Department of Homeland Security
 

Personnel Security and Internal Control at TSA’s 


Legacy Transportation Threat Assessment and 


Credentialing Office
 

OIG-13-05 October 2012
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

0 _ J ~ J r,4 

l ~.fo? ~ 

October 26, 2012
 

MEMORANDUM FOR: The Honorable John S. Pistole 

Administrator 

Transportation Security Administration 

FROM: Charles K. Edwards 

Acting Inspector Genera

SUBJECT: Personnel Security and Internal Control at TSA's Legacy 

Transportation Threat Assessment and Credentialing Office 

Attached for your information is our final report, Personnel Security and Internal Control at 

TSA's Legacy Transportation Threat Assessment and Credentialing Office. We incorporated 

the formal comments from the Transportation Security Administration (TSA) in the final 

report. 

The report contains eight recommendations aimed at improving legacy Transportation 

Threat Assessment and Credential Offices. TSA concurred with seven recommendations 

and did not concur with one recommendation. As prescribed by the Department of 

Homeland Security Directive 077-1, Follow-Up and Resolutions for the Office of Inspector 

General Report Recommendations, within 90 days of the date of this memorandum, please 

provide our office with a written response that includes your (1) agreement or disagreement, 

(2) corrective action plan, and (3) target completion date for each recommendation. Also, 

please include responsible parties and any other supporting documentation necessary to 

inform us about the current status of the recommendation. Based on information provided 

in TSA's response, we consider Recommendations 1 and 2 closed and resolved. No further 

reporting concerning these is necessary. We consider Recommendations 3 through 7 open 

and resolved. Recommendation 8 is open and unresolved. 

Consistent with our responsibility under the Inspector General Act, we are providing copies 

of our report to appropriate congressional committees with oversight and appropriation 

responsibility for the Department of Homeland Security. We will post the report on our 

website for public dissemination. 

Please call me with any questions, or your staff may contact Deborah L. Outten-Mills, Acting 

Assistant Inspector General, at (202) 254-4015, or Marcia Moxey Hodges, Chief Inspector, at 

(202) 254-4202. 

Attachment 
 

Table of Contents 


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


 


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


 


Results of Review ................................................................................................................ 8 


 


Personnel Security Uses Appropriate Standards and Is Improving Timeliness ...... 9 


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


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


 


Secure Flight and the Adjudication Center Have Addressed Some Internal Control 


Issues, but Additional Changes Could Improve Adjudication Center Program 


Oversight............................................................................................................... 13 


Recommendation.................................................................................................. 16 


Management Comments and OIG Analysis .......................................................... 16 


 


Secure Flight Staffing and Supervisory Structure Is Inefficient ............................ 17 


Recommendation.................................................................................................. 19 


Management Comments and OIG Analysis .......................................................... 19 


 


Legacy TTAC Needs To Develop a Shared TSA Culture ......................................... 20 


Recommendation.................................................................................................. 23 


Management Comments and OIG Analysis .......................................................... 23 


 


Poor Managerial Practices at Legacy TTAC Must Be Addressed .......................... 23 


Recommendations ................................................................................................ 31 


Management Comments and OIG Analysis .......................................................... 31 


 


The Appearance of Fairness and Accountability Is Necessary for TSA’s 


Restructuring Initiative ......................................................................................... 32 


Recommendation.................................................................................................. 34 


Management Comments and OIG Analysis .......................................................... 34 


 


Appendixes 


Appendix A: Objectives, Scope, and Methodology ............................................ 37 


Appendix B: Recommendations ......................................................................... 39 


Appendix C: Management Comments to the Draft Report ............................... 40 


 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov OIG-13-05 
 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D: GAO Standards for Internal Controls............................................. 45 

Appendix E: Major Contributors to This Report ................................................ 46 

Appendix F: Report Distribution ........................................................................ 47 

Abbreviations 

BMO Business Management Office 

CSA Customer Support Agent 

DHS Department of Homeland Security 

EEO Equal Employment Opportunity 

FY fiscal year 

GAO Government Accountability Office 

IRTPA Intelligence Reform and Terrorism Prevention Act

ODNI Office of the Director of National Intelligence 

OIG Office of Inspector General 

OLE/FAMS Office of Law Enforcement/Federal Air Marshal Service 

OPM Office of Personnel Management 

PSD Personnel Security Division 

SCI Sensitive Compartmented Information 

SFA Secure Flight Analyst 

TIM Technology Infrastructure Modernization 

TSA Transportation Security Administration 

TSA OCRL TSA Office of Civil Rights and Liberties 

TSA OHC TSA Office of Human Capital 

TSA PSD TSA Personnel Security Division 

TTAC Transportation Threat Assessment and Credentialing 

www.oig.dhs.gov OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

The Department of Homeland Security’s (DHS) Transportation Security Administration 

(TSA) Transportation Threat Assessment and Credentialing Office was established as the 

lead for conducting security threat assessments and credentialing initiatives for 

domestic passengers on public and commercial modes of transportation, transportation 

industry workers, and individuals seeking access to critical infrastructure. Two 

programs, the Secure Flight Operations Center and the Security Threat Assessment 

Operations Adjudication Center, were established to conduct case-specific adjudications 

of potential threats to transportation security. In 2010, TSA initiated an administrationwide restructuring that includes reviewing all personnel position descriptions and 

realigning Transportation Threat Assessment and Credentialing Office functions under 

other TSA offices. 

We reviewed TSA’s oversight of personnel in the legacy Transportation Threat 

Assessment and Credentialing Office. Specifically, we reviewed whether position 

descriptions and background investigations are appropriate for employees’ authority 

and responsibility levels. We also reviewed whether there are adequate internal 

controls to provide oversight of personnel workplace activities. 

We determined that TSA employee background investigations met Federal adjudicative 

standards, but were not timely. The Secure Flight Operations Center and the Security 

Threat Assessment Operations Adjudication Center identified potential insider threat 

risks; however, limited resources weaken internal control at the Security Threat 

Assessment Adjudication Center, and the shift and supervisory structure at the Secure 

Flight Operation Center uses resources inefficiently. 

Within the legacy Transportation Threat Assessment and Credentialing Office, there has 

been a pattern of poor management practices and inappropriate use of informal 

administrative processes to assess and address misconduct. We are making eight 

recommendations to improve background investigations, internal controls, staffing 

models, data system development coordination, and use of TSA or DHS formal 

complaint processes, and to establish an independent panel for legacy Transportation 

Threat Assessment and Credentialing employees to request review of reassignments. 

www.oig.dhs.gov 1 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

TSA’s Transportation Threat Assessment and Credentialing (TTAC) Office was 

established as the lead for conducting security threat assessments and credentialing 

initiatives for domestic passengers on public and commercial modes of transportation, 

transportation industry workers, and individuals seeking access to critical infrastructure. 

Congressman Bennie G. Thompson, Ranking Member of the House Committee on 

Homeland Security, requested that we review the background investigations and 

suitability determinations conducted for TTAC personnel. Specifically, Congressman 

Thompson requested a review of the quality, fairness, and impartiality of the clearance 

and suitability system at TTAC, and how TTAC evaluates judgment, reliability, and 

trustworthiness. 

Our objectives were to determine whether TTAC employees have (1) position 

descriptions that reflect authority and responsibility levels accurately; (2) a personnel 

security screening process that complies with Federal laws, regulations, policy, and 

guidance; and (3) adequate internal controls on workplace activities. While each 

objective is distinct, all assess whether personnel with critical roles in transportation 

security have sufficient oversight. In addition, in 2010 TSA began a restructuring 

initiative that included an administration-wide review of personnel position descriptions 

and a reorganization of TSA, which realigned TTAC functions among three different TSA 

operational organizations. We reviewed the potential effect of these changes on 

oversight of legacy TTAC personnel. To provide context for this review, we will describe 

standards for personnel oversight, summarize the structure and functions of legacy 

TTAC, and outline the elements of TSA’s restructuring that affect legacy TTAC. 

Personnel Oversight Involves Multiple Federal, DHS, and TSA Offices 

Although TSA was established through the Aviation and Transportation Security Act of 

2001, with excepted service authority, standards for human capital, personnel security, 

and workplace conduct are governed by a number of Federal laws, regulations, and DHS 

policies for competitive service positions.1 As figure 1 illustrates, oversight of TSA 

personnel involves multiple Federal, DHS, and TSA offices. 

1

 P.L. 107-71. Competitive service positions are subject to the civil service laws passed by Congress and 

codified under Title 5 of the United States Code. Excepted service positions are not subject to the 

appointment, pay, and classification rules of the competitive service. 

http://www.dhs.gov/xabout/careers/gc_1303762131481.shtm. Excepted service authorities, which apply 

to TSA’s personnel management system, are cited under 49 U.S.C. § 114(n), and 49 U.S.C. § 40122. 

www.oig.dhs.gov 2 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1: Personnel Oversight
 

FEDERAL

Office of Personnel Management

• Human capital management 

• Personnel security programs (background investigations, national security clearances)2 

Office of the Director of National Intelligence

• National security clearances 

• Security clearance reciprocity between Federal departments and agencies3 

DEPARTMENT OF HOMELAND SECURITY

Office of the Chief Human Capital Officer

• Human capital guidance, training 

Office of the Chief Security Officer—Personnel Security Division

• Personnel security monitoring, guidance, and training 

Office for Civil Rights and Civil Liberties

• Violations of civil rights and Equal Employment Opportunity standards 

Office of Inspector General

• Allegations of misconduct, violations of civil rights and liberties 

• Program review 

TRANSPORTATION SECURITY ADMINISTRATION

Office of Human Capital

• Identification of risks and sensitivities for position descriptions 

• Documentation, management of formal disciplinary actions (Office of Human Capital 

Employee Relations) 

Personnel Security Division

• Personnel security management 

• National security clearances 

Office of Inspection

• Allegations of misconduct 

• Program review 

Office of Professional Responsibility

• Allegations of misconduct by senior-level employees, law enforcement officers 

• Standardization and fairness of disciplinary actions 

Office of Civil Rights and Liberties

• Allegations of violations of civil rights and Equal Employment Opportunity standards 

Office of Civil Rights and Liberties Ombudsman

• Mediation for TSA personnel and programs 

Source: OIG analysis.
 

2

 Consistent with Federal laws and regulations, and DHS and TSA policy. 
 3

 Reciprocity occurs when a department or agency accepts an active clearance granted to an individual by 


a previous department or agency. 


www.oig.dhs.gov 3 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Federal Government Positions Require Risk and Sensitivity Designations 

All Federal Government positions require risk and sensitivity designations. 

According to DHS policy, “[t]he risk level is based on an overall assessment of the 

damage that an untrustworthy individual could cause to the efficiency or the 

integrity of DHS operations.”4

 Risk levels for DHS employee positions are 

determined by the program official with hiring authority and the component’s 

human capital and personnel security offices.5 Sensitivity designations determine 

the level of public trust or access to national security information a position 

requires. DHS guidance requires a component’s sensitivity designations to be 

made by “the supervising official with sufficient knowledge of duty assignments,” 

subject to final approval by the component’s Chief Security Officer.6 

The Office of Personnel Management (OPM) provides guidance, training, and a 

Job Analysis Tool to assist department and agency human capital officials analyze 

each Federal position for risks and sensitivities; required knowledge, skills, and 

abilities; and the appropriate pay grade or pay band.7 TSA policy requires that 

each Job Analysis Tool identify risk and sensitivity designations and the 

competencies required for each employee position.8 

TSA Personnel Security Process Is Guided by Federal Law, DHS, and TSA Policy 

The position description, which results from analysis of job risks and sensitivities, 

determines how extensive a background investigation is required, what 

information must be obtained, and what criteria are used to adjudicate eligibility 

for employment. Although OPM authority for excepted service positions is more 

limited than for competitive service positions, Federal laws, DHS policies, and 

TSA policies require adherence to many OPM personnel security standards. For 

example, standards for national security clearances apply to excepted service 

employees and contractors, as well as competitive service employees. OPM 

shares oversight authority for national security clearances, including the 

application of security clearance reciprocity between Federal departments and 

agencies, with the Office of the Director for National Intelligence (ODNI). 

4

 The Department of Homeland Security Personnel Suitability and Security Program, DHS Instruction 


Handbook 121-01-007, June 18, 2009, p. 14. 
 5

 Ibid.
 

6

 Ibid., p. 20.
 

7 http://www.opm.gov/hiringtoolkit/docs/jobanalysis.pdf, 


http://www.opm.gov/investigate/resources/position/Introduction.aspx. 
 8

 “Policy on Determining Position Sensitivity Designations For All TSA Positions,” TSA Human Capital 


Management Policy Number 731-1, August 11, 2008, p. 4.
 

www.oig.dhs.gov 4 OIG-13-05 
 

 

The Intelligence Reform and Terrorism Prevention Act (IRTPA) of 2004 and 

subsequent Executive Orders established the following Federal personnel 

security standards for timeliness, reciprocity, and case tracking: 

•	 Timeliness: IRTPA requires 90 percent of national security background 

investigations to be completed within 40 days, and adjudication of these 

background investigations to be conducted within 20 days.9 

 Most TSA 

background investigations are conducted by OPM or its contractors, and 

adjudications are conducted by TSA’s Personnel Security Division (PSD). 

•	 Reciprocity: IRTPA and Executive Order 13381 encourage Federal 

departments and agencies to apply reciprocity to background investigations 

conducted by other Federal departments and agencies.10 Executive Order 

13467 encourages agencies to accept favorable adjudications of 

investigations as well.11 There are exceptions to reciprocity when the 

receiving department or agency’s mission requires more stringent criteria— 

for example, a polygraph requirement or less tolerance for bad debt—than 

the sending department or agency.12 

•	 Case Tracking: IRTPA requires Federal departments and agencies to 

establish an integrated database that tracks background investigations and 

adjudications.13 To meet this requirement, OPM upgraded its database to 

enable applicants to complete background investigation forms electronically, 

provide the results to departments and agencies electronically, and track the 

outcome of adjudicative decisions. ODNI maintains a database, Scattered 

Castles, which enables departments and agencies to document and verify an 

individual’s clearance level and whether the individual is authorized access to 

Sensitive Compartmented Information (SCI).14 Most DHS components meet 

case tracking requirements through the Integrated Security Management 

System, which transfers information to and from the OPM and ODNI 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

9

 P.L. No. 108-458 § 3001 (2004).
 10 P.L. No. 108-458 § 3001 (2004); Executive Order 13381, “Strengthening Processes Relating to 


Determining Eligibility for Access to Classified National Security Information,” June 27, 2005.
 11 Executive Order 13467, “Reforming Processes Related to Suitability for Government Employment, 


Fitness for Contractor Employees, and Eligibility for Access to Classified National Security Information,” 


June 30, 2008; Intelligence Community Policy Guidance [ICD] Number 704.4, “Reciprocity of Personnel
 

Security Clearance and Access Determinations.” 


12 Memorandum from DHS Chief Security Officer to DHS component Chief Security Officers, “Department 


of Homeland Security Reciprocity Guidelines,” June 22, 2010. 
 13 P.L. No. 108-458 § 3001 (2004).
 14 Intelligence Community Policy Guidance Number 704.5, Intelligence Community Personnel Security 

Database, Scattered Castles, October 2, 2008. 


www.oig.dhs.gov 5 	 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

databases. TSA plans to begin using the Integrated Security Management 

System in calendar year 2012. 

Internal Controls Are as Essential as Background Investigations 

Background investigations are essential to security, but personnel are only 

reinvestigated after 5 years for Top Secret access, 10 years for Secret access, or 

when job requirements change to require increased access. Internal control 

measures are therefore critical to effective oversight of personnel. The 

Government Accountability Office’s (GAO) Standards for Internal Control in the 

Federal Government provides five standards for effective internal control: 

(1) Control Environment; (2) Risk Assessment; (3) Control Activities; 

(4) Information and Communications; and (5) Monitoring.15 For example, 

elements of an effective Control Environment include managerial integrity and 

ethical values, commitment to competence, and sound human capital policies 

and practices.16 Examples of effective Control Activities include performance 

reviews, controls over information processing, and segregation of duties.17 

Additional information on internal control is provided in appendix D. As noted in 

figure 1, several TSA offices, including the Office of Inspection, Office of Civil 

Rights and Liberties (OCRL), and Office of Human Capital (OHC) Employee 

Relations, monitor internal control for TSA programs and personnel. 

Many Legacy TTAC Positions Are Designated as High Risk and Top Secret 

Sensitivity

Two programs within TTAC were established to conduct case-specific evaluation 

of threats to transportation security, and are therefore critical to national 

security and the integrity of DHS operations. The Secure Flight Operations 

Center (Secure Flight) uses the Federal Government’s consolidated terrorist 

watch list to identify potential threats from travelers for all flights into, out of, 

and over the United States.18 Secure Flight Analysts (SFAs) require a Top Secret 

national security clearance and access to SCI information to assess potential 

matches to the Government’s consolidated terrorist watch list. The Security 

Threat Assessment Operations Adjudication Center (Adjudication Center) 

screens transportation workers against information in national security, 

immigration, and criminal databases. Most staff at the Adjudication Center 

15 GAO/AIMD-00-21.3.1 (November 1999).
 

16 Ibid., pp. 8–9.
 

17 Ibid., pp. 12–18. 


18 Secure Flight Program; Final Rule, 73 Fed. Reg. 64018-64066 (Oct. 28, 2008). 


www.oig.dhs.gov 6 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

require a Secret clearance. Security clearance requirements for the remaining 

staff, listed in figure 2, range from Top Secret with SCI access for technology staff 

to Secret for administrative staff. 

Figure 2: Functions and Status of Legacy TTAC 

Secure Flight (Annapolis Junction, MD, and Colorado Springs, CO) 

• Provides passenger consolidated terrorist watch list matching for all flights into, out of, and 

over the United States. 

Adjudication Center (Herndon, VA) 

• Screens transportation workers against information in national security, immigration, and 

criminal databases. 

Vetting Operations (Colorado Springs, CO) 

• Vets transportation workers against terrorism and intelligence information. 

Technology (Annapolis Junction, MD) 

• Developed, operates, and maintains the Secure Flight data system, and data systems used 

for Adjudication Center vetting and credentialing. 

TTAC Technology Infrastructure Modernization (Annapolis Junction, MD) 

• Developing a replacement data system for the Adjudication Center. 

Security Threat Assessment Programs (Arlington, VA) 

• Responsible for the Security Threat Assessment process, to include budget, 

acquisitions/contracts, enrollment, operations, stakeholder and customer 

coordination/communications, DHS and Office of Management and Budget acquisition 

program reporting, external agency coordination, rulemaking and regulatory compliance, 

and congressional communication. Programs include— 

• Aviation Credentialing Alien Flight Student Program, Aviation Workers Program, Crew 

Vetting Program, Federal Aviation Administration Certificate Holders, and other 

aviation credentialing programs 

• Maritime – Transportation Worker Identification Credential program 

• Surface Credentialing – Hazardous Materials Endorsement Threat Assessment 

Program, Universal Rule, and Universal Enrollment Services 

• Business requirements for future Security Threat Assessment needs for individuals 

seeking to work in freight rail, mass transit and passenger rail, as well as other 

programs requesting vetting as a service by TSA, such as chemical facilities, and 

ammonium nitrate transport 

Business Management Office (Arlington, VA) 

• Provides administrative, financial, acquisition, human capital, and information technology 

services. 

Source: OIG analysis. 

Since 2010, TSA has initiated three restructuring projects that affect TTAC 

personnel: a balanced workforce initiative; a review of all TSA position 

descriptions; and a reorganization of TSA offices. 

•	 Balanced Workforce Initiative: TSA participated in the DHS balanced 

workforce initiative to determine the proper balance of Federal and 

www.oig.dhs.gov 7 	 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

contractor staff to reduce risks and costs inherent in contracts.19 As a result, 

Secure Flight has converted most of its staff to Federal employee positions. 

While the Adjudication Center conducted an assessment in preparation for 

conversion, the conversion process has not started as of August 2012. 

•	 Position Description Review (Desk Audit): TSA OHC, in consultation with 

program officials, initiated an administration-wide desk audit to determine 

whether job titles and pay bands reflect required competencies and authority 

and responsibility levels accurately.20 Positions may be downgraded when 

authorities and responsibilities do not match compensation levels, and after 

2 years pay will be reduced. Some positions may be eliminated, for example, 

for individuals in supervisory positions who do not supervise sufficient staff 

levels. When positions are eliminated, the incumbent is placed in a resource 

pool and can be assigned to another office that requires additional staff. TSA, 

however, does not plan to reduce its overall workforce during this process. 

•	 Reorganization: TSA initiated an administration-wide reorganization that 

dissolved TTAC and reassigned its functions to three TSA Assistant 

Administrators. The Adjudication Center was assigned to the Office of Law 

Enforcement/Federal Air Marshal Service (OLE/FAMS), and Programs 

excluding Secure Flight to the Office of Security Policy and Industry 

Engagement. The remaining legacy TTAC functions, including Secure Flight, 

TTAC Technology, Technology Infrastructure Modernization (TIM), and the 

TTAC Business Management Office (BMO), were assigned to TSA’s Office of 

Intelligence and Analysis. All legacy TTAC functions will remain in their 

current geographical locations. 

Results of Review

The background investigations of legacy TTAC employees met Federal standards for the 

quality of adjudicative decisions and reciprocity. Until 2012, however, TSA PSD did not 

meet Federal timeliness standards, and clearance delays resulted in inefficient 

management of Secure Flight personnel resources. Both Secure Flight and the 

Adjudication Center have identified and taken measures to address potential risks to 

their adjudication programs from human error or insider threats, but limited 

technological resources and an insufficient number of Federal employees weaken 

internal controls at the Adjudication Center. Secure Flight’s shift schedule and 

supervisory structure use personnel resources inefficiently. Employees at legacy TTAC 

19 http://www.dhs.gov/ynews/testimony/20120329-mgmt-contractors-hsgac.shtm. 20 TSA Handbook to Management Directive Number 1100.51-1, July 6, 2011, p. 16. 

www.oig.dhs.gov 8 	 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

are committed to TSA’s transportation security mission and seek to fulfill TSA’s mandate 

regardless of these challenges. However, perceptions of favoritism in hiring and 

management, and unresolved tensions between legacy TTAC functions, hinder achieving 

a shared mission. 

Legacy TTAC employees have made allegations of improper conduct through formal and 

informal processes, including allegations of poor management practices and violations 

of Equal Employment Opportunity (EEO) standards. While all employees said they 

would report national security vulnerabilities, some feared retaliation for raising other 

concerns. Senior legacy TTAC leaders sought to address allegations of misconduct 

through training and TTAC BMO’s informal internal administrative processes, but efforts 

were not successful. For example, use of informal administrative processes did not 

address or expose the extent of workplace complaints and led to internal investigations 

being managed inappropriately. Employee complaints raised through TSA’s formal 

grievance processes were managed and documented appropriately, but not all 

employees had sufficient information to access formal redress options. Unaddressed 

workplace complaints of favoritism, discrimination, and retaliation hinder TSA’s efforts 

to streamline its operational structure and align compensation with appropriate 

authorities and responsibilities. 

Personnel Security Uses Appropriate Standards and Is Improving Timeliness

Employees received the appropriate level of background investigations, even 

though more than half of the Job Analysis Tools for legacy TTAC positions were 

missing the required risk and sensitivity designations. TSA PSD met Federal, DHS, 

and TSA standards for adjudicative decisions and for the application of reciprocity. 

However, until 2012, adjudications were not timely, and delays had negative 

consequences for TSA’s Secure Flight program. 

Position Descriptions Missing Job Analysis Tool Risk and Sensitivity Designations

TSA’s Policy on Determining Position Sensitivity for All TSA Positions requires that 

each employee position description Job Analysis Tool include a risk and 

sensitivity designation, which identifies the level of background investigation 

necessary.21 Between 2007 and 2009, TSA OHC reviewed all position 

descriptions using OPM guidance. However, during our review of position 

descriptions provided by legacy TTAC BMO, 22 of the 35 Job Analysis Tools were 

missing risk and sensitivity designations, and were performed before 2008. 

21 Policy on Determining Position Sensitivity Designations for All TSA Positions, TSA Human Capital 

Management Policy Number 731-1, August 11, 2008, p. 4. 

www.oig.dhs.gov 9 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Although the Job Analysis Tools did not meet TSA standards, our review of 

personnel security files indicates that employees received background 

investigations appropriate to duties and required level of access to classified 

information. Because TSA is conducting desk audits that will result in new 

position descriptions, we make no recommendations on this deficiency, as any 

recommendation would be overtaken by these efforts. 

Personnel Security Meets Federal, DHS, and TSA Standards for Adjudicative 

Decisions and Application of Reciprocity

TSA’s personnel security program has adequate internal controls to ensure that 

adjudicators meet required standards for adjudicative decisions and reciprocity. 

TSA PSD adjudicators attend personnel security training provided for Federal 

adjudicators. In addition, adjudicators receive guidance developed by OPM, 

ODNI, Federal training programs, and DHS, as well as Aviation and 

Transportation Security Act-related guidance specific to TSA. TSA PSD 

participates in a DHS-led Personnel Security Officers’ Working Group, which 

meets quarterly to discuss changes in laws, regulations, and guidance, and can 

address any concerns about the quality and timeliness of decisions. The 

adjudicators we interviewed understood Federal, DHS, and TSA guidance on 

adjudicative standards and reciprocity. In addition, TSA PSD provides adequate 

oversight of the adjudicative process, including comprehensive adjudicative 

checklists and templates, 100 percent review of negative suitability 

determinations, and 40 percent review of positive determinations. 

We reviewed personnel security files of all senior TTAC managers and a sampling 

of other TTAC employees, and determined that TSA PSD adjudicative decisions 

met Federal, DHS, and TSA standards. The files were documented appropriately 

and included current and previous background investigations, as well as 

reinvestigations conducted by OPM and other authorized Federal departments 

and agencies. When necessary, adjudicators sought additional information and 

weighed potentially derogatory issues that would affect suitability for 

employment, such as the recency and severity of financial or misconduct issues 

and evidence of rehabilitation. For Top Secret and Secret security clearances, 

relevant issues such as the potential for foreign influence were also considered. 

TSA PSD also met guidelines for reciprocity. When reciprocity was applied, files 

included necessary documentation, including required Federal forms, Federal 

Bureau of Investigation fingerprint results, a credit check, and confirmation of a 

current security clearance from another Federal department or agency. In some 

instances, such as when an applicant had debt issues, the adjudicator accepted a 

www.oig.dhs.gov 10 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

previous background investigation appropriately, but obtained additional 

information to conduct a new adjudication. 

Past Timeliness Issues Have Had a Negative Effect on Secure Flight

TSA PSD did not meet the timeliness standard for conducting 90 percent of 

adjudications within 20 days after OPM completed its background investigations 

until the first quarter of fiscal year (FY) 2012, when personnel and organizational 

changes improved productivity. Before FY 2012, OPM delays in conducting 

background investigations and TSA PSD delays in adjudicating the results created 

a backlog, and cases that should have been completed in 2 months were taking 5 

months or longer to complete. As a result, because SFA positions require a Top 

Secret clearance and SCI access, Secure Flight managers said that SFAs without a 

clearance could fulfill only a portion of their responsibilities, which placed an 

additional burden on cleared personnel to perform necessary operational duties. 

Secure Flight managers said that TSA PSD did not appear to be actively managing 

or tracking its background investigations and that continuous followup was 

necessary to obtain clearances for many employees. In addition, managers were 

unsure why some employees with Top Secret clearances and SCI access in 

previous positions were eligible for reciprocity while others were not. Secure 

Flight managers did note that timeliness had improved recently. 

TSA PSD officials agreed that timeliness and case tracking had been problematic, 

but said they had taken aggressive actions to address the causes. Specifically, in 

the past TSA hired large groups of employees or contractors quickly, resulting in 

backlogs for existing programs, but TSA PSD has increased resources to address 

current and anticipated volume, while ensuring that a new backlog situation is 

not created in the event of similar hiring spikes in the future. TSA PSD shifted all 

personnel security responsibilities from contractors to Federal employees and 

expects to be fully staffed in late FY 2012. Adjudicator productivity goals are 

more stringent, so each adjudicator is completing more cases. In addition, TSA 

PSD has integrated the security clearance and SCI access processes better. 

Conversion to DHS’ Integrated Security Management database, scheduled to 

occur in calendar year 2012, will also improve case management and reporting. 

TSA PSD has taken measures to improve timeliness, and in the second half of 

FY 2012 has established a consistent process to meet Federal timeliness goals for 

adjudicating background investigations. In the third quarter of FY 2012, 

adjudications averaged 10 days, and in the fourth quarter adjudications are 

averaging 11 days. However, TSA PSD cannot control other sources of delay, 

www.oig.dhs.gov 11 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

such as backlogged OPM background investigations. TSA PSD could provide 

programs with more information about which employees are eligible for 

reciprocity. Improved communication would enable program managers to 

coordinate the hiring process for employees who require Top Secret clearances 

and SCI access. 

Recommendations

We recommend that the TSA Chief Security Officer: 

Recommendation #1:

Establish a point of contact, email address, or contact number for TSA managers 

to follow up on the status of employees who require Top Secret and Sensitive 

Compartmented Information investigations or reinvestigations. 

Recommendation #2:

Provide TSA Assistant Administrators who have employees with pending Top 

Secret and Sensitive Compartmented Information investigations and 

reinvestigations with monthly statistics on the number of cases pending, number 

of days cases have been in the system, and current backlog when applicable. 

Management Comments and OIG Analysis 

A summary of TSA’s written response to the report recommendations and our 

analysis of the response follows each recommendation. A copy of TSA’s 

response, in its entirety, is included as appendix C. 

In addition, we received technical comments from TSA and incorporated these 

comments into the report where appropriate. TSA concurred with seven 

recommendations and did not concur with one recommendation in the report. 

We appreciate the comments and contributions made by TSA. 

Management Response: TSA officials concurred with Recommendation 1. In its 

response, TSA said the Personnel Security Section has established a home page 

on the TSA intranet as the primary source of information for stakeholders 

requiring information or assistance with security clearance requests or other 

Personnel Security products and services. In addition to points of contact, email 

addresses, and phone numbers, the home page provides information regarding 

Personnel Security forms and documents, reference materials, and Frequently 

www.oig.dhs.gov 12 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Asked Questions. TSA provided copies of the intranet pages. TSA considers this 

recommendation closed and implemented. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 1, which is resolved and closed. No further reporting 

concerning Recommendation 1 is necessary. 

Management Response: TSA officials concurred with Recommendation 2. In its 

response, TSA said that in December 2012, Personnel Security will begin using 

the DHS electronic Integrated Security Management System to record and 

manage all background investigation and security clearance information. The 

data system’s functionalities will allow for automatic, timely notifications and 

updates to stakeholders, as well as to offices within TSA that do not currently 

have access to Personnel Security information. TSA said that pending final 

transition to the Integrated Security Management System, interim measures 

have been implemented to provide case statuses through “tickler” reports. TSA 

provided examples of recent reports it provides to TSA leadership. TSA considers 

this recommendation closed and implemented. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 2, which is resolved and closed. No further reporting 

concerning Recommendation 2 is necessary. 

Secure Flight and the Adjudication Center Have Addressed Some Internal 

Control Issues, but Additional Changes Could Improve Adjudication Center 

Program Oversight

Both Secure Flight and Adjudication Center staff identified and addressed 

potential personnel risks to their adjudication functions. For example, Secure 

Flight developed an effective data system, assigns cases randomly, segregates 

duties, and provides managerial oversight to mitigate potential risks. The 

Adjudication Center has mitigated some risks through active oversight of 

contractors and random case assignments. However, data system deficiencies 

and an insufficient number of Federal employees to segregate duties potentially 

increase internal control vulnerabilities at the Adjudication Center. 

Secure Flight Has Mitigated System and Procedural Security Risks

According to GAO’s Standards for Internal Control in the Federal Government, 

activities such as control over information processing, segregation of duties, 

accurate and timely recording of transactions and events, and access restrictions 

www.oig.dhs.gov 13 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

to and accountability for resources and records are essential to internal control.22 

Secure Flight’s procedures and its data system help provide these control 

activities. Specifically, the volume of records, lead time for vetting, random 

records assignment, data system audit trails, supervisory oversight, reliance on 

Federal employees, and segregation of duties all limit potential for insider threat 

vulnerabilities. 

To provide continuity of operations, Secure Flight has two Operation Centers, 

one in Colorado Springs and one in Annapolis Junction. The Operation Centers 

are staffed primarily with Federal employees who serve as SFAs, Supervisory 

SFAs, Customer Support Agents (CSAs), Supervisory CSAs, Watch Managers, and 

Senior Watch Managers. Records are randomly assigned between the two 

Operation Centers. The Secure Flight System automatically vets more than 14 

million airline passengers each week, from which SFAs manually compare data of 

more than 54,000 passengers to available Federal Government watch list 

records. This volume limits the chance that staff can predict which records they 

will review. The fact that aircraft operators send most passenger data to Secure 

Flight more than 72 hours before flights depart also makes it difficult for SFAs to 

predict which shift will vet a given passenger record. 

When SFAs compare passenger data to watch list records, they determine 

whether to clear a passenger or “inhibit” a passenger’s ability to print a boarding 

pass. Inhibiting a passenger requires the traveler to present identification to an 

aircraft operator employee before being granted a boarding pass. SFAs obtain 

records to analyze and mark as cleared or inhibited from an automated queue. 

The Secure Flight data system was designed with audit trails, so the system logs 

which SFA made each match determination and keeps historical data on 

previous matches. 

Additionally, Supervisory SFAs are assigned to review SFA match decisions and 

work with Watch Managers and Senior Watch Managers when a particular SFA is 

improperly clearing or improperly inhibiting records. Because most Secure Flight 

contract adjudicators were converted to Federal employees through the 

balanced workforce initiative, Secure Flight oversees the quality and quantity of 

employee work products directly and can intervene with specific corrective 

action and training when necessary. 

Most adjudications are completed without requiring passenger or aircraft 

operator employee interactions. When interaction is necessary, Secure Flight 

22 GAO/AIMD-00-21.3.1, November 1999, p. 12. 

www.oig.dhs.gov 14 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

minimizes insider threats by segregating duties, and randomizing the structure of 

customer support calls and further record vetting. A passenger with an inhibited 

boarding pass cannot print the boarding pass at home or at an airport kiosk and 

must speak with an aircraft operator employee and present identification. The 

aircraft operator employee must call a general Secure Flight number for 

inhibited passengers, which is routed to the first available CSA in an automated 

queue of available agents located near one of the two Secure Flight Operation 

Centers. CSAs have scripted language to verify the caller’s authenticity and 

request additional information about the passenger. The CSA then calls the 

Operations Center, which routes callers to the next available SFA. The SFA 

speaks only with the CSA, never with the aircraft operator employee, and places 

the CSA on hold to determine when the additional information clears a 

passenger or positively identifies the passenger as a watch list match. The SFA 

communicates this information to the CSA, who uses scripted language to inform 

the aircraft operator of what action to take. 

Adjudication Center Requires Resources Comparable to Secure Flight

Adjudication Center officials, who conduct case management review for 

immigration and criminal checks for security threat assessment programs, have 

identified and attempted to address risks and security vulnerabilities properly in 

the work contractors perform. For example, contract staff cannot access 

adjudication case management systems until they have received a Secret 

clearance and are trained on the Adjudication Center’s standards and the 

adjudication case management systems. Federal employees limit contractor 

system access so that only authorized contractors can obtain information and 

make adjudicative decisions. Cases are assigned on a first-in-first-out basis so 

that contractors cannot choose which cases they work. The volume of cases— 

between 5,000 and 7,000 a week for each major credentialing program—also 

limits the likelihood that any given contractor will be assigned a particular case. 

Federal employees actively monitor contractor performance, including the 

quality of adjudicative decisions and the accuracy of workload reports 

contractors submit. 

However, with an insufficient number of Federal employees, the Adjudication 

Center does not have the same level of internal control as Secure Flight. The 

balanced workforce initiative has not started at the Adjudication Center, and 

fewer than 20 Federal employees manage, train, and oversee approximately 50 

contractors. Federal employees are also responsible for adjudicating more 

complex cases. Federal employees routinely work overtime to manage a 

backlog, which limits the time they have to assume responsibilities for other 

www.oig.dhs.gov 15 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

employees on leave. Several employees at the Adjudication Center said that 

they do not have a backup Federal employee who can cover their work when 

they are absent. 

In addition, Adjudication Center adjudication case management systems do not 

have the same functionality as the Secure Flight case management system. 

Without a sufficient number of Federal employees, the Adjudication Center has 

not been able to segregate duties related to data management to provide 

internal control. The existing case management systems have limited 

functionality for audit trails, alerts, and automated reports. Only one Federal 

official is able to generate the workload and timeliness reports that are provided 

to DHS and Congress. The manual process by which these reports must be 

generated is so complex and labor-intensive that no other employees have been 

trained to provide backup or review. In addition, the Adjudication Center does 

not have direct access to some DHS data systems, and only one employee is 

assigned to conduct criminal and watch list systems checks at a nearby TSA 

facility. The TTAC TIM program plans to replace the existing Adjudication Center 

case management systems, but we were unable to obtain documentation to 

determine whether the new case management systems would incorporate the 

necessary internal control. 

Recommendation 

We recommend that the Assistant Administrator for the Office of Law 

Enforcement/Federal Air Marshals: 

Recommendation #3:

Provide the Adjudication Center sufficient Federal employees to establish 

internal control over operations and reporting requirements. 

Management Comments and OIG Analysis 

Management Response: TSA officials concurred with Recommendation 3. In its 

response, TSA said that it is pursuing efforts to increase the number of Federal 

employees assigned to the Security Threat Assessment Office. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 3, which is resolved and open. This recommendation will 

remain open pending our receipt of documentation confirming that the 

www.oig.dhs.gov 16 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Adjudication Center has sufficient Federal employees to establish internal 

control over operations and reporting requirements. 

Secure Flight Staffing and Supervisory Structure Is Inefficient

Secure Flight’s rotating shift schedule is not aligned with its operational 

requirements, and its supervisory structure is unnecessarily complex. For 

example, equally sized teams work each shift, even though fewer employees are 

needed during off-peak air carrier travel periods. All Secure Flight staff work an 

overlapping shift 1 day each week, which is an inefficient use of human capital 

resources. In addition, the Secure Flight supervisory structure limits personal 

interaction between supervisors and employees. Supervision of CSAs, SFAs, and 

Watch Managers is divided between the Annapolis Junction and Colorado 

Springs locations, resulting in supervisors rating employees without firsthand 

knowledge of their work because a supervisor is in one location, but direct 

reports are in another. 

Secure Flight Rotating Shifts Are Not Aligned With Operational Requirements 

According to GAO guidance, “[i]nternal control should provide reasonable 

assurance that the objectives of the agency are being achieved in the ... 

[e]ffectiveness and efficiency of operations including the use of the entity’s 

resources.”23 In 2011, Secure Flight managers introduced a shift schedule in 

which fixed teams of SFAs and CSAs rotate together every 8 weeks to cover 6 

shifts. The rotating schedule is not aligned with Secure Flight’s operational 

requirements. For example, because Secure Flight receives most records from 

air carriers more than 72 hours before flights depart, the day shift could conduct 

most vetting within 24 hours of receipt. While Secure Flight watch list vetting 

requires some real-time interaction with air carrier employees, CSAs on night 

shifts said that they receive relatively few calls. Even though Secure Flight must 

be staffed at all times to manage international flights and domestic airports that 

are open overnight, maintaining the same number of employees on night and 

day shifts may indicate an unnecessary expenditure of night differential pay. 

Moreover, with teams on a 4-day schedule, teams overlap each Wednesday, as 

half the teams work from Sunday to Wednesday, and half from Wednesday to 

Saturday. With each team on a 10-hour shift, shifts overlap every day between 

6:00 and 6:30 a.m., 1:00 and 4:30 p.m., and 8:00 and 11:00 p.m. Figure 3 shows 

that on Wednesdays, both teams and shifts overlap. As a result, staff at 

23 Ibid., pp. 4–5. 

www.oig.dhs.gov 17 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Annapolis Junction said that there is often no place to sit on Wednesdays, and 

the workload is quickly depleted. Staff who had worked in other operations 

centers said that some law enforcement and intelligence departments and 

agencies use this scheduling model to provide staff training time, but SFAs do 

not require the same level of ongoing physical, operational, or substantive 

training as these entities. Further, Watch Managers reported having difficulty 

obtaining permission for staff to take advantage of available free or low-cost 

training. The overlap of both teams and shifts is, therefore, an inefficient use of 

human capital resources. 

Figure 3: Number of Personnel on Each Secure Flight Shift

Source: TSA Secure Flight Operations Center. 

0 

5 

10 

15 

20 

25 

30 

35 

40 

45 

Shift 1: 

11:00pm -

6:00am 

Shifts 1 & 2: 

6:00am -

6:30am (Shift 

Overlap) 

Shift 2: 

6:30am -

1:00pm 

Shifts 2 & 3: 

1:00pm -

4:30pm (Shift 

Overlap) 

Shift 3: 

4:30pm -

8:00pm 

Shifts 3 & 1: 

8:00pm -

11:00pm 

(Shift Overlap) 

13 

23 

10 

21 

11 

24 22 

44 

22 

42 

20 

42 

9 

21 

12 

21 

9 

18 

Number of Staff on Each Secure Flight Shift

Sun-Tues Teams Wed (Teams Overlap) Thurs - Sat Teams 

Direct Supervision Could Improve Secure Flight Management

According to GAO guidance, establishing a positive attitude toward internal 

control and conscientious management requires that management “identify 

appropriate knowledge and skills needed for various jobs and provide needed 

training, as well as candid and constructive counseling and performance 

appraisals.”24 However, the supervisory structure at Secure Flight limits personal 

interaction between supervisors and direct reports because supervisors are 

located at different Operation Centers. 

24 Ibid., p. 8. 

www.oig.dhs.gov 18 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

As of July 2012, Supervisory CSAs, SFAs, and Watch Managers supervise staff 

both locally and remotely. Supervisory Watch Managers fly between the Secure 

Flight locations to meet with direct reports, but lower level supervisors may not 

have this opportunity. Many of the employees and supervisors we interviewed 

said that supervisors cannot rate remotely stationed staff work performance 

accurately. Some supervisors said that they rely on local second-line supervisors 

when rating remote direct reports. In addition, Colorado Springs begins each 

shift 2 hours later than Annapolis Junction, so supervisors must make operational 

decisions for employees who are not direct reports. While it may be necessary 

for Senior Watch Commanders to supervise some staff at each location, local 

supervision for other employees would enable supervisors to assess and counsel 

direct reports more accurately and efficiently, and improve overall internal 

control. 

Recommendation 

We recommend that the Assistant Administrator for the TSA Office of 

Intelligence and Analysis: 

Recommendation #4:

Develop a restructuring plan to enhance operational effectiveness in the Secure 

Flight Operations Center staffing model. 

Management Comments and OIG Analysis 

Management Response: TSA officials concurred with Recommendation 4. In its 

response, TSA said that the Secure Flight Operations Center has made significant 

changes and implemented new programs and schedules to address many of the 

issues identified. TSA said that these modifications include schedule changes 

based on employee feedback, structural changes to improve communication and 

enhance career and role progression, internal and external training programs to 

support in-position refresher courses and knowledge development opportunities, 

and more structured use of employee overlap time. TSA provided examples of 

modifications it has made, which included a training program, career progression 

goals, and a review of the supervisory structure. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 4, which is resolved and open. This recommendation will 

remain open pending the receipt of documentation confirming that the Secure 

www.oig.dhs.gov 19 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Flight Operations Center has analyzed and addressed the concerns we identified 

in our report. Specifically, the documentation should include the following: 

•	 Data supporting the conclusion that call volume distribution is relatively 

consistent across 24-hour periods. 

•	 Data supporting the conclusion that maintaining an equal number of 

Secure Flight Analysts on each shift, and the night differential pay this 

entails, is operationally effective. 

•	 Analysis that led to the conclusion that the level of training proposed to 

justify overlapping work schedules is appropriate to Secure Flight’s 

operational requirements. TSA’s response appears to indicate that staff 

at the Secure Flight Operations Center would be receiving extensive 

training every second Wednesday. Analysis should include how this level 

of training compares with that provided to other TSA employees with 

similar positions, such as adjudicators at the Adjudication Center, and 

intelligence analysts in TSA’s Office of Intelligence and Analysis. 

•	 Organizational charts that demonstrate that the Secure Flight Operations 

Center has taken measures to reduce the level of cross-site supervision. 

Legacy TTAC Needs To Develop a Shared TSA Culture

Legacy TTAC employees are committed to TSA’s transportation security mission 

and seek to fulfill TSA’s mandate regardless of work environment challenges. 

However, many employees perceive that there is favoritism in hiring practices at 

legacy TTAC, and that hiring and personnel management decisions are not based 

consistently on competence, skill, or ability. Legacy TTAC offices have difficulty 

working cooperatively with each other, and unresolved tensions hinder achieving 

a shared mission. 

www.oig.dhs.gov 20 	 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

TTAC Hiring and Management Perceived as Influenced by Favoritism 

According to GAO guidance, “[m]anagement and employees should establish and 

maintain an environment throughout the organization that sets a positive and 

supportive attitude toward internal control and conscientious management.”25 

This includes, but is not limited to (1) integrity and ethical values maintained and 

demonstrated by management and staff; (2) management’s commitment to 

competence; and (3) appropriate practices for hiring, orienting, training, 

evaluating, counseling, promoting, compensating, and disciplining personnel.26 

Legacy TTAC employees said that they are committed to TSA’s transportation 

security mission and seek to fulfill TSA’s mandate, regardless of work 

environment challenges. However, more than 66 percent of the employees we 

interviewed at Annapolis Junction and TSA headquarters raised concerns about 

workplace favoritism, or mentioned their personal connections and relationships 

to TTAC coworkers from prior employment. 

Employees said that some senior managers hired staff primarily from the 

departments, agencies, or industries where they had worked before TSA. Many 

employees said that hiring and personnel management decisions were based 

more on personal connections and relationships than on competence, skill, or 

ability. Further, during the past 4 years some employees with extensive TSA or 

DHS experience were removed from their positions. Some were not given new 

job assignments or responsibilities, and had to initiate work from managers in 

other program areas. Assessing allegations of favoritism is difficult, but the Job 

Analysis Tools for TTAC demonstrated a pattern of positions written for specific 

individuals, as identified by a person’s name or initials on the position description. 

Some of these positions required overly specific qualifications, and some did not 

identify authorities and responsibilities to justify designated pay band levels. 

Developing a Shared TSA Culture Would Benefit Legacy TTAC’s Mission

According to GAO guidance, “[a] good internal control environment requires that 

the agency’s organizational structure clearly define key areas of authority and 

responsibility and establish appropriate lines of reporting.”27 Unresolved 

tensions between legacy TTAC offices and unclear lines of authority and 

responsibility have hindered developing a shared mission. The most notable 

25 Ibid., p. 8. 

26 Ibid., pp. 8–9. 

27 Ibid., p. 9. 

www.oig.dhs.gov 21 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

challenge we identified was between TTAC Technology, which built and 

maintains existing data systems, and TTAC TIM, which is building a replacement 

data system for the Adjudication Center. 

A cooperative relationship between legacy TTAC Technology and TIM is 

necessary for the Adjudication Center data system replacement projects to 

attain intended outcomes. Throughout the data system development process, 

TSA will need to monitor contractors to ensure that technical requirements, 

including requirements to develop data system internal controls, are met. After 

the new data system is operational, it will be necessary to phase out existing 

data systems, and for TTAC Technology to assume operation and maintenance of 

the new system. 

However, TTAC Technology and TIM personnel question each other’s 

competence, skill, and ability, and managers have been unable to agree on 

authorities and responsibilities between the two programs. In TSA, authority 

and responsibility for specialized technology functions is limited to technology 

offices such as the TSA Office of Information Technology and TTAC Technology. 

TIM is authorized to hire employees only in generalist positions, such as program 

analyst positions, but TIM officials have been hiring employees with technical 

backgrounds into program analyst positions in an attempt to develop the data 

systems without technical expertise from Technology. Several TSA officials 

expressed concern about TIM’s ability to conduct contract oversight without an 

effective working relationship with Technology. Although a portion of the TIM 

database is projected to be operational in calendar year 2013, we could not 

identify plans to phase out existing data systems or integrate Technology in 

operating or maintaining the new system. 

TSA senior leadership has not established clear lines of authority and 

responsibility to integrate shared Technology and TIM functions. Several senior 

managers from legacy TTAC offices said that the previous TTAC Assistant 

Administrator fostered tension between the two programs by not clearly 

defining lines of authority and resource allocation. There has also been a history 

of personal antagonisms between senior managers in the two programs, 

including an official complaint, and a separate dispute that resulted in one 

program moving its staff out of a shared workspace. While officials in both 

programs said that they continue to make efforts to work cooperatively, we are 

concerned that these attempts to resolve differences are not focused on 

replacing the Adjudication Center data systems in an efficient and effective 

manner. A new TIM data system is necessary to address internal control 

weaknesses in the Adjudication Center’s transportation worker vetting and 

www.oig.dhs.gov 22 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

credentialing programs. Ongoing active oversight by senior leadership of TSA’s 

Office of Intelligence and Analysis, which assumed responsibility for Technology 

and TIM after TSA’s reorganization, would be prudent to improve planning and 

implementation efforts. 

Recommendation 

We recommend that the Assistant Administrator for the TSA Office of 

Intelligence and Analysis: 

Recommendation #5:

Coordinate with both the Director of TIM and the Director of legacy TTAC 

Technology and oversee the development of the TIM data system and the 

decommissioning of legacy TTAC data systems. 

Management Comments and OIG Analysis 

Management Response: TSA officials concurred with Recommendation 5. In its 

response, TSA said that at the direction of the Assistant Administrator for the 

Office of Intelligence and Analysis, senior managers from TIM and Technology 

initiated a plan to put protocols in place that will ensure that the two Divisions 

maximize the resources in both organizations and effectively support the 

successful design and development of the TIM system. TSA said that to a great 

degree, the plan will follow the model successfully applied to other design, 

development, and implementation efforts. In addition, TSA said that the 

Assistant Administrator for the Office of Intelligence and Analysis chairs a 

monthly Executive Steering Committee Review, a monthly Program 

Management Review, and biweekly teleconference calls. These measures 

enable key DHS and TSA stakeholder organizations to provide input and 

oversight during the development of the TIM system. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 5, which is resolved and open. TSA should provide quarterly 

progress reports, and we will close this recommendation when the TIM data 

system has been implemented and legacy TTAC data systems decommissioned. 

Poor Managerial Practices at Legacy TTAC Must Be Addressed

Legacy TTAC employees have made allegations of improper conduct through 

formal and informal channels. These included allegations of poor management 

www.oig.dhs.gov 23 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

practices as well as violations of EEO standards, and some employees feared 

retaliation for raising such concerns. Senior legacy TTAC leaders sought to 

address misconduct through training and informal TTAC BMO internal 

administrative processes, but efforts were not successful. The use of informal 

administrative processes did not address or expose the extent of workplace 

complaints and led to inappropriately managed internal investigations. 

Employee complaints raised through TSA’s formal grievance processes were 

managed and documented appropriately, but not all employees had sufficient 

information to access formal redress options. 

Pattern of Allegations Regarding Inappropriate Human Capital Practices 

According to GAO guidance, human capital practices are a factor in effective 

internal control, and include “establishing appropriate practices for hiring, 

orienting, training, evaluating, counseling, promoting, compensating, and 

disciplining personnel.”28 As noted in figure 4, we obtained testimony or 

documentary evidence that indicates weaknesses in each of those areas in 

legacy TTAC. The type and extent of difficulties vary, and challenges differ 

between offices. For example, some offices trained and supervised contracting 

officer representatives adequately, and other offices did not. However, all 

offices have been affected to some degree by weak human capital practices. 

28 Ibid. 

www.oig.dhs.gov 24 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 4: Weaknesses in Human Capital Practices
 

Hiring

• Favoritism in hiring former colleagues from certain departments, agencies, and 

industries 

Orienting

• Contracting officer representatives without adequate training and supervision 

Training

• Unequal access to professional development through training and details 

Counseling

• Inappropriate informal or open-ended disciplinary measures 

• Reprimands for individuals in front of their peers or subordinates 

• Low performance ratings not tied to documentation or counseling 

• Failure to counsel individual employees for consistently poor performance 

• Criticism of whole teams instead of counseling individuals on persistent errors 

Promoting

• Promotions that displace an incumbent without a performance-related reason 

• Reorganization to promote staff without open competition 

Compensation

• Different salaries and raises for comparable experience and performance 

• Misapplication of Federal cost-of-living locality supplements 

• Failure of supervisors to submit required paperwork for pay increases 

Discipline

• Avoidance of formal disciplinary processes 

• Encouraging employees to file complaints against individuals out of favor with 

management 

Source: OIG analysis. 

Pattern of Allegations of Workplace Bullying and Hostile Work Environment 

According to GAO guidance, one factor in effective internal control is “the 

integrity and ethical values maintained and demonstrated by management and 

staff.”29 GAO notes that the quality of management plays a key role in “setting 

and maintaining the organization’s ethical tone, providing guidance for proper 

behavior, removing temptations for unethical behavior, and providing discipline 

when appropriate.”30 Through interviews with employees and TSA and DHS 

officials involved in civil rights and EEO grievance processes, and a review of 

pertinent documents, we determined that employees have made allegations of 

misconduct through formal and informal processes. These allegations include 

workplace bullying, a hostile work environment, and discrimination based on 

gender, race, religion, age, and disability. Allegations also involve difficulty 

29 Ibid., p. 8. 

30 Ibid. 

www.oig.dhs.gov 25 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

obtaining reasonable accommodation for medical conditions, and supervisors 

who did not protect the privacy of employees with medical conditions. 

Some legacy TTAC employees told us they had witnessed or experienced such 

misconduct, but had not reported it because they believed there would be 

retaliation or damage to their careers. Some employees said that they faced 

retaliation when raising questions about management decisions, defending their 

colleagues or subordinates who had raised such questions, or after filing a formal 

or informal complaint. We determined many of these allegations to be credible, 

based on specific detail, corroborating testimony, and documentation. Notably, 

even employees who raised concerns about retaliation said that they would not 

hesitate to report national security vulnerabilities, regardless of the consequences. 

TTAC Leadership Sought to Address Deficiencies Through Training

Senior legacy TTAC leadership was aware of many allegations related to 

improper supervisory practices and EEO violations, and sought to address these 

deficiencies through training. TTAC employee training sessions on EEO and 

diversity were held in 2009, 2010, and 2011. Team-building training was 

provided in 2011 to a TTAC office with the highest incidence of EEO complaints. 

In addition, there was leadership training for managers and team leads in 2011, 

and in March 2012 more supervisory training was provided. Given that incidents 

have continued since those trainings, we conclude that training has had little 

effect on changing behavior or improving improper supervisory practices. 

TTAC BMO Did Not Address or Expose the Extent of Worksite Problems 

TTAC BMO internal administrative processes were also used to informally 

address complaints. TTAC employees were told to raise complaints with TTAC 

BMO rather than directly with TSA’s OCRL, OHC Employee Relations, or the 

Ombudsman. This informal process led to confusion about the status of 

complaints, as TTAC BMO’s record-keeping system does not provide requisite 

specificity and formal operating procedures. In addition, TTAC BMO employees 

are not required to have competency or formal training to address allegations of 

misconduct. As a result, in at least two cases, internal investigations were 

managed inappropriately. In contrast, employee complaints raised through TSA 

formal processes, such as TSA OCRL, were managed and documented 

appropriately. 

www.oig.dhs.gov 26 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Some TTAC Employees Are Unaware of Official Administrative and Judicial 

Remedial Processes 

TSA is required by law to [m]ake “written materials available to all employees ... 

informing them of the variety of ... administrative and judicial remedial 

procedures available to them and prominently post[ing] such written materials 

in all personnel and EEO offices and throughout the workplace.”31 According to 

TSA policy, the only way to file an EEO complaint is for employees to communicate 

directly with TSA OCRL. Although information on formal remedial procedures is 

available through internal TSA websites that handle complaint processes, we did 

not observe TSA OCRL or Ombudsman materials posted in Annapolis Junction 

common areas. In addition, some TTAC employees were unaware of the official 

complaint process, how to contact TSA’s OCRL, the Ombudsman, or OHC 

Employee Relations, or where to direct complaints or grievances about 

employment issues. 

We identified multiple cases of TTAC employees who called or wrote to TTAC 

BMO with EEO and other workplace allegations, which TTAC BMO should have, 

but did not, refer to official TSA processes. In some cases, TTAC employees 

believed that these calls or written allegations constituted a formal complaint 

that would be investigated by an official body, such as TSA’s OCRL, OHC 

Employee Relations, or Office of Inspection. Employees who reported 

allegations to TTAC BMO expressed frustration after being told that the matter 

was investigated and closed, with no other information available. 

Based on interviews with and document requests to TSA’s OCRL, the 

Ombudsman, and Office of Inspection, we determined that these offices did not 

receive most of the allegations employees believed had been referred by TTAC 

BMO to an official TSA process. By law, TSA OCRL documents all pre-complaints 

(initial contacts with employees about workplace concerns or allegations), 

regardless of merit or whether the employee files a formal complaint.32 TSA 

OCRL officials explained that a BMO referral of an allegation would have been 

documented as part of the pre-complaint process. TSA OCRL’s pre-complaint 

and complaint records indicate that no TTAC BMO EEO allegations were referred. 

TTAC BMO should have reported allegations related to EEO or discriminatory 

practices to TSA’s OCRL or OHC Employee Relations. Many of the allegations 

submitted to TTAC BMO involved senior-level employees in K and L Band 

(General Schedule-15 equivalent) positions. 

31 29 C.F.R. §1614.102(b)(5). 

32 29 C.F.R. 1614.104. 

www.oig.dhs.gov 27 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Managing EEO Complaints Requires Human Resource Specialists and EEO 

Counselors With Specific Training 

According to GAO guidance, significant events should be authorized and 

executed only by persons acting within the specific scope of their authority.33 

None of the Job Analysis Tools for TTAC BMO employees required specific 

competency for handling EEO complaints. TTAC BMO employees who handle 

employee complaints described their positions as Human Capital Management 

or Human Resources, but were hired in program analyst positions. TTAC 

employees, including TTAC BMO employees, cited examples of inappropriate 

counseling and advice from TTAC BMO staff. Specifically, when some employees 

raised EEO issues, TTAC BMO staff counseled employees to speak with their 

manager and coached employees on what to say, asked employees if they could 

prove their claim, or encouraged employees not to file because there would be 

no benefit and the employee would “stir things up.” 

TSA OCRL officials said that TSA designates EEO counselors who are responsible 

for handling field office EEO issues. TSA provides these counselors with specific 

training on how EEO allegations should be handled and the scope of their job 

duties. In contrast, TTAC BMO employees are not required to have any specific 

knowledge, competency, or training in handling or referring EEO allegations. As 

a result, TTAC BMO employees are acting outside the specific scope of their 

authority by taking EEO complaints and counseling employees. 

Although effective internal control requires segregating duties and 

responsibilities, two key duties of TTAC BMO have not been segregated 

appropriately.34 For example, employees contact TTAC BMO staff about EEO 

allegations, and TTAC BMO also assists in TSA’s defense against formal EEO 

complaints. When an official EEO complaint is filed, TSA OCRL contacts TTAC 

BMO for assistance in processing those complaints by gathering documents and 

coordinating the official program management response. TTAC BMO staff said 

they assisted TSA management during EEO mediations “in an HR capacity.” TTAC 

BMO staff also acknowledged removing documents submitted by management 

that they perceived to be irrelevant, and advised managers about their 

responses before forwarding documents and responses to TSA’s Office of Chief 

Counsel for review. To minimize the appearance of bias and the risk of error or 

potential fraud, the duty to defend TSA management, who are subject to 

33 GAO/AIMD-00-21.3.1, November 1999, p. 14. 

34 Ibid. 

www.oig.dhs.gov 28 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

investigation, and the duty of accepting and referring TSA employee allegations, 

should be segregated among different position descriptions. 

TTAC BMO Has Conducted Inappropriate Internal Investigations 

According to GAO guidance, control environments should include sound human 

capital policies and practices, to include appropriate practices for disciplining 

personnel.35 TTAC BMO has conducted its own investigations of complaints and 

allegations among TTAC staff. In one case, a former TTAC Assistant 

Administrator assigned a subordinate K Band in TTAC BMO to review and make 

recommendations about a dispute between two higher graded L Band managers 

within TTAC. The K Band official did not receive training or guidance on 

conducting an administrative investigation, and the employee’s investigative 

report resulted in disciplinary action for one senior L Band official. To ensure 

that both the fact-finder and the employees are treated fairly and to minimize 

the appearance of bias or undue influence, this type of review and 

recommendation is handled best by an objective and trained third party from a 

separate office. 

In another internal investigation, which involved a pattern of alleged civil rights 

violations by a senior TTAC manager, several senior TTAC program officials 

believed that a formal complaint they raised with TTAC BMO had been reported 

through appropriate channels and would result in an official investigation. The 

TTAC program officials said that they decided the complaint should be formal, 

and described the formal process they followed as drafting a written complaint, 

encrypting it, sending it to TTAC managers, and providing evidence and 

statements from other senior TTAC officials to TTAC BMO. The senior program 

officials who raised the issue believed that a TSA investigation had been 

conducted. However, TTAC BMO did not refer the complaint or the individuals 

involved to TSA’s OCRL or the Ombudsman. TSA OCRL officials were unaware of 

the case, but noted that its description would merit an investigation as 

“management misconduct.” 

TTAC BMO Record Keeping Is Not Detailed Sufficiently 

As GAO identified in guidance, internal control activity includes clear 

documentation of significant events, which should be readily available for 

examination, properly managed, and maintained.36 TTAC BMO’s documentation 

35 Ibid., p. 9. 

36 Ibid., p. 15. 

www.oig.dhs.gov 29 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

of the allegations it receives is not detailed sufficiently and is incomplete. In 

response to a request for copies of allegations TTAC BMO received from staff, 

TTAC BMO provided us an informal one-page list of allegations and referrals that 

did not— 

•	 Consistently list both the complainant and the accused employee; 

•	 Include a specific or detailed description of the allegations; 

•	 Document whether the issue was referred to another office; 

•	 Track resolution or any final disposition of the complaint; or 

•	 Track whether any resolution or disposition was communicated to the 

parties involved. 

Although we requested that TTAC BMO officials provide us with copies of 

investigations they initiated, TTAC BMO did not provide any investigative 

reports. Due to insufficient legacy TTAC employee knowledge of formal 

complaint processes and poor record keeping by TTAC BMO, it was difficult to 

determine the extent and resolution of worksite allegations. Furthermore, 

because TTAC BMO did not report EEO complaints, interfered during the formal 

EEO complaint process, and managed allegations of discrimination by seniorlevel employees internally, it did not address nor expose the extent of worksite 

misconduct at legacy TTAC offices. 

Complaints From Legacy TTAC Employees Should Be Referred to TSA’s Formal 

Processes

In contrast, TSA’s formal processes for investigating allegations of misconduct 

and discriminatory practices are professional, responsive, and transparent. TSA’s 

Office of Inspection, Office of Professional Responsibility, OCRL, and OHC 

Employee Relations manage TSA’s formal processes. These offices responded 

quickly and comprehensively to our requests for interviews and documents, 

including documentation of their inspections and investigations. The records we 

reviewed indicate that investigations were thorough, balanced, and documented 

appropriately. 

Although each TSA office that handles formal complaint processes has a website 

on the TSA intranet, the websites are not linked to each other. As a result, 

employees would need to know specific search terms or TSA’s organizational 

structure to locate relevant websites. TSA has not compiled a website or 

brochure to guide employees through all available redress options, eligibility to 

file complaints, complaint processes, or direct contact information. 

www.oig.dhs.gov 30 	 OIG-13-05 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Channeling legacy TTAC complaints, allegations, and disciplinary actions through 

these TSA formal processes for a minimum of 2 years is prudent, and would 

enhance transparency and resolution. Reliance on formal processes and 

centralized tracking systems would provide TSA senior management with 

information on the extent and sources of persistent workplace misconduct. 

Centralized oversight would also assist the three TSA Assistant Administrators 

who will manage legacy TTAC employees to understand and address the 

underlying causes of personnel challenges. 

Recommendations 

We recommend that the TSA Administrator: 

Recommendation #6:

For a minimum of 2 years, direct legacy TTAC offices to refer all personnelrelated complaints, grievances, disciplinary actions, investigations, and 

inspections to appropriate TSA or DHS offices with primary oversight 

responsibility. 

Recommendation #7:

Provide employees a Know Your Rights and Responsibilities website and 

brochure that compiles appropriate directives on conduct, processes, and 

redress options. 

Management Comments and OIG Analysis 

Management Response: TSA officials concurred with Recommendation 6. In its 

response, TSA said that any matter affecting a TTAC legacy office, relating to 

complaints, grievances, disciplinary/adverse actions, investigations, or 

inspections, will be handled and resolved under the provisions outlined in TSA 

management directives and policies. TSA said that in accordance with these 

directives, responsibility for certain actions resides within the employee’s 

management chain. TSA said that in such limited instances, the restructuring, 

including changes in management personnel, ensures fair and impartial handling 

of such actions. Measures outlined in TSA’s Response to Recommendation 7 

provide additional means of safeguarding employee rights. Further, the time 

limitation noted in the recommendation is not necessary, as it implies that the 

related directives and policies would not apply. TSA said that the provision of 

www.oig.dhs.gov 31 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the directives and policies is in effect indefinitely for all TSA employees, including 

employees in the legacy TTAC offices. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 6, which is resolved and open. This recommendation will 

remain open pending confirmation that TSA has implemented our 

recommendation as written, or has revised its management directives, policies, 

incident reporting methodologies, and oversight sufficiently to provide 

transparent formal processes, centralized tracking systems, and centralized 

oversight for all TSA employees. The policies, guidance, and incident reporting 

processes in place for legacy TTAC employees during our review, which 

concluded after TSA reorganized, were not sufficient to address or expose the 

extent of workplace problems. Should TSA place legacy TTAC employees under 

the oversight of the Office of Professional Responsibility, as was done for Federal 

Air Marshals following our January 2012 report, Allegations of Misconduct and 

Illegal Discrimination and Retaliation in the Federal Air Marshal Service, OIG-12-

28, this action would be sufficient to close our recommendation. While we 

commend TSA’s interest in improving its processes for all its employees, poor 

managerial practices for legacy TTAC employees hinder the complaint reporting 

process and should be addressed promptly. 

Management Response: TSA officials concurred with Recommendation 7. In its 

response, TSA said that the Office of Civil Rights and Liberties, Ombudsman and 

Traveler Engagement would collaborate with all relevant offices to assess the 

current informational medium to implement direct access to pertinent 

information for all employees on their rights and responsibilities. TSA said that 

the Office of Civil Rights and Liberties would implement a new “Know Your Rights 

and Responsibilities” website and brochure that would compile appropriate 

directives on conduct, eligibility to file complaints, complaint processes, direct 

contact information, and redress options, with final action to be completed on 

November 22, 2012. 

OIG Analysis: We consider TSA’s actions responsive to the intent of 

Recommendation 7, which is resolved and open. This recommendation will 

remain open pending our receipt of the brochure and review of the TSA website. 

The Appearance of Fairness and Accountability Is Necessary for TSA’s 

Restructuring Initiative

TSA is restructuring to streamline its operations. This effort is intended to align 

intelligence, law enforcement, and policy functions better, and to ensure that 

www.oig.dhs.gov 32 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

employee titles and pay bands reflect job authorities and responsibilities 

properly. Employment practices in legacy TTAC offices, however, leave TSA 

exposed to grievances that could undermine these reforms. Specifically, 

irregular managerial practices and a pattern of past grievances could result in 

additional complaints of favoritism, discrimination, or retaliation. 

TSA Undergoing Workplace Realignment

TSA is undergoing a major reorganization to streamline its organizational 

structure. Aligning legacy TTAC’s intelligence, law enforcement, and policy 

functions with the Office of Intelligence and Analysis, OLE/FAMS, and Office of 

Security Policy and Industry Engagement, respectively, is intended to create 

efficiencies and improve integration and communication. TSA’s desk audit, to 

ensure that employee titles and pay bands reflect job authorities and 

responsibilities properly, is intended to promote fairer and more uniform 

compensation. We consider these reforms necessary and appropriate. 

Legacy TTAC Employee Concerns About Fairness Should Be Addressed

Legacy TTAC employment practices, including allegations of favoritism and EEO 

violations, as well as a practice of removing job responsibilities from employees, 

leave TSA exposed to grievances from employees who have been transferred or 

downgraded. Multiple credible grievances could undermine reforms. More than 

50 percent of the employees we interviewed believe that favoritism affects 

management decisions, and several identified changes in supervisory 

relationships during the initial stages of TSA’s reorganization that they believed 

were influenced by favoritism. Employees who have been removed from 

positions and not assigned new responsibilities are vulnerable to demotion 

during desk audits, as their duties, authorities, and responsibilities would not 

justify their pay band. Employees who raised concerns about management 

decisions, contracting practices, or EEO violations could reasonably perceive 

reassignment or demotion as a form of retaliation for their roles as complainants 

or whistleblowers. 

TSA should take measures to ensure that the restructuring process is fair for 

employees of legacy TTAC, and is perceived as transparent. Establishing an 

independent review panel whose members do not have a prior relationship with 

legacy TTAC could address concerns about fairness in staffing decisions during 

the reorganization and desk audits. The panel should report to the Office of the 

TSA Chief Human Capital Officer so that the three TSA Assistant Administrators 

who have assumed responsibility for legacy TTAC can remain impartial. 

www.oig.dhs.gov 33 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Current and former legacy TTAC employees could request an independent 

review of reassignment or demotion to a lower pay band. Employees who 

worked at legacy TTAC from September 2009, when legacy TTAC employees first 

raised concerns about management practices with members of Congress, should 

be eligible to request review. Eligibility to request review should continue until 

the current TSA-wide desk audits and reorganizations are complete, and 

employees have sufficient information about how their final placements will 

likely affect their roles and responsibilities. Aggregating cases may enable TSA to 

identify patterns or practices of unfair decisions. More important, creating an 

independent review panel would promote objective and defensible decisions. 

Recommendation 

We recommend that the TSA Chief Human Capital Officer: 

Recommendation #8:

Establish an independent review panel reporting to the Office of the Chief 

Human Capital Officer through which legacy TTAC employees may request a 

review of desk audits and reassignments. 

Management Comments and OIG Analysis 

Management Response: TSA did not concur with Recommendation 8. In its 

response, TSA said that it did not concur because multiple levels of controls in 

existing policy and procedures ensure independence and objectivity in the 

classification process. TSA provided specific information on these processes, 

including appeal processes. TSA said that it disagreed with the concept of a 

separate process specifically for legacy TTAC employees that would not be 

extended to other staff, as this would be an unequal application of position 

management and classification rules without legitimate cause, and would create 

an additional, unnecessary layer of review on top of avenues of review already in 

place. TSA believes its existing management directive and associated handbook 

afford legacy TTAC and all other affected employees fairness and equity in 

position management and classification. 

OIG Analysis: This recommendation was redirected from the TSA Administrator 

to the TSA Human Capital Officer. We consider TSA comments not responsive to 

the intent of Recommendation 8, which remains unresolved and open. Our 

recommendation was based on several issues which, taken together, leave TSA 

exposed to grievances that could undermine its restructuring initiative. We 

www.oig.dhs.gov 34 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

determined that legacy TTAC employment practices included widespread 

perceptions of favoritism in hiring and promotion, perceptions of retaliation 

against employees who raised concerns about management decisions and EEO 

violations, and past practices of removing job responsibilities from employees 

without cause. In addition, we noted that changes in supervisory structures that 

have taken place in the reorganization process have effectively resulted in 

promotions and demotions without a transparent process to compete for 

positions. In these circumstances, a desk audit based solely on classification 

rules would not address the underlying reasons that employees have been 

moved to a lower pay band. 

Therefore, we anticipate that many employees could file EEO grievances based 

on credible concerns about past discriminatory practices and retaliation that left 

them vulnerable in the restructuring process. TSA has in other circumstances 

changed redress options for certain employees to address past personnel issues, 

for example for Federal Air Marshals following our January 2012 report, 

Allegations of Misconduct and Illegal Discrimination and Retaliation in the 

Federal Air Marshal Service, OIG-12-28. This recommendation will remain 

unresolved and open until TSA establishes an independent review panel or 

comparable process through which legacy TTAC employees may request a review 

of desk audits and reassignments. 

Conclusion

Although TSA has instituted some oversight measures for personnel in legacy TTAC, 

there are weaknesses that must be addressed to reduce inefficiencies and employee 

misconduct, and limit the risk of insider threats. TSA PSD met Federal and departmental 

standards for adjudicating background investigations and applying reciprocity, but the 

lengthy process had a negative effect on the Secure Flight program. Secure Flight and 

the Adjudication Center have assessed internal control risks, but the Adjudication 

Center does not have the resources to mitigate some risks. 

Inefficient management structures and unclear lines of authority and responsibility 

hinder some legacy TTAC programs, and legacy TTAC officials have not addressed 

patterns of poor management and misconduct. Legacy TTAC employees have made 

credible allegations of violations of EEO standards and retaliation for raising concerns 

about management practices, but the extent of misconduct is not addressed or exposed 

because legacy TTAC BMO does not report allegations to appropriate TSA authorities. 

These weaknesses leave TSA vulnerable to grievances as it reforms its personnel 

positions and organizational structure. For the reforms to attain intended outcomes, 

www.oig.dhs.gov 35 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

TSA should provide more information about formal complaint processes to legacy TTAC 

employees and offer them a review process for transfers and position downgrades that 

they will perceive as objective, fair, and transparent. 

www.oig.dhs.gov 36 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

The DHS Office of Inspector General (OIG) was established by the Homeland Security Act 

of 2002 (Public Law 107-296) by amendment to the Inspector General Act of 1978. This 

is one of a series of audit, inspection, and special reports prepared as part of our 

oversight responsibilities to promote economy, efficiency, and effectiveness within the 

Department. 

We initiated this review to evaluate TSA’s oversight of personnel at legacy TTAC. Our 

objectives were to determine whether legacy TTAC employees have (1) position 

descriptions that reflect authority and responsibility levels accurately; (2) a personnel 

security screening process that complies with Federal laws, regulations, policy, and 

guidance; and (3) adequate internal controls on workplace activities. 

Our scope was limited to the review of personnel security decisions for legacy TTAC 

employees. We reviewed only internal controls on TTAC personnel and the data 

systems they access, not TTAC programs or TTAC stakeholders. Although adjudicators at 

Secure Flight and the Adjudication Center make decisions on air carrier passengers and 

workers who require access to transportation infrastructure, our review did not 

evaluate the quality or timeliness of those decisions. We did not assess legacy TTAC 

financial decisions or transportation security policies. We also did not assess the 

Colorado Springs Operations Center, except in the context of the joint management of 

the Secure Flight Operations Center. 

We conducted fieldwork for this report from January to May 2012. We reviewed 75 

TTAC personnel security files; 21 Office of Inspection files that involved legacy TTAC 

programs; 2 OHC files that involved disciplinary issues; and 10 OCRL files that involved 

EEO complaints. We also reviewed documentation that TSA provided to Congressman 

Bennie Thompson. 

We interviewed more than 80 legacy TTAC employees, and the TSA Offices of Personnel 

Security; Human Resources; Professional Responsibility; and Civil Rights and Liberties; 

the Ombudsman; and Traveler Engagement; as well as the DHS Offices of the Chief 

Security Officer Personnel Security Division; Human Resources; Civil Rights and Civil 

Liberties; and the Screening Coordination Office. In addition, we met with OPM and 

ODNI officials. OPM has oversight authority for Federal personnel security programs, 

and shares with ODNI oversight authority for national security clearances, including the 

application of reciprocity between Federal departments and agencies. 

www.oig.dhs.gov 37 OIG-13-05 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We reviewed more than 400 TSA documents, including Personnel Security laws, 

regulations, guidance, procedures, and training materials; OHC laws, regulations, 

guidance, procedures, and training materials; position descriptions and Job Analysis 

Tools developed for legacy TTAC positions; Office of Professional Responsibility 

guidance on conduct and disciplinary actions; DHS and TSA Management Directives 

related to personnel security and internal controls; TSA PSD performance metrics; 

legacy TTAC laws, regulations, guidance, procedures, training materials, and 

performance metrics; guidance provided to TSA personnel on conduct, disciplinary 

actions, and complaint and grievance procedures; and documentation provided by 

individual employees related to allegations of contracting impropriety and staff 

misconduct. 

We conducted this review under the authority of the Inspector General Act of 1978, as 

amended, and according to the Quality Standards for Inspections issued by the Council 

of the Inspectors General on Integrity and Efficiency. 

www.oig.dhs.gov 38 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Recommendations 

Recommendation #1: Establish a point of contact, email address, or contact number for 

TSA managers to follow up on the status of employees who require Top Secret and 

Sensitive Compartmented Information investigations or reinvestigations. 

Recommendation #2: Provide TSA Assistant Administrators who have employees with 

pending Top Secret and Sensitive Compartmented Information investigations and 

reinvestigations with monthly statistics on the number of cases pending, number of 

days cases have been in the system, and current backlog when applicable. 

Recommendation #3: Provide the Adjudication Center sufficient Federal employees to 

establish internal control over operations and reporting requirements. 

Recommendation #4: Develop a restructuring plan to enhance operational 

effectiveness in the Secure Flight Operations Center staffing model. 

Recommendation #5: Coordinate with both the Director of TIM and the Director of 

legacy TTAC Technology and oversee the development of the TIM data system and the 

decommissioning of legacy TTAC data systems. 

Recommendation #6: For a minimum of 2 years, direct legacy TTAC offices to refer all 

personnel-related complaints, grievances, disciplinary actions, investigations, and 

inspections to appropriate TSA or DHS offices with primary oversight responsibility. 

Recommendation #7: Provide employees a Know Your Rights and Responsibilities 

website and brochure that compiles appropriate directives on conduct, processes, and 

redress options. 

Recommendation #8: Establish an independent review panel reporting to the Office of 

the Chief Human Capital Officer through which legacy TTAC employees may request a 

review of desk audits and reassignments. 

www.oig.dhs.gov 39 OIG-13-05 
 

Appendix C 

Management Comments to the Draft Report

U.S, Dtp.r1mtnt of Hom and StctJ rity 

601 South 12th Street 

Arlington, VA 20598 

Transportation 

Security 

Administration 

OCT' 2 2012 

INFORMATION 

MEMORANDUM FOR: Charles K. Edwards 

Acting Inspector Generay 

FROM: John S. Pi stOlc~ ~ Administrator \j 

SUBJECT: Transportation Security Administration's (TSA) Response to 

U.S. Department of Homeland Security (DHS) Office of Inspector 

General 's (OIG) Draft Report Titled Personnel Security and 

Internal Control at TSA '.I' Legacy Threat Assessment and 

Credentialing Office - For Official Use Only, OIG Project 

No.12-049-ISP-TSA-A 

Purpose 

This memorandum constitutes TSA's formal Agency response to the DHS OIG draft report 

Personnel Security and Internal Control at TSA '.1' Legacy Threat Assessment and Credenlialing 

Office. TSA appreciates the opportunity to review and provide comments to your draft report. 

Background 

In February 2012, OIG began a review ofTSA's Personnel Security practices and management 

controls in the legacy offices of the former Threal Assessment and Credentialing Office (TT AC). 

OIG's objectives were to determine whether IT AC employees have: (l) position descriptions 

that reOecl authority and responsibility levels accurately; (2) a personnel security screening 

process that complies with Federal laws, regulations, policy, and guidance; and (3) adequate 

internal controls on workplace activities. OIG conducted its fieldwork from February 2012 to 

July 2012. 

www.oig.dhs.gov 40 OIG-13-05

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 
www.oig.dhs.gov 41 OIG-13-05

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

Discussion 

TSA welcomes the OIG review of the Personnel Security and legacy TTAC programs. Overall , 

the OIG recommendations will help TSA to continue to improve and to implement more 

effective programs. We COnCur with many of the recommendations and have already taken steps 

to address them. What follows are TSA's specific responses to the recommendations contained 

in OIG's report. 

Recommendation #1: Establish a point of contact, e-mail address, or contact number for TSA 

managers to follow up on the status of employees who require Top Secret and Sensitive 

Compartmented Information investigations or reinvestigations. 

TSA Response: Concur. The Personnel Security Section (PerSec) has established a homepage 

On the TSA intranet (iShare) as the primary source of information for stakeholders requiring 

infornlation or assistance with security clearance requests or other PerSec products and services. 

In addition to points of contact, e-mail addresses, and phone numbers, the homepage provides 

infomJation regarding PerSec forms and documents, reference materials, and Frequently Asked 

Questions. Portable Document Format (PDF) screenshots of the PerSec home and contact 

information pages are attached. TSA considers this recommendation closed and implemented. 

Recommendation #2: Provide TSA Assistant Administrators who have employees with pending 

Top Secret and Sensitive Compartmented Information investigations and reinvestigations with 

monthly statistics on the number of cases pending, number of days cases have been in the system, 

and current backlog when applicable. 

TSA Response: Concur. In December 2012, PerSec will begin using the DHS electronic 

Integrated Security Management System (ISMS) to record and manage all background 

investigation and security clearance information. ISM S functionalities will allow for automatic, 

timely notifications and/or updates to stakeholders, as well as to ortiees within TSA that do not 

currently have access to PerSec information. Pending final transition to ISMS, interim measures 

have been implemented to provide case statuses through "tickl er" reports. Examples of recent 

reports provided to TSA leadership are attached. TSA considers this recommendation closed and 

implemented. 

Recommendation #3: Provide the Adjudication Center sufficient Federal employees to 

establish internal control over operations and reporting requirements. 

TSA Response: Concur. TSA Office of Law Enforcement/Federal Air Marshal Service 

(OLE/FAMS) is pursuing efforts to increase the number of federal employees assigned to the 

Security Threat Assessment Office. 

OIG Recommendation #4: Develop a restructuring pl an to enhance operational effectiveness in 

the Secure Flight Operations Center staffing model. 

TSA Response: Concur. The Secure Flight Operations Center (SOC) has made significant 
changes and implemented new programs and schedules since the OIG audit was conducted to 

address many of the areas identified in the audit. These modifications include changes to the 

schedule based on employee feedback, structural changes to improve communication and 

enhance career and role progression, internal and external training programs to support inposition refresher courses and knowledge development opportunities, and more structured use of 

employee overlap time. Spec ific modifications include: 

• The ex isting schedule was modified to remove the 4-month rotational set that occurred 

every 2 months due to a switch from front-half to back-half of the week. The schedule 

was redesigned to ensure a fair and equitable distribution across the workforce of work 

requiring differential pay. Additionally, the order of the rotation was changed to better 

address people's natural sleep and rhythm schedules. 

• The SOC has implemented a regimented in-position training program. A training matrix 

was published in August 2012 that identifies training specific to job skills and operations. 

The SOC will also be implementing a Learning Series to provide refresher training during 

overlap times by the end of Calendar Year 2012. The SOC implemented a robust and 

simple shift swap program in April 2012 to support the needs of the workforce for days 

off, to schedule classes, and have time for other personal matters while still maintaining 

sufficient operational capacity. 

• In August 20 12, the SOC announced a new structure and role progression model for 

analyst positions consistent with the career progression goals ofTSA and the Office of 

Intelligence and Analysis. 

• SOC is currently in the final planning phase for a redesign of the Customer Support 

Agent (CSA) area in the Annapolis Junction Operations Center, which will alleviate 

overlap spacing issues. 

• Distribution of call volume and manual review volume is relatively consistent across a 

24-hour period and drives scheduling and staffing in the SOC. While a multitude of 

scheduling options are used in the Federal Government operations center environment, 

the Modified 4-3 10 hour schedule used by the SOC supports current operations. The 

SOC will continue to conduct periodic review of the schedule based on workload and 

feedback of SOC personnel. 

• Regarding the supervisory structure, all analysts have on-site supervision and Watch 

Managers have either a first- or second-line supervisor co-located with them. There are 

five CSAs on each team and they are supervised by a single supervisor at one of the 

locations. Supervisory CSAs conduct bi-annual site visits; regular video teleconference 

meetings; daily, real-time communications through instant messaging groups; and quality 

control reviews of calls through the Remedy system. Given the findings, the SOC will 

explore additional ways to support cross-site supervision or exanline alternative 

supervisory structures for CSAs to determine if there is a better and more efficient 

method of supervision. 

OIG Recommendation #/5: Coordinate with both the Director of TIM and the Director of 

legacy TTAC Technology and oversee the development of the TIM database and the 

decommissioning oflegacy TT AC databases. 

 

www.oig.dhs.gov 42 OIG-13-05

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 
TSA Response: Concur. At the direction of the Assistant Administrator (AA) for the Office of 

Intelligence and Analysis (OIA), Tech nology In tTastructure Modernization (TIM) and 

Technology Solutions Division (TSD) senior managers initiated a plan to put protocols in place 

that will ensure the divisions maximi ze the resources in both organizations and effectively 

SUpp0l1 the successful design and development of the TIM system. To a great degree, it will 

follow the model successfull y applied to mher design, development, and implementation efforts. 

In addition, the Assistant Administrator for OIA chairs a monthl y Exec utive Steering Committee 

Review, a monthly Program Management Review, and biweekly teleconference calls. These 

mea 'ures enable key DHS and TSA stakeholder organizations to provide input and oversight 

during the development of the TIM system. 

Recommendation #6: For a minimum of 2 years, direct legacy TTAC offices to refer all 

personnel related complaints, grievances, disciplinary actions, investigations, and inspections to 

appropriate TSA or DHS offices with primary oversight responsibi lities. 

TSA Response: Concur, except that it is unnecessary to include a 2-year time frame. Any 

matter affecting a 1TAC legacy office relating to complaints, grievances, disciplinaryladverse 

actions, investigations, or inspections will be handled and resolved under the provisions outlined 

in TSA management directives and policies. In accordance with these directives, responsibility 

for certain actions resides within the employee's management chain. In such limited instances, 

the restructuring, including changes in management personnel, ensures fair and impurtial 

handling of such actions. Additionally, the measures outlined in TSA's Response to 

Recommendation 7 provide additional means of safeguarding employee rights. 

The time limitation noted in the recommendation is not necessary as this implies that after 

2 years, the provisions of the related directives and policies will not apply. The provisions of the 

directives and policies are in effect indefinitely for all TSA employees, includi ng employees in 

the legacy IT AC offices. 

Recommendation # 7: Provide employees a Know Your Rights and Responsibilities Web site 

and brochure that compile appropriate directives on conduct, processes, and redress options. 

TSA Response: Concur. TSA Office of Civil Rights & Liberties, Ombudsman, & Traveler 

Engagement (CRUOTE) will collaborate with all relevant offices to assess the current 

infonoational medium to implement direct access to pertinent infomlation for all employees on 

their rights and responsibilities. CRUOTE will implement a new "Know Your Rights and 

Responsibilities" Web site and brochure that compiles appropriate directives on conduct, 

eligibil ity to file complaints, complaint processes, direct contact information, and redress 

options, with final action to be completed on November 22, 2012. 

Recommendation #8: Establish an independent review panel reporting to the Office of the 

TSA Administrator through which legacy IT AC employees may request a review of desk audits 

and reassignments. 

 

www.oig.dhs.gov 43 OIG-13-05

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 
 

TSA Response: Non-concur. The Recommendation provides that: "Aggregating cases may 

enable TSA to identitY pattems or practices of unfair decisions. More important, creating an 

independent review panel would promote objective and defensible decisions." TSA does not 

concur with this recommendation because multiple levels of controls in existing policy and 

procedures ensure independence and objectivity in the classification process. Per TSA 

Management Directive (MOl No. 1100.51·1 , Position Management and Position Classification, 

the Omce of Human Capital (OHC) is the sole office responsible for making position 

classification determinations. OHC is required to apply the specific process and use the 

established standards detailed in the TSA Handbook /0 MD No. 1100.51·1 for all classification 

reviews. Existing policies and procedures ensure that OHC actions and decisions are uniformly 

administered across all program offices and positions, and are independent of extemal influence. 

The data collection process used by OHC is inclusive, with multiple opportunities for input and 

verification by employees and managers to ensure that OHC accurately understands each 

position's responsibilities and technical knowledge requirements. Validated information is 

evaluated against the established standards documented in the TSA Halldbook fo MD 

No. 1100.51·1 to make classification determinations. Material changes to current classifications, 

such as a Change to Lower Band (CLB), often undergo secondary peer review, and all cases are 

reviewed by OHC management. Each determination resulting in a CLB is subject to multiple, 

escalating checks for compliance with process, including analysis, and documentation 

requirements designed to guarantee independence, objectivity, and thoroughness before reaching 

the OHC/AA for signature. In addition, TSA MD No. 1100.51·1 provides employees affected by 

a CLB the right to reply to the classification decision, which is reviewed by the ANOHC before 

a final decision is made. Further, upon completion of this rigorous internal process, employees 

whose positions undergo a CLB have the right to seek external redress by appealing to the Merit 

Systems Protection Board (MSPB). 

TSA disagrees with the concept of a separate process specifically for legacy TT AC employees 

that would not be extended to other staff, as this would be an unequal application of position 

management and position classification rules without legitimate cause. Establishment of such a 

process for legacy TT AC employees would result in an unequal application of position 

management and position classification rules without legitimate cause. At the same time, 

extending the proposed independent review panel to cover all legacy TT AC employees affected 

by reclassification would create an additional , unnecessary layer of review on top of the internal 

and external review avenues already in place, with affects ranging from delaying an already 

extensive process to undermining the OHC's position as TSA's personnel management aut hority. 

TSA believes that the provisions of MD 1100.51 ·1 and the associated Handbook effectively 

afford legacy IT AC and all other affected employees faimess and equity in position management 

and classification. 

Attachments 

 

www.oig.dhs.gov 44 OIG-13-05

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

GAO Standards for Internal Controls 

GAO’s Standards for Internal Control in the Federal Government provides five standards 

for effective internal control.37 

GAO Standards for Internal Control 

Control Environment 

Management and employees should establish and maintain an environment throughout the 

organization that sets a positive and supportive attitude toward internal control and 

conscientious management. Examples: 

• Integrity and ethical values maintained and demonstrated by management and staff 

• Management’s commitment to competence 

• The manner in which the agency delegates authority and responsibility 

• Sound human capital policies and practices 

Risk Assessment 

Internal control should provide for an assessment of the risks the agency faces from both 

external and internal sources. Examples: 

• Clear, consistent agency objectives 

• Identification and analysis of risks 

Control Activities 

Internal control activities help ensure that management's directives are carried out. The 

control activities should be effective and efficient in accomplishing the agency’s control 

objectives. Examples: 

• Performance reviews 

• Management of human capital 

• Controls over information processing 

• Segregation of duties 

• Documentation of transactions and events 

Information and Communications 

Information should be recorded and communicated to management and others within the 

entity who need it and in a form and within a time frame that enables them to carry out their 

internal control and other responsibilities. Examples: 

• Operational and financial data 

• Information flowing down, across, and up in the organization 

Monitoring 

Internal control monitoring should assess the quality of performance over time and ensure 

that the findings of audits and other reviews are promptly resolved. Examples: 

• Ongoing monitoring during normal operations 

• External evaluation of controls 

37 Ibid., pp. 8–21. 

www.oig.dhs.gov 45 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Major Contributors to This Report 

Marcia Moxey Hodges, Chief Inspector 

Lorraine Eide, Lead Inspector 

Heidi Einsweiler, Inspector 

Morgan Ferguson, Inspector 

www.oig.dhs.gov 46 OIG-13-05 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Administrator, Transportation Security Administration 

Undersecretary for Management 

TSA Audit Liaison 

Acting Chief Privacy Officer 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 47 OIG-13-05 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this document, please call us at (202) 254-4100, fax your 

request to (202) 254-4305, or e-mail your request to our Office of Inspector General 

(OIG) Office of Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

For additional information, visit our website at: www.oig.dhs.gov, or follow us on Twitter 

at: @dhsoig. 

OIG HOTLINE 

To expedite the reporting of alleged fraud, waste, abuse or mismanagement, or any 

other kinds of criminal or noncriminal misconduct relative to Department of Homeland 

Security (DHS) programs and operations, please visit our website at www.oig.dhs.gov 

and click on the red tab titled "Hotline" to report. You will be directed to complete and 

submit an automated DHS OIG Investigative Referral Submission Form. Submission 

through our website ensures that your complaint will be promptly received and 

reviewed by DHS OIG. 

Should you be unable to access our website, you may submit your complaint in writing 

to: DHS Office of Inspector General, Attention: Office of Investigations Hotline, 245 

Murray Drive, SW, Building 410/Mail Stop 2600, Washington, DC, 20528; or you may 

call 1 (800) 323-8603; or fax it directly to us at (202) 254-4297. 

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