FEDERAL REAL 

PROPERTY

DHS and GSA Need 

to Strengthen the 

Management of DHS 

Headquarters 

Consolidation

Report to Congressional Requesters

September 2014

GAO-14-648

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-648, a report to 

congressional requesters

September 2014

FEDERAL REAL PROPERTY

DHS and GSA Need to Strengthen the Management of 

DHS Headquarters Consolidation

Why GAO Did This Study

DHS and GSA are managing an 

estimated $4.5 billion construction 

project at the St. Elizabeths Campus in 

Washington, D.C. The project, 

designed to consolidate DHS’s 

executive leadership, operational 

management, and other personnel at 

one secure location rather than at 

multiple locations throughout the 

Washington, D.C., metropolitan area, 

has a projected completion date of 

2026. 

GAO was asked to examine DHS and 

GSA management of the headquarters 

consolidation, including the 

development of the St. Elizabeths 

campus. This report addresses the 

extent to which DHS and GSA have (1) 

developed consolidation plans in 

accordance with leading capital 

decision-making practices and (2) 

estimated the costs and schedules of 

the St. Elizabeths project in a manner 

that is consistent with leading 

practices. GAO assessed various DHS 

and GSA plans, policies, and 

cost/schedule estimates, and

interviewed DHS and GSA officials.

What GAO Recommends

GAO recommends, among other 

things, that DHS and GSA develop 

revised DHS headquarters plans that 

reflect leading practices for capital 

decision making and reliable cost and 

schedule estimates. Congress should

consider making future funding for the 

project contingent upon DHS and GSA 

developing plans and estimates

commensurate with leading practices.

DHS and GSA concurred with our 

recommendations. 

What GAO Found

The Department of Homeland Security (DHS) and General Services 

Administration (GSA) planning for the DHS headquarters consolidation does not 

fully conform with leading capital decision-making practices intended to help 

agencies effectively plan and procure assets. DHS and GSA officials reported 

that they have taken some initial actions that may facilitate consolidation planning 

in a manner consistent with leading practices, such as adopting recent workplace 

standards at the department level and assessing DHS’s leasing portfolio. For 

example, DHS has an overall goal of reducing the square footage allotted per 

employee across DHS in accordance with current workplace standards. Officials 

acknowledged that this could allow more staff to occupy less space than when 

the campus was initially planned in 2009. DHS and GSA officials also reported 

analyzing different leasing options that could affect consolidation efforts. 

However, consolidation plans, which were finalized between 2006 and 2009, 

have not been updated to reflect these changes. According to DHS and GSA 

officials, the funding gap between what was requested and what was received 

from fiscal years 2009 through 2014, was over $1.6 billion. According to these 

officials, this gap has escalated estimated costs by over $1 billion—from $3.3

billion to the current $4.5 billion—and delayed scheduled completion by over 10 

years, from an original completion date of 2015 to the current estimate of 2026. 

However, DHS and GSA have not conducted a comprehensive assessment of 

current needs, identified capability gaps, or evaluated and prioritized alternatives 

to help them adapt consolidation plans to changing conditions and address 

funding issues as reflected in leading practices. DHS and GSA reported that they 

have begun to work together to consider changes to their plans, but as of August 

2014, they had not announced when new plans will be issued and whether they 

would fully conform to leading capital decision-making practices to help plan 

project implementation. 

DHS and GSA did not follow relevant GSA guidance and GAO’s leading 

practices when developing the cost and schedule estimates for the St. Elizabeths 

project, and the estimates are unreliable. For example, GAO found that the 2013 

cost estimate—the most recent available—does not include a life-cycle cost 

analysis of the project, including the cost of operations and maintenance; was not 

regularly updated to reflect significant program changes, including actual costs; 

and does not include an independent estimate to help track the budget, as 

required by GSA guidance. Also, the 2008 and 2013 schedule estimates do not 

include all activities for the government and its contractors needed to accomplish 

project objectives. GAO’s comparison of the cost and schedule estimates with 

leading practices identified the same concerns, as well as others. For example, a 

sensitivity analysis has not been performed to assess the reasonableness of the 

cost estimate. For the 2008 and 2013 schedule estimates, resources (such as 

labor and materials) are not accounted for and a risk assessment has not been 

conducted to predict a level of confidence in the project’s completion date. 

Because DHS and GSA project cost and schedule estimates inform Congress’s 

funding decisions and affect the agencies’ abilities to effectively allocate 

resources, there is a risk that funding decisions and resource allocations could 

be made based on information that is not reliable or is out of date.

View GAO-14-648. For more information, 

contact David C. Maurer at (202) 512-9627 or 

maurerd@gao.gov; or David J. Wise at (202) 

512- 2834 or wised@gao.gov
Page i GAO-14-648 Headquarters Consolidation

Letter 1

Background 3

DHS and GSA Consolidation Plans Do Not Fully Conform with 

Leading Capital Decision-Making Practices 13

DHS and GSA Cost and Schedule Estimates for the St. Elizabeths 

Project Do Not Conform with Leading Practices 30

Conclusions 44

Recommendations for Executive Action 45

Matter for Congressional Consideration 46

Agency Comments and Our Evaluation 46

Appendix I Objectives, Scope, and Methodology 52

Appendix II Leading Practices in Capital Decision-Making 56

Appendix III The Leading Practices for Developing High-Quality Cost Estimates 58

Appendix IV 10 Leading Practices for Developing High-Quality Schedule 

Estimates 60

Appendix V Summary Assessment of St. Elizabeths 2013 Cost Estimate 

Compared with Leading Practices 62

Appendix VI Summary Assessment of St. Elizabeths 2008 and 2013 Schedule 

Estimates Compared with Leading Practices 64

Appendix VII Comments from the Department of Homeland Security 65

Contents
Page ii GAO-14-648 Headquarters Consolidation

Appendix VIII Comments from General Services Administration 68

Appendix IX GAO Contacts and Staff Acknowledgments 70

Tables

Table 1: Summary of Department of Homeland Security (DHS) 

and General Services Administration (GSA) Key Capital 

Planning Documents 5

Table 2: Planned Construction and Estimated Completion Date for 

Department of Homeland Security (DHS) Headquarters 

Consolidation at St. Elizabeths 8

Table 3: General Services Administration (GSA) Estimates of 

Department of Homeland Security Headquarters 

Consolidation Cost, Completion Date, and Projected 

Savings, by Calendar Year 10

Table 4: Example of Potential Changes to St. Elizabeths Footprint 

Scenarios if Alternative Workplace Standards Were 

Applied 21

Table 5: Four Characteristics of a High-Quality, Reliable Cost 

Estimate 32

Table 6: Four Characteristics of a High-Quality, Reliable Schedule 

Estimate 33

Table 7: Summary Assessment of 2013 St. Elizabeths 

Development Cost Estimate Compared with Leading 

Practices 35

Table 8: Summary Assessment of 2008 St. Elizabeths 

Development Schedule Estimate Compared with Leading 

Practices 37

Table 9: The Characteristics of a High-Quality Cost Estimate, 

Mapped to the 12 Steps of High-Quality Cost Estimating 58

Table 10: 10 Leading Practices for Developing High-Quality 

Schedule Estimates 60

Table 11: Summary Assessment of St. Elizabeths 2013 Cost 

Estimate Compared with Leading Practices 62

Table 12: Summary Assessment of St. Elizabeths 2008 and 2013 

Schedule Estimates Compared with Leading Practices 64
Page iii GAO-14-648 Headquarters Consolidation

Figures

Figure 1: St. Elizabeths West Campus 7

Figure 2: Requested and Received Funding for Fiscal Years 2006 

through 2014 9

Figure 3: Schedule Slippage for St. Elizabeths Development 11

Figure 4: United States Coast Guard Headquarters 12

Figure 5: Department of Homeland Security’s (DHS) Annual Costs 

and Useable Square Feet by Year of Lease Expiration 

2013 through 2023, as of February 2014 23

Figure 6: Department of Homeland Security’s (DHS) 

Consideration of the Headquarters Consolidation as a 

Major Acquisition Has Varied 26

Figure 7: St. Elizabeths Development Baseline Updated in 2013 31

Figure 8: Leading Practices in Capital Decision-Making 57
Page iv GAO-14-648 Headquarters Consolidation

Abbreviations

ARRA American Recovery and Reinvestment Act of 2009

CBP U.S. Customs and Border Protection

CPM critical path method

DHS Department of Homeland Security

EAC estimate at completion

FEMA Federal Emergency Management Agency

gPM Global Project Management Guidance

GSA General Services Administration

ICE U.S. Immigration and Customs Enforcement

IGE independent government estimate

IMS Integrated Master Schedule

IRB Investment Review Board

IT information technology

LCCE life-cycle cost estimate

NCR National Capital Region

NPPD National Protection and Programs Directorate

OIG Office of the Inspector General

OMB Office of Management and Budget

PARM Office of Program Accountability and Risk Management

PBS Public Building Service

TIP Technology Integration Program

TSA Transportation Security Administration

USCG United States Coast Guard

WBS Work Breakdown Structure

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Page 1 GAO-14-648 Headquarters Consolidation

441 G St. N.W.

Washington, DC 20548

September 19, 2014

Congressional Requesters

The Department of Homeland Security (DHS) and General Services 

Administration (GSA) are managing a $4.5 billion construction project at 

the federally owned St. Elizabeths Campus in Washington, D.C.1 The 

project, known as the DHS headquarters consolidation project at St. 

Elizabeths, is the centerpiece of DHS’s larger effort to manage and 

consolidate its workforce of over 20,000 in the National Capital Region 

(NCR).2

The DHS headquarters consolidation effort involves multiple management 

issues that we consider high-risk. For example, we have found over the 

years that many federal agencies face long-standing challenges involving 

excess and underutilized property, deteriorating facilities, unreliable 

property data, and facility protection in the post-September 11 

environment. These findings led to our designation, in January 2003, of 

real property management as a high-risk area.

As conceived in 2006, the St. Elizabeths site was designed to 

consolidate DHS’s executive leadership, operational management, and 

other personnel at one secure location rather than at multiple locations 

throughout the Washington, D.C., metropolitan area. Specifically, DHS 

envisioned moving about 14,000 staff to the new headquarters facility and 

housing its remaining personnel in other consolidated spaces across the 

region. With a current projected completion date of 2026, the St. 

Elizabeths project is intended to provide DHS a secure facility to allow for 

more efficient incident management response and command-and-control 

operations, and also provide long-term cost savings by reducing reliance 

on leased space.

3 In addition, DHS 

management issues, including acquisition management, have been 

documented in our high-risk list since 2005.4

 1

The St. Elizabeths campus is a National Historic Landmark and a former federally run 

hospital for the mentally ill.

For example, in September 

2

The National Capital Region is composed of the District of Columbia and nearby 

jurisdictions in Maryland and Virginia.

3

GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: Feb. 14, 2013).

4

GAO-13-283.
Page 2 GAO-14-648 Headquarters Consolidation

2012, we reported that DHS’s acquisition policy reflects many key 

management practices that could help mitigate risks and increase 

chances for successful outcomes. However, most of DHS’s major 

acquisition programs continue to cost more than expected, take longer to 

deploy than planned, or deliver less capability than promised.5

Given the magnitude of the St. Elizabeths project and the impact of 

headquarters consolidation on DHS operations, you asked us to examine 

DHS and GSA management of the consolidation efforts. Specifically, this 

report addresses the extent to which DHS and GSA have

• developed DHS headquarters consolidation plans in accordance with 

leading capital decision-making practices and

• estimated the costs and schedules of the DHS headquarters 

consolidation project at St. Elizabeths in a manner that is consistent 

with leading practices.

The scope of this work included DHS and GSA management of DHS 

headquarters consolidation—principally the St. Elizabeths development

project—from 2005 through 2014, and DHS and GSA actions to create 

and maintain cost and schedule estimates for the St. Elizabeths project. 

To determine the extent to which DHS and GSA developed DHS 

headquarters consolidation plans in accordance with leading capital 

decision-making practices, we reviewed DHS and GSA documents 

pertaining to how project requirements were determined and evaluated 

DHS and GSA capital planning efforts against applicable leading 

practices in capital decision-making.6

 5

GAO, Homeland Security: DHS Requires More Disciplined Investment Management to 

Help Meet Mission Needs, 

We interviewed DHS and GSA 

GAO-12-833 (Washington, D.C.: Sept. 18, 2012).

6

GAO, Executive Guide: Leading Practices in Capital Decision-Making, GAO/AIMD-99-32 

(Washington, D.C.: December 1998). To produce this guide, we conducted extensive 

research to identify leading practices in capital decision-making used by state and local 

governments and private sector organizations. Specifically, on the basis of interviews and 

documentation obtained from site visits to leading organizations, we identified innovative 

practices used by individual organizations as well as approaches and elements that were 

common across organizations. The leading organizations in our study reviewed a draft of 

this guide and verified that the case study examples are an accurate representation of 

their practices. These practices are, in part, intended to provide a disciplined approach or 

process to help federal agencies effectively plan and procure assets to achieve the 

maximum return on investments. In the overall capital decision-making framework, 

planning is the first phase—and arguably the most important—since it drives the 

remaining phases of budget, procurement, and management.
Page 3 GAO-14-648 Headquarters Consolidation

officials responsible for the planning and management of the DHS 

headquarters consolidation. Additionally, we reviewed DHS documents to 

determine the extent to which the St. Elizabeths project is subject to DHS 

oversight and agency document requirements for major acquisitions, and 

evaluated the program’s compliance with acquisition directives. We also 

interviewed DHS officials responsible for overseeing DHS major 

acquisitions. To determine the extent to which DHS and GSA estimated 

the costs and schedules of the DHS headquarters consolidation project at 

St. Elizabeths in a manner that is consistent with leading practices, we 

evaluated DHS and GSA documents on the estimated cost and schedule 

for the St. Elizabeths project using GAO cost- and schedule-estimating 

leading practices and relevant GSA guidance. We also interviewed DHS 

and GSA officials responsible for managing the estimates. Appendix I 

contains more detailed information on our objectives, scope, and 

methodology.

We conducted this performance audit from August 2013 to September 

2014 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The Homeland Security Act of 2002 combined 22 federal agencies 

specializing in various missions under DHS.7 Numerous departmental 

offices and seven key operating components are headquartered in the 

NCR.8

 7

Pub. L. No. 107-296, 116 Stat. 2135.

When the department was formed, the headquarters functions of 

its various components were not physically consolidated, but instead 

were dispersed across the NCR in accordance with their history. For 

example, in 2007, DHS employees in the NCR were located in 85 

buildings and 53 locations, accounting for approximately 7 million gross 

square feet of government-owned and -leased office space. As of July 

8

Departmental offices encompass core management and policy functions, among other 

things. The seven core DHS operating components headquartered in the NCR are U.S. 

Citizenship and Immigration Services, U.S. Coast Guard, U.S. Customs and Border 

Protection, Federal Emergency Management Agency, U.S. Immigration and Customs 

Enforcement, U.S. Secret Service, and Transportation Security Administration.

Background
Page 4 GAO-14-648 Headquarters Consolidation

2014, DHS employees were located in 94 buildings and 50 locations, 

accounting for approximately 9 million gross square feet of governmentowned and -leased office space.

GSA, the landlord for the civilian federal government, acquires space on 

behalf of the federal government through new construction and leasing, 

and acts as a caretaker for federal properties across the country.9

 9

GSA provides related real estate services including the operation and maintenance of 

buildings and outleasing programs.

Federal 

agencies give GSA information on their program and mission 

requirements and GSA then works with those agencies to develop and 

refine their real estate space needs. As such, GSA had the responsibility 

to select the specific site for a new, consolidated DHS headquarters 

facility, based on DHS needs and requirements. In addition, GSA is 

responsible for awarding and managing contracts for design and 

construction. DHS began planning the consolidation of its headquarters in 

2005. According to DHS, increased colocation and consolidation were 

critical to achieve the following objectives: (1) improve mission 

effectiveness, (2) create a unified DHS organization, (3) increase 

organizational efficiency, (4) size the real estate portfolio accurately to fit 

the mission of DHS, and (5) reduce real estate occupancy costs. DHS 

and GSA developed a number of capital planning documents to guide the 

DHS headquarters consolidation process. To start, DHS identified its 

original housing requirements in 2006 during the development of the DHS 

National Capital Region Housing Master Plan. In the housing master plan, 

DHS identified a requirement for approximately 7.1 million square feet of 

total office space in the NCR to accommodate DHS headquarters 

operations, with 4.5 million square feet on a secure campus. DHS also 

developed a program of requirements for DHS headquarters components 

that included a listing of current and projected space needs. In June 

2007, DHS released its Consolidated Headquarters Collocation Plan. The 

colocation plan summarized component functional requirements and the 

projected number of seats needed on- and off-campus for NCR 

headquarters personnel. According to DHS, the colocation plan is based 

on the idea that the consolidated headquarters campus serves as a 

central hub for leadership, operations coordination, policy, and program 

management in support of the department’s strategic goals. Table 1 

summarizes DHS and GSA key planning documents.
Page 5 GAO-14-648 Headquarters Consolidation

Table 1: Summary of Department of Homeland Security (DHS) and General Services Administration (GSA) Key Capital 

Planning Documents

Planning document Date issued Purpose

DHS National Capital Region 

(NCR) Housing Master Plan

October 2006 Identified scenarios covering:

• DHS program of requirements for DHS headquarters and all component 

headquarters functions in the NCR, and

• each component’s level of presence on an unspecified campus and during 

which phase each component would relocate.

DHS Consolidated 

Headquarters Collocation Plan

June 2007 Summarized component functional requirements and projected number of seats 

needed on and off an unspecified campus for NCR headquarters personnel. 

According to the plan:

• DHS would need 4.5 million gross square feet of office space to 

accommodate about 14,000 staff on campus and the site would 

accommodate:

• all headquarters U.S. Coast Guard (USCG) and Federal Emergency 

Management Agency (FEMA) components;

• portions of other components—Transportation Security Administration 

(TSA), U.S. Immigration and Customs Enforcement (ICE), U.S. Customs 

and Border Protection (CBP), National Protection and Programs

Directorate (NPPD), Intelligence; and

• the Office of the Secretary of Homeland Security, the Office of the 

Assistant Secretary for Policy, and the DHS Office of the General 

Counsel, among others.

• DHS would continue to house staff off-campus (via leased or federally owned 

space) in the NCR, covering about 12,500 staff.

GSA’s DHS Headquarters

Consolidation Location 

Analysis

September 2008 Analyzed options to fulfill space needs based on DHS headquarters requirements. 

GSA identified a list of 15 federally owned sites in the NCR and then evaluated the 

sites against a series of evaluation criteria. The evaluation criteria included

• compatibility with DHS’s security needs and proximity to the White House and 

Congress, as well as major roadways and Metrorail;

• availability for use by DHS to accommodate DHS’s fiscal year 2013 

occupancy timetable and availability of land adjacent to the site to 

accommodate additional square footage plus parking; and

• accessibility to neighborhood amenities (within walking distance).

GSA’s analysis showed that St. Elizabeths would best meet DHS’s various 

requirements.

GSA’s Environmental Impact 

Statement

November 2008 Assessed and reported potential impacts from the consolidation of DHS 

headquarters at St. Elizabeths, including

• natural resources such as air and water quality, social resources such as 

community services and facilities, and cultural resources such as historic 

sites, and

• transportation improvement required to support increased traffic volume.
Page 6 GAO-14-648 Headquarters Consolidation

Planning document Date issued Purpose

GSA’s Master Plan January 2009 Guided the redevelopment of the West Campus of St. Elizabeths (see fig. 1) for 

DHS. Among other things, the goals of the Master Plan included:

• the provision of facilities that meet the programmatic needs of DHS while 

maintaining the historic character of the West Campus,

• satisfaction of federal security requirements,

• preservation of the natural context of the site,

• the improvement of transportation access to the campus, and

• optimization of the federal investment.

Source: GAO summary of DHS and GSA documents. | GAO-14-648

According to GSA’s planning documents, the West Campus of St. 

Elizabeths, held by GSA, was the preferred site for DHS headquarters 

consolidation because (1) it could accommodate the 4.5 million square 

feet of office space, plus parking, and (2) was available immediately—two 

key requirements for DHS. GSA developed a Master Plan in 2009 that 

was to guide the overall development at the St. Elizabeths site. The plan 

was vetted through numerous stakeholders and received final approval in 

2009.10

 10In part because of St. Elizabeths’ status as a National Historic Landmark, federal laws 

require GSA to consult with relevant stakeholders. See 36 C.F.R. pt. 800. According to 

GSA, it is in ongoing consultation with the District of Columbia Historic Preservation Office 

and the Advisory Council on Historic Preservation. Also, the St. Elizabeths Master Plan 

was approved by the National Capital Planning Commission, and the Commission of Fine 

Arts.

Construction started at the campus in 2009. Figure 1 depicts the 

campus as envisioned in the 2009 Master Plan.
Page 7 GAO-14-648 Headquarters Consolidation

Figure 1: St. Elizabeths West Campus

The full development of the St. Elizabeths Campus was intended to occur 

in three phases, with subphases, over 8 years. Table 2 shows the original 

planned construction for each of the project’s three phases, including the 

subphases, and their original and current estimated completion dates.
Page 8 GAO-14-648 Headquarters Consolidation

Table 2: Planned Construction and Estimated Completion Date for Department of Homeland Security (DHS) Headquarters 

Consolidation at St. Elizabeths

Phase Planned construction

Initial estimated 

completion Current status 

Phase 1a United States Coast Guard (USCG) 

headquarters, site utilities, the Phase 1 central 

utilities plant, and improvements to security 

perimeter fencing

2013 USCG headquarters completed in 2013. 

Other planned construction scoped 

down because of a lack of funding.

Phase 1b Adaptive reuse of six historic buildings for shared 

use space

St. Elizabeths West Campus is a National 

Historic Landmark District, and some buildings 

will be renovated for reuse. These buildings 

include the auditorium, cafeteria, and credit 

union.

2013 Cafeteria and credit union completed in 

2013. The auditorium and other 

historical buildings were scoped down 

because of a lack of funding.

Phase 2a Office of the Secretary of Homeland Security

Departmental headquarters offices

DHS operation centers for critical incident 

management and response activities.

2014 Delayed to 2017 because of a lack of 

funding.

Phase 2b Federal Emergency Management Agency 

headquarters

2014 Delayed to 2021 because of a lack of 

funding.

Phase 3 Transportation Security Administration (TSA), 

U.S. Customs and Border Protection (CBP), and 

U.S. Immigration and Customs Enforcement 

(ICE) headquarters

2016 Delayed because of a lack of funding. 

Current estimated completion dates 

include

TSA–2022

CBP–2024

ICE–2025

Source: GAO analysis of DHS and General Services Administration data. | GAO-14-648

Note: Initial estimated completion date based on GSA’s Master Plan, issued in January 2009.

From fiscal years 2006 through 2014, the St. Elizabeths consolidation 

project had received $494.8 million through DHS appropriations and $1.1 

billion through GSA appropriations, for a total of over $1.5 billion. As part 

of this total, the DHS headquarters consolidation project received $650 

million from the American Recovery and Reinvestment Act of 2009 

(ARRA).11

 11Pub. L. No. 111-5, 123 Stat. 115. ARRA was an economic stimulus package that 

provided almost $800 billion in government-wide appropriations and revenue provisions. 

The act provided $200 million to DHS for headquarters consolidation, and the 

accompanying conference report provided that $450 million of the funding for the GSA 

Federal Buildings Fund was to go to the DHS headquarters consolidation project. Pub. L. 

No. 111-5, 123 Stat. at 162; H.R. Rep. No. 111-16, at 432 (2009) (Conf. Rep.).

In general, GSA funding was used for building construction and 
Page 9 GAO-14-648 Headquarters Consolidation

renovation, and other major infrastructure; DHS funding was used for 

tenant-specific capabilities, such as information technology (IT) 

infrastructure, furniture, and secure spaces, among other things. From 

fiscal year 2009—when construction began—through the time of the fiscal 

year 2014 appropriation, however, the gap between requested and 

received funding was over $1.6 billion. Figure 2 compares funds 

requested and received for the project for fiscal years 2006 through 2014.

Figure 2: Requested and Received Funding for Fiscal Years 2006 through 2014

In 2007, DHS and GSA estimated that the total cost of construction at St. 

Elizabeths was $3.26 billion, with construction to be completed in 2015, 

with potential savings of $1 billion attributable to moving from leased to 

owned space. However, according to DHS and GSA officials, the lack of 

consistent funding has affected cost estimates, estimated completion 

dates, and savings. Table 3 shows changes over time to GSA cost 

estimates and scheduled completion dates, as well as projected savings 
Page 10 GAO-14-648 Headquarters Consolidation

associated with moving DHS staff from leased space into federally owned 

space.

Table 3: General Services Administration (GSA) Estimates of Department of 

Homeland Security Headquarters Consolidation Cost, Completion Date, and 

Projected Savings, by Calendar Year

Year

Estimated 

completion

Estimated 

cost

Projected savings resulting from moving 

employees from leased to owned space

2007 2015 $3.26 billion $1 billion, then reduced to $743 million

2009 2016 $3.40 billion $632 million

2011 2021 $3.99 billion $516 million

2013 2026 $4.50 billion $532 million

Source: GSA Estimates. | GAO-14-648

The majority of funding for the St. Elizabeths consolidation project 

through fiscal year 2013 has been allocated to the construction of a new 

consolidated headquarters for the U.S. Coast Guard (USCG) on the 

campus. In 2006, DHS and GSA projected that USCG would move to St. 

Elizabeths in 2011, but the move was delayed because sufficient funding 

for Phase 1 of the project was not available until fiscal year 2009. In 2009, 

DHS and GSA updated the projected completion date to the summer of 

2013. Subsequently, USCG moved to the new building in August 2013. 

Figure 3 shows schedule slippage for the overall project.
Page 11 GAO-14-648 Headquarters Consolidation

Figure 3: Schedule Slippage for St. Elizabeths Development

a

The cafeteria and credit union were completed in 2013. Renovation of the auditorium and other 

historic buildings was delayed because of a lack of funding.

According to DHS and GSA officials, beginning in calendar year 2009, 

when construction commenced, Phase 1 of the overall project was 

successfully executed on schedule despite funding delays and shortfalls 
Page 12 GAO-14-648 Headquarters Consolidation

during fiscal years 2011 and 2012. GSA officials told us that, from fiscal 

years 2009 through 2013, DHS and GSA had requested about $1.6 billion 

to complete Phase 1 of the project but received only about $933 million 

for this purpose over the period. They said that they completed this phase 

of the project by deferring work planned to be completed in Phase 1 so 

that the USCG building could be occupied in 2013. GSA officials said that 

their efforts to save money by deferring work included reducing the scope 

of work needed to complete access road stonework and deferring 

landscaping and construction work on one building and the visitors’ center 

to future years. Figure 4 shows the entrance to the new U.S Coast Guard 

Headquarters Building on the St. Elizabeths Campus.

Figure 4: United States Coast Guard Headquarters

Congress, the Office of Management and Budget (OMB), and GAO have 

all identified the need for effective capital decision-making among federal 

agencies. In addition, budgetary pressures and demands to improve 

performance in all areas put pressure on agencies to make sound capital 

acquisition choices. OMB’s Capital Programming Guide, a supplement to 
Page 13 GAO-14-648 Headquarters Consolidation

OMB Circular A-11, provides guidance to federal agencies in conducting 

capital decision-making.12 GAO also developed its Executive Guide: 

Leading Practices in Capital Decision-Making, which provides detailed 

guidance to federal agencies on leading practices for the four phases of 

capital programming—planning, budgeting, acquiring, and managing 

capital assets.13 These practices are, in part, intended to provide a 

disciplined approach or process to help federal agencies effectively plan 

and procure assets to achieve the maximum return on investment.

DHS and GSA’s overall plans for headquarters consolidation do not fully 

conform with leading capital decision-making practices related to 

planning.14

In the overall capital decision-making framework, planning is the first 

phase—and arguably the most important—since it drives the remaining 

DHS and GSA officials reported that they have taken some 

initial actions that could affect consolidation plans, such as adopting 

recent workplace standards at the department level and assessing DHS’s 

leasing portfolio. These types of actions may facilitate consolidation 

planning in a manner consistent with leading practices. However, the 

current collection of plans, which DHS and GSA finalized between 2006 

and 2009, have not been updated to address these changes and funding 

instability that could affect future headquarters needs and capabilities. 

DHS and GSA have not conducted a comprehensive assessment of 

current needs, identified capability gaps, or evaluated and prioritized 

alternatives that would help officials adapt consolidation plans to 

changing conditions and address funding issues as reflected in leading 

practices. In addition, DHS has not consistently applied its acquisition 

guidelines to review and approve the project’s development. According to 

DHS and GSA officials, they have begun to work together to consider 

changes to the DHS headquarters consolidation plans. However, DHS 

and GSA have not announced when new plans will be issued, and it is 

unclear if they will fully conform with leading capital decision-making 

practices to help plan project implementation.

 12OMB, Capital Programming Guide, Supplement to OMB Circular A-11 (Washington, 

D.C.: July 2014).

13GAO, Executive Guide: Leading Practices in Capital Decision-Making; GAO/AIMD-99-32 

(Washington, D.C.: December 1998).

14GAO/AIMD-99-32.

DHS and GSA 

Consolidation Plans 

Do Not Fully Conform 

with Leading Capital 

Decision-Making 

Practices
Page 14 GAO-14-648 Headquarters Consolidation

phases of budget, procurement, and management.15 The results from this 

phase are used throughout the remaining phases of the process; 

therefore, if key practices during this phase are not followed, there may 

be repercussions on agency operations if poor capital investment 

decisions are made. Given that some aspects of the project are complete, 

we compared DHS and GSA headquarters consolidation efforts to date 

with the 5 of 12 capital decision-making practices that are most applicable 

to planning for the remaining segments of the consolidation.16

• conducting comprehensive assessments of needs to achieve results,

These 5 

practices are

• identifying gaps between current and needed capabilities,

• evaluating alternatives to best decide how to meet any gaps,

• prioritizing and selecting projects based on established criteria, and

• establishing a review and approval framework supported by analysis.

Appendix II lists these 5 planning practices along with the remaining 

practices that focus on other aspects of the overall capital decisionmaking framework not included in the scope of this review, such as 

budgeting, procurement, and management. In addition to the above, one 

important aspect of capital decision-making is recognition of the dynamic 

nature of capital plans and the planning process.17

The following compares DHS and GSA planning and oversight for the 

remainder of the DHS headquarters consolidation project with the leading 

capital decision-making practices identified above.

 15See GAO, Federal Capital: Three Entities’ Implementation of Capital Planning is Mixed, 

GAO-07-274 (Washington, D.C.: Feb. 23, 2007), and Budget Issues: Agency 

Implementation of Capital Planning Principles Is Mixed, GAO-04-138 (Washington, D.C.: 

Jan. 16, 2004). 

16One other practice related to the planning phase is to develop a long-term capital plan 

that defines capital asset decisions. We did not include this practice, as it is more 

applicable to DHS’s overall capital asset planning process and broader portfolio 

management. 

17OMB, Capital Programming Guide, Supplement to OMB Circular A-11.
Page 15 GAO-14-648 Headquarters Consolidation

DHS and GSA capital planning efforts for DHS headquarters 

consolidation have not been updated to reflect changing workplace 

standards and inconsistent project funding. Leading practices in capital 

decision-making call for agencies to assess requirements and determine 

gaps between current and needed capabilities based on the resultsoriented goals and objectives that flow from the organization’s mission. A 

comprehensive assessment of needs considers the capability of existing 

resources and makes use of an accurate and up-to-date inventory of 

capital assets and facilities, as well as current information on asset 

condition. Using this information, an organization can make decisions 

about where and how to invest in facilities. During the early stages of 

planning for the project, DHS and GSA developed various reports and 

planning documents (see table 1) to comprehensively assess DHS needs 

for a consolidated headquarters. DHS planning documents identified 

office space and DHS program requirements, and discussed which DHS 

functions needed to be colocated to achieve DHS’s mission. However, 

the plans, which were developed prior to the release of GSA’s Master 

Plan in 2009, have not kept pace with changes since then in workplace 

standards and do not account for delays attributable to inconsistent 

funding.

Workplace standards. Leading organizations we studied developed 

comprehensive needs assessments that usually cover 5 or 6 years into 

the future and are updated frequently—for example, as a part of the 

organizations’ budget cycles. A needs assessment is to examine, among 

other things, external factors that affect or influence the organizations’

operations, such as workplace standards. However, the current plans for 

St. Elizabeths do not reflect changes in the workplace, such as telework 

and smaller standard work areas that could reduce the volume of space 

needed to house DHS employees.18 Furthermore, leading practices state 

that utilizing current and accurate information is essential when taking an 

inventory of current capabilities and assessing future needs.19

 18Telework is a work arrangement in which employees perform all or a portion of their 

work at an alternative worksite, such as from home or a telework center. According to 

GSA, facility managers have focused on ways to use work space more efficiently as a 

means to reduce overall space use costs by reducing the amount of space occupied. For 

example, since the early 2000s, typical work space needs have declined as a result of the 

widespread application of more efficient facility standards. See GSA, Workspace 

Utilization and Allocation Benchmark (Washington, D.C.: updated July 2012). 

While DHS 

19GAO/AIMD-99-32.

DHS and GSA 

Assessment of Needs and 

Capability Gaps for 

Headquarters 

Consolidation Have Not 

Been Updated to Reflect 

Changing Conditions
Page 16 GAO-14-648 Headquarters Consolidation

and GSA’s original plans called for a certain size and configuration to 

house employees at St. Elizabeths, changes in workplace standards 

could affect the overall footprint of the St. Elizabeths project or increase 

the number of staff designated to occupy space at the site, or both. This 

could ultimately reduce the number of DHS headquarters employees 

housed in leased space. Recent federal initiatives have been introduced 

to reduce federal agency space. For example, a June 2010 presidential 

memorandum directed agencies to explore how innovative approaches to 

space management and alternative work arrangements, such as 

telework, could help reduce the need for real estate and office space.20

Another alternative work arrangement, hoteling, would allow employees 

to work at multiple sites and use non-dedicated, nonpermanent 

workspaces assigned for use by reservation on an as-needed basis. 

Implementing hoteling could also reduce an agency’s need for office 

space. Subsequently, in May 2012, OMB issued a memorandum that, 

among other things, establishes the Freeze the Footprint policy.21

Inconsistent project funding. In addition to workplace standards, 

current funding for the St. Elizabeths project has not aligned with what 

DHS and GSA initially planned. As discussed earlier, from fiscal year 

2009—when construction began—through the time of the fiscal year 2014 

appropriation, the gap between what DHS and GSA requested and what 

was received was over $1.6 billion. According to DHS and GSA officials, 

this funding gap has created cost escalations of over $1 billion and 

schedule delays of 10 years, relative to their original estimates. DHS and 

This 

policy directs agencies to restrict growth in their civilian real estate 

inventory. OMB supplemented that policy in March 2013 with 

implementing guidance for Freeze the Footprint that required agencies 

not to increase the total square footage of their office and warehouse 

inventory, using fiscal year 2012 as a baseline. OMB’s implementing 

guidance also directs agencies to use various strategies to maintain the 

baseline, including consulting with GSA about using technology and 

space management to consolidate, increasing occupancy rates in 

facilities, and eliminating lease arrangements that are not cost- or space 

effective.

 20Presidential Memorandum: Disposing of Unneeded Federal Real Estate (Washington, 

D.C.: June 10, 2010).

21OMB, OMB Memorandum 12-12: Promoting Efficient Spending to Support Agency 

Operations (Washington, D.C.: May 11, 2012).
Page 17 GAO-14-648 Headquarters Consolidation

GSA officials cited funding shortfalls as being disruptive in sequencing 

work, such as excavating soil for the DHS Operations Center and 

enabling repairs on the foundation of the St. Elizabeths Center Building.22

Funding instability can be a significant factor in advancing a project of the 

magnitude of St. Elizabeths, and maintaining updated consolidation plans 

that are informed by more current assessments of DHS and GSA’s needs 

and gaps could help the agencies navigate such changing factors as 

workplace requirements and funding levels. By comparing updated DHS 

and GSA resource needs information with data on current asset 

capabilities—such as the location, condition, and performance of DHS 

facilities in the NCR—DHS and GSA could be better positioned to identify 

any gaps between what is needed to fulfill their headquarters 

consolidation objectives and what resources are currently available. As 

stated earlier, leading practices for capital decision-making call for 

agencies to (1) conduct a comprehensive assessment of needs to carry 

out their missions and (2) identify gaps between current and needed 

capabilities. Furthermore, capital plans should be dynamic and updated to 

reflect decisions about the addition of new assets and deletion of old or 

even in-process acquisitions that are not meeting goals.

According to these officials, if funding had been available, excavation 

work associated with the new USCG building could have been extended

to these other parts of the project without interruption. Officials said that if 

they had funds to do the excavation, they could have completed it while 

the site was under construction, instead of having to work around the full 

occupation and operation of the USCG building. DHS and GSA deemed 

this as a lost opportunity to purposely sequence the work to maximize 

construction efficiency and reduce the overall cost of development.

23

 22The Center Building will house the Office of the Secretary of Homeland Security, among 

other things.

According to 

DHS, the colocation plan is a living document and will be updated as 

necessary to accommodate changes in mission, mission focus, emerging 

threats, identified vulnerabilities, new program additions, existing program 

completions, and potential future reorganization initiatives. However, as of 

August 2014, DHS and GSA had not updated their DHS headquarters 

consolidation planning documents, including the 2009 Master Plan and 

colocation plan, to reflect these changes. DHS and GSA had also not 

completed a current assessment of needs and capability gaps related to 

23OMB, Capital Programming Guide, Supplement to OMB Circular A-11.
Page 18 GAO-14-648 Headquarters Consolidation

changes in workplace standards and delays attributable to funding 

shortfalls.

A senior DHS project official stated that the basis of the consolidation 

plan remains the same and that it would be illogical to discard the plan 

mid-stream in favor of some unspecified alternative, given the years of 

comprehensive analysis that underpin the development and approval of 

the original 2009 Master Plan. However, DHS and GSA officials reported 

that they have begun to work together to consider changes to DHS 

headquarters consolidation plans. Specifically, in January 2014, DHS and 

GSA officials stated that they are currently reassessing requirements and 

alternatives for consolidation and colocation in recognition that workplace 

conditions have changed since the plan was formulated, beginning in 

2006. The agencies have not announced when new plans will be issued. 

Furthermore, because final documentation of agency deliberations or 

analyses have not yet been developed, it is unclear if any new plans will 

be informed by an updated comprehensive needs assessment and 

capability gap analysis as called for by leading capital decision-making 

practices. Until DHS and GSA update their capital planning documents 

related to DHS headquarters consolidation—showing how DHS and GSA 

asset portfolios for the consolidation efforts meet the goals and objectives 

of the agencies’ strategic and annual performance plans and how these 

assets will be used to help agencies achieve their goals and objectives—

agency managers and Members of Congress will be limited in their ability 

to fully understand how DHS and GSA intend to accomplish the 

consolidation and, consequently make informed decisions about future 

multi-billion dollar investments. Utilizing an updated comprehensive 

needs assessment and gap analysis of current and needed capabilities to 

inform revised headquarters consolidation plans can better position DHS 

and GSA to assure decision makers within both agencies and in 

Congress that consolidation is justified.

Changes to workplace standards and funding instability provide GSA a 

commensurate opportunity to evaluate and prioritize alternative 

construction and leasing options to meet DHS space needs in the NCR. 

As stated earlier, leading capital decision-making practices call for 

agencies to determine how best to bridge performance gaps by 

identifying and evaluating alternative approaches. Before choosing to 

purchase or construct a capital asset or facility, leading organizations are 

to carefully consider a wide range of alternatives, such as using existing 

assets, leasing, or undertaking new construction. After evaluating 

alternatives, leading practices call for organizations to select projects 

Changing Conditions Call 

for DHS and GSA to 

Reevaluate Alternative 

Approaches and Prioritize 

Projects for Headquarters 

Consolidation
Page 19 GAO-14-648 Headquarters Consolidation

based on a relative ranking of investment proposals. This prioritization of 

projects is important because limited resources require organizations to 

choose alternatives with the highest benefit or return. In the years leading 

up to 2009, when GSA issued the project Master Plan, DHS and GSA 

conducted alternatives analyses and used the results of these efforts to 

support the existing DHS headquarters consolidation plan and prioritize 

the individual projects that encompass the larger consolidation effort. For 

example, in 2007, we found that DHS examined various scenarios for 

housing DHS employees, such as a “campus” scenario, which would 

entail consolidation resulting in several campuses, including one large 

campus.24

Given changes in workplace standards, among other things, as well as 

cost escalation and schedule slippage associated with funding instability, 

DHS and GSA would benefit from updating their alternatives evaluation 

and prioritizing the range of leasing and construction alternatives. One 

potential alternative, for example, would be for DHS to consider moving 

entire components from currently leased space to St. Elizabeths, rather 

than only the leadership of particular components as originally 

envisioned. Moving more staff than currently planned to the campus from 

leased space could potentially increase long-term cost savings and 

facilitate more effective collaboration. If DHS and GSA were to take such 

an action, this would require an overall change in their approach to 

housing staff in government-owned and -leased space—a change beyond 

that already considered within the context of DHS’s 2007 colocation plan. 

Even if DHS were to consider moving smaller portions of its workforce 

rather than entire components—for example, certain offices within 

components—to St. Elizabeths, DHS would need to consider the 

cascading effect of those changes and develop updated plans to reflect 

Likewise, in 2008, GSA analyzed the feasibility of consolidating 

DHS headquarters at a variety of sites throughout the NCR, and 

determined that the only site with space available to accommodate DHS 

needs was the St. Elizabeths campus. After the site was selected, DHS 

and GSA worked together to prioritize the multiple construction phases 

that constitute the overall St. Elizabeths campus development.

 24GAO, Federal Real Property: DHS Has Made Progress, but Additional Actions Are 

Needed to Address Real Property Management and Security Challenges, GAO-07-658 

(Washington, D.C.: June 22, 2007). In 2007, DHS stated that the colocation and 

consolidation benefits of the campus scenario were more favorable than those of the other 

scenarios and the estimated annual costs of the campus scenario were 10 to 15 percent 

lower than for the baseline scenario. 
Page 20 GAO-14-648 Headquarters Consolidation

that. This would entail a reconsideration of space needs in both owned 

and leased space, and a commensurate reevaluation of funding needs, 

depending on, among other things, the volume and type of available or 

projected owned and leased space, and associated costs and benefits, as 

well as alternative estimates showing when owned or leased space might 

be available.

DHS and GSA officials acknowledged that new workplace standards 

could create a number of new development options to consider, as the 

new standards would allow for more staff to occupy the current space at 

St. Elizabeths than previously anticipated.25 DHS officials told us that 

when the St. Elizabeths project was conceived, the standard office 

workspace was 200 square feet per person. In response to the 2012 

Freeze the Footprint initiative described earlier, where applicable, DHS 

intends to reduce the average space per person for its employees across 

the department to 150 square feet of space per person. However, this 

potential change is not reflected in current headquarters consolidation 

plans. As a result, if DHS and GSA choose to keep the original 4.5 million 

square foot footprint they initially planned, they could increase the number 

of staff occupying the 14,000 seats at St. Elizabeths from 14,000 to about 

20,000. Conversely, if DHS and GSA decide to keep 14,000 staff they 

initially planned to work at St. Elizabeths, they could shrink the overall 

footprint to about 3.7 million square feet. According to DHS and GSA, the 

agencies have taken steps to adapt to the changes in workplace 

standards. For example, flexible workspaces were incorporated into the 

build-out of the Coast Guard headquarters building during construction. 

Specifically, the internal build-out of the space has flexible configurations 

that can be easily and inexpensively changed to support changes in the 

workplace environment, in the event that DHS decided to expand or 

reduce the workforce or space. Table 4 shows the original estimates, and 

the effect of increasing the number of staff occupying 14,000 seats from 

14,000 to 20,000 (scenario A), or reducing the footprint to about 3.7 

million square feet by keeping the estimated number of staff at 14,000 

(scenario B).

 25According to DHS and GSA, the Master Plan set the seat-to-staff ratio at 1 seat for 

every 1 person. That ratio was changed to 1 seat for approximately every 1.3 persons to 

help meet the Freeze the Footprint initiative in 2012.
Page 21 GAO-14-648 Headquarters Consolidation

Table 4: Example of Potential Changes to St. Elizabeths Footprint Scenarios if 

Alternative Workplace Standards Were Applied

Original estimate Scenario A Scenario B

Square feet 4.5 million 4.5 million 3.7 million

Seats 14,000 14,000 12,000

Staff 14,000 20,000 14,000

Seat-to-staff ratioa 1:1 1 : ~1.3 1 : ~1.3

Source: GAO analysis of Department of Homeland Security and General Services Administration data. | (GAO-14-648)

a

DHS’s seat-to-staff ratio of 1:1.3 is an approximate goal for DHS’s real property portfolio, but not the 

actual seat-to-staff ratio for scenarios A and B.

Adopting either scenario or some variation between the two could have a 

significant impact on the scope and cost of the project and could change 

how DHS and components perform their missions. The following is a 

description of potential alternatives that DHS and GSA could consider in 

light of new workplace standards. DHS and GSA officials said they are 

considering these types of options, although they have not yet developed 

final documents or analysis. For example:

• Keep the current estimated number of staff (14,000) with a reduced 

square footage (3.7 million). GSA and DHS could, over the short term, 

reduce the overall cost of the project with a decrease in construction 

costs. Furthermore, DHS and the components slated to move to St. 

Elizabeths would likely carry out their mission at the new location as 

originally intended.

• Maintain the current square footage projection (4.5 million square 

feet) while increasing the number of staff occupying the 14,000 seats 

(from 14,000 to 20,000). This change could result in an increase of 

the overall short-term cost of the project because GSA might have to 

build out additional office space and meet requirements for additional 

services, such as computer and telecommunication lines and 

technological services. However, the increased staff at St. Elizabeths 

could also increase long-term savings because DHS would not need 

to lease space for an increased number of employees should DHS 

decide to move more to St. Elizabeths.

In addition, as discussed earlier, from fiscal years 2009 to 2014, the gap 

between requested funding and funding received was over $1.6 billion. 

According to DHS and GSA officials, this funding gap has created cost 

escalations of over $1 billion. To help address the variation in funding 

requested and received, DHS and GSA have revised their funding 

strategy to focus on developing smaller construction segments that are 
Page 22 GAO-14-648 Headquarters Consolidation

intended to be more financially viable and less subject to uncertainty. For 

example, DHS and GSA may request full funding for a construction 

segment that will result in a functional, usable building and not be

dependent on additional future funding to complete. This funding strategy 

is consistent with a leading practice related to the budgeting phase of 

capital decision-making, which calls for agencies to budget for projects in 

useful segments.26

Schedule delays—up to 10 years relative to original estimates, according 

to DHS officials—have also resulted from the gap between funding 

requested and funding received. These delays have posed challenges for 

DHS in terms of its current leasing portfolio. Specifically, DHS’s long-term 

leasing portfolio was developed based on the original expected 

completion date for St. Elizabeths development in 2016. However, 

according to DHS leasing data, 52 percent of DHS’s current NCR leases 

will expire in 2014 and 2015, accounting for almost 39 percent of its 

usable square feet. See figure 5 for DHS’s annual leasing costs and 

usable square feet by year of lease expiration for 2013 through 2023.

Specifically, DHS and GSA would allocate funding for 

the remaining work at St. Elizabeths into usable segments that are 

independent of the overall consolidation, rather than incrementally over 

the length of the project, as has been done in the past. Developing a 

funding strategy into segments may be a viable approach in managing 

and overseeing a project with a scope and potential cost as large as St. 

Elizabeths, particularly in a constrained budgetary environment.

 26For example, OMB’s Capital Programming Guide states that agencies should request 

budget authority sufficient to complete a useful segment of a project (or the entire project, 

if it is not divisible into useful segments). Budgeting for projects in useful segments is also 

a GAO leading practice in capital decision-making during the budget phase of capital 

programming.
Page 23 GAO-14-648 Headquarters Consolidation

Figure 5: Department of Homeland Security’s (DHS) Annual Costs and Useable Square Feet by Year of Lease Expiration 2013 

through 2023, as of February 2014

DHS officials told us that, given delays moving the project forward and the 

expiration of existing leases, DHS is currently working with GSA to 

renegotiate leases where staff of individual components are currently 

housed. However, DHS acknowledged that a comprehensive analysis of 

its real property and leasing options in the NCR—which has a direct 

bearing on development options at St. Elizabeths—is ongoing, but not 

complete, and documents related to the analysis have not been finalized.

Given uncertainties about the size, scope, and timing of the project 

moving forward as well as the overall cost of the project to the 

government—DHS and GSA would be better positioned to make choices 

about capital investments if they were to identify and analyze a broader 

range of alternatives and use this alternatives analysis to inform their 

prioritization and selection of efforts related to headquarters 

consolidation. For example, a comprehensive alternatives analysis could 

take into account (1) DHS’s actual and projected leasing costs for 

locations where employees are currently housed; (2) DHS and GSA costs 
Page 24 GAO-14-648 Headquarters Consolidation

to develop additional segments of the St. Elizabeths Campus, as well as 

any transportation and infrastructure improvements; and (3) a range of 

leasing and construction alternatives and their associated costs for the St. 

Elizabeths site, depending on a determination of usable square footage 

needed. After identifying and analyzing a range of alternatives that better 

reflects current conditions, DHS and GSA would be better positioned to 

prioritize the individual steps or projects that will compose the larger 

headquarters consolidation effort. Given that $1.5 billion has already been 

invested in the headquarters consolidation, a comprehensive analysis 

and prioritization of alternatives, including cost and benefit analyses for 

each of the alternatives being considered, that accounts for the complete 

costs and benefits to the federal government as a whole, would improve 

transparency and allow for more informed decision making by DHS and 

GSA leadership and Members of Congress.

DHS has not consistently applied its major acquisition guidance for 

reviewing and approving the headquarters consolidation project. Leading 

practices call for agencies to establish a formal process for senior 

management to review and approve proposed capital assets. The cost of 

a proposed asset, the level of risk involved in acquiring the asset, and its 

importance to achieving the agency mission should be considered when 

defining criteria for executive review. Leading organizations have 

processes that determine the level of review and analysis based on the 

size, complexity, and cost of a proposed investment or its organizationwide impact. DHS has guidelines in place to provide senior management 

the opportunity to review and approve its major projects, but DHS has not 

consistently applied these guidelines to its efforts to work with GSA to 

plan and implement headquarters consolidation. As discussed below, 

DHS has sometimes, but not always, classified the consolidation project 

as a major acquisition, which has affected the extent to which the 

department has oversight of the project. By not consistently applying this 

review process to headquarters consolidation, DHS management risks 

losing insight into the progress of the St. Elizabeths project, as well as 

how the project fits in with its overall acquisitions portfolio.

DHS programs designated as major acquisitions are governed by the 

policies and processes contained in DHS Acquisition Management 

Directive 102-01 (MD 102) and the accompanying DHS Instruction 

Project Review and 

Approval Process Does 

Not Consistently Follow 

DHS Acquisition 

Standards
Page 25 GAO-14-648 Headquarters Consolidation

Manual 102-01-001.27 MD 102 establishes an acquisition life-cycle 

consisting of four phases.28 According to MD 102, an acquisition program 

is considered a Level 1 Major Acquisition if its life-cycle cost is at or 

above $1 billion, and a Level 2 Major Acquisition if its life-cycle cost is 

$300 million or more, but less than $1 billion. At predetermined points 

throughout the life-cycle—known as Acquisition Decision Events—a 

program deemed to be a major acquisition undergoes review by a 

designated senior official, referred to as the Acquisition Decision 

Authority, to assess whether the program is ready to proceed through 

each of the four phases. An important aspect of this process is the review 

and approval of key acquisition documents that, among other things, 

establish the need for a major program, its operational requirements, and 

an acquisition baseline and plan.29 MD 102 also requires that a DHS 

Investment Review Board (IRB) review major acquisitions programs at 

Acquisition Decision Events and other meetings, as needed. The IRB is 

chaired by the Acquisition Decision Authority and made up of other senior 

officials from across the department responsible for managing DHS 

mission objectives, resources, and contracts. DHS’s Office of Program 

Accountability and Risk Management (PARM) is responsible for DHS’s 

overall acquisition governance process, supports the IRB, and reports 

directly to the DHS Chief Acquisition Officer. PARM is to develop and 

update program management policies and practices, oversee the 

acquisition workforce, provide support to program managers, and collect 

program performance data. Our prior work has assessed MD 102 and 

found that it establishes a knowledge-based acquisition policy for 

program management that is largely consistent with key practices.30

 27See related work at GAO-12-833. MD 102 was issued in 2008 and updated in 2010. It 

replaced Management Directive 1400, which had governed major acquisition programs 

since 2006. DHS originally established an investment review process in 2003 to provide 

departmental oversight of major investments throughout their life-cycles, and to help 

ensure that funds allocated for investments through the budget process are well spent.

28The four phases of the acquisition life-cycle are (1) needs phase, (2) analyze/select 

phase, (3) obtain phase, and (4) produce/deploy/support phase.

29Key DHS acquisition documents requiring department level approval are the (1) mission 

need statement, (2) capability development plan, (3) operational requirements document, 

(4) acquisition plan, (5) integrated logistics support plan, (6) life-cycle cost estimate, (7)

acquisition program baseline, and (8) test and evaluation master plan.

30GAO-12-833.
Page 26 GAO-14-648 Headquarters Consolidation

DHS has designated the headquarters consolidation project as a major 

acquisition in some years but not in others. In 2010 and 2011, DHS 

identified the headquarters consolidation project as a major acquisition 

and included the project on DHS’s Major Acquisition Oversight List.31

Thus, the project was subject to the oversight and management policies 

and procedures established under MD 102. In 2012, the project as a 

whole was dropped from the list, and in 2013 DHS included the IT 

acquisition portion of the project on the list. DHS issued the 2014 list in 

June 2014, which again included the IT portion of the project, but not the 

entire project.32

Figure 6: Department of Homeland Security’s (DHS) Consideration of the 

Headquarters Consolidation as a Major Acquisition Has Varied

Figure 6 shows the extent to which the headquarters 

consolidation project has or has not been considered a major acquisition 

by DHS under MD 102.

Note: A DHS acquisition program is considered a Level 1 Major Acquisition if its life-cycle cost is at or 

above $1 billion, and a Level 2 Major Acquisition if its life-cycle cost is $300 million or more, but less 

than $1 billion.

 31DHS reviews its acquisition portfolio annually and designates programs as major 

acquisitions based on DHS investment thresholds. Generally, programs that incur costs 

greater than $300 million over the life-cycle of the program are considered major 

acquisitions. 

32In 2014, DHS changed the name of the Major Acquisition Oversight List to the Master 

Acquisition Oversight List to more accurately distinguish between the department’s major 

(Level 1 and 2) and non-major (Level 3) acquisitions and non-acquisition activities 

included in the list. 
Page 27 GAO-14-648 Headquarters Consolidation

PARM officials explained that they considered the St. Elizabeths project 

to be more of a GSA acquisition than a DHS acquisition because GSA 

owns the site and the majority of building construction is funded through 

GSA appropriations. Furthermore, they stated that DHS appropriations for 

the project are largely transferred to GSA through interagency 

mechanisms so that, in effect, GSA is responsible for managing contracts 

procured with DHS funding. PARM officials also explained that they did 

not believe that the IT portion of the St. Elizabeths project should be 

classified as a DHS major acquisition. They said that although the IT 

acquisitions are a DHS responsibility and funded with DHS 

appropriations, GSA is managing the IT contracts and therefore they 

believe those acquisitions’ oversight should reside with GSA. They said 

that the reason the IT component was placed on the Major Acquisition 

Oversight List in 2013 was because the DHS Office of Inspector General 

(OIG) recommended its inclusion.33

We recognize that GSA has responsibility for managing contracts 

associated with the headquarters consolidation project. However, a 

variety of factors, including the overall cost, scope, and visibility of the 

project, as well as the overall importance of the project in the context of 

DHS’s mission, make the consolidation project a viable candidate for 

consideration as a major acquisition. As noted above, an acquisition 

program is considered a Level 1 Major Acquisition if its life-cycle cost is at 

or above $1 billion. DHS and GSA were unable to provide an estimate of 

the life-cycle cost for the St. Elizabeths project. However, under the 

When asked why the overall 

headquarters consolidation program was previously identified by DHS as 

a major acquisition in earlier years, and what had changed, PARM 

officials said that it was likely included on past acquisition lists because it 

was a new program and DHS and GSA roles and responsibilities had yet 

to be firmly established.

 33DHS OIG, Adherence to Acquisition Management Policies Will Help Reduce Risks to the 

Technology Integration Program, OIG-12-107 (Washington, D.C.: Sept. 11, 2012). The 

OIG found that the IT portion of the consolidation project, called the Technology 

Integration Program (TIP) was a large and costly acquisition, valued at over $875 million, 

that was critical to the establishment of a robust IT infrastructure at the St. Elizabeths 

Campus. The OIG stated that despite GSA’s role in awarding and administering the IT 

contracts, TIP was a DHS IT project and no GSA funding was involved in TIP. Among 

other things, the OIG went on to say that without the proper reporting processes, DHS had 

little guarantee that TIP was properly progressing, or that its strategic goals would be 

reached, and that DHS lacked full understanding of any potential risks or the opportunity 

to evaluate or mitigate them. DHS concurred with the DHS OIG recommendation and 

placed the TIP program on the major acquisition list. 
Page 28 GAO-14-648 Headquarters Consolidation

current plan, DHS reports it will need about $1.7 billion to complete the 

project by 2026, not including life-cycle cost, well above the normal 

threshold required for a major acquisition classification called for by MD 

102. Furthermore, per MD 102, the Acquisition Review Board may 

consider a project a candidate for oversight under MD 102 if the project’s 

importance to DHS’s strategic and performance plans is disproportionate 

to its size, or if the project has high executive visibility, impacts more than 

one DHS component, has significant program or policy implications, or if 

the Deputy Secretary, Chief Acquisition Officer or Acquisition Decision 

Authority recommends an increase to a higher acquisition level. Given the 

size and scope of the project and the extent to which the completion of 

the project could impact the performance of DHS’s mission, the 

headquarters consolidation project should be considered a candidate for 

treatment as a major acquisition under MD 102. If DHS were to consider 

the headquarters consolidation project a major acquisition, consistent with 

MD 102 requirements, DHS would be better positioned to oversee the 

project and provide decision makers in DHS and Congress, and the 

taxpayer greater assurance that the project is being acquired on-time and 

on-budget.

We also observed that, during the years (2010, 2011, 2013, and 2014) 

that the headquarters consolidation project, or portions of it, was on 

DHS’s major acquisition list and therefore subject to MD 102 

requirements, the project did not comply with major acquisition 

requirements as outlined by DHS guidelines. Specifically, the project has 

not produced any of the required key acquisition documents requiring 

department-level approval: (1) mission need statement, (2) capability 

development plan, (3) operational requirements document, (4) integrated 

logistics support plan, (5) life-cycle cost estimate, (6) acquisition program 

baseline, and (7) test and evaluation master plan. Furthermore, one role 

of PARM is to conduct independent evaluations of major programs’ health 

and risks, but PARM has not assessed the St. Elizabeths project as of 

March 2014. PARM officials stated, however, that they informally monitor 

the project through regular communication with DHS officials who 

oversee the St. Elizabeths project and have no concerns about the 

project’s management. In accordance with MD 102, the IRB’s 

predecessor body—the Acquisition Review Board—reviewed the 

headquarters consolidation program with a focus on ARRA funding in 

2009 and 2010, but has not reviewed the program since then, even 

though the program as a whole was considered a major acquisition in 

2011, and likewise with the IT component in 2013 and 2014. In May 2010, 

the board generally expressed concern about the level of DHS oversight 

given that the project was highly visible and important for the department, 
Page 29 GAO-14-648 Headquarters Consolidation

and recommended senior leadership meetings between DHS and GSA. 

In September 2010, DHS and GSA signed a memorandum of 

understanding that defined certain roles for both agencies regarding 

project oversight. As noted earlier, DHS officials stated the headquarters 

consolidation has not undergone review by the IRB since 2010 because 

they viewed it as primarily a GSA project.

DHS officials also stated that the program was under way before MD 102 

was issued and that the directive requirements were not applicable. In 

addition, officials stated that they regularly briefed leadership on the 

status of the project and have produced some documentation, such as a 

needs assessment and baseline, which officials said are similar to 

documents required by MD 102. For example, the St. Elizabeths baseline 

contains some cost and schedule information for the project as required 

by MD 102. However, it does not contain other required information to 

help measure program performance. In addition, a 2010 update to MD 

102 stated the directive requirements are to be applied to the maximum 

extent possible to all major acquisitions in existence when the update was 

issued. According to DHS acquisition officials, since 2010, the DHS 

Acquisition Officer has issued waivers for some legacy programs, but not 

for the headquarters consolidation program or its IT component. Although 

the St. Elizabeths program managers may provide visibility of the project 

to leadership and may have similar key documentation, this falls short of 

the requirements contained in MD 102. The MD 102 process provides a 

more consistent, transparent review process that would involve a greater 

cross section of departmental stakeholders, among other things, 

especially given the magnitude of the project and the numbers of 

components that would occupy space at St. Elizabeths.

DHS has established through MD 102 an acquisitions policy for major 

capital assets that provides the agency with tools to better manage large 

projects. For example, regular project review and approval by a cross 

section of departmental leadership, along with having standardized 

project documentation, can help mitigate significant acquisitions 

challenges such as funding instability and capability changes. 

Furthermore, the MD 102 process provides oversight and facilitates 

program accountability. If the entire headquarters consolidation program

were designated as a major acquisition, DHS would be better positioned 

to follow its own acquisition policy. Utilizing the MD 102 review framework 

could provide the structure for more efficient program management and 

provide DHS, Congress, and taxpayers greater assurance that 

government funds are being spent in a way that is consistent with sound 

acquisition practices, and the project is moving forward as intended.
Page 30 GAO-14-648 Headquarters Consolidation

DHS and GSA cost and schedule estimates for the headquarters 

consolidation project at St. Elizabeths do not or only minimally or partially 

conform with leading estimating practices, and are therefore unreliable. 

Furthermore, in some areas, the cost and schedule estimates do not fully 

conform with GSA guidance relevant to developing estimates. Developing 

cost and schedule estimates consistent with leading practices could 

promote greater transparency and provide decision makers needed 

information about the St. Elizabeths project and the larger DHS 

headquarters consolidation effort.

DHS and GSA cost and schedule estimates for the headquarters 

consolidation project at St. Elizabeths contain numerous deficiencies that 

do not reflect leading practices, which render the estimates unreliable. In 

2013, DHS and GSA updated earlier estimates to produce the current St. 

Elizabeths cost and schedule estimates summarized in figure 7.34

 34To analyze the schedule estimate, we asked DHS and GSA to provide the most recent 

Integrated Master Schedule (IMS) that included all related embedded project schedules. 

However, the 2013 schedule estimate provided by DHS and GSA did not cover the entire 

consolidation project in sufficient detail. As a result, we analyzed the most recent complete 

schedule available, which was created in 2008. Subsequently, at the request of GSA, we 

also applied our leading practices criteria to the incomplete 2013 schedule.

These 

DHS and GSA estimates showed a total project cost of about $4.5 

billion—$2.8 billion funded through GSA appropriations and the remaining 

$1.7 billion funded through DHS appropriations. According to the 2013 

estimates provided by DHS and GSA, based on this level of funding, the 

project would be completed in 2026.

DHS and GSA Cost 

and Schedule 

Estimates for the St. 

Elizabeths Project Do 

Not Conform with 

Leading Practices

St. Elizabeths Cost and 

Schedule Estimates Are 

Unreliable
Page 31 GAO-14-648 Headquarters Consolidation

Figure 7: St. Elizabeths Development Baseline Updated in 2013

a

Total cost includes approximately $64 million received in prior fiscal years.

We compared the 2013 cost estimate and the 2008 and 2013 schedule 

estimates with leading practices for developing such estimates and found 

that the estimates do not or only minimally or partially conform with key 

characteristics for developing reliable estimates. Specifically, we 

compared DHS and GSA overall project cost estimates with the GAO 

Cost Estimating and Assessment Guide (Cost Guide),35 which defines 

leading practices related to four characteristics—comprehensive, well 

documented, accurate, and credible—that are important to developing 

high-quality, reliable cost estimates.36

 35GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, 

We also compared DHS and GSA 

GAO-09-3SP (Washington, D.C.: Mar. 2, 2009). The 

methodology outlined in this guide is a compilation of best practices that federal costestimating organizations and industry use to develop and maintain reliable cost estimates 

throughout the life of a government acquisition program. The leading practices were 

developed in conjunction with government and industry experts in the cost-estimating 

community. By default, the guide also serves as a guiding principle for our auditors to 

evaluate the economy, efficiency, and effectiveness of government programs.

36See app. III for the list of 4 characteristics of high-quality cost estimates mapped to the 

12 steps of high-quality cost estimates.
Page 32 GAO-14-648 Headquarters Consolidation

overall schedule estimates with the GAO Schedule Assessment Guide,

37

which defines leading practices related to four characteristics—

comprehensive, well constructed, credible, and controlled—that are 

important to developing high-quality, reliable schedule estimates.38

Table 5: Four Characteristics of a High-Quality, Reliable Cost Estimate

Tables 

5 and 6 describe the characteristics of high-quality, reliable cost and 

schedule estimates that served as the foundation of our comparative 

analysis.

Characteristic Description

Comprehensive The cost estimate should include both government and contractor costs of the program over its full life cycle, 

from inception of the program through design, development, deployment, and operation and maintenance to 

retirement of the program. It should also completely define the program, reflect the current schedule, and be 

technically reasonable. Comprehensive cost estimates should be structured in sufficient detail to ensure that 

cost elements are neither omitted nor double-counted. Specifically, the cost estimate should be based on a 

product-oriented work breakdown structure (WBS) that allows a program to track cost and schedule by 

defined deliverables, such as hardware or software components. Finally, where information is limited and 

judgments must be made, the cost estimate should document all cost-influencing ground rules and 

assumptions.

Well documented A good cost estimate—while taking the form of a single number—is supported by detailed documentation that 

describes how it was derived and how the expected funding will be spent in order to achieve a given 

objective. Therefore, the documentation should capture in writing such things as the source data used, the 

calculations performed and their results, and the estimating methodology used to derive each WBS element’s 

cost. Moreover, this information should be captured in such a way that the data used to derive the estimate 

can be traced back to and verified against their sources so that the estimate can be easily replicated and 

updated. The documentation should also discuss the technical baseline description and how the data were 

normalized. Finally, the documentation should include evidence that the cost estimate was reviewed and 

accepted by management.

 37GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules, 

GAO-12-120G (Washington, D.C.: May 2012). Developing the scheduling concepts 

introduced in the Cost Estimating and Assessment Guide, the GAO Schedule Assessment 

Guide presents them as ten leading practices associated with developing and maintaining 

a reliable, high-quality schedule. The leading practices were developed in conjunction with 

government and industry experts in the schedule estimating community. A companion to 

the Cost Guide, the GAO Schedule Assessment Guide serves also to present guiding 

principles for our auditors in evaluating the economy, efficiency, and effectiveness of 

government programs.

38See app. IV for a description of 10 leading practices for developing high-quality 

schedule estimates. 
Page 33 GAO-14-648 Headquarters Consolidation

Characteristic Description

Accurate The cost estimate should provide for results that are unbiased, and it should not be overly conservative or 

optimistic. An estimate is accurate when it is based on an assessment of most likely costs; adjusted properly 

for inflation; and contains few, if any, minor mistakes. In addition, a cost estimate should be updated regularly 

to reflect significant changes in the program—such as when schedules or other assumptions change—and 

actual costs, so that it is always reflecting current status. During the update process, variances between 

planned and actual costs should be documented, explained, and reviewed. Among other things, the estimate 

should be grounded in a historical record of cost estimating and actual experiences on other comparable 

programs.

Credible The cost estimate should discuss any limitations of the analysis because of uncertainty or biases surrounding 

data or assumptions. Major assumptions should be varied, and other outcomes recomputed to determine how 

sensitive they are to changes in the assumptions. Risk and uncertainty analysis should be performed to 

determine the level of risk associated with the estimate. Further, the estimate’s cost drivers should be crosschecked, and an independent cost estimate conducted by a group outside the acquiring organization should 

be developed to determine whether other estimating methods produce similar results.

Source: GAO. | GAO-14-648

Table 6: Four Characteristics of a High-Quality, Reliable Schedule Estimate

Characteristic Description

Comprehensive A comprehensive schedule includes all activities for both the government and its contractors necessary to 

accomplish a project’s objectives as defined in the project’s work breakdown structure (WBS). The schedule 

includes the labor, materials, travel, facilities, equipment, and the like needed to do the work and depicts when 

those resources are needed and when they will be available. It realistically reflects how long each activity will 

take and allows for discrete progress measurement.

Well constructed A schedule is well constructed if all its activities are logically sequenced with the most straightforward logic 

possible. Unusual or complicated logic techniques are used judiciously and justified in the schedule 

documentation. The schedule’s critical path represents a true model of the activities that drive the project’s 

earliest completion date, and total float accurately depicts schedule flexibility.

Credible A schedule that is credible is horizontally traceable—that is, it reflects the order of events necessary to 

achieve aggregated products or outcomes. It is also vertically traceable: Activities in varying levels of the 

schedule map to one another and key dates presented to management in periodic briefings are in sync with 

the schedule. Data about risks and opportunities are used to predict a level of confidence in meeting the 

project’s completion date. The level of necessary schedule contingency and high-priority risks and 

opportunities are identified by conducting a robust schedule risk analysis.

Controlled A schedule is controlled if it is updated periodically by trained schedulers using actual progress and logic to 

realistically forecast dates for program activities. It is compared against a designated baseline schedule to 

measure, monitor, and report the project’s progress. The baseline schedule is accompanied by a baseline 

document that explains the overall approach to the project, defines ground rules and assumptions, and 

describes the unique features of the schedule. The baseline schedule and current schedule are subject to a 

configuration management control process.

Source: GAO. | GAO-14-648

We have applied our leading cost and schedule estimation practices in 

past work involving federal construction projects, and the leading 
Page 34 GAO-14-648 Headquarters Consolidation

practices were developed in conjunction with numerous stakeholders 

from government and the private sector, including DHS and GSA.39

Furthermore, GSA acknowledged the value of our leading cost estimation 

practices in 2007 and issued an order to apply the principles to all cost 

estimates prepared in every GSA project, process, or organization.40

For both the cost and schedule estimates, our analysis focused on how 

well DHS and GSA met each of the four characteristics based on our 

assessment of conformance to the leading practices associated with that 

characteristic. We then arrayed the extent to which DHS and GSA cost 

and schedule estimates conformed with the four characteristics of each 

using five rating categories—fully meets, substantially meets, partially 

meets, minimally meets, or does not meet.41

 39See for example GAO, Architect of the Capitol: Incorporating All Leading Practices 

Could Improve Accuracy and Credibility of Projects’ Cost Estimates, 

We considered cost and 

schedule estimates to be reliable if the overall assessment ratings for 

each of the four characteristics were substantially or fully met. 

Conversely, if our analysis showed that any of the characteristics were 

not met, minimally met, or partially met, then the estimate did not fully 

GAO-14-333 

(Washington, D.C.: Mar. 25, 2014); VA Construction: VA Is Working to Improve Initial 

Project Cost Estimates, but Should Analyze Cost and Schedule Risks, GAO-10-189 

(Washington, D.C.: Dec. 14, 2009); and Modernizing the Nuclear Security Enterprise: New 

Plutonium Research Facility at Los Alamos May Not Meet All Mission Needs, GAO-12-337 

(Washington, D.C.: Mar. 26, 2012).

40See GSA Order 4210.1: CFO P Cost Estimation Policy Handbook, June 27, 2007. The 

GSA Chief Financial Officer initiated this cost estimation policy in response to a GAO 

recommendation contained in GAO, Telecommunications: GSA Has Accumulated 

Adequate Funding for Transition to New Contracts, but Needs Cost Estimation Policy, 

GAO-07-268 (Washington, D.C.: Feb. 23, 2007). Specifically, GSA concurred with a 

recommendation to establish a policy for cost estimation efforts that reflects leading 

practices by requiring that estimates be: comprehensive, well documented, accurate, and 

validated. 

41We established five descriptions for our assessments of leading practices and cost 

estimate characteristics: fully meets, substantially meets, partially meets, minimally meets, 

and does not meet. We consider a leading practice to be fully met when the associated 

tasks are completely satisfied, substantially met when a large portion of the associated 

tasks are satisfied, partially met when about half of the associated tasks are satisfied, 

minimally met when a small portion of the associated tasks are satisfied, and not met 

when none of the associated tasks are satisfied. Our assessment method weights each 

leading practice equally and bases the assessment of each characteristic on the average 

score of underlying leading practices. We assign each description a numerical value (5 for 

fully meets to 1 for does not meet) and round scores to the higher numerical value (i.e., a 

score of 4.5 would round up to 5). Assessments were conducted by an individual analyst, 

and then the results were independently traced and verified by a second analyst. 
Page 35 GAO-14-648 Headquarters Consolidation

reflect the characteristics of a high-quality estimate and cannot be 

considered reliable. The following two sections provide an overview of the 

results of our comparison of DHS and GSA cost and schedule estimates 

with the four characteristics for each of GAO’s cost- and scheduleestimating guidelines.

Our overall comparison of the 2013 cost estimate for St. Elizabeths 

development with leading cost-estimating best practices showed that the 

estimate partially or minimally conforms with leading practices. 

Specifically, we found that the cost estimate for the headquarters 

consolidation at St. Elizabeths partially conforms with leading practices 

associated with the characteristics of comprehensive and welldocumented estimates, and minimally conforms with leading practices 

associated with characteristics of accurate and credible estimates.

We assessed the DHS and GSA cost estimate using the framework of the 

four characteristics above associated with high-quality, reliable cost 

estimates. Table 7 shows the overall results of our comparison along with 

examples of selected leading practices under each characteristic and our 

rationale for assessment. Appendix V provides greater detail on our 

comparison of the estimate with specific leading practices that constitute 

the four cost-estimating characteristics.

Table 7: Summary Assessment of 2013 St. Elizabeths Development Cost Estimate Compared with Leading Practices

Characteristic

GAO 

assessment Selected leading practice Examples of rationale for assessment

Comprehensive ◑ Include all life-cycle costs Estimate does not include annual costs for the full useful 

life of the campus or costs for all civilian and contractor 

support personnel. 

Completely define program, reflect 

current schedule, and be technically 

reasonable

Estimate is not technically reasonable because ground 

rules and assumptions have not been updated for several 

years, other than adjustment for inflation.

Well documented ◑ Use data that are adequate for 

easily updating the estimate to 

reflect actual costs or program 

changes so that they can be used 

for future estimates

Several data items are built into the estimate’s cost model 

and are not adjustable, which makes it difficult to update 

the model to reflect actual costs or program changes.

Describe how the estimate was 

developed so that a cost analyst 

unfamiliar with the program could 

understand and replicate the 

estimate

Key content related to the estimate was spread across 

several documents, and an analyst unfamiliar with the 

program could not understand and replicate the estimate 

without significant additional information.

St. Elizabeths Cost Estimate 

Partially or Minimally Conforms 

with Leading Practices
Page 36 GAO-14-648 Headquarters Consolidation

Characteristic

GAO 

assessment Selected leading practice Examples of rationale for assessment

Accurate ◔ Produce results that are unbiased, 

not overly conservative or optimistic, 

and based on an assessment of 

most likely costs

Estimate is optimistic in assuming that none of the costs 

grew more than the overall inflation rate, and does not 

include an uncertainty analysis to evaluate whether the 

estimate is based on most likely costs.

Regularly update estimate to reflect 

significant changes in the program 

Estimate is not regularly updated to reflect significant 

changes to the program, other than adjustments based on 

available funding.

Credible ◔ Conduct sensitivity analysis that 

identifies a range of possible costs 

No sensitivity analysis was performed on the cost estimate.

Conduct independent cost estimate 

by a group outside the acquiring 

organization

DHS/GSA did not obtain an independent cost estimate to 

determine whether other estimating methods produce 

similar results.

● = Fully meets: DHS/GSA provided complete evidence that satisfies the entire criterion

◕ = Substantially meets: DHS/GSA provided evidence that satisfies a large portion of the criterion

◑ = Partially meets: DHS/GSA provided evidence that satisfies about half of the criterion

◔ = Minimally meets: DHS/GSA provided evidence that satisfies a small portion of the criterion

○ = Does not meet: DHS/GSA provided no evidence that satisfies any of the criterion

Source: GAO analysis of Department of Homeland Security and General Services Administration cost data. | GAO-14-648

A reliable cost estimate is critical to the success of any program. Such an 

estimate provides the basis for informed investment decision making, 

realistic budget formulation and program resourcing, meaningful progress 

measurement, proactive course correction when warranted, and 

accountability for results. Accordingly, DHS and GSA would benefit from 

maintaining current and well-documented estimates of project costs at St. 

Elizabeths—even if project funding is not fully secured—and these 

estimates should encompass the full life-cycle of the program and be 

independently assessed. Among other things, OMB states that generating 

reliable program cost estimates is a critical function necessary to support 

OMB’s capital programming process. Without this capability, DHS and 

GSA are at greater risk of experiencing cost overruns, missed deadlines, 

and performance shortfalls related to the headquarters consolidation 

program.

Our overall comparison of DHS and GSA schedule estimates with leading 

schedule-estimating practices showed that the most recent schedule 

estimate DHS and GSA prepared with sufficient detail for the entire 

project—in 2008—minimally conforms with leading practices. Specifically, 

the 2008 estimate minimally conforms with leading practices related to 

each of the characteristics of comprehensive, well-constructed, credible, 

and controlled estimates.

St. Elizabeths Schedule 

Estimates Minimally Conform 

with Leading Practices
Page 37 GAO-14-648 Headquarters Consolidation

We assessed DHS and GSA schedule estimates using the framework of 

the four characteristics above associated with high-quality, reliable 

schedule estimates. Table 8 shows the overall results of our analysis of 

the 2008 schedule estimate, along with examples of select leading 

practices under each characteristic and our rationale for assessment. We 

highlighted the results of the 2008 schedule comparison because the 

2008 schedule was the most recent schedule that included logic 

necessary for identifying a critical path. As noted above, at the request of 

GSA, we also analyzed a schedule estimate updated in 2013. However, 

the 2013 estimate was incomplete and did not cover the overall 

consolidation program in sufficient detail. For example, the schedule 

depicts only high-level activities and does not provide details needed to 

understand the sequence of events, including work to be performed in 

fiscal years 2014 and 2015. As a result, the 2013 schedule satisfied fewer 

leading practices than the 2008 schedule, and is also unreliable. 

Appendix VI provides greater detail on our comparison of both the 2008 

and 2013 estimates with 10 specific leading practices that compose the 

four schedule estimating characteristics.

Table 8: Summary Assessment of 2008 St. Elizabeths Development Schedule Estimate Compared with Leading Practices

Characteristic

GAO 

assessment Select leading practice Examples of rationale for assessment

Comprehensive ◔ Capture all activities Estimate does not include all activities for both the government and 

its contractors necessary to accomplish the project’s objectives.

Assign resources to all 

activities

Schedule does not account for when all resources (such as labor, 

materials, travel, facilities, and equipment) are needed and when 

they will be available.

Well constructed ◔ Sequence all activities Parts of the estimate are not logically sequenced, and DHS/GSA 

utilized unusual and complicated logic techniques without 

justification in the schedule documentation.

Credible ◔ Verify that the schedule is 

traceable horizontally and 

verticallya

Alignment of varying levels of activities and supporting sub activities 

could not be verified because DHS/GSA could not provide sufficient 

documentation. 

Conduct a schedule risk 

analysis 

Estimate does not include a risk assessment to predict a level of 

confidence in the project’s completion date.

Controlled ◔ Update the schedule with 

actual progress and logic 

DHS/GSA has not updated the schedule containing the entire 

program since December 2008.

Maintain a baseline 

schedule 

DHS/GSA could not provide a baseline schedule document that 

explains the overall approach to the project, defines ground rules 

and assumptions, and describes the unique features of the 

schedule.

● = Fully meets: DHS/GSA provided complete evidence that satisfies the entire criterion

◕ = Substantially meets: DHS/GSA provided evidence that satisfies a large portion of the criterion

◑ = Partially meets: DHS/GSA provided evidence that satisfies about half of the criterion
Page 38 GAO-14-648 Headquarters Consolidation

◔ = Minimally meets: DHS/GSA provided evidence that satisfies a small portion of the criterion

○ = Does not meet: DHS/GSA provided no evidence that satisfies any of the criterion

Source: GAO analysis of Department of Homeland Security and General Services Administration schedule data. | GAO-14-648 

a

A schedule that is credible is horizontally traceable—that is, it reflects the order of events necessary 

to achieve aggregated products or outcomes. It is also vertically traceable: activities in varying levels 

of the schedule map to one another and key dates presented to management in periodic briefings are 

in sync with the schedule.

In accordance with leading schedule estimation practices, the success of 

a major program such as the consolidation project at St. Elizabeths 

depends in part on having an integrated and reliable master schedule that 

defines when work will occur and how long it will take and how each 

activity is related to the others. For example, the program schedule 

provides not only a road map for systematic project execution but also the 

means by which to gauge progress, identify and resolve potential 

problems, and promote accountability at all levels of the program. A 

program schedule is also a vehicle for developing a time-phased budget 

baseline and an essential basis for managing trade-offs among cost, 

schedule, and scope. Accordingly, and despite current funding 

uncertainty for the project, DHS and GSA would benefit from developing a 

comprehensive schedule for the St. Elizabeths consolidation project in 

accordance with leading practices. DHS and GSA officials, as discussed 

in more detail below, generally did not agree with this overall assessment 

because they believe the leading practices are not well-suited for the type 

of complex construction projects occurring at the St. Elizabeths site.

We compared the cost and schedule estimates prepared by DHS and 

GSA for the St. Elizabeths project with relevant GSA guidance and found 

that the estimates do not always conform with agency estimating 

requirements.42

 42According to DHS and GSA officials, creating the cost and schedule estimates for the 

St. Elizabeths project was a joint undertaking. However, GSA and its contractors led the 

management of the cost and schedule estimates and therefore apply relevant GSA 

guidance. 

In commenting on our assessments of the St. Elizabeths 

cost and schedule estimates, DHS and GSA officials acknowledged that 

the estimates do not fully conform with our leading practices, but said that 

the estimates do conform with GSA project estimation policies. GSA 

officials agreed with the underlying objectives of our leading cost- and 

schedule-estimating practices, but noted that other methodologies are 

St. Elizabeths Cost and 

Schedule Estimates Do 

Not Always Conform with 

GSA Project-Estimating 

Guidance
Page 39 GAO-14-648 Headquarters Consolidation

valid and better suited to GSA projects like construction at St. Elizabeths. 

GSA officials cited GSA’s Project Estimating Requirements for the Public 

Buildings Service, also called P-120, and GSA’s Facilities Standards for 

the Public Buildings Service, also called P-100, as the key documents for 

estimating and managing building construction programs within GSA.43

Because P-120 and P-100 focus on cost estimation requirements and do 

not fully describe schedule estimation, GSA officials subsequently 

provided us with GSA’s Global Project Management (gPM) guidance as 

an additional source as it includes the Scheduling Fundamental Guide.

44

We reviewed the GSA guidance listed above and noted several areas 

where GSA cost and scheduling-estimating policies align with our leading 

practices. More specifically, 8 of the 12 steps of a high-quality cost 

estimate were at least partially reflected in GSA guidance, and 5 of our 10 

leading schedule-estimating practices were at least partially reflected. For 

example, GSA’s P-100 guidance fully reflects our leading cost estimation 

practice of “defining the program’s characteristics,” as it contains formal, 

detailed design standards and criteria for construction of new facilities 

and repairs or alterations to existing buildings. GSA’s gPM guidance fully 

reflects our leading schedule estimation practice of “capturing all 

activities,” as it states that the first step in building a schedule is to identify 

all activities required to complete the project and recommends 

incorporating the activities to the project’s Work Breakdown Structure 

(WBS)—a framework for documenting certain activities like estimating 

costs, identifying resources, determining where risks may occur, and 

providing the means for measuring program status.

 43See GSA, P-120: Project Estimating Requirements for the Public Buildings Service, 

January 2007, and GSA, P-100: Facilities Standards for the Public Buildings Service, 

November 2010. According to GSA, P-120 is the cost-estimating and cost management 

criteria document that presents the technical and administrative requirements for routine 

cost- estimating and cost management tasks involved in a construction project’s planning 

and execution stages, and defines cost-estimating practices and standards for 

professional services. P-100 establishes design standards and criteria for new buildings, 

repairs and alterations, and modernizations and also applies to lease construction with 

government option to purchase buildings. P-100 contains policy and technical criteria to 

be used in the programming, design, and documentation of GSA facilities. 

44GSA’s Global Project Management (gPM) guidance, including the PBS Scheduling 

Fundamentals Guide, can be accessed by all GSA employees on their gPM intranet

website.
Page 40 GAO-14-648 Headquarters Consolidation

In cases where GSA guidance and our leading practices align, we 

compared the St. Elizabeths cost estimates with GSA guidance and found 

some areas where the project estimates were developed consistent with 

the guidance. For example, P-120 and P-100 call for GSA to establish a 

set of ground rules for estimating GSA construction projects, such as how 

inflation is applied or how budget constraints might affect the project. Our 

comparison of the St. Elizabeths project cost estimate with GSA guidance 

showed that the project estimate documents the ground rules consistent 

with the guidance. Likewise, P-120 recommends using a WBS for 

projects to be funded over more than 1 year. Our comparison showed 

that the estimate included a WBS that outlined the end product and major 

program effort.

In contrast, we also found areas where the 2013 St. Elizabeth cost 

estimate was not prepared consistent with GSA guidelines. Specifically, 

our comparison showed that the project cost estimate:

• Does not include a life-cycle cost analysis. P-120 and P-100 both 

require that a life-cycle cost analysis be conducted to help determine 

the value of a project beyond just the cost of acquiring it, such as the 

cost of repairs, operations, preventive maintenance, logistic support 

utilities, and depreciation over the useful lifetime of the facility. P-100 

states, for example, that “three characteristics distinguish GSA 

buildings from buildings built for the private sector: longer life span, 

changing occupancies, and the use of a life-cycle cost approach to 

determine overall project cost.” No life-cycle cost analysis for St. 

Elizabeths is reflected in the estimate, including the cost of repair, 

operations, and maintenance.

• Is not regularly updated to reflect significant changes in the 

program. P-120 guidance states that the cost estimates for design 

projects should be updated throughout the design process, and 

furthermore, where costs are included, design assumptions must be 

addressed in order to completely define the scope of the estimate. We 

found that the estimate was updated based on available funding, but 

was not regularly updated to reflect significant changes to the 

program including actual costs.

• Does not include an independent cost estimate. P-100 states that 

GSA will develop two separate independent government estimates 

(IGE) to aid in effective project controls and assist in tracking the 

budget. The GSA definition of IGE does not completely align with the 

GAO definition of an independent cost estimate, but no IGEs were 

conducted for the entire St. Elizabeths project.
Page 41 GAO-14-648 Headquarters Consolidation

With regard to St. Elizabeths 2008 and 2013 schedule estimates, we 

found some instances where the project schedule estimates were partially 

consistent with GSA guidelines—the estimates covered elements of the 

guidance—and others where they did not. For example, P-120 states that 

schedules should realistically reflect how long each activity should take.

Our comparison of the St. Elizabeths schedule estimates with GSA 

guidance showed that the project estimates partially establish the 

duration of all activities—a factor that is reflected in both the 2008 and 

2013 schedule estimates. Likewise, GSA’s gPM states that activities 

should be sequenced after they have been defined and their duration has 

been estimated, tracked according to start and finish dates, and 

structured to show relationships between them to reflect their dependency 

on each other. Our comparison showed that the 2008 schedule estimate 

(not the 2013 estimate) partially reflected these gPM guidelines. In those 

instances where schedule estimates were not prepared in a manner 

consistent with GSA guidelines, we found that the 2008 and 2013 

schedule estimates:

• Do not capture all project activities. GSA’s gPM states that the first 

step in building a schedule is to identify all activities required to 

complete the project. GSA scheduling guidance also recommends 

incorporating the activities into the project’s WBS as this feature helps 

to organize and define the total scope of the project. However, we 

observed that the St. Elizabeths schedules did not define in detail the 

work necessary to accomplish a project’s objectives, including 

activities both the government and contractors are to perform.

• Do not contain an updated Integrated Master Schedule (IMS).

GSA’s gPM stresses the importance of regularly updating the 

schedule so that it represents the most up-to-date information on 

planned and completed activities, but we found no evidence that DHS 

and GSA maintained and regularly updated an IMS for the entire 

project. This includes providing a review of missed milestones, current 

expected completion dates, and actions needed to maintain/regain 

schedule progress.

• Do not include a complete schedule baseline document. GSA’s 

gPM states that establishing a baseline schedule that should be 

changed only with formal approvals from both the project team and 

the client is one of the four steps to establish a schedule. The gPM 

guidance also states that the baseline schedule should be maintained 

and that it should serve as the record of the “approved” schedule to 

allow the project manager to calculate variance. We found no 

evidence of a schedule baseline document that described the overall 
Page 42 GAO-14-648 Headquarters Consolidation

schedule, the sequencing of events, and the basis for activity 

durations, among other things, to help measure performance.

Reliable cost and schedule estimates are critical to providing overall 

project transparency and also in providing information to a variety of 

decision makers. However, in commenting on our analysis of St. 

Elizabeths cost and schedule estimates, DHS and GSA officials said that 

it would be difficult or impossible to create reliable estimates that 

encompass the scope of the entire St. Elizabeths project. Officials said 

that given the complex, multiphase nature of the overall development 

effort, specific estimates are created for smaller individual projects, but 

not for the campus project as a whole. Therefore, in their view, leading 

estimating practices and GSA guidance cannot reasonably be applied to 

the high-level projections developed for the total cost and completion date 

of the entire St. Elizabeths project. In addition, DHS and GSA officials 

stated that given funding uncertainty for the St. Elizabeths project as a 

whole, they were reluctant to allocate resources to conduct more detailed 

cost and schedule estimates until additional appropriations were received. 

They described future project phases as “not real” until they are funded. 

They added that once funding for a project phase is secured, more 

complete estimates would be created as part of that segment’s design. 

For example, regarding the schedule estimates, a senior DHS official said 

that at the programmatic level, since future phases of construction have 

not been authorized, funded, or designed, it would be illogical to develop 

anything beyond a generalized milestone schedule. GSA officials also 

commented that planning estimates for future unfunded work is 

conceptual and milestone based and therefore is sufficient for planning 

Phases 2 and 3. GSA stated that the higher-level, milestone schedule 

currently being used to manage the program is more flexible than the 

detailed schedule GAO proposes, and has proven effective even with the 

highly variable funding provided for the project.

We found, however, that this high-level schedule is not sufficiently defined 

to effectively manage the program. For example, our review of the 

schedule showed that project bars in the schedule that represent the two 

active Phase 1 and Phase 2A efforts do not contain detailed schedule 

activities that include current government, contractor, and applicable 

subcontractor effort. Specifically, there is no detailed program schedule 

that enables the tracking of key deliverables, and the activities shown in 

the schedule address only high-level agency square footage segments, 

security, utilities, landscape, and road improvements. While we 

understand the need to keep future effort contained in high-level planning 

packages, in accordance with leading practices, near-term work occurring 
Page 43 GAO-14-648 Headquarters Consolidation

in fiscal years 2014 and 2015 should have more detailed information. 

Further, there are no milestones identified that are consistent with the 

contract dates and other key dates established by management in the 

baseline schedule, and the project bars for near-term work are not 

mapped to a statement of work to ensure all effort is accounted for in the 

schedule. Finally, the project bars for near-term work also do not contain 

any risk mitigation activities. We recognize the challenges of developing 

reliable cost and schedule estimates for a large-scale, multiphase project 

like St. Elizabeths, particularly given its unstable funding history and that 

incorporating GAO’s cost- and schedule-estimating leading practices may 

involve additional costs. However, unless DHS and GSA invest in these 

practices, Congress risks making funding decisions and DHS and GSA 

management risk making resource allocation decisions without the benefit 

that a robust analysis of levels of risk, uncertainty, and confidence 

provides.

In addition to stating that it is not feasible to develop cost and schedule 

estimates for the entire St. Elizabeths project that conform with leading 

practices, DHS and GSA officials pointed to the project’s performance to 

date as an indicator of sound overall management. Specifically, DHS and 

GSA officials maintained that Phase 1 of the overall consolidation 

project—primarily the USCG headquarters—was completed “on-schedule 

and near on-budget,” after taking into account delays in the project start 

and smaller than expected annual appropriations, thus proving that their 

estimation practices were sound. As noted earlier, some of the work that 

was originally planned for Phase 1, such as utility installation; security 

measures; landscaping; and work on the visitors’ center, historic 

auditorium, and access road, was deferred to later project stages. 

According to DHS and GSA officials, reducing the scope of Phase 1 

enabled the project team to shift resources to more critical capabilities 

required for USCG occupancy, which resulted in on-schedule and near 

on-budget completion for the portion of Phase 1 funded by Congress. 

DHS and GSA officials maintained that the execution of Phase 1 was 

successful and that this should have factored into our analysis of cost and 

schedule estimates. However, our analysis of estimates is focused on the 

remaining work in the project, not the actual performance of work 

completed. Phase 1 results cannot be the sole basis used to forecast the 

reliability of cost and schedule estimates for the remaining phases of 

development at St. Elizabeths. As our analyses showed, the estimates 

were deficient in several areas, including comprehensiveness, accuracy, 

and credibility, which renders them unreliable in the context of future 

work.
Page 44 GAO-14-648 Headquarters Consolidation

In addition to the planned work deferrals and reductions in scope 

described above, other unanticipated obstacles affected Phase 1 project 

cost and schedule as well, but DHS and GSA officials did not document 

these impacts. For example, GSA officials noted that the original design 

for the Coast Guard fitness center was complete and construction was set 

to begin, but the building had to be redesigned and sunk farther 

underground after a historic preservation stakeholder objected to the 

structure’s sight-lines. Also, toxic ash was unexpectedly discovered in the 

walls of one of the historic buildings, which required additional funds and 

time to remove.45 DHS and GSA officials were not able to tell us how 

much additional funding and time were required to redesign and construct 

the fitness center and to remediate the toxic ash. Overall, without 

documentation, we could not quantify the specific effects of these types of 

actions on Phase 1 cost growth and delays. Because DHS and GSA 

project cost and schedule estimates inform Congress’s funding decisions 

and affect the agencies’ abilities to effectively allocate resources across 

competing projects in their capital programs, there is a risk that funding 

decisions and resource allocations could be made based on information 

that is not reliable.

Several factors have changed since DHS began planning its consolidated 

headquarters in 2005. New workplace standards allow more people to 

work in less space, and recent government-wide initiatives like Freeze the 

Footprint have prompted agencies to rethink their real property portfolios 

and lease arrangements. In addition, the DHS headquarters consolidation 

effort has not received the level of funding that DHS and GSA officials 

originally envisioned. By taking into account changing workplace 

standards and funding instability, assessing alternatives, prioritizing 

projects, and using the results of these analyses to inform the revised 

project plan in accordance with leading practices, DHS and GSA would 

be better positioned to assure decision makers within both agencies and 

in Congress that the consolidation project is justified. In addition, DHS 

has an acquisitions policy that generally aligns with leading capital 

decision-making practices, which applies to major acquisitions, as 

determined by cost criteria and other factors such as project visibility. 

However, DHS has moved the headquarters consolidation project or 

elements of the project on and off its list of major acquisitions over the 

 45The ash originated from the hospital’s coal-fired power plant and was used as insulation.

Conclusions
Page 45 GAO-14-648 Headquarters Consolidation

last several years. Furthermore, during the periods when the project was 

identified by DHS as a major acquisition, the program did not fully comply 

with acquisition policy requirements, such as obtaining department-level 

approval of certain documents. Although GSA owns the site, funds the 

majority of the building construction, and oversees other contracts on 

behalf of DHS, given DHS’s significant monetary investment, along with 

the project’s visibility and potential impact on DHS missions, treating 

headquarters consolidation as a major acquisition and applying the policy 

to the maximum extent possible would provide greater assurance that 

government funds are being spent in a way that is consistent with sound 

acquisition practices and that the project is moving forward as intended.

Creating reliable cost and schedule estimates for the headquarters 

consolidation project should be an integral part of DHS and GSA efforts to 

reassess the project. DHS and GSA current estimates do not conform 

with several leading practices, which make the estimates unreliable. 

Furthermore, in several instances, the cost and schedule estimates do 

not fully conform with GSA’s estimation policies. Although DHS and GSA 

maintain that more comprehensive estimates will be conducted as the 

project advances and funding is secured, decision makers could benefit 

now from accurate estimates that encompass the life-cycle of the project. 

Without this information, it is difficult for agency leadership and Members 

of Congress to make informed decisions regarding resource allocations 

and compare competing priorities. Pending the development of reliable 

cost and schedule estimates, the project risks potential cost overruns, 

missed deadlines, and performance shortfalls.

In order to improve transparency and allow for more informed decision 

making by congressional leaders and DHS and GSA decision-makers, we 

recommend that, before requesting additional funding for the DHS 

headquarters consolidation project, the Secretary of Homeland Security 

and the Administrator of the General Services Administration work jointly 

to take the following two actions:

• conduct the following assessments and use the results to inform 

updated DHS headquarters consolidation plans:

• a comprehensive needs assessment and gap analysis of current 

and needed capabilities that take into consideration changing 

conditions, and

• an alternatives analysis that identifies the costs and benefits of 

leasing and construction alternatives for the remainder of the 

project and prioritizes options to account for funding instability.

Recommendations for 

Executive Action
Page 46 GAO-14-648 Headquarters Consolidation

• After revising the DHS headquarters consolidation plans, develop 

revised cost and schedule estimates for the remaining portions of the 

consolidation project that conform to GSA guidance and leading 

practices for cost and schedule estimation, including an independent 

evaluation of the estimates.

We further recommend that the Secretary of Homeland Security 

designate the headquarters consolidation program a major acquisition, 

consistent with DHS acquisition policy, and apply DHS acquisition policy 

requirements.

Congress should consider making future funding for the St. Elizabeths 

project contingent upon DHS and GSA developing a revised 

headquarters consolidation plan, for the remainder of the project, that 

conforms with leading practices and that (1) recognizes changes in 

workplace standards, (2) identifies which components are to be colocated 

at St. Elizabeths and in leased and owned space throughout the NCR, 

and (3) develops and provides reliable cost and schedule estimates.

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

comment. In written comments, DHS concurred with all three of the 

recommendations, and GSA concurred with the two recommendations 

that applied to it. DHS and GSA comments are summarized below and 

reprinted in appendix VII and appendix VIII respectively. 

• DHS and GSA concurred with our first recommendation that DHS 

and GSA conduct a comprehensive needs assessment and 

alternatives analysis. DHS and GSA commented that DHS and 

GSA have already completed a draft enhanced consolidation plan 

which DHS believes includes the needs assessment and gap 

analysis envisioned by GAO. In addition, DHS stated that that the 

cost-benefit analysis of leasing versus construction completed 

during development of the original project master plan has been 

updated to reflect current conditions and included as part of this 

draft plan. GSA reported that it is working closely with DHS and 

will share this plan with stakeholders upon completion.

• DHS and GSA concurred with our second recommendation that 

DHS and GSA develop revised cost and schedules that conform 

to GSA guidance and leading practices. DHS commented that a 

revised programmatic schedule and estimate was created in 

Matter for 

Congressional 

Consideration

Agency Comments 

and Our Evaluation
Page 47 GAO-14-648 Headquarters Consolidation

conjunction with development of the draft enhanced plan, which, 

according to DHS, is currently with the Office of Management and 

Budget for approval. DHS stated that it defers to GSA as to 

whether this estimate conforms to GSA or other criteria for cost 

and schedule estimation, since the project is being managed and 

executed by GSA and not DHS. GSA commented that it plans to 

update the cost and schedule estimates upon completion of the 

Enhanced Plan, and may adopt some of the leading practices 

referenced by GAO.

• DHS concurred with our third recommendation that DHS 

designate the headquarters consolidation program a major 

acquisition and apply DHS acquisition policy requirements. DHS 

reported that the Acting Under Secretary for Management 

determined in September 2014 that the DHS-funded portions of 

the St. Elizabeths project will come under the purview of the DHS 

Acquisition Review Board for oversight effective immediately to 

assure senior leadership visibility over DHS funds executed by 

GSA. DHS also requested that we consider this recommendation 

resolved and closed. Designating the DHS-funded portions of the 

St. Elizabeths project a major acquisition partially addresses our 

recommendation. It is still too early to assess the extent to which 

DHS is applying its acquisition policy to the project. As stated in

our report, the St. Elizabeths headquarters consolidation project 

has been moved off and on the DHS master acquisition oversight 

list in prior years and in the years that it has been on the list, the 

project did not comply with major acquisition requirements as 

outlined by DHS guidelines. We will continue to monitor DHS’s 

actions to apply its acquisition policy to the project as part of our 

normal recommendation follow-up process.

In its comments, DHS also expressed concern that our report did not 

sufficiently describe the roles and responsibilities of DHS and GSA. 

Specifically, DHS stated that, as a tenant agency, its role is to establish 

programmatic requirements; budget for and fund tenant responsible 

items; provide oversight on GSA's use of DHS funds; validate that GSA 

managed design and construction activities meet DHS operational and 

program requirements; and coordinate with GSA and other stakeholders 

throughout the process, as appropriate. DHS also noted that other

activities are managed by GSA in accordance with GSA policies and 

under GSA supervision and oversight. DHS stated that, while DHS 

cooperates with GSA and helps facilitate completion of these activities as 

appropriate, DHS does not have any supervisory control over the 
Page 48 GAO-14-648 Headquarters Consolidation

activities. Specifically, DHS stated that it did not select the St. Elizabeths 

site, nor does not award or manage contracts for design and construction. 

We agree that GSA has responsibility for these activities and have added 

more detailed discussion of DHS and GSA roles to the report. However, 

cooperation and collaboration between DHS and GSA is essential for a 

variety of reasons, including the overall cost, scope, and visibility of the 

project; the overall importance of the project in the context of DHS’s 

mission; and in light of the fact that DHS has received $494.8 million to 

date for the project. This does not include the additional $1.2 billion that 

DHS expects that it will need to ensure that the project is completed by 

2026. In this context, we believe that the management and 

implementation of the St. Elizabeths project is a shared responsibility 

between DHS and GSA, requiring them to work closely together to help 

provide greater assurance to decision makers in Congress, DHS, and 

GSA—as well as taxpayers—that the project is being appropriately 

managed and acquired on-time and on-budget.

DHS also expressed concern that the report is overly focused on “leading 

practices” as opposed to being more outcome and results oriented. We 

believe that applying the leading practice cited in our draft report would 

better position DHS and GSA to manage the St. Elizabeths’ project and 

help ensure better outcomes and results. DHS stated that GSA, in 

concert with DHS, has already conducted sufficient analysis to support 

the best practices in our report. We disagree. As we note in the report, 

cost and schedule estimates for the project were deficient in several 

areas, including comprehensiveness, accuracy, and credibility. Estimates 

also failed to comply with GSA’s internal guidance for cost and schedule.

In its written response, GSA also commented that several of the leading 

practices GAO identifies are better suited to non-real estate investments 

such as weapons systems, spacecraft, aircraft carriers, and software 

systems. We disagree. As stated in our report, we have applied our 

leading cost and schedule estimation practices in past work involving 

federal construction projects, and the leading practices were developed in 

conjunction with numerous stakeholders from government and the private 
Page 49 GAO-14-648 Headquarters Consolidation

sector, including DHS and GSA.46 Furthermore, GSA acknowledged the 

value of our leading cost estimation practices in 2007 and issued an order 

to apply the principles to all cost estimates prepared in every GSA 

project, process, or organization.47

We are sending copies to the Secretary of Homeland Security, 

Administrator of GSA, and other interested parties. In addition, the report 

will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staffs have questions about this report, please contact 

either David Maurer at (202) 512-9627 or maurerd@gao.gov, or David 

Wise at (202) 512-2834 or wised@gao.gov. Contact points for our Offices 

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

 46 See for example GAO, Architect of the Capitol: Incorporating All Leading Practices 

Could Improve Accuracy and Credibility of Projects’ Cost Estimates, GAO-14-333 

(Washington, D.C.: Mar. 25, 2014); VA Construction: VA Is Working to Improve Initial 

Project Cost Estimates, but Should Analyze Cost and Schedule Risks, GAO-10-189 

(Washington, D.C.: Dec. 14, 2009); and Modernizing the Nuclear Security Enterprise: New 

Plutonium Research Facility at Los Alamos May Not Meet All Mission Needs, GAO-12-337 

(Washington, D.C.: Mar. 26, 2012).

47 See GSA Order 4210.1: CFO P Cost Estimation Policy Handbook, June 27, 2007. The 

GSA Chief Financial Officer initiated this cost estimation policy in response to a GAO 

recommendation contained in Telecommunications: GSA Has Accumulated Adequate 

Funding for Transition to New Contracts, but Needs Cost Estimation Policy, GAO-07-268 

(Washington, D.C.: Feb. 23, 2007). Specifically, GSA concurred with a recommendation to 

establish a policy for cost estimation efforts that reflects leading practices by requiring that 

estimates be: comprehensive, well documented, accurate, and validated.
Page 50 GAO-14-648 Headquarters Consolidation

page of this report. Key contributors to this report are listed in appendix 

IX.

David C. Maurer

Director

Homeland Security and Justice Issues

David J. Wise

Director

Physical Infrastructure Issues
Page 51 GAO-14-648 Headquarters Consolidation

List of Requesters

The Honorable Thomas R. Carper

Chairman

The Honorable Tom A. Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Michael T. McCaul

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Jeff Duncan

Chairman

Subcommittee on Oversight and Management Efficiency

Committee on Homeland Security

House of Representatives

The Honorable Richard Hudson

Chairman

Subcommittee on Transportation Security

Committee on Homeland Security

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 52 GAO-14-648 Headquarters Consolidation

We conducted our review to examine (1) the extent to which the 

Department of Homeland Security (DHS) and the General Services 

Administration (GSA) developed DHS headquarters consolidation plans in 

accordance with leading capital decision-making principles, and (2) the 

extent to which DHS and GSA have estimated the costs and schedules of 

the DHS headquarters consolidation project at St. Elizabeths in a manner 

that is consistent with leading practices.

To determine the extent to which DHS and GSA developed DHS 

headquarters consolidation plans in accordance with leading capital 

decision-making principles, we reviewed and analyzed DHS and GSA 

capital planning documents and interviewed DHS and GSA officials 

responsible for the planning and management of the St. Elizabeths 

project, as well as DHS and GSA senior leadership. We compared DHS 

and GSA capital planning actions against Office of Management and 

Budget (OMB) and GAO leading practices (see app. II).1 Our analysis of 

DHS and GSA efforts using criteria for leading capital decision-making 

focused on planning for the remaining segments or phases of the project 

because, as we stated in previous reports, the planning phase is the crux 

of the capital decision-making process.2

 1

See GAO, Executive Guide: Leading Practices in Capital Decision-Making, 

The results from this phase are 

used throughout the remaining phases of the process; therefore, if key 

practices during this phase are not followed there may be repercussions 

on agency operations if poor capital investment decisions are made. To 

determine the extent to which DHS planned and implemented the DHS 

headquarters consolidation project at St. Elizabeths in accordance with 

GAO/AIMD-99-32 (Washington, D.C.: Dec. 1, 1998). To produce this guide, we conducted 

extensive research to identify leading practices in capital decision-making used by state 

and local governments and private sector organizations. Specifically, on the basis of 

interviews and documentation obtained from site visits to leading organizations, we 

identified innovative practices used by individual organizations as well as approaches and 

elements that were common across organizations. The leading organizations in our study 

reviewed a draft of this guide and verified that the case study examples are an accurate 

representation of their practices. These practices are, in part, intended to provide a 

disciplined approach or process to help federal agencies effectively plan and procure 

assets to achieve the maximum return on investments. In the overall capital decisionmaking framework, planning is the first phase—and arguably the most important—since it 

drives the remaining phases of budget, procurement, and management. 

2

See GAO, Federal Capital: Three Entities’ Implementation of Capital Planning Is Mixed, 

GAO-07-274 (Washington, D.C.: Feb. 23, 2007), and Budget Issues: Agency 

Implementation of Capital Planning Principles Is Mixed, GAO-04-138 (Washington, D.C.: 

Jan. 16, 2004).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 53 GAO-14-648 Headquarters Consolidation

departmental acquisition guidelines, we interviewed officials from DHS’s 

Office of Program Accountability and Risk Management (PARM) as well

as DHS project managers. We reviewed and analyzed DHS Acquisition 

Management Directive 102-01 (MD 102) and DHS’s Major Acquisitions 

Oversight List for fiscal years 2010 through 2014. We then compared the 

acquisition standards detailed in MD 102 with DHS’s efforts to acquire a 

consolidated headquarters facility at the GSA-owned St. Elizabeths 

Campus.

To determine the extent to which DHS and GSA have estimated the costs 

and schedules of the DHS headquarters consolidation project at St. 

Elizabeths in a manner that is consistent with leading practices, we 

interviewed DHS and GSA program officials and compared DHS and 

GSA overall project cost and schedule estimates with GAO leading 

practices. Specifically, the GAO Cost Estimating and Assessment Guide

(Cost Guide) identifies leading practices that represent work across the 

federal government and are the basis for a high-quality, reliable cost 

estimate.3

 3

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, 

A cost estimate created using the leading practices exhibits 

four broad characteristics: it is accurate, well documented, credible, and 

comprehensive. That is, each characteristic is associated with a specific 

set of leading practices. In turn, each leading practice is made up of a 

number of specific tasks (see app. III). Similarly, we compared DHS and 

GSA overall schedule estimates with the GAO Schedule Assessment 

Guide, which defines leading practices related to four characteristics—

comprehensive, well constructed, credible, and controlled—that are 

important to developing high-quality, reliable schedule estimates (see 

GAO-09-3SP (Washington, D.C.: Mar. 2, 2009). The 

methodology outlined in this guide is a compilation of best practices that federal costestimating organizations and industry use to develop and maintain reliable cost estimates 

throughout the life of a government acquisition program. The leading practices were 

developed in conjunction with government and industry experts in the cost-estimating 

community. By default, the guide also serves as a guiding principle for our auditors to 

evaluate the economy, efficiency, and effectiveness of government programs. 
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-14-648 Headquarters Consolidation

app. IV).4 For our evaluations of the cost and schedule estimates, when 

the tasks associated with the leading practices that define a characteristic 

were mostly or completely satisfied, we considered the characteristic to 

be substantially or fully met. When all four characteristics were at least 

substantially met, we considered a cost or schedule estimate to be 

reliable.5

 4

GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules, 

To analyze the St. Elizabeths schedule estimate, we asked DHS 

and GSA to provide the most recent Integrated Master Schedule (IMS) 

that included all related embedded project schedules. Although the 2013 

cost estimate provided by DHS and GSA was complete, the 2013 

schedule estimate did not cover the entire consolidation project in 

sufficient detail. As a result, we initially analyzed the most recent 

complete schedule available, which was created in 2008. The 2008 

schedule estimate listed project completion in 2016. Subsequently, at the 

request of GSA, we also applied our leading practices criteria to the 

incomplete 2013 schedule. We shared our analysis with DHS and GSA 

officials to review, comment on, and provide additional information, and 

we adjusted our analysis where appropriate. Finally, we reviewed GSA 

guidance that DHS and GSA officials stated was relevant to cost and 

schedule estimating for the St. Elizabeths project: P-120: Project 

Estimating Requirements for the Public Buildings Service (PBS); P-100: 

Facilities Standards for the Public Buildings Service; and GSA’s Global 

Project Management (gPM) guidance, which includes the PBS 

GAO-12-120G (Washington, D.C.: May 2012). Developing the scheduling concepts 

introduced in the Cost Estimating and Assessment Guide, the GAO Schedule Assessment 

Guide presents them as 10 leading practices associated with developing and maintaining 

a reliable, high-quality schedule. The leading practices were developed in conjunction with 

government and industry experts in the schedule-estimating community. A companion to 

the Cost Guide, the GAO Schedule Assessment Guide serves also to present guiding 

principles for our auditors in evaluating the economy, efficiency, and effectiveness of 

government programs.

5 We established five descriptions for our assessments of leading practices and cost 

estimate characteristics: fully meets, substantially meets, partially meets, minimally meets, 

and does not meet. We consider a leading practice to be fully met when the associated 

tasks are completely satisfied, substantially met when a large portion of the associated 

tasks are satisfied, partially met when about half of the associated tasks are satisfied, 

minimally met when a small portion of the associated tasks are satisfied, and not met 

when none of the associated tasks are satisfied. Our assessment method weights each 

leading practice equally and bases the assessment of each characteristic on the average 

score of underlying leading practices. We assign each description a numerical value (5 for 

fully meets to 1 for does not meet) and round scores to the higher numerical value (i.e., a 

score of 4.5 would round up to 5). Assessments were conducted by an individual analyst, 

and then the results were independently traced and verified by a second analyst.
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-14-648 Headquarters Consolidation

Scheduling Fundamentals Guide. In areas where GSA estimating 

guidance aligned with our leading cost and schedule-estimating leading 

practices, we evaluated the extent to which the St. Elizabeths cost and 

schedule estimates conformed with GSA guidance.

We conducted our work from August 2013 to September 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Leading Practices in Capital 

Decision-Making

Page 56 GAO-14-648 Headquarters Consolidation

Congress, the Office of Management and Budget (OMB), and GAO have 

all identified the need for effective capital planning among federal 

agencies. GAO developed its Executive Guide: Leading Practices in 

Capital Decision-Making, which provides guidance to federal agencies on 

planning, budgeting, acquiring, and managing capital assets.1

 1

GAO, Executive Guide: Leading Practices in Capital Decision-Making,

Figure 8 

illustrates how capital decision-making principles fit together.

GAO/AIMD-99-32 

(Washington, D.C.: December 1998).

Appendix II: Leading Practices in Capital

Decision-Making
Appendix II: Leading Practices in Capital 

Decision-Making

Page 57 GAO-14-648 Headquarters Consolidation

Figure 8: Leading Practices in Capital Decision-Making
Appendix III: The Leading Practices for 

Developing High-Quality Cost Estimates

Page 58 GAO-14-648 Headquarters Consolidation

We developed the GAO Cost Estimating and Assessment Guide in order 

to establish a consistent methodology that is based on best practices and 

that can be used across the federal government for developing, 

managing, and evaluating capital program cost estimates. We have 

identified 12 steps under 4 characteristics that, followed correctly, should 

result in reliable and valid cost estimates that management can use for 

making informed decisions.

Table 9: The Characteristics of a High-Quality Cost Estimate, Mapped to the 12 Steps of High-Quality Cost Estimating

Cost estimate characteristic Cost-estimating step 

Well documented 

The estimate is thoroughly documented, including source data and significance, clearly 

detailed calculations and results, and explanations for choosing a particular method or 

reference.

• Data are traced back to the source documentation

• Includes a technical baseline description

• Documents all steps in developing the estimate so that a cost analyst unfamiliar 

with the program can recreate it quickly with the same result

• Documents all data sources for how the data were normalized

• Describes in detail the estimating methodology and rationale used to derive each 

Work Breakdown Structure (WBS) element’s cost 

1. Define the estimate’s purpose

3. Define the program

5. Identify ground rules and assumptions

6. Obtain the data

10.Document the estimate 

11.Present the estimate to management 

Comprehensive 

The estimate’s level of detail ensures that cost elements are neither omitted nor 

double counted.

• Details all cost-influencing ground rules and assumptions

• Defines the WBS and describes each element in a WBS dictionary

• A major automated information system program may have only a cost element 

structure 

2. Develop the estimating plan

4. Determine the estimating approach 

Accurate 

The estimate is unbiased, not overly conservative or overly optimistic, and based on 

an assessment of most likely costs.

• It has few, if any, mathematical mistakes; its mistakes are minor

• It has been validated for errors like double counting and omitted costs

• Cost drivers have been cross-checked to see if results are similar

• It is timely

• It is updated to reflect changes in technical or program assumptions and new 

phases or milestones

• Estimates are replaced with Earned Value Managementa (EVM) estimate at 

completionb (EAC) and the independent EAC from the integrated EVM system 

7. Develop the point estimate and compare it 

with an independent cost estimate

12. Update the estimate to reflect actual 

costs and changes 

Credible 

Appendix III: The Leading Practices for 

Developing High-Quality Cost Estimates
Appendix III: The Leading Practices for 

Developing High-Quality Cost Estimates

Page 59 GAO-14-648 Headquarters Consolidation

Cost estimate characteristic Cost-estimating step 

Discusses any limitations of the analysis from uncertainty or biases surrounding data 

or assumptions.

• Major assumptions are varied and other outcomes recomputed to determine their 

sensitivity to changes in assumptions

• Risk and uncertainty analysis is performed to determine the level of risk 

associated with the estimate

• An independent cost estimate is developed to determine if other estimating 

methods produce similar results 

7. Develop the point estimate and compare it 

with an independent cost estimate

8. Conduct sensitivity analysis

9. Conduct risk and uncertainty analysis 

Source: GAO. | GAO-14-648

a

EVM is a project management tool that integrates the technical scope of work with schedule and cost 

elements for investment planning and control. It compares the value of work accomplished in a given 

period with the value of the work expected in that period. Differences in expectations are measured in 

both cost and schedule variances.

b

An EAC is an independent assessment of the cost to complete authorized work based on a 

contractor’s historical EVM performance. It uses various EVM metrics to forecast the expected final 

cost.
Appendix IV: 10 Leading Practices for 

Developing High-Quality Schedule Estimates

Page 60 GAO-14-648 Headquarters Consolidation

The GAO Schedule Assessment Guide is a companion to the Cost Guide. 

A consistent methodology for developing, managing, and evaluating 

capital program cost estimates includes the concept of scheduling the 

necessary work to a timeline, as discussed in the Cost Guide. A wellplanned schedule is a fundamental management tool that can help 

government programs use public funds effectively by specifying when 

work will be performed in the future and measuring program performance 

against an approved plan. Table 10 represents the 10 leading practices 

associated with a high-quality and reliable schedule and their concepts.

Table 10: 10 Leading Practices for Developing High-Quality Schedule Estimates

Appendix IV: 10 Leading Practices for 

Developing High-Quality Schedule Estimates

Leading practice Explanation 

Capturing all activities The schedule should reflect the resources (labor, materials, and overhead) needed to do the work, 

whether they will be available when needed, and any funding or time constraints. 

Sequencing all activities The schedule should be planned so that critical project dates can be met. To do this, activities need 

to be logically sequenced—that is, listed in the order in which they are to be carried out. In 

particular, activities that must be completed before other activities can begin (predecessor 

activities), as well as activities that cannot begin until other activities are completed (successor 

activities), should be identified. Date constraints and lags should be minimized and justified. This 

helps ensure that the interdependence of activities that collectively lead to the completion of events 

or milestones can be established and used to guide work and measure progress.

Assigning resources to all 

activities 

The schedule should reflect the resources (labor, materials, and overhead) needed to do the work, 

whether they will be available when needed, and any funding or time constraints.

Establishing the duration of all 

activities 

The schedule should realistically reflect how long each activity will take. When the duration of each 

activity is determined, the same rationale, historical data, and assumptions used for cost estimating 

should be used. Durations should be reasonably short and meaningful and allow for discrete 

progress measurement. Schedules that contain planning and summary planning packages as 

activities will normally reflect longer durations until broken into work packages or specific activities. 

Verifying that the schedule can 

be traced horizontally and 

vertically 

The detailed schedule should be horizontally traceable, meaning that it should link products and 

outcomes associated with other sequenced activities. These links are commonly referred to as 

handoffs and serve to verify that activities are arranged in the right order for achieving aggregated 

products or outcomes. The integrated master schedule (IMS) should also be vertically traceable—

that is, varying levels of activities and supporting subactivities can be traced. Such mapping or 

alignment of levels enables different groups to work to the same master schedule.

Confirming that the critical path 

is valid 

The schedule should identify the program critical path—the path of longest duration through the 

sequence of activities. Establishing a valid critical path is necessary for examining the effects of any 

activity’s slipping along this path. The program critical path determines the program’s earliest 

completion date and focuses the team’s energy and management’s attention on the activities that 

will lead to the project’s success.

Ensuring reasonable total float The schedule should identify reasonable float (or slack)—the amount of time by which a 

predecessor activity can slip before the delay affects the program’s estimated finish date—so that 

the schedule’s flexibility can be determined. Large total float on an activity or path indicates that the 

activity or path can be delayed without jeopardizing the finish date. The length of delay that can be 

accommodated without the finish date’s slipping depends on a variety of factors, including the 

number of date constraints within the schedule and the amount of uncertainty in the duration 

estimates, but the activity’s total float provides a reasonable estimate of this value. As a general 

rule, activities along the critical path have the least float.
Appendix IV: 10 Leading Practices for 

Developing High-Quality Schedule Estimates

Page 61 GAO-14-648 Headquarters Consolidation

Source: GAO. | GAO-14-648

Conducting a schedule risk 

analysis 

A schedule risk analysis uses a good critical path method (CPM) schedule and data about project 

schedule risks and opportunities as well as statistical simulation to predict the level of confidence in 

meeting a program’s completion date, determine the time contingency needed for a level of 

confidence, and identify high-priority risks and opportunities. As a result, the baseline schedule 

should include a buffer or reserve of extra time.

Updating the schedule using 

actual progress and logic 

Progress updates and logic provide a realistic forecast of start and completion dates for program 

activities. Maintaining the integrity of the schedule logic at regular intervals is necessary to reflect 

the true status of the program. To ensure that the schedule is properly updated, people responsible 

for the updating should be trained in critical path method scheduling.

Maintaining a baseline schedule A baseline schedule is the basis for managing the project scope, the time period for accomplishing 

it, and the required resources. The baseline schedule is designated the target schedule, subject to 

a configuration management control process, against which project performance can be measured, 

monitored, and reported. The schedule should be continually monitored so as to reveal when 

forecasted completion dates differ from planned dates and whether schedule variances will affect 

downstream work. A corresponding baseline document explains the overall approach to the project; 

defines custom fields in the schedule file; details ground rules and assumptions used in developing 

the schedule; and justifies constraints, lags, long activity durations, and any other unique features 

of the schedule.
Appendix V: Summary Assessment of St. 

Elizabeths 2013 Cost Estimate Compared with 

Leading Practices

Page 62 GAO-14-648 Headquarters Consolidation

We assessed the Department of Homeland Security (DHS) and General 

Services Administration (GSA) cost estimate using the framework of the 

four characteristics—comprehensive, well documented, accurate, and 

credible—associated with high-quality, reliable cost estimates. Table 11 

provides greater detail on our comparison of the estimate with leading 

practices that constitute the four cost-estimating characteristics.

Table 11: Summary Assessment of St. Elizabeths 2013 Cost Estimate Compared with Leading Practices

Characteristic

Overall 

assessment Leading practice

Individual 

assessment

Comprehensive ◑ The cost estimate includes all life-cycle costs ◑

The cost estimate completely defines the program, reflects the current 

schedule, and is technically reasonable

◑

The cost estimate is product-oriented, traceable to the statement of 

work/objective, and at an appropriate level of detail to ensure that cost 

elements are neither omitted nor double-counted.

◑

The estimate documents all cost-influencing ground rules and 

assumptions.

◑

Well documented ◑ The documentation should capture the source data used, the 

reliability of the data, and how the data were normalized.

◑

The documentation describes in sufficient detail the calculations 

performed and the estimating methodology used to derive each 

element’s cost.

◑

The documentation describes step by step how the estimate was 

developed so that a cost analyst unfamiliar with the program could 

understand what was done and replicate it

◔

The documentation discusses the technical baseline description and 

the data in the baseline are consistent with the estimate

◕

The documentation provides evidence that the cost estimate was 

reviewed and accepted by management.

◔

Accurate ◔ The cost estimate results are unbiased, not overly conservative or 

optimistic and based on an assessment of most likely costs.

◔

The estimate has been adjusted properly for inflation. ◑

The estimate contains few, if any, minor mistakes. ◑

The cost estimate is regularly updated to reflect significant changes in 

the program so that it is always reflecting current status.

◔

Variances between planned and actual costs are documented, 

explained, and reviewed. 

◔

The estimate is based on a historical record of cost estimating and 

actual experiences from other comparable programs. 

◔

The estimating technique for each cost element was used 

appropriately 

◑

Appendix V: Summary Assessment of St. 

Elizabeths 2013 Cost Estimate Compared 

with Leading Practices
Appendix V: Summary Assessment of St. 

Elizabeths 2013 Cost Estimate Compared with 

Leading Practices

Page 63 GAO-14-648 Headquarters Consolidation

Characteristic

Overall 

assessment Leading practice

Individual 

assessment

Credible ◔ The cost estimate includes a sensitivity analysis that identifies a range 

of possible costs based on varying major assumptions, parameters, 

and data inputs.

○

A risk and uncertainty analysis was conducted that quantified the 

imperfectly understood risks and identified the effects of changing key 

cost driver assumptions and factors.

◔

Major cost elements were cross-checked to see whether results were 

similar.

◔

An independent cost estimate was conducted by a group outside the 

acquiring organization to determine whether other estimating methods 

produce similar results.

○

● = Fully meets: DHS/GSA provided complete evidence that satisfies the entire criterion

◕ = Substantially meets: DHS/GSA provided evidence that satisfies a large portion of the criterion

◑ = Partially meets: DHS/GSA provided evidence that satisfies about half of the criterion

◔ = Minimally meets: DHS/GSA provided evidence that satisfies a small portion of the criterion

○ = Does not meet: DHS/GSA provided no evidence that satisfies any of the criterion

Source: GAO analysis of Department of Homeland Security and General Services Administration cost data. | GAO-14-648
Appendix VI: Summary Assessment of St. 

Elizabeths 2008 and 2013 Schedule Estimates 

Compared with Leading Practices

Page 64 GAO-14-648 Headquarters Consolidation

We assessed Department of Homeland Security (DHS) and General 

Services Administration (GSA) schedule estimates using the framework 

of the four characteristics—comprehensive, well constructed, credible, 

and controlled—associated with high-quality, reliable schedule estimates. 

Table 12 provides greater detail on our comparison of both the 2008 and 

2013 estimates with 10 specific leading practices that constitute the four 

schedule estimating characteristics.

Table 12: Summary Assessment of St. Elizabeths 2008 and 2013 Schedule Estimates Compared with Leading Practices

Overall assessment Individual assessment

Characteristic

2008

schedule

2013 

schedule Leading practice

2008

schedule

2013

schedule

Comprehensive ◔ ◔ Capturing all activities ◔ ◔

Assigning resources to all activities ○ ○

Establishing the duration of all activities ◑ ◑

Well constructed ◔ ○ Sequencing all activities ◑ ○

Confirming that the critical path is valid ◔ ○

Ensuring reasonable total float ◔ ○

Credible ◔ ◔ Verifying that the schedule is traceable horizontally 

and vertically 

○ ○

Conducting a schedule risk analysis ◔ ◔

Controlled ◔ ◔ Updating the schedule with actual progress and logic ◔ ◔

Maintaining a baseline schedule ○ ◔

● = Fully meets: DHS/GSA provided complete evidence that satisfies the entire criterion

◕ = Substantially meets: DHS/GSA provided evidence that satisfies a large portion of the criterion

◑ = Partially meets: DHS/GSA provided evidence that satisfies about half of the criterion

◔ = Minimally meets: DHS/GSA provided evidence that satisfies a small portion of the criterion

○ = Does not meet: DHS/GSA provided no evidence that satisfies any of the criterion

Source: GAO analysis of Department of Homeland Security and General Services Administration schedule data. | GAO-14-648

Appendix VI: Summary Assessment of St. 

Elizabeths 2008 and 2013 Schedule 

Estimates Compared with Leading Practices
Appendix VII: Comments from the Department 

of Homeland Security

Page 65 GAO-14-648 Headquarters Consolidation

Appendix VII: Comments from the 

Department of Homeland Security 
Appendix VII: Comments from the Department 

of Homeland Security

Page 66 GAO-14-648 Headquarters Consolidation
Appendix VII: Comments from the Department 

of Homeland Security

Page 67 GAO-14-648 Headquarters Consolidation
Appendix VIII: Comments from General 

Services Administration

Page 68 GAO-14-648 Headquarters Consolidation

Appendix VIII: Comments from General 

Services Administration
Appendix VIII: Comments from General 

Services Administration

Page 69 GAO-14-648 Headquarters Consolidation
Appendix IX: GAO Contacts and Staff 

Acknowledgments

Page 70 GAO-14-648 Headquarters Consolidation

David C. Maurer, Director, Homeland Security and Justice Issues, (202) 

512-9627 or maurerd@gao.gov

David J. Wise, Director, Physical Infrastructure Issues, (202) 512-2834 or 

wised@gao.gov

In addition to the contacts named above, John Mortin (Assistant Director), 

Karen Richey (Assistant Director), Juana Collymore, Giselle Cubillos, 

Daniel Hoy, Abishek Krupanand, Jennifer Leotta, and David Lutter made 

key contributions to this report. Also contributing to this report were 

Charles Bausell, Susan Hsu, Eric Hauswirth, Tracey King, Linda Miller, 

Jan Montgomery, and Cynthia Saunders.

Appendix IX: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments:

(441178)
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