Department of Homeland Security
 

Federal Protective Service's Exercise of a 

Contract Option for the Risk Assessment and 

Management Program 

OIG-12-67 (Revised) August 2012
 
August 31 , 2012 

MEMORANDUM FOR: L. Eric Patterson 

Director 

Federal Protective Service 

FROM: Deborah O~~~I~~'~ ~ Acting Assistant Inspector General for Inspections 

SUBJECT: Re-issuance of Inspection Report OIG-12-67, FPS' 

h.'xercise of a Contract Option for the Risk Assessment and 

Management Program 

I am wTiting to infonn you that the Department ofHomc1and Security Office of Inspector 

General (OIG) has recalled the subject report and is now fe-issuing it to modify the 

statement of compliance with Quality Stafldardsjor Inspections (QSI) . We took these 

actions because it recently came to our attention that a fmnily member of a senior OIG 

official was employed by an entity associated with this inspection. 

To ensure that this impairment to our independence in appearance did not afleet our 

findings and conclusions, we thoroughl y fe-reviewed our work on this inspection, as well 

as the results. Through this re-review, we verified that the impairment did not affect our 

results; our evidence is sound and fully supports our findings and conclusions. 

Therefore, we are fe-issuing this report and fe-posting it on our website. The report is 

unchanged excepl for the statement of compliance with QSI found on page 6 of Appendix 

A - Purpose, Scope, and Methodology. 

We remain committed to assisting the Department in improving its effectiveness and 

etliciency to better carry out its mission, and we appreciate your support of our work. 

Please do not hesitate to call me at (202) 254-4015 if you have ally questIOns or concerns, 

or your staff may contact William McCarron, ChiefInspector, at (202) 254- 4206. 

Altachment 
Background 

The mission of the Federal Protection Service (FPS) is to render more than 9,000 federal 

facilities owned or leased by the General Services Administration (GSA) safe and secure 

for federal employees, officials, and visitors. FPS employs 1,225 federal staff, including 

various law enforcement and support personnel, and utilizes 15,000 contract security 

guards. The Homeland Security Act of 2002 transferred FPS from GSA to the Department 

of Homeland Security (DHS). In October 2009, DHS moved FPS from U.S. Immigration 

and Customs Enforcement (ICE) to its National Protection and Programs Directorate 

(NPPD). 

In August 2008, ICE competitively awarded and FPS funded a $21 million, 7-year 

contract (1 base year and 6 option years) to a company to develop and maintain the Risk 

Assessment and Management Program (RAMP). RAMP was intended to be a next 

generation risk assessment tool to enable FPS to: 

•	 Assess and analyze risk posed to federal facilities and mitigate those risks by 

recommending and tracking countermeasures; and 

•	 Manage post inspections, guard contracts, and individual guard certification 

compliance. 

In July 2011, the Government Accountability Office (GAO) reported that RAMP was 

over budget, behind schedule, and could not be used as intended. According to the GAO 

report, several factors contributed to RAMP deficiencies. Specifically, FPS changed the 

original requirements, which caused the contractor to add additional resources; FPS did 

not conduct user testing as part of development; and ICE did not complete contractor 

performance evaluations. 

In an attempt to meet deployment milestones, FPS expended all $21 million of obligated 

funds by 2010, 5 years sooner than expected. In May 2010, ICE awarded the original 

developer a second contract, called a logical follow-on, to continue RAMP development 

and prepare for the transition to NPPD.1 According to ICE, this contract was awarded 

without full and open competition because it was logistically impossible to compete and 

award a contract and allow time for a new contractor to create and train a team capable of 

continuing the development schedule while performing operations and maintenance prior 

to the expiration date of the original RAMP contract. The follow-on contract included a 

base year and 1 option year with a total projected cost of $25 million. 

Results of Review 

Notwithstanding the previous overspending that GAO identified, FPS minimized some 

costs of RAMP by stopping development and paying the contractor only to operate and 

maintain the program. As a result, FPS will save the government at least $13.2 million 

1

 A logical follow-on is an exemption to the fair opportunity process described at 48 CFR 16.505(b)(2)(iii), 

recodified at 48 CFR 16.505(b)(2)(i)(C). 

1 
(see table 1). However, FPS has not determined how it will maintain data in RAMP or 

transfer critical data out of RAMP after June 2012. FPS risks incurring additional 

expenditures, including paying for the transfer of useless data, as well as losing critical 

data, if it does not act soon. 

Table 1: Obligated, Revised, and Unspent Funding for the RAMP Follow-on Contract 

Base Year Option Year Total 

Obligated Funding $12,499,832 $12,498,779 $24,998,611 

Revised Funding $9,154,961 $2,619,836 $11,774,796 

Unspent Funding $3,344,871 $9,878,943 $13,223,815 

FPS Ceased RAMP Development Because It Was Not Cost Effective and Did Not 

Fulfill Its Original Goals 

FPS ceased development of RAMP in May 2011 because RAMP was not cost effective 

and did not fulfill its original goals. GAO reported that RAMP’s actual costs were almost 

three times more than the $21 million original development contract amount. GAO also 

determined that FPS could not use RAMP to complete facility security assessments or 

reliable guard inspections. The FPS decision resulted in unspent funds of $3.3 million for 

the base year of the follow-on contract (see table 1). 

FPS officials told us that the FPS Director reached this decision after he, senior FPS 

officials, program managers, and end users held a series of meetings at headquarters and 

regional offices to discuss problems with RAMP. These meetings occurred from October 

to December 2010. In late March 2011, FPS began exploring options for developing a 

new version of RAMP with NPPD’s Office of Infrastructure Protection and Argonne 

National Laboratory. In late April 2011, FPS evaluated options for limiting RAMPassociated costs and ultimately decided in May 2011 to cease development of RAMP. 

FPS also did not exercise an option for a separate contract that provided project 

management for RAMP. 

FPS Minimized RAMP Costs by Exercising a Descoped Contract Option 

Although FPS is no longer developing RAMP, it is still using the system to manage its 

guard force through post inspections. RAMP also contains historical data from legacy 

systems that FPS wants to retain and maintain, such as countermeasures in place at 

facilities.2

 If RAMP is not maintained, then FPS will not be able to access historical post 

inspections or facilities security assessments. These records are important when 

determining what security countermeasures are and have been in place at a given facility. 

In June 2011, NPPD’s Acquisition Division, the office that administers the contract, 

exercised its 1-year option for the follow-on contract, extending it to June 2012. The 

contracting officer modified the scope of work for the option year by removing 

2

 RAMP replaced three FPS systems: Federal Security Risk Manager, Security Tracking System, and 

Contract Employment Requirements Tracking System. 

2 
development but keeping operations and maintenance. FPS was able to deobligate 

$9.9 million for the option year since it required only $2.6 million to fund operations and 

maintenance.3

 The contracting officer determined that exercising the option was the most 

advantageous and cost-efficient method of fulfilling the government’s needs in 

accordance with federal acquisition regulations.4 

It would not have been feasible to create, solicit, and award a new contract for operations 

and maintenance before the base year of the follow-on contract expired. Transitioning 

RAMP to a new contractor would have caused an interruption or degradation in service 

until the contractor could reach full performance. According to the contracting officer, 

the original developer was already performing operations and maintenance at an 

acceptable level, so he saw no reason not to exercise the option. Additionally, the 

developer estimated operations and maintenance costs separately from development. 

This allowed the contracting officer to modify the contract by mutual agreement instead 

of partially terminating it for convenience. 

By exercising the option year, FPS is paying the original developer to manage and 

maintain RAMP in order to identify and correct software failures, performance failures, 

and implementation failures for all RAMP components. Per the contract’s statement of 

work, operations and maintenance includes: 

• Conducting emergency repairs; 

• Performing maintenance tasks; 

• Providing documentation for procedures and help desk support; and 

• Providing Tier 2 and 3 help desk support.5 

As described in its monthly and weekly status reports, the developer is primarily helping 

FPS and ICE migrate data to a new server, debug the system, resolve guard data 

discrepancies, and provide RAMP deployment metrics to management. As of November 

2011, FPS had paid the developer $1.2 million for work performed during the option year. 

FPS Does Not Have a Long-term Solution To Maintain or Transfer Critical Data 

FPS has not determined the nature of data in RAMP, what data are valid, and what data 

need to be preserved for future use. FPS is just beginning to evaluate its options but does 

not have a timeline for performing this analysis, despite the impending end of the followon contract in June 2012. 

FPS will likely consider two options: (1) transfer operations and maintenance of RAMP 

to a company that was recently awarded a contract for infrastructure technology support, 

or (2) decommission RAMP in a way that preserves critical data. According to FPS, 

there are approximately 75,000 documents in RAMP. With 6 months left on the current 

3

 The actual amount spent on the option year of the follow-on contract will not be known until the end of 


the contract year. 


4

 48 CFR 17.207. 


5

 Tier 2 and 3 help desk support handles questions or problems that the ICE Help Desk cannot resolve. 


3 
contract, FPS may not have enough time to analyze this large volume of data and either 

transfer them to another contractor or have them decommissioned. FPS also has not 

analyzed the costs or benefits of either option. FPS should complete this analysis before 

choosing a course of action. 

Recommendation 

We recommend that the Director of the Federal Protective Service plan and evaluate the 

projected costs and benefits of both potential courses of action—for the operation and 

maintenance or transfer of data in the Risk Assessment and Management Program— 

before taking action regarding these data. This plan should include a determination of 

what data are critical to FPS’ mission and should be preserved. 

Management Comments and OIG Analysis 

A copy of the Department’s response is included as appendix B. The Department 

concurred with our recommendation. FPS has initiated a review of RAMP 

documentation and data, looking specifically at the type and usage of the data as well as 

options for retrieval and storage outside of RAMP. The Department will decide on or 

before June 8, 2012, as to the continuation of RAMP. 

The Department’s actions are consistent with the intent of the recommendation. In the 

corrective action plan, the Department should provide further details regarding the results 

of its review of RAMP documentation and data, particularly the type and use of the data 

and retrieval options. Also, we have been made aware that since the Department owns 

the RAMP data, the data will be accessible to FPS for operations and maintenance after 

the expiration of the current contract. 

4 
Appendix A 

Purpose, Scope, and Methodology 

In June 2011, Representative Bennie G. Thompson asked that we review two areas of 

FPS’ operations: RAMP and whether a company breached its contract with FPS to 

provide protective services for federal buildings in Michigan when its guards did not 

properly attend to an explosive device at the Patrick V. McNamara Federal Building. As 

part of our review of the Michigan contract, we also determined if the contractor’s 

performance has been sufficiently remedied. 

There is only slight overlap between the RAMP and Michigan contracts, which procure 

different services and are administered by different offices. Therefore, we are issuing 

two separate reports in response to Representative Thompson’s request. This letter report 

contains the results of our review of RAMP. 

Our original objectives concerning RAMP were to determine (1) the extent to which 

internal control weaknesses exist within the FPS Acquisition Division; (2) the plausibility 

of opening the RAMP contract to full and open competition; and (3) the amount of 

money spent on RAMP and the extent to which RAMP has been deployed by FPS. We 

altered these objectives as a result of actions taken by FPS and ongoing work by GAO. 

We included GAO conclusions regarding RAMP in our report to provide context. 

First, the FPS Acquisition Division is responsible for administering FPS’ guard contracts 

and has no role in administering the RAMP contract other than advising FPS’ Director, 

when asked. Therefore, we did not seek to determine the extent to which internal control 

weaknesses exist within the FPS Acquisition Division. 

Second, in July 2011, 1 month before the start of our fieldwork, Congress requested that 

GAO review FPS’ efforts to contract for a new version of RAMP. FPS had already 

ceased development of RAMP and was reevaluating RAMP requirements and alternative 

programs to meet its requirements. Therefore, we did not seek to determine the 

plausibility of opening the RAMP contract to full and open competition. However, 

because Representative Thompson expressed concern that FPS awarded the original 

developer an option year for operation and maintenance of RAMP, we reviewed the 

factors that FPS considered, and its rationale, to determine whether this action was in the 

best interest of the government. 

In addition, we did not seek to determine the total amount of money spent on RAMP 

because GAO addressed this issue in its July 2011 report. However, because FPS did not 

expend all allocated funds for the base year of the follow-on contract and awarded the 

option year after GAO ended its work, we determined the amount spent on the base year 

of the follow-on contract and the amount obligated for the option year. 

Although we did see indications that FPS is using RAMP for post inspections, Congress 

has asked GAO to determine how FPS is performing facility security assessments and 

managing its guard force as it transitions to a new version of RAMP. Therefore, we did 

not review the extent to which FPS has deployed RAMP. 

5 
Appendix A 

Purpose, Scope, and Methodology 

We reviewed sections of the Federal Acquisition Regulation and examined files from the 

RAMP logical follow-on contract. We also interviewed officials from FPS, ICE, and the 

NPPD Acquisition Division. 

We conducted our fieldwork from August to December 2011. This review was 

conducted under the authority of the Inspector General Act of 1978, as amended, and 

according to the Quality Standards for Inspections (QSI) issued by the President’s 

Council on Integrity and Efficiency, except that we identified an impairment to our 

independence in appearance. Following completion of our review, it came to our 

attention that a family member of a senior OIG official was employed by an entity 

associated with this inspection. We took steps to re-evaluate the evidence supporting our 

findings and conclusions. In our opinion, the impairment to our independence in 

appearance did not affect the findings and conclusions developed during this inspection. 

QSI requires that we adequately plan and perform the inspection to obtain sufficient, 

competent, and relevant evidence to provide a reasonable basis for reaching conclusions, 

consistent with inspection objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based upon our inspection objectives, 

and that the impairment to our independence in appearance did not affect this evidence or 

any findings and conclusions. 

6 
Appendix B 

Management Comments to the Draft Letter Report 

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\gt ' Homeland 

Security 

MAR 082012 

Mr. Carlton I. Mann 

Assistant Inspector General lor Inspections 

Officc of the Inspector General 

U.S. Department of Home land Security 

Washi ngton, DC 20528 

Dear Mr. Mann: 

Re: OIG Report 11-144-ISP-NPPO, FN;" Erercise 0/ a Contract Option/or tile Risk AsseSSlI/el/l 

(lnd Management Program 

The Department of Homeland Security (D I-IS)lNational Protec tion and Programs Directorate 

(NPPD) appreciates the opportunity to review and respond to the Office of Inspector General 

(O IG) report ll-1 44-ISP-NPPD, FPS ' E'Cerc:ise o/a Colllract Oplion/ol" the Risk Jlssessmelll 

and Mallagemelll Program (RAMP). This audit was conducted at the reque st of Representati ve 

Bcnnie G. Thompson to review the circumstances surrounding thc initiation <Inc! continuation of 

the RAMP contract. DI-ISINPPD is working to resolve the isslles identified by the OIG. 

The Federal Protective Service (FPS) is responsible for the protection of more than 9,000 Federal 

facilities owned or leased by the Gcneral Services Administration (GSA). In 2003, FPS was 

transferred from GSA to the U.S. Immigration and Customs Enforcement (ICE). In 2009, FilS 

was transferred to NPPD. 

In 2008, ICE competitively awarded a COntract for the developmcnt and maintenance 0 1· RAMP. 

This action was taken to address insufficient risk assessments and data weaknesses identified by 

the Governmcnt Accountability Office (GAO). RAM P was intendcd to be a next generation ris k 

assessment tool that would enable FilS to assess and analyze risk posed to Federal fa cilities and 

mitigatc those risks by recommcnding and tracking countenneasures. In addition, RAMP's 

operating capabilities would assist FPS in managing post inspections, guard contrac ts, and 

individual guard certification compliance. In an attempt to meet deployment milcslOl1cs, the 

total fu nding amount for the entire perfonnancc period was expendcd Jive years sooner than 

contemplated by the term of the contract. To continue RAMP development and prepare for the 

transition to NPPD, a shorte r term " logical follow-on" contract was issued in 2010 to continue 

with development and systcm operations and maintcnance of RAMP whil e allowing timc for tbe 

Governmcnt to re-cxamine any changes in its req uirements and thereafier competitively awa rd a 

new contract renecting these requirements. 

The GAO report titled, Aclions Needed to Reso"le Delays and Illadequale OverSight issues wilh 

FPS' Risk Assessment Mcmagemcm Program ( 11 -70SR), issued in 2011 , revealed that a factor 

7
 
Appendix B 

Management Comments to the Draft Letter Report 

contributing to RAM P deficienc ies was the change to original contrac t requirements resulting in 

the contractor having to add resources. In late Apri l 20 11, FPS evaluated options for limiting 

RAMP~assoc d costs and ultimate ly decided in May 201 1 to cease RAM P deve lopment 

because it was not cos ~efrcct ve and it did not fu lfi ll its original goa ls. The contract was 

modified to remove deve lopment activities and focus on system opcrations and maintcnancc. 

OIG concl uded that issuing this modification was the most advantageous and cost-efficient 

method of fulfi lling the Government's needs. 

DI-ISINP PD has no techni cal and sensitivity comments. 

Recommenda tion : '/11e Director oj FPS plan and evaluate the projected COSls and benefits of 

both potential courses oj action- for the operafioll and maintenance or tra11SJe,. of data in the 

AlvfP befo ,. e lClking action regarding these data. This plcll1 should il1c1ude a determination of 

what data are critical to FPS' mission and should be preser ved. 

NPllD/F PS concurs with this recommendati on. FPS has initi ated a comprehensive review of 

RAM P document ation and data, looking spec ifically at the type and usage orthe data as well as 

options for retrieval and storage outside of RAMP. In consultation with the NPPD Office of the 

Chief In foflllation Officer, FPS will make a decision as to continuation of RAM P withi n 90 days 

from the date of this letter. 

We thank YOll for the opportunity to review and provide comment on this draft letter report, and 

we look forward to working wi th yo u on fUlure homeland security engagements. 

Sincerely, 

(VJ~ 

Rand Beers 

Under Secretary 

8
 
Appendix C 

Major Contributors to this Report 

William McCarron, Chief Inspector 

Paul H. Bergstrand, Senior Inspector 

Lindsay K. Clarke, Inspector 

Jasmine K. Davis, Inspector 

9 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Representative Bennie G. Thompson 

10 
 

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