HOMELAND 

SECURITY

DHS Has Enhanced 

Procurement 

Oversight Efforts, but 

Needs to Update 

Guidance

Report to the Subcommittee on 

Oversight, Investigations, and 

Management, Committee on Homeland 

Security, House of Representatives

September 2012

GAO-12-947

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-947, a report to the 

Subcommittee on Oversight, Investigations, 

and Management, Committee on Homeland 

Security, House of Representatives

September 2012

HOMELAND SECURITY

DHS Has Enhanced Procurement Oversight Efforts, 

but Needs to Update Guidance

Why GAO Did This Study

DHS bought over $14 billion in goods 

and services in fiscal year 2011—over 

one quarter of its budget—and 

processed over 100,000 transactions 

to support its homeland security 

missions. In 2005, DHS established an 

oversight program to provide 

department-level insight into 

components’ procurement of goods 

and services and to identify successful 

acquisition management approaches. 

DHS has also established specific 

initiatives, such as a strategic sourcing 

program in 2003 to reduce 

procurement costs and gain other 

efficiencies by consolidating 

requirements. GAO (1) assessed 

DHS’s efforts to implement 

procurement oversight, and (2) 

identified DHS components’ use of 

strategic sourcing to leverage their 

buying power. To do this, GAO 

reviewed procurement oversight 

policies and guidance, interviewed 

officials from OCPO and DHS 

components, reviewed prior GAO 

reports, reviewed on-site review 

findings and recommendations, and 

examined DHS and component 

documentation of oversight and 

strategic sourcing efforts. 

What GAO Recommends

Based on DHS’s actions in response to 

the recommendation contained in the 

draft report, GAO recommends that the 

Secretary of Homeland Security direct 

the Chief Procurement Officer to 

review and ensure consistency 

between the new procurement 

oversight directive and guidebook and 

with the department’s current 

procurement oversight efforts.

What GAO Found

The Department of Homeland Security’s (DHS) Office of the Chief Procurement 

Officer (OCPO) continues to implement and has improved some aspects of its 

procurement oversight but has not sufficiently updated its guidance. OCPO’s 

oversight has helped ensure that DHS components receive and address 

constructive assessments of their compliance with procurement regulations and 

policies. The oversight also has increased the Chief Procurement Officer’s

visibility into components’ progress against procurement-related metrics. For 

example, OCPO establishes annual procurement goals for the components and 

tracks their progress in quarterly reports. OCPO has been less consistent in—but 

continues to hone its implementation of—other aspects of the program, such as 

self assessments and parts of its acquisition planning reviews. However, until 

GAO sent DHS a draft of this report recommending that DHS issue updated 

policy and guidance to reflect changes to the department’s procurement 

oversight efforts, the department did not issue updated policy or guidance. This 

has led to a lack of clarity among components regarding what the oversight 

efforts entail. For example, some components did not complete a required self 

assessment in 2011. GAO’s review of the revised policy and guidance found

inconsistencies between the two and with current oversight efforts.

Examples of Procurement-Related Goals OCPO Established and Tracked in 2011 and 2012, for 

the Transportation Security Administration

Topic 2011 Goal 

Tracked in 2011 

Quarterly Report 2012 Goal

Percent of obligated dollars awarded 

competitively 

≥74% Yes ≥76%

Percent of contracts awarded to small 

businesses

≥23% Yes ≥23%

Accuracy of Federal Procurement Data 

System-Next Generation Dataa

≥92%

 

Yes ≥93%

Source: GAO analysis of DHS documents.

a

DHS component officials stated that most of their efforts to leverage buying 

power are through the department’s strategic sourcing program, which provides 

departmentwide contract vehicles for the purchase of specific items or services.

According to DHS data, the department’s spending through strategic sourcing 

contract vehicles has increased steadily from $1.8 billion in fiscal year 2008 to 

almost $3 billion in fiscal year 2011, representing about 20 percent of DHS’s 

procurement spending for that year. The Office of Management and Budget has 

recognized some of DHS’s strategic sourcing efforts as best practices. DHS 

policies encourage components to consider, but do not require, the use of 

strategic sourcing contract vehicles. The Chief Procurement Officer has identified 

increasing strategic sourcing as a departmentwide priority and OCPO 

encourages the utilization and development of strategic sourcing contract 

vehicles in a variety of ways, including hosting quarterly training sessions and

posting contract information on the strategic sourcing web page. In addition, 

while components have leveraged contracts with other agencies, many found it 

more efficient to use DHS’s strategic sourcing contract vehicles. DHS 

components generally do not use other components’ contracts.

For all elements subject to annual Office of Federal Procurement Policy certification.

View GAO-12-947. For more information, 

contact John Hutton at (202) 512-4841 or 

huttonj@gao.gov. 
Page i GAO-12-947 Homeland Security

Letter 1 

Background 3

DHS Has Improved Some Aspects of Its Procurement Oversight but 

Guidance Is Not Sufficiently Updated 5

Components Leverage Buying Power through DHS’s Strategic 

Sourcing Program 15

Conclusions 17

Recommendation for Executive Action 18

Agency Comments and Our Evaluation 18

Appendix I Scope and Methodology 20

Appendix II Comments from the Department of Homeland Security 22

Appendix III Snapshot from a 2012 DHS Component Quarterly Report 24

Appendix IV GAO Contact and Staff Acknowledgments 25

Tables

Table 1: Comparison of Oversight Mechanisms in the Original 

Directive and Guidebook with Current Efforts as 

Described by OCPO Officials 7

Table 2: Examples of OCPO On-Site Review Findings and 

Recommendations from Contract File Reviews and 

Actions Components Took to Address the 

Recommendations 9

Table 3: Examples of Contracting-Related Goals OCPO Established 

and Tracked with Metrics in 2011 and 2012, for TSA 11

Figures

Figure 1: Organization Chart for OCPO’s Oversight and Strategic 

Support Division 3

Figure 2: DHS Components with HCAs and Lines of Reporting 4

Contents
Page ii GAO-12-947 Homeland Security

Abbreviations

DHS Department of Homeland Security

GAO Government Accountability Office

HCA Head of Contracting Activity

OCPO Office of the Chief Procurement Officer

HSAM Homeland Security Acquisition Manual

FAR Federal Acquisition Regulation

TSA Transportation Security Administration

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-947 Homeland Security

United States Government Accountability Office

Washington, DC 20548

September 10, 2012

The Honorable Michael T. McCaul

Chairman

Subcommittee on Oversight, Investigations, 

and Management

Committee on Homeland Security

House of Representatives

The Honorable William R. Keating

Ranking Member

Subcommittee on Oversight, Investigations, 

and Management

Committee on Homeland Security

House of Representatives

The Department of Homeland Security (DHS) is a complex organization 

responsible for a broad range of mission and management areas, such as 

border security, immigration services, aviation security, maritime security, 

and emergency preparedness and response. DHS bought over $14 billion 

in goods and services in fiscal year 2011—representing over one quarter of 

its budget—and processed over 100,000 transactions to support its 

homeland security missions. DHS has initiated broad oversight efforts to 

improve its procurement of goods and services as well as specific initiatives 

to reduce procurement costs, such as strategic sourcing.1

DHS’s Office of the Chief Procurement Officer (OCPO) established an 

acquisition oversight program in 2005 to complement DHS’s existing 

acquisition management governance process for major investments. 

Management Directive 0784, “Acquisition Oversight Program” (2005) and 

the “Acquisition Oversight Program Guidebook” (2006) included policy 

and guidance for the program, which was designed to provide 

The Chief 

Procurement Officer’s Strategic Plan for Fiscal Year 2012 to 2014 

highlights these efforts and other priorities for improving procurement 

operations including the oversight activities required to implement the plan.

 

1

DHS defines strategic sourcing as a collaborative and structured process of critically 

analyzing DHS spending and using an enterprise approach to make business decisions 

about acquiring and managing commodities and services more effectively and efficiently 

across multiple components or the entire department.

 
 

Page 2 GAO-12-947 Homeland Security

department-level insight into components’ acquisition functions and to 

identify successful acquisition management approaches. The program

addressed a broad range of acquisition- and procurement-related issues2

through four main oversight mechanisms: operational status reviews, onsite reviews, self assessments, and acquisition planning reviews.3

OCPO established a strategic sourcing program in 2003 to leverage 

DHS’s buying power to increase savings and other efficiencies by 

consolidating requirements, increasing standardization of requirements 

across components, and enhancing management of commodities or 

services. According to DHS, since the program’s inception, it has led to 

over $1 billion in savings and increased administrative efficiencies.

Given your interest in sound procurement practices, you requested that 

we undertake a review of DHS procurement oversight efforts. 

Accordingly, we (1) assessed DHS’s efforts to implement procurement 

oversight, and (2) identified DHS components’ use of strategic sourcing to 

leverage their buying power.

To assess DHS’s efforts in implementing procurement oversight, we 

reviewed procurement oversight policies and guidance; interviewed 

knowledgeable officials from OCPO and DHS components; reviewed prior 

GAO reports; and examined DHS and component documentation of 

oversight efforts, including OCPO’s review schedule, quarterly reports,

goal letters, and on-site reviews from 2007 to the present. To evaluate the 

extent to which DHS components address the recommendations 

identified in on-site reviews, we interviewed OCPO and component 

contracting officials, reviewed on-site review findings and 

recommendations, and analyzed components’ written responses 

regarding, and documentation of, actions they took to address 

recommendations in their most recent on-site reviews.

 

2

For the purpose of this report, the term “acquisition” refers to the broader process of 

conceptualization, initiation, design, development, test, contracting, production, 

deployment, logistics support, modification, and disposal of systems, supplies, or services 

to satisfy the government’s needs; we use the terms “procurement” and “contracting” 

interchangeably to refer to the specific act of buying or otherwise obtaining goods and 

services for the government. 

3

The Federal Acquisition Regulation defines acquisition planning as the process by which 

the efforts of all personnel responsible for an acquisition are coordinated through a 

comprehensive plan for fulfilling the agency need in a timely manner. FAR §2.101. 
 

Page 3 GAO-12-947 Homeland Security

To identify practices DHS components use to leverage their buying power 

through strategic sourcing, we reviewed relevant policies and guidance; 

examined OCPO documentation of strategic sourcing efforts; and 

interviewed OCPO and component officials about practices they employ, 

contracts they have leveraged, and resulting benefits.

A more detailed description of our scope and methodology is presented in 

appendix I. We conducted this performance audit from March 2012 to 

September 2012 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

OCPO’s Oversight and Strategic Support Division manages the Chief 

Procurement Officer’s procurement oversight efforts. Figure 1 shows the 

division’s four branches. All branches except the strategic sourcing 

branch are responsible for aspects of the procurement oversight efforts.

Figure 1: Organization Chart for OCPO’s Oversight and Strategic Support Division

Component-level contracting activity is led by component Heads of 

Contracting Activity (HCA), who have overall responsibility for the day-today management of the component’s contracting function. OCPO has 

oversight responsibilities for all nine DHS HCAs—one for each of the 

seven components with procurement offices and one HCA each for the 

Office of Selective Acquisitions and the Office of Procurement 

Operations, which provide contracting support to all other components. 

The Selective Acquisitions and Procurement Operations HCAs report 

directly to the Chief Procurement Officer. The seven other HCAs report 

directly to their component heads, but their contracting authority is 

delegated to them from the Chief Procurement Officer. Figure 2 shows 

Background 
 

Page 4 GAO-12-947 Homeland Security

the organizational relationships among the HCAs, the Chief Procurement 

Officer, and other senior DHS leadership.

Figure 2: DHS Components with HCAs and Lines of Reporting
 

Page 5 GAO-12-947 Homeland Security

The Oversight and Strategic Support Division’s strategic sourcing branch 

has management responsibilities for DHS’s strategic sourcing initiative. 

DHS defines strategic sourcing as a collaborative and structured process 

of critically analyzing DHS spending and using an enterprise approach to 

make business decisions about acquiring and managing commodities and 

services more effectively and efficiently across multiple components or 

the entire department. DHS’s strategic sourcing contract vehicles include 

contracts or agreements that have been established for use by two or 

more components. To maximize cost savings, DHS encourages 

component utilization of established strategic sourcing vehicles.

OCPO’s oversight has helped ensure that components address 

constructive assessments of their compliance with procurement 

regulations and policies and has increased the Chief Procurement 

Officer’s visibility into components’ progress against procurement-related 

metrics. OCPO has been less consistent in—but continues to hone—its 

implementation of other aspects of the program, including self 

assessments and parts of its acquisition planning reviews. However, at 

the time of our review, DHS had not issued updated policy or guidance 

reflecting OCPO’s current approach to procurement oversight, which led 

to a lack of clarity for components regarding what the oversight efforts 

entail.

OCPO has maintained the overarching structure of its oversight program 

while making some modifications to reflect a more specific focus on 

procurement issues versus broader acquisition issues. As described in 

the management directive and guidebook, OCPO’s original oversight 

program included four types of reviews: on-site reviews, operational 

status reviews, self assessments, and acquisition planning reviews. It was 

based largely on GAO’s Framework for Assessing the Acquisition 

Function at Federal Agencies4

 

4

GAO, Framework for Assessing the Acquisition Function at Federal Agencies, 

and assessed broad issues related to both 

acquisitions and procurement. Our prior work on the acquisition oversight 

GAO-05-218G (Washington, D.C.: September 2005). The framework includes tools to 

enable high-level, qualitative assessments of the strengths and weaknesses of the 

acquisition function at federal agencies, focusing on the following topics: (1) organizational 

alignment and leadership, (2) policies and processes, (3) human capital, and (4) 

knowledge and information management.

DHS Has Improved 

Some Aspects of Its 

Procurement 

Oversight but 

Guidance Is Not 

Sufficiently Updated

Procurement Oversight 

Focus Has Changed
 

Page 6 GAO-12-947 Homeland Security

program in 2007 found that OCPO’s oversight plan generally incorporated 

effective acquisition management principles, but that DHS faced 

challenges in implementing its oversight program.5 OCPO began making 

changes to the program in 2008, starting a transition to what is now 

referred to as “procurement oversight.” OCPO’s current efforts, which at 

the time of our review were not documented in written policy or guidance, 

still include the four types of reviews, but no longer fully reflect the original 

guidance. For example, some reviews are now focused on procurement 

rather than broader acquisition-related topics, which now fall under the 

responsibility of other offices such as the recently created Program 

Accountability and Risk Management Division, which is responsible for 

acquisition program management oversight.6 Specifically, OCPO’s 

current oversight efforts no longer examine cost, schedule, and 

performance variances for major investments, which are the responsibility 

of the Program Accountability and Risk Management Division. Table 1 

compares the oversight review structure and focus as described in the 

original management directive and guidebook with current efforts as 

described by OCPO officials, since updated guidance was not available at 

the time of our review.

 

5

GAO, Department of Homeland Security: Progress and Challenges in Implementing the 

Department’s Acquisition Oversight Plan, GAO-07-900 (Washington, D.C.: 

June 13, 2007). 

6

We plan to issue a report in September 2012 examining DHS’s oversight and 

management of its major acquisition programs.
 

Page 7 GAO-12-947 Homeland Security

Table 1: Comparison of Oversight Mechanisms in the Original Directive and Guidebook with Current Efforts as Described by 

OCPO Officials

Review Original Oversight Program Current Oversight Efforts

On-site reviews On-site review—Triennial review of each component’s 

(a) compliance with acquisition regulations, (b) contract 

administration, (c) acquisition management, and (d) 

verification of procurement data. 

Two types of on-site reviews:

(1) On-site review—Review of each component’s (a) 

compliance with procurement regulations and policies, 

and (b) workforce issues. 

(2) Special review—Topic-specific reviews to address 

immediate concerns.

Operational status 

reviews

A quarterly meeting with each HCA to discuss the 

results of data submitted by components on a range of 

acquisition and performance-related metrics. 

Semi-annual meeting with each HCA to discuss 

procurement-related performance metrics from 

quarterly reports; number of metrics has increased.

Self-assessments HCA assesses component’s acquisition staff, 

processes, and programs using a questionnaire from 

the guidebook.

Same except use of questionnaire is not required.

Acquisition 

planning reviews

Three elements:

(1) Individual Acquisition Plans—Review of acquisition 

plans that exceed a contract value of $50 million for 

most components.a

 

Review and approval for procurements with a total 

lifecycle cost of at least $300 million for supplies and 

annual costs that exceed $100 million for services.

(2) Advanced Acquisition Planning database—

Information required for all acquisitions over $100,000. 

Acquisition Planning Forecast System—Information 

required for acquisitions that meet the simplified 

acquisition threshold.b 

(3) Acquisition Planning Review—HCAs assess the 

efficiency and effectiveness of their component’s 

acquisition planning process.

Not an element of oversight efforts.

Source: GAO analysis of DHS documents and interviews with OCPO and component officials.

a

The Chief Procurement Officer was to review acquisitions that exceeded $5 million for the Secret 

Service and Federal Law Enforcement Training Center.

b

The simplified acquisition threshold is $150,000 with some exceptions.

OCPO continues to conduct triennial on-site reviews and has streamlined 

the focus of the reviews from broad acquisition-related issues to 

compliance with contracting policies and regulations. OCPO conducted its 

initial round of reviews, called baseline reviews, from 2007 to 2010. The 

baseline reviews focused on a variety of acquisition-related topics, such 

as organizational leadership and financial accountability, and included a 

review of a stratified sample of contract files to assess compliance with 

regulations, policies, and procedures, including the Federal Acquisition 

Regulation (FAR), the Homeland Security Acquisition Manual (HSAM), 

and the Homeland Security Acquisition Regulation. OCPO began a 

second round of on-site reviews, called follow-on reviews, in 2010 and 

has completed these reviews for all but one of the components. OCPO 

has not yet conducted any on-site reviews for the Office of Selective 

On-site Reviews Are More 

Streamlined and 

Components Generally 

Have Been Responsive to 

the Recommendations
 

Page 8 GAO-12-947 Homeland Security

Acquisitions, which was created in 2008, but OCPO officials stated that 

they plan to do so in 2013 because the component now has sufficient 

contract activity to merit an on-site review. OCPO narrowed the scope of 

the second round reviews to focus on compliance with regulations, 

policies, and procedures. OCPO also assessed procurement workforce 

issues in both sets of the reviews.

OCPO has taken steps to encourage components to address on-site 

review recommendations. More specifically, prior to finalizing results of 

on-site reviews, OCPO first requires components to develop plans 

describing actions they will take to address the recommendations. OCPO 

then monitors components’ efforts by requiring them to submit 

documentation of the actions they took. For example, for the three on-site 

reviews OCPO conducted in 2011 that included recommendations, 

OCPO collected component documentation of actions taken in response 

to the 40 OCPO recommendations.7

Components generally have been responsive to OCPO’s on-site review 

recommendations. All components reported actions taken in response to 

all 89 recommendations from their most recent on-site reviews, which 

OCPO conducted between 2009 and 2012. The components provided 

descriptions of these actions, although a few of the actions were still 

underway. In most cases, components provided documentation that 

verified the actions they took. Table 2 below provides examples of 

OCPO’s on-site review findings, recommendations, and actions 

components took to address the recommendations.

 

7

OCPO also conducted a follow-on review of the Secret Service in 2011. The review did 

not include any findings or recommendations and determined the component significantly 

improved since its baseline review.
 

Page 9 GAO-12-947 Homeland Security

Table 2: Examples of OCPO On-Site Review Findings and Recommendations from Contract File Reviews and Actions 

Components Took to Address the Recommendations

OCPO Finding and Year OCPO Recommendation

Action Component Took to Address 

Recommendation

Insufficient documentation of legal 

reviews (2011).

Customs and Border Protection should 

emphasize to contracting personnel the 

HSAM requirements for legal reviews.

Issued a memorandum on August 12, 2011, 

and emphasized at its HCA’s all-hands 

meeting in June 2011 the importance of 

ensuring that legal reviews are conducted and 

including evidence in the contract file to 

demonstrate compliance.

Insufficient documentation of 

justification for using other than full 

and open competition (2008).

The Secret Service should issue a 

memorandum to contracting personnel 

emphasizing the importance of including an 

adequate justification in the files for using 

other than full and open competition as 

required by FAR 6.303-2.

Forwarded policy memorandum to contracting 

personnel to highlight the importance of 

competition and adequate justifications in files 

where other than full and open competition is 

utilized. Provided refresher training.

Insufficient documentation of small 

business reviews (2010). 

Immigration and Customs Enforcement 

should emphasize to contracting personnel 

the FAR and HSAM requirements to conduct 

small business reviews.

Communicated to contracting officers the 

circumstances under which the DHS small 

business review form is required and advised 

them that the form should be kept in the 

contract file. 

Source: GAO analysis of DHS documents, component officials’ responses, and component documentation.

OCPO also conducts another type of on-site review, called a “special 

review” or a “DHS-wide review,” to address issues and risk areas OCPO 

identifies in on-site reviews or that are identified by other sources, such 

as DHS’s inspector general or GAO reports. These reviews were not 

included in the original guidance. However, in 2007, OCPO started 

conducting these reviews to address special topics of concern and OCPO 

has completed 12 of these reviews since 2011. These reviews may focus 

on a specific topic at one component, such as a review of Customs and 

Border Protection’s credit card transactions to purchase fuel for its fleet of 

vehicles, or across multiple components, such as a review of the award of 

non-competitive contracts. When OCPO identifies weaknesses or gaps in 

the reviews, they typically issue memorandums to contracting staff. In 

addition, OCPO officials said that they sometimes provide training or 

share best practices with the components in response to review findings.

Since 2011, OCPO has more consistently developed quarterly reports to 

track components’ performance against established goals. Under the 

original program, operational status reviews were to include a quarterly 

meeting with each HCA to discuss reports based on data submitted by 

components on a range of acquisition and performance-related metrics. 

We found in 2008 that the quarterly meetings were not being held, 

Operational Status 

Reviews Are More 

Consistent 
 

Page 10 GAO-12-947 Homeland Security

indicating that the review process consisted primarily of preparing the 

quarterly reports. Furthermore, OCPO documentation showed that OCPO 

only completed one to two reports per year. Initially, the reports tracked 

up to 29 metrics, but for many metrics, data were lacking or DHS noted 

they were unreliable. In addition, the process was not automated or 

standardized. Under OCPO’s current oversight efforts, quarterly reports 

continue to be central to the operational status review process and, since 

2011, OCPO’s procurement oversight branch has developed a report 

each quarter. Furthermore, most aspects of the reports are now 

automated and standardized to focus on tracking about 40 metrics 

associated with contracting goals as reflected in OCPO’s fiscal year 2012 

strategic plan. The reports contain data from DHS’s Enterprise Reporting 

Application, which relies on data the components enter as well as 

contract data that it automatically pulls from the governmentwide Federal 

Procurement Data System—Next Generation (FPDS-NG) and 

components’ contract writing systems. In addition, OCPO’s acquisition 

systems branch officials stated that they perform data validation on a 

regular basis to help ensure the reliability of the FPDS-NG data the 

system uses.

OCPO’s current effort ties contracting goals from annual goal letters to 

the quarterly reports and includes semi-annual meetings with HCAs to 

discuss component performance against the goals. The Chief 

Procurement Officer provides annual goal letters to component HCAs, 

which include tailored quantitative targets that OCPO then tracks with 

metrics in its quarterly reports. In turn, the quarterly reports help inform 

the following year’s goal letters. Some officials explained that the goals 

help them determine what areas to focus on and that they in turn use the 

goals to motivate or assess performance within their contracting activities. 

In addition, the Chief Procurement Officer stated that he conducts semiannual meetings with each HCA to discuss the component’s goals, 

performance reflected in the quarterly reports, and the HCA’s plans to 

address areas that need improvement. To motivate performance toward 

the goals, component goals are reflected in HCAs’ performance plans 

and the Chief Procurement Officer stated that he provides input into the 

HCAs’ performance assessments based on the quarterly reports. Table 3 

includes examples of contracting-related goals established in goal letters 

and tracked with metrics in quarterly reports for the Transportation 

Security Administration (TSA). An excerpt from a quarterly report is 

included in appendix III.
 

Page 11 GAO-12-947 Homeland Security

Table 3: Examples of Contracting-Related Goals OCPO Established and Tracked 

with Metrics in 2011 and 2012, for TSA

Topic 2011 Goal

Tracked in 2011 

Quarterly Report 2012 Goal

Percent of obligated dollars awarded 

competitively 

≥74% Yes ≥76%

Percent of contracts awarded to small 

businesses

≥23% Yes ≥23%

Accuracy of Federal Procurement Data 

System—Next Generation Dataa 

≥92% Yes ≥93%

Source: GAO analysis of DHS documents.

a

For all elements subject to annual Office of Federal Procurement Policy certification.

OCPO officials stated that annual self assessments continue to be part of 

their oversight efforts. However, OCPO’s expectations regarding self 

assessments are unclear and some components did not complete a self 

assessment in 2011. Under the original program, component HCAs were 

required to complete annual self assessments, using a questionnaire that 

addressed a broad range of acquisition and procurement-related issues.

OCPO officials stated that, at first, they collected the self assessments, 

but they stopped doing so and instead asked components to inform 

OCPO of their completion because the officials thought collecting the 

assessments led the HCAs to be less forthcoming on the results. 

Currently, OCPO officials stated that they still expect components to 

conduct annual self assessments; however, they have not been requiring 

components to use the questionnaire. In addition, OCPO no longer 

checks with components to confirm they have completed the 

assessments. At least four components did not prepare a self 

assessment for fiscal year 2011 and we found that many components 

were not aware of this requirement. Among the components that did

prepare self assessments, two HCAs explained that some of the 

questions in the questionnaire address topics that are outside of their 

authority and one component has shifted responsibility for the 

assessment to its Chief Acquisition Officer because of the questionnaire’s 

focus on acquisition issues. OCPO officials stated that, moving forward, 

they plan to ensure components develop self assessments and that they 

plan to use the original questionnaire despite the shift in oversight focus 

to procurement.

Self Assessment 

Expectations Are Unclear
 

Page 12 GAO-12-947 Homeland Security

OCPO continues to have mechanisms in place to help ensure acquisition 

plans comply with applicable regulations, policies, and procedures, 

though some of these differ from the original acquisition oversight 

program established in 2005.

• Under the original program, the Chief Procurement Officer was 

required to review acquisition plans for contracts with an expected 

value of $50 million or more for most components to ensure that each 

complied with regulations and policies and to provide 

recommendations and guidance when necessary. Our prior work in 

2007 found that OCPO had little assurance that components 

addressed the review comments because the review was advisory.8

• As under the original program, HCAs are still required to provide data 

into an advanced acquisition planning database to publicize 

contracting opportunities and to assist components in managing 

schedules for planned acquisitions. However, we found in 2007 that 

OCPO had not established an effective mechanism to monitor the 

database to ensure complete information is entered into the 

database.

In 2009, DHS increased the dollar threshold of the plans that the Chief 

Procurement Officer is to review to those with life cycle costs of at 

least $300 million for products and annual costs that exceed $100 

million for services, which would include major acquisitions. Chief 

Procurement Officer approval is now required before these acquisition 

plans can move forward, which OCPO officials stated is a significant 

improvement from the original program.

9

• Under the original guidance, HCAs were required to annually review 

the efficiency and effectiveness of their acquisition planning process. 

OCPO officials stated that this aspect of the oversight was never 

implemented, but that they have taken some steps to examine 

acquisition planning across DHS. For example, in 2011 OCPO 

conducted a special review on acquisition plans that examined 

compliance of acquisition plans for DHS’s 11 procurements in 2009 

While OCPO has still not implemented a mechanism to 

monitor its database, OCPO officials stated that, as part of the on-site 

review process, they plan to examine whether required information 

has been entered into the database.

 

8

GAO-07-900. 

9

GAO-07-900. 

Acquisition Planning 

Reviews Have Evolved and 

Some Plans Require 

Approval 
 

Page 13 GAO-12-947 Homeland Security

with a value greater than $10 million but below the Chief Procurement 

Officer’s review and approval threshold. The review identified several 

problems, such as lack of appropriate signatures on some of the 

plans, which OCPO highlighted to HCAs in a memorandum. OCPO 

officials stated that, moving forward, as part of the on-site review 

process, they will examine acquisition plans associated with the 

contracts they review.

At the time of our review, DHS had not issued updated policy or guidance 

reflecting its current approach to procurement oversight and was still 

defining certain aspects of the program. As noted in the Standards for 

Internal Control in the Federal Government, agency policies should be 

clearly documented and readily available for examination to ensure 

effective program management.10

We found that the absence of an updated directive and guidebook led to 

a lack of clarity among the components regarding what the efforts entail

and reliance on less formal channels for advice. In addition to the general 

lack of awareness of the requirement for self assessments, we found that 

several component officials responsible for oversight were new to their 

The existing guidance on the oversight 

efforts at the time of our review was Management Directive 0784, 

“Acquisition Oversight Program” (2005) and the “Acquisition Oversight 

Program Guidebook” (2006). Management Directive 0784, which officially 

established the oversight program, described OCPO’s original approach 

to oversight and department and component officials’ roles in the 

program. The acquisition oversight guidebook provided instructions, 

checklists, and questionnaires to help guide execution of the program. 

According to OCPO officials, these documents were removed from DHS’s 

internal website since they no longer fully represented current efforts. 

Since 2007, OCPO developed multiple versions of the directive and 

guidebook though the department had not issued an update to either.

Furthermore, we found that OCPO had not fully determined the scope of 

some of the efforts. For example, at the beginning of our audit, OCPO 

officials informed us that they did not consider acquisition planning 

reviews to be part of their current oversight effort. However, much later in 

the audit, they stated that they plan to include acquisition planning as one 

aspect of the overall effort when they update the guidance.

 

10GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999). 

Procurement Oversight 

Policy and Guidance Are 

Not Sufficiently Updated
 

Page 14 GAO-12-947 Homeland Security

positions and some did not have extensive knowledge of the oversight 

efforts. In the absence of up-to-date written policy and guidance, 

components have relied on OCPO communications about upcoming 

reviews through e-mail and at monthly HCA meetings. Most component 

officials we spoke to indicated that OCPO’s communications regarding 

upcoming reviews and expectations of component involvement in the 

oversight efforts were helpful.

DHS has since updated its policy and guidebook to more closely reflect 

OCPO’s current oversight efforts, but we found inconsistencies in the 

revised documents. In our draft report, we recommended that the 

Secretary of Homeland Security direct the Chief Procurement Officer to 

issue updated policy and guidance to reflect changes to the department’s 

procurement oversight efforts. In commenting on a draft of this report, 

DHS informed us that to address the recommendation it updated its policy 

and guidebook to better mirror current procurement oversight 

practices. The Under Secretary for Management signed the new directive, 

DHS Directive Number 143-05 “Procurement Oversight Program” on 

August 28, 2012. DHS also reported that it had completed revisions to the 

newly named guidebook, “Procurement Oversight Program Guidebook,” 

MD 0143-05, on August 29, 2012. We reviewed the revised policy and 

guidebook and found inconsistencies between the two as well as with the 

program as described to us by DHS officials during the course of our 

review. For example, the directive stated that the program has three 

elements: HCA self assessment, operational status reports, and on-site 

component and special reviews. However, the guidebook includes four 

elements—the three above plus acquisition planning reviews. In another 

example, the guidebook states that the HCA should review the 

component’s acquisition planning process each year to ensure that the 

component plans all of its acquisitions. However, OCPO officials told us 

this part of the original program was never implemented and indicated it 

would be replaced with other acquisition planning oversight-related 

efforts. 
 

Page 15 GAO-12-947 Homeland Security

DHS component officials stated that most of their efforts to leverage 

buying power are through the department’s strategic sourcing program, 

which facilitates the development and award of contracts for the purchase 

of specific items or services across DHS. According to DHS data, DHS’s 

spending through strategic sourcing contract vehicles has increased 

steadily from $1.8 billion in fiscal year 2008, to almost $3 billion in fiscal 

year 2011, representing about 20 percent of DHS’s $14 billion in 

procurement spending for that year.11 The Office of Management and 

Budget’s Office of Federal Procurement Policy has cited DHS’s efforts 

among best practices for implementing federal strategic sourcing 

initiatives. DHS has implemented 42 strategic sourcing efforts, including 

indefinite-delivery indefinite-quantity contracts and blanket purchase 

agreements12

DHS policies encourage components to consider, but do not require, the 

use of departmentwide strategic sourcing contract vehicles. Usage of all 

departmentwide contracts is “mandatory for consideration” unless 

otherwise approved by the Under Secretary for Management, and 

therefore must be considered by DHS components prior to awarding a 

contract. Before pursuing their own procurements, components are to 

review the DHS-wide intranet site that lists available strategic sourcing 

for goods and services ranging from ammunition to 

engineering services. The department also has several new initiatives 

under development.

 

11We plan to issue a report in September 2012 examining DHS and other selected 

agencies’ strategic sourcing efforts, including those under the Federal Strategic Sourcing 

Initiative, and savings they have achieved.

12Indefinite-delivery indefinite-quantity contracts are contracts that are established to buy 

goods and services when the exact times and exact quantities of future deliveries are not 

known at the time of award. Blanket purchase agreements are agreements between 

agencies and vendors with terms in place for future use; funds are obligated when orders 

are placed.

Components Leverage 

Buying Power 

through DHS’s 

Strategic Sourcing 

Program 

Components Actively 

Support DHS’s Strategic 

Sourcing Program
 

Page 16 GAO-12-947 Homeland Security

contract vehicles. Some component officials said that their staff routinely 

check that list to determine whether one of those vehicles can be used 

before initiating a new procurement effort. Further, to encourage 

increased establishment of strategic sourcing contract vehicles, the 

HSAM requires the components to involve the strategic sourcing program 

office to determine if the requirement lends itself to the establishment of a 

departmentwide contract. If a DHS component makes a decision to 

implement its own contract instead of a departmentwide contract, it must 

document in the acquisition plan and contract file the rationale for doing 

so and notify the Chief Procurement Officer for review and approval. DHS 

is taking steps to strengthen the use of strategic sourcing at the 

department and has drafted, but not yet issued, a management directive 

that would make use of strategic sourcing contract vehicles mandatory 

with exceptions.

The Chief Procurement Officer has identified increasing strategic sourcing 

as a departmentwide priority and OCPO encourages the utilization and 

development of strategic sourcing vehicles in a variety of ways. OCPO 

officials explained that they host quarterly meetings and training sessions 

with the DHS Strategic Sourcing Working Group, meet with individual 

component programs and procurement offices, and post all contract 

information and ordering guides on the strategic sourcing web page. 

OCPO includes metrics in its quarterly reports to track components’ 

strategic sourcing contract vehicle utilization rates and savings, though it 

has not established component-specific goals or targets to further 

encourage use and development of strategic sourcing contract vehicles. 

OCPO officials told us that they consider their strategic sourcing program 

to be robust, and therefore do not currently think it would be worth the 

additional effort to develop and track component-specific goals. They said 

that if component participation were to decline, they might consider 

developing component-specific goals.

Component officials we met with cited a variety of benefits associated 

with using DHS’s strategic sourcing program. Most components we 

interviewed stated that they rely on department-level strategic sourcing 

policy and efforts rather than developing their own. Several officials 

explained that, once the contract vehicle is in place, it is much quicker to 

award contracts. Some components cited economies of scale and 

indicated that they thought prices had gone down in some areas.

In addition to using the vehicles, DHS components are involved with the 

program in a variety of ways. Component representatives serve on 

working groups to help identify potential strategic sourcing opportunities 
 

Page 17 GAO-12-947 Homeland Security

and develop shared requirements. Components are also tasked with 

serving as the lead for specific initiatives. For example, the Secret Service 

initiated a department-wide contract on tactical communications in 2012 

and Customs and Border Protection led a department effort to obtain 

canines in 2011.

Some components offered examples of contracts they leveraged with 

other agencies. For example, Customs and Border Protection leveraged a 

contract with the Department of Defense for air and marine assets in 

2008 and the Secret Service partnered with the Defense Information 

Systems Agency and White House Communications Agency in 2012 to 

obtain an event planning, scheduling and reporting system. In another 

example, the Coast Guard received price discounts for its HC-130J 

aircraft starting in 2000 by leveraging an Air Force vehicle rather than 

contracting directly with the manufacturer. However, most components 

found it more efficient to use DHS’s strategic sourcing vehicles than to 

leverage contracts with other agencies. Components described several 

challenges associated with leveraging contracts with other agencies, such 

as additional up front planning, identifying shared requirements, and 

paying associated fees to the lead agency.

Component officials indicated that they generally do not leverage 

contracts directly with other DHS components. Several component 

officials and the director of DHS’s strategic sourcing branch said that it is 

not an efficient use of time or resources for individual components to 

reach out directly to other components to identify shared requirements 

given the DHS-wide effort does this across components. The director also 

noted that if a component had an idea of a contract to leverage with 

another component, they should first share that example at a DHS-wide 

strategic sourcing forum in case any other components share that same 

requirement. However, if the components then determine only two 

components share that requirement, it would make sense for those two 

components to work together directly.

With its initial oversight efforts in 2005 and today’s more streamlined 

procurement oversight approach, OCPO has increased department-level 

insight into components’ procurement operations and recommended 

ways that components can take steps to improve their overall 

procurement operations. OCPO’s consistent and constructive on-site and 

operational status reviews also help ensure that components work 

towards common departmental procurement goals. However, we found 

Components Have 

Leveraged Contracts with 

Other Agencies

Conclusions 
 

Page 18 GAO-12-947 Homeland Security

that DHS had not updated its procurement oversight policy and guidance 

to reflect the increased focus on procurement and changes to the original 

oversight program. As a result, we found that component officials did not 

always know what was expected of them regarding the implementation of 

the procurement oversight efforts. DHS’s recent revision of its policy and 

guidebook is a step in the right direction, but inconsistencies in the 

documents as well as with the program as described to us by DHS 

officials could lead to further confusion, which would diminish the value of 

the program and opportunities for increased accountability for 

procurements. 

In order to help ensure that DHS component officials understand what 

OCPO expects of them in its procurement oversight, we recommend that 

the Secretary of Homeland Security direct the Chief Procurement Officer 

to review and ensure consistency between Directive 143-05 and the 

Procurement Oversight Program Guidebook and with the department’s 

current procurement oversight efforts. 

We provided a draft of this report to DHS for review and comment. The 

draft included a recommendation that DHS issue updated policy and 

guidance to reflect changes to the department’s procurement oversight 

efforts. In written comments, the department concurred with our findings 

and recommendation. The department’s comments are reprinted in 

Appendix II. DHS informed us that, to address the recommendation in our 

draft report, it updated its directive and guidebook to better mirror current 

procurement oversight practices and that it will make both documents 

available on DHS’s internal website. 

DHS’s revisions to the policy and guidance are a step in the right 

direction. However, we found inconsistencies between the updated 

directive and guidebook as well as with the program as described to us by 

DHS officials. As we noted when we made our draft recommendation, 

component officials do not always know what is expected of them 

regarding the implementation of the procurement oversight efforts, which 

diminishes the value of the program. Therefore, while we acknowledge 

DHS’s most recent efforts to update the directive and guidebook, we 

continue to believe that additional action is needed and have therefore 

revised our recommendation.

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 19 GAO-12-947 Homeland Security

We are sending copies of this report to the Secretary of Homeland 

Security. In addition, the report is also available at no charge on the GAO 

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

If you or your staff have any questions about this report or need additional 

information, please contact me at (202) 512-4841 or huttonj@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. Staff 

acknowledgments are provided in appendix IV.

John P. Hutton

Director

Acquisition and Sourcing Management
Appendix I: Scope and Methodology

Page 20 GAO-12-947 Homeland Security

The objectives of this review were to (1) assess the Department of 

Homeland Security’s (DHS) efforts to implement procurement oversight, 

and (2) identify DHS components’ use of strategic sourcing to leverage 

their buying power.

To assess DHS efforts to implement procurement oversight, we examined 

DHS’s procurement oversight policies and guidance; reviewed prior GAO 

reports on acquisition and procurement oversight; interviewed 

knowledgeable officials from the Office of the Chief Procurement Officer 

(OCPO) and from DHS components; and examined OCPO and 

component documentation of oversight efforts, including OCPO’s review 

schedule, quarterly reports, goal letters, operational status reports, and 

documentation of on-site reviews from 2007 to the present. Specifically, 

we interviewed the Chief Procurement Officer, the Director for Oversight 

and Strategic Support, officials from the four branches of the Oversight 

and Strategic Support Division, and senior officials, including four Heads 

of Contracting Activity (HCA), from the nine DHS contracting offices with 

HCAs to discuss the evolution of DHS’s oversight efforts. To evaluate the 

extent to which DHS components address the findings and 

recommendations identified in on-site reviews, we interviewed OCPO and 

component contracting officials, reviewed on-site review findings and 

recommendations, and analyzed components’ written responses 

regarding actions they took to address recommendations from their most 

recent reviews. For all eight contracting offices that OCPO reviewed,

1

To identify DHS components’ use of strategic sourcing to leverage their 

buying power, we reviewed relevant policies and guidance, examined 

department and component documentation and interviewed OCPO and 

component officials on practices they employ, contracts they have 

leveraged, and views on resulting benefits. Specifically, we interviewed 

officials from DHS’s strategic sourcing branch, as well as all nine 

contracting offices with HCAs, to gain an understanding of DHS’s 

strategic sourcing processes, the availability of strategic sourcing 

contracting vehicles, and the potential of establishing component specific 

strategic sourcing goals.

we 

examined the contracting offices’ descriptions of actions they took to 

address recommendations from their most recent on-site reviews and 

assessed their documentation of those actions.

 

1

OCPO did not conduct an on-site review for the Office of Selective Acquisitions.

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

Page 21 GAO-12-947 Homeland Security

We conducted our work from March 2012 to September 2012 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Homeland Security

Page 22 GAO-12-947 Homeland Security

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 23 GAO-12-947 Homeland Security
Appendix III: Snapshot from a 2012 DHS 

Component Quarterly Report

Page 24 GAO-12-947 Homeland Security

Appendix III: Snapshot from a 2012 DHS 

Component Quarterly Report
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 25 GAO-12-947 Homeland Security

John P. Hutton, (202) 512-4841 or huttonj@gao.gov

In addition to the contact named above, the following individuals made 

key contributions to this report: Katherine Trimble, Assistant Director; 

Laura Holliday, Andrea Bivens, Laura Greifner, and Sylvia Schatz.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(121040)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations 

Public Affairs

Please Print on Recycled Paper.