FBI COUNTERTERRORISM

Vacancies Have Declined, 

but FBI Has Not Assessed 

the Long-Term 

Sustainability of Its 

Strategy for Addressing 

Vacancies

Report to Congressional Requesters

April 2012

GAO-12-533

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-533, a report to 

congressional requesters

April 2012

FBI COUNTERTERRORISM

Vacancies Have Declined, but FBI Has Not Assessed 

the Long-Term Sustainability of Its Strategy for 

Addressing Vacancies

Why GAO Did This Study

Following the September 11, 2001,

terrorist attacks, the FBI established 

counterterrorism as its top investigative 

priority. Since 2001, the FBI has hired 

thousands of additional staff, 

increasing its total onboard workforce 

by 38 percent. In particular, the FBI 

has increased both the size and the 

role of its headquarters CTD that is 

located in Washington, D.C. In 2005, 

the FBI reported that nearly 40 percent 

of staff positions in certain parts of 

CTD were vacant, raising concerns 

about the FBI’s ability to fulfill its most 

important mission. As requested, GAO

reviewed FBI CTD vacancies.

Specifically, this report discusses 

(1) the extent to which counterterrorism 

vacancies existed at FBI HQ since 

2005 and the reasons for the 

vacancies and (2) the impact of the 

strategies implemented by the FBI to 

address these vacancies. GAO 

obtained data on CTD vacancies from 

fiscal years 2005 through 2011 as well 

as strategies the FBI used to address 

vacancies and their associated costs. 

GAO also interviewed FBI human 

resources and counterterrorism 

officials regarding vacancies and the 

FBI’s steps to address them. This 

report is an unclassified version of a 

classified report GAO issued in 

February 2012.

What GAO Recommends

GAO recommends the FBI establish 

criteria, time frames, and other factors 

for its evaluation of the long-term 

sustainability and effectiveness of HSI

to determine whether it is the most 

effective strategy for reducing

vacancies. The FBI concurred with this 

recommendation.

What GAO Found

From fiscal years 2005 through 2011, the Federal Bureau of Investigation’s (FBI)

human capital strategies contributed to reductions in the vacancy rate for all 

positions in the Counterterrorism Division (CTD) from 26 percent to 6 percent 

(shown in figure below). Most vacancies were caused by transfers to other parts 

of the FBI. While overall vacancies declined, trends in vacancies varied by 

position. For example, vacancies for special agents and professional staff 

generally decreased each year while vacancies for intelligence analysts varied

during the same time period. 

Vacancy Rate for All CTD Positions from Fiscal Years 2005 through 2011

The FBI developed the Headquarters Staffing Initiative (HSI) in 2005 to reduce

special agent vacancies in CTD and other headquarters (HQ) divisions, and 

primarily used workforce flexibilities, such as recruitment incentives, and targeted 

recruitment to reduce vacancies for intelligence analysts and professional staff. 

Overall, FBI officials reported that these strategies have been effective in 

reducing vacancies. Specifically, HSI included two primary strategies to reduce 

vacancies: (1) allowing special agents to come to HQ on 18-month temporary 

duty assignments instead of permanent transfers and (2) providing relocation 

incentives to special agents to permanently transfer to HQ. Since 2006, GAO

estimates that the FBI has spent $50 million to staff CTD with special agents 

under HSI. According to the FBI, HSI is the primary reason agent vacancies in 

CTD were reduced. In addition, FBI officials said HSI yielded other benefits. For 

example, officials from all sections within CTD stated that HSI helped to build a 

cadre of experienced counterterrorism agents both within CTD and in field 

offices. HSI has reduced vacancies, but a 2005 FBI working group report noted

that while HSI may be effective in the short term, a long-term solution would 

require a more thorough analysis. FBI officials reported that they are planning an 

evaluation of HSI; however, they have not established criteria, time frames, and 

other factors of the evaluation. By defining these elements, the FBI could better 

ensure that the evaluation of HSI will produce accurate and relevant findings that 

can inform the long-term staffing strategy for agents in CTD and other HQ 

programs.

View GAO-12-533 or key components.

For more information, contact David C. Maurer 

at (202) 512-9627 or maurerd@gao.gov. 
Page i GAO-12-533 FBI Counterterrorism Vacancies

Letter 1 

Background 5

CTD Vacancies Have Declined since 2005, and Most Vacancies 

Were Caused by Internal Transfers within the FBI 13

FBI Staffing Initiatives Have Helped Reduce CTD Vacancies, but 

the FBI Has Not Assessed the Long-Term Sustainability of Its 

Strategy for Addressing Vacancies 22

Conclusions 34

Recommendation for Executive Action 35

Agency Comments and Our Evaluation 35

Appendix I Scope and Methodology 38

Appendix II Special Agent Headquarters Assignment 43

Appendix III Vacancy Rates for CTD and Other Operational HQ Programs 44

Appendix IV Separations from CTD by Type of Separation 48

Appendix V Comments from the Federal Bureau of Investigation 51

Appendix VI GAO Contact and Staff Acknowledgments 52

Tables

Table 1: Short-Term Recommendations to Fill Supervisory Special 

Agent Positions in HQ from Understaffing Working Group 10

Table 2: Options for Field Agents to Come to HQ under the 

Headquarters Staffing Initiative 11

Table 3: Other Benefits and Costs of the Headquarters Staffing 

Initiative 24

Contents
Page ii GAO-12-533 FBI Counterterrorism Vacancies

Table 4: Financial Expenses for the FBI Associated with HSI 

Options 28

Figures

Figure 1: Vacancy Rate for All CTD Positions from Fiscal Years 

2005 through 2011 13

Figure 2: Vacancy Rates and Separation Rates for Agents in CTD, 

Fiscal Years 2005 through 2011 17

Figure 3: Vacancy Rates and Separation Rates for Intelligence 

Analysts in CTD, Fiscal Years 2005 through 2011 19

Figure 4: Vacancy Rates and Separation Rates for Professional 

Support Staff in CTD, Fiscal Years 2005 through 2011 21

Figure 5: Agents on 18-Month TDY as Percentage of Total Agents in 

CTD, Fiscal Years 2006 through 2011 23

Figure 6: Percentage of Agents Completing 18-Month TDY 

Assignment in CTD Who Converted to Permanent 

Positions, Fiscal Years 2008 through 2011 25

Figure 7: Annual Financial Expenses for 18-Month TDYs in CTD, 

Fiscal Years 2006 through 2011 27

Figure 8: Vacancy Rates for All Staff in CTD and Other Operational 

HQ Programs, Fiscal Years 2005 through 2011 44

Figure 9: Vacancy Rates for Agents in CTD and Other Operational 

HQ Programs, Fiscal Years 2005 through 2011 45

Figure 10: Vacancy Rates for Intelligence Analysts in CTD and 

Other Operational HQ Programs, Fiscal Years 2005 

through 2011 46

Figure 11: Vacancy Rates for Professional Support Staff in CTD and 

Other Operational HQ Programs, Fiscal Years 2005 

through 2011 47

Figure 12: Separation Rates for Agents in CTD, by Type of 

Separation, for Fiscal Years 2005 through 2011 48

Figure 13: Separation Rates for Intelligence Analysts in CTD, by 

Type of Separation, for Fiscal Years 2005 through 2011 49

Figure 14: Separation Rates for Professional Support Staff in CTD, 

by Type of Separation, for Fiscal Years 2005 through 2011 50
Page iii GAO-12-533 FBI Counterterrorism Vacancies

Abbreviations

CTD Counterterrorism Division

DI Directorate of Intelligence

DOJ Department of Justice

FBI Federal Bureau of Investigation

GS General Schedule

HQ headquarters

HRD Human Resources Division 

HIS Headquarters Staffing Initiative

IC Intelligence Community

IG Inspector General

IRS Internal Revenue Service

NAPA National Academy of Public Administration

OPM Office of Personnel Management

SAHA Special Agent HQ Assignment

SET Strategic Execution Team

TDY temporary duty

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Page 1 GAO-12-533 FBI Counterterrorism Vacancies

United States Government Accountability Office 

Washington, DC 20548

April 16, 2012

Following the September 11, 2001, terrorist attacks, the Federal Bureau 

of Investigation (FBI) established counterterrorism as its top investigative 

priority and shifted resources to this area from its more traditional law 

enforcement activities, such as drug, white-collar, and violent crime. In 

addition to transferring hundreds of agents and support staff from criminal 

areas to counterterrorism, the FBI also subsequently hired thousands of 

additional agents, intelligence analysts, and other professional support 

staff to fulfill its mission. The FBI has increased in size from 

approximately 26,000 positions in fiscal year 2003 to almost 36,000 

positions in fiscal year 2012, an increase of about 38 percent. The FBI 

also increased the role that its headquarters (HQ) Counterterrorism 

Division (CTD), located in Washington, D.C., plays in managing and 

overseeing counterterrorism cases and significantly increased the number 

of staff in CTD. For example, from fiscal years 2002 through 2011 the 

number of special agents assigned to CTD increased by nearly 160 

percent.

In 2005, the FBI found that CTD was experiencing vacancies of nearly 40 

percent, raising concerns about the FBI’s ability to fulfill one of its most 

important missions. A subsequent congressional hearing on this matter 

further highlighted concerns about these vacancies and the extent to 

which the FBI had adequate numbers of staff with the right skills and 

abilities to effectively fulfill its counterterrorism mission.1

 

1 FBI Whistleblowers: Hearing before the Subcommittee on Crime, Terrorism, and 

Homeland Security of the Committee on the Judiciary, House of Representatives, 110th

Congress (May 21, 2008).

To address this 

problem, the FBI formed the Understaffing Working Group in 2005 to 

identify potential solutions to the staffing challenges at FBI HQ, including 

vacancies in CTD.

 
 

Page 2 GAO-12-533 FBI Counterterrorism Vacancies

Previous work by the Department of Justice (DOJ) Inspector General 

(IG)2 and the National Academy of Public Administration (NAPA),3 as well 

as our own work,4 has highlighted the challenges the FBI has faced in 

staffing counterterrorism positions in HQ. This work identified three broad 

challenges: (1) fully staffing CTD positions, (2) effectively utilizing and 

retaining intelligence analysts, and (3) effectively incorporating strategic 

human capital planning to ensure that its staffing is adequate to meet its 

mission. Specifically, the DOJ IG found that the FBI faced significant 

challenges in hiring and effectively utilizing intelligence analysts and 

made recommendations focusing on, among other things, developing 

hiring goals and improving intelligence training. The FBI concurred with all 

of the IG’s recommendations and subsequently took actions to address 

them.5 In 2005, NAPA reported that the FBI faced challenges retaining 

intelligence analysts and that CTD was significantly understaffed, 

subsequently recommending that the FBI fully staff CTD and that CTD 

reduce its reliance on temporary duty assignments from field offices to 

keep positions filled. Though our prior work did not provide 

recommendations to the FBI, we reported in June 2003 that the FBI 

initially did not have a strategic human capital plan,6

 

2 Department of Justice Office of Inspector General, Follow-Up Audit of the Federal 

Bureau of Investigation’s Efforts to Hire, Train, and Retain Intelligence Analysts, DOJ IG 

07-30 (Washington, D.C.: April 2007); The Federal Bureau of Investigation’s Efforts to 

Hire, Train, and Retain Intelligence Analysts, DOJ IG 05-20 (Washington, D.C.: May 

2005); and A Review of the Federal Bureau of Investigation’s Counterterrorism Program: 

Threat Assessment, Strategic Planning, and Resource Management, DOJ IG 02-38 

(Washington, D.C.: September 2002).

its performance 

management system was inadequate to discern meaningful distinctions in 

3 National Academy of Public Administration, Transforming the FBI: Progress and 

Challenges (Washington, D.C.: January 2005).

4 GAO, Intelligence Reform: Human Capital Considerations Critical to 9/11 Commission’s 

Proposed Reforms, GAO-04-1084T (Washington, D.C.: Sept. 14, 2004); FBI 

Transformation: Human Capital Strategies May Assist the FBI in Its Commitment to 

Address Its Top Priorities, GAO-04-817T (Washington, D.C.: June 3, 2004); FBI 

Transformation: FBI Continues to Make Progress in Its Efforts to Transform and Address 

Priorities, GAO-04-578T (Washington, D.C.: Mar. 23, 2004); FBI Reorganization: Progress 

Made in Efforts to Transform, but Major Challenges Continue, GAO-03-759T (Washington, 

D.C.: June 18, 2003); and FBI Reorganization: Initial Steps Encouraging but Broad 

Transformation Needed, GAO-02-865T (Washington, D.C.: June 21, 2002). 

5 The FBI informed us that the DOJ IG closed out all recommendations as of 2009.

6 In March 2004, we reported that the FBI issued its strategic human capital plan.
 

Page 3 GAO-12-533 FBI Counterterrorism Vacancies

performance, and the FBI needed to evaluate the effectiveness of its 

workforce flexibilities in fully staffing counterterrorism positions.

To assist with its oversight responsibilities, you requested that we conduct 

a review of vacancies within CTD. Specifically, this report addresses the 

following two questions:

1. What is the extent of counterterrorism vacancies at FBI HQ since 

2005 and what are the reasons for these vacancies?

2. What has been the impact of the strategies implemented by the FBI to 

address these vacancies?

In February 2012 we reported to you on the results of our work in a 

classified report. This is an unclassified version of that report. The FBI 

deemed some of the information in the prior report classified information, 

which must be protected from public disclosure. Therefore, this report 

omits classified information about staffing levels in CTD. Although the 

information provided in this report is more limited in scope, it addresses 

the same questions as the classified report. Also, the overall methodology 

used for both reports is the same.

To address these objectives, we obtained and analyzed data from the FBI 

on staffing levels and vacancies in CTD HQ from fiscal years 2005 

through 2011 for agents, intelligence analysts, and all other professional 

staff. We assessed the reliability of FBI vacancy data through electronic 

testing, internal consistency checks, and interviews with knowledgeable 

officials, and concluded that the data were sufficiently reliable for the 

purposes of this report. We compared fiscal year 2011 CTD vacancy 

rates with historic rates in CTD as well as with rates in other FBI HQ 

programs to understand whether they differed substantially. We 

interviewed officials from CTD, the Human Resources Division (HRD), 

and other relevant FBI offices to obtain their perspectives on the reasons 

for vacancies and the strategies that have been used to fill them. We also 

reviewed the 2005 FBI HQ Understaffing Report as well as other official 

FBI documents.

In addition, we obtained data on the financial costs of FBI strategies from 

fiscal years 2005 through 2011 to determine their total and average costs 

to the FBI since 2005. We also interviewed section chiefs and assistant 

section chiefs from each section within CTD to better understand their 

operations and mission and obtain their perspectives on the benefits, 

costs, and effectiveness of the strategies the FBI has used to fill these 

vacancies. We reviewed the FBI’s use of human capital flexibilities and 
 

Page 4 GAO-12-533 FBI Counterterrorism Vacancies

strategies and applicable federal statutes, regulations, and policies on the 

use of such strategies from the Office of Personnel Management (OPM), 

DOJ, and the FBI. We also compared the FBI’s efforts to assess these 

strategies against criteria for effective human capital planning established 

by us7 and OPM,8 and criteria for conducting evaluations we identified 

from social science and evaluation literature as well as our own 

guidance.9

We conducted this performance audit from May 2009 through April 2012 

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.

In addition, we interviewed officials from other federal law 

enforcement agencies, including the U.S. Marshals Service; Bureau of 

Alcohol, Tobacco, Firearms and Explosives; Drug Enforcement 

Administration; Secret Service; and Immigration and Customs 

Enforcement, to discuss the strategies they use to fill HQ vacancies. After 

conducting these interviews, we determined that these agencies’ efforts 

and missions where not directly comparable to those of the FBI. More 

details on our scope and methodology can be found in appendix I.

Shortly after we began the review in May 2009, DOJ and the FBI raised 

questions about GAO’s access authority to obtain certain information from 

the Intelligence Community (IC) about FBI counterterrorism positions, 

which resulted in the FBI temporarily not providing certain information.10

 

7 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

8 Office of Personnel Management, Human Capital Assessment and Accountability 

Framework (HCAAF), 5 C.F.R. Part 250.

9 Sources for criteria include P. H. Rossi, M. W. Lipsey, and H. E. Freeman, Evaluation: A 

Systematic Approach, 7th ed. (Thousand Oaks, Calif.: Sage Publications, Inc., 2004); 

B. R. Worthen., J. R. Sanders, and J. L. Fitzpatrick, Program Evaluation: Alternative 

Approaches and Practical Guidelines, 4th ed. (Allyn & Bacon, 2010); and GAO, Designing 

Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January 2012); and 

Assessing the Reliability of Computer-Processed Data, GAO-09-680G (Washington, D.C.: 

July 2009); and Assessing Social Program Impact Evaluations: A Checklist Approach, 

PAD-79-2 (Washington, D.C.: October 1978).

10 CTD is considered part of the IC.
 

Page 5 GAO-12-533 FBI Counterterrorism Vacancies

We obtained general information from the FBI on policies, protocols, and 

strategies related to human capital issues, such as staffing, retention, 

recruitment, and workforce planning. However, because we were 

temporarily denied access to the information, we suspended our work. On 

June 30, 2011, in response to a statutory requirement,11 the Director of 

National Intelligence finalized a directive pertaining to the Comptroller 

General’s access to IC information, which provides, among other things, 

that elements of the IC shall not categorically deny GAO access to 

information and shall not withhold information solely because that 

information relates to a program funded by the National Intelligence 

Program. As a result, we reinitiated our review in June 2011 and 

completed our work in April 2012. In February 2012, we reported to you 

on the results of our work in a classified report. This is an unclassified 

version of that report.

CTD was established in FBI HQ to coordinate the counterterrorism 

investigations conducted in FBI HQ and its field offices. CTD is staffed by 

three broad position types: special agents (agents), intelligence analysts, 

and other professional support staff. Eighty percent of agents working in 

CTD are supervisory agents, most employed at the General Schedule 

(GS) 14 level and above, the majority managing operations in the field or 

HQ under their areas of responsibility. Intelligence analysts analyze 

intelligence gathered by field agents or from other sources and 

disseminate reports throughout the FBI and the broader IC. Other 

professional support staff provide technical and administrative support to 

agents and intelligence analysts and include 54 different position types. 

Examples of professional support staff include accountants, computer 

scientists, and management and program analysts.

Since the terrorist attacks of September 11, 2001, the FBI has 

substantially increased its counterterrorism resources and capabilities, 

 

11 In general, section 348 of the Intelligence Authorization Act for Fiscal Year 2010 (Pub. 

L. No. 111-259, 124 Stat. 2654, 2700 (2010)) required the Director of National 

Intelligence, in consultation with the Comptroller General of the United States, to issue a 

written directive governing the access of the Comptroller General to information in the 

possession of an element of the IC.

Background 

FBI Counterterrorism and 

Growth after 

September 11, 2001
 

Page 6 GAO-12-533 FBI Counterterrorism Vacancies

making counterterrorism its number one priority. Specifically, from fiscal 

years 2002 through 2004, the FBI permanently realigned 674 agent 

positions to counterterrorism and counterintelligence from other areas, 

such as drug and white-collar crime. Further, from fiscal years 2006 

through 2010, congressional appropriations for counterterrorism as 

reported in DOJ budget justifications increased from $1.34 billion to 

$1.96 billion, a 46 percent increase, and the number of full-time 

equivalent positions allocated increased 31 percent.

In addition to changes in resource allocations, the FBI has also worked to 

transform its operations to better meet its counterterrorism mission. This 

transformation has been described by FBI officials as a shift from a 

reactive law enforcement agency to one that is forward thinking and 

focused on intelligence gathering and terrorism prevention. According to 

the FBI, part of this transformation included shifting the program 

management of counterterrorism cases from field offices to CTD at FBI 

HQ and significantly increasing the number of staff working in CTD. CTD 

is organized into separate branches, each headed by a deputy assistant 

director, and is broken out into sections with varying counterterrorism 

responsibilities. As part of adapting to changing priorities and threats, 

CTD has undergone various reorganizations since September 11, 2001. 

These reorganizations had implications for CTD’s human capital 

management as well as the operations under its purview. For example, in 

2007, the Weapons of Mass Destruction Directorate was created out of 

functions that were formerly part of other divisions, including CTD, which 

resulted in the transfer of positions from CTD.

Federal agencies, including the FBI, have certain human capital 

flexibilities at their disposal to help ensure that they can meet their staffing 

needs, including filling vacant positions. The FBI has primarily used 3R 

incentives (financial incentives for recruitment, relocation, and retention of 

staff) and temporary duties (TDY) to fill positions in CTD. Aside from 3R 

incentives, the FBI can bring staff from field offices or other HQ programs 

to CTD on TDY to fill positions in CTD. Employees on TDY in the FBI are 

provided additional compensation intended to cover the expenses of 

being away from home, which include lodging, meals, and incidental 

expenses.

FBI Human Capital 

Flexibilities
 

Page 7 GAO-12-533 FBI Counterterrorism Vacancies

In general, with OPM authorization, federal agencies have statutory 

authority, as amended by the Federal Workforce Flexibility Act of 2004,12

• A recruitment incentive could be given to a new employee if the 

agency has determined that the position is likely to be difficult to fill in 

the absence of such an incentive. In general, the recruitment incentive 

may not exceed 25 percent of the employee’s annual rate of basic 

pay.

to provide 3R incentives under the following circumstances:

• A relocation incentive could be given to a current employee who must 

relocate to accept a position in a different geographic area that the 

agency determines is likely to be difficult to fill in the absence of such 

an incentive. In general, the relocation incentive may not exceed 25 

percent of the employee’s annual rate of basic pay.

• A retention incentive could be given to a current employee if the 

unusually high or unique qualifications of the employee or a special 

need of the agency for the employee’s services makes retaining that 

employee essential and the agency determines that the employee 

would be likely to leave federal service in the absence of the 

incentive. In general, the retention incentive may not exceed 25 

percent of the employee’s annual rate of basic pay.

With additional approval from OPM, based on critical agency need, each 

incentive may be increased up to 50 percent, as long as the total 

incentive does not exceed 100 percent of the annual rate of basic pay. 

Any employee receiving these incentives generally must sign a service 

agreement with the agency, stating that the employee will remain in the 

position associated with the incentive for a predetermined amount of time. 

For such recruitment and relocation incentives, a service agreement may 

not exceed 4 years.

In addition to the above authority granted to federal agencies, the FBI 

was provided special statutory authority to provide relocation and 

 

12 Pub. L. No. 108-411, 118 Stat. 2305 (2004) (codified at 5 U.S.C. §§ 5753, 5754).
 

Page 8 GAO-12-533 FBI Counterterrorism Vacancies

retention incentives in the Consolidated Appropriations Act, 2005.13

• A retention incentive to an employee if (1) the unusually high or 

unique qualifications of the employee or a special need of the FBI for 

the employee’s services makes it essential to retain the employee and 

(2) the FBI determines that in the absence of the incentive, the 

employee would be likely to leave either the federal service or leave 

the FBI for a different position in the federal service.

In 

general, this authority allows the FBI, after consultation with OPM, to pay 

the following on a case-by-case basis:

• A relocation incentive to an employee subject to a mobility agreement 

who is transferred to a position in a different geographic area in which 

there is a shortage of critical skills, as determined by the FBI.

Retention and relocation incentives under the special FBI authority may 

not exceed 50 percent of the employee’s annual rate of basic pay. In 

addition, unlike the 4-year service agreement limitation for the general 

recruitment and relocation incentive authority, service agreements under 

the special FBI retention and relocation incentive authority are not subject 

to a 4-year limitation.

According to FBI policy, agents wanting to become supervisors at the GS14 level and above or wanting to be promoted to management positions 

in the field, such as special agents in charge, are required to accept an 

assignment in FBI HQ for a set period of time, generally for 2 years. 

According to FBI officials, historically, to be promoted agents were 

required to permanently transfer to a HQ division, and as soon as the 

assignment was complete, most would apply for a promotion in a field 

office. Despite this requirement as part of the agent career path, the FBI 

has historically faced challenges in filling agent positions in HQ. For 

example, a 1998 FBI survey identified that a very small percentage of 

agents surveyed indicated an interest in promotion if it required a transfer 

 

13 Pub. L. No. 108-447, 118 Stat. 2809, 2868-69 (2004) (codified, as amended, at 5 

U.S.C. § 5759). The conference report accompanying this legislation provided, in part, that 

“the conferees understand that the FBI is having difficulty retaining certain staff in critical 

senior management positions and other specialized positions. For example, since 

September 2001, the attrition rate for intelligence analysts has exceeded 10 percent. The 

conferees understand that other agencies in the Intelligence Community have more 

flexible pay and benefits authorities than the FBI and consequently are able to recruit 

talented staff from the FBI.” 

Challenges in Staffing 

Agent Positions in FBI HQ
 

Page 9 GAO-12-533 FBI Counterterrorism Vacancies

to FBI HQ.14

In response to the difficulties in filling HQ agent positions, the FBI formed 

the internal HQ Understaffing Working Group in 2005 to propose shortterm solutions to the continual inability to attract agents to serve an FBI 

HQ assignment, particularly in the FBI’s most critical HQ divisions.

In addition, of the field supervisory agents surveyed, most 

said they would step down rather than accept an assignment at FBI HQ. 

The FBI attributes the cost of living in the Washington, D.C., area and 

disruptions in one’s personal or family life caused by a relocation as the 

two primary disincentives historically deterring agents from accepting an 

HQ assignment.

15 The 

working group found, among other things, that the six priority FBI HQ 

divisions were collectively understaffed by 39 percent of the total funded 

positions.16

The working group placed a priority on determining an effective stopgap 

measure to quickly mitigate the staffing shortage and presented five 

According to the working group, this was largely a result of a 

lack of candidates applying for positions. For example, the working group 

reported that almost half of FBI HQ agent position postings in 2004 were 

canceled because of a lack of a qualified candidate pool. This shortage 

also came at a time of unprecedented expansion at FBI HQ to meet the 

priority objectives, including counterterrorism. FBI officials also stated that 

in the immediate aftermath of the terrorist attacks of September 11, 2001, 

there were limited numbers of supervisory agents with experience in 

counterterrorism cases, which further contributed to challenges in filling 

agent positions in CTD. Officials also noted that the pace and pressure of 

work in CTD was extremely high. For example, some agents were 

expected to participate in multiple briefings each day with the FBI Director 

and were expected to follow up on each lead with no margin for error. 

Officials said that these working conditions may not have been attractive 

to many qualified agents in the field.

 

14 We did not assess the reliability and validity of this survey.

15 The FBI HQ Understaffing Working Group was formed and completed its work in 2005. 

It was led by members of the Executive Development and Selection Program Section, and 

in addition consisted of members of CTD, the Criminal Division, the Cyber Division, the 

Security Division, and the Counterintelligence Division, and personnel from Directorate of 

Intelligence (DI), the Office of General Counsel, the Personnel Policy Unit, the Finance 

Division, the Administrative Services Division, and the Budget Unit.

16 The six priority FBI HQ components are CTD, the Counterintelligence Division, the 

Cyber Division, the Security Division, the Criminal Investigative Division, and DI.
 

Page 10 GAO-12-533 FBI Counterterrorism Vacancies

short-term alternatives to address vacancies among supervisory agents, 

which are listed in table 1.

Table 1: Short-Term Recommendations to Fill Supervisory Special Agent Positions 

in HQ from Understaffing Working Group

Recommendation Description

Competitive long-term TDY 

assignments

Field agents would relocate to HQ on a temporary basis 

and receive per diem payments for lodging, meals, and 

incidental expenses. Upon completion of the 

assignment, agents would return to their field offices of 

origin. 

Volunteer nonsupervisory 

TDYs to HQ

Field agents would volunteer to serve a 12-month TDY 

assignment in HQ. Positions would be noncompetitive 

and would not require selection through a career board.

Volunteer permanent transfers 

to Washington, D.C. and 

Baltimore Field Offices

Field agents would volunteer to transfer permanently to 

the Washington, D.C. or Baltimore Field Offices and be 

required to serve a TDY assignment in HQ for a 

minimum of 12 months.

Internal transfers of agents 

within HQ

Agents serving in an HQ division designated as low 

priority would be assigned to a HQ division designated 

as high priority.

Involuntary draft of field agents 

to HQ

Field agents would be required to transfer to a HQ 

division, allowable under the FBI’s transfer policy all 

agents sign when joining the agency.

Source: FBI HQ Understaffing Report.

In assessing these short-term solutions, the working group conducted 

analysis and consulted internal stakeholders to determine the feasibility of 

each. The working group noted that long-term solutions would also need 

to be developed to ensure sustainability, and that what may be best for 

the FBI in the short term may not be sufficient over the long term. 

Although the working group suggested three potential long-term solutions, 

it noted that providing long-term recommendations would require a more 

detailed study. The long-term solutions it suggested included 

(1) relocation incentives to attract field agents to HQ, (2) expansion of the 

Washington, D.C. Field Office to provide support to HQ divisions, or 

(3) the creation of a “57th Field Office” to provide support for HQ 

divisions. The 57th Field Office would be located outside of the 

Washington, D.C., metropolitan area to avoid the area’s high cost of living 
 

Page 11 GAO-12-533 FBI Counterterrorism Vacancies

and staffed principally by nonsupervisory agents.17 These agents would 

provide support to CTD and other HQ divisions.

Using the results of the working group’s analysis, the FBI implemented 

the Headquarters Staffing Initiative (HSI), which used a combination of 

18-month TDYs and financial incentives to attract agents from the field to 

HQ. In July 2005, the FBI began piloting HSI with the objective to fill 

supervisory agent positions in critical HQ divisions, including CTD. After

the FBI deemed the pilot successful, it was established as a Director’s 

initiative in December 2006. The FBI also implemented another 

recommendation from the working group, called the 57th Field Office, but 

ultimately discontinued the program in 2011 because it was not meeting 

its objective.18

Since its implementation, all agents transferring to HQ to fill supervisory 

agent positions at the GS-14 and GS-15 levels are part of HSI. HSI offers 

field agents one of two options to come to FBI HQ, as outlined in table 2.

Table 2: Options for Field Agents to Come to HQ under the Headquarters Staffing 

Initiative

Permanent transfer Eighteen-month TDY

• Agent receives 

relocation incentive of 

at least $25,000.

• Agent agrees to 

service agreement of 1 

year.

• The FBI pays for

relocation expenses.

• Agent comes to HQ on an 18-month TDY assignment.

• While agent is on TDY, his or her position in field is 

back-filled.

• Upon completion of 18-month TDY assignment, agent 

returns to his or her field office to fill former position.

• The FBI pays a per diem (including lodging and meals 

and incidental expenses) reduced by a minimum of 25 

percent the normal rate and one trip home per month.

Source: FBI.

Under either option, agents receive full credit for a tour in HQ for 

purposes of career development and may subsequently be promoted to a 

supervisory position in a field office. Upon completion of the assignment, 

agents selecting the 18-month TDY option are given the choice to either 

 

17 The FBI has 56 field offices. 

18 Details of this program, known as the Special Agent Headquarters Assignment, can be 

found in app. II. 

FBI Actions to Address 

Agent Vacancies
 

Page 12 GAO-12-533 FBI Counterterrorism Vacancies

return to their prior position in the field or convert the TDY to a permanent 

position in CTD.

In designing the 18-month TDY option of HSI, the FBI considered both 

the staffing needs of HQ as well as the tax implications of TDY expenses. 

In general, per diem and other travel expense payments to most 

employees are not taxable income if the employee is temporarily away 

from home within a certain time period.19 Internal Revenue Service (IRS) 

guidance to DOJ indicated that among other things, for such certified 

employees, the determination of whether a job location is temporary 

depends upon the facts and circumstances of each particular case and 

that courts have typically examined a variety of factors to make such a 

determination. IRS additionally noted that when examining whether a job 

location is temporary, courts have historically viewed assignments lasting 

longer than 2 years as not being temporary, resulting in a shift in the 

taxpayer’s tax home.20

 

19 In general, under Internal Revenue Code provision 26 U.S.C. § 162(a), tax deductions 

are allowed for ordinary and necessary expenses in carrying on any trade or business, 

including traveling expenses such as meals and lodging while away from home in pursuit 

of a trade or business. With respect to traveling expenses, however, this Internal Revenue 

Code provision further provides that a taxpayer shall not be treated as being temporarily 

away from home during any period of employment in excess of 1 year. An exception in 26 

U.S.C. § 162(a) provides that the 1-year limit shall not apply to any federal employee 

during any period for which such employee is certified by the Attorney General as 

traveling on behalf of the United States in TDY status to investigate or prosecute, or 

provide support services for the investigation or prosecution of, a federal crime. According 

to FBI officials, a blanket exemption has been granted that covers employees assigned to 

operational divisions under HSI. This exemption, according to the officials, was granted by 

the Assistant Attorney General pursuant to authority delegated from the Attorney General. 

Given these tax implications, while the FBI has 

historically required agents to have at least 2 years of HQ experience to 

apply for a supervisory position in a field office, to minimize the likelihood 

that agents would be required to pay taxes on TDY payments, the FBI 

chose to set the TDY term at 18 months with the expectation that many 

agents may have their assignments extended any number of months 

because of operational circumstances. Agents on TDY completing 18 

months under HSI are deemed to have met their requirement for HQ 

experience to apply for a supervisory position in a field office.

20 See, for example, Hummel v. Commissioner, T.C. Memo 1977-135; Jones v. 

Commissioner, 54 T.C. 734 (1970) and 444 F.2d 508 (5th Cir 1971); Michaels v. 

Commissioner, 53 T.C. 269, 275 (1969); and Norwood v. Commissioner, 66 T.C. 467 

(1976).
 

Page 13 GAO-12-533 FBI Counterterrorism Vacancies

From fiscal years 2005 through 2011, the vacancy rate for all positions in 

CTD declined by 20 percentage points from 26 percent at the end of fiscal 

year 2005 to 6 percent at the end of fiscal year 2011.21

Figure 1: Vacancy Rate for All CTD Positions from Fiscal Years 2005 through 2011

The vacancy rate 

decreased in each year except fiscal year 2008, when it rose from 12 

percent to 18 percent, and 2011, when it rose from 4 percent to 6 percent. 

In addition, most of the vacancies that occurred in CTD from fiscal years 

2005 through 2011 were caused by internal staff transfers to other parts 

of the FBI. Specifically, 77 percent of all separations from CTD from fiscal 

years 2005 through 2011 were due to internal transfers. (See app. IV for 

more details on separations.) Figure 1 provides vacancy rates at the end 

of each fiscal year from 2005 through 2011 for all CTD positions.

 

21 The vacancy data we received were as of the last day of each fiscal year 

(September 30), and therefore our analysis provides a snapshot of the vacancies in CTD 

at one point in time. Vacancies and vacancy rates can fluctuate throughout the fiscal year 

for a variety of reasons, for example, changes in allocations of funded positions, 

separations, and hiring of new staff members. Our analysis does not capture the 

continuous vacancy rates over the fiscal year.

CTD Vacancies Have 

Declined since 2005, 

and Most Vacancies 

Were Caused by 

Internal Transfers 

within the FBI
 

Page 14 GAO-12-533 FBI Counterterrorism Vacancies

While the overall vacancy rate in CTD declined from fiscal years 2005 

through 2011, vacancy trends varied by position type. From fiscal years 

2005 through 2011, agent vacancies decreased by 31 percentage points, 

intelligence analyst vacancies showed no steady trend, and professional 

support vacancies decreased 22 percentage points. Furthermore, 

vacancies for agents and professional support staff decreased 

consistently each year but one, while vacancies for intelligence analysts 

exhibited more variation during the period.

Regarding individual CTD sections and units, there was some variation in 

vacancies. FBI officials told us they have the flexibility to move staff 

between sections and units depending on organizational priorities. For 

example, in April 2011, the Strategic Operational Section was formed in 

CTD and staffed entirely with onboard employees from other parts of 

CTD. To the extent that certain skills are transferable between sections, 

this type of flexibility assists the FBI in ensuring that no CTD section or 

unit has a substantially higher number of vacancies than another section 

or unit. At the end of fiscal year 2011, the majority of sections had 

vacancy rates under the CTD-wide rate of 6 percent, and only a few 

sections had vacancy rates over 10 percent.

While the FBI has no targets for vacancy rates, and there is no general 

governmentwide guideline for what an acceptable vacancy rate is for an 

agency, an agency’s ability to perform its mission can be negatively 

affected if high vacancy rates are affecting agency operations. According 

to the 2005 Understaffing Working Group, an internal FBI document, and 

some CTD officials we spoke with, CTD’s vacancy rate for agents in 2005 

(41 percent) was too high and negatively affected operations. In addition, 

in fiscal years 2005 through 2007, CTD’s agent vacancy rates were 

higher than those for other HQ operational programs by 9 percentage 

points or more.22

 

22 Operational HQ programs include the Counterintelligence Division, CTD, the Criminal 

Investigation Division, the Critical Incident Response Group, the Cyber Division, DI, the 

International Operations Division, the Office of Victim Assistance, the Terrorist Screening 

Center, and the Weapons of Mass Destruction Directorate.

However, after fiscal year 2007 agent vacancy rates in 

CTD were either less than those of other HQ programs or greater by only 

1 percentage point. In addition, from fiscal years 2005 through 2011 

overall vacancy rates for CTD and other operational HQ programs did not 

differ by more than 7 percentage points. (See app. III for a comparison of 

annual vacancy rates for CTD and other operational HQ programs.) This 

CTD’s Overall Vacancy 

Rate Decreased and Varied 

by Position Type 
 

Page 15 GAO-12-533 FBI Counterterrorism Vacancies

suggests that during the first 4 years following the FBI’s prioritization of 

counterterrorism after September 11, 2001, CTD struggled more than 

other HQ programs to fill positions, but that more recently those 

challenges have lessened and are more consistent with those of other 

HQ divisions. All section chiefs as well as one deputy assistant director in 

CTD told us that current vacancy rates in CTD have no negative impact 

on their operations. In addition, officials from HRD who oversee staffing in 

all of HQ told us that the staffing challenges CTD currently faces, as well 

as the strategies to address those challenges, are no different than those 

of any other HQ division.

According to FBI officials we spoke with, the current vacancy rate of 6 

percent is relatively low and reaching a 0 percent rate is virtually 

impossible because of the steps associated with filling a position, many of 

which are in place to ensure that the FBI has qualified staff filling 

positions. For example, agents in a field office applying to positions in HQ 

must be approved by a career board, made up of officials who review 

each candidate’s application and qualifications. These career boards take 

place on monthly cycles, thus depending on when the vacancy arises 

there may be a gap in when the position is filled. For intelligence analysts 

and professional support staff, new hires may come from outside the 

agency and must therefore be vetted through a lengthy security clearance 

process before they can be brought on board. According to the FBI, 

depending on how much lead time the FBI has to prepare for a vacancy, 

there can be a lengthy period before the position is filled. Because the 

FBI does not maintain data on the number of vacancies caused by these 

delays, we were unable to estimate the number of vacancies that resulted 

from these delays.

Agent vacancies decreased by 31 percentage points from fiscal years 

2005 to 2011. As shown in figure 2, the agent vacancy rate decreased 

consistently at an average of 5 percentage points per year, from a peak of 

41 percent at the end of 2005 to a low of 10 percent at the end of fiscal 

year 2011. Our analysis of FBI data suggested that this decrease was a 

result of a combination of factors, including the decrease and subsequent 

stabilization of annual funded agent positions combined with a decrease 

in agents separating from CTD. FBI officials also told us that the decrease 

was also partially a result of increases in the number of agents applying 

for positions in CTD. Specifically, as shown in figure 2, overall funded 

positions for agents in CTD decreased from fiscal years 2005 through 

2007 and marginally increased from 2007 through 2011, meaning that 

CTD did not have large numbers of new positions to fill each year. In 

addition, the percentage of agents separating from CTD decreased from 

Agent Vacancies
 

Page 16 GAO-12-533 FBI Counterterrorism Vacancies

fiscal years 2006 through 2011. Although the separation rate increased 

from fiscal years 2005 to 2006, it did not lead to an increase in vacancies 

because the FBI began implementing HSI, which increased the number of 

onboard agents in CTD (we discuss this in more detail later in this 

report).23

 

23 In addition, the restructuring of FBI HQ was responsible for 7 percent of all agent 

separations in 2007 and 2008. In 2006, the Weapons of Mass Destruction Directorate was 

created out of functions that were formerly part of other divisions, including CTD. 

According to the FBI, staffing data reflected this change starting in 2007, and several staff 

members, including some agents, left CTD for the Weapons of Mass Destruction 

Directorate that year. In 2008, the Terrorist Screening Center was moved out of CTD to 

become its own stand-alone program, and staff, including agents, left CTD for the Terrorist 

Screening Center that year.

Figure 2 shows the year-end vacancy rates and number of 

funded positions and staff onboard as well as the yearly separation rates 

for agents from fiscal years 2005 through 2011.
 

Page 17 GAO-12-533 FBI Counterterrorism Vacancies

Figure 2: Vacancy Rates and Separation Rates for Agents in CTD, Fiscal Years 2005 

through 2011

Notes: Onboard counts include employees on TDY assignments of over 180 days. Vacancy rates and 

the number of funded positions and staff on board are as of the last day of each fiscal year. 

Separation rates are the percentage of staff separating over the course of the fiscal year. Employees 

on TDY assignments are not included in the calculation of separation rates.

a

The exact total number of funded agent positions in CTD was deemed sensitive by FBI. As a result, 

that information has been redacted from this report.
 

Page 18 GAO-12-533 FBI Counterterrorism Vacancies

b

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years, and accounted for 2 percent of total onboard agents at the end of each 

these fiscal years.

While the vacancy rate for intelligence analysts fluctuated from fiscal 

years 2005 through 2011, these fluctuations showed no consistent trends. 

Specifically, the vacancy rate for intelligence analysts was relatively 

stable from fiscal years 2005 through 2009, fluctuating close to the 

average of 11 percent for that time period. At the end of fiscal year 2010, 

the vacancy rate decreased to 0 percent, and then rose to 4 percent at 

the end of fiscal year 2011. According to our analysis of FBI data, 

fluctuations in vacancy rates for intelligence analysts were in large part a 

result of restructuring in FBI HQ, which changed the number of funded 

positions and staff separating from CTD to other divisions. As shown in 

figure 3, the decrease in vacancies for intelligence analysts from fiscal 

years 2005 through 2007 was due in part to a relatively small increase in 

funded positions from fiscal years 2005 through 2006, and a subsequent 

decrease from fiscal years 2006 through 2007, a result of the 

restructuring of FBI HQ that shifted intelligence analyst funded positions 

out of CTD. The higher vacancy rates in fiscal years 2008 and 2009 were 

related to continued increases in separation rates for those years, 

according to FBI officials, as a result of the implementation of the 

Strategic Execution Team (SET).24

 

24 The formation of the Weapons of Mass Destruction Directorate in 2007 and the 

Terrorist Screening Center in 2008 led to the transfer of intelligence analysts out of CTD, 

representing 19 percent of all intelligence analyst separations over the 2 years. 

In an initiative designed to help the 

FBI become more intelligence driven, one aspect of SET moved 

intelligence analysts to field offices to increase FBI field awareness of 

intelligence work. From fiscal years 2009 through 2010, intelligence 

analyst funded positions were stable and in fiscal years 2010 and 2011 

separation rates decreased, corresponding to the lowest vacancy rates 

from fiscal years 2005 through 2011. CTD’s ability to hire new intelligence 

analysts to fill vacancies contributed to the generally lower level of 

vacancies for intelligence analysts relative to agents. Our analysis of FBI 

data showed that for every fiscal year from 2005 through 2011, on 

average more qualified candidates applied to job announcements for 

intelligence analysts than there were vacant positions associated with 

those announcements. Figure 3 shows the year-end vacancy rates and 

number of funded positions and staff on board, as well as the yearly 

Intelligence Analyst Vacancies
 

Page 19 GAO-12-533 FBI Counterterrorism Vacancies

separation rates for intelligence analysts from fiscal years 2005 through 

2011.

Figure 3: Vacancy Rates and Separation Rates for Intelligence Analysts in CTD, 

Fiscal Years 2005 through 2011
 

Page 20 GAO-12-533 FBI Counterterrorism Vacancies

Notes: Onboard counts include employees on TDY assignments of over 180 days. Vacancy rates and 

the number of funded positions and staff on board are as of the last day of each fiscal year. 

Separation rates are the percentage of staff separating over the course of the fiscal year. Employees 

on TDY assignments are not included in the calculation of separation rates.

a

In 2010, CTD had an excess of intelligence analysts beyond its number of funded positions. Onboard 

counts include employees on TDY assignments of over 180 days. Vacancy rates and the number of 

funded positions and staff on board are as of the last day of each fiscal year. Separation rates are the 

percentage of staff separating over the course of the fiscal year. Employees on TDY assignments are 

not included in the calculation of separation rates.

b

The exact total number of funded intelligence analyst positions in CTD was deemed sensitive by FBI. 

As a result, that information has been redacted from this report.

c

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years, and accounted for 1 to 2 percent of total onboard intelligence analysts at 

the end of each of these fiscal years.

From fiscal years 2005 through 2011, the vacancy rate for all CTD 

professional support staff declined from 28 percent to 6 percent. 

Vacancies decreased every fiscal year except 2008, when the rate rose 

from 7 percent the prior year to 25 percent. As shown in figure 4, while 

the number of funded positions gradually increased, the general decrease 

in separation rates from fiscal years 2005 through 2011 and a 

consistently higher number of qualified applicants than job 

announcements were responsible for the downward trend in vacancies. 

The peak in vacancies at the end of fiscal year 2008 corresponded to 

increases in funded positions and a peak in separations. At the end of 

fiscal year 2008, CTD had a 40 percent increase in professional support 

funded positions from fiscal year 2007. In addition, separations caused by 

transfers within the FBI peaked in fiscal year 2008 at 27 percent, in part 

because of the restructuring of FBI HQ (see app. IV for details).25

 

25 The formation of the Weapons of Mass Destruction Directorate in 2007 and the 

Terrorist Screening Center in 2008 led to the transfer of professional support staff out of 

CTD, representing 36 percent of all professional support separations over the 2 years.

Figure 4 

shows the year-end vacancy rates and number of funded positions and 

staff on board, as well as the yearly separation rates for professional 

support staff from fiscal years 2005 through 2011.

Professional Support Staff
 

Page 21 GAO-12-533 FBI Counterterrorism Vacancies

Figure 4: Vacancy Rates and Separation Rates for Professional Support Staff in 

CTD, Fiscal Years 2005 through 2011

Notes: Onboard counts include employees on TDY assignments of over 180 days. Vacancy rates and 

the number of funded positions and staff on board are as of the last day of each fiscal year. 

Separation rates are the percentage of staff separating over the course of the fiscal year. Employees 

on TDY assignments are not included in the calculation of separation rates.

a

The exact total number of funded professional staff positions in CTD was deemed sensitive by FBI. 

As a result, that information has been redacted from this report.
 

Page 22 GAO-12-533 FBI Counterterrorism Vacancies

b

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years, and accounted for 11 to 13 percent of total onboard professional support 

staff at the end of each of these fiscal years.

While the FBI’s staffing initiatives have helped to reduce vacancies in 

CTD, the FBI has not yet identified its long-term strategy for addressing 

vacancies in HQ. All FBI officials we interviewed told us that HSI has 

been very successful in helping them reduce agent vacancies in CTD 

since 2005, and that its benefits outweigh its costs. In addition, FBI 

officials also told us that their use of 3R incentives and other workforce 

flexibilities has helped to fill intelligence analyst and professional support 

staff positions. While FBI officials told us that its staffing strategies have 

so far been effective, the FBI has not assessed their long-term 

sustainability nor identified a long-term strategy for maintaining adequate 

staffing levels in CTD.

According to all FBI officials we interviewed, HSI has been successful in 

helping them reduce agent vacancies in CTD, and its benefits outweigh 

its costs. Chiefs from all CTD sections we interviewed, as well other CTD 

and HRD officials, stated that without HSI they would have trouble 

keeping agent positions filled. Following the implementation of HSI as a 

full program in 2006, vacancy rates for agents began a decreasing trend 

until 2011. The 18-month TDY option has been the most commonly 

selected by agents. Specifically, our analysis of FBI data showed that 

from 2007 through 2010, 71 percent of all new agents coming to CTD 

under HSI came as 18-month TDYs, rather than permanent transfers. As 

shown in figure 5, from fiscal years 2006 through 2011, 18-month TDYs 

made up from 21 to 33 percent of all agents in CTD, suggesting that the 

program had a significant impact on vacancies.26

 

26 While CTD and FBI HQ in general depend on TDYs for other purposes, agents on 18-

month TDY accounted for 87 percent of all TDYs in CTD at the end of fiscal year 2011. 

According to the FBI, 

because it has been more frequently chosen by agents, the 18-month 

TDY option has been more effective than the permanent transfer option in 

filling vacancies.

FBI Staffing 

Initiatives Have 

Helped Reduce CTD 

Vacancies, but the FBI 

Has Not Assessed the 

Long-Term 

Sustainability of Its 

Strategy for 

Addressing Vacancies

HSI Has Helped Reduce 

Agent Vacancies in CTD
 

Page 23 GAO-12-533 FBI Counterterrorism Vacancies

Figure 5: Agents on 18-Month TDY as Percentage of Total Agents in CTD, Fiscal 

Years 2006 through 2011

However, because it is not possible to identify how many HSI participants 

would have taken a position in CTD without the relocation incentive or the 

TDY option, it is not possible to quantify this effect. Further, HSI did not 

work in isolation of other factors, which also likely affected vacancies. 

Specifically, FBI officials identified other factors that also contributed to 

the decrease in agent vacancies, including the improved operational 

efficiency in CTD and increased counterterrorism experience in the FBI in 

general. According to the FBI, following its prioritization of 

counterterrorism work in 2002, many agents across the FBI lacked the 

experience they have today in conducting counterterrorism work. This 

lack of experience combined with the high number of agent vacancies in 

CTD at the time resulted in an extremely fast-paced and high-stress work 

environment, making it difficult to attract agents to CTD. All CTD section 

chiefs told us that some field agents considering positions in CTD 

negatively perceived the division’s high pace of work and lack of 

experience of its staff. However, officials said that as CTD and the FBI 

became more experienced and achieved better staffing levels, its 

operations became more efficient. The section chiefs said specifically that 

CTD is better at gathering, analyzing, and disseminating intelligence and 

collaborates better with other components of the IC. This increase in 
 

Page 24 GAO-12-533 FBI Counterterrorism Vacancies

efficiency translated to an improved work environment, which in turn 

improved field agents’ perceptions of CTD.

In addition to filling positions, FBI officials also identified various other 

benefits that were not originally intended as part of the HSI program. 

Table 3 summarizes these other benefits as well as costs associated with 

HSI.

Table 3: Other Benefits and Costs of the Headquarters Staffing Initiative

Benefits Costs

• HQ experience without committing to permanently 

relocate.

• Stability in workforce planning.

• Exchange of experience between CTD and field offices.

• Increased leadership development among agents.

• Financial costs.

• Administrative 

burden.

• Continuity of 

operations.

Source: GAO analysis.

HQ experience without committing to permanently relocate. In 

addition to reducing vacancies, officials from HRD and all CTD sections 

stated that another benefit of HSI is that the TDY option allows agents to 

gain experience in CTD without committing to permanently relocate to 

Washington, D.C. This has been an important aspect to the program, as 

71 percent of all agents coming to CTD under HSI from 2007 through 

2010 came on TDYs. According to the FBI, this has brought three 

benefits for the agents on TDY. First, it mitigates the family disruption 

associated with relocating agents permanently, as an agent can maintain 

residence in the field. Second, for field agents affected by a depressed 

housing market, the TDY allows them to gain experience in CTD without 

incurring the financial hardship associated with selling a potentially 

undervalued home. Third, it allows agents to assess the extent to which 

they enjoy working in CTD. In addition, agents who decide to stay in CTD 

after the completion of their 18-month TDY assignment can elect to 

permanently relocate, and officials stated this has helped them fill some 

agent positions on a permanent basis. In fact, since the program began, 

32 percent of all agents on 18-month TDY converted their positions to 

permanent. This rate is comparable to the overall HQ rate, which is 

slightly lower at 31 percent. Figure 6 shows the percentage of agents on 

18-month TDY that converted to permanent status for fiscal years 2008 

through 2011.

Other Benefits of HSI
 

Page 25 GAO-12-533 FBI Counterterrorism Vacancies

Figure 6: Percentage of Agents Completing 18-Month TDY Assignment in CTD Who 

Converted to Permanent Positions, Fiscal Years 2008 through 2011

Following fiscal year 2008, when only a small number of agents 

completed their TDY terms, conversions of agents from 18-month TDYs 

to permanent positions ranged from a high of 36 percent in 2010 to a low 

of 27 percent in 2011.

Stability in workforce planning. Officials stated that another benefit of 

HSI is that it facilitates workforce planning by stabilizing a schedule of 

when agents join and separate from CTD. According to officials, 

historically agents typically transfer out of CTD after 2 to 3 years. 

However, CTD does not have a schedule for when agents who are 

permanently staffed to CTD will transfer out, making it difficult to plan 

ahead for upcoming vacancies. According to FBI officials, the 18-month 

TDY option provides certainty to CTD workforce planning by providing a 

schedule of when agents on TDY will leave, allowing the division time to 

plan for vacancies in advance.

Exchange of experience between CTD and field offices. Another 

benefit of HSI cited by FBI officials is that the TDY option circulates HQ 

counterterrorism experience to field offices and regularly brings field 

experience to CTD. Officials said that CTD provides agents with a broad 

perspective on counterterrorism investigations as well as experience 
 

Page 26 GAO-12-533 FBI Counterterrorism Vacancies

working on a large number of complex cases and collaborating with the 

IC. The Deputy Assistant Director of CTD cited examples where key 

counterterrorism operations have been successful because of field agents 

having had experience in CTD. A corollary benefit, officials also said, is 

that the constant inflow of agents on TDY to CTD brings field 

perspectives to CTD. These field perspectives benefit other agents, 

analysts, and support staff working in CTD by helping keep their work 

grounded in the reality of FBI investigations.

Increased leadership development among agents. A final benefit to 

HSI identified by officials is the increase in the pool of leaders across the 

FBI. The TDY option in HSI brings a large number of agents through CTD 

and other HQ divisions, giving them HQ experience not only valuable for 

operational purposes but also for career development purposes.

While FBI officials identified benefits to using 18-month TDYs for 

attracting agents to work in CTD, they also identified three primary costs: 

(1) financial costs, (2) administrative burden, and (3) continuity of 

operations.

Financial costs. From 2006 through September 2011, based on FBI 

data, we estimate that the FBI has incurred financial expenses of 

$50 million for the CTD staff under HSI, in addition to normal salaries and 

benefits. Most of these expenses have been associated with 18-month 

TDYs, totaling $36.5 million, according to the FBI. Figure 7 provides the 

total annual costs for all 18-month TDYs assigned to CTD for fiscal years 

2006 through 2011. According to the FBI, the average cost for each TDY 

in CTD from fiscal years 2006 through 2010 was $102,900.

Costs of HSI
 

Page 27 GAO-12-533 FBI Counterterrorism Vacancies

Figure 7: Annual Financial Expenses for 18-Month TDYs in CTD, Fiscal Years 2006 

through 2011

According to the FBI, in addition to normal salaries and benefits, the 

average financial expense incurred by FBI per permanent transfer is at 

least $113,633, including an average cost of relocation expenses of 

$88,633 and a relocation incentive of at least $25,000. Our analysis of 

FBI data estimated that the FBI spent $13.5 million on permanent 

transfers from 2006 through September 2011, $2.88 million of which was 

for relocation incentives.27 The FBI pays for specific categories of 

financial expenses associated with permanent transfers and 18-month 

TDYs, as summarized in table 4.

 

27 The FBI provided us 3R incentive data through June 6, 2011.
 

Page 28 GAO-12-533 FBI Counterterrorism Vacancies

Table 4: Financial Expenses for the FBI Associated with HSI Options

Permanent transfer 18-month TDY

Expense

Average 

cost

Expense (per 12-month 

period)

Average 

cost

Real estate assistance in 

selling home in point of origin

$52,340 Lodging $37,361

Relocation incentivea 25,000 Meals and incidental 

expenses

16,279

Shipment and storage of 

household goods

9,946 Gross-up of tax liabilities 

under the Income Tax 

Reimbursement Allowanceb

16,160

Real estate assistance in 

purchasing home in point of 

destination 

8,869 One trip home per month 3,243

Temporary quarters 5,789 Initial and return trip to and 

from TDY destination

405

Gross-up of tax liabilities under 

the Relocation Income Tax 

Allowancec

6,707

Miscellaneous expenses 4,982

Total average costa $113,633 Total average cost per 12-

month period

$68,600

Total average cost for full 

18-month termd $102,900

Source: FBI.

a

As of fiscal year 2011, relocation incentives for permanent transfers were set at a minimum of 

$25,000, or 24 percent of the agent’s base salary. As a result, our estimate of the total average cost 

of permanent transfers should be interpreted as a lower bound to the actual total average cost.

b

The Income Tax Reimbursement Allowance, in general, is a reimbursement of federal, state, and 

local income taxes incurred as a result of an extended TDY assignment in one location. According to 

the FBI, TDYs in nonoperational offices in the FBI, for example HRD, are eligible to receive this 

allowance.

c

The Relocation Income Tax Allowance, in general, is a reimbursement for additional federal, state, 

and local income taxes incurred by an employee as a result of certain travel and transportation 

expenses and relocation allowances provided by the government.

d

The sum of the individual expenses for 18-month TDYs is greater than the total average cost 

because most agents on TDY under HSI were assigned to operational divisions, such as CTD, and 

did not receive gross-up payments under the Income Tax Reimbursement Allowance.

FBI officials told us that of the two options agents can choose to come to 

HQ, the 18-month TDY option presents the lowest financial cost per agent 

to the FBI. However, a direct comparison between the two options is 

complicated by the fact that permanent agents and agents on TDY often 

stay in CTD for different periods of time. Agents on TDY are assigned to 

CTD for 18 months, whereas agents who permanently transfer to CTD 

must stay a minimum of 1 year to receive the relocation incentive and do 
 

Page 29 GAO-12-533 FBI Counterterrorism Vacancies

not have a maximum time limit. Our analysis of FBI data showed that half 

of agents permanently assigned to CTD from fiscal years 2006 through 

2011 left the division after just over 2 years, 6 months longer than agents 

on TDY. A second complicating factor in comparing TDYs to permanent 

transfers is that the FBI pays the relocation costs for agents who transfer 

from CTD to a supervisory position in a field office. Our analysis of FBI 

data from fiscal years 2005 through 2011 showed that 31 percent of all 

agent separations from CTD were due to promotions to a field office. 

Assuming that permanent transfers stay in CTD for 2 years, and taking 

into consideration that the FBI will incur the average transfer cost of 

$88,633 for 31 percent of agents in CTD, we estimate that the average 

annual cost for permanent transfers is from $70,112 to $71,112. This is 3 

to 4 percent higher than the average annual cost for agents on 18-month 

TDY, which according to the FBI is $68,600.

Administrative burden. Aside from financial costs, there are 

administrative costs to HSI that are not easily quantified. The frequency 

with which agents separate from CTD means CTD continuously needs to 

fill agent positions. As a result, there is a constant inflow and outflow of 

agents who must be trained. For example, from fiscal years 2007 through 

2011 on average 5 agents per month joined CTD on 18-month TDY, with 

6 months having more than 10 agents entering on TDY. There are 

various administrative processes involved in bringing these agents on 

board, for example, two levels of career boards made up of CTD 

managers must be held for each vacant agent position. After joining CTD, 

depending on the section, new agents may go through training in a new 

subject area. There is also a burden associated with managing the 

program, whereby CTD and HRD staff must constantly monitor the flow of 

agents to ensure that time frames are met to avoid short-term vacancies 

during the period between when one agent leaves and another joins CTD.

Continuity of operations. FBI human capital officials we met with stated 

that managing the constant flow of agents circulating through CTD can 

sometimes make it difficult to align new agents being brought on board to 

fill the positions of departing agents. In addition, all section chiefs we 

interviewed in CTD stated that the learning curve for working in their 

sections can be steep and that it can take up to 1 month or more before 

an agent is fully contributing (or independently operating), depending on 

which section an agent enters and how much counterterrorism 

experience he or she brings. Three CTD section chiefs told us that the 

constant flow of agents in and out of CTD can have impact on the 

effectiveness and morale of intelligence analysts and professional support 

staff. According to these officials, because intelligence analysts and 
 

Page 30 GAO-12-533 FBI Counterterrorism Vacancies

professional support staff in general have a longer tenure in CTD, they 

typically have the legacy and historical knowledge that is critical to 

understanding CTD intelligence and operations. CTD relies on 

intelligence analysts and professional support staff to help new agents get 

up to speed on CTD operations and procedures, which can take time 

away from their day-to-day work and analysis.

Despite these costs, FBI officials stated that they do not negatively affect 

the FBI’s ability to meet its mission. Prior to HSI, officials told us that 

agents typically only stayed in CTD 2 years anyway, after which they are 

eligible for a promotion to a supervisory position in a field office. This 

resulted in a constant turnover of agents similar to the current flow 

stemming from the 18-month TDYs. Our analysis of FBI data showed that 

of the agents who permanently transferred to CTD since fiscal year 2006, 

nearly 50 percent left the division after 2 years. Therefore, these 

challenges are not direct results of HSI, but rather a result of the amount 

of time agents typically stay at FBI HQ.

The FBI has used various strategies to fill positions for intelligence 

analysts and professional support staff, including the use of 3R 

incentives, targeted recruitment for technical positions, and developing 

clearly defined career paths for intelligence analysts. CTD faces different 

challenges in filling intelligence analyst and support staff positions than 

those related to filling agent positions. Most agents in CTD are at the GS14 and GS-15 supervisory level and are required to have a certain level of 

FBI experience in the field. Because of the unique type of work conducted 

by agents, officials told us that they do not consider external candidates 

for supervisory agent positions in CTD. In contrast, intelligence analysts 

and support staff are typically recruited from other law enforcement 

agencies, other components of the IC, and the private sector. Unlike 

agents, intelligence analysts and professional staff do not need to 

relocate from a field office to fill a position in CTD. The strategies used to 

reduce vacancies in these positions therefore differ from those used to fill 

agent positions.

The FBI uses 3R incentives to fill positions for agents, intelligence 

analysts, and professional staff. As discussed above, the FBI primarily 

has used relocation incentives for agents, totaling $4.3 million in 

The FBI Has Used 3R 

Incentives and Other 

Workforce Flexibilities to 

Fill Intelligence Analyst 

and Professional Support 

Staff Positions
 

Page 31 GAO-12-533 FBI Counterterrorism Vacancies

incentives from 2005 through 2011.28 For intelligence analyst positions, 

the FBI has primarily used recruitment incentives. According to FBI data, 

from calendar years 2005 through 2011, the FBI provided $970,489 in 

recruitment incentives, $5,000 in relocation incentives, and $58,842 in 

retention incentives for intelligence analysts. The number of incentives 

decreased steadily from calendar years 2005 through 2007, reflecting a 

diminishing need to fill positions as the number of intelligence analyst 

vacancies decreased during these years, but increased in 2008. As 

discussed previously, the separation rate for intelligence analysts peaked 

in 2008, and these incentives may have been provided to fill positions. 

Since 2009, no intelligence analyst in CTD has received any incentive, 

which corresponds to a diminished need to fill positions, as vacancies 

decreased to 0 in 2010 and remained lower than the period average in 

2011.29

Aside from financial incentives, the FBI also engages in other efforts to 

continue to attract and retain qualified intelligence analyst and 

professional support staff to FBI HQ. For example, the FBI engages in 

various targeted recruiting efforts at universities and other organizations 

to identify individuals with certain skill sets, such as technical and 

language capabilities, necessary for working in certain parts of the FBI. In 

addition, since 2005, regardless of the division intelligence analysts are 

located in, the FBI has reorganized their career development under the 

Directorate of Intelligence to better manage their development and 

training needs as well as provide them with a more centralized 

management structure. In 2011, the FBI also created three distinct career 

paths for intelligence analysts, specializing in one of the three 

components of intelligence work: (1) collection and reporting, (2) tactical 

analysis, and (3) strategic analysis. All intelligence analysts have been 

placed into one of these paths. According to FBI officials, all applicants to 

intelligence analyst positions at the FBI will choose which career path 

they wish to apply for and will be vetted against the requirements of that 

path, which will ensure that new intelligence analysts are a good match 

for the position they will fill in CTD. Officials said that before these career 

 

28 Relocation incentives used for special agents were provided as part of HSI and the 

Special Agent Headquarters Assignment. Details of the Special Agent Headquarters 

Assignment can be found in app. II. 

29 The FBI has used far fewer incentives for professional support staff than for agents and 

intelligence analysts, providing $45,030 in recruitment incentives for three management 

and program analysts since 2005. 
 

Page 32 GAO-12-533 FBI Counterterrorism Vacancies

paths, new intelligence analysts often did not know where they would be 

placed when they joined the FBI. Aside from other operational 

improvements, FBI officials stated that they expected these changes to 

improve the recruitment and retention of quality intelligence analysts in 

CTD and across the FBI.

While FBI officials told us that its strategies to fill vacant CTD positions 

with qualified candidates have so far been effective, the FBI has not yet 

assessed their long-term sustainability nor identified a long-term strategy 

for maintaining adequate staffing levels in CTD. Under the Chief Human 

Capital Officers Act of 2002,30 federal agencies have the responsibility to 

incorporate strategic workforce planning into their operations. Strategic 

workforce planning addresses two critical needs: (1) aligning an 

organization’s human capital program with its current and emerging 

mission and programmatic goals and (2) developing long-term strategies 

for acquiring, developing, and retaining staff to achieve programmatic 

goals. In addition, to ensure their long-term ability to match human capital 

with goals, both OPM31 and our32

The 2005 working group identified the need for the FBI to assess the 

long-term effectiveness of any staffing strategies implemented as a result 

of the 2005 study, reporting that long-term staffing solutions should be 

developed to ensure sustainability, and that what may be best for the FBI 

in the short term may not be sufficient over the long term. According to 

best practices state that agencies need 

to measure the effects of key initiatives to address critical skills gaps, 

evaluate the performance of those initiatives and their contribution to key 

programmatic results, and make appropriate adjustments. By following 

these principles, agencies can better ensure that their human capital 

management appropriately addresses the staffing challenges of the future 

and better contributes to their efforts to meet their missions and goals. 

Particularly given the fiscal constraints federal agencies are facing and 

will continue to face, it is incumbent on the FBI to make sure its efforts are 

cost-effective and sustainable over the long term.

 

30 Pub. L. No. 107-296, 116 Stat. 2287 (2002).

31 Office of Personnel Management, Human Capital Assessment and Accountability 

Framework (HCAAF). 

32 GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011), 

and GAO-04-39. 

The FBI Has Not Assessed 

the Long-Term 

Sustainability of Its 

Strategy for Addressing 

Vacancies
 

Page 33 GAO-12-533 FBI Counterterrorism Vacancies

the FBI, the working group’s analysis was restricted to stopgap measures, 

and its recommendation of 18-month TDYs was not assessed as a longterm strategy. The working group provided potential long-term solutions, 

but it noted that providing long-term recommendations would require a 

more detailed study to ensure that the FBI is adequately staffed in HQ. 

While FBI officials agreed that such a long-term evaluation was 

necessary, the FBI has not yet conducted such an evaluation of HSI. FBI 

officials told us in December 2011 that they were planning to review HSI, 

including the 18-month TDY option, to better assess its success since 

2005, and how it can be improved. In January 2012, the FBI provided us 

with a brief description of its future plans to evaluate HSI, including the 

overall research objectives, some methodological information, and a 

deadline of spring 2012 for preliminary results.

However, the FBI has not yet clearly defined several key elements of its 

evaluation, including planning and design, what specific data will be 

analyzed, management of the evaluation, and how results will be 

disseminated. These elements include specific actions, such as 

developing measurable objectives and criteria to measure performance, 

identifying sufficient data sources and methodology, determining and 

allocating sufficient resources to conduct the evaluation, and establishing 

time frames for completing the evaluation phases. Best practices we 

established indicate that successful evaluations should articulate these 

elements to help ensure overall usefulness, reliability, objectivity, and 

timeliness of the results.33

 

33 Rossi, Lipsey, and Freeman, Evaluation: A Systematic Approach; Worthen, Sanders, 

and Fitzpatrick, Program Evaluation: Alternative Approaches and Practical Guidelines;

For example, the FBI’s overall objective for the 

evaluation is to determine what has been learned and what, if any, 

refinements need to be made to HSI in the future. While this may be 

adequate as a broad goal, outlining more measurable objectives and 

specific criteria as well as a comparison to alternative staffing strategies 

could better position the FBI to determine the long-term sustainability of 

HSI. In addition, while the FBI has broadly defined some aspects of its 

evaluation methodology, including, for example, interviews and surveys of 

managers and HSI participants, additional programmatic data could also 

be important to use in the study, including data on staff participation, 

financial costs of the program, and the perspectives of nonsupervisory 

CTD staff, such as intelligence analysts and professional staff. 

Specifically, it is important for the FBI to account for the full costs of its 

GAO-12-208G; GAO-09-680G; and PAD-79-2.
 

Page 34 GAO-12-533 FBI Counterterrorism Vacancies

current and any proposed alternatives strategies, including financial, 

administrative, and operational costs as well as an estimation of the total 

and average per person cost. Operational or administrative costs to the 

program to be considered could include burdens placed on intelligence 

analysts and professional staff who support agents entering CTD and 

help them learn CTD operations and procedures quickly.

Aside from the objectives, evaluation methods, and costs, the FBI has 

also not yet articulated other important aspects of the evaluation, as 

called for in our best practices, such as determining and allocating 

sufficient resources for conducting the evaluation and establishing time 

frames for completing different phases of the evaluation, including 

disseminating results. By defining these key aspects, the FBI could better 

ensure that its evaluation will produce accurate and relevant findings that 

can inform the long-term staffing strategy for agents in CTD and other HQ 

programs. The FBI acknowledged that it was still in the beginning phases 

of its evaluation of HSI and that incorporating these elements into the 

evaluation could help it identify the most effective long-term staffing 

strategies moving forward.

Since the terrorist attacks of September 11, 2001, the FBI has undergone 

a major transformation and reallocation of resources toward 

counterterrorism, its number one priority. In addition to this 

transformation, the FBI has had to manage a significant expansion of 

resources and staff to fulfill this mission, particularly within CTD at FBI 

HQ. In 2005, the FBI identified that it had significantly high vacancies in 

CTD and other HQ divisions and subsequently took actions to assess and 

develop strategies to address this problem. While, according to the FBI, 

these strategies have helped to reduce vacancies and provided other 

benefits, the FBI has not yet assessed their long-term sustainability nor 

identified a long-term strategy for maintaining adequate staffing levels in 

CTD. The FBI is in the early stages of assessing its HSI program; 

however, it is too early to determine what, if any, refinements or 

alternative strategies will need to be developed in the future to ensure 

adequate staffing levels in CTD. In addition, the FBI has not yet 

established clear criteria, time frames, and other factors of the evaluation, 

which could help ensure that HSI or any proposed alternative strategies 

will be sustainable and effective over the long term. In this era of fiscal 

constraint, it is important that the FBI ensure that its staffing strategies 

allow it to meet its top priority counterterrorism mission in the most costeffective manner possible.

Conclusions 
 

Page 35 GAO-12-533 FBI Counterterrorism Vacancies

As the FBI conducts its evaluation of HSI to determine its long-term 

effectiveness and sustainability for addressing vacancies at FBI HQ, we 

recommend that the FBI Director include the following best practices for 

conducting evaluations:

• develop measurable objectives and criteria for the evaluation;

• determine and allocate sufficient resources for the evaluation;

• establish time frames for completing different phases of the 

evaluation;

• include a comparison of current strategies to any proposed 

alternatives; and

• fully account for the financial, administrative, and operational costs.

We provided a draft of this report to DOJ and FBI for review and 

comment. The FBI provided written comments, which are reprinted in 

appendix V. The FBI concurred with our recommendation and identified 

actions to implement it. We believe the steps the FBI is taking, and plans 

to take, to assess HSI should help it identify HSI as sustainable over the 

long term or determine what, if any, refinements or alternative strategies 

will need to be developed in the future to ensure adequate staffing levels 

in CTD. The FBI also provided us written technical comments, which we 

incorporated as appropriate.

We are sending copies of this report to the Attorney General, the Director 

of the FBI, appropriate congressional committees, and other interested 

parties. In addition, this report is available at no charge on the GAO 

website at http://www.gao.gov. 

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

me at (202) 512-9627 or maurerd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 36 GAO-12-533 FBI Counterterrorism Vacancies

the last page of this report. Key contributors to this report are listed in 

appendix VI.

David C. Maurer

Director, Homeland Security and Justice Issues
 

Page 37 GAO-12-533 FBI Counterterrorism Vacancies

List of Requesters

The Honorable Patrick Leahy

Chairman

The Honorable Chuck Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Daniel K. Akaka

Chairman

Subcommittee on Oversight of Government Management

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Lamar Smith

Chairman

The Honorable John Conyers, Jr.

Ranking Member

Committee on the Judiciary

House of Representatives

The Honorable Louie Gohmert

Vice-Chairman

The Honorable Bobby Scott

Ranking Member

Subcommittee on Crime, Terrorism, and Homeland Security

Committee on the Judiciary

House of Representatives
Appendix I: Scope and Methodology

Page 38 GAO-12-533 FBI Counterterrorism Vacancies

To determine the extent of counterterrorism vacancies at Federal Bureau 

of Investigation’s (FBI) headquarters (HQ) since 2005, we obtained and 

analyzed Counterterrorism Division (CTD) staffing data from the FBI on 

the number of funded positions, the number of onboard staff, and the 

number of staff on temporary duty (TDY), for fiscal years 2005 through 

2011.1

To understand the reasons for identified vacancies in CTD since 2005, 

we interviewed knowledgeable officials and staff in CTD, the Human 

Resources Division (HRD), the Directorate of Intelligence (DI), and the 

Resources Planning Office for their perspectives on the reasons for 

vacancies. In addition, we examined three general categories of FBI data, 

including how fluctuations in these data categories affected CTD 

vacancies. The categories were funded positions, separations, and 

applicants. More specifically, we obtained data from the FBI on the total 

number of funded positions in the last pay period of each year, the total 

number of staff who separated from CTD for any reason throughout each 

year,

Specifically, we calculated vacancy rates for agents, intelligence 

analysts, and professional support staff by subtracting the total number of 

onboard staff from the total number of funded positions and then dividing 

the result by the total number of funded positions. We also compared 

vacancy rates between CTD and other operational HQ programs in order 

to understand whether CTD vacancies differed substantially from those of 

other HQ programs. The FBI provided data on funded positions and 

onboard staff as of the last pay period in each fiscal year, and therefore 

any calculations based on these data only provide a snapshot of the 

vacancies in CTD at one point in time. In addition, vacancy rates can 

fluctuate throughout the fiscal year for a number of reasons, including 

changes in allocations of funded positions, separations, and hiring of new 

staff members. Therefore, our analysis does not capture the continuous 

vacancy rate fluctuations over each fiscal year.

2

 

1 The analysis was restricted to CTD because CTD coordinates all counterterrorism 

operations in FBI HQ and field offices. Other offices conduct counterterrorism work, 

including the Terrorist Screening Center (an independent office from CTD as of 2008) and 

the Directorate of Intelligence. The extent of vacancies in those offices is not addressed in 

this report.

and the total number of applicants to external vacancy 

2 Although the Terrorist Screening Center was part of CTD from fiscal years 2005 through 

2007, the FBI was unable to provide us with data on separations for the Terrorist 

Screening Center for these years by the time we completed our review. The Terrorist 

Screening Center made up from 3 to 4 percent of total CTD onboards for these years. 

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

Page 39 GAO-12-533 FBI Counterterrorism Vacancies

announcements throughout each year, from fiscal years 2005 through 

2011. To calculate separation rates, we divided the total number of 

separating staff in the given fiscal year by the average number of onboard 

staff at the beginning and end of that fiscal year. To calculate application 

rates, we calculated the average number of best qualified applicants to 

each vacant position announced by CTD. To understand the trends in the 

number of qualified applicants to internal positions in CTD, we 

interviewed knowledgeable officials in CTD and HRD. Unlike data on 

vacancies and funded positions, data on separations and applicants 

included the total number of separations and applicants throughout the 

entire fiscal year, not solely at one point during the year. As a result, 

reported data totals for separations and applicants do not match the 

reported end of the fiscal year totals for vacancies and funded positions. 

To analyze the impact that changes in the number of funded positions, 

separations, and applicants had on vacancies in CTD, we based our 

analysis on how each of these factors conceptually relates to vacancies. 

For example, an increase in the number of funded positions or high levels 

of staff separations increase the likelihood of vacancies, while high rates 

of applicants per vacancy decrease the likelihood of vacancies. We 

calculated annual changes in funded positions, separation rates, 

applicant rates, and vacancy rates to identify any patterns.

To assess the reliability of the data we received from the FBI, we 

conducted interviews with FBI officials and staff who regularly work with 

the data and were tasked with extracting the data. In our interviews we 

asked about the internal controls related to inputting the data, as well as 

the programming criteria used to extract the data. We also conducted 

electronic checks of the data, including logic checks, checks for missing 

and unreasonable data, and comparisons across different data sets the 

FBI provided that contain the same or similar information. We compared 

our own analysis to testimonial evidence from interviews with FBI officials 

and discussed with officials potential inconsistencies in the data. We 

determined all data used to be sufficiently reliable for the purposes of this 

report.

To determine the impact of the FBI’s human capital strategies on CTD 

vacancies, we reviewed the 2005 Understaffing Working Group study as 

well as other official FBI documents and interviewed officials in HRD and 

CTD. In addition, we analyzed whether there were substantive changes in 

agent vacancies following the initiation of the Headquarters Staffing 

Initiative (HSI) and whether those changes continued over the course of 

implementation. We also obtained and analyzed data on participation in 

the 18-month TDY option of HSI to determine the percentage of all agents 
Appendix I: Scope and Methodology

Page 40 GAO-12-533 FBI Counterterrorism Vacancies

in CTD on 18-month TDY and the percentage of agents on TDY who 

converted to a permanent position in CTD. We also interviewed relevant 

officials in CTD, HRD, and DI, including section chiefs and assistant 

section chiefs for all CTD sections, to obtain their perspectives of the 

benefits, costs, and effectiveness of HSI. To compare the tenure of 

agents on TDY and permanent transfer, we conducted a life table 

analysis to estimate the median number of months agents not on TDY 

stayed in CTD, for agents entering the division in fiscal years 2005 

through 2011.

We also estimated the total financial cost of HSI to CTD by obtaining data 

on the various costs associated with the program, including relocation 

incentives, relocation costs for permanent transfers, and costs for TDYs. 

We used these data to calculate the total cost of the program, as well as 

the average cost per agent on TDY and permanent transfer. While the 

FBI provided us an average 12-month cost of TDYs under HSI, it did not 

provide one for permanent transfers. To estimate the average per agent 

cost of permanent transfers, we summed the average cost of relocation 

expenses, the average relocation incentive, and an estimate of relocation 

expenses to transfer an agent from CTD to a supervisory position in the 

field.3 To determine the financial costs of other strategies, we obtained 

and analyzed data on the 3R incentives received by staff in CTD for 

calendar years 2005 through 2011, and tabulated the sum of the number 

and value of incentives by position type (agent, intelligence analyst, 

professional support) and type of incentive (recruitment, relocation, 

retention). To determine the extent to which the FBI has evaluated the 

long-term sustainability of HSI and other staffing strategies, we compared 

the FBI’s efforts to principles of strategic workforce planning established 

by us4 and the Office of Personnel Management,5

 

3 To calculate this last estimate, we first estimated the likelihood of paying these relocation 

expenses as the percentage of agents who separate from CTD for a promotion to a field 

office. We then multiplied that percentage by the average relocation cost provided by the 

FBI. To make the average costs of TDYs and permanent transfers comparable, we 

converted the average cost to permanent transfers to a cost per 12 months, using our 

estimate of the median time permanent agents remain in CTD from our life table analysis.

as well as the 2005 

Understaffing Working Group’s report, which stated that a further 

4 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

5 Office of Personnel Management, Human Capital Assessment and Accountability 

Framework (HCAAF), 5 C.F.R. Part 250.
Appendix I: Scope and Methodology

Page 41 GAO-12-533 FBI Counterterrorism Vacancies

evaluation of long-term strategies would be necessary. In addition, we 

assessed the extent to which the FBI’s plans to conduct an evaluation of 

HSI followed criteria for conducting evaluations we identified from the 

social science and evaluation literature6 as well as our own published 

guidance.7

We conducted this performance audit from May 2009 through April 2012 

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.

In addition, we interviewed officials from other federal law 

enforcement agencies, including the U.S. Marshals Service; Bureau of 

Alcohol, Tobacco, Firearms and Explosives; Drug Enforcement 

Administration; Secret Service; and Immigration and Customs 

Enforcement, to discuss the strategies they use to fill HQ vacancies. After 

conducting these interviews, we determined that these agencies’ efforts 

and missions where not directly comparable to those of the FBI.

Shortly after we began the review in May 2009, the Department of Justice 

and the FBI raised questions about GAO’s access authority to obtain 

certain information from the Intelligence Community (IC) about FBI 

counterterrorism positions, which resulted in the FBI not providing 

information necessary for completing our review.8

 

6 P. H. Rossi, M. W. Lipsey, and H. E. Freeman, Evaluation: A Systematic Approach, 7th 

ed. (Thousand Oaks, Calif.: Sage Publications, Inc., 2004), and B. R. Worthen, J. R. 

Sanders, and J. L. Fitzpatrick, Program Evaluation: Alternative Approaches and Practical 

Guidelines, 4th ed. (Allyn & Bacon, 2010). 

We obtained general 

information from the FBI on policies, protocols, and strategies related to 

human capital issues, such as staffing, retention, recruitment, and 

workforce planning. However, because we were temporarily denied 

access to the information necessary to complete our review, we 

suspended our work. On June 30, 2011, in response to a statutory 

7 GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January 

2012); Assessing the Reliability of Computer-Processed Data, GAO-09-680G 

(Washington, D.C.: July 2009); and Assessing Social Program Impact Evaluations: A 

Checklist Approach, PAD-79-2 (Washington, D.C.: October 1978).

8 CTD is considered part of the IC.
Appendix I: Scope and Methodology

Page 42 GAO-12-533 FBI Counterterrorism Vacancies

requirement,9

 

9 In general, section 348 of the Intelligence Authorization Act for Fiscal Year 2010 (Pub. L. 

No. 111-259, 124 Stat. 2654, 2700 (2010)) required the Director of National Intelligence, in 

consultation with the Comptroller General of the United States, to issue a written directive 

governing the access of the Comptroller General to information in the possession of an 

element of the IC.

the Director of National Intelligence finalized a directive 

pertaining to the Comptroller General’s access to IC information, which 

provides, among other things, that elements of the IC shall not 

categorically deny GAO access to information and shall not withhold 

information solely because that information relates to a program funded 

by the National Intelligence Program. As a result, we reinitiated our 

review in June 2011 and completed our work in April 2012.
Appendix II: Special Agent Headquarters 

Assignment

Page 43 GAO-12-533 FBI Counterterrorism Vacancies

Following up on a recommendation of the 2005 Understaffing Working 

Group study, the FBI implemented the Special Agent HQ Assignment 

(SAHA). SAHA was based on the working group’s long-term 

recommendation of establishing a “57th Field Office,” and was announced 

in early 2008 as an effort to realign agent staffing levels in HQ. SAHA 

allowed field agents at the General Schedule (GS) 12 and 13 levels to fill 

nonsupervisory agent positions in HQ. Participating agents would receive 

a relocation incentive of $25,000, and serve in HQ for a minimum of 2 

years and a maximum of 3 years. Upon completion of the assignment, 

participants were given a choice as to which region in the United States 

they would like to transfer. Unlike the 18-month TDY option in HSI, the 

time spent in HQ as part of the SAHA did not count as HQ supervisory 

experience for participating agents.

According to the Assistant Director of HRD, SAHA was based on the 

FBI’s assumption that the nonsupervisory tasks assigned to supervisory 

agents at the GS-14 and GS-15 levels could be fulfilled by 

nonsupervisory agents of a lower grade. In this manner, the initiative 

would have reduced the staffing pressure to fill supervisory agent 

positions in divisions such as CTD. SAHA reached its staffing goals, but 

the FBI determined that these positions needed to be filled with 

supervisory agents at the GS-14 level or above. According to officials, the 

supervisory tasks typically assigned to supervisory agents cannot be 

isolated from nonsupervisory tasks, and therefore the nonsupervisory 

agents were not as productive as the FBI had expected. Subsequently, 

the program was discontinued in early 2011. We estimate that the FBI 

spent a total of $1.1 million in relocation incentives as part of SAHA.

Appendix II: Special Agent Headquarters 

Assignment 
Appendix III: Vacancy Rates for CTD and Other 

Operational HQ Programs

Page 44 GAO-12-533 FBI Counterterrorism Vacancies

Figures 8 through 11 show vacancy rates for CTD and other operational 

HQ programs for fiscal years 2005 through 2011. 

Figure 8: Vacancy Rates for All Staff in CTD and Other Operational HQ Programs, 

Fiscal Years 2005 through 2011

Note: Other operational HQ programs include the Counterintelligence Division, Criminal Investigation 

Division, Critical Incident Response Group, Cyber Division, DI, International Operations Division, 

Office of Victim Assistance, Terrorist Screening Center, and Weapons of Mass Destruction 

Directorate.

Appendix III: Vacancy Rates for CTD and 

Other Operational HQ Programs
Appendix III: Vacancy Rates for CTD and Other 

Operational HQ Programs

Page 45 GAO-12-533 FBI Counterterrorism Vacancies

Figure 9: Vacancy Rates for Agents in CTD and Other Operational HQ Programs, 

Fiscal Years 2005 through 2011

Note: Other operational HQ programs include the Counterintelligence Division, Criminal Investigation 

Division, Critical Incident Response Group, Cyber Division, DI, International Operations Division, 

Office of Victim Assistance, Terrorist Screening Center, and Weapons of Mass Destruction 

Directorate.
Appendix III: Vacancy Rates for CTD and Other 

Operational HQ Programs

Page 46 GAO-12-533 FBI Counterterrorism Vacancies

Figure 10: Vacancy Rates for Intelligence Analysts in CTD and Other Operational 

HQ Programs, Fiscal Years 2005 through 2011

Note: Other operational HQ programs include the Counterintelligence Division, Criminal Investigation 

Division, Critical Incident Response Group, Cyber Division, DI, International Operations Division, 

Office of Victim Assistance, Terrorist Screening Center, and Weapons of Mass Destruction 

Directorate.

a

In fiscal year 2008, the number of onboard intelligence analysts in other operational HQ programs 

exceeded the number of funded positions for intelligence analysts by 17.

b

In 2010, the number of onboard intelligence analysts in CTD exceeded the number of funded 

positions for intelligence analysts by 29.
Appendix III: Vacancy Rates for CTD and Other 

Operational HQ Programs

Page 47 GAO-12-533 FBI Counterterrorism Vacancies

Figure 11: Vacancy Rates for Professional Support Staff in CTD and Other 

Operational HQ Programs, Fiscal Years 2005 through 2011

Note: Other operational HQ programs include the Counterintelligence Division, Criminal Investigation 

Division, Critical Incident Response Group, Cyber Division, DI, International Operations Division, 

Office of Victim Assistance, Terrorist Screening Center, and Weapons of Mass Destruction 

Directorate.
Appendix IV: Separations from CTD by Type of 

Separation

Page 48 GAO-12-533 FBI Counterterrorism Vacancies

Figures 12 through 14 provide information on staff separations for CTD 

from fiscal years 2005 through 2011.

Figure 12: Separation Rates for Agents in CTD, by Type of Separation, for Fiscal 

Years 2005 through 2011

Notes: Transfer includes reassignments, realignments, relocations, conversions, and grade changes. 

Termination includes removals and terminations. Resignation includes all resignations. Other includes 

death, retirement, and other less frequent categories.

a

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years.

Appendix IV: Separations from CTD by Type 

of Separation
Appendix IV: Separations from CTD by Type of 

Separation

Page 49 GAO-12-533 FBI Counterterrorism Vacancies

Figure 13: Separation Rates for Intelligence Analysts in CTD, by Type of Separation, 

for Fiscal Years 2005 through 2011

Notes: Transfer includes reassignments, realignments, relocations, conversions, and grade changes. 

Termination includes removals and terminations. Resignation includes all resignations. Other includes 

death, retirement, and other less frequent categories.

a

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years.
Appendix IV: Separations from CTD by Type of 

Separation

Page 50 GAO-12-533 FBI Counterterrorism Vacancies

Figure 14: Separation Rates for Professional Support Staff in CTD, by Type of 

Separation, for Fiscal Years 2005 through 2011

Notes: Transfer includes reassignments, realignments, relocations, conversions, and grade changes. 

Termination includes removals and terminations. Resignation includes all resignations. Other includes 

death, retirement, and other less frequent categories.

a

Separation data for 2005 through 2007 do not include the Terrorist Screening Center, which was a 

part of CTD for these years.
Appendix V: Comments from the Federal

Bureau of Investigation

Page 51 GAO-12-533 FBI Counterterrorism Vacancies

Appendix V: Comments from the Federal 

Bureau of Investigation
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 52 GAO-12-533 FBI Counterterrorism Vacancies

David C. Maurer, (202) 512-9627 or maurerd@gao.gov

In addition to the contact named above, Chris Currie, Assistant Director, 

and Christopher E. Ferencik, Analyst-in-Charge, and Robin Ghertner, 

Analyst, managed this review. Geoffrey Hamilton provided legal support. 

Rebecca Shea, Monique Williams, and Gregory Wilmoth assisted with 

design, methodology, and data analysis. Lara Miklozek provided 

assistance in report preparation.

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441059)
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