Office of Inspector General 

DEPARTMENT OF HOMELAND SECURITY 

Better Management Needed for the 

National Bio-Surveillance Integration 

System Program 

OIG-07-61 July 2007 
U.S. Department of Homeland Security 

Washington, DC 20528

July 26, 2007 

 

Preface 

The Department of Homeland Security, Office of Inspector 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 audit, inspection, and special reports prepared 

as part of our oversight responsibilities to promote economy, efficiency, and effectiveness 

within the department. 

This report addresses how well the National Bio-Surveillance Integration System is being 

developed to provide comprehensive and integrated bio-surveillance situational awareness. 

It is based on interviews with employees and officials of relevant agencies and institutions, 

direct observations, and a review of applicable documents. 

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

office, and have been discussed in draft with those responsible for implementation. It is our 

hope that this report will result in more effective, efficient, and economical operations. We 

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

 

Richard L. Skinner 

Inspector General 
Table of Contents/Abbreviations 

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

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

 Results of Audit .........................................................................................................................6 

 Program Leadership and Support...................................................................................6 

 

 NBIS Program Execution ............................................................................................14 

Recommendations....................................................................................................................24 

Management Comments and OIG Analysis ............................................................................24 

Appendices 

Appendix A: Purpose, Scope, and Methodology....................................................................27 

Appendix B: Management Responses to the Draft Report.....................................................29 

Appendix C: Major Contributors to this Report .....................................................................33 

Appendix D: Report Distribution............................................................................................34 

 Abbreviations 

BCOP Biological Common Operating Picture 

 DHS Department of Homeland Security 

 GAO Government Accountability Office 

 HSPD Homeland Security Presidential Directive 

 IAIP Information Analysis and Infrastructure Protection 

 IT Information Technology 

 NBIS National Bio-Surveillance Integration System 

 OCMO Office of the Chief Medical Officer 

 OHA Office of Health Affairs 

Figures 

Figure 1 – NBIS Operating Environment ..................................................................................4 

Figure 2 – NBIS Program Depiction of the BCOP....................................................................5 

Figure 3 – NBIS Ownership and Program Transitions..............................................................6 

Figure 4 – President G.W. Bush Speaking on Pandemic Influenza...........................................9 

Figure 5 – NBIS Organization Chart, as of March 2007 .........................................................13
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 1

OIG 

Department of Homeland Security 

Office of Inspector General 

 

Executive Summary 

The ability to recognize quickly the signs of an intentional biological attack or 

naturally occurring outbreak is crucial to protecting the American public. 

Recognizing a gap in national biological threat analysis, in 2004, the President 

directed the Department of Homeland Security (DHS) to consolidate federal 

agency bio-surveillance data in one system. In response, DHS began efforts 

to develop the National Bio-Surveillance Integration System (NBIS), the 

nation’s first system capable of providing comprehensive and integrated biosurveillance and situational awareness. 

As part of our ongoing responsibility to assess the efficiency, effectiveness, 

and economy of departmental programs and operations, we audited the NBIS 

program. The objectives of our audit were to determine (1) the efficacy of 

DHS’ plans, policies, and procedures for collaborating with other federal, 

state, and local stakeholders to gather and share bio-surveillance information 

via NBIS; and (2) whether the system will meet user needs, information 

security requirements, and privacy policies and procedures. The purpose, 

scope, and methodology of this audit are discussed in Appendix A. 

NBIS, a key element of DHS’ bio-protection program, is falling short of its 

objectives. Specifically, DHS has not provided consistent leadership and staff 

support to ensure successful execution of the NBIS program. For various 

reasons, NBIS ownership has shifted among department organizations 

numerous times, with corresponding fluctuations in the program approach, 

priority, and accomplishments. NBIS also has struggled since its inception to 

secure the staff needed to manage program activities effectively. As a result 

of the repeated transitions and staffing shortfalls, planning documents needed 

to guide information technology (IT) development have yet to be finalized. 

Program management has not effectively communicated and coordinated with 

stakeholders to secure the data, personnel, and information sharing 

agreements needed to support system development. Additionally, program 

management did not provide the contractor with adequate guidance, 

requirements input, or data sources to deliver a fully functional system. As 

such, the contractor may not fulfill NBIS capability and schedule 

requirements, which potentially could result in cost increases to the program. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Background 

The President issued two directives in 2004, aimed at improving coordination 

across all federal agency bio-awareness programs. Specifically, Homeland 

Security Presidential Directive (HSPD) 9, Defense of United States 

Agriculture and Food, dated January 30, 2004, charges federal agencies to 

create a new biological threat awareness capacity. HSPD-9 directs the 

Secretary of Homeland Security to coordinate with cross-federal efforts to 

build on updated and improved surveillance systems and create a new 

biological threat awareness capacity that will enhance detection and 

characterization of an attack. Further, HSPD-10, Biodefense for the 21st 

Century, dated April 28, 2004, calls for an integrated and comprehensive 

attack warning system that will assist in recognizing and responding to 

biological attacks on humans, animals, food, water, agriculture, and 

environmental resources. HSPD-10 directs the Secretary of Homeland 

Security to integrate all federal agency efforts to create a national bioawareness system that will detect a biological attack at the earliest possible 

moment and permit initiation of a robust response to prevent unnecessary loss 

of life, economic impact, and social disruption. In addition, in November 

2005, the President issued the National Strategy for Pandemic Influenza, 

which outlines the need for an early warning system to identify possible 

pandemic outbreaks. 

Since 2001, federal agencies collectively have spent an estimated $32 billion 

on electronic surveillance systems and various other IT initiatives to address 

bio-defense. Bio-defense is defined as procedures involved in taking 

defensive measures against attacks using biological agents. Defensive 

measures include research on vaccines and medications, hospital 

preparedness, and protection of water supplies. For example, since 2003, the 

Centers for Disease Control and Prevention has operated its BioSense 

program, which collects data on human health through partnerships with the 

Department of Veterans Affairs, the Department of Defense, and state and 

local entities. DHS, in cooperation with the Environmental Protection Agency 

and the Centers for Disease Control and Prevention, created the BioWatch 

program in 2004 to detect the release of airborne biological agents. In 

addition, the Food and Drug Administration and the United States Department 

of Agriculture, in September 2000 and October 2006 respectively, initiated 

programs to better analyze plant, animal, and human health data available 

within their agencies. Although these individual programs have helped in 

gathering and reviewing sector-specific data, the federal government has had 

no single system for consolidating and examining bio-surveillance across 

federal, state, and local lines. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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DHS’ Science and Technology Directorate began the NBIS program in 2004 

as a means of integrating bio-surveillance information across government. 

The program essentially is composed of three parts: 

• A robust information management system capable of handling large 

quantities of structured and unstructured data; 

• A corps of specially skilled subject matter experts responsible for 

analyzing the data and providing situational awareness; and 

• A culture of cooperation among interagency partners. 

In addition to integrating disparate agency systems, NBIS was designed to 

bring together bio-surveillance data from the various sector-specific systems 

used for human, animal, and plant health surveillance; environmental 

monitoring of air, agriculture, water, and food; and intelligence and threat 

analysis. Such data will be digitally fed into the system, integrated and 

illustrated based on defined ontologies,1 analyzed using specific analytical 

tools, and then disseminated via a web portal. The data flow will be bidirectional, taking the sector-specific information from the relevant agencies 

and fusing it to provide comprehensive situational awareness back to the 

agencies. By correlating “subthreshold” data across the various sectors, NBIS 

can help ensure earlier recognition of biologically significant information and 

events that otherwise might not be reported beyond the originating agency. 

NBIS will incorporate rules, based on participating agency restrictions, to 

ensure protection of the information shared. Figure 1 provides a depiction of 

the NBIS data flow, as initially designed. 

 

1

 Ontologies are data models that represent a set of concepts within a system domain and the relationships between those 

concepts. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Figure 1: NBIS Operating Environment 

NBIS will employ an open architecture using off-the-shelf tools and 

technologies, and operate at the top secret, secret, and sensitive-butunclassified levels. The system will be flexible enough to join the disparate 

underlying IT systems and languages to provide a biological common 

operating picture (BCOP) for the world. This BCOP will assist in detecting 

anomalies or abnormalities caused by intentional or natural biological events. 

Figure 2 provides an illustration of the BCOP, highlighting how the data from 

the various sectors will be fused to identify biological patterns and trends, and 

provide actionable intelligence to facilitate national decisionmaking and 

timely response. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Figure 2: NBIS Program Depiction of the BCOP 

The Government Accountability Office (GAO) discussed NBIS in its June 

2005 report, which focused on federal activities and ongoing IT initiatives 

related to public health and agricultural infrastructure.2

 GAO reported that 

while the Centers for Disease Control and Prevention, Department of Health 

and Human Services, and DHS each have made progress in their respective 

public health IT initiatives, many challenges remain: 

• Integrating current initiatives into a national health IT strategy and 

federal architecture to reduce the risk of duplicative efforts; 

• Developing and adopting consistent standards to encourage 

interoperability; 

• Coordinating initiatives with state and local agencies to improve the 

public health infrastructure; and 

• Overcoming federal IT management weaknesses to improve progress 

on IT initiatives. 

As such, GAO recommended that DHS assess the alignment of its two biosurveillance initiatives, BioWatch and NBIS, with those of other federal 

organizations. 

 

2 Information Technology: Federal Agencies Face Challenges in Implementing Initiatives to Improve Public Health 

Infrastructure, U.S. Government Accountability Office (GAO-05-308, June 2005). 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Results of Audit 

Program Leadership and Support

The NBIS program has not had the sustained leadership and priority needed to 

ensure continued progress toward achieving bio-surveillance systems 

integration goals. Although the program began with a clear mandate, strong 

support, and a strategy for accomplishing the presidential direction, for 

various reasons NBIS ownership has shifted among department organizations 

numerous times, with corresponding fluctuations in the program approach, 

priority, and accomplishments. In addition, NBIS has struggled since its 

inception to secure the staff needed to manage program activities effectively. 

Repeated Changes in Program Ownership and Direction

Sustained leadership and direction are critical to ensure continued 

advancement of any IT program or improvement initiative. Senior executives 

have a major role to play in clearly assigning program sponsorship and 

holding managers accountable for leading the IT change process. With such 

leadership support, program managers can then move forward in establishing 

the management organizations, securing the resources, and guiding the 

directions and steps toward successfully accomplishing program objectives. 

Maintaining a consistent management structure and approach throughout the 

duration of a project can further ensure continuity toward meeting program 

goals. 

However, the NBIS program has not had the benefit of sustained program 

leadership and priority. Although the program began with a clear mandate, 

strong support, and a strategy for accomplishing the presidential direction, for 

various reasons NBIS ownership since has shifted among department 

organizations numerous times, with corresponding fluctuations in the program 

approach, priority, and accomplishments. Figure 3 shows the repeated 

changes in NBIS sponsorship since the program’s inception in 2004. 

Science and 

Technology 

Directorate

2004 2005 2006 2007

IAIP 

Directorate Preparedness Directorate

Office of 

Health

Affairs

NBIS Ownership 2004-present

Office of Chief 

Medical Officer 

(Preparedness 

Directorate)

Science and 

Technology 

Directorate

2004 2005 2006 2007

IAIP 

Directorate Preparedness Directorate

Office of 

Health

Affairs

NBIS Ownership 2004-present

Office of Chief 

Medical Officer 

(Preparedness 

Directorate)

Figure 3: NBIS Ownership and Program Transitions 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Initial Science and Technology Accomplishments

NBIS initially flourished under the leadership of the Science and Technology 

Directorate. In early 2004, DHS assigned the initial design work for this new 

effort to the directorate because, at the time, it had the technical knowledge 

and resources necessary to effectively undertake a public health program. 

Science and Technology was working daily with federal stakeholders on other 

bio-surveillance initiatives, such as the BioWatch program. The directorate 

used the contacts and experience gained through such programs to help 

identify an approach to developing an integrated bio-surveillance system. 

Specifically, the directorate held meetings with senior officials of the various 

federal stakeholders to determine the feasibility of a new system and draft a 

statement of work. During these meetings, the directorate also discussed 

scenarios for NBIS operations, data sharing challenges, and steps toward 

forging interagency cooperative agreements. 

Under Science and Technology direction, the program made good first steps 

in initiating system design. Since funds had yet to be appropriated for the 

NBIS program, in July 2004, Science and Technology used $1.686 million of 

its budget to contract for the initial architecture design study, known as NBIS 

1.0. Science and Technology coordinated meetings with interagency 

representatives to obtain their assistance in evaluating vendor proposals and 

making the contract award decision. Subsequently, the stakeholders also 

assisted the contractor in formulating general system requirements and 

participated in a series of system design reviews to help validate these 

requirements. All such activities served to build a sense of community among 

federal agency participants. 

Program Changes Under IAIP 

Due to its transfer to the former Information Analysis and Infrastructure 

Protection (IAIP) Directorate in January 2005, the NBIS program lost 

momentum generated during the Science and Technology design study phase. 

The program appointed a new program manager, a contractor to oversee NBIS 

development, but this official had minimal assistance. Because the program 

received limited office space, the program manager was hindered in efforts to 

bring on board additional staff or detailees to assist with activities such as 

stakeholder outreach, contract management, and information analysis. Also, 

although the program manager suggested awarding a sole source contract to 

expedite development of the IT system, NBIS 2.0, DHS determined that the 

contract should be competitively bid to ensure it was awarded fairly and 

objectively. The additional time required to competitively bid the contract 

contributed to delays in NBIS 2.0 development. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Increased Priority, But Contract Challenges Remained Under 

Preparedness

The NBIS program received limited attention in the initial months after being 

reassigned from IAIP to the new Preparedness Directorate (Preparedness). 

This directorate, focused on preparedness and response, was one of three 

organizations established after DHS reorganized IAIP in July 2005. Program 

management attempted to encourage program progress in August 2005 by 

awarding a contract, at a cost of about $123,000, for development of a 

prototype system known as NBIS Lite. This prototype was a basic database 

designed to receive and store bio-surveillance data from open sources, such as 

ARGUS, an information gathering tool sponsored by Georgetown University. 

ARGUS integrates and catalogs biological indicators and threat warnings 

gathered from open source information, such as news releases, reports, or 

other publicly available media. 

The contractor created and demonstrated the prototype system, which also 

received initial authority to operate on the DHS network. However, NBIS 

Lite had limited capability and was not robust enough for widespread use. 

The program needed additional funding for a follow-on development contract 

to achieve full functionality. Program managers awarded the follow-on 

contract in August 2006, but ultimately decided not to proceed with this effort 

after progress was concurrently made in getting the full-scale system, NBIS 

2.0, in place. 

The Administration’s spotlight on bio-defense and pandemic issues helped 

ensure increased priority and leadership attention for the NBIS program. 

Specifically, in a November 1, 2005, speech at the National Institutes of 

Health, the President discussed his bio-surveillance initiatives, including 

NBIS, capturing the attention of senior Preparedness officials. (See Figure 4.) 

Program officials said that prior to the President’s speech, they sensed no 

urgency by Preparedness leadership to promote a functioning NBIS program. 

However, following the President’s speech, the program received additional 

support in terms of office space and contract personnel. For example, an 

NBIS management official explained that the program was assigned office 

space in a secure location, affording program management not only ample 

room to work and house additional staff, but also the facilities needed to 

handle potentially sensitive bio-defense information. Further, existing 

contract vehicles were used to bring contract staff on board to support NBIS 

program activities. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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To strengthen domestic surveillance, my administration is launching 

the National Bio-surveillance Initiative. This initiative will help us 

rapidly detect, quantify and respond to outbreaks of disease in humans 

and animals, and deliver information quickly to state, and local, and 

national and international public health officials. By creating systems 

that provide continuous situational awareness, we're more likely to be 

able to stop, slow, or limit the spread of the pandemic and save 

American lives. 

Figure 4: President G.W. Bush Speaking on Pandemic Influenza 

With the added support, the program manager was able to move the program 

forward in a number of ways. Specifically, a new staff member was assigned 

to manage NBIS planning and policy formation, provide briefings to market 

the program, and initiate discussions with interagency stakeholders 

concerning the memoranda of understanding needed to govern their 

participation in the NBIS program. The program manager used the secure 

office space to establish a 24-hour watch capability. Watch staff were 

responsible for conducting nonstop research and analysis on biological events 

and their impacts worldwide, and producing bio-surveillance reports for DHS 

and federal agency stakeholders. Distributed daily and weekly, these 

situational reports included both new developments and updates on previously 

reported information. Further, another newly acquired employee with a 

biological science background assisted watch staff efforts by determining the 

types of data needed to perform bio-surveillance and developing catalogues 

that describe the protocols for and implications of reported outbreaks of 

various diseases. By late 2005, the NBIS program had distributed a first draft 

of the interagency memorandum of understanding for comment, developed an 

audience for its situational reports, and determined the types of information 

that NBIS, once implemented, should report to meet bio-defense mission 

needs. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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However, the additional resources alone were not adequate to help move the 

program forward to contract award without further setbacks. For example, as 

the NBIS program prepared in early 2006 to issue a request for proposals for 

NBIS 2.0 development, the Office of Procurement Operations assigned a new 

contracting officer to the program. This official tasked the NBIS program to 

refine the proposal language, thereby delaying the contract by several months. 

Moreover, in February 2006 when the program was ready to issue a request 

for bid, the Office of Procurement Operations decided to use the department’s 

new Enterprise Acquisition Gateway for Leading Edge Solutions program to 

award the NBIS 2.0 contract, even though DHS had not yet finalized this 

contract vehicle. DHS will use the Enterprise Acquisition Gateway for 

Leading Edge Solutions contract vehicle to purchase a range of IT services to 

support the department’s mission of securing the homeland. This contract 

vehicle constitutes DHS’ preferred method to obtain end-to-end solutions for 

IT development, deployment, operations, and maintenance. Because NBIS 

2.0 was the first contract awarded using this vehicle, significant revisions 

were required to restructure the contract to meet the new documentation 

format. This rework delayed the contract by a few more months. 

The Preparedness Directorate assigned a full-time employee to help overcome 

these challenges and prepare the NBIS program for projected transition to the 

Office of the Chief Medical Officer. Recognizing that program funding 

would no longer be available once appropriations expired by the end of the 

fiscal year, the program manager gave priority attention to working with the 

Office of Procurement Operations and closely monitoring contract 

management processes to get the NBIS 2.0 contract in place. On 

September 28, 2006, DHS finally succeeded in awarding a $14.3 million 

contract for NBIS 2.0 development—albeit well over a year after the contract 

award time frame anticipated when the program first began. 

Program Redirected Again Under Office of Chief Medical Officer 

Concurrent with NBIS 2.0 contract award, program ownership shifted once 

again. This time, DHS moved NBIS to the Office of the Chief Medical 

Officer (OCMO), where the program focus changed to become more medicalbased and risk-averse in sharing information, versus the prior emphasis on 

situational awareness and response under Preparedness. In line with the new 

focus, the NBIS program decided to seek personnel with medical training and 

public health knowledge and expertise to staff the 24-hour watch capability. 

Despite positive feedback from stakeholders who had received the 

publications, in October 2006, OCMO management decided to stop 

distributing the situational awareness reports begun in 2005 under 

Preparedness. Although several stakeholders appreciated the publications, 

OCMO officials said that they included inconsistent interagency input, 

provided little or no medical oversight, and contained inaccuracies, as 

reported by subject matter experts. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Despite the changes in program focus, the NBIS program benefited from 

increased senior-level support and priority under OCMO. For example, the 

Chief Medical Officer assigned a new director and program manager for 

NBIS, and instructed the director to give the program top priority. With this 

heightened support, the program director and manager have been able to 

pursue additional personnel to assist with program development. Principally, 

this has included hiring contractors to support watch operations, conduct 

stakeholder outreach, and manage program activities. 

The NBIS program received even greater visibility when OCMO was elevated 

within DHS in March 2007 to form part of the newly created Office of Health 

Affairs (OHA). This shift consolidated NBIS and other biological and 

chemical threat programs, such as BioWatch, under one office, reporting 

directly to the DHS Secretary and Deputy Secretary. The NBIS program 

manager said that the Secretary is optimistic about NBIS; program officials 

are scheduled to brief the Secretary every 90 days on program progress. As a 

sign of support for OHA’s authority in managing bio-threat programs, the 

President has requested an increase in the office’s funding, from $5 million in 

FY 2007 to $118 million in FY 2008. 

Program Staffing

Leading organizations assign adequate human resources to help ensure 

successful accomplishment of their IT initiatives. However, with NBIS 

experiencing inconsistent leadership, the program has struggled since its 

inception to secure the staff needed to manage program activities effectively. 

For example, it was not until May 2006, when the program was under the 

auspices of Preparedness, that a full-time DHS program manager was 

assigned. Prior to this time, for about one and half years, the program was led 

by a detailee, who encountered roadblocks in obtaining needed information 

and working through unfamiliar DHS processes to carry out assigned program 

management responsibilities. As an external agency employee, this official 

also had problems getting the hiring authority to bring additional staff into 

DHS. This official, along with subsequent NBIS program managers, needed 

personnel of all types—full-time government employees, detailees, and 

contractors—to help support the program. 

Initially, NBIS sought interagency detailees to manage program activities, but 

arranging to bring them on board was problematic. For example, despite 

assurances from senior leadership that temporary staff would be made 

available, the first NBIS program manager, who was also a detailee, faced 

barriers to acquiring other detailees to support program efforts. First, the 

general shortage of personnel meant a lack of staff to develop and coordinate 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 12 

the interagency agreements needed to govern the personnel exchanges. 

Second, the agencies that considered lending personnel to DHS to support 

NBIS would not agree to do so until sufficient office space was arranged to 

house them. DHS had not yet provided the NBIS program the office space 

needed. 

NBIS also has looked to contractor personnel as an alternative means of 

staffing. As previously discussed, following the President’s speech in 

November 2005 that drew priority attention to the program, there was an 

influx of contractors to assist with the NBIS program. Specifically, the 

program used existing contract vehicles to bring in 8-10 contract staff. These 

contractors helped support the NBIS watch capability, reporting, stakeholder 

outreach, and IT contract management. Since that time, additional contractors 

have been added to assist with program management activities such as 

planning, policy formulation, outreach, and coordination of interagency 

agreements on data sharing and personnel exchanges with federal 

stakeholders. 

Although the contractor support has been beneficial, the program still needs 

adequate full-time federal employees to oversee contractor activities. This 

need for additional employees was documented in the September 2006 “OMB 

300” program business case, which advised hiring additional full-time 

program staff. Further, the NBIS program lacked specialized personnel in 

several key areas. For example, the program does not have sufficient staff, 

such as public health officials, to analyze and process biological information. 

The program has not fully staffed analyst positions needed to provide 

expertise in reviewing and interpreting NBIS information on the range of 

agriculture, human, and environmental matters. The program also needs a 

staff representative to coordinate with the intelligence community and gain 

access to the information needed for bio-surveillance analysis and reporting. 

The statement of work says that NBIS 2.0 should integrate intelligence data 

into the system. However, the staff member with biological and defense 

subject matter expertise who initially served as liaison to coordinate such 

matters left the program in late 2006 and has not yet been replaced. 

These staffing challenges have been complicated by high turnover rates 

among the staff positions that the program did acquire. For example, the 

program has had four program managers since its inception. For the most 

part, turnover among these officials was due to changes in program 

ownership. It nonetheless has resulted in a loss of institutional knowledge and 

a lack of continuity in program management direction. For example, whereas 

the Preparedness program manager promoted collaboration and teamwork, 

OCMO program managers have guided the various aspects of the program in 

more of a “stovepipe” manner. Disconnected from the technical management 

aspects of the program due to the stovepipes, one official said that NBIS staff 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 13 

no longer have a good understanding of the direction in which the program is 

headed. 

In recent months, the NBIS director responsible for governing the program 

within OCMO acknowledged that the program needs more staff resources and 

cannot continue to run primarily on a contractor supported basis. The 

program manager said that although OHA management approved hiring seven 

additional full-time employees to oversee functional program areas, the office 

delayed announcing these positions until after March 31, 2007, when its new 

organization became official. Specifically, OHA approved the billets for GS14 and GS-15 federal employees in each of its four divisions: Program 

Management, Administration, and Business Support; Operations; Plans, 

Policy, and Outreach; and Information Technology. As of April 2007, these 

vacancies had not yet been announced. Until these inherently government 

positions are filled, the program will continue to rely on contractors to fill the 

void. Figure 5 displays the current organization chart for the NBIS program, 

showing full-time staff positions as well as vacancies. 

NBIS Director

NBIS Deputy 

Director

Program Management 

Administration and 

Business Support

GS-15 (Vacant)

Operations 

GS-15 (Vacant)

Plans, Policy and 

Outreach 

 GS-15 (Vacant)

Information 

Technology

GS-15 (Vacant)

Analysts 

- 5 Staff Positions

1 Pending 

3 Vacant

Watch

- 6 Staff Positions 

1 Vacant

- GS-14 (Vacant)

- 3 Staff Positions

1 Pending 

1 Vacant

- GS-14 (Vacant)

- 3 Staff Positions

- GS-14 (Vacant)

- 2 Staff Positions

1 Vacant

Figure 5: NBIS Organization Chart, as of March 2007 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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NBIS Program Execution 

Because of repeated changes in program leadership and direction, and a need 

for staff support, DHS has not effectively executed the NBIS program. A 

number of the planning documents needed to guide IT development have yet 

to be finalized. Further, NBIS program management has not effectively 

communicated and coordinated with stakeholders to secure their commitment 

to provide the data and personnel needed to support system development. 

Key security and privacy issues related to bio-surveillance data sharing remain 

unaddressed. Additionally, program management did not provide the 

contractor with adequate guidance, requirements input, or data sources to 

deliver a fully functional system. As such, the contractor may not fulfill the 

system capability and schedule requirements for NBIS development, which 

potentially could result in cost increases to the program. 

Program Planning 

The Government Performance and Results Act of 1993 (Section 2, Findings 

and Purposes, Public Law 103-62) was enacted to help federal managers 

improve service delivery by requiring that they plan for meeting program 

objectives. Program planning should include a description of how goals and 

objectives are to be achieved, as well as details on the operational processes, 

human capital, information, technology, and other resources needed to meet 

those goals. Where program goals are insufficiently articulated, federal 

managers are seriously disadvantaged in their efforts to improve program 

efficiency and effectiveness. 

Despite such guidance, planning to support the NBIS program has not been 

adequate. In September 2006, Preparedness officials submitted a business 

case to the Office of Management and Budget to justify the investment and 

establish the NBIS program framework. This business case outlines the NBIS 

vision for developing a collaboration tool to complement and interoperate 

with existing bio-surveillance systems of other federal government agencies. 

The business case and supporting documentation also discuss at a high-level 

the strategic goals, milestones, costs, staffing levels, and performance 

measures for accomplishing the program. As such, the business case provides 

the foundation for additional, more detailed planning by which to guide the 

program. 

However, NBIS does not have an up-to-date plan at the tactical, more detailed 

level for managing day-to-day program activities in support of system 

development. In September 2006, concurrent with developing the business 

case, Preparedness officials began drafting a program plan for NBIS. The 

draft includes limited discussion of the end-state for NBIS; how the system 

will operate to collect, collate, and provide context for bio-surveillance 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 15 

information; and the tools that will be integrated into the system to expand 

situational awareness. However, NBIS transferred to OCMO before the 

program officials who began drafting the plan could complete it or get it 

approved. 

Initially, OCMO did not focus on creating an approved program plan given 

competing priorities, such as securing staff resources and data sharing 

agreements. At the time, the office did not have the staff available to devote 

to planning activities; the program manager was working alone to carry out a 

range of program activities, such as stakeholder outreach and defining 

requirements, which consumed his time. However, as of March 2007, the 

NBIS program plan was still in draft. 

Without a tactical plan to guide program directions and decisions, NBIS 

program managers have been managing in an ad hoc manner. For example, 

without clear program milestones, NBIS managers have been unable to track 

accomplishment of program activities or monitor progress toward meeting 

long-term goals. An NBIS official cautioned that the program must first 

define its “as is” and “to be” architectures before management can establish 

milestones for measuring program progress. 

Recognizing the potential consequences of inadequate plans to guide program 

activities and decisions, NBIS officials have recently taken steps to correct 

this situation. For example, in April 2007, program branch chiefs hosted an 

off-site workshop to address program priorities. The goals of this workshop 

were to develop functional descriptions of staff roles and responsibilities, a 

mission statement for at least one program division (Operations), an 

organization chart, and a master schedule of program development milestones. 

The branch chiefs also developed a strategy for improved communication and 

coordination in conducting program activities. Further, the branch chiefs 

discussed how NBIS fits into the overarching DHS enterprise architecture 

goals and worked to finalize an NBIS concept of operations. Program 

managers have initiated similar discussions to define the final capabilities for 

the system, including what information NBIS should acquire, and what 

outputs it should offer. 

Outreach to Ensure Stakeholder Involvement 

A major concept of HSPD-9 and -10 is that DHS should coordinate with other 

federal agencies to create a coordinated biological threat awareness and 

detection capability. Similarly, a supplement to Office of Management and 

Budget Circular A-11 directs federal agencies to reduce project risk by 

involving stakeholders in the requirements definition process to ensure that IT 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 16 

assets meet mission and user needs.3 Further, a task order request pursuant to 

the NBIS 2.0 contract also encourages user cooperation in the iterative and 

incremental system development process. 

Initial Outreach To Federal Agency Stakeholders

In 2004, Science and Technology began NBIS outreach activities by hosting a 

series of meetings to involve federal agency stakeholders in early system 

design planning and review. An NBIS management official said that 

approximately 40 representatives from a range of stakeholder organizations 

attended these sessions. One stakeholder said that program officials used 

these meetings to discuss NBIS goals and how the system would operate to 

meet the needs of the user community. Subsequently, in 2005, NBIS hosted 

tabletop exercises and planning meetings with stakeholders to consider 

biological event scenarios and provide updates on NBIS program activities. 

Collectively, these meetings helped forge broad interagency cooperation, 

develop trust, and ensure buy-in for the NBIS approach.

As previously discussed, situational reports distributed to DHS components 

and other federal, state, and local agencies on a routine basis during 2005 and 

2006 also facilitated communications and coordination with NBIS 

stakeholders. The 24-hour watch function, established to monitor biological 

events worldwide, helped produced the daily reports. The watch officers 

would research and compile information on the pathogens and then draft the 

reports. The reports were then reviewed for content and edited, and upon 

approval, disseminated to stakeholders in the afternoon. Along with NBIS 

program officials and DHS component representatives, a number of federal 

agencies participated or provided routine input in the process of reviewing and 

finalizing the reports. This process generally yielded two different types of 

reports: publications on outbreaks of general diseases such as E. Coli or 

salmonella, and supplemental information on avian influenza. 

According to NBIS officials, stakeholders found the reports highly useful in 

that they provided broader, more in-depth coverage than other existing 

sources. The reports were important to advancing the NBIS approach of 

integrating bio-surveillance information in one central location. The reports 

also heightened trust in sharing information and raised expectations among 

stakeholders that they would continue to receive some sort of NBIS product or 

publication while system development was ongoing. 

 

3

 Office of Management and Budget Circular No. A-11, Part 7, Planning Budgeting, Acquisition, and Management of 

Capital Assets, Executive Office of the President, Supplement, June 2006. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 17 

Communication and Coordination Needed to Sustain

Stakeholder Commitment

As NBIS ownership was transferred from one DHS component to the next, 

continuity of operations was disrupted. For example, one federal agency 

representative told us that each time there was a change, the new program 

leadership had to be reeducated on the inner workings of the stakeholder 

agency, creating a sense that no progress was being made in NBIS 

development. Further, the new program managers did not ensure effective 

communications to sustain working relationships with federal agency 

stakeholders. As successive management teams introduced new processes and 

approaches to accomplishing NBIS development, the mission and vision for 

the interagency system became less clear and agency stakeholders struggled to 

keep up with the transitions. Disengaged and lacking communications from 

program officials, agencies had no effective means of keeping abreast of 

program direction and status. During lengthy communication lapses in 2005, 

several stakeholders questioned whether NBIS was still being developed at 

all. Moreover, when U.S. Department of Agriculture representatives offered 

help in developing interagency agreements to move the program forward, 

NBIS managers did not follow up or communicate effectively to accept their 

offer. Given the lack of communications to keep them engaged, federal 

stakeholders’ commitment and support for the NBIS program declined. As 

the program lost credibility, stakeholders began to doubt that anything would 

ever result from the initiative. 

Conversely, coordination with NBIS in some areas helped stimulate internal 

federal agency efforts to improve systems and processes for managing biosurveillance information. For example, the Department of Agriculture is 

creating an NBIS-like system that will integrate, analyze, and monitor 

agriculture and food safety data maintained in its various subagency systems. 

Proof of concept for this system was scheduled for March-April 2007. 

Similarly, in September 2000, the Food and Drug Administration began 

developing an integrated, web-based, information network to allow health 

officials engaged in food safety activities at multiple government agencies to 

compare, share, and coordinate laboratory analysis findings. These two 

agencies have not yet determined how these systems will potentially share 

information with NBIS. 

Coordination with Stakeholders on Data Sharing

NBIS program managers have not effectively coordinated with interagency 

stakeholders on the data resources needed to support IT system development. 

In 2004, NBIS officials began high-level discussions with interagency 

stakeholders concerning establishing partnership agreements, as well as 

determining the types of data needed to support system operations. Despite 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 18 

these initial communications on data sharing matters, there was little follow 

up with stakeholders to refine the details. As program officials focused 

increasingly on getting the NBIS 2.0 contract in place and managing the 

repeated transfers of program ownership, the data issues received less 

attention. According to stakeholders, NBIS program managers still had not 

defined the details as to what data would be needed and how it would be 

supplied to NBIS. One official said that NBIS managers had not conducted an 

information needs assessment to define specific data requirements to support 

system operations. 

After the NBIS 2.0 contract was awarded in September 2006, the need for 

data once again came to the fore. By this time, the contactor had begun 

system development and needed interagency bio-surveillance information to 

populate NBIS and test its operations. Because the task order request 

promised that data would be available, NBIS program managers reached out 

once again to agencies to put data sharing agreements in place. Specifically, 

the approach was to draft broad memoranda of understanding on stakeholder 

participation, get the memos signed, and then determine the details later. 

Subsequent interagency agreements would be used to govern the details of the 

data sharing arrangements, i.e., what data would be shared and through what 

means, along with such matters as the exchange of personnel, information 

security, and IT systems interfaces. The Chief Medical Officer transmitted a 

memorandum of understanding signed by the DHS Deputy Secretary to 

stakeholders on December 26, 2006. By February 2007, five agencies4

 had 

agreed to sign the document and participate in the program. 

However, subsequent efforts by NBIS program officials to work out the 

details of these interagency partnerships were not effective. Specifically, in 

January 2007, NBIS officials requested meetings with the Departments of 

Defense and Interior, two key stakeholder agencies, to establish data sharing 

arrangements as a prelude to forging interagency agreements. However, 

program officials held the meeting with Defense representatives without first 

identifying NBIS data needs to support a meaningful discussion as to what 

information the agency might provide. A Defense official said that NBIS 

program officials needed to schedule a follow up meeting for a later date, after 

they had more specifics about NBIS data requirements. As of late March 

2007, program officials had not yet reached agreement with any federal 

stakeholders on when and how data would be supplied to support system 

operations. 

In the absence of interagency agreements, program officials have not been 

able to secure the federal data needed to test or develop the NBIS system. To 

proceed with some level of system development until the federal data is 

 

4

 The five agencies included; U.S. Department of Agriculture, Department of Defense, Department of Health and Human 

Services, Department of the Interior, and Department of State. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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acquired, the program pursued open source information to populate the NBIS 

database. As a result, as of March 2007, the NBIS system contained only 

publicly available information, such as reports from the World Health 

Organization, the Organization for Animal Health, and the European 

Commission, which can be obtained via the internet. This approach to using 

open source data has helped further NBIS 2.0 development activities; 

however, it has not fulfilled HSPD guidance for integrating the biosurveillance information of the various federal agencies. 

In attempts to get back on track, NBIS program officials have modified their 

approach to acquiring bio-surveillance data once again. Specifically, in 

March 2007, NBIS staff met with contractor representatives to develop a twotiered approach to securing data sources. This approach involves continued 

use of open source data, but concurrent pursuit of federal information, which 

will take more time to acquire. NBIS officials said that priority remains on 

ensuring access to federal data sources. Officials said that with this approach, 

they can increase the amount of data provided to NBIS and also advance 

system development efforts. 

 Information Security and Privacy Concerns

In conjunction with not getting the data sharing agreements in place, NBIS 

officials also did not effectively coordinate with federal stakeholders to 

address concerns about the privacy and security of data shared. Without 

NBIS program officials first defining what information NBIS needs, there is 

little basis for stakeholders to determine what information might be released 

by their agencies. For example, one stakeholder said that any release of 

sensitive or inaccurate information about U.S. agricultural products could 

have serious repercussions on exports and trade. Other stakeholders 

expressed similar concerns about releasing human health data. For example, a 

stakeholder said that, according to the Health Information Portability and 

Accountability Act of 1996, Public Law 104-191, information on human 

populations generally cannot be shared outside of the public health 

community without prior authorization. 

Interagency agreements can help outline basic data handling procedures and 

prescribe the measures that partner agencies should take to ensure the security 

of shared data. NBIS program officials have developed a general interagency 

agreement to address these information security and privacy issues. NBIS 

officials plan to use the draft agreement as a mechanism for coordinating with 

stakeholders on what systems will feed NBIS. As of March 2007, however, 

this document was still in draft and had not been finalized with any 

stakeholder agency. Until the NBIS program coordinates these issues, 

officials cannot know the full range of privacy and information security 

implications for each agency data source. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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Guidance for Contractor Efforts

Office of Management and Budget Circular A-11 directs agencies to employ 

good management disciplines to ensure that programs achieve intended cost, 

schedule, and performance outcomes. More specifically, the circular directs 

federal agencies to provide clear guidance and support to ensure contractor 

activities and products deliver intended benefits. Further, agencies are to 

reduce project risk by involving stakeholders in the requirements definition 

process to ensure that IT assets meet mission and user needs. 

 Functional System Requirements

NBIS program management did not provide the contractor with adequate 

guidance to support system development activities. NBIS 2.0 was proposed 

as an iterative developmental system, for which methods, requirements, and 

data sources were to be identified in the course of system development. As 

such, program management established general system requirements at the 

outset, but tasked the contractor to develop more detailed requirements as the 

program evolved. Specifically, the task order request includes a broad 

statement of objectives regarding what the system is intended to do to enhance 

detection and awareness of biological events and support the exchange of biosurveillance information among agencies. 

The task order request also addresses high-level technical requirements that 

NBIS integrate stakeholder systems, be bi-directional to provide 

comprehensive situational awareness back to the agencies, and ensure 

protection of the information shared based on participating agency 

restrictions. The document does not provide detailed procedures on how the 

contractor is to develop the system to meet these requirements; rather, the 

contractor is to outline these strategies for subsequent DHS approval. As 

system development activities progress, NBIS program management is to 

incrementally provide additional guidance to support contractor efforts and 

ensure complete coverage of the statement of objectives. 

Based on the limited guidance, the contractor proceeded to outline a statement 

of work, program management plan, quality assurance plan, configuration 

management plan, risk management plan, and implementation plan for 

moving forward. The contractor also created a basic framework for NBIS to 

demonstrate limited system capabilities. However, NBIS management did not 

provide the supplemental guidance as promised to support continued 

contractor efforts. Specifically, NBIS management did not provide a concept 

of operations, outlining the strategies, policies, and operational processes for 

implementing the system with full functionality. This document was due to 

the contractor at the time of contract award in September 2006. The 

contractor’s monthly earned value reports for NBIS 2.0 development, from 

October 2006 through February 2007, identified the continued lack of this 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 21 

document as a risk to system development. As of April 2007, NBIS program 

management had not officially approved a concept of operations; the 

document had undergone several iterations and was still under review. 

User Requirements

Although user input is critical to the requirements definition process, NBIS 

management also did not ensure that subject matter expert personnel were 

available to support the development effort. The contractors needed user 

input to understand how to automate routine business processes for analyzing 

bio-surveillance information. For example, contractors needed to know 

frequently used sources for such information, types of data needed to perform 

analysis, and the content and structure of reports generated to share biosurveillance information among the user community. As such, the contractor 

expressed an interest in October 2006 in meeting with NBIS watch officers to 

discuss how they might use the system. The contractors also wanted to meet 

with interagency analysts to determine how the system might be developed to 

address their individual agency requirements. 

Although the contractors began NBIS 2.0 development in October 2006, they 

were not able to obtain any form of interagency user input until April 2007 

when NBIS program managers held focus group sessions with interagency 

representatives to discuss their user needs. Up until that time, new NBIS 

program management focused on competing program management activities 

such as acquiring staff and securing access to the data needed for system 

development. Additionally, as previously discussed, NBIS program managers 

had not established the interagency agreements needed to secure interagency 

participation in defining NBIS 2.0 user needs. In April 2007, however, 

recognizing the contractors’ need for user requirements to support achieving 

full operating capability by September 2008, NBIS program management 

finally brought users in from selected stakeholder organizations to dialogue 

openly on what they expected from the system. 

Similarly, internal DHS end users have had only limited involvement in 

defining user requirements. NBIS contractors expected to meet with watch 

officers and subject matter experts that the program intended to bring on 

board. However, the subject matter experts, who would use NBIS tools to 

perform bio-surveillance information monitoring on a daily basis, had not yet 

been hired. Watch officers were the only potential users of the system already 

in place. Nonetheless, in January 2007, the program manager told us of a 

decision to have NBIS administrative and management personnel, acting as 

users, meet with the contractor to provide user requirements instead. Program 

management ultimately coordinated a meeting between the contractor and 

watch officers in March 2007 but, for the most part, NBIS administrative and 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 22 

management personnel will continue to be the primary source for user 

requirements. 

Delays in Providing Needed Data Resources

NBIS program officials were not timely in providing the contractor with the 

federal data resources they needed to support system development. For each 

of the first two phases of NBIS 2.0 development after contract award in 

September 2006, the contractor requested that NBIS program officials provide 

three data sources for use in populating and testing the system. The first time, 

program management responded by identifying two sources, the Global 

Disaster Alert and Coordination System, and EpiSpider ProMed, which 

provide biological or medical surveillance data via the internet. The two 

sources were integrated into the system in time for the initial NBIS 2.0 

demonstration in January 2007. Program management was not able to execute 

the nondisclosure agreements necessary to use a third source, Georgetown 

University’s ARGUS information gathering tool. 

Further, NBIS program management was late in providing the contractor with 

three additional data sources needed for the second phase of system 

development, which began in November 2006. The contractor had requested 

that NBIS management arrange access to those sources by late January 2007; 

however, NBIS program managers did not officially approach the owners of 

two identified data sources, Wildlife Mortality Database (EPIZOO) and 

Electronic Surveillance System for the Early Notification of CommunityBased Epidemic (ESSENCE), until that same month.5

 At that time, NBIS 

managers learned that they could neither arrange data access to meet the 

January 2007 deadline, nor ensure a date as to when access would be possible. 

Due to the delays in acquiring the sources, in March 2007 NBIS management 

once again substituted open source data feeds to sustain development. This 

was about two months later than the timeframe for which the contractor 

needed to support system development. Additionally, program managers still 

had not secured a nondisclosure agreement for contractor to access to 

ARGUS, the third data source, by the January 2007 time frame. 

Contractor May Not Meet Schedule and Requirements for NBIS 

Development

Because program management did not provide adequate system guidance, 

user input, and data sources to support system development activities, the 

contractor has made limited progress in executing the NBIS 2.0 contract. 

 

5

 EPIZOO is a U. S. Geological Survey database documenting over 25 years of information on epizootics (epidemics) in 

wildlife. EPIZOO tracks die-offs throughout the United States and its territories, primarily among migratory birds and 

endangered species. Further, ESSENCE is a prototype system developed by the Department of Defense for early 

detection of human infectious disease outbreaks. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

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First, without clear guidance on system needs and functionalities, the 

contractor is spending valuable time and resources determining the system 

design, processes, and products needed to fulfill NBIS program objectives. 

For example, while the statement of objectives establishes broad guidance for 

NBIS to integrate, monitor, and analyze bio-surveillance information across 

federal agencies, the program office has not provided additional guidance or a 

concept of operations to guide contractor activities. As a result, the contractor 

has relied on its own in-house disease specialists to draft functional 

requirements, including how to structure and sort biological information 

supplied to the system—an approach that may not adequately satisfy NBIS 

mission requirements. 

Second, without user input the contractor was unable to gather and integrate 

DHS and stakeholder requirements in the initial demonstration of NBIS 2.0 

capabilities. Specifically, without the opportunity to interact with system 

users to determine their preferences regarding report format or content, the 

contractor could only present generic, analytical reports of bio-surveillance 

information as a part of its January 2007 NBIS 2.0 demonstration. Such 

reports provided a general illustration of what the system could produce, but 

may not be a true reflection of the types of NBIS products that users really 

need or want. It remains unclear as to whether or how user requirements will 

be incorporated at initial operating capability for NBIS 2.0, which is expected 

for June-July 2007. 

Third, the lack of federal data to support NBIS development has hindered 

contractor efforts in several ways. In particular, the contractor has been 

unable to build and test system functionality, such as how interagency 

information will flow within NBIS 2.0 and then be sorted, integrated, and 

analyzed to support government-wide bio-surveillance. Further, because DHS 

did not provide adequate data for the first stage of NBIS 2.0 development, the 

contractor had to develop a synthetic data set to support testing of the 

analytical tools needed for continued system development. 

Overall, because of the lack of data, the contractor has struggled to meet 

scheduled program milestones, which could have an adverse effect on contract 

costs. Specifically, initial operating capability for NBIS 2.0 was projected for 

April 2007; however, delays in receiving the data needed to ensure system 

functionality postponed delivery by approximately three months, to June-July 

2007. This delay is significant when combined with the fact that the system 

projected for delivery at this time may have limited functionality due to the 

lack of user input and adequate data sources. The contractor submitted an 

unofficial proposal, outlining suggestions for modifying the NBIS 2.0 contract 

and adjusting the system development schedule. As of April 2007, program 

management had not yet made a decision on this proposal. However, pushing 

back these interim dates could have the ultimate effect of delaying full 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 24 

operational capability, the date when contractor is scheduled to deliver the 

system, which is set for March 2008. Further, an NBIS official said accepting 

the modifications could potentially increase the contract cost by $2.8 million, 

beyond the initial award cost of $14.3 million. 

Recommendations 

We recommend that the Assistant Secretary and Chief Medical Officer of the 

Office of Health Affairs ensure that NBIS program management: 

Recommendation #1: Assess NBIS staffing needs and apply adequate 

resources to effectively oversee and support program management activities. 

Recommendation #2: Develop and implement a program plan identifying 

program activities, milestones, and outcomes needed to develop an integrated 

bio-surveillance system as required by HSPD-9 and -10. 

Recommendation #3: Develop a concept of operations, outlining functional 

and user requirements for NBIS 2.0 to the IT system contractor. 

Recommendation #4: Develop a plan aimed at improving NBIS outreach and 

communication with stakeholders to ensure commitment and participation in 

the creation of an integrated bio-surveillance system.

Recommendation #5: Perform an information needs assessment, outlining 

interagency data content requirements to support NBIS 2.0 operational 

capability. 

Management Comments and OIG Analysis

 

We obtained written comments on a draft of this report from the Assistant 

Secretary and Chief Medical Officer for the Office of Health Affairs. We 

have included a copy of the comments in their entirety at Appendix B. 

In the comments, the Assistant Secretary concurred with all of the findings 

and recommendations in our report. The Assistant Secretary said that since 

the conclusion of the audit, significant accomplishments have been achieved 

that directly apply to the audit recommendations. In an attachment to these 

general comments, and in response to each of our report recommendations, 

the Assistant Secretary summarized progress that the NBIS program has 

made. We believe that such efforts are good steps toward addressing the 

various issues we raised in our report and look forward to learning more about 

continued progress and improvements in the future. 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 25 

Responding to Recommendation 1, the Assistant Secretary commented that 

NBIS management has worked to address staffing issues since August 2006, 

and more recently, since the formation of the Office of Health Affairs. 

Specifically, NBIS management has assessed staffing needs through FY 2008, 

put a staffing plan into place, and requested resources for personnel to support 

NBIS activities. In addition, the Assistant Secretary explained that the NBIS 

program is working to hire government employees to fill positions, which 

have been occupied by contract personnel; the program has advertised four 

federal employee positions for management slots and selected seven members 

of the U.S. Public Health Service to provide improved expertise and 

continuity for the 24/7 watch function. Further, a contractor support 

assessment was conducted to identify the nature and extent of future 

contractor requirements. 

In response to Recommendation 2, regarding the need for a program plan, the 

Assistant Secretary indicated that the program has contracted a project 

manager to develop a master schedule, consisting of a work breakdown 

structure and a chart to track the project’s timelines. These documents outline 

tasks, deliverables, and timelines from January 2007 through full operational 

capability in September 2008. Also, the Assistant Secretary noted that these 

planning documents are updated weekly and tracked by the Secretary.

The Assistant Secretary outlined various efforts to address Recommendation 

3, regarding development of a concept of operations. The Assistant Secretary 

acknowledged the importance of a cross-cutting concept of operations and, as 

result, has enlisted a contractor to develop this document. In addition, the 

program addressed certain system requirements by developing standardized 

daily reports for interagency partners. Further, the NBIS program will solicit 

input on the concept of operations from four interagency customer focus 

groups. 

The Assistant Secretary discussed NBIS’ commitment to outreach and 

communication with stakeholders to address Recommendation 4. The 

Assistant Secretary stated that an engagement plan is in place, which 

establishes milestones and timelines for memorandums of understanding and 

interagency agreements; these timelines are reflected in the program plan 

discussed above regarding Recommendation 2. In addition to the five 

agencies that have signed a memorandum of understanding with the NBIS 

program already, a sixth federal agency has since been added. Further, the 

Assistant Secretary stated that all remaining federal agencies designated as 

future NBIS partners have been positively engaged and briefed on NBIS, and 

involved in an Interagency Principals Working Group. Also, the NBIS 

leadership recognizes that any successful interagency effort requires 

justification beyond what is directed by a single HSPD, and they are focusing 

on active two-way communication between all federal partners to foster the 
Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 26 

necessary understanding, willingness, and cooperation. Lastly, the Assistant 

Secretary stated that they are actively soliciting partner concerns, 

requirements, and needs to avoid communication lapses that might otherwise 

slow progress. 

Finally, in response to Recommendation 5 on performing an information 

needs assessment, the Assistant Secretary stated that direct engagement using 

focus groups and meetings with interagency partners to discuss applicable 

data content and feeds for NBIS 2.0 have resulted in refined requirements, 

enhanced understanding of program deliverables, and the near-term addition 

of comprehensive data sources to establish an integrated common operating 

picture. In addition, the NBIS program and the system development 

contractor are designing a Data Acquisition Strategy as part of an overarching 

transition plan to move the program from Initial Operational Capability to Full 

Operational Capability. 
Appendix A 

Purpose, Scope, and Methodology 

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 27 

As part of our ongoing responsibility to assess the efficiency, effectiveness, 

and economy of departmental programs and operations, we conducted an 

audit of the NBIS program. The objectives of our audit were to determine: 

• The efficacy of DHS’ plans, policies, and procedures for collaborating 

with other federal, state, and local stakeholders to gather and share 

bio-surveillance information via NBIS; and 

• Whether NBIS will meet user needs, information security 

requirements, and privacy policies and procedures. 

To establish criteria for this review, we researched U.S. laws, regulations, and 

other federal guidance applicable to bio-surveillance initiatives. 

Documentation, such as media articles and press releases obtained through 

internet searches, provided background information on the NBIS program. 

Additionally, we reviewed prior reports and congressional testimony by the 

Government Accountability Office and industry organizations to learn more 

about their findings and recommendations related to the NBIS program and 

federal bio-surveillance initiatives. 

We met with representatives from DHS’ Preparedness Directorate, Science 

and Technology Directorate, Office of Intelligence and Analysis, and Office 

of the Chief Medical Officer to learn about their roles, responsibilities, and 

activities related to the NBIS program. Senior Preparedness officials provided 

initial briefings on the program, and more specifically on NBIS and its 

functionality. The NBIS program manager discussed with us the system 

development process, as well as the incremental approach to implementing IT. 

Current and former NBIS officials, along with other staff from the contractor 

organization, Science Applications International Corporation, told us about 

NBIS development, testing, plans for ensuring systems interoperability, and 

end-user training. Additionally, these officials provided information on NBIS 

contract requirements and performance measurement. 

We also interviewed NBIS stakeholder representatives from the Department 

of State, the United States Postal Service, the Centers for Disease Control and 

Prevention, the Central Intelligence Agency, the U.S. Department of 

Agriculture, the Department of Defense, the Department of Interior, the 

Environmental Protection Agency, the Federal Bureau of Investigation, the 

National Oceanic and Atmospheric Administration, the Department of 

Veterans Affairs, the National Geospatial-Intelligence Agency, and 

Georgetown University’s Imaging Science and Information System Center. 

These officials offered their perspectives on NBIS program management 

activities, communication with stakeholders, and strategies for sharing biosurveillance information. These officials also discussed their involvement in 
Appendix A 

Purpose, Scope, and Methodology

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 28 

NBIS development activities and their views on the successes and possible 

challenges that the program may face in the future. 

We limited our work to the planning, requirements definition, and information 

sharing activities ongoing during NBIS development at the time of our audit. 

We did not observe systems testing or address classified aspects of the NBIS 

program. 

We conducted our audit from November 2006 through May 2007 in the 

Washington, D.C. metropolitan area. We performed our work according to 

generally accepted government audit standards. The principal OIG points of 

contact for this audit are Frank Deffer, Assistant Inspector General, 

Information Technology Audits, and Sondra McCauley, Director, Information 

Management Division. Other major contributors are listed in Appendix C. 

 
Appendix B 

Management Comments to the Draft Report

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 29 
Appendix B 

Management Comments to the Draft Report

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 30 
Appendix B 

Management Comments to the Draft Report

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 31 
Appendix B 

Management Comments to the Draft Report

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 32 
Appendix C 

Major Contributors to this Report 

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 33 

 Information Management Division

Sondra McCauley, Director 

John Shiffer, Audit Manager 

Meghan Sanborn, Auditor 

Kristina Hayden, Auditor 

Kia Smith, Auditor 

Eugene Yu, Referencer 
Appendix D 

Report Distribution

Better Management Needed for the National Bio-Surveillance Integration System Program 

Page 34 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Assistant Secretary and Chief Medical Officer, Office of Health Affairs 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Policy 

Assistant Secretary for Public Affairs 

Assistant Secretary for Legislative and Intergovernmental Affairs 

Program Director, National Bio-Surveillance Integration System 

Program Manager, National Bio-Surveillance Integration System 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 
Appendix D 

Report Distribution 

Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4199, 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.