FEDERAL 

PROTECTIVE 

SERVICE

Challenges with 

Oversight of Contract 

Guard Program Still 

Exist, and Additional 

Management Controls 

Are Needed

Report to the Chairman, Subcommittee 

on Oversight and Management 

Efficiency, Committee on Homeland 

Security, House of Representatives

September 2013

GAO-13-694

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-694, a report to the 

Chairman of the Subcommittee on Oversight 

and Management Efficiency, Committee on 

Homeland Security, House of Representatives

September 2013

FEDERAL PROTECTIVE SERVICE

Challenges with Oversight of Contract Guard 

Program Still Exist, and Additional Management 

Controls Are Needed

Why GAO Did This Study

FPS relies on a privately contracted 

guard force (about 13,500 guards) to 

provide security to federal facilities 

under the custody and control of the 

General Services Administration. In 

2010 and 2012, GAO reported that 

FPS faced challenges overseeing its 

contract guard program, specifically in 

ensuring guards’ qualifications. 

GAO was asked to update the status of 

FPS’s contract guard oversight. This 

report examines (1) how FPS’s 

requirements for contract guards 

compare to those of selected federal 

agencies and challenges, if any, that 

FPS faces in ensuring its requirements 

are met; (2) the extent to which guard 

companies have documented 

compliance with FPS’s guard 

requirements; and (3) the management 

controls FPS uses to ensure 

compliance with its guard 

requirements. GAO reviewed 31 FPS 

guard contracts, and analyzed guard 

files from 11 contracts, selected based 

on geographic diversity; interviewed 

officials from guard companies, FPS 

headquarters, and 4 of 11 FPS 

regions; and reviewed the contract 

guard requirements and processes at 

six federal agencies, selected for their 

comparability to FPS. 

What GAO Recommends

GAO recommends that the Secretary 

of DHS direct FPS to take immediate 

steps to determine which guards have 

not had screener or active-shooter 

scenario training and provide it to 

them; require that guard instructors be 

certified to teach basic and refresher

training; and develop and implement 

guidance for selecting guard files and 

verifying the results. DHS concurred 

with GAO’s recommendations.

What GAO Found

Several of the Department of Homeland Security’s (DHS) Federal Protective 

Service’s (FPS) guard requirements are generally comparable to those of the six 

selected agencies GAO reviewed, but FPS faces challenges in some aspects of 

guards’ training. FPS and the six selected agencies GAO reviewed require basic, 

firearms, and screener (x-ray and magnetometer equipment) training for their 

armed guards. However, GAO found that providing screener training remains a 

challenge for FPS. For example, officials from one of FPS’s contract guard 

companies stated that 133 (about 38 percent) of its approximately 350 guards

have never received this training. Similarly, according to officials at five guard 

companies, some of their contract guards have not received training on how to 

respond during incidents involving an active shooter. Additionally, while contract 

guard industry guidance states that all training should be done with a certified 

instructor, GAO found that FPS does not require guard instructors to be certified 

to provide basic and refresher training, which represents the majority of guards’

training. According to six guard companies, the lack of a requirement has led to 

having to retrain some guards, potentially increasing costs to FPS.

Twenty-three percent of contract guard files GAO reviewed did not have required 

training and certification documentation. GAO reviewed 276 randomly selected

(non-generalizable) guard files maintained by 11 of the 31 guard companies 

GAO interviewed and found that 212 files (77 percent) contained the required 

training and certification documentation, but 64 files (23 percent) were missing 

one or more required documents. For example, the 64 files were missing items 

such as documentation of initial weapons and screener training and firearms 

qualifications. Although FPS has taken steps to address its challenges in this 

area, GAO’s previous recommendations concerning monitoring guard 

companies’ performance are a guide to furthering FPS’s efforts. According to 

FPS officials, it plans to address GAO’s recommendations in the near future.

FPS continues to lack effective management controls to ensure its guards have 

met its training and certification requirements. For instance, although FPS agreed 

with GAO’s 2010 and 2012 recommendations that it develop a comprehensive 

and reliable system for managing information on guards’ training, certifications, 

and qualifications, it still does not have such a system. According to FPS officials, 

it plans to address this recommendation in the near future. FPS also lacks 

sufficient management controls to ensure consistency in its monthly guard file 

review process (its primary management control for ensuring that guards are 

trained and certified), raising questions about the utility of this process. In the 

absence of specific guidance regarding how files are to be selected, FPS’s 11 

regions varied in how they conducted the monthly file reviews. For example, FPS 

officials from three regions stated that they randomly select their files for review, 

while officials from one guard company in another region stated that FPS asks 

the guard company to select the files for review. Allowing contract guard 

company officials to select files for review by FPS could result in selection bias 

and affect the results of FPS’s review. FPS also lacks guidance on reviewing and 

verifying the results of its guard-file reviews. Without such guidance, FPS may 

not be able to determine the accuracy of its monthly file review results or if its 

contract guard companies are complying with the guard training and certification 

requirements.

View GAO-13-694. For more information, 

contact Mark L. Goldstein at (202) 512-2834 

or GoldsteinM@gao.gov.
Page i GAO-13-694 Federal Protective Service

Letter 1

Background 4

Several of FPS’s Guard Requirements Are Generally Comparable to 

Selected Agencies, but FPS Faces Challenges in Other Aspects 

of Guards’ Training 7

Twenty-three Percent of Contract Guard Files We Reviewed Did 

Not Have Required Training and Certification Documentation 14

FPS Still Lacks Effective Management Controls to Ensure Guards 

Have Met Training and Certification Requirements 16

Conclusions 21

Recommendations for Executive Action 22

Agency Comments 22

Appendix I Status of GAO’s 2010 and 2012 Recommendations

to the Department of Homeland Security’s

Federal Protective Service 24

Appendix II Comments from the Department of Homeland Security 25

Appendix III GAO Contact and Staff Acknowledgments 28

Tables

Table 1: FPS Contract Guard Requirements, as of October 2011 8

Table 2: Total Missing Documents Identified in 64 of 276 Guard 

Files GAO Reviewed 15

Table 3: Status of GAO’s 2010 and 2012 Recommendations to the 

Department of Homeland Security’s Federal Protective 

Service 24

Figure

Figure 1: Number of FPS Contract Guards, by Region, as of 

September 2012 5

Contents
Page ii GAO-13-694 Federal Protective Service

Abbreviations

AED automated external defibrillator

CALEA Commission on Accreditation for Law Enforcement 

Agencies, Inc.

COR Contracting Officer’s Representative

CPR cardiopulmonary resuscitation

DCJS Virginia Department of Criminal Justice Services

DHS Department of Homeland Security

DOE Department of Energy

FLETA Federal Law Enforcement Training Accreditation Board

FLETC Federal Law Enforcement Training Center

FPS Federal Protective Service

GSA General Services Administration

ISC Interagency Security Committee

NASA National Aeronautics and Space Administration

NASCO National Association of Security Companies

NPPD National Protection and Programs Directorate

OPM Office of Personnel Management

PFPA Pentagon Force Protection Agency

PSO Protective Security Officer

RAMP Risk Assessment and Management Program

SGIM Security Guard Information Manual

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-13-694 Federal Protective Service

441 G St. N.W.

Washington, DC 20548

September 17, 2013

The Honorable Jeff Duncan

Chairman

Subcommittee on Oversight and Management Efficiency

Committee on Homeland Security

House of Representatives

Dear Mr. Chairman:

The Department of Homeland Security’s (DHS) Federal Protective 

Service (FPS) is the primary agency responsible for providing law 

enforcement and related security services for the approximately 9,600 

federal facilities under the control and custody of the General Services 

Administration (GSA). These facilities house 1.1 million occupants and 

average 1.4 million visitors per day. To help accomplish the mission of 

protecting federal facilities, FPS obligated about $767 million in fiscal year 

2012 for contract guard companies to provide about 13,500 guards at 

over half of GSA’s facilities.1 In recent years, we have reported on the 

challenges FPS faces overseeing its contract guard program. Specifically, 

in August 2012, we reported that FPS had no centralized database to 

ensure that guards have completed required training and have the 

appropriate certifications and qualifications to be deployed at federal 

facilities.2 In 2010, we reported that FPS’s contract guard program 

required more oversight and that FPS should reassess its use of contract 

guards.3

 1

FPS refers to its contract security guards as Protective Security Officers (PSO). 

However, for the purposes of this report we use the term guard. 

We recommended, among other things, that FPS develop and 

implement a comprehensive guard management system capable of 

providing reliable, comprehensive data on its contract guard program on a 

real time basis, and that FPS provide guards with building-specific and 

scenario-based training and guidance. Our 2010 and 2012 reports 

contained 13 recommendations. DHS agreed with all of our 

2

GAO, Federal Protective Service: Actions Needed to Assess Risk and Better Manage 

Contract Guards at Federal Facilities, GAO-12-739 (Washington, D.C.: August 2012).

3

GAO, Homeland Security: Federal Protective Service’s Contract Guard Program 

Requires More Oversight and Reassessment of Use of Contract Guards, GAO-10-341

(Washington, D.C.: April 2010).
Page 2 GAO-13-694 Federal Protective Service

recommendations and is in the process of implementing two of them (see 

app. I for a list of recommendations and status).

You asked us to update the status of FPS’s management of its contract 

guard program. This report provides information and analysis on (1) how 

FPS’s guard training, certification, and qualification requirements for 

contract guards compare to those of other selected federal agencies and 

challenges, if any, that FPS faces in ensuring those requirements are 

met; (2) the extent to which FPS’s guard companies have documented 

compliance with training and certification requirements; and (3) the 

management controls FPS and its guard companies use to ensure 

compliance with training, certification, and qualification requirements.

To determine FPS’s training, certification, and qualification requirements 

for contract guards, we analyzed selected guard services contracts active 

as of September 2012 and FPS’s Security Guard Information Manual. We 

drew a non-generalizable sample of 31 contracts from FPS’s 117 guard 

services contracts (one contract for every guard company with which FPS 

has contracted for non-emergency guard services).4

 4

When we chose contracts for review, FPS had a total of 117 contracts with 32 guard 

companies. However, 1 of the 32 companies had a contract with FPS for only emergency 

guard services. As such, we chose 1 contract for review for each company with which 

FPS had contracted for non-emergency guard services as of November 2012.

Eleven of the 31 

guard contracts were chosen based on geographic diversity and 

geographic density of contracts within FPS regions to allow us to conduct 

file reviews for multiple contracts during each of four site visits that we 

conducted. For each of these 11 contracts, we reviewed the contracts as 

well as a random sample of guard files associated with each contract. 

The remaining 20 guard services contracts we selected were the most 

recent contract for each of the remaining guard companies that FPS had 

contracted with as of November 2012. We also interviewed officials from 

each of the 31 contract guard companies and industry stakeholders, 

including the National Association of Security Companies (NASCO), the 

Commission on Accreditation for Law Enforcement Academies (CALEA), 

the Federal Law Enforcement Training Accreditation Board (FLETA), and 

the Department of Homeland Security’s (DHS) Interagency Security 

Committee (ISC). To determine how FPS’s requirements compare to 

those of other agencies that contract for guard services, we selected six 

federal agencies that contract for guard services and reviewed their 

requirements and processes for managing their contract guards. 
Page 3 GAO-13-694 Federal Protective Service

Agencies were selected based on survey responses regarding use of 

contract guards for a previous GAO report5

To determine the extent to which contract guard companies documented 

compliance with FPS’s guard training and certification requirements, we 

examined documentation related to our non-generalizeable sample of 11 

contracts, as previously discussed. From these 11 contracts, we 

randomly selected 276 guard files to review for compliance with FPS 

requirements. For each guard file, we compared the file documents to a 

list of requirements contained in FPS’s Administrative Audit and 

Protective Security Officer File Review Forms, which FPS uses to 

conduct its monthly guard file reviews.

and discussions with guard 

companies and industry stakeholders. Specifically, we reviewed policies 

and interviewed officials from the Department of Energy (DOE), the 

National Aeronautics and Space Administration (NASA), the Department 

of Defense’s Pentagon Force Protection Agency (PFPA), the Department 

of State (State), the John F. Kennedy Center for the Performing Arts 

(Kennedy Center), and the U.S. Holocaust Memorial Museum (Holocaust 

Museum). Our findings from our review of these agencies’ practices are 

not generalizeable to other agencies that contract for guard services. 

However, the six agencies we selected are comparable to FPS because 

they also are responsible for protecting and providing guard services to a 

large number and wide variety of federal facilities such as public buildings 

and museums.

To identify the management controls and processes FPS and the guard 

companies use to ensure compliance with training, certification, and 

qualification requirements, we reviewed FPS’s procedures for (1) 

conducting monthly guard file reviews; (2) documenting compliance with 

guard training, certification, and qualification requirements; and (3) 

monitoring performance. We also visited 4 of FPS’s 11 regions to discuss 

how regional officials ensure that guards are qualified to be deployed to 

federal facilities. We selected the 4 regions to provide geographic density 

of contracts in the region to facilitate reviews of guard files, diversity in the 

size of guard companies, and geographic diversity. During regional visits, 

 5

GAO, Facility Security: Greater Outreach by DHS on Standards and Management 

Practices Could Benefit Federal Agencies, GAO-13-222 (Washington, D.C.: January 

2013) and GAO, Facility Security: Results of GAO’s Survey on the Physical Security of 

Federal Facilities, an E-supplement to GAO-13-222, GAO-13-223SP (Washington, D.C.: 

January 2013).
Page 4 GAO-13-694 Federal Protective Service

we interviewed FPS regional managers, contract guard program 

managers, contracting officers, contracting officer’s representatives, and 

inspectors regarding oversight policies and practices and challenges to 

ensuring compliance with requirements. In addition, we interviewed 

officials from each of FPS’s 31 guard companies regarding their policies 

and procedures for complying with FPS’s guard training and certification 

requirements. While the results of our work are not generalizeable, about 

40 percent of the GSA facilities with guards are located in the four regions 

where we conducted our site visits and our review of guard files involved 

11 of FPS’s 31 guard companies. To assess the extent to which FPS 

monthly guard file review results identified files with missing 

documentation of training, certifications, and qualifications, we compared 

FPS’s monthly file review results from the month in which we conducted 

our file review for each of the 11 contracts to identify guard files that were 

included in both our review and FPS’s monthly review. We identified any 

discrepancies between the reviews and used FPS’s file review forms to 

examine the discrepancies.

We conducted this performance audit from August 2012 through 

September 2013 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.

FPS is responsible for protecting federal employees and visitors in 

approximately 9,600 federal facilities under the custody and control of 

GSA. The level of security FPS provides at each of the facilities (including 

whether guards are deployed) varies depending on the building’s facility 

security level.

To fund its operations, FPS charges fees for its security services to 

federal tenant agencies in GSA-controlled facilities. For fiscal year 2013, 

FPS expects to receive $1.3 billion in fees. FPS has about 1,200 full-time 

employees and about 13,500 contract security guards deployed at 

approximately 5,650 (generally level III and IV facilities) of GSA’s 9,600 

facilities. Figure 1 shows the location of FPS’s 11 regions and the 

approximate number of guards serving under contracts in each of these 

regions.

Background
Page 5 GAO-13-694 Federal Protective Service

Figure 1: Number of FPS Contract Guards, by Region, as of September 2012

Note: The number of guards in each region could fluctuate daily depending on contract guard 

company personnel changes (i.e.: hiring and firing, added services, etc). Our figure shows the 

approximate number of guards (13,503), as of September 2012.

FPS’s contract guard program is the most visible component of the 

agency’s operations, and the agency relies on its guards to be its “eyes 

and ears” while performing their duties. Contract guards are responsible 

for controlling access to facilities; conducting screening at access points 

to prevent the introduction of prohibited items, such as weapons and 

explosives; enforcing property rules and regulations; detecting and 

reporting criminal acts; and responding to emergency situations involving 

facility safety and security. In general, guards may only detain, not arrest, 
Page 6 GAO-13-694 Federal Protective Service

individuals, and guards’ authorities typically do not extend beyond the 

facility. However some guards may have arrest authority under conditions 

set forth by the individual states.

According to FPS’s contract for guard service, its private-sector contract 

guard companies have primary responsibility for training and ensuring 

that guards have met certification and qualification requirements; 

however, FPS is ultimately responsible for oversight of the guards. FPS 

relies on its Contracting Officer Representatives (COR) and inspectors 

located in its 11 regions to inspect guard posts and verify that training, 

certifications, and time cards are accurate, among other responsibilities.6

CORs are individuals appointed by the contracting officer to assist in the 

monitoring or administration of a contract including monitoring contractor 

performance, receiving reports and other documentation, performing 

inspections, and maintaining contact with both the contract guard 

company and the contracting officer.7 FPS’s contractors are responsible 

for providing and maintaining all guard services as described in the 

contract statement of work, including management, supervision, training, 

equipment, supplies, and licensing.

 6

FPS inspectors monitor the security posture of federal facilities by responding to 

incidents, testing countermeasures, and conducting guard post inspections. 

7

FPS guard services are acquired through competitive 5-year indefinite-delivery, 

indefinite-quantity contracts or blanket purchase agreements, consisting of a 1-year base 

period and four 1-year renewal option periods.
Page 7 GAO-13-694 Federal Protective Service

Before guards are assigned to a post or an area of responsibility at a 

federal facility, FPS requires that they all have contractor employee 

fitness determinations (the employee’s fitness to work on behalf of the 

government based on character and conduct) and complete 

approximately 120 hours of training provided by the contractor and FPS, 

including basic training, firearms training, and screener (X-ray and 

magnetometer) training. Guards must also pass an FPS-administered 

written examination and possess the necessary certificates, licenses, and 

permits as required by the contract. Additionally, FPS requires its guards 

to complete 40 hours of refresher training every 3 years. Some states and 

localities require that guards obtain additional training and certifications.8

See table 1 for a detailed list of FPS’s guard training, certification, and 

qualification requirements.

 8

FPS requires that guards comply with state and local requirements for armed security 

personnel. For example, armed guards providing services in Virginia must successfully 

complete registration and training requirements set by the Virginia Department of Criminal 

Justice Services (DCJS), including firearms endorsement, prior to being deployed in the 

state.

Several of FPS’s 

Guard Requirements 

Are Generally 

Comparable to 

Selected Agencies, 

but FPS Faces 

Challenges in Other 

Aspects of Guards’

Training

FPS Has Several Guard 

Training Requirements 

That Are Generally 

Comparable to Other 

Selected Agencies
Page 8 GAO-13-694 Federal Protective Service

Table 1: FPS Contract Guard Requirements, as of October 2011

Requirement Description

Background 

investigation/contractor 

employee fitness 

determination

Background checks conducted by FPS and the Office of Personnel Management (OPM), as well as 

documentation for guard files including: contractor employee’s fitness-determination letter,a preemployment drug screening, copy of driver’s license or state identification, Domestic Violence Declaration 

Form (“Lautenberg Form”) which certifies that guards have not been convicted of a crime of domestic 

violence, medical certification, and verified alien/immigration status. Fitness determinations are required 

every 5 years.

Basic training Guards are required to complete a 64-hour training course provided by the contract guard company or a 

third party at the time of hiring. This training is based on the FPS Security Guard Information Manual 

(SGIM), which describes the guard’s roles and responsibilities. Subject areas include: ethics, public 

relations, search and seizure, crime scene detection, access control, and crime detection and response, 

among other things. 

Initial weapons training Guards receive 40 hours of Basic Weapons Training provided by the contract guard company or a third 

party at the time of hiring. Prior to being deployed, guards are required to receive a qualifying score for 

each weapon associated with the contract or specific post requirement. 

FPS screener training Guards take an 8-hour Initial Screener (i.e., x-ray and magnetometer equipment) training provided by FPS 

at the time of hiring. Some newer contracts require guards to undergo 8-hours of annual refresher training.

FPS orientation Guards take an 8-hour DHS orientation training provided by FPS at the time of hiring. Topics include: rules 

and regulations, report writing, bomb threats and natural disaster responses, as well as training on special 

situations, such as handling an active shooter or workplace violence situation.

Firearms qualifications Guards are required to successfully complete prescribed course of firearms training, provided by the 

contractor or a third party but witnessed by FPS, and achieve a minimum score for a firearms performance 

qualification test at a range. Qualifications are required semi-annually.

Baton certification Guards take a 4-hour training class on how to use a baton. This training is provided by the contract guard 

company or a third party on an annual basis.

Oleoresin Capsicum 

spray certification

Guards take a 4-hour training class on how to use Oleoresin Capsicum spray (commonly referred to as 

“OC Spray” or pepper spray). This training is provided by the contract guard company or a third party on an 

annual basis.

State and local permits Some states and localities require weapons permits and/or security officer certifications, which may include 

additional required training. Requirements and frequency of renewal are determined by the state or locality.

CPR certification Guards are required to complete training and receive certification. Training is provided by the contract 

guard company or a third party and frequency is determined by the certifying body (e.g., the American 

Heart Association or American Red Cross).

AED certification Guards are required to complete training and receive certification on how to use an automated external 

defibrillator (AED, a device used for restoring a regular heart rhythm during cardiac arrest). This training is 

provided by the contract guard company or a third party and frequency is determined by the certifying body 

(e.g., the American Heart Association or American Red Cross).

First-aid certification Guards are required to complete first-aid training and receive certification. This training is provided by the 

contract guard company or a third party and frequency is determined by the certifying body (e.g., the 

American Heart Association or American Red Cross).

Refresher training Guards are required to complete a 40-hour refresher training course. This training is provided by the 

contract guard company or a third party triennially. This training is generally a refresher of basic training 

and may also include screener refresher training. 

Source: GAO analysis of FPS guard service contracts.

a

A contractor employee’s fitness determination is based on the employee’s suitability for work for or 

on behalf of the government based on character and conduct.
Page 9 GAO-13-694 Federal Protective Service

We found similarities in the ways that FPS and six federal agencies we 

reviewed ensure that contract guards have received required training, 

certifications, and qualifications. Similar to FPS, each of the six agencies 

we examined—DOE, NASA, PFPA, State, the Kennedy Center, and the 

Holocaust Museum—depend largely on the contract guard companies to 

ensure guards are trained, certified, and qualified. They also depend on 

the guard companies to document compliance with contract 

requirements. All six agencies and FPS require basic, firearms, and 

screener (x-ray and magnetometer) training for their armed guards. In 

addition, FPS and five of the six agencies we reviewed require refresher 

training.

FPS continues to experience difficulty providing required screener (x-ray 

and magnetometer equipment) training to all guards. In 2009 and 2010, 

we reported that FPS had not provided screener training to 1,500 contract 

guards in one FPS region.9 In response to our reports, FPS stated that it 

planned to implement a program to train its inspectors to provide screener 

training to all of its contract guards.10

As noted in table 1, FPS requires all guards to receive 8 hours of initial 

screener training provided by FPS. Screener training is important 

because guards control access points at federal facilities and thus must 

be able to properly operate x-ray and magnetometer machines and 

understand their results. However, 3 years after our 2010 report, guards 

Under this program, FPS planned to 

first provide x-ray and magnetometer training to its inspectors who would 

subsequently be responsible for training the guards. However, FPS 

continues to have guards deployed to federal facilities without this 

training.

 9

GAO, Homeland Security: Federal Protective Service Has Taken Some Initial Steps to 

Address Its Challenges, but Vulnerabilities Still Exist, GAO-09-1047T (Washington, D.C.: 

Sept. 23, 2009) and GAO-10-341.

10GAO-10-341.

FPS Continues to Face 

Challenges in Some 

Aspects of Guards’

Training

FPS Is Not Providing Required 

Screener Training to All Guards
Page 10 GAO-13-694 Federal Protective Service

are deployed to federal facilities who have never received this training. 

For example, an official at one contract guard company stated that 133 of 

its approximately 350 guards (about 38 percent) on three separate FPS 

contracts (awarded in 2009) have never received their initial x-ray and 

magnetometer training from FPS. The official stated that some of these 

guards are working at screening posts without having received the 

training. Further, officials at another guard company in a different FPS 

region stated that, according to their records, 78 of 295 guards (about 26 

percent) deployed under their contract have never received FPS’s x-ray 

and magnetometer training. These officials stated that FPS’s regional 

officials were informed of the problem, but allowed guards to continue to 

work under this contract, despite not having completed required training. 

Because FPS is responsible for this training, according to guard company 

officials, no action was taken against the company. In May 2013, FPS 

headquarters officials stated that they were unaware of any regions in 

which guards had not received screener training.

In July 2013, according to FPS officials, the agency began designing a 

“train-the-trainer” pilot program with four guard companies. Through this 

pilot program, contract guard company instructors, in addition to FPS 

inspectors, will be certified to provide screener training to guards. FPS 

officials stated that they plan to implement the pilot program in the first 

quarter of 2014. According to FPS officials, once implemented, FPS’s 

train-the-trainer program should increase the number of certified 

instructors capable of providing screener training nationwide. If this 

program is fully implemented, FPS screener training could be provided 

largely by the guard companies. This is the method by which four of the 

six agencies we spoke with provide their guards with screener training. In 

addition, officials from 13 of the 31 guard companies that we interviewed 

stated that responsibility for x-ray and magnetometer training should be 

shifted to the guard companies to alleviate scheduling problems, while 

officials from 7 companies stated that FPS should retain this 

responsibility. The remaining 11 guard companies did not state an opinion 

on this issue. FPS’s train-the-trainer program could provide resources to 

address the challenges it faces in providing screener training to guards. 

However, the program is in its beginning stages and there are still guards 

deployed to federal facilities who have not received required screener 

training. Screener training is essential to helping prevent unauthorized 

individuals and items from entering federal facilities. Thus, it is critical that 

FPS immediately provide this training to those guards who have not 

received it.
Page 11 GAO-13-694 Federal Protective Service

According to FPS officials, the agency requires its guards to receive 

training on how to respond to an active-shooter scenario, but we found 

that some guards have not received it. According to DHS, an active 

shooter is an individual killing or attempting to kill people in a confined 

and populated area. Since June 2009 there have been several incidents 

involving active-shooters at government facilities. For instance, in 2010 

an active-shooter opened fire in the Lloyd D. George Federal Courthouse 

in Las Vegas, Nevada, killing a security officer and wounding a deputy 

U.S. Marshal.

According to FPS officials, since 2010, it has provided training on how 

guards should respond during an active-shooter incident to guards as part 

of the 8-hour FPS-provided orientation training guards receive. FPS 

officials were not able to specify how much time is devoted to this

training, but said that it is a small portion of the 2-hour special situations 

training.11

However, when we asked contract guard company officials if their guards 

had received training on how guards should respond during activeshooter incidents, responses varied. For example, of the 16 contract 

guard companies we interviewed about this topic:

In addition, officials stated that guards hired before 2010 should 

have received this information during guard-company-provided training on 

the guards’ post orders (which outline the duties and responsibilities 

associated with each guard post and include information on responding to 

an active-shooter situation) during basic and refresher training.

• eight contract guard company officials stated that their guards have 

received active-shooter scenario training during orientation,

• five guard company officials stated that FPS has not provided activeshooter scenario training to their guards, and

• three guard companies stated that FPS had not provided activeshooter scenario training to their guards during the FPS-provided 

orientation training, but that the topic was covered in one of the 

following ways:

 11This training is provided during a block of training on special situations, which includes 

information on how guards should respond to situations other than their normal duties, 

such as reports of missing or abducted children, bomb threats, and active-shooter 

scenarios.

Some FPS Guards Have Not 

Received Training on How to 

Respond to an Active-Shooter 

Scenario
Page 12 GAO-13-694 Federal Protective Service

• during guard company-provided basic training or refresher training,

• FPS provided on-the-job instruction on the topic during post 

inspections, and

• FPS provided a link to an active-shooter training video, which the 

company shows its guards.

The six agencies we reviewed—State, the Holocaust Museum, NASA, 

PFPA, the Kennedy Center, and DOE—also recognize this threat and five 

of them require active-shooter response training for their contract guards. 

According to officials at DOE, the agency is in the process of requiring 

guards to complete active-shooter response training to ensure they are 

capable of addressing this threat and protecting facility occupants. 

Similarly, Holocaust Museum officials stated that they require this training 

because current trends in law enforcement warrant active-shooter 

response training for guards.

In May 2013, an FPS official stated that the agency is collaborating with 

its guard companies to develop a standardized national lesson plan for 

guards and revising the Security Guard Information Manual (SGIM). FPS 

officials stated that the lesson plan being developed is meant to 

standardize the training guards receive. However, according to the 

official, FPS has not yet decided whether the national lesson plan will 

specify countermeasures necessary to mitigate threats from active 

shooters. FPS does not have a timeline for developing or implementing a 

national lesson plan for guards. Until it develops one, some guards may 

continue to go without training on how guards should respond to incidents 

at federal facilities involving an active shooter.

FPS requires some contract guard company instructor certifications, but 

does not require guard company instructors to be certified to teach basic 

or refresher training or have any training in basic instructional techniques. 

According to ISC guidance, training is a critical component of developing 

a well-qualified guard force and all training should be done with a certified 

instructor or training organization.12

 12ISC, Best Practices for Armed Security Officers in Federal Facilities, April 2013, 2nd

Edition.

Similarly, Federal Law Enforcement 

FPS Does Not Require Guard 

Instructors to Be Certified for 

Some Training Courses
Page 13 GAO-13-694 Federal Protective Service

Training Accreditation Board (FLETA)13

In contrast to FPS, three of the six selected agencies that we reviewed 

(NASA, DOE, and the Holocaust Museum) require guard instructors to 

attend instructor training or to be certified by the agency. For example, 

NASA requires contract guard company instructors to be certified by a 

NASA training academy. NASA stated that instructor certification 

requirements have reduced legal liabilities, ensured standardization of 

training, and led to greater efficiency of its training programs throughout 

the agency. Under NASA’s instructor certification program, instructors 

must meet the following requirements, among others:

standards require that accredited 

training programs have an instructor development course and review 

process to ensure that instructors provide consistent, quality instruction. 

FPS requires that guard instructors be certified to provide training in CPR, 

first aid, AED, and firearms and have a minimum of 2 years of law 

enforcement, military, or security training experience. However, FPS has 

no certification requirements for instructors teaching the guards’ basic 

and refresher training, nor does FPS require instructors to be 

knowledgeable in instructional techniques. Basic training, which 

represents 64 hours of the initial 120 hours of training that guards receive, 

and the 40-hour refresher class cover topics included in the SGIM, such 

as access control and crime detection and response.

• completed training from the Federal Law Enforcement Training Center 

(FLETC);

• 2-week internship as a student instructor to observe and work with an 

established instructor, including an evaluation;

• physical fitness requirements;

• re-evaluation every 2 years to ensure instructors are effective and 

follow required lesson plans; and

• annual workshop for instructors on curriculum development.

 13The Federal Law Enforcement Training Accreditation Board is an independent body of 

DHS that accredits and provides standards for federal law-enforcement training programs, 

including the Federal Law Enforcement Training Center (FLETC), which provides training 

to FPS Inspectors.
Page 14 GAO-13-694 Federal Protective Service

Similarly, DOE requires that in addition to specific certifications for the 

level of training they provide, instructors must complete a basic instructor 

training course and be evaluated for competency at least once every 36 

months.

According to some of FPS’s guard companies, the absence of an 

instructor certification requirement has affected the quality of training 

provided to some guards. For example, 6 of FPS’s 31 contract guard 

companies stated that they have experienced problems related to training 

quality when taking over a contract from a previous guard company and 

employing guards who had worked for the previous company. The 

companies stated that they either retrained or did not hire guards who 

they believed had been inadequately trained by the previous company. In 

these situations, costs may be passed on to FPS via increased rates for 

guard services to account for the increased training costs to guard 

companies. Four of the 31 guard companies stated that they already have 

additional requirements or training for instructors. However, such 

additional requirements and training are on a company-by-company basis 

and do not necessarily conform to any standards. Sixteen of the guard 

companies and officials from FLETA and CALEA stated that FPS should 

standardize instructor training and certification requirements or require 

FPS certification for guard instructors. Such standardization would help 

ensure quality and consistency in the training received by guards 

providing protective services across GSA’s federal buildings. FPS officials 

stated that FPS reviews each instructor’s resume to ensure that 

instructors have the minimum qualifications necessary to provide guard 

instruction.

Some contract guard files we reviewed did not contain all required 

documentation. We reviewed 276 randomly selected (non-generalizeable)

guard files maintained by 11 of the 31 guard companies we interviewed 

and found that 212 files (77 percent) contained the required training and 

certification documentation, but 64 files (23 percent) were missing one or 

more required documents. See table 2 for information on the results of 

our review. These 64 files were maintained by 9 of the 11 companies. 

According to FPS’s policies and contracts for guard service, each contract 

guard company must maintain a file for each guard to document that all 

FPS training, certification, and qualification requirements have been met 

and are current. We examined the files against the required training, 

certification, and qualification documentation listed by FPS on the forms it 

uses to conduct its monthly file reviews. 

Twenty-three Percent 

of Contract Guard 

Files We Reviewed 

Did Not Have 

Required Training and 

Certification 

Documentation
Page 15 GAO-13-694 Federal Protective Service

Table 2: Total Missing Documents Identified in 64 of 276 Guard Files GAO Reviewed

Requirement

Number of instances of each missing

document

Copy of DL/State ID 1

Domestic Violence “Lautenberg” Form 1

Medical certification 1

Verified alien/immigration status 3

Current baton certification 3

Basic training 3

Firearms qualifications 3

First-aid certification 5

FPS screener training—8 hours 5

FPS orientation 8

Contractor employee fitness determination 12

CPR certification 12

AED certification 12

Refresher training 15

Pre-employment drug testing 16

Initial weapons training 17

Total 117a

Source: GAO Analysis of contract guard company data.

a

Some of the 64 files that were not in compliance with requirements were missing more than one 

required document, for a total of 117 missing documents.

As shown in table 2, the 64 guard files were missing 117 total documents.

For example:

• Three files were missing documentation of basic training, and 15 were 

missing documentation of refresher training, both of which cover the 

guards’ roles and responsibilities and duties such as access control.

• Five files were missing documentation of screener training, which as 

mentioned above, is meant to prepare guards to prevent prohibited 

items from being brought into federal facilities.

• Seventeen files were missing documentation of initial weapons 

training, which indicates guards have passed the 40-hour weapons 

training, including 32 hours of firearms training.
Page 16 GAO-13-694 Federal Protective Service

• One file was missing the form that certifies that a guard has not been 

convicted of a crime of domestic violence.

In addition to the 117 missing documents, there was no indication that 

FPS had monitored firearms qualifications in 68 of the 276 guard files 

reviewed. The other 208 files had a current firearms qualification form 

with an indication (such as initials or a signature) that FPS witnessed the 

qualification. The FPS Protective Security Officer (PSO) File Review 

Form lists documentation requirements as “Firearms Qualifications 

Witnessed by an FPS Employee,” but is not clear regarding whether 

documentation of the FPS witness is required in the file. Although FPS 

has taken some steps to address its challenges in this area, our previous 

recommendations are a guide to furthering its efforts. For example, we 

recommended that FPS rigorously and consistently monitor contract 

guard companies’ performance and step up enforcement against guard 

companies that are not complying with the terms of the contract. Although 

FPS agreed with this recommendation, it has yet to implement it. 

According to FPS officials, it plans to address this recommendation in the 

near future.

DHS agreed with our 2010 and 2012 recommendations to develop a 

comprehensive and reliable system for contract guard oversight, but it still 

does not have such a system. Without a comprehensive guard 

management system, FPS has no independent means of ensuring that its 

contract guard companies have met contract requirements, such as 

providing qualified guards to federal facilities. According to FPS officials, it 

plans to address this recommendation in the near future. GAO’s 

Standards for Internal Control in the Federal Government also states that 

program managers need access to data on agency operations to 

FPS Still Lacks 

Effective Management 

Controls to Ensure 

Guards Have Met 

Training and 

Certification 

Requirements

FPS Continues to Lack a 

Comprehensive System to 

Effectively Manage Guard 

Training, Certification, and 

Qualification Data
Page 17 GAO-13-694 Federal Protective Service

determine whether they are meeting goals for the effective and efficient 

use of resources. The standards state that such information should be 

captured and distributed in a form that permits officials to perform their 

duties efficiently.14

In the absence of a comprehensive guard-data-management system, 

FPS requires its guard companies to maintain files containing guard 

training and certification information and to submit a monthly report with 

this information to their CORs. FPS headquarters officials stated that the 

monthly reports are primarily to ensure that regional managers have 

access to training and certification information, although there are no 

requirements for regional officials to use or analyze the monthly reports. 

The officials stated that regions are occasionally asked to supply these 

reports to FPS headquarters as a check to ensure regions and guard

companies are sharing this information, but that headquarters officials do 

not analyze the data.

Although FPS does not have a system to track guard data, 13 of FPS’s 

31 guard companies maintain training, certification, and qualification data 

in either proprietary or commercially available software programs with 

various management capabilities. For example, one system used by 

multiple companies tracks the training and certification status of each 

guard and prevents the company from scheduling the guard to work if the 

guard is not in compliance with requirements. Virginia’s Department of 

Criminal Justice Services (DCJS) has a database system that also allows 

training academies, guards, and guard companies to upload training and 

certification documentation so that DCJS can track the training and 

certification status of guards. According to industry stakeholders and 

contract guard company officials, a comprehensive guard management 

system could:

• provide FPS direct access for updating guard training, certification, 

and qualification data while performing post inspections and other 

oversight activities such as file reviews;

• enable FPS and guard company officials to more easily develop 

reports and identify trends in data to recognize areas that need 

attention;

 14GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
Page 18 GAO-13-694 Federal Protective Service

• store training, certification, and qualification documentation, that could 

reduce the need to obtain documentation from a prior guard company 

when a new company takes over a contract; and

• help identify guards working under more than one FPS contract and 

verify that they do not work more than the maximum of 12 hours in 

one day.

FPS’s monthly reviews of contract guard companies’ guard files are its 

primary management control for ensuring that the companies are 

complying with contractual requirements for guards’ training, certification, 

and qualifications. FPS’s directive for monthly file reviews requires, for 

example, that:

• Ten percent of the guard files for each contract are to be selected 

randomly for the monthly review.

• Selected files should be compared to the data in the reports provided 

to FPS by the contract guard company that month.

• FPS reviewers must note any deficiencies in which the file 

documentation and dates do not match the data included in the 

monthly report and promptly notify the guard company, COR, and 

FPS regional program manager of the deficiencies.

• If there are deficiencies in 40 percent or more of the reviewed files, 

the region must immediately initiate an audit of 100 percent of the 

company’s guard files.

• Results should be recorded in FPS’s Administrative Audit Form and 

individual Protective Security Officer File Review Forms.

• An effort should be made to exclude files that have been reviewed 

within the last 6 months from the selection process.

FPS’s directive on its monthly file reviews does not include specific 

information about the importance of randomly selecting guard files and 

ensuring contract guard company personnel do not know which files will 

be reviewed. In the absence of specific guidance regarding how files are 

to be selected, the four regions we visited varied in how they conducted 

the monthly file reviews. For example, three of the four regions we visited 

told us that they review randomly selected files either at the guard 

company’s office or the guard company gives them electronic access to 

FPS Management Controls 

Do Not Ensure 

Consistency in Monthly 

File Review Process
Page 19 GAO-13-694 Federal Protective Service

the files for review. In contrast, officials in the fourth FPS region stated 

that they submit a list of the selected guard files to the guard company 24 

to 48 hours before the file review and request that the files be delivered 

either electronically or in hard copy to the regional office. As such, 

contract guard company officials in that region stated that they can review 

the selected files to ensure that they comply with requirements prior to 

delivering them to FPS. FPS headquarters officials stated that this 

indicates that guard company officials are performing due diligence to 

ensure the file is up to date. However, this practice decreases the utility of 

randomly selecting files for review and reduces the ability of FPS 

reviewers to accurately assess the guard company’s ongoing ability to 

keep all of its guard files up to date. Additionally, officials at a contract 

guard company in another FPS region stated that the COR occasionally 

asks the guard company to select the files for review and bring them to 

the regional office. FPS stated that this is not standard practice. Allowing 

contract guard company officials to select files for review by FPS could 

result in selection bias and affect the results of FPS’s review.

FPS headquarters officials stated that monthly file review results are 

reported to headquarters and that the data are combined into a 

spreadsheet, summarizing the number of deficiencies by contract, region, 

and nationally. Officials stated that these data are used to identify 

possible trends in vendor documentation and to determine if corrective 

actions need to be taken at the regional level. However, if file review 

results are affected by selection bias or by guard company actions to alter 

the contents of the files selected for review, these data may not lead to an 

accurate understanding of trends or the need for corrective action.

The Government Performance and Results Act Modernization Act of 2010 

requires agencies to develop an approach to validation and verification in 

order to assess the reliability of performance data.15

 15 Pub. L. No. 111-352, §3, 124 Stat. 3866, 3867 (Jan. 4, 2011).

However, FPS’s 

directive regarding monthly file reviews, discussed above, does not 

include requirements for reviewing and verifying the results of the file 

reviews. From March 2012 through March 2013, FPS reviewed more than 

23,000 guard files as part of its monthly review process. FPS found that a 

majority of the guard files had the required documentation but more than 

800 (about 3 percent) did not. FPS’s file reviews for that period showed 

FPS Lacks Guidance on 

Reviewing and Verifying 

File Review Results
Page 20 GAO-13-694 Federal Protective Service

files missing, for example, documentation of screener training, initial 

weapons training, CPR certification, and firearms qualifications. However, 

without an approach to reviewing and verifying results, FPS is not able to 

use these results to accurately assess the performance of its contract 

guard companies in complying with training and certification 

requirements.

As part of its monthly file reviews for November 2012 through March 

2013, FPS reviewed some of the same guard files we examined, but our 

results differed substantially from what FPS found. Specifically, we 

compared the results of FPS’s file reviews for the 11 contracts for which 

we conducted file reviews; we found that 29 of the 276 files we reviewed 

had also been reviewed by FPS. FPS’s review and our examination of 

each file occurred in the same month. For each of the 29 files, FPS did 

not identify any missing documentation. In contrast, we found that 6 of the 

29 files did not have the required training and certification documentation 

(and some were missing more than one required document). In 4 of the 6 

guard files, FPS’s review indicated that required documentation was 

present, but we were not able to find documentation of training and 

certification, such as initial weapons training, DHS orientation, and preemployment drug screenings. We also identified files with expired 

documentation. For example, 2 of the 6 files had expired refreshertraining documentation and another guard file had expired firearms 

qualification documentation. Since we used FPS’s file review checklist to 

conduct our file review, it is unclear why the results differed. FPS officials 

were unsure about the reasons for this, but stated that human error and 

contract requirements that differ from the requirements listed on 

administrative audit forms may have been factors.

Additionally, differing results may be due to differences in the type of 

documentation accepted by GAO and FPS. For example, in our review of 

FPS monthly file review records for one contract, we identified 2 files for 

which, according to the PSO file review form, the FPS reviewer accepted 

documentation of CPR and AED training that we did not accept as valid. 

While FPS guard contracts require guard files to contain a copy of the 

CPR and AED certification card, the FPS reviewer accepted a roster of 

individuals who attended the training. However, the roster did not indicate 

whether attendees had passed the course or been officially certified and 

was not signed by an instructor.

FPS can take action against guard companies if it determines that a 

contract guard company has not complied with contractual requirements, 

but it may not have accurate information to do so. FPS’s contracts for 
Page 21 GAO-13-694 Federal Protective Service

guard services state that if guard companies do not comply with contract 

requirements (e.g., guard training, certification, and qualification 

requirements), FPS may require the contractor to take actions to ensure 

compliance in the future and also may reduce the contract price to reflect 

the reduced value of the service provided. Determining the extent to 

which FPS took actions against guard companies for not complying with 

guard training and certification requirements was not within the scope of 

our engagement. However, the results of our comparison of FPS’s guard 

file reviews to our reviews raises questions about whether FPS has 

effective management controls in place to identify areas in which guard 

companies have not complied with requirements.

FPS continues to lack the management controls to ensure that its 

approximately 13,500 contract guards have the required training, 

certification, and qualifications, which are central to effectively protecting 

employees and visitors in federal facilities. FPS agreed with the 

recommendations in our 2010 and 2012 reports. We recommended, 

among other things, that FPS develop and implement a comprehensive 

system for guard oversight. Without such a system, among other things, 

FPS has no independent means of ensuring that its 13,500 guards 

deployed to federal facilities are properly trained and qualified. As such, 

we strongly encourage FPS to continue addressing the challenges we 

identified in our prior work and to be more proactive in managing its 

contract guard workforce. Although FPS has taken steps to address some 

of our prior recommendations, we found that FPS still has challenges 

providing screener training to some guards. Consequently, some guards 

deployed to federal facilities may be using x-ray and magnetometer 

equipment that they are not qualified to use. This raises questions about 

the capability of some guards to screen access control points at federal 

facilities─one of their primary responsibilities.

According to FPS officials, the agency has recently decided to make 

changes to its guard program, including developing a national lesson 

plan. We agree with this decision, given the problems that we have 

identified. A national lesson plan could help FPS standardize and ensure 

consistency in its training efforts. For example, without ensuring that all 

guards receive training on how to respond to incidents at federal facilities 

involving an active shooter, FPS has limited assurance that its guards are 

prepared for this threat. Similarly, the lack of certification requirements for 

instructors who teach basic and refresher training may ultimately affect 

guards’ ability to perform their duties.

Conclusions
Page 22 GAO-13-694 Federal Protective Service

Finally, inconsistencies in how FPS regional officials conduct monthly file 

reviews (which are FPS’s primary management control for ensuring 

compliance with the guard contract requirements) indicate that the current 

guidance for monthly file reviews is insufficient to ensure that, for 

instance, guard companies do not have the opportunity to select files for 

review and thus affect the results of the file reviews. Further, our work 

raises questions about the reliability and quality of FPS’s monthly file 

reviews. These findings are of particular concern given that FPS 

continues to pay guard companies over half a billion dollars annually to 

provide qualified guards yet it appears that some guards have been 

deployed to federal facilities without meeting all of the training, 

certification, and qualification requirements.

To improve the management and oversight of FPS’s contract guard 

program, we recommend that the Secretary of Homeland Security direct 

the Under Secretary of NPPD and the Director of FPS to take the 

following three actions:

• take immediate steps to determine which guards have not had 

screener or active-shooter scenario training and provide it to them 

and, as part of developing a national lesson plan, decide how and 

how often these trainings will be provided in the future

• require that contract guard companies’ instructors be certified to teach 

basic and refresher training courses to guards and evaluate whether a 

standardized instructor certification process should be implemented; 

and

• develop and implement procedures for monthly guard-file reviews to 

ensure consistency in selecting files and verifying the results.

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

concurred with our recommendations and provided written comments that 

are reprinted in appendix II. DHS also provided technical comments, 

which we incorporated as appropriate.

Recommendations for 

Executive Action

Agency Comments
Page 23 GAO-13-694 Federal Protective Service

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to appropriate 

congressional committees, the Secretary of Homeland Security, and other 

interested parties. In addition, the report will be available at no charge on 

GAO’s web site at http//www.gao.gov.

If you have any questions about this report, please contact me at (202) 

512-2834 or goldsteinm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III.

Sincerely yours,

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Status of GAO’s 2010 and 2012 

Recommendations to the Department of 

Homeland Security’s Federal Protective 

Service

Page 24 GAO-13-694 Federal Protective Service

Table 3: Status of GAO’s 2010 and 2012 Recommendations to the Department of Homeland Security’s Federal Protective 

Service

GAO Reports Recommendations Status

Homeland Security: Federal Protective Services 

Contract Guard Program Requires More Oversight 

and Reassessment of Use of Contract Guards, 

GAO-10-341, April 2010

Identify other approaches and options that would be 

most beneficial and financially feasible for protecting 

federal facilities.

Not Implemented

Rigorously and consistently monitor guard contractors’ 

and guards’ performance and step up enforcement 

against contractors that are not complying with the terms 

of the contract.

Not Implemented

Complete all contract performance evaluations in 

accordance with FPS and Federal Acquisition 

Regulation requirements.

In process

Issue a standardized record-keeping format to ensure 

that contract files have required documentation.

In process

Develop a mechanism to routinely monitor guards at 

federal facilities outside metropolitan areas.

Not Implemented

Provide building-specific and scenario-based training 

and guidance to its contract guards.

Not Implemented

Develop and implement a management tool for ensuring 

that reliable, comprehensive data on the contract guard 

program are available on a real-time basis.

Not Implemented

Verify the accuracy of all guard certification and training 

data before entering them into RAMP, and periodically 

test the accuracy and reliability of RAMP data to ensure 

that FPS management has the information needed to 

effectively oversee its guard program. 

Not Implemented

Federal Protective Service: Actions Needed to Asses 

Risk and Better Manage Contract Guards at Federal 

Facilities, GAO-12-739, August 2012. 

Incorporate NIPP’s risk management framework—

specifically in calculating risk to include threat, 

vulnerability, and consequence information—in any 

permanent risk assessment tool.

Not Implemented

Coordinate with GSA and other federal tenant agencies 

to reduce any unnecessary duplication in security 

assessments of facilities under the custody and control 

of GSA

Not Implemented

Address MIST’s limitations (assessing consequence, 

comparing risk across federal facilities, and measuring 

performance) to better assess and mitigate risk at 

federal facilities until a permanent system is developed 

and implemented.

Not Implemented

Develop and implement a new comprehensive and 

reliable system for contract guard oversight.

Not Implemented

Verify independently that FPS’s contract guards are 

current on all training and certification requirements.

Not Implemented

Source: GAO.

Appendix I: Status of GAO’s 2010 and 2012 

Recommendations to the Department of 

Homeland Security’s Federal Protective 

Service
Appendix II: Comments from the Department 

of Homeland Security

Page 25 GAO-13-694 Federal Protective Service

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 26 GAO-13-694 Federal Protective Service
Appendix II: Comments from the Department 

of Homeland Security

Page 27 GAO-13-694 Federal Protective Service
Appendix III: GAO Contact and 

Staff Acknowledgments

Page 28 GAO-13-694 Federal Protective Service

Mark Goldstein, (202) 512-2834, GoldsteinM@gao.gov

In addition to the contact name above, Tammy Conquest, Assistant 

Director; Antoine Clark; Colin Fallon; Kathleen Gilhooly; Katherine Hamer; 

Amanda Miller; Ramon Rodriguez; William Woods; and Gwyneth 

Woolwine made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(543312)
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