Page 1 GAO-12-185R DHS Realignment Efforts

United States Government Accountability Office 

Washington, DC 20548

September 28, 2012

The Honorable Joseph Lieberman

Chairman

The Honorable Susan Collins

Ranking Member

Committee on Homeland Security and

Governmental Affairs

United States Senate

The Honorable Candice S. Miller

Chairman

The Honorable Henry Cuellar

Ranking Member

Subcommittee on Border and

Maritime Security

Committee on Homeland Security

House of Representatives

Subject: Department of Homeland Security: Efforts to Assess Realignment of Its Field Office 

Structure

This letter formally transmits a summary of oral briefings we gave on September 19 and 21, 

2012 (see enc. 1), and subsequent agency comments. We provided this briefing in response 

to a request from you to examine issues surrounding the Department of Homeland 

Security’s (DHS) regional/field office realignment efforts. Our work focused on DHS 

realignment efforts beginning in 2004, when DHS submitted a report to Congress stating 

that it would implement a “Regional Concept” to improve coordination with external partners 

and integrate internal DHS functions within departmental regions. Specifically, we 

addressed

(1) the extent to which DHS has assessed the realignment of its key operational 

components’ regional/field office structures since submitting its initial plan to 

Congress in 2004,

1

(2) the challenges, if any, DHS and its key operational components have identified in 

the department’s efforts to realign into a single DHS regional/field office structure, 

and what, if any, alternative actions have been identified.

and

 

1

DHS officials identified the following as the key DHS operational components: Transportation Security 

Administration, U.S. Customs and Border Protection, U.S. Citizenship and Immigration Services, U.S. 

Immigration and Customs Enforcement, U.S. Secret Service, Federal Emergency Management Agency, and the 

U.S. Coast Guard.
Page 2 GAO-12-185R DHS Realignment Efforts

Scope and Methodology

To address the first objective, we analyzed available reports and other documentation 

related to DHS’s efforts to realign the regional/field office structure of its key operational 

components since 2004. These efforts included DHS’s 2004 Operational Integration Staff (I–

Staff) effort, which focused on planning a DHS regional structure, and a recommendation 

from the 2010 DHS Bottom-Up Review (BUR) Report to realign component regional 

configurations into a single DHS regional structure.2

To address the second objective, we interviewed and corresponded with cognizant DHS 

headquarters and component officials to obtain their perspectives on the challenges or 

drawbacks of regionalization in relation to the potential benefits. In these interviews and 

correspondences, we also discussed alternatives to regionalization (such as colocation, 

consolidation, or integration) that could better integrate component operations in the 

region/field and achieve cost savings and efficiencies. We will initiate a follow-on effort to 

examine the operational impacts of select smaller-scale alternatives (e.g., colocation, 

consolidation, and integration) in more detail.

We selected this period for review 

because in 2004 DHS submitted a report to Congress stating that the department would 

implement a “Regional Concept” and study other consolidation and colocation opportunities.

We also interviewed and corresponded with cognizant DHS headquarters and operational 

component officials about past regionalization assessments, the current status of any 

regionalization efforts, and any related potential future studies—including the extent to 

which, if at all, any regionalization initiatives/recommendations were implemented, and the 

basis for those decisions. Given the passage of time since the I-Staff effort, we also 

interviewed a former department official who managed this effort.

We conducted this performance audit from February 2012 through 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.

Summary

DHS reported taking some steps to assess the realignment of its regional/field office 

structure. Since submitting an initial plan to Congress in 2004 that outlined regionalization, 

consolidation, and colocation opportunities, DHS officials said the agency considered the 

potential implementation of a unified regional field office structure through two major 

initiatives—the 2004 I-Staff review and the department’s 2010 BUR. However, the I-Staff 

Regional Concept of Operations was not finalized or adopted, and in April 2012 a senior 

DHS official involved in the BUR effort stated that DHS no longer intends to implement the 

BUR recommendation related to regionalization because it is no longer the department’s 

preferred approach. DHS had limited or no documentation related to either of these reviews, 

including the resulting key decisions from the efforts. As a result, we are unable to 

 

2

The BUR report identified 43 initiatives/recommendations, such as strengthening aviation security and enhancing 

the department’s risk management capability, to strengthen DHS’s mission performance, improve departmental 

management, and increase accountability. I-Staff personnel were responsible for assisting the Department 

Leadership Team in the coordination and integration of cross-organizational operational missions, activities, and 

programs at the DHS headquarters level.
Page 3 GAO-12-185R DHS Realignment Efforts

determine the extent to which DHS has fully considered the realignment of its regional/field 

office structure, including costs and benefits, since 2004. Standards for Internal Control in 

the Federal Government calls for clear documentation of significant events, which include 

assumptions and methods surrounding key decisions, and the standards also state that this 

documentation should be readily available for examination.3

DHS and component officials stated that operational and current budgetary constraints were 

key challenges to establishing a single DHS regional/field office structure, but they are 

exploring smaller-scale alternatives. DHS and component officials identified several 

challenges related to large-scale regionalization, including concerns that the initiative would 

be disruptive to DHS and component workforce, missions, and operations. DHS officials 

also said that such realignment efforts would likely divert staff from their normal missionfocused duties. Another challenge cited was the cost associated with relocating facilities and 

terminating leases. While officials acknowledged that long-term cost savings and efficiencies 

could exceed the costs of initial investments in some cases, they stated that the short-term 

implementation costs remain a significant barrier to the implementation of a regional 

structure. Given the identified challenges of implementing a single, unified field office 

structure, DHS officials said the department’s current thinking on harmonizing component 

regional configurations is best reflected in the Department of Homeland Security Strategic 

Plan: Fiscal Years 2012–2016.

DHS officials acknowledged the 

lack of documentation and plan to better document any future realignment efforts.

4

Agency Comments

Specifically, the department plans to “explore virtual 

approaches to regional and functional coordination.” However, without having adequate, 

specific documentation related to its regionalization assessments, decision makers at DHS 

are in a weaker position to assess the strengths and weaknesses of related policy options or 

alternatives.

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

comments from DHS, which are reproduced in enclosure II.

In commenting on this report, the department agreed with our findings and acknowledged 

that its efforts to assess regionalization, colocation, consolidation, and operational 

integration options could have been better documented. In addition, DHS stated that its 

leadership is committed to better documenting any future examinations of regional/field 

office realignment, as appropriate.

Although DHS stated in its agency comments letter that it appreciated GAO’s 

acknowledgement that short-term implementation costs remain a significant barrier to 

establishing a regional structure, it is important to note that we did not independently assess 

any such costs. High implementation costs were identified to us by DHS and component 

officials as one of several challenges to creating a regional structure. As noted throughout 

the briefing, however, the department lacked documentation that would have allowed us to 

evaluate its current position that the costs of developing a regional structure outweigh the 

 

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: 

November 1999).

4

DHS, Department of Homeland Security Strategic Plan: Fiscal Years 2012-2016 (Washington, D.C.: February 

2012).
Page 4 GAO-12-185R DHS Realignment Efforts

benefits. Additionally, we received technical comments from DHS, which were incorporated 

where appropriate.

We are sending copies of this report to the appropriate congressional committees, the 

Secretary of Homeland Security, and other interested parties. This report is also available at 

no charge on our website at http://www.gao.gov. Should you or your staffs have any 

questions concerning this report, please contact me at (202) 512-9610 or 

caldwells@gao.gov. Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. Key contributors to this report were 

Dawn Hoff, Assistant Director; Charles Bausell; Tracey King; David Lutter; Frederick Lyles, 

Jr.; Jessica Orr; and Cynthia Saunders.

Stephen L. Caldwell

Director

Homeland Security and Justice

Enclosures (2)
Page 5 GAO-12-185R DHS Realignment Efforts

Enclosure I: Briefing for Congressional Committees

Page 1

Department of Homeland Security: Efforts to 

Assess Realignment of Its Field Office Structure

Prepared for the 

Senate Committee on Homeland Security and 

Governmental Affairs and the House Subcommittee on 

Border and Maritime Security, House Committee on 

Homeland Security

For more information, contact Stephen Caldwell, at (202) 512-9610 or caldwells@gao.gov.
Page 6 GAO-12-185R DHS Realignment Efforts

Page 2

Contents

• Introduction

• Objectives

• Scope and Methodology

• Results in Brief

• Background

• Findings

• Appendix I
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Page 3

Introduction

• DHS was created from 22 separate legacy agencies, and is currently the third largest 

federal department. DHS inherited the legacy regional/field office structures of many of its 

components. According to DHS officials, the department’s seven key operational 

components—each with a unique set of geographic regions and system of field offices that 

allow components to carry out their missions and deliver services across the country—are 

the 

(1) Transportation Security Administration (TSA), 

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

(3) U.S. Citizenship and Immigration Services (USCIS), 

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

(5) U.S. Secret Service (USSS), 

(6) Federal Emergency Management Agency (FEMA), and the 

(7) U.S. Coast Guard (USCG).1

• See appendix 1 for DHS’s organizational structure as of August 2012. 

1TSA protects the nation’s transportation systems to ensure freedom of movement for people and commerce. CBP protects the nation’s borders to prevent terrorists and terrorist weapons 

from entering the United States. while facilitating the flow of legitimate trade and travel. USCIS processes millions of applications and petitions for immigrant and nonimmigrant-related 

benefits for persons seeking to study, work, visit, or live in the United States. ICE, the largest investigative arm of DHS, identifies and mitigates vulnerabilities in the nation’s border, 

economic, transportation, and infrastructure security. USSS protects the President and other high-level officials and investigates counterfeiting and other financial crimes and computer-based 

attacks on the nation’s financial, banking, and telecommunications infrastructure. FEMA prepares the nation for hazards, manages federal response and recovery efforts following any 

national incident, and administers the National Flood Insurance Program. USCG protects the public, the environment, and U.S. economic interests in the nation’s ports and waterways, along 

the coast, on international waters, and in any maritime region as required to support national security. 
Page 8 GAO-12-185R DHS Realignment Efforts

Page 4

Introduction (cont.)

• The Homeland Security Act of 2002 required DHS to submit a plan to Congress for 

consolidating or colocating certain components’ regional or field offices, among other 

things.2

• In response to this requirement, in 2004 DHS submitted a seven page document to 

Congress that presented the department’s actions and its proposed high-level approach to 

developing a consolidation and colocation plan. This report also stated the department 

would implement a “Regional Concept” to establish DHS regional directors in specific 

geographic areas to better integrate components, reduce unnecessary duplication, and 

improve coordination with external partners. 

2Pub. L. No. 107-296, § 706, 116 Stat. 2135, 2220 (2002). 
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Page 5

Introduction (cont.)

• When discussing the department’s realignment efforts, DHS officials defined and used the 

following terms: 

1. Regionalization refers to full-scale realignment of DHS’s regional/field office structure, 

which includes the establishment of a single, commonly defined set of regions for all 

components. 

2. Colocation refers to the sharing of space, buildings, property, or other physical assets 

by components. 

3. Consolidation refers to the merging of organizational functions.

4. Integration refers to the coordination of functions across components without 

consolidation or merger. 

• Given the magnitude and breadth of DHS’s operations and assets, potential changes to 

DHS’s regional/field office structure and also its physical footprint can have profound 

budgetary impacts—both costs and savings—as well as impacts on how the department 

carries out its homeland security missions. 
Page 10 GAO-12-185R DHS Realignment Efforts

Page 6

Objectives

• This briefing addresses the following questions: 

o To what extent has DHS assessed the realignment of the regional/field office structure 

of its key operational components since submitting its initial consolidation and 

colocation plan to Congress in 2004?3

o What challenges, if any, have DHS and its key operational components identified in 

DHS’s efforts to realign into a single DHS regional/field office structure, and what, if 

any, alternative actions have been identified?

3DHS officials identified the following as the key DHS operational components: TSA, CBP, USCIS, ICE, USSS, FEMA, and USCG.
Page 11 GAO-12-185R DHS Realignment Efforts

Page 7

Scope and Methodology

• To address the first objective, we analyzed available reports and other documentation on 

DHS’s efforts to realign its regional/field office structure since 2004. This included DHS’s 

2004 Operational Integration Staff (I–Staff) effort, which focused on establishing a single 

DHS regional structure, and the 2010 DHS Bottom-Up Review (BUR) Report 

recommendation to realign component regional configurations into a single DHS 

regional structure.4 We selected this time frame because in 2004, in response to a 

legislative requirement, DHS submitted a report to Congress on office consolidation and 

colocation. We interviewed and corresponded with cognizant DHS headquarters and 

component officials about past regionalization assessments, the current status of any 

related efforts, and potential future studies—including the extent to which, if at all, any 

regionalization initiatives were implemented, and the basis for those decisions. Given the 

passage of time since the I-Staff effort, we also interviewed a former department official 

who managed that effort.

4The BUR report identified priority initiatives, such as strengthening aviation security and enhancing the department’s risk management capability, to strengthen DHS’s mission 

performance, improve departmental management, and increase accountability. I-Staff personnel were responsible for assisting the Department Leadership Team in the 

coordination and integration of cross-organizational operational missions, activities, and programs at the DHS headquarters level. 
Page 12 GAO-12-185R DHS Realignment Efforts

Page 8

Scope and Methodology (cont.)

• To address the second objective, we interviewed and corresponded with cognizant DHS 

headquarters and component officials to obtain their perspectives on regionalization 

challenges in relation to potential benefits. We also obtained DHS headquarters and 

component officials’ views regarding alternatives to regionalization (such as colocation, 

consolidation, or integration) that could better integrate component operations in the 

region/field and achieve cost savings and efficiencies.

• We will initiate a follow-on effort to examine the operational impacts of select smaller-scale 

alternatives to regionalization (e.g., colocation, consolidation, and integration) in more 

detail.

• We conducted this performance audit from February 2012 through 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.
Page 13 GAO-12-185R DHS Realignment Efforts

Page 9

Results in Brief

DHS Regionalization Efforts

• DHS reported taking some steps to assess the realignment of its regional/field office 

structure. Since submitting an initial plan to Congress in 2004, DHS officials said the 

department considered the potential implementation of a unified regional field office 

structure through two major initiatives—the 2004 I-Staff effort and the department’s 2010 

BUR. However, the I-Staff Regional Concept of Operations was not finalized or adopted, 

and a senior DHS official involved with the creation of the BUR stated in April 2012 that DHS 

no longer intends to implement the BUR recommendation related to regionalization because 

it is not the department’s preferred approach. 

• DHS had limited documentation related to these reviews, including the resulting key 

decisions from the efforts. As a result, we are unable to determine the extent to which DHS 

has fully considered the realignment of its regional/field office structure, including costs and 

benefits, since 2004. Standards for Internal Control in the Federal Government calls for 

clear documentation of significant events, which include assumptions and methods 

surrounding key decisions, and the standards also state that this documentation should be 

readily available for examination.5 DHS officials acknowledged the lack of documentation 

and plan to better document any future regionalization efforts.

5GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
Page 14 GAO-12-185R DHS Realignment Efforts

Page 10

Results in Brief (cont.)

DHS Identified Challenges to Regionalization

• DHS headquarters and component officials identified operational and current budgetary 

constraints as key challenges to implementing a single DHS regional/field office 

structure, but said they are exploring smaller-scale alternatives. According to these 

officials, regionalization challenges include the following: 

o DHS components each have a different regional or field office structure based on 

unique mission needs.

o Disruptions to DHS and component workforce, missions, and operations. Such a 

move would likely divert staff from their normal mission-focused duties. 

o Costs associated with relocating facilities and terminating leases. 

o Statutory provisions affecting DHS’s authority to reorganize.
Page 15 GAO-12-185R DHS Realignment Efforts

Page 11

Results in Brief (cont.)

DHS Identified Challenges to Regionalization

• Given the challenges identified with implementing a single, unified field office structure, a 

senior DHS official said the department’s current thinking on harmonizing component 

regional configurations is best reflected in the Department of Homeland Security Strategic 

Plan: Fiscal Years 2012–2016.6

o Specifically, the department plans to “explore virtual approaches to regional and 

functional coordination,” which according to the strategic plan includes using models 

established in the interagency counternarcotics infrastructure. 

• However, as previously noted, without having adequate documentation related to its 

regionalization assessments, decision makers at DHS have incomplete information to 

evaluate related policy options or alternatives. 

6DHS, Department of Homeland Security Strategic Plan: Fiscal Years 2012-2016 (Washington, D.C.: February 2012).
Page 16 GAO-12-185R DHS Realignment Efforts

Page 12

Results in Brief (cont.)

DHS Identified Alternatives to Regionalization 

• DHS and some components have studied alternatives to regionalization to improve the 

effectiveness and efficiency of their regional/field office operations through smaller-scale 

efforts such as colocation, consolidation, and integration. However, without adequate 

documentation on its regionalization assessments, DHS decision makers have limited 

information about the relative costs and benefits of regionalization versus these 

alternatives. 

• If DHS decides to revisit regionalization options in the future, it could improve the 

analytical foundation of its decisions through better documentation, including the basis for 

those decisions. Better documentation of regionalization options would also help DHS 

decision makers evaluate regionalization challenges and weigh the relative costs and 

benefits of alternatives, including smaller-scale alternatives, such as colocation, 

consolidation, and integration. In commenting on a draft of this briefing, DHS has agreed 

to better document any future examinations of regional/field office realignment, as 

appropriate. 
Page 17 GAO-12-185R DHS Realignment Efforts

Page 13

Background 

• The Homeland Security Act of 2002 established DHS—combining 22 federal agencies 

specializing in various disciplines (such as law enforcement, border security, biological 

research, computer security, and disaster mitigation)—eventually resulting in seven major 

operational components with real property.7 When the legacy agencies were combined 

under DHS, they each brought with them their own field office structures and locations. 

• The seven key DHS operational components—TSA, CBP, USCIS, ICE, USSS, FEMA, and 

USCG—each have their own unique regional structures and systems of field offices. For 

example: 

o Under FEMA’s structure, North Carolina is grouped with Southeastern states under a 

FEMA regional office in Atlanta, GA, while under USCG’s structure, North Carolina is 

grouped with Mid-Atlantic states under a USCG district office in Portsmouth, VA. 

o Multiple components may maintain field offices in the same geographic location. 

Seattle, for example, is the site of a major district/regional/field office for USCG, 

FEMA, and CBP, respectively. 

7Pub. L. No. 107-296, 116 Stat. 2135 (2002).
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Page 14

Background (cont.)

• The inefficiences associated with each operational component having a different area of 

responsibility prompted some in DHS to promote the idea of a single, unified DHS 

regional/field office structure, sometimes referred to as regionalization. 

o This concept would include a common set of boundaries for components’ regional 

operations, and the establishment of a DHS regional office within each of those 

regions headed by a regional director. 

o Proponents believe that this system of DHS regional offices could better integrate the 

operations of multiple components, making DHS as a whole more responsive and 

better prepared to counter man-made or natural threats. Proponents also see 

opportunities for cost savings through the sharing of assets, including office space.

• Within the separate regional/field office structures that currently exist, DHS manages a 

portfolio of real property assets utilized by its multiple components. DHS reported that in 

fiscal year 2011, DHS managed a global real property portfolio of approximately 38,000 

assets, spanning all 50 states and 7 U.S. territories. These assets included approximately 

16,000 buildings, 19,000 structures (e.g., docks, airfields, and communication systems), and 

3,000 land assets. 
Page 19 GAO-12-185R DHS Realignment Efforts

Page 15

Background (cont.)

• In addition to broad efforts to realign the regional/field office structure, DHS and its 

components have focused more narrowly on individual assets and specific operations, 

including opportunities for colocation, consolidation, and integration. 

• In 2010, as part of a governmentwide effort to dispose of unneeded federal real estate 

and cut operating costs,8 DHS implemented its FY 2011 Cost Savings and Innovation 

Plan. Among other things, the plan includes proposals to consolidate certain assets.

8Presidential Memorandum: Disposing of Unneeded Federal Real Estate–Increasing Sales Proceeds, Cutting Costs, and Improving Energy Efficiency, June 10, 2010. 
Page 20 GAO-12-185R DHS Realignment Efforts

Page 16

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure 

• Since first reporting to Congress on this issue in 2004, DHS officials said that the 

department considered the potential implementation of a unified regional/field office 

structure through two major initiatives—the department’s I-Staff review in 2004, and the 

BUR process in 2010.9 Table 1 on the next slide provides a summary of these efforts and 

illustrates how at two different times—in 2004 and 2010—the department concluded that 

regionalization was a worthwhile endeavor, but then was not able to follow through with 

implementation for a variety of reasons.

• Congress did not appropriate funds to implement the I-Staff’s Regional Concept in fiscal 

year 2006, and committee reports accompanying the appropriations act note a lack of 

specific planning by DHS.10

9Another significant DHS-wide structural review was the 2006 Second Stage Review, but this review did not explicitly examine field office regionalization.

10S. Rep. No. 109-083, at 11 (2005); H.R. Rep. No. 109-079, at 7 (2005).
Page 21 GAO-12-185R DHS Realignment Efforts

Page 17

Objective 1

Table 1: Major DHS Assessments of Regionalization since 

2004 

Assessment efforts Description Conclusion or recommendation Implementation status

Draft DHS Regional 

Concept of Operations, 

2004 

The I-Staff was tasked with the development and 

implementation of a Regional Concept of 

Operations for a unified DHS regional/field office 

structure.

The draft 2004 Regional Concept of 

Operations called for the 

establishment of common regions, 

each with a regional headquarters 

led by a regional director. DHS 

requested about $50 million in its 

fiscal year 2006 budget request to 

implement the Regional Concept. 

Not implemented—Congress did not 

appropriate funds to implement the 

Regional Concept in fiscal year 2006, 

and committee reports 

accompanying the appropriations act 

noted a lack of specific planning by 

DHS. In addition, DHS was not able 

to provide GAO with documentation 

to further justify this budget request 

or explain why the Regional Concept 

was not finalized or implemented. 

Bottom-Up Review Report, 

2010a

The BUR included an assessment of the 

organizational alignment of the department with 

homeland security missions set forth in the 

Quadrennial Homeland Security Review Report 

(QHSR), including the department’s organizational 

structure.b

The BUR contained a 

recommendation for DHS to realign 

its component regional 

configurations into a single DHS 

regional structure.

Not implemented—DHS officials said 

there was no documentation to 

support why the BUR realignment 

recommendation was included in the 

BUR, or documentation to support 

why it is no longer being pursued. 

Source: GAO analysis of documents provided by DHS.

aDHS, Bottom-Up Review Report, Washington, D.C., July 2010.

bThe BUR Report contains 43 recommendations. The Implementing Recommendations of the 9/11 Commission Act of 2007 required DHS to provide a comprehensive 

examination of the U.S. homeland security strategy every 4 years. 6 U.S.C. § 347. In response, DHS issued its first QHSR report in February 2010 and a BUR report in 

July 2010, to identify initiatives to implement the QHSR.
Page 22 GAO-12-185R DHS Realignment Efforts

Page 18

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

I-Staff Effort

• In 2004, the I-Staff was established to assist DHS leadership to coordinate and integrate 

department missions and operational activities, including the development and 

implementation of a single, unified DHS regional/field office structure. According to senior 

DHS officials, the goal of this structure was to increase national homeland security 

functions through greater coordination and integration—not just among DHS headquarters 

and components—but also among other federal, state, local, tribal, international, and 

private stakeholders. 

• To this end, in 2004 the I-Staff developed a draft Regional Concept of Operations, which 

included regionalization pilot exercises, and a phased implementation timeline for eight 

regional locations. The draft Regional Concept of Operations also included a detailed 

description of regional concept legal authorities, mission, and staff structure. The draft 

Regional Concept of Operations delineated roles and responsibilities for DHS 

headquarters and regional offices in seven key areas: 

o (1) Communication and coordination; (2) planning and analysis; (3) situational 

awareness; (4) integration; (5) preparedness, training, and exercises; (6) routine 

operations; and (7) contingency operations. 
Page 23 GAO-12-185R DHS Realignment Efforts

Page 19

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

I-Staff Effort

• The draft plan outlined the roles of DHS regional directors and identified their particular 

authorities and relationships with DHS headquarters and component officials. The 

Regional Concept of Operations contained an implementation timeline to establish the 

DHS regions over a period of approximately 2 years. In 2005, then-secretary Thomas 

Ridge publicaly praised the Regional Concept of Operations as the next logical step to 

support an integrated, unified national effort to secure the United States. 

• However, the I-Staff Regional Concept of Operations was not finalized or adopted. DHS 

requested about $50 million in its fiscal year 2006 budget submission to support the 

establishment of a unified regional structure, stating that the department anticipated that 

regionalization would improve program delivery and effectiveness, as well as achieve 

efficiencies through such things as the integration and consolidation of information 

technology, facilities, and operations centers. Congress did not appropriate funds for this 

purpose, however, and committee reports accompanying the appropriations act state that 

the committees did not yet have enough information about DHS’s plan. DHS did not 

provide us with any additional documentation that may have further justified this request 

for an appropriation. 
Page 24 GAO-12-185R DHS Realignment Efforts

Page 20

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

BUR Recommendation

• The BUR was initiated in November 2009 as an immediate follow-on and complement to 

the DHS QHSR.11 Secretary Janet Napolitano noted that “the BUR provides the results of 

an unprecedented Department-wide assessment of DHS” to align its programs and 

organizational structure with the mission sets and goals contained in the QHSR. To help 

achieve this, the BUR contains 43 specific initiatives to be implemented over several years. 

• One BUR recommendation is for the department to “realign component regional 

configurations into a single DHS regional structure.” Specifically, the recommendation 

states: 

“To streamline operations nationally, increase efficiencies, and enhance crosstraining and rotational assignments, DHS will align the seven separate regional 

structures currently in use . . . to a single nation-wide regional structure.” 

• Despite the publication of this recommendation in the July 2010 BUR report, in April 2012 

a senior DHS official involved with the creation of the BUR stated that DHS has no plan to 

implement this recommendation because the department and its components no longer 

view regionalization as their preferred approach. 11In February 2010, DHS issued its first QHSR, outlining a strategic framework for homeland security to guide the activities of homeland security 

partners, including federal, state, local, and tribal government agencies; the private sector; and nongovernmental organizations. 
Page 25 GAO-12-185R DHS Realignment Efforts

Page 21

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

• Both the I-Staff effort and the BUR recommendation that directly focused on potential DHS 

actions to create a unified regional/field office structure have limited or incomplete 

analytical assessments to assist decision makers, or limited documentation to help explain 

or justify the decisions that DHS leadership ultimately made. Although DHS and other 

knowledgeable officials reported that significant effort and resources were invested in 

these reviews, DHS was not able to provide substantial documentation or analyses of their 

results, including evaluations of costs and benefits.

o According to DHS officials, the analysis underlying the I–Staff draft Regional Concept 

of Operations was fairly robust. However, the I-Staff’s draft Regional Concept of 

Operations document provided to us was incomplete—it contained placeholders for 

future analyses and component input, and actions that were never conducted, 

according to a senior DHS official. 

o For the BUR, DHS could not provide any documentation or analyses to demonstrate: 

(1) how the BUR regional/field office initiative was initially developed and why it was 

included in the BUR report, and (2) how the decision was made subsequently to not 

implement the initiative. 
Page 26 GAO-12-185R DHS Realignment Efforts

Page 22

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

o According to a senior DHS official, most of the deliberations about the BUR 

realignment recommendation were conducted orally and not documented. As a 

result, we are unable to determine the extent to which DHS has fully assessed the 

realignment of its regional/field office since 2004. 

o In addition, the department has been unable to provide us with documentation 

underlying the key decisions resulting from both the I-Staff and BUR efforts, 

especially regarding the change in policy from supporting DHS regional/field offices 

in 2004 and 2010 to no longer supporting this concept.

• Standards for Internal Control in the Federal Government calls for clear documentation of 

significant events, which includes assumptions and methods surrounding key decisions, 

and the standards also state that this documentation should be readily available for 

examination. All documentation and records should be properly managed and 

maintained.12

12GAO/AIMD-00-21.3.1.
Page 27 GAO-12-185R DHS Realignment Efforts

Page 23

Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field 

Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

• DHS leadership ultimately decided that the costs and other challenges to develop and 

implement a unified regional field office structure outweighed the potential benefits. Since 

then a senior DHS official authorized to speak about departmental policy stated that the 

department has no plans to study regionalization options in the future. 

• In discussing the lack of documentation with DHS officials, they acknowledged that the 

documentation of earlier analyses, and the retention of such documentation, should have 

been better. They also stated that if the department undertakes another effort to study 

the costs and benefits of a unified regional structure, it will document any analyses and 

decisions in accordance with internal control standards and maintain such information in 

accordance with applicable DHS document retention policies—such as the Executive 

Level Records Schedule and the National Archives and Records Administration General 

Records Schedule. The department repeated this intention in its official response to our 

report.
Page 28 GAO-12-185R DHS Realignment Efforts

Page 24

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives 

DHS Identified Challenges

• Officials from DHS headquarters and key operational components commented on 

challenges to implementing a single DHS regional/field office structure. Identified 

challenges included 

o variation in the geographic basis for operational component missions,

o potential disruption and negative impacts on components’ operations, 

o potential large up-front costs of creating a single DHS regional office structure, and

o statutory provisions affecting DHS’s authority to reorganize. 

• Given these types of challenges, officials stated that DHS and its components are 

exploring alternatives to regionalization, such as colocation, consolidation, and 

integration. 
Page 29 GAO-12-185R DHS Realignment Efforts

Page 25

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Challenges

• DHS components each have a different regional or field office structure based on 

unique mission needs. For example, FEMA’s 10 “regions” do not correspond to the 

USCG’s 9 “districts,” which do not correspond to CBP’s 20 Border Patrol “sectors.” 

Officials said that there were mission-based reasons for each of the components having 

different regional structures:

o According to DHS officials, it would be a challenge to establish criteria and determine 

a single set of regional office locations and geographic boundaries across all 

components. For example, a regional footprint that may make sense for CBP along 

the border may not be well suited to FEMA’s mission. 
Page 30 GAO-12-185R DHS Realignment Efforts

Page 26

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.) 

DHS Identified Challenges

• Potentially Disruptive to DHS and Component Workforce, Missions, and Operations

o DHS officials stated that a large-scale realignment effort would likely divert staff from 

their normal mission-focused duties.

o DHS officials also said that chain of command issues were a challenge to creating 

DHS regional offices that house multiple components. According to senior DHS 

officials, from the components’ viewpoint, they have certain authorities and mission 

obligations for which they are held accountable. Senior DHS officials stated that 

component heads largely objected, therefore, to a structure that would turn over any 

component authority to regional DHS officials. 
Page 31 GAO-12-185R DHS Realignment Efforts 

Page 27

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.) 

DHS Identified Challenges

• Potentially Disruptive to DHS and Component Workforce, Missions, and Operations 

(cont.) 

o Some component officials also commented that field office realignment could 

negatively affect their relationships with stakeholders. For example, FEMA officials 

said that state and local governments, along with private sector entities, “knew who to 

call” at FEMA, and that coordination between FEMA regions and stakeholders was 

generally good. FEMA officials said that adding another federal layer (e.g., a DHS 

regional office official) could complicate FEMA’s relationships with locals. 

o Moving to a unified field office structure would also likely require operational sacrifices 

by some of the components. For example, different components have different publicfacing “personas.” From a public relations perspective, it may not make sense to 

colocate USCIS’s customer service-oriented functions with ICE’s investigative 

functions, according to DHS officials.
Page 32 GAO-12-185R DHS Realignment Efforts

Page 27

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.) 

DHS Identified Challenges

• Potentially Disruptive to DHS and Component Workforce, Missions, and Operations 

(cont.) 

o Some component officials also commented that field office realignment could 

negatively affect their relationships with stakeholders. For example, FEMA officials 

said that state and local governments, along with private sector entities, “knew who to 

call” at FEMA, and that coordination between FEMA regions and stakeholders was 

generally good. FEMA officials said that adding another federal layer (e.g., a DHS 

regional office official) could complicate FEMA’s relationships with locals. 

o Moving to a unified field office structure would also likely require operational sacrifices 

by some of the components. For example, different components have different publicfacing “personas.” From a public relations perspective, it may not make sense to 

colocate USCIS’s customer service-oriented functions with ICE’s investigative 

functions, according to DHS officials.

Page 28

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Challenges

• Budgetary, Management, and Data Constraints Associated with Relocating 

Facilities

o DHS officials cited challenges due to the constrained budget environment, and the 

logistical issues involved with DHS components receiving appropriations through 

several separate funding streams. 

o DHS and component officials also cited costs associated with relocating facilities and 

terminating leases. While officials acknowledged that large long-term cost avoidance 

may be achieved through streamlining and reducing real estate, they said 

implementation and maintenance costs of a regional structure could be significant. 

o DHS officials stated and our prior work has found that DHS real property data are 

unreliable and inconsistent across components.13 Although efforts are under way to 

improve data, it remains difficult for planners to identify opportunities for office 

realignment. 13We have identified real property management across the federal government as a high-risk area. Many of the challenges highlighted in this work are applicable to 

DHS’s portfolio management. See for example, GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011). Also see GAO, Federal Real Property: 

DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges, GAO-07-658 (Washington, D.C.: June 

22, 2007). 
Page 33 GAO-12-185R DHS Realignment Efforts

Page 28

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Challenges

• Budgetary, management, and data constraints associated with relocating facilities.

o DHS officials cited challenges due to the constrained budget environment, and the 

logistical issues involved with DHS components receiving appropriations through 

several separate funding streams. 

o Costs associated with relocating facilities and terminating leases. While officials 

acknowledged that large long-term cost avoidance may be achieved through 

streamlining and reducing real estate, they said implementation and maintenance 

costs of a regional structure could be significant. 

o DHS officials stated and our prior work has found that DHS real property data are 

unreliable and inconsistent across components.14 Although efforts are underway to 

improve data, it remains difficult for planners to identify opportunities for office 

realignment. 

14We have identified real property management across the federal government as a high risk area. Many of the challenges highlighted in this work are applicable to 

DHS’s portfolio management. See for example, GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011). Also see GAO, Federal Real Property: 

DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges, GAO-07-658 (Washington, D.C.: June 

22, 2007). 

Page 29

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Challenges

• DHS’s authority to reorganize has statutory limits. According to a senior DHS official, 

the agency faces legal constraints to departmental reorganizations. The Homeland 

Security Act provided the Secretary of Homeland Security certain authorities to “establish” 

and “alter” organizational units within the department.14 However, a senior DHS official 

stated that the authority of the department to create a unified regional/field office structure 

remains limited. For example, by law USSS and USCG must be maintained as “distinct 

entities” within DHS.15 However, similar limitations existed at the time of the I-Staff and 

BUR studies which did not prevent these efforts from recommending a unified regional 

structure. 

• In part because of all of these challenges, DHS officials reported prioritizing other 

initiatives over a unified field office structure. These include smaller-scale colocation, 

consolidation, and integration efforts that are largely led by the components. 

• However, as noted previously in this briefing, without the benefit of substantive 

documentation related to regionalization efforts, DHS decision makers may lack 

assurances that their decisions are based on sound analyses. For example, documenting 

the costs and benefits of regionalization and alternatives could assist officials in 

evaluating a range of field office realignment options. 146 U.S.C. § 452.

1518 U.S.C. § 3056(g); 6 U.S.C. § 468.
Page 34 GAO-12-185R DHS Realignment Efforts

Page 30

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Alternatives to Regionalization

• Given the challenges of implementing a single, unified field office structure, a senior DHS 

official said the department’s current thinking on harmonizing component regional 

configurations is best reflected in the DHS Strategic Plan: Fiscal Years 2012–2016.16

o Specifically, the department plans to “explore virtual approaches to regional and 

functional coordination,” which according to the strategic plan includes using models 

established in the interagency counternarcotics infrastructure. For example, USCG is 

establishing capabilities for some Interagency Operations Centers virtually—that is, 

sharing information and coordinating with port partners through an Internet web 

portal.17 In addition, DHS and some components have studied or taken actions to 

improve the effectiveness and efficiency of their regional/field office operations 

through actions such as colocation, consolidation, and integration. 

o Table 2 provides an overview of initiatives that DHS identified as alternatives to 

regionalization. These reports or assessments were intended to identify opportunities 

to improve aspects of DHS’s regional/field office structure since 2004; however, not 

all recommendations were fully implemented as of August 2012. 16DHS, Department of Homeland Security Strategic Plan: Fiscal Years 2012–2016 (Washington, D.C.: February 2012).

17Interagency Operations Centers are designed to, among other things, share maritime information with USCG’s port partners (other agencies and organizations it 

coordinates with). See GAO, Maritime Security: Coast Guard Needs to Improve Use and Management of Interagency Operations Centers, GAO-12-202 

(Washington, D.C.: Feb. 13, 2012). 
Page 35 GAO-12-185R DHS Realignment Efforts

Page 31

Objective 2

Table 2: DHS Reports and Assessments of Colocation, 

Consolidation, and Integration Options since 2004

aDHS, Homeland Security Act of 2002 (P.L. 107-296); Section 706 Report to Congress on Office Consolidation and Co-location, Washington, D.C., February 4, 2004.

bDHS, Section 706 Congressional Report: DHS Inquiry Response to the Subcommittee on Energy Policy, Natural Resources, and Regulatory Affairs, Washington, D.C., 2004.

cBoth Section 706 Reports reference DHS regionalization. We did not include these reports in table 1 because they respond to Congressional inquiries primarily related to consolidation 

and colocation.

dGSA, Draft DHS Regional Office Site Analysis, Washington, D.C., 2004. 

eICE, ICE Co-location Study: Volume 1 (Rationale and Execution) & Volume 2 (Acquisition Strategy), Washington D.C., Sept. 12, 2008.

f

DHS, Real Property Co-location Study: DHS-wide Co-location Feasibility Initiative, Washington, D.C., Mar. 18, 2008.

.

Source: GAO analysis of documents provided by DHS. 

Reports/assessments Description Conclusion or recommendation

Department of Homeland Security, Homeland 

Security Act of 2002 (P.L. 107-296); Section 

706 Report to Congress on Office 

Consolidation and Co-locationa

Follow-on Section 706 Congressional Report: 

DHS Inquiry Response to the Subcommittee 

on Energy Policy, Natural Resources, and 

Regulatory Affairsb, c

Initial 2004 report responded to a statutory 

requirement by presenting DHS’s actions to 

date and approach to develop a consolidation 

and colocation plan. 

Follow-on report addressed operational 

coordination/integration. 

Initial report did not identify any specific regional or field offices to consolidate or colocate; 

rather it outlined the key steps to create such a plan. 

Follow-on report stated that a “Regional Concept” referenced in the initial Section 706 

Report would address operational and coordination/integration concerns.

According to a senior DHS official, recommendations have not been fully implemented.

General Services Administration (GSA), Draft 

DHS Regional Office Site Analysis, 

Washington, D.C., 2004d

Draft report provided information to DHS to 

assist it in establishing its regional structure—

included analyses on site and space selection. 

GSA identified 158 buildings in 42 cities for potential regional office sites. 

According to a senior DHS official, recommendations have not been fully implemented.

Immigration and Customs Enforcement (ICE), 

ICE Co-location Study Volumes 1 & 2e

Congress directed ICE to submit a report on 

the cost and schedule for colocating ICE 

personnel within cities where ICE assets were 

located. 

The plan identified 56 consolidation projects in 55 cities to be completed from fiscal year 

2008 through 2018. 

According to a senior DHS official, recommendations have not been fully implemented.

Department of Homeland Security, Real 

Property Co-location Study: DHS-Wide CoLocation Feasibility Initiativef

2008 report focused on potential colocation

scenarios in the Miami, Florida area. 

Recommended (1) Co-locate CBP, USCG and TSA at a new location near the Miami 

International Airport; and (2) Co-locate CBP and USCG Port of Miami operations. 

According to a senior DHS official, recommendations have not been fully implemented.
Page 36 GAO-12-185R DHS Realignment Efforts

Page 32

Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office 

Structure, and Alternatives (cont.)

DHS Identified Alternatives to Regionalization

• According to senior DHS officials, consolidation, colocation, or integration efforts have 

been initiated by one or more components based on local conditions and smaller-scale 

regionalization has occurred “organically” where it makes sense. For example, multiple 

DHS components and other stakeholders utilize colocation and intelligence integration to 

coordinate counternarcotics operations through JIATF South.18

• DHS’s Chief Administrative Officer is accountable for managing DHS’s real estate 

portfolio. In addition, officials with the Program Analysis and Evaluation (PA&E) Division 

described past colocation studies conducted as part of the budget process. Specifically, in 

2009 PA&E identified 22 colocation opportunities for FEMA, ICE, USCG, and CBP offices. 

A parallel effort identified opportunities for USCG and CBP air asset co-location. No 

recommendations from these studies were implemented. However, DHS has requested 

funding for the ICE-wide colocation strategy in its fiscal year 2013 budget submission. A 

PA&E official said that it is now largely up to individual components to pursue their own 

opportunities for colocation, but resource constraints have limited such initiatives, given 

the expenses of lease consolidation.

18JIATF South, located in Key West, Florida, serves as the catalyst for integrated and synchronized interagency counterdrug operations and is responsible for the detection and monitoring 

of suspect air and maritime drug activity in the Caribbean Sea, the Gulf of Mexico, and the eastern Pacific. 
Page 37 GAO-12-185R DHS Realignment Efforts

Page 33

Appendix I

Figure 1: DHS Agencies and Key Operational Components as 

of August 2012

Note: DHS officials identified the following as the key DHS operational components—Transportation Security Administration, U.S. Customs and Border Protection, U.S. Citizenship and 

Immigration Services, U.S. Immigration and Customs Enforcement, U.S. Secret Service, Federal Emergency Management Agency, and the U.S. Coast Guard. 
Page 38 GAO-12-185R DHS Realignment Efforts

Enclosure II: Agency Comments
Page 39 GAO-12-185R DHS Realignment Efforts

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