OKC) $ 3,427,888 $ 3,427,888 

Adams Field Little Rock National Airport (LIT) $ 5,514,430 $ 5,515,430 

Omaha Eppley Airfield Airport (OMA) $ 2,862,994 $ 2,862,994 

Chicago Midway International Airport (MDW) $ 1,334,418 $ 1,334,418 

Kansas City International Airport (MCI) $ 6,554,288 $ 6,554,288 

Tampa International Airport (TPA) $ 6,022,084 $ 6,022,084 

Salt Lake City International Airport (SLC) $ 3,641,200 $ 3,641,200 

Orlando International Airport (MCO) $ 5,590,808 $ 5,590,808 

 Total $ 43,402,464 $43,403,464 

Appendix H 

Locations and Funding for the Advanced Surveillance Program as of June 2010 
Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


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Page 28 

Appendix I 

TSA Allocation of the Cost of Financing the Deloitte Consulting Contract, Fiscal 

Year 2009 
Appendix J 

Major Contributors 

Roger LaRouche, Director 

Jerome Fiely, Audit Manager 

William Gillies, Audit Manager 

Stephen Doran, Lead Auditor 

Kendra Loper, Auditor 

Shawn Cosman, Auditor 

Pamela Weatherly, Program Analyst 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


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Page 29 
Appendix K 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Senior Counselor to the Secretary 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Under Secretary for Management 

DHS Acting Chief Procurement Officer 

Director Office of Procurement Operations 

DHS Component Liaison, TSA 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Use of American Recovery and Reinvestment Act Funds by the Transportation Security
 


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Page 30 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.