GAO-04-329R FTE Transfers to DHS 

United States General Accounting Office

Washington, DC 20548 

April 30, 2004 

The Honorable Don Young 

Chairman 

Committee on Transportation and Infrastructure 

United States House of Representatives 

Subject: Transfer of Budgetary Resources to the Department of Homeland Security

(DHS) 

Dear Mr. Chairman: 

The enactment of the Homeland Security Act of 20021

 led to the most substantial 

reorganization of the federal government since the 1940s by creating the Department 

of Homeland Security (DHS). Established in January 2003, DHS combined 29 

program functions that were transferred from 10 agencies, referred to as the legacy 

agencies (appendix I lists the functions, by agency, identified for transfer).2 In 

addition, legacy agencies transferred resources for support functions, such as offices 

of inspectors general and management and support. DHS was created to improve the 

government’s coordination of efforts to protect against threats to the homeland. 

According to the President’s proposal to create DHS, the reorganization was also 

designed to, among other things, achieve future savings through the elimination of 

redundancies among the transferred programs. Given the breadth and magnitude of 

the reorganization, questions have been raised among members of Congress and in 

the media about whether the creation of DHS would prompt increases in the size of 

the workforces at the agencies affected by the reorganization. 

This report responds to your request that we examine how the transfer of full-time 

equivalent (FTE) positions—a workforce measure equal to one work year or 2,080 

nonovertime hours—to DHS was conducted at the agencies involved in the 

transfer. Specifically, in this report, we (1) identify the budgetary resources and 

number of FTEs transferred from the legacy agencies to DHS, (2) compare the 

number of FTEs at DHS with the number of FTEs transferred from functions at 

legacy agencies, (3) identify differences between legacy agency fiscal year 2003 FTE 

balances after the transition and their fiscal year 2004 FTE requests, and (4) discuss 

any DHS efforts to identify opportunities to achieve personnel cost savings related to 

the reorganization. 

 

1

P.L. 107-296 (Nov. 25, 2002). 

2

As of March 1, 2003, the Federal Emergency Management Agency (FEMA) transferred to DHS and no 

longer exists as a stand-alone federal agency. Therefore, there are nine legacy agencies currently in 

existence. 
 

Page 2 GAO-04-329R FTE Transfers to DHS 

As agreed with your office, we are not reporting on changes to the contractor 

workforce because reliable data on the total number of contractor employees are not 

available. Except for cases involving certain cost reimbursement contracts, the 

government generally does not require its contractors to report on the number of 

employees involved in performing government contracts. We are not aware of any 

source from which complete and reliable data on this matter would be readily 

available. Similarly, we are also not providing information on the dollar value of 

contracts transferred by legacy agencies to DHS because, according to DHS officials, 

such information is not readily available for the inventory of contracts that DHS 

inherited from legacy agencies. 3 DHS officials report that they have created a 

contract transfer list based on on-going contract obligations, which at the time of the 

DHS transfer was the government-wide standard for reporting procurement actions 

to the Federal Procurement Data System (FPDS), the federal government’s central 

source of statistical information on federal contracting.4 DHS officials said that to 

obtain total contract value information for contracts transferred into the Department, 

DHS would have to compile these data from a variety of sources, most of which are 

manual, and they would not have a high degree of confidence in the data. 

According to DHS officials, FPDS does not provide data on total contract value for 

legacy agency contracts transferred to DHS in fiscal year 2003. Consistent with 

expected changes to FPDS, DHS officials stated that they are now tracking contract 

dollar value data for DHS’s new contracts executed in fiscal year 2004 and future 

years.5

The transfer of programs, funding, and personnel resources from legacy agencies to 

DHS began on March 1, 2003.6

 OMB had and continues to have responsibility for 

overseeing the transfer of FTEs, positions, and budget authority from legacy agencies 

to the new department.7

 OMB staff said that they worked with legacy agencies to 

 

3

According to DHS officials, total contract value represents the total amount estimated to be spent 

under a contract, often over multiple years. 4

According to DHS officials, contract obligations are actions that financially bind the federal 

government. DHS officials said that there is no direct correlation between total contract value and 

contract obligation amounts. DHS officials said that internal controls to ensure contract obligations 

do not exceed total contract values are in place and controlled at the local level by individual 

contracting officers. 

5

In March 2004, the Department of Homeland Security’s Office of Inspector General issued a report 

entitled “Review of the Status of Department of Homeland Security Efforts to Address Its Major 

Management Challenges,” which stated that a major challenge for DHS is the identification and 

management of its procurements. The report states that DHS has struggled to prepare a sufficiently 

detailed and accurate listing of its procurements and that data that DHS has received to date come 

from 22 different sources and do not provide total contract award information. In a report to the 

Director of the Office of Management and Budget (OMB), we conveyed our serious and continuing 

concerns with the reliability of data contained in FPDS and recommended steps to help improve data 

reliability as the successor system, FPDS-Next Generation, is implemented. See U.S. General 

Accounting Office, Reliability of Federal Procurement Data, GAO-04-295R (Washington D.C.: Dec. 30, 

2003). 

6

The Department of Homeland Security Reorganization Plan, required under Section 1502 of the 

Homeland Security Act of 2002, specified that transfers were to begin on March 1, 2003. 

7

Under 5 U.S.C. 5102(a)(3), position is defined as the work, consisting of the duties and 

responsibilities, assignable to an employee. Positions can represent full-time or part-time employees or 

can be vacant and do not represent actual full-time equivalent employment. Budget authority is the 

authority provided by law to enter into financial obligations that will result in immediate or future 
 

 GAO-04-329R FTE Transfers to DHS Page 3

determine the functions, number of corresponding FTEs and positions, and budget 

dollars to be transferred to DHS.8 Given that the transfer occurred midway through 

fiscal year 2003, OMB estimated DHS’s “gross discretionary budget authority,” which, 

according to OMB, represented a projection of what DHS’s budget authority would 

have been if DHS had been operating for the entire fiscal year 2003. OMB also 

estimated the corresponding number of fiscal year 2003 FTEs DHS would have 

needed to operate for the entire fiscal year. Once OMB developed these estimates, it 

directed the legacy agencies to reduce their fiscal year 2003 budget authority and 

FTEs by amounts equal to the amounts transferred from them to DHS. For example, 

according to OMB staff, OMB directed the Department of the Treasury to reduce its 

budget authority and FTEs from its Office of Inspector General budget account for 

fiscal year 2003, and these resources were then transferred to DHS’s Office of 

Inspector General budget account.9

 OMB also used the estimates it prepared for 

DHS’s transition in fiscal year 2003 as the basis for developing DHS’s 2004 budget 

request.10

To meet our objectives, we reviewed available data and documentation and 

interviewed officials from DHS, OMB, the nine legacy agencies still in existence, and 

the Office of Personnel Management (OPM) in Washington, D.C.11 To identify 

information on the number of FTEs and budgetary resources transferred from the 

legacy agencies to DHS, we obtained OMB estimates of fiscal year 2003 FTEs and 

“gross discretionary budget authority” transferred to DHS. To compare the number of 

FTEs at DHS after the transfer with decreases in FTEs at legacy agencies, we 

identified legacy agency functions and related budget accounts affected by the 

transfer, obtained and compiled by function and budget account FTE data from each 

legacy agency before and after the transfer, compared the results of our compilation 

with OMB estimates, and asked OMB and legacy agencies to confirm whether our 

compilations were correct.12 To identify differences between legacy agency fiscal 

year 2003 FTE balances after the transition and their fiscal year 2004 FTE requests, 

we obtained available legacy agency FTE data for functions and budget accounts 

affected by the transfer and compared these data with the fiscal year 2004 FTE 

requests developed by legacy agencies for the President’s budget. Finally, to discuss 

 outlays involving federal government funds. Budget authority includes the credit subsidy cost for 

direct loan and loan guarantee programs, but does not include authority to ensure or guarantee the 

repayment of indebtedness incurred by another person or government. The basic forms of budget 

authority include (1) appropriations, (2) borrowing authority, (3) contract authority, and (4) authority 

to obligate and expend offsetting receipts and collections. 

8

On January 7, 2003, OMB issued a directive that asked heads of selected departments and agencies to, 

among other things, identify financial, logistical, and human resources that could be transferred to 

DHS as part of the reorganization. 

9

For purposes of this report, we used the term budget account in the same context as OMB, described 

in OMB Circular A-11, Section 20.11. 

10 The President’s fiscal year 2004 budget request presented DHS as a freestanding agency and 

constructed comparable estimates from legacy agency budget accounts for fiscal years 2002 and 2003. 11Since FEMA became part of DHS on March 1, 2003, and no longer exists as a stand-alone agency, we 

met with former FEMA officials in DHS’s Emergency Preparedness and Response Directorate who 

were responsible for the FEMA transfer process. 

12Our comparison focused only on functions with budget accounts in the nine legacy agencies that 

existed after the transfer occurred. 
 

Page 4 GAO-04-329R FTE Transfers to DHS 

DHS efforts to identify opportunities to achieve personnel cost savings related to the 

reorganization, we interviewed DHS officials from the Office of the Undersecretary 

for Management and reviewed available DHS documents on cost savings 

opportunities. We also asked OMB to review our comparisons of OMB and legacy 

agency-provided data on FTEs to explain any differences between the OMB-provided 

numbers and those from the legacy agencies. In comments on this report, OMB staff 

explained that FTE estimates are made as point-in-time estimates and can change, 

but did not specifically comment on the differences between legacy agency and OMB 

data. 

In addition to analyzing FTE data on the transfer, during our review, we sought to 

analyze whether there were increases in positions, budget authority, and personnel at 

legacy agencies after the transition. However, we did not report on increases in these 

other data because some of the information obtained was either incomplete or we 

were unable to reconcile differences in data provided by OMB, OPM, and the legacy 

agencies. According to OMB staff, differences could occur because (1) estimates on 

positions were in flux at the time the transfer occurred and (2) budget authority 

estimates could have been collected at different points in time and were subject to 

change. OPM officials said that OPM’s data on personnel could differ from legacy 

agency personnel data because (1) OPM’s personnel data included both those 

personnel who were part of the formal DHS transfer as well as those personnel who 

voluntarily left their positions at legacy agencies and were hired by DHS during the 

time of the DHS transition and (2) data on personnel could have been collected at 

different points in time. 

Because of generally corresponding FTE data from OMB and legacy agencies and 

basic confirmation during interviews with knowledgeable officials, we determined 

the FTE data used to develop this report to be sufficiently reliable to meet our 

objectives for this report. We did our work from May 2003 to April 2004 in 

accordance with generally accepted government auditing standards. Appendix II 

discusses our scope and methodology in greater detail. 

Results in Brief 

OMB estimated that of the $38.28 billion transferred from 10 legacy agencies to DHS, 

$24.76 billion would support DHS’s fiscal year 2003 needs, including funding for the 

181,875 FTEs transferred from legacy agencies. Ninety-seven percent of the FTEs 

transferred were associated with seven program functions whose budget accounts 

were transferred to DHS in their entirety, including the functions of a former standalone agency, the Federal Emergency Management Agency. The nine remaining 

legacy agencies reported FTE decreases in their fiscal year 2003 budgets that 

generally matched OMB estimates of FTEs transferred to DHS. Only limited 

information was available to identify differences between legacy agency FTE 

balances after the transfer and their fiscal year 2004 requests. For the 24 budget 

accounts that were the source of the remaining 3 percent of FTEs transferred to DHS, 

the nine legacy agencies reported that, for their fiscal year 2004 requests: 
 

 GAO-04-329R FTE Transfers to DHS Page 5

• 17 of 24 budget accounts included requests for FTEs less than or equal to the 

number of FTEs remaining after the transfer,13 and 

• 7 of 24 budget accounts included requests for FTEs greater than the number of 

FTEs remaining after the transfer. 

All legacy agencies reported that requested increases in FTEs were unrelated to the 

transfer of FTEs to DHS. 

Figure 1 shows the FTEs transferred to DHS, by budget accounts, for accounts that 

were transferred in their entirety, and for accounts with remaining balances at legacy 

agencies. 

Figure 1: Percentage of FTEs Transferred to DHS Associated with Budget Accounts Transferred in their 

Entirety and Those That Remain at Legacy Agencies 

97% of FTEs transferred to DHS 

associated with program functions 

whose budget accounts were 

transferred to DHS in their entirety

3% of FTEs transferred to DHS 

from 9 agencies associated with 

24 budget accounts that remain 

at legacy agencies

176,466

FTEs

5,409

FTEs

Breakdown of Total 181,875 FTEs

Source: GAO analysis of fiscal year 2003 estimated FTEs transferred to DHS provided by OMB on August 7, 2003.

DHS officials told us that while it was too early to identify personnel savings from the 

consolidation of legacy agency program functions in DHS, the department is 

beginning to examine some opportunities that may lead to such savings. They also 

said that these savings opportunities will have to be balanced with new departmental 

mission needs as yet to be determined. 

Resource Transfer to DHS 

According to OMB, a total of $38.28 billion in unobligated funding—including fiscal 

year 2003 funding and funds from prior budget years—was transferred from the 10 

legacy agencies to DHS. Given that DHS was established midway through fiscal year 

2003, OMB estimated a transfer of $24.76 billion from legacy agencies to DHS in fiscal 

year 2003 “gross discretionary budget authority”—which represented current year 

funding DHS would have needed during fiscal year 2003. This included funds for an 

estimated 181,875 FTEs transferred from legacy agencies. OMB data also showed 

that the transfer included 209,105 full- and part-time positions.14 Table 1 shows 

 

13U.S. Department of Agriculture (USDA) officials provided fiscal year 2003 FTE data for the Animal 

and Plant Health Inspection Service—Plant Protection and Quarantine Program. 

14Positions can be part-time, full-time, or vacant and do not equate to the number of FTEs, e.g., one 

FTE can include two or more part-time positions. According to DHS and legacy agency officials, 

additional positions were scheduled to transfer to DHS after the official transfer date of March 1, 2003. 

They said position data are expected to be adjusted based on continuing negotiations between DHS 

and legacy agency offices. Some of the legacy agencies are still providing support services to DHS via 
 

Page 6 GAO-04-329R FTE Transfers to DHS 

OMB’s March 2003 estimates of the legacy agency resources that would have been 

needed to operate DHS during all of fiscal year 2003. 

Table 1: Estimated Legacy Agency Resources Needed to Operate the Department of Homeland Security 

during Fiscal Year 2003 

Legacy agency 

Fiscal year 

2003 estimated 

FTEs 

transferred a

Estimated 

positionsb

Fiscal year 2003 “gross 

discretionary budget 

authority” transferred 

(in millions of dollars)c

Agriculture 2,690 2,655d $56.0 

Commerce 35e 50 8.0 

Defense 92 105 500.0 

Energy 101 101 148.0

Federal Emergency Management 

Agencyf 5,330 8,542 2,830.0 

General Services Administration 1,497 1,713 450.0 

Health and Human Services 110 91d 500.0 

Justice 40,053 37,154d 5,500.0 

Transportation 103,073 129,302 10,348.0 

Treasury 28,894 29,392 4,417.0 

Total 181,875 g 209,105 $24,757.0 

Source: GAO analysis of OMB data as of March 2003. 

 aBased on estimates provided by OMB on August 7, 2003. Although the transfer of legacy agency resources began on March 

1, 2003, OMB estimates of FTEs are projected for the entire fiscal year 2003. This allows comparisons with other fiscal years 

that cover a 12-month period. For civilian employees in the executive branch, one FTE is equal to one work year or 2,080 

nonovertime hours. 

b

Based on data compiled by OMB as of February 28, 2003. Positions are the specific duties and responsibilities assignable to 

an employee and can be full-time, part-time, or vacant. Positions do not represent actual full-time equivalent employment. 

c

Based on estimates provided by OMB as of August 7, 2003. Given that the transfer occurred midway through fiscal year 

2003, OMB estimated DHS’s “gross discretionary budget authority,” which, according to OMB, represented a projection of what 

DHS’s budget authority would have been if DHS had been operating for the entire fiscal year 2003. According to OMB data, a 

total of $38.28 billion in unobligated funding was transferred to DHS’s budget. d

According to OMB staff, the number of positions could be lower than the number of FTEs for these agencies because OMB 

position data were not necessarily complete at the time the OMB estimates of FTEs were compiled. 

e

Although OMB FTE estimates show that 35 FTEs were transferred from the Department of Commerce to DHS for the Critical 

Infrastructure Assurance Office (CIAO), according to Department of Commerce officials, Commerce reduced the number of 

FTEs associated with this budget account by 50 FTEs because of the transfer. Commerce officials said that 50 FTEs have 

been associated with CIAO since its inception in Commerce. 

f

FEMA became a part of DHS on March 1, 2003, and no longer exists as a freestanding agency. 

g

An additional 100 new FTEs were allocated to DHS to establish a budget for departmental operations in fiscal year 2003. 

Ninety-seven percent of the estimated FTEs (176,466 FTEs) transferred were 

associated with seven program functions whose budget accounts were transferred to 

DHS in their entirety, and budget accounts for these functions no longer exist at the 

legacy agencies.15 For example, the Coast Guard was transferred from the 

Department of Transportation (DOT), and the Immigration and Naturalization Service 

(INS) was abolished and its functions were transferred from the Department of 

Justice (DOJ).16 In addition, FEMA, formerly a stand-alone agency, was merged into 

 memorandums of agreement. As of March 31, 2003, DHS had 160,201 full- and part-time civilian 

employees on board, according to OPM’s Central Personnel Data File. 15These seven program functions are the Federal Emergency Management Agency, Secret Service, 

Federal Law Enforcement Training Center, Customs Service, U.S. Coast Guard, Transportation 

Security Administration, and Immigration and Naturalization Service. 

16In comments on this report, DOJ noted that functions delegated to INS transferred to DHS, but that 

the Attorney General did not delegate to INS every function under the Immigration and Naturalization 

Act. Specifically, according to DOJ, the Attorney General continues to manage those functions that he 
 

 GAO-04-329R FTE Transfers to DHS Page 7

DHS in its entirety. The remaining 3 percent of the estimated FTEs (5,409 FTEs) 

were associated with transfers from 24 budget accounts that remain at the legacy 

agencies. For example, FTEs for the Federal Protective Service were formerly 

included in the General Services Administration’s (GSA) Real Property Activities—

Federal buildings fund—budget account and are now with DHS. In another instance, 

some FTEs were transferred from offices of inspectors general budget accounts at 

DOT, Treasury, DOJ, GSA, and USDA for a new office of inspector general budget 

account at DHS. Appendix III provides information on OMB estimates of fiscal year 

2003 FTE transfers, by function, for each legacy agency. 

In addition to the resources transferred, for DHS’s fiscal year 2003 budget, OMB 

allocated DHS an additional 100 FTEs for management staff. In fiscal year 2003, DHS 

also received $6.61 billion in budget authority through supplemental appropriations 

for a total of $31.37 billion in budget authority. 

The Homeland Security Act of 2002 requires the legacy agencies to transfer identified 

programs, personnel, and funding resources to DHS within one year of the 

department’s creation.17 According to DHS and legacy agency officials, the transfer of 

funding, FTEs, and positions is not complete; legacy agencies are still providing 

support services to DHS through memorandums of agreement. According to DHS 

and legacy agency officials, these agreements—of which there are at least 50--cover a 

variety of services such as mail and messenger services, payroll processing, computer 

network services, building security, and shuttle bus services. DHS and legacy agency 

officials told us that some of the agreements may have extended beyond the one-year 

period, and additional personnel could be transferred when these agreements end. 

However, DHS officials said that, so far, as agreements have ended, DHS has 

absorbed the additional workload without increasing FTEs or personnel because of 

DHS’s consolidation of support services. 

Our discussions with legacy agency officials indicated that it would be difficult to 

estimate (1) the number of FTEs associated with existing agreements at legacy 

agencies and (2) how FTEs might be affected once memorandums of agreement end. 

Officials said that some of the agreements were shared service arrangements where 

DHS agreed to pay a proportionate share of the total cost of services rendered; the 

agreements did not include a dedicated number of personnel providing services to 

DHS. Officials stated other agreements included staff hour cost estimates that could 

not be readily converted to FTEs. 

Legacy agency officials also indicated that legacy agencies vary in their plans for 

reassigning personnel after the agreements end. For example, officials at the 

Department of Commerce, the Department of Defense (DOD), DOJ, and GSA said 

that they do not plan to reassign staff after the agreements end because dedicated 

 did not delegate to INS, e.g., the management of certain law enforcement responsibilities related to 

visas that were delegated to DOJ’s Criminal Division. 

17Section 1502(d) of the Act states that the Department of Homeland Security Reorganization Plan shall 

become effective for an agency by the date specified in the plan or by the end of the transition period, 

whichever is earlier. Pursuant to Section 1501(2), the end of the “transition period” is January 24, 2004, 

12 months following the effective date of the Act as specified in Section 4. The Reorganization Plan 

specified an earlier date for the transfers to begin, March 1, 2003. 
 

Page 8 GAO-04-329R FTE Transfers to DHS 

staff are not providing these services or the amount of support provided is small. 

Treasury officials said that they might need to reduce staff if DHS decided to 

discontinue receiving working capital fund services, such as those for telephone 

operator services, and no other client required additional support. 

Legacy Agencies Fiscal Year 2003 FTE Decreases Generally 

Matched FTEs Transferred to DHS 

All legacy agencies reported FTE decreases in their fiscal year 2003 budgets, and 

these decreases generally matched OMB's data on the number of FTEs transferred to 

DHS.18 Specifically, data provided to us by the legacy agencies for those budget 

accounts still existing at the agencies showed that all nine legacy agencies decreased 

their budgeted FTEs by amounts that generally corresponded to OMB data on the 

FTEs transferred to DHS. Three of the nine agencies—USDA, DOT, and GSA—

provided data that showed that their FTE decreases were the same as OMB data on 

the transfer. Four of the nine agencies—Commerce, Department of Energy (DOE), 

Department of Health and Human Services (HHS), and Treasury—said that their FTE 

decreases were slightly greater than OMB’s data on FTEs transferred.19 The number 

of FTEs over and above the amounts transferred by OMB ranged from 1 FTE at DOE 

to 45 FTEs at Treasury. DOD said that it decreased its FTE budget by 1 FTE less than 

the number of FTEs in OMB’s data.20

Finally, the ninth legacy agency, DOJ, provided data showing FTE decreases that 

differed from OMB estimates associated with three budget accounts: 

• General Administration—Office of Inspector General (OIG) budget account 

DOJ said that it transferred 15 FTEs to DHS, rather than 55 FTEs as shown in 

OMB’s data. DOJ said that originally, the Treasury OIG was to transfer 155 FTEs 

to DHS and 40 FTEs to the DOJ OIG for the transfer of the Bureau of Alcohol, 

Tobacco, and Firearms to DOJ. 

However, under a second plan agreed to by DOJ, Treasury, DHS, OMB, and OPM, 

the Treasury OIG transferred 195 FTEs directly to DHS’s OIG, reducing to 15 the 

number of FTEs that DOJ’s OIG transferred to DHS’s OIG.21

 

 

18Our analysis did not include budget decreases that legacy agencies made for FEMA, the Secret 

Service, Federal Law Enforcement Training Center, Customs Service, U.S. Coast Guard, 

Transportation Security Administration, and Immigration and Naturalization Service transfers to DHS 

because budget accounts for these program functions no longer existed at legacy agencies after the 

March 1, 2003, transfer. Our analysis included other program function transfers, such as the Critical 

Infrastructure Assurance Office and Federal Protective Service because their former budget accounts 

still exist at the legacy agencies. 

19In addition to transferring the amounts identified by OMB, DOE transferred one additional FTE for 

DHS support activities. Also, HHS transferred an additional seven FTEs from the Office of Inspector 

General, Centers for Disease Control and Prevention, Food and Drug Administration, and National 

Institutes of Health. 

20According to DOD, all FTEs for the National Communication System function were transferred to 

DHS. 

21According to DOJ, the original transfer plan would have resulted in DOJ’s OIG receiving 40 

individuals from Treasury’s OIG while at the same time transferring 55 of its personnel to DHS’s OIG. 
 

 GAO-04-329R FTE Transfers to DHS Page 9

• General Administration—Salaries and expenses budget account 

 DOJ said that it transferred 10 FTEs in fiscal year 2003, rather than 93 as shown 

in OMB’s data. DOJ said that only 10 of the 93 FTEs for the General 

Administration—Salaries and expenses budget account were planned for transfer 

in 2003 and the remaining 83 FTEs were transferred in the fiscal year 2004 budget 

submission. 

• Office of Justice Programs—Justice assistance budget account 

DOJ said that it transferred 55 FTEs, rather than no FTEs as shown in OMB’s data. 

OMB staff explained that, as discussed earlier, FTE estimates are made as point in 

time estimates and can change.

Limited Information Available to Identify Differences between 

Legacy Agency FTE Balances after the Transfer and Requested 

FTEs 

As mentioned earlier, 97 percent of the estimated FTEs (176,466 FTEs) transferred 

were associated with seven program functions that were transferred to DHS in their 

entirety, and their budget accounts no longer exist at the legacy agencies. For the 24 

budget accounts that were the source of the remaining 3 percent of FTEs transferred 

to DHS, the nine legacy agencies reported that, for their fiscal year 2004 requests, 

• 17 of 24 budget accounts included requests for FTEs less than or equal to the 

number of FTEs remaining after the transfer,22and 

• 7 of 24 budget accounts included requests for FTEs greater than the number of 

FTEs remaining after the transfer. 

Figure 2 shows a breakdown of FTEs transferred by agency and budget account. 

 DOJ stated that the inspectors general for DOJ, the Department of Treasury, and DHS agreed that the 

transfers originally directed by OMB would have been inefficient and would have caused undue 

personal and mission-related disruptions, particularly to the personnel and field offices affected by the 

transfers. DOJ said that the three inspectors general conferred and agreed to a proposal that would 

avoid such disruptions but still accomplish the same overall number of transfers. 22USDA officials provided fiscal year 2003 FTE data for the Animal and Plant Health Inspection 

Service—Plant Protection and Quarantine Program. 
 

Page 10 GAO-04-329R FTE Transfers to DHS 

Figure 2: Breakdown of FTEs Transferred to DHS, by Agencies and Budget Account

Agency and budget accounts

 Federal Emergency Management Agency 

(FEMA)l 5,330 N/A N/A

Justice (DOJ)

Immigration and Naturalization Service (INS) m 39,598 N/A N/A 

Transportation (DOT)

U.S. Coast Guard (USCG)n 43,508 N/A N/A 

Transportation Security Administration (TSA)n 59,512 N/A N/A 

Treasury (Treasury) U.S. Customsn 21,570 N/A N/A U.S. Secret Servicen 6,111 N/A N/A Federal Law Enforcement Training Centern 837 N/A N/A 

Total 176,466 N/A N/A 

FY 2003 FTEs 

before transfer

FY 2003 FTEs 

after transfer

FY 2004 FTE 

request

97% of FTEs 

transferred to 

DHS associated 

with program 

functions whose 

budget accounts 

were transferred 

to DHS in their 

entirety

3% of FTEs 

transferred to 

DHS from 9 

agencies 

associated with 

24 budget 

accounts that 

remain at legacy 

agencies

176,466

FTEs

5,409

FTEs

TOTAL FTEs:

181,875

Breakdown

of FTEs

Agency and Budget Account FTEs

transferred

to DHS

FY 2003 

FTEs before 

transfer

FY 2003 

FTEs after 

transfer

FY 2004 

FTE 

request

Difference between 

FY 2004 request 

and FY 2003 FTEs 

after transfer

Increase in 

fiscal year 2004 

FTEs related to 

transfer? Agriculture (USDA)

Animal and Plant Health Inspection Service —

Salaries and expensesa 2,684 3,974 1,290 1,290 0 N/A 

Departmental Administration 2 807 805 801 -4 N/A Executive Operations —

Office of Chief Information Officer 2 344 342 342 0 N/A 

Office of Inspector General 2 723 721 721 0 N/A Commerce (Commerce)

Bureau of Industry and Security —

Operations and administration 35b 504 454 470 +16 Unrelated 

Defense (DOD)

Operations and Maintenance — Operation and

Maintenance, Defense-wide 92 c 65,950 61,797d 64,686 +2,889 Unrelated 

Energy (DOE) e

Environmental and Other Defense Activities — Defense environmental restoration and waste

management

57 2,401 2,344 1,972 -372 NA 

Environmental and Other Defense Activities— Other defense activities 22 30 8 8 0 N/A 

National Nuclear Security Administration — Office of the Administrator 22 2,009 1,987 1,697 -290 N/A 

General Services Administration (GSA)

Real Property Activities — Federal buildings fund 1,452 7,080 5,628 5,574 -54 N/A 

General Activities —

Operating expenses 25 398 373 433 +60 Unrelated 

General Activities —

Working capital fund 16f

 1,361 1,345 1,355 +10 Unrelated 

General Activities —Office of Inspector General 4 302 298 298 0 N/A 

Health and Human Services (HHS) g 

Departmental Management —

General departmental management 

110 1,646 1,536 1,532 -4 N/A 

Justice (DOJ)

Federal Bureau of Investigation—Salaries and 

expenses 307 25,179 24,872 26,740 +1,868 Unrelated 

Office of Justice Programs— 

Justice assistance --h 804 804 729 -75 N/A 

General Administration—Salaries and 

expenses 93i 686 599 658 +59 Unrelated 

General Administration—Office of Inspector 

General 55j

 496 441 409 -32 N/A 

Transportation (DOT)

Office of Inspector General— Salaries and expenses 40 470 430 430 0 N/A 

Office of the Secretary—Transportation, 

planning, research, and development

1 32 31 31 0 N/A 

Office of the Secretary—Office of Civil Rights 3 70 67 64 -3 N/A 

Office of the Secretary—Salaries and 

expenses 9 467 458 480 +22 Unrelated 

Treasury (Treasury)

Departmental Offices—Salaries and expenses 221k 1,086 860 860 0 N/A Departmental Offices— 

Office of Inspector General 155j 282 87 87 0 N/A 

Total 5,409 117,101 107,577 111,667 +4,090 -- 

Source: GAO analysis of OMB, USDA, Commerce, DOD, DOE, GSA, HHS, DOT, DOJ, and Treasury data.

Legend: N/A = Not applicable. 

Notes: 

a

USDA officials provided fiscal year 2003 FTE data for the Animal and Plant Health Inspection Service—Plant Protection and 

Quarantine Program. 

b

According to the Department of Commerce, Commerce reduced FTEs by 50 because of the transfer. 

c

According to DOD, 91 FTEs, representing all FTEs for the National Communication System, were transferred to DHS. 

d

According to DOD, the fiscal year 2003 FTE balance for the DOD—Operations and Maintenance—Operation and 

maintenance, Defense-wide budget account after the transfer included a larger decrease (-4,153 FTEs) than the 91 FTEs 

transferred to DHS because it reflects FY 2003 actual data submitted in the FY 2005 budget cycle and decreases occurred for 

other management and budgetary reasons. 

e

In addition to transferring the amounts identified by OMB, DOE transferred 1 additional FTE for DHS support activities. 

f

According to GSA, 1 FTE was transferred to DHS immediately and 15 FTEs are being retained at GSA to provide support 

services for DHS while the GSA/DHS support services are in effect. GSA’s total reduction to the working capital fund account 

as a result of the transfer is 16 FTEs. 

g

HHS transferred an additional 7 FTEs from the Office of Inspector General, Centers for Disease Control and Prevention, Food 

and Drug Administration, and National Institutes of Health. 
 

 GAO-04-329R FTE Transfers to DHS Page 11

h

According to DOJ officials, FTEs were transferred from the Office of Justice Programs to DHS in 2002. According to DOJ, 55 

FTEs were transferred from the Office of Justice Programs to DHS. 

i

DOJ officials stated that only 10 of the 93 FTEs for the General Administration—Salaries and expenses budget account were 

planned for transfer in 2003. According to DOJ, the remaining 83 FTEs were transferred in the fiscal year 2004 budget 

submission. 

j

According to DOJ officials, as part of the formation of DHS, the Office of Management and Budget (OMB), directed the 

Treasury Office of Inspector General (OIG) to transfer 155 FTEs to DHS’s OIG and directed the DOJ OIG to transfer 55 FTEs 

to DHS’s OIG. At the same time, OMB directed the Treasury OIG to transfer 40 FTEs to the DOJ OIG to compensate for the 

transfer of the Bureau of Alcohol, Tobacco, and Firearms from the Department of the Treasury to DOJ. According to DOJ, this 

would have resulted in the DOJ OIG receiving 40 individuals from the Treasury OIG while at the same time transferring 55 of its

personnel to DHS’s OIG. DOJ said that the inspectors general for DOJ, the Department of the Treasury, and DHS agreed that 

the series of transfers originally directed by OMB was inefficient and would cause undue personal and mission-related 

disruptions, particularly to the personnel and field offices affected by the proposed transfers. According to DOJ, the three 

inspectors general conferred and agreed to a proposal that would avoid such disruptions but still accomplish the same overall 

number of transfers. Under this plan, DOJ said that the Treasury OIG transferred 195 FTEs directly to DHS’s OIG (the 155 

FTEs it was required to transfer to DHS’s OIG as well as the 40 it was required to transfer to DOJ’s OIG). This reduced to 15 

(55 minus 40) the number of FTEs that DOJ’s OIG had to directly transfer to DHS’s OIG. 

k

According to the Department of the Treasury, Treasury transferred 226 FTEs from the Departmental Offices—Salaries and 

expenses budget account to DHS. 

l

FEMA became a part of DHS on March 1, 2003, and no longer exists as a freestanding agency with its own budget accounts. 

m

Under the Homeland Security Act of 2002, P.L. 107-296 (Nov. 25, 2002), the Immigration and Naturalization Service was 

abolished and its functions were transferred from the Department of Justice. In its technical comments, DOJ noted that 

functions delegated to INS transferred to DHS, but that the Attorney General did not delegate to INS every function under the 

Immigration and Naturalization Act. Specifically, according to DOJ, the Attorney General continues to manage those functions 

that he did not delegate to INS, e.g., the management of certain law enforcement responsibilities related to visas that were 

delegated to DOJ’s Criminal Division. 

n

U.S. Coast Guard, Transportation Security Administration, U.S. Customs, U.S. Secret Service, and Federal Law Enforcement 

Training Center budget accounts were transferred to DHS in their entirety, and budget accounts for these functions no longer 

exist at the legacy agencies. 

We asked the five agencies that provided data showing that they requested increased 

FTEs associated with seven budget accounts to explain why they requested these 

increases. For all seven budget accounts, agency officials said that requested 

increases in FTEs were for programmatic or mission changes in the programs. 

Specifically, for those budget accounts: 

• GSA requested 10 additional FTEs for its working capital fund. A GSA official 

explained that the additional FTEs were requested to staff GSA’s Human Capital 

Strategy and Competitive Sourcing Initiatives related to the President’s 

Management Agenda and for other programmatic changes unrelated to the 

transfer.23

 

• GSA requested 60 additional FTEs for its General Activities—Operating expenses 

budget account. A GSA official said that the requested increase was a result of 

the restructuring of the GSA budget internally, which would have occurred 

regardless of the transfer of FTEs to DHS and is unrelated to the transfer.24 

 

23The President’s Management Agenda (PMA), announced in fiscal year 2002, is the President’s strategy 

for improving management and performance of the federal government. Under PMA, the President 

identified five government-wide management initiatives—budget and performance integration, 

strategic human capital management, improved financial performance, expanded electronic 

government, and competitive sourcing. 

24For fiscal year 2004, the General Activities—Operating expenses budget account FTE request 

included the transfer of funding for the Office of Citizen Services and Communications (OCSC) from 

the Policy and Citizen Services account. The GSA official told us that GSA requested this 

reorganization because of inherent differences in the Office of Government-wide Policy and the OCSC 

programs, and the diverse budgetary and accounting requirements needed to properly manage them. 
 

Page 12 GAO-04-329R FTE Transfers to DHS 

• DOT requested 22 additional FTEs for its Office of the Secretary—Salaries and 

expenses budget account. A DOT official said that the requested increase 

included FTEs for the Office of Intelligence and Security, which, among other 

things, coordinates DOT transportation security issues with DHS. The official 

said that the requested increase was not related to the transfer. 

• Commerce requested 16 additional FTEs for its Bureau of Industry and Security— 

Operations and administration budget account. A Commerce official said that the 

requested FTEs were for the bureau’s core export enforcement and export 

regulation missions and not related to the missions that were transferred. 

• DOD requested 2,889 additional FTEs for its Operations and Maintenance— 

Operation and maintenance, Defense-wide budget account. A DOD official said 

that the requested increase is related to changes in the composition of the budget 

account and the conversion of military positions to civilian positions and is 

unrelated to the transfer.25 

• DOJ requested 1,868 additional FTEs for its Federal Bureau of Investigation—

Salaries and expenses budget account. A DOJ official said that the requested 

increase is associated with Counterterrorism and Operations Support, 

Counterintelligence, Cybercrime Investigations, Security, Technology 

Investments, and Criminal Investigations and is unrelated to the transfer. 

• DOJ requested 59 additional FTEs for its General Administration—Salaries and 

expenses account. A DOJ official said that the requested increase is associated 

with transfers from the Department of Treasury and increases in the Office of 

Intelligence Policy and Review and is unrelated to the DHS transfer. 

DHS Officials Identified a Preliminary Plan They Hope Will Achieve 

Personnel Cost Savings 

In November 2003, officials with DHS’s Office of the Undersecretary for Management 

said that they had developed a plan that could lead to potential personnel cost 

savings through the consolidation of DHS-wide support services. According to these 

officials, DHS had begun to implement a tri-bureau initiative, which is a plan to 

identify and reorganize support services to achieve management efficiencies in the 

Bureaus of Immigration and Customs Enforcement, Citizenship and Immigration 

Services, and Customs and Border Protection. As part of this initiative, DHS said it 

was evaluating (1) how and where support services were currently being provided 

within the department; (2) what the optimal service level should be, based on quality 

 According to the official, GSA also transferred functions from the Public Buildings Service to OCSC in 

the General Activities—Operating expenses budget account and the management of the FirstGov Web 

site function from the General activities—operating expenses budget account to the Federal Citizen 

Information Center Fund. 

25A DOD official said that the requested increase was related to (1) the stand-up, or transfer in, of two 

defense agencies into the budget account—the National Defense University and Counter-Intelligence 

Field Activity; (2) transfers in of other subfunctions, such as continuity of government functions, into 

the budget account; and (3) the conversion of military positions to civilian positions as part of the 

Secretary of Defense’s plan to ensure military members serve military purposes rather than fulfill 

functions that can be performed by civilians. 
 

 GAO-04-329R FTE Transfers to DHS Page 13

and cost considerations; and (3) what was the best approach for realigning and 

reorganizing support services. For example, officials said they had begun to examine 

how motor vehicle fleet management in particular locations was currently being 

provided and how it could be reorganized at these locations so that customers could 

share services. 

Officials from the Office of the Undersecretary for Management said the 

reorganization and consolidation of these services through the tri-bureau initiative 

should yield efficiencies and cost savings, including possible personnel savings. 

However, these officials said that they were still in the early stages of identifying and 

assessing the agency’s support service needs and how they should be provided. Thus, 

DHS was not at the point of realizing savings in the support service area. In addition, 

they said that although there may be opportunities to realize personnel cost savings, 

DHS would have to consider personnel needs as new missions arise. 

In the meantime, for fiscal year 2004, DHS requested a total of 179,241 FTEs—2,634 

FTEs less than the number of FTEs transferred in fiscal year 2003. According to DHS 

officials, DHS’s fiscal year 2004 enacted appropriation will support 179,917 FTEs. 

 

Agency Comments and Our Evaluation 

On January 14, 2004 and April 14, 2004, we requested comments on this report from 

the Attorney General, Secretary of Agriculture, Secretary of Commerce, Secretary of 

Defense, Secretary of Energy, Secretary of Health and Human Services, Secretary of 

Homeland Security, Secretary of Transportation, Secretary of the Treasury, Director 

of the Office of Management and Budget, Director of the Office of Personnel 

Management, and the Administrator of the General Services Administration. The 

Department of Defense, in a letter, which is included in appendix IV, stated that it 

concurred with our report. The Department of Justice provided comments that are 

discussed below and included in appendix V. The Departments of Agriculture, 

Energy, Treasury; the Office of Personnel Management; and the General Services 

Administration stated that they had no comments on our draft report. The 

Departments of Commerce, Justice, Health and Human Services, Transportation, and 

Homeland Security and Office of Management and Budget also provided technical 

comments that we have incorporated where appropriate. 

In written comments dated February 6, 2004, DOJ stated that it was concerned that 

the draft report, as written, could be misconstrued when trying to discern what 

resources DOJ provided to DHS. DOJ provided data showing that FTEs transferred 

to DHS differed from OMB estimates for transfers associated with three DOJ budget 

accounts. We included additional language in the report to reflect the information 

provided by DOJ. DOJ also stated that while the draft report referred to the transfer 

of INS to DHS, the functions of INS were transferred to DHS and INS was abolished. 

We included additional language in the report to clarify how INS functions were 

transferred. Regarding differences in OMB and DOJ provided data on FTEs 

transferred to DHS, in comments provided during an interview with us on March 12, 

2004, OMB staff said that there could be differences between these data because 
 

Page 14 GAO-04-329R FTE Transfers to DHS 

OMB gave agencies flexibility and discretion to determine “what made sense” for the 

transfer of functions. 

DHS officials commented that DHS has made “significant progress” in consolidating 

services under fewer service providers within the department. Specifically, these 

officials said that DHS had reduced the number of financial management service 

providers from 19 to 10, separate contracting offices from 13 to 8, human resource 

offices from 22 to 7, and property management systems from 22 to 3. In addition, 

they also indicated that DHS had reduced its payroll systems from 8 to 3, and it 

expects to pay all of its employees using one system by the end of the year. DHS 

officials said that they believe that their continued focus on consolidation and 

integration of services and service providers will aid DHS in realizing further savings 

and efficiencies in support of its overall mission. Because DHS provided this 

information after the completion of our review, we were not able to assess these DHS 

efforts. 

_ _ _ _ _ 

As agreed with your office, unless you publicly announce the contents of this report 

earlier, we plan no further distribution until 15 days from the report date. At that 

time, we will send copies of this report to other interested congressional committees 

and to the agencies included in our review. We will also make copies available to 

others upon request. In addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 

If you have any questions about this report, please contact my Assistant Director, 

John F. Mortin, or me at (202) 512-8777. Key contributors to this report were Vickie 

Miller, Barbara Stolz, Chelsa Kenney, Julian King, Christine Davis, Katherine Davis, 

Jenna Aurand, Denise Fantone, Bill Woods, Michele Mackin, and Gregory Wilmoth. 

Sincerely yours, 

Paul L. Jones, Director 

Homeland Security and Justice Issues 
 

 GAO-04-329R FTE Transfers to DHS Page 15

Appendix I 

Program Functions Transferred to the

Department of Homeland Security

List of program functions transferred to the Department of Homeland Security (DHS) 

under the Homeland Security Act of 2002, P.L. 107-296 (Nov. 25, 2002). For program 

functions in italics, budget accounts no longer exist at legacy agencies because these 

functions were transferred in their entirety to DHS. 

Department of Agriculture

1. Specified agricultural import and entry inspection activities from the Animal and 

 Plant Health Inspection Servicea

2. Plum Island Animal Disease Centerb

Department of Commerce 

3. Critical Infrastructure Assurance Officec

4. Integrated Hazard Information System (to be renamed “FIRESAT”)d

Department of Defense 

5. National Communications Systemc

6. National Bio-Weapons Defense Analysis Centere

Department of Energy 

7. Chemical and biological national security program and supporting programs and 

 activities of the nonproliferation and verification research and development 

 programe 

8. Nuclear smuggling programs and activities within the proliferation detection 

 program of the nonproliferation and verification research and development 

 programe, m

9. Nuclear assessment program and activities of the assessment, detection, and 

 cooperation program of the international materials protection and cooperation 

 programe

10. Such life sciences activities of the biological and environmental research program 

 related to microbial pathogens as the President may designate for transfer to 

 DHSe

11. Advanced scientific computing research and program activities at Lawrence 

 Livermore National Laboratory e 

12. Environmental Measurements Laboratory e 

13. National Infrastructure Simulation and Analysis Center and the energy security 

 and assurance programc

14. Nuclear Incident Response Teamf 
 

Page 16 GAO-04-329R FTE Transfers to DHS 

15. Federal Emergency Management Agencyd

General Services Administration 

16. Federal Protective Serviceg

17. Federal Computer Incident Response Centerc

Department of Health and Human Services

18. Office of Emergency Preparedness, the National Disaster Medical System, and the 

 Metropolitan Medical Response Systemd 

19. Strategic National Stockpiled,n

Department of Justice 

20. Immigration and Naturalization Servicei

21. National Infrastructure Protection Center (other than the Computer Investigations 

 and Operations Section)c

22. National Domestic Preparedness Officed

23. Domestic Emergency Support Teamsd, j 

24. Office for Domestic Preparednessg 

Department of Transportation

25. Coast Guardk

26. Transportation Security Administrationg

Department of the Treasury 

27. U.S. Customs Serviceg,h

28. U.S. Secret Servicel

29. Federal Law Enforcement Training Centerg

Source: GAO analysis of the Homeland Security Act of 2002, P.L. 107-296 (Nov. 25, 2002). 

a

P.L. 107-296, § 421. 

b

P.L. 107-296, § 310. This section authorizes the Department of Agriculture to continue research, 

diagnostic, and other activities at the Plum Island Animal Disease Center after its transfer to DHS. 

c

P.L. 107-296, § 201(g). 

d

P.L. 107-296, § 503. 

e

P.L. 107-296, § 303. 

f

P.L. 107-296, § 504. This section provides that at the direction of the Secretary of Homeland Security 

(in connection with an actual or threatened terrorist attack, major disaster, or other emergency in the 

United States), the Nuclear Incident Response Team of the Department of Energy shall operate as an 

organizational unit of DHS. The Secretary of Energy and the Administrator of the Environmental 

Protection Agency shall exercise direction, authority, and control over the team when it is not 

operating as a unit of DHS. 

g

P.L. 107-296, § 403. 

h

Certain customs revenue functions did not transfer to DHS under the Homeland Security Act, 

although Section 412 authorizes the Secretary of the Treasury to delegate such functions to DHS. i

P.L. 107-296, §§ 441, 451(b). Certain federal immigration functions relating to the care of 

unaccompanied alien children transferred to the Department of Health and Human Services under the 

Act rather than DHS. P.L. 107-296, § 462. 

j Interagency group mobilized in response to major incidents. 

k

P.L. 107-296, § 888(b). 

l

P.L. 107-296, § 821. 
 

 GAO-04-329R FTE Transfers to DHS Page 17

m

Section 303(1)(B) of the Homeland Security Act of 2002 authorizes the President to designate the 

nuclear smuggling programs and activities either for transfer to the Department of Homeland Security 

or for joint operation by the Homeland Security and Energy Departments. 

n

In its technical comments, HHS noted that Section 1705 of the Homeland Security Act divides 

responsibilities for the Strategic National Stockpile between DHS and HHS, with HHS retaining 

management authority over the stockpile. DHS, on the other hand, is to “maintain” the stockpile under 

Section 1705 and direct its response in the event of a terrorist attack or major disaster under Section 

502(3)(B). Because of the agencies’ respective spheres of authority under the Homeland Security Act, 

the agencies have entered a memorandum of agreement interpreting the Act’s stockpile transfer 

provision, Section 503(6), to require the transfer of stockpile assets, except for personnel, who are to 

remain with HHS to carry out the agency’s statutory management responsibilities. 
 

Page 18 GAO-04-329R FTE Transfers to DHS 

Appendix II

Scope and Methodology

Our objectives were to determine the number of full-time equivalent26 (FTE) positions 

and amount of funding transferred from the legacy agencies to the Department of 

Homeland Security (DHS), compare the number of FTEs at DHS after the transfer 

with decreases in FTEs from affected programs at the legacy agencies, identify 

differences between legacy agency fiscal year 2003 FTE balances after the transition 

and their fiscal year 2004 FTE requests, and describe any DHS efforts to identify 

opportunities to achieve personnel cost savings related to the reorganization. 

To meet our objectives, we conducted our work in Washington, D.C., at DHS, the 

Office of Management and Budget (OMB), the Office of Personnel Management 

(OPM), and the nine agencies that were required to transfer program functions to 

DHS under the Homeland Security Act of 2002. Referred to as legacy agencies and 

remaining after the transition, the nine agencies were the Department of Agriculture, 

Department of Defense, Department of Energy, Department of Commerce, 

Department of Justice, Department of Health and Human Services, Department of the 

Treasury, Department of Transportation, and the General Services Administration. A 

tenth agency, the Federal Emergency Management Agency (FEMA) was transferred 

in its entirety and became part of DHS on March 1, 2003. At each agency, we 

interviewed budget and program officials and obtained and reviewed documentation 

related to the transfer. In addition, we obtained and reviewed applicable laws and 

documents related to the reorganization. 

To determine the number of FTEs and amount of funding transferred from the legacy 

agencies to DHS, we met with officials at DHS, OMB, and the nine legacy agencies to 

discuss the approach OMB and DHS used to carry out the transfer.27 For each of the 

nine legacy agencies and FEMA, OMB provided estimates of the number of fiscal year 

2003 FTEs28 and fiscal year 2003 “gross discretionary budget authority”29 transferred 

to DHS. OMB also provided data on the number of positions that were transferred to 

DHS from the legacy agencies. 30 We also met with OPM officials to discuss their role 

in the transfer. 

 

26For civilian employees in the executive branch, one FTE is equal to one work year or 2,080 

nonovertime hours. 

27Funding may include support for FTEs or program funds. 

28Although the transfer of legacy agency resources began on March 1, 2003, OMB estimates of FTEs 

transferred from legacy agencies are projected for the entire fiscal year 2003. 

29Budget authority is the authority provided by law to enter into financial obligations that will result in 

immediate or future outlays involving federal government funds. Budget authority includes the credit 

subsidy cost for direct loan and loan guarantee programs, but does not include authority to ensure or 

guarantee the repayment of indebtedness incurred by another person or government. The basic forms 

of budget authority include (1) appropriations, (2) borrowing authority, (3) contract authority, and (4) 

authority to obligate and expend offsetting receipts and collections. Given that the transfer occurred 

midway through fiscal year 2003, OMB estimated DHS’s “gross discretionary budget authority,” which, 

according to OMB, represented a projection of what DHS’s budget authority would have been if DHS 

had been operating for the entire fiscal year 2003. 

30FTE and position data are not comparable. Under 5 U.S.C. 5102 (a)(3), position is defined as the 

work, consisting of the duties and responsibilities, assignable to an employee. Positions can represent 
 

 GAO-04-329R FTE Transfers to DHS Page 19

To compare the number of FTEs at DHS with decreases in FTEs from programs at 

the legacy agencies remaining after the transfer, we obtained OMB estimates of DHS 

and legacy agency budgeted FTEs and available data from each legacy agency on 

fiscal year 2003 FTE balances, before and after the transfer. We compiled OMB data 

by agency and asked each legacy agency to confirm whether our compilations were 

correct. In order to provide the most accurate data on these transfers, we compared 

OMB estimates with legacy agency data to determine whether any differences existed 

between them. We also asked OMB to review this information and to explain any 

differences between the OMB-provided numbers and those from the legacy agencies. 

OMB staff explained that FTE estimates are made as point-in-time estimates and can 

change, but did not specifically comment on differences between legacy agency and 

OMB data. In addition to analyzing FTE data, during our review, we also sought to 

analyze whether there were increases in positions, budget authority, and personnel 

after the transition. Some of the position, budget authority, and personnel 

information obtained were incomplete, and we also were unable to reconcile all the 

differences in data provided by OMB, OPM, and the legacy agencies. According to 

OMB staff, differences in position and budget authority data could occur because 

estimates on positions were in flux at the time the transfer occurred, and budget 

authority estimates could have been collected at different points in time and were 

subject to change. OPM officials said that OPM and legacy agency personnel data 

could differ because of what the data include and the point in time the data were 

collected. 

To identify differences between legacy agency fiscal year 2003 FTE balances after the 

transition and their fiscal year 2004 budget requests, we obtained available data from 

the legacy agencies associated with their fiscal year 2003 FTE budget balances after 

the transfer and fiscal year 2004 FTE requests when budget accounts remained at the 

legacy agency. We then compared agencies’ fiscal year 2003 balances after the 

transition with their fiscal year 2004 requests to determine any differences. Once we 

did our comparison, we focused on those cases where legacy agencies’ fiscal year 

2004 requested FTEs were greater than their fiscal year 2003 balances after the 

transition and asked agency officials to provide explanations for the increases. 

To describe any DHS efforts to identify opportunities to achieve personnel cost 

savings related to the reorganization, we interviewed DHS officials from the Office of 

the Undersecretary for Management about their efforts to identify such opportunities 

and barriers in the support services area. We obtained and reviewed the plans that 

they had developed to consolidate support services and that may result in cost 

savings. DHS did not, however, respond to our request to meet with those agency 

officials who could discuss with us the steps DHS is taking to identify opportunities 

and barriers to personnel cost savings in program offices. 

Because of generally corresponding FTE data from OMB and legacy agencies and 

basic confirmation during interviews with knowledgeable officials, we determined 

the FTE data used to develop this report to be sufficiently reliable to meet our 

 full-time or part-time employees or can be vacant and do not represent actual full-time equivalent 

employment. 
 

Page 20 GAO-04-329R FTE Transfers to DHS 

objectives for this report. We conducted our work from May 2003 to April 2004 in 

accordance with generally accepted government auditing standards. 
 

 GAO-04-329R FTE Transfers to DHS Page 21

Appendix III 

Fiscal Year 2003 Estimated FTEs

Transferred to the Department of Homeland Security

by Legacy Agency Function and Budget Account

The full-time equivalent (FTE) data included in tables III.1 to III.10 below are based 

on estimates provided by the Office of Management and Budget (OMB) on August 7, 

2003. Although the transfer of legacy agency resources to the Department of 

Homeland Security (DHS) began on March 1, 2003, OMB estimates are projected for 

the entire fiscal year of 2003. For civilian employees in the executive branch, one 

FTE is equal to one work year, or 2,080 nonovertime hours. 

Table III.1: Fiscal Year (FY) 2003 Estimated FTEs Transferred from the Department of Agriculture (USDA) 

to DHS by Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Agriculturea 2,690

Animal Plant and Health Inspection Service 

[USDA—Animal and Plant Health Inspection Service—Salaries and expenses 

budget account] 

2,684

Departmental Administration 

[USDA—Departmental administration budget account] 

2

Executive Operations—Office of Chief Information Officer 

[USDA—Executive Operations—Office of Chief Information Officer budget 

account] 

2

Office of the Inspector General 

[USDA—Office of the Inspector General budget account] 

2

Source: GAO analysis of OMB estimates. 

a

According to a USDA official, on March 17, 2004, 17 FTEs and personnel were transferred from the USDA's Agricultural 

Research Service to DHS as part of the transfer of the Plum Island Animal Disease Center. Although the Plum Island Animal 

Disease Center facility was transferred to DHS on June 1, 2003, under the Homeland Security Act of 2002, USDA and DHS 

agreed that the transfer of personnel resources to operate the center should be delayed to a later date. USDA entered into a 

reimbursable agreement with DHS to provide operating personnel for the center until March 17, 2004. 

Table III.2: FY 2003 Estimated FTEs Transferred from the Department of Commerce (Commerce) to DHS 

by Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Commerce 35

Critical Infrastructure Assurance Office (CIAO) 

[Commerce—Bureau of Industry and Security—Operations and administration 

budget account] a 35 b

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 15 FTEs were transferred from Commerce’s Bureau of Industry and Security—Operations and 

administration budget account to DHS’s Department-wide Technology Investments budget account. 

b

According to the Department of Commerce, 50 FTEs have been associated with CIAO since its inception in Commerce. 
 

Page 22 GAO-04-329R FTE Transfers to DHS 

Table III.3: FY 2003 Estimated FTEs Transferred from the Department of Defense (DOD) to DHS by 

Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Defense 92 

National Communications System 

[DOD—Operations and Maintenance—Operation and maintenance, Defensewide budget account] 92 

Source: GAO analysis of OMB estimates. 

Table III.4: FY 2003 Estimated FTEs Transferred from the Department of Energy (DOE) to DHS by Legacy 

Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Energy 101 

Environmental Measurements Laboratory [portion of Environmental Management 

Program Direction] 

[DOE—Environmental and Other Defense Activities—Defense environmental 

restoration and waste management budget account] 57

Energy Security and Assurance and National Infrastructure Simulation Center

[DOE—Environmental and Other Defense Activities—Other defense activities 

budget account] 22

Program Direction, Defense Nuclear Nonproliferation, Office of the Administrator, 

National Nuclear Security Administration 

[DOE—National Nuclear Security Administration—Office of the Administrator 

budget account] 22

Source: GAO analysis of OMB estimates. 

Table III.5: FY 2003 Estimated FTEs Transferred from the Federal Emergency Management Agency 

(FEMA) to DHS 

Legacy agency function and budget account Total FY 2003 FTE transfer

Federal Emergency Management Agency

[FEMA budget accounts] a 5,330

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 42 FTEs were transferred from the FEMA—Salaries and expenses budget account to DHS’s 

Departmental Operations budget account; 206 FTEs were transferred from the FEMA—Working capital fund to DHS’s Working 

capital fund; and 200 FTEs were transferred from the FEMA—Office of the Inspector General budget account to DHS’s Office 

of the Inspector General budget account. 
 

 GAO-04-329R FTE Transfers to DHS Page 23

Table III.6: FY 2003 Estimated FTEs Transferred from the General Services Administration (GSA) to DHS 

by Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

General Services Administration 1,497

Federal Protective Service 

[GSA—Real Property Activities—Federal buildings fund budget account] a 1,452

Federal Computer Incident Response Center 

[GSA—General Activities—Operating expenses budget account] 25

Working Capital Fund 

[GSA—General Activities—Working capital fund account] 16b

Office of the Inspector General 

[GSA—General Activities—Office of the Inspector General budget account] 4

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 29 FTEs were transferred from the GSA—Real Property Activities—Federal buildings fund budget 

account to DHS’s Departmental Operations budget account. 

b

According to GSA, 1 FTE was transferred to DHS immediately and 15 FTEs are being retained at GSA to provide support 

services for DHS while the GSA/DHS support services are in effect. GSA’s total reduction to the working capital fund account 

as a result of the transfer is 16 FTEs. 

Table III.7: FY 2003 Estimated FTEs Transferred from the Department of Health and Human Services 

(HHS) to DHS by Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Heath and Human Services 110 

Office of Emergency Preparedness 

—National Disaster 

 Medical System 

—Metropolitan 

 Medical Response 

 System 

[HHS—Departmental Management—General departmental management 

budget account] 

107

Departmental Management 

[HHS—Departmental Management—General departmental management 

budget account] a 3

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 3 FTEs were transferred from the HHS Departmental Management—General departmental 

management budget account to DHS’s Departmental Operations budget account. 
 

Page 24 GAO-04-329R FTE Transfers to DHS 

Table III.8: FY 2003 Estimated FTEs Transferred from the Department of Justice (DOJ) to DHS by Legacy 

Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Justice 40,053

Immigration and Naturalization Service

[DOJ—INS budget accounts] a

39,598

National Infrastructure Protection Office 

[DOJ—Federal Bureau of Investigation—Salaries and expenses budget account] 307

Office for Domestic Preparedness (from DOJ Office of Justice Programs) 

[DOJ—Office of Justice Programs—Justice assistance budget account]

-- b

General Administration—Salaries and expenses 

[DOJ—General Administration—Salaries and expenses budget account] 

93 c

Office of the Inspector General 

[DOJ—General Administration—Office of the Inspector General budget account] 55d

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 87 FTEs were transferred from the Immigration and Naturalization Service—Immigration Enforcement 

budget account to DHS’s Departmental Operations budget account. 

b

According to DOJ officials, FTEs were transferred from the Office of Justice Programs to DHS in 2002. According to DOJ, 55 

FTEs were transferred from the Office of Justice Programs to DHS. 

c

DOJ officials stated that only 10 of the 93 FTEs for the General Administration—Salaries and expenses budget account were 

planned for transfer in 2003. According to DOJ, the remaining 83 FTEs were transferred in the fiscal year 2004 budget 

submission. 

d

According to DOJ officials, as part of the formation of DHS, OMB directed the Treasury Office of Inspector General (OIG) to 

transfer 155 FTEs to DHS’s OIG and directed the DOJ OIG to transfer 55 FTEs to DHS’s OIG. At the same time, OMB 

directed the Treasury OIG to transfer 40 FTEs to the DOJ OIG to compensate for the transfer of the Bureau of Alcohol, 

Tobacco, and Firearms from the Department of the Treasury to DOJ. According to DOJ, this would have resulted in the DOJ 

OIG receiving 40 individuals from the Treasury OIG while at the same time transferring 55 of its personnel to DHS’s OIG. DOJ 

said that the inspectors general for DOJ, the Department of the Treasury, and DHS agreed that the series of transfers originally 

directed by OMB was inefficient and would cause undue personal and mission-related disruptions, particularly to the personnel 

and field offices affected by the proposed transfers. According to DOJ, the three inspectors general conferred and agreed to a

proposal that would avoid such disruptions but still accomplish the same overall number of transfers. Under this plan, DOJ 

said that the Treasury OIG transferred 195 FTEs directly to DHS’s OIG (the 155 FTEs it was required to transfer to DHS’s OIG 

as well as the 40 it was required to transfer to DOJ’s OIG). This reduced to 15 (55 minus 40) the number of FTEs that DOJ’s 

OIG had to directly transfer to DHS’s OIG. 
 

 GAO-04-329R FTE Transfers to DHS Page 25

Table III.9: FY 2003 Estimated FTEs Transferred from the Department of Transportation (DOT) to DHS by 

Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Transportation 103,073a

U.S. Coast Guard (USCG)

[USCG budget accounts] b 43,508 a

Transportation Security Administration (TSA)

[TSA budget accounts] c 59,512

Office of the Inspector General 

[DOT—Office of the Inspector General—Salaries and expenses budget account] 40

Office of the Secretary 

[DOT—Office of the Secretary—Salaries and expenses budget account] 9

Office of the Secretary 

[DOT—Office of the Secretary—Office of Civil Rights budget account] 3

Office of the Secretary 

[DOT—Office of the Secretary—Transportation planning, research, and 

development budget account] 1

Source: GAO analysis of OMB estimates. 

a

Includes 37,074 military FTEs. 

b

According to OMB data, 44 FTEs were transferred from the USCG—Operating expenses budget account to DHS’s 

Departmental Operations budget account. 

c

According to OMB data, 18 FTEs were transferred from TSA budget accounts to DHS’s Departmental Operations budget 

account. 
 

Page 26 GAO-04-329R FTE Transfers to DHS 

Table III.10: FY 2003 Estimated FTEs Transferred from the Department of the Treasury (Treasury) to DHS 

by Legacy Agency Function and Budget Account 

Legacy agency function and budget account Total FY 2003 FTE transfer

Treasury 28,894 

U.S. Customs

[U.S. Customs budget accounts] a

21,570

U.S. Secret Service

[U.S. Secret Service budget accounts] b 6,111

Federal Law Enforcement Training Center (FLETC)

[FLETC budget accounts] c 837 

Departmental Offices—Salaries and expenses 

[Departmental Offices—Salaries and expenses budget account] 221

Office of the Inspector General 

[Departmental Offices—Office of the Inspector General budget account] 155d

Source: GAO analysis of OMB estimates. 

a

According to OMB data, 97 FTEs were transferred from the U.S. Customs Service—Salaries and expenses budget account to 

DHS’s Departmental Operations budget account. 

b

According to OMB data, 45 FTEs were transferred from the U.S. Secret Service—Salaries and expenses budget account to 

DHS’s Departmental Operations budget account. 

c

According to OMB data, 4 FTEs were transferred from the Federal Law Enforcement Training Center—Salaries and expenses 

budget account to DHS’s Departmental Operations budget account. 

d

According to DOJ officials, as part of the formation of DHS, OMB directed the Treasury Office of Inspector General (OIG) to 

transfer 155 FTEs to DHS’s OIG and directed the DOJ OIG to transfer 55 FTEs to DHS’s OIG. At the same time, OMB 

directed the Treasury OIG to transfer 40 FTEs to the DOJ OIG to compensate for the transfer of the Bureau of Alcohol, 

Tobacco, and Firearms from the Department of the Treasury to DOJ. According to DOJ, this would have resulted in the DOJ 

OIG receiving 40 individuals from the Treasury OIG while at the same time transferring 55 of its personnel to DHS’s OIG. DOJ 

said that the inspectors general for DOJ, the Department of the Treasury, and DHS agreed that the series of transfers originally 

directed by OMB was inefficient and would cause undue personal and mission-related disruptions, particularly to the personnel 

and field offices affected by the proposed transfers. According to DOJ, the three inspectors general conferred and agreed to a

proposal that would avoid such disruptions but still accomplish the same overall number of transfers. Under this plan, DOJ 

said that the Treasury OIG transferred 195 FTEs directly to DHS’s OIG (the 155 FTEs it was required to transfer to DHS’s OIG 

as well as the 40 it was required to transfer to DOJ’s OIG). This reduced to 15 (55 minus 40) the number of FTEs that DOJ’s 

OIG had to directly transfer to DHS’s OIG. 
 

 GAO-04-329R FTE Transfers to DHS Page 27

Appendix IV 

Comments from the Department of Defense
 

Page 28 GAO-04-329R FTE Transfers to DHS 

Appendix V 

Comments from the Department of Justice
 

 GAO-04-329R FTE Transfers to DHS Page 29

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