United States Government Accountability Office

GAO Report to Congressional Requesters

DEPARTMENT OF 

HOMELAND 

SECURITY 

Better Planning and 

Assessment Needed to 

Improve Outcomes for 

Complex Service 

Acquisitions 

April 2008 

 

GAO-08-263 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

April 2008

DEPARTMENT OF HOMELAND SECURITY

Better Planning and Assessment Needed to Improve 

Outcomes for Complex Service Acquisitions

Highlights of GAO-08-263, a report to 

congressional requesters 

The Department of Homeland

Security (DHS) has relied on 

service acquisitions to meet its 

expansive mission. In fiscal year

2006, DHS spent $12.7 billion to 

procure services. To improve 

service acquisition outcomes, 

federal procurement law

establishes a preference for a 

performance-based approach,

which focuses on developing 

measurable outcomes rather than 

prescribing how contractors should

perform services. 

GAO was asked to (1) evaluate the 

implementation of a performancebased approach in the context of

service acquisitions for major, 

complex investments, and (2) 

identify management challenges 

that may affect DHS’s successful

acquisitions for major investments, 

including those using a 

performance-based approach. 

GAO reviewed judgmentally

selected contracts for eight major

investments at three DHS 

components totaling $1.53 billion in 

fiscal years 2005 and 2006; prior 

GAO and DHS Inspector General 

reviews; management documents 

and plans; and related data,

including 138 additional contracts 

for basic services. 

What GAO Recommends

DHS generally concurred with 

GAO’s recommendations that DHS 

develop measurable standards 

consistently linked to well-defined 

requirements, evaluate acquisition 

outcomes for major investments, 

and improve data quality to help 

identify and assess contracting 

methods and outcomes. 

All service contracts for the eight major, complex investments GAO reviewed had 

outcome-oriented requirements; however, four of these contracts did not have 

well-defined requirements, a complete set of measurable performance 

standards, or both. These service contracts experienced cost overruns, 

schedule delays, or did not otherwise meet performance expectations. In 

contrast, service contracts for the other four investments GAO reviewed had 

well-defined requirements linked to measurable performance standards. 

Contractors had begun work on three of these four contracts and performed within 

budget meeting the standards. This finding is consistent with prior GAO work 

on service acquisitions, which has highlighted the criticality of sound 

acquisition planning to develop well-defined requirements and measurable 

performance standards to achieving desired outcomes. In the four cases that 

had negative outcomes, program officials identified the contractor 

performance weaknesses through quality assurance surveillance and took 

corrective actions. Prior GAO work has found that if acquisitions, including 

those that are performance-based, are not appropriately planned, structured, 

and monitored, there is an increased risk that the government may receive 

products or services that are over budget, delivered late, and of unacceptable 

quality. 

In managing its service acquisitions, including those that are performance 

based, DHS has faced workforce and oversight challenges. Prior GAO work 

has highlighted the importance of having the right people with the right skills 

to achieve successful acquisition outcomes. Contracts for two major 

investments with negative cost and schedule outcomes did not have the staff 

needed to adequately plan and execute the contracts. Further, while 

representatives for several of the contracts GAO reviewed indicated that 

contracting and program staff worked well together, some senior acquisition 

representatives at the component level indicated that a lack of collaboration 

between these key stakeholders has been a challenge when developing and 

managing complex service acquisitions. In terms of oversight, component 

contracting and program officials said they used a performance-based approach to 

the maximum extent practicable; however, DHS does not have reliable data to 

facilitate required reporting, informed decisions, and analyzing acquisition 

outcomes. GAO’s review also found that about half of an additional 138 

contracts for basic services identified as performance-based did not have any 

of the elements intended to foster good outcomes: a performance work 

statement, measurable performance standards, and a quality assurance 

surveillance plan. DHS’s Chief Procurement Officer (CPO)—who is 

responsible for departmentwide oversight of acquisitions—has several efforts 

under way to address some of these workforce and oversight issues. One

initiative is an acquisition oversight program that is intended to assess (1) 

compliance with federal acquisition guidance, (2) contract administration, and 

(3) business judgment. However, this oversight program has not yet included 

an evaluation of the outcomes of contracting methods such as performancebased service acquisition. 

To view the full product, including the scope 

and methodology, click on GAO-08-263. 

For more information, contact John Hutton 

(202) 512-4841 or huttonj@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 5

Definition of Requirements and Performance Standards Influenced 

Contract Outcomes 8 

DHS Has Faced Workforce and Oversight Challenges in Managing 

Its Service Acquisitions 19 

Conclusions 26

Recommendations for Executive Action 26 

Agency Comments and Our Evaluation 27 

Appendix I Scope and Methodology 29 

Appendix II Comments from the Department of Homeland 

Security 32 

Appendix III GAO Contact and Staff Acknowledgments 35

Tables 

Table 1: Key Characteristics of Eight Performance-Based Service 

Contracts 9

Table 2: Less Than Expected Performance Identified through 

Surveillance and Action Taken 18 

Table 3: Review of Performance-Based Elements on Selected

Contracts 23

Figure 

Figure 1: Percent of Contracts and Obligations by Contract Type 

for 42 DHS Performance-Based Service Acquisitions 

(Fiscal Years 2005 and 2006) 25 

Page i GAO-08-263 DHS Service Acquisitions 
Abbreviations 

ACE Automated Commercial Environment 

CBP Customs and Border Protection 

CPO Chief Procurement Officer 

DHS Department of Homeland Security 

FAR Federal Acquisition Regulation 

FEMA Federal Emergency Management Agency 

FPDS-NG Federal Procurement Data System-Next Generation 

ICE Immigration and Customs Enforcement 

NPI National Prime Integration 

OFPP Office of Federal Procurement Policy 

SBInet Secure Border Initiative Network 

TSA Transportation Security Administration 

TWIC Transportation Worker Identification Credential 

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 ii GAO-08-263 DHS Service Acquisitions 
United States Government Accountability Office

Washington, DC 20548 

 

April 22, 2008

The Honorable Joseph I. Lieberman 

Chairman 

The Honorable Susan M. Collins 

Ranking Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Daniel K. Akaka 

Chairman 

The Honorable George V. Voinovich

Ranking Member 

Subcommittee on Oversight of Government Management, the 

Federal Workforce and the District of Columbia 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Bennie G. Thompson

Chairman 

Committee on Homeland Security 

House of Representatives 

In fiscal year 2006, the Department of Homeland Security (DHS) spent 

$12.7 billion on services, representing more than 80 percent of its total 

procurement spending for that year. DHS has relied on service acquisitions 

to meet its expansive homeland security mission. However, prior GAO 

work has found that if acquisitions are not appropriately planned, 

structured, and monitored, there is an increased risk that the services 

provided will not fulfill intended acquisition outcomes or, ultimately, meet 

government needs.1

To help improve service acquisition outcomes, federal procurement policy 

calls for agencies to use a performance-based approach to the maximum 

extent practicable. This approach includes: a performance work statement 

that describes outcome-oriented requirements, measurable performance 

standards, and quality assurance surveillance. These characteristics, if 

properly implemented, can help ensure that the services meet cost, 

 1

 GAO, Defense Acquisitions: Tailored Approach Needed to Improve Service Acquisition

Outcomes, GAO-07-20 (Washington, D.C.: Nov. 9, 2006). 

Page 1 GAO-08-263 DHS Service Acquisitions 
schedule, and performance requirements. Since this concept was 

introduced in the 1990s, it has become widely accepted as a sound 

acquisition approach. 

Despite its governmentwide acceptance, concerns have been raised about 

how well agencies are using a performance-based approach, particularly 

for complex or major investments. Given the significant amount of DHS 

spending on services and its critical mission, you asked us to (1) evaluate

the implementation of a performance-based approach in the context of 

service acquisitions for major, complex investments; and (2) identify 

management challenges that may affect DHS’s successful implementation 

of service acquisitions for major investments, including those using a 

performance-based approach. 

To conduct our work, we focused on the Coast Guard, Customs and 

Border Protection (CBP), Immigrations and Custom Enforcement (ICE), 

and the Transportation Security Administration (TSA)—four of the five 

DHS components reporting the highest obligations for performance-based 

service acquisitions in fiscal years 2005 and 2006.2

 To evaluate DHS’s 

implementation of a performance-based approach in the context of service 

acquisitions for major investments,3

 we judgmentally selected eight major 

investments at the Coast Guard, CBP, and TSA4 based on size and 

complexity, and reviewed actions for one performance-based service 

contract associated with each investment.5

 These contracts had a 

combined estimated value of $1.53 billion and included services provided 

in the acquisition and sustainment phases of the investments.6

 We assessed 

these contracts against acquisition regulations and policy and interviewed

contracting and program management staff. Performance-based service

 2

We excluded the Federal Emergency Management Agency (FEMA) because of atypical 

fiscal year 2006 spending on Gulf Coast hurricane relief efforts. 

3

DHS has categorized major investments as Levels 1 and 2 and Level 3 (information 

technology). For the purposes of our review, we focused on Level 1 investments. A Level 1 

major investment is defined in DHS Management Directive 1400 as an investment with 

greater than $100 million in total acquisition costs including planning, or for information 

technology investments, a life-cycle cost greater than $200 million. 

4

ICE officials told us that none of their major investments used a performance-based 

approach. 

5

We reviewed either the contract or selected orders on the contract. 

6

DHS’s investment review process includes three phases: pre-acquisition, acquisition, and 

sustainment. The acquisition phase includes systems development, and the sustainment 

phase includes operations and maintenance. 

Page 2 GAO-08-263 DHS Service Acquisitions 
acquisitions were difficult to identify and were not clearly distinct from 

other service acquisitions because they did not always include all required

elements. Therefore, we reviewed prior GAO reports and DHS Inspector 

General reports to provide a broader context on DHS’s major service 

acquisitions. 

To identify management challenges that may affect DHS’s successful 

implementation of service acquisitions for major investments, we analyzed

management documents and plans; staffing data; and oversight 

mechanisms, including the Federal Procurement Data System-Next 

Generation (FPDS-NG), the governmentwide database for procurement 

spending. From FPDS-NG, we judgmentally selected 138 contracts for 

primarily basic services coded as performance-based and awarded in fiscal 

years 2005 or 2006 at Coast Guard, CBP, ICE, and TSA with obligations 

greater than $1 million dollars and asked the components to verify 

whether these contracts included the required performance-based 

elements. Finally, we interviewed contracting and program management 

staff and DHS Chief Procurement Office (CPO) representatives and met 

with representatives from the Office of Management and Budget’s Office 

of Federal Procurement Policy (OFPP). For more information on our 

scope and methodology, see appendix I. 

We conducted this performance audit from January 2007 to April 2008 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. 

All service contracts for the eight major, complex investments we 

reviewed had outcome-oriented requirements, but the requirements were 

not always well-defined. Four of the eight contracts we reviewed did not 

have well-defined requirements, or a complete set of measurable 

performance standards, or both at the time of contract award or start of 

work. These service contracts experienced cost overruns, schedule delays, 

or did not otherwise meet performance expectations. In contrast, service 

contracts for the other four investments had well-defined requirements 

linked to measurable performance standards. Contractors had begun work 

on three of these four contracts and performed within budget meeting the 

standards. This finding is consistent with our prior work on service 

contracting, which has highlighted the criticality of sound acquisition 

planning to develop stable, well-defined requirements and measurable 

Results in Brief 

Page 3 GAO-08-263 DHS Service Acquisitions 
performance standards to achieving desired outcomes. Components 

conducted quality assurance surveillance for the contracts we reviewed. 

For the four contracts that had negative outcomes, surveillance helped 

DHS components to identify contractor performance weaknesses and 

corrective actions were taken. Prior GAO work has found that if 

acquisitions, including those that are performance-based, are not 

appropriately planned, structured, and monitored, there is an increased 

risk that the government may receive products or services that are over 

budget, delivered late, and of unacceptable quality. 

In managing its service acquisitions, including those that are performancebased, DHS has faced workforce and oversight challenges. Our prior work 

has highlighted the importance of having the right people with the right 

skills to achieve successful acquisition outcomes. Contracts for two of the 

eight major investments we reviewed that had negative cost or schedule 

outcomes did not have the staff needed to adequately plan and execute the 

contracts. Further, while representatives for several of the contracts we 

studied indicated contracting and program staff worked together 

effectively, at the component level, senior acquisition representatives 

indicated that a lack of collaboration between the program and 

contracting offices in general has been challenging. In terms of oversight,

DHS component contracting and program staff told us they used a 

performance-based approach to the maximum extent practicable; 

however, the department does not have reliable data to facilitate reporting

or perform management assessments of these acquisitions. Moreover, 

while the CPO has implemented a departmentwide acquisition oversight 

program, the CPO has not performed management assessments of 

performance-based service acquisitions. Our review of an additional 138 

contracts for primarily basic services found that about half of the 

contracts identified as performance-based in FPDS-NG did not have any of 

the three elements: a performance work statement, measurable 

performance standards, and a quality assurance surveillance plan, which 

are intended to foster good outcomes. Inaccurate data limit DHS’s 

visibility over service acquisitions and the department’s ability to make 

informed acquisition management decisions. DHS’s CPO has several 

efforts under way to address departmentwide workforce and oversight 

challenges. One initiative is an acquisition oversight program that is 

intended to assess (1) compliance with federal acquisition guidance, (2) 

contract administration, and (3) business judgment. However, this 

oversight program has not yet included an evaluation of the outcomes of 

contracting methods such as performance-based service acquisition. 

Page 4 GAO-08-263 DHS Service Acquisitions 
To increase DHS’s ability to improve outcomes for its service acquisitions, 

including those that are performance-based, we are recommending that

the Secretary of Homeland Security take several actions. These actions 

include improving acquisition planning for requirements for major, 

complex investments to ensure they are well-defined, and developing 

consistently measurable performance standards linked to those 

requirements; systematically evaluating the outcomes of major 

investments and relevant contracting methods at a departmentwide level; 

and improving the quality of FPDS-NG data so that DHS can more 

accurately identify and assess the use and outcomes of various contracting 

methods. In written comments on a draft of this report, DHS generally

concurred with our recommendations and provided some information on 

efforts under way to improve acquisition management. The department’s 

comments are reprinted in appendix II. OMB did not comment on the 

findings or conclusions of this report. DHS and OMB each provided 

technical comments, which we incorporated as appropriate and where 

supporting documentation was provided. 

Over the last decade, the use of federal service contracting has increased 

and now accounts for over 60 percent of federal procurement dollars 

spent annually. Prior GAO work has found that if acquisitions are not 

appropriately planned, structured, and monitored, there is an increased 

risk that the services provided will not fulfill intended acquisition 

outcomes or, ultimately, meet agency needs. 

Background 

A performance-based approach, if successfully implemented, can help 

improve service acquisition outcomes. This concept—introduced during 

the 1990s—represented a shift in emphasis from specifying methods in 

which contracted work should be performed to specifying acquisition 

outcomes. In 2000, federal procurement law established a performancebased approach as the preferred acquisition method for services.7

 The FAR 

requires all performance-based service acquisitions to include: 

 7

Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001, Pub. L. No. 106-

398 § 821(a) (2000) required that the Federal Acquisition Regulation (FAR) be revised to

establish a preference for the use of a performance-based approach in the acquisition of 

services, which was done in FAR 37.102(a), providing that performance-based acquisition 

is the preferred method for acquiring services and generally is to be used to the maximum 

extent practicable. 

Page 5 GAO-08-263 DHS Service Acquisitions 
• a performance work statement that describes outcome-oriented 

requirements in terms of results required rather than the methods of 

performance of the work; 

• measurable performance standards describing how to measure 

contractor performance in terms of quality, timeliness, and quantity; 

and 

• the method of assessing contract performance against performance 

standards, commonly accomplished through the use of a quality 

assurance surveillance plan.8

In addition, federal procurement law established a preference for using 

firm fixed-price contracts or task orders—where a specified price is paid 

regardless of the contractor’s incurred costs—when using a performancebased approach for service acquisitions.9

 A performance-based acquisition 

approach also calls for greater collaboration among procurement and 

program representatives throughout the contract period and often requires

more time for acquisition planning and management than other 

contracting methods. Agencies may also involve the contractor in the 

multi-functional team responsible for developing performance-based 

acquisition planning documents to leverage the contractor’s technical 

expertise. Including stakeholders with varied knowledge and skills enables 

acquisition teams to determine at the earliest point possible that all 

aspects of the acquisition are necessary, executable, and tailored to the 

transaction’s risk level. Regardless of the contracting method, focusing on 

outcomes and collaboration among multiple stakeholders in the 

contracting process has been acknowledged as sound contract 

management. Other factors, such as pressure to get programs up and 

running, additional external requirements, and technological challenges 

also impact the ability to achieve good acquisition outcomes. 

A 1998 OFPP study on performance-based contracts—based largely on

contracts for basic services, such as janitorial or maintenance services—

showed that a number of anticipated benefits had been achieved: reduced 

acquisition costs, increased competition for contracts, and improved 

 8

FAR 37.601; FAR 37.602(b); FAR 37.604. A fourth element, performance incentives, is 

required where appropriate. 

9

Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001, Pub. L. No. 106-

398, § 821(a) (2000); FAR 37.102(a). 

Page 6 GAO-08-263 DHS Service Acquisitions 
contractor performance.10 However, our prior work and the work of others 

has found that implementing a performance-based approach is often more 

difficult for complex acquisitions because agencies begin with

requirements that are less stable, making it difficult to establish 

measurable outcomes. OFPP has noted in policy that certain types of 

services, such as research and development, may not lend themselves to 

outcome-oriented requirements.11 CPO representatives also have noted 

that defining outcome-oriented requirements and measurable performance 

standards may be more challenging for certain types of services, such as 

research and development or professional and management support 

services. Further, complex service contracts, such as those for information 

technology, may need to have requirements and performance standards 

continually refined throughout the life-cycle of the acquisition for a 

contractor to deliver a valuable service over an extended period of time. 

To encourage agencies to apply a performance-based approach to service

acquisitions, the Office of Management and Budget established 

governmentwide performance targets: 20 percent of eligible service 

contract dollars for fiscal year 2002, 40 percent for fiscal year 2005 and 

fiscal year 2006, 45 percent for fiscal year 2007, and 50 percent for fiscal 

year 2008. 

In 2007, the congressionally mandated Acquisition Advisory Panel12

reported on the implementation of a performance-based approach and 

concluded that agencies were not clearly defining requirements, not 

identifying meaningful quality measures, not effectively managing the 

contract, and had limited data to make informed decisions. The panel

made recommendations to improve application of the performance-based 

approach in three areas: goal setting and management, guidance for 

acquisition staff, and data quality.13 For example, the panel recommended 

 10Office of Management and Budget, Office of Federal Procurement Policy, A Report on the 

Performance-Based Service Contracting Pilot Project, May 1998. 

11Office of Federal Procurement Policy Memorandum, “Increasing the Use of Performancebased Service Acquisitions,” September 7, 2004. 

12Services Acquisition Reform Act of 2003, Title XIV, National Defense Authorization Act 

for Fiscal Year 2004, Pub. L. No. 108-136, § 1423 (2003); National Defense Authorization Act 

for Fiscal Year 2006, Pub. L. No. 109-163, § 843 (2006) (extended the deadline for the

Panel’s report by 6 months).

13Report of the Acquisition Advisory Panel to the Office of Federal Procurement Policy and 

the United States Congress, January 2007. 

Page 7 GAO-08-263 DHS Service Acquisitions 
that the Office of Management and Budget adjust the governmentwide 

target to reflect individual agency assessments and plans. 

In May 2007, OFPP issued a memo directing agencies, at a minimum, to 

meet targets established and report on them in their management plans. In 

response, DHS’s CPO, who is responsible for creating departmentwide 

policies and processes for managing and overseeing the acquisition 

function, established a performance-based target of 25 percent for fiscal 

year 2007, increasing to 40 percent by fiscal year 2010, that was included in

DHS’s Performance-Based Management Plan. Meeting these targets is a 

responsibility shared between the CPO and the component heads, in 

accordance with DHS’ system of dual accountability for managing the 

acquisition function.14

Requirements definition and performance standards influenced outcomes 

for performance-based contracts associated with eight major, complex 

investments. While all eight contracts for the investments we reviewed had 

outcome-oriented requirements, the requirements were not always welldefined.15 Further, contracts for half of the investments did not have a 

complete set of measurable performance standards. Major investments 

with contracts that did not have well-defined requirements or complete 

measurable performance standards at the time of contract award or start 

of work experienced either cost overruns, schedule delays, or did not 

otherwise meet performance expectations. Conversely, contracts with 

well-defined requirements linked to measurable performance standards 

delivered results within budget and provided quality service. This finding

is consistent with our body of work on service contracting, which has 

Definition of 

Requirements and 

Performance 

Standards Influenced 

Contract Outcomes 

 14Responsibility for the acquisition function at DHS is shared between the CPO and each 

DHS component head. Eight DHS components have internal procurement offices with a 

Head of Contracting Activity (HCA) who reports directly to the component head and is

accountable to the CPO. The eight components are: Coast Guard, CBP, FEMA, Federal Law

Enforcement Training Center, ICE, Office of Procurement Operations, Secret Service, and 

TSA. The HCA for each component has overall responsibility for the day-to-day 

management of the component’s acquisition function. See GAO, Department of Homeland 

Security: Progress and Challenges in Implementing the Department’s Acquisition 

Oversight Plan, GAO-07-900 (Washington, D.C.: June 2007).

15In using the performance-based approach, sound contracting practices dictate that 

required contract outcomes or requirements be well-defined, providing clear descriptions 

of results to be achieved. FAR 2.101 specifically provides that a performance work

statement for performance-based acquisitions describe the required results in clear, 

specific, and objective terms with measurable outcomes.

Page 8 GAO-08-263 DHS Service Acquisitions 
emphasized the importance of sound acquisition planning to develop welldefined requirements and measurable performance standards to achieve 

desired results. Table 1 summarizes our analysis of the requirements, 

performance standards, and outcomes for the eight performance-based 

contracts we reviewed. Component program staff conducted surveillance 

for these contracts, and in the four cases that had negative outcomes, 

identified less than expected performance and took action.

Table 1: Key Characteristics of Eight Performance-Based Service Contracts 

Major investment by

component Service

Well-defined

requirementsa

Measurable 

performance 

standardsb

Outcomes 

Coast Guard

Response Boat 

Medium 

Research, analysis, and 

financial and information 

management z z

Contractor submitted all required documentation 

on time; met project management quality 

standards; and maintained electronic archiving 

and restoration standards. 

Customs and Border Protection

Automated 

Commercial 

Environment 

Trade systems software 

development (task order 

23) 

{ 

Costs increased by 40 percent ($21.1 million). 

More than a year behind schedule; unplanned 

software redesign. 

National Prime

Integration 

Maintenance of

equipment used at 

border crossings, 

airports, and seaports 

z 

Costs increased by 53 percent ($24 million). 

Maintenance wait times were longer than 

planned. 

SBInet Project 28 border 

surveillance systems 

development and fielding 

{ 

DHS rejected initial acceptance of Project 28. 

The project was delayed 8 months with final 

acceptance in February 2008. DHS noted that 

the contractor met the requirements, but the 

project did not fully meet DHS’s needs and the 

technology will not be replicated in future SBInet

development. 

Transportation Security Administration

Electronic Baggage 

Screening Program 

Maintenance for 

explosive trace detection 

machines 

z z

Contractor exceeded the performance standard 

for machine downtime with a score 1 hour less 

than required and operated at cost through the 

second quarter of fiscal year 2007. 

Screening Partnership

Program 

Passenger screening 

services at one airport 

z z

Contractor exceeded most performance 

standards; for example: threat detection 

performance and false alarm rates exceeded the 

quality standards. Contractor had cost underrun 

of 2.2 percent ($677,000). 

Page 9 GAO-08-263 DHS Service Acquisitions 
Major investment by

component Service 

Well-defined

requirementsa

Measurable 

performance 

standardsb

Outcomes 

Secure Flight Maintaining database 

used to screen airline 

passenger data z 

Initial contractor planning reports were 

inadequate; system experienced operational 

downtime; surveillance reports identified poor

contractor performance. Contractor generally met 

time frames and delivered within budget. 

Transportation Worker 

Identification 

Credential 

Issuing identification 

credentials to maritime 

workers 

z z

Outcomes not available at the time of our review.

Legend: z contract met or mostly met the criteria;  contract partially met the criteria; { contract did 

not meet the criteria 

Source: GAO analysis.

a

Well-defined requirements should provide clear descriptions of results to be achieved at the time of 

the award or start of work and primary requirements should not change substantially following 

contract award. 

b

The set of measurable performance standards for a contract enables the government to assess all 

aspects of the contractor’s work in terms of quality, timeliness, and quantity. The contract’s

performance standards are also linked to the requirements. 

Contracts That Lacked 

Stable, Well-Defined 

Requirements, Complete 

Measurable Performance 

Standards, or Both 

Experienced Negative 

Outcomes 

Although all contracts we reviewed for the eight major, complex 

investments had outcome-oriented requirements, contracts for four 

investments—two for systems development and two for operations and 

maintenance—did not have stable and well-defined requirements, a full 

complement of measurable performance standards, or both. These four 

contracts experienced schedule delays, cost increases, or other negative 

outcomes. Prior GAO and DHS Inspector General work on other DHS 

major investments have similarly found that when requirements were not 

well-defined, performance did not meet expectations. Our work has found 

that performance-based acquisitions must be appropriately planned and 

structured to minimize the risk of the government receiving services that

are over cost estimates, delivered late, and of unacceptable quality.16

Specifically, we have emphasized the importance of clearly defined 

requirements to achieving desired results and measurable performance 

standards to ensuring control and accountability.17

 16GAO, Coast Guard: Observations on the Fiscal Year 2008 Budget, Performance, 

Reorganization, and Related Challenges, GAO-07-489T (Washington D.C.: Apr. 18, 2007).

17GAO-07-20; and GAO, Coast Guard: Status of Efforts to Improve Deepwater Program

Management and Address Operational Challenges, GAO-07-575T (Washington D.C.: Mar.

8, 2007). 

Page 10 GAO-08-263 DHS Service Acquisitions 
Two CBP systems development contracts lacked both well-defined 

requirements and measurable performance standards prior to the start of 

work. The first—ACE Task Order 23 project, a trade software 

modernization effort under a letter contract18—was originally estimated to 

cost $52.7 million over a period of approximately 17 months. DHS 

contracting representatives told us that some technical requirements were 

not fully defined within the original scope of work, and some new 

software requirements were added after contract award. Because many 

requirements were not fully defined in advance of the contract’s award, 

the program was unable to establish clear, measurable performance 

standards and valid cost or schedule baselines for assessing contractor 

performance. The need to redefine contract requirements for the ACE 

program contributed to significant schedule delays and cost increases.19

ACE Task Order 23 was completed at the end of October 2007 with a 

project cost increase of approximately $21.1 million, or 40 percent, over 

the original estimate. As of April 2008, DHS reported that some portions of 

the work were delayed to better define requirements, and the final portion 

of the software was projected to be completed in June 2009, about 26 

months later than planned. 

Systems Development Efforts 

The second, CBP’s Secure Border Initiative Network (SBInet) Project 28 

contract, was intended to help secure a section of the United StatesMexico border using a surveillance system. Project 28 was planned to be 

SBInet's proof of concept, as well as the first increment of the fielded 

SBInet system. CBP awarded the Project 28 contract before the overall

SBInet operational requirements and system specifications were finalized. 

Additional design requirements for equipment installation were added

after contract award. DHS’s Inspector General reported in February 

2007—more than 3 months after the Project 28 contract was awarded—

that CBP had not properly defined SBInet’s operational requirements and 

needed to do so quickly to avoid rework of the contractor’s systems 

engineering. Several performance standards were not clearly defined to 

isolate the contractor’s performance from that of CBP employees, making 

it difficult to determine whether any problems were due to the 

contractor’s system design, CBP employees, or both. Other performance 

standards were difficult to measure because CBP did not plan a controlled 

 18A letter contract authorizes a contractor to begin work and incur costs before reaching a

final agreement on contract terms and conditions, including price. 

19GAO, Information Technology: Improvements for Acquisition of Customs Trade

Processing System Continue, but Further Efforts Needed to Avoid More Cost and

Schedule Shortfalls, GAO-08-46 (Washington, D.C.: Oct. 25, 2007). 

Page 11 GAO-08-263 DHS Service Acquisitions 
operational test, which is a test conducted in a separate, instrumented test 

area that resembles the border environment. CBP planned to conduct 

operational testing, which is less rigorous, after the system was fully 

accepted. As a result, it was not clear how CBP intended to measure 

compliance with the Project 28 standard for probability of detecting 

persons attempting to illegally cross the border. Another standard stated

that the acceptable level of contractor performance would be determined

in the future. Project 28, planned as an 8-month, $20 million firm fixedprice effort,20 did not meet the June 2007 delivery date, and in August 2007 

CBP notified the contractor that it did not approve delivery because the 

system failed the initial acceptance test. DHS conditionally accepted the 

system in December 2007 and fully accepted it in February 2008. DHS 

noted that the contractor met the requirements; however, Project 28

resulted in a product that did not fully meet user needs and its design will 

not be used as a basis for future SBInet development.21 In addition, DHS 

officials have stated that much of the Project 28 system will be replaced by 

new equipment and software. 

Performance-based contracts for two other major investments—CBP’s 

National Prime Integration (NPI) contract and a TSA Secure Flight 

contract—included well-defined requirements but did not have a full 

complement of measurable performance standards. These operations and 

maintenance contracts had less than expected contractor performance or 

significant cost increases. 

Operations and Maintenance 

Efforts 

CBP’s NPI contract for maintenance of inspection, detection, and 

surveillance devices at border crossings, airports, and seaports included 

well-defined requirements for conducting equipment deployment, 

maintenance, and replacement as well as engineering and logistics 

support. For example, the requirements for equipment corrective 

maintenance specify the contractor shall conduct maintenance, including

parts and labor, as a result of equipment or system failure. However, the 

contract did not incorporate performance standards for post-maintenance 

inspections and other standards needed to fully assess the quality of 

equipment maintenance performed by the contractor. CBP representatives 

acknowledged the need for additional measurable performance standards 

 20The contractor testified in October 2007 before subcommittees of the House Homeland 

Security Committee, that it spent approximately double the original contract amount.

Because this is a firm fixed price contract, absent changes or delays created by the

government, CBP is not responsible for these additional costs.

21GAO, Secure Border Initiative: Observations on the Importance of Applying Lessons 

Learned to Future Projects, GAO-08-508T (Washington D.C.: Feb. 27, 2008).

Page 12 GAO-08-263 DHS Service Acquisitions 
addressing quality of equipment maintenance to help ensure good 

contractor performance. While CBP does not plan to incorporate 

additional performance measures until September 2008, CBP revised the 

contract documentation in December 2007 to emphasize program 

management. Regarding contract outcomes, during the last year of the 

contract, costs were about $24 million, or 53 percent, higher than original 

estimates, in part because of increases in the quantity of equipment being 

supported. Customer wait times have been much longer than expected for 

equipment maintenance, and wait time standards have been revised to 

between 24 and 96 hours depending on the type of equipment. Average 

wait times from September 2006 to September 2007 were between 118 and 

106 hours, not meeting the revised standard. 

A TSA Secure Flight contract for operations and maintenance of the 

federal terrorist watchlist database, which is used to screen airline 

passenger data, also experienced less than expected outcomes. The 

contract we reviewed contained well-defined requirements and 

measurable performance standards for operation, maintenance, repair, 

and upgrade of the system. For example, the requirements specify that the 

contractor shall provide on-site technical and management support. 

Although the contract had some measurable performance standards, the 

contract did not have the full complement of standards needed to monitor 

performance, according to program representatives. For example, one 

standard required no operational system downtime and the contractor was 

not always able to meet this standard. After we reviewed the performance 

standards, program representatives subsequently incorporated some 

additional, improved standards to provide increased visibility over how 

well the contractor responds to system outages. These standards are 

designed to measure the time required to switch from the primary to the 

secondary system for planned and unplanned system outages. 

Additionally, according to program and contracting representatives, the 

contractor initially delivered inadequate plans for staffing and operations, 

and did not always meet the operational system downtime requirement, 

but was within budget and generally met established time frames. 

The inability to manage requirements and meet cost, schedule, and 

performance objectives is not limited to the components and systems we 

reviewed. Several prior GAO and DHS Inspector General reviews of major 

DHS investments using a performance-based approach point to such 

shortcomings. For example: 

Prior Reviews Have Similar 

Findings 

Page 13 GAO-08-263 DHS Service Acquisitions 
• In June 2007, we reported that DHS’s performance-based contract for a 

departmentwide financial management system, eMerge2, did not have

clear or complete requirements.22 Consequently, the program 

experienced schedule delays and less than acceptable contractor 

performance and was ultimately terminated after a $52 million 

investment. 

• In March 2007, we reported that the Coast Guard’s performance-based 

contract for replacing or modernizing its fleet of vessels and aircraft, 

Deepwater, had requirements that were set at unrealistic levels and 

then were frequently changed.23 This resulted in cost escalation,

schedule delays, and reduced contractor accountability. The DHS 

Inspector General has also indicated that numerous opportunities exist 

for DHS to make better use of sound practices, such as well-defined 

requirements. The DHS Inspector General recently concluded that 

Deepwater had poorly defined requirements and inadequate oversight 

that contributed to ineffective or inefficient results and increased 

costs.24

• In February 2006, DHS’s Inspector General reported that TSA’s 

Information Technology Managed Services contract had unclear 

requirements that contributed to negative outcomes, including an 85

percent increase to nearly $834 million in DHS’s 3-year cost estimate 

and a failure to deliver expected information technology capabilities.25

Contracts with WellDefined Requirements and 

Measurable Performance 

Standards Experienced 

Positive Outcomes 

Contracts for four other major investments we reviewed—one at the Coast 

Guard and three at TSA—had well-defined requirements and measurable 

performance standards. These requirements did not significantly change in

scope after contract award. Contracts for program management support 

for the Response Boat-Medium program, maintenance of the Electronic 

Baggage Screening Program, and passenger and baggage screening for the 

 22GAO, Homeland Security: Departmentwide Integrated Financial Management Systems 

Remain a Challenge, GAO-07-536 (Washington, D.C.: June 21, 2007).

23GAO-07-575T. 

24Department of Homeland Security Inspector General, Major Management Challenges

Facing the Department of Homeland Security, OIG-08-11 (January 2008). 

25Department of Homeland Security Inspector General, Transportation Security

Administration’s Information Technology Managed Services Contract, OIG-06-23 

(February 2006). 

Page 14 GAO-08-263 DHS Service Acquisitions 
Screening Partnership Program met the performance standards and were 

within budget. We were unable to evaluate outcomes for the fourth 

contract associated with the Transportation Worker Identification 

Credential (TWIC) program because key work under the contract was 

delayed. 

Program management support and related services we reviewed for the 

Coast Guard’s Response Boat-Medium investment had well-defined 

requirements, and two of three performance standards were measurable. 

The contracted services included research and project support, financial 

and information management, and Web site support. The requirements for 

research and project support clearly stated the contractor was to provide 

project planning and execution support; documentation, database, and 

internet support; and administrative support. The performance standards 

were linked directly to the requirements. The two measurable standards 

were for timely submission of documents and electronic records keeping.

The Coast Guard did not indicate how it would measure contractor 

performance for the third standard addressing research analysis and 

advisory services. Coast Guard representatives said the contractor had 

fulfilled the requirements within budget and on time, but did not document 

contractor performance. 

A maintenance contract for TSA’s Electronic Baggage Screening Program 

also had well-defined program management and technical requirements. 

For example, the requirements for maintenance clearly stated the 

contractor should perform preventative and corrective maintenance on

detection machines, providing specific definitions for each of these tasks. 

The contract also had measurable performance standards linked directly 

to the technical requirements. Specifically, program representatives used 

the ‘mean downtime’ performance standard to calculate the average

number of hours a machine was unable to perform its mission during a 

16-hour day as a means of evaluating how quickly the contractor restored 

the detection equipment to operation. For fiscal years 2006 through 2007,

the contractor met or exceeded the mean downtime performance 

standard, which has become more rigorous each year. Additionally, the 

contractor has stayed within the budget established in the firm fixed-price 

contract. The current maintenance contract improved TSA’s ability to 

manage costs. Previously, DHS’s Inspector General found TSA’s initial 

electronic baggage screening maintenance contracts did not follow sound 

contracting practices. The Inspector General recommended TSA take 

Page 15 GAO-08-263 DHS Service Acquisitions 
action to control costs by modifying the type of contract used.

26 TSA 

subsequently withdrew the initial maintenance contract and issued four 

new contracts, one of which we reviewed, for maintenance of detection

machines at over 400 airports in the United States. 

Contracted security services at the San Francisco International Airport for 

the Screening Partnership Program also had well-defined requirements, 

and all measurable performance standards corresponded to contract 

requirements. This was an improvement from our prior reviews of TSA’s 

Screening Partnership Program, which found that TSA had not finalized 

performance-based planning documentation, including developing 

measurable performance standards.27 The contract we reviewed contained 

well-defined requirements for gate, checkpoint, and baggage screening; 

basic preventative and corrective maintenance; initial, recurrent, and 

remedial training; and recruiting and supervising screeners. For example, 

the requirements for gate, checkpoint, and baggage screening services 

clearly stated the contractor should use technology and staff to prevent 

prohibited items from entering sterile areas of the airport and should work

to minimize customer complaints while addressing in a timely manner any 

complaints received. The performance standards assessed how often 

screeners could successfully detect test images of prohibited items in 

checked baggage; the percentage of audited records and inspected 

equipment, property, and materials that were well-kept, operational, and 

recorded on maintenance logs; and whether all new hires received the 

required training before assuming their screening responsibilities. In terms 

of expected outcomes, the contractor achieved a 2.2 percent cost 

underrun during the first 5 months of the contract and exceeded most 

requirements. 

While the worker enrollment services contract for TSA’s TWIC program 

for a tamper-resistant biometric credential for maritime workers included 

well-defined requirements and measurable performance standards, we 

were unable to review the contract’s outcomes as key work under the 

 26Department of Homeland Security Inspector General, Evaluation of TSA’s Contract for 

the Installation and Maintenance of Explosive Detection Equipment at United States 

Airports, OIG-04-44 (September 2004). 

27GAO, Aviation Security: Preliminary Observations on TSA’s Progress to Allow Airports

to Use Private Passenger and Baggage Screening Services, GAO-05-126 (Washington, D.C.: 

Nov. 19, 2004); and GAO, Aviation Security: Progress Made to Set Up Program Using 

Private-Sector Airport Screeners, but More Work Remains, GAO-06-166 (Washington, D.C.: 

Mar. 31, 2006). 

Page 16 GAO-08-263 DHS Service Acquisitions 
contract was delayed.28 Prior GAO work found that during the TWIC 

program’s prototype phase, the program contract costs doubled due to

expanded requirements after contract award.29 The contract we reviewed 

contained well-defined requirements for developing enrollment centers; 

providing information technology maintenance services; and setting up 

help desk services for TSA employees, maritime workers, and other TWIC

stakeholders. For example, the requirements for enrollment centers 

clearly stated the contractor was to provide maintenance services; 

infrastructure support such as work stations; and operations, 

management, and administrative support. Moreover, the contract’s 

performance standards were measurable and linked to the requirements. 

For example, the program developed performance standards assessing the 

amount of time the contractor took to respond to and resolve each caller’s

issue and to enroll maritime workers in the program. By using measurable 

performance standards linked to the contract’s requirements, TSA has 

improved its ability to identify and address performance issues and avoid 

negative outcomes. 

Quality Assurance 

Surveillance Identified 

Less Than Expected 

Performance 

Agencies are required to ensure that contractors are providing timely and

quality services and mitigate contractor performance problems. The FAR 

indicates that surveillance plans provide for contract quality assurance by 

specifying contractor work requiring surveillance and the method of 

surveillance.30 While not all of the contracts we reviewed had a quality 

assurance surveillance plan in place at contract award, in all cases DHS 

components monitored and assessed contractor performance against the 

contract performance standards. In the four cases where we found poor 

contract outcomes, program staff identified and documented less than 

expected performance and took action as shown in table 2. 

 28TSA awarded a contract in January 2007 to issue biometric credentials to maritime 

workers. TSA officials told us it took more time than originally planned to bring the TWIC

prototype enrollment system into alignment with new government security standards.

During the course of our review, the schedule to initiate work was delayed from March to

October 2007. 

29GAO, Transportation Security: DHS Should Address Key Challenges before

Implementing the Transportation Worker Identification Credential Program, GAO-06-982

(Washington, D.C.: Sept. 29, 2006).

30FAR 37.604 and 46.401. 

Page 17 GAO-08-263 DHS Service Acquisitions 
Table 2: Less Than Expected Performance Identified through Surveillance and Action Taken 

Major investment by

component Service Performance Action taken

Customs and Border Protection

Automated Commercial 

Environment Task Order 

23 

Developing trade systems 

software 

Costs increased by 40 percent 

($21.1 million) and contractor did 

not achieve project milestones 

according to schedule 

Contractor did not earn full

incentive fees 

National Prime

Integration 

Maintaining equipment used 

at border crossings, airports, 

and seaports 

Longer than expected 

maintenance wait times 

Contractor did not earn full award 

fees 

SBInet Project 28 Developing and fielding border 

surveillance systems 

System failed the initial 

performance test and project was 

delayed 8 months with final 

acceptance in February 2008

Contractor did not receive 20 

percent of contract payment and 

DHS did not initially accept the 

system 

Transportation Security Administration

Secure Flight Maintaining database used to 

screen airline passenger data

Inadequacies identified in initial 

contractor planning reports 

provided to TSA; operational 

downtime; and other forms of less 

than expected performance 

Contractor did not earn full award 

fees and DHS worked with 

contractor to increase staffing 

levels 

Source: GAO analysis.

In two of these cases—ACE and Secure Flight—program representatives 

identified less than expected performance through the use of a quality 

assurance surveillance plan. In contrast, the NPI program office told us 

they did not have a quality assurance surveillance plan for the first year of 

the contract, but instead relied on award fee plan criteria to assess 

contractor performance. The SBInet program office monitored Project 28’s

execution through other means, such as program reviews, technical 

interchange meetings, status and issue reporting, and observation of 

contractor testing. Our prior work has found that if performance-based 

acquisitions are not appropriately planned and structured, including 

surveillance planning, there is an increased risk that the government may 

receive products or services that are over budget, delivered late, and of 

unacceptable quality.31

 31GAO-07-489T. 

Page 18 GAO-08-263 DHS Service Acquisitions 
Insufficient workforce and limited oversight of acquisition outcomes has 

presented significant challenges for DHS in implementing its service 

acquisitions, including those that use a performance-based approach. 

Having adequate staff who collaborate across functions, and reliable data

are among the key success factors that we have identified for achieving

intended outcomes for all types of service acquisitions.32 However, DHS 

continues to lack contracting and program staff with the expertise needed

to adequately plan or monitor contractor execution of requirements, and 

some component acquisition representatives indicated a lack of 

collaboration between the program and contracting offices. In terms of 

oversight, inaccurate data has limited departmentwide visibility into DHS’s 

service acquisitions, including those that are performance-based. 

DHS Has Faced 

Workforce and 

Oversight Challenges 

in Managing Its 

Service Acquisitions 

Sufficient and Experienced 

Staff Are Needed to 

Ensure Successful Service 

Acquisitions 

Our prior work has highlighted the importance of having the right people 

with the right skills to achieve successful acquisition outcomes.33 However, 

DHS has not fully defined the types of positions or numbers of staff for 

each position for its acquisition workforce. CPO representatives identified

acquisition staff shortages as one of the primary obstacles to successful 

acquisitions, including those that are performance-based. CPO 

representatives have established departmentwide interim staffing goals 

addressing minimum and optimal staffing levels for contract specialists for 

each component. As of February 2008, CPO representatives reported that

approximately 61 percent of the minimum required staff, and 38 percent of 

the optimal level of contract specialists, were in place. 

Insufficient contracting and program office staff was a challenge for two

of the investments we reviewed—SBInet and ACE. In these two cases, 

contracts were not on schedule or contractor performance was otherwise 

less than expected. In November 2006—the month following SBInet

Project 28’s contract award—the DHS Inspector General reported that 

DHS did not have the capacity needed to effectively plan, oversee, and 

execute the SBInet investment; administer its contracts; and control costs 

and schedule.34 For example, SBInet had a shortage of engineers, logistical

personnel, contracting officers, and cost analysts. In January 2007, DHS’s 

Investment Review Board confirmed there were critical staffing shortages 

 32GAO, Framework for Assessing the Acquisition Function at Federal Agencies, 

GAO-05-218G (Washington, D.C.: Sept. 2005), and GAO-07-20. 

33GAO-07-20. 

34Department of Homeland Security Inspector General, Risk Management Advisory for the

SBInet Program Initiation, OIG-07-07 (November 2006). 

Page 19 GAO-08-263 DHS Service Acquisitions 
in the SBInet investment, including Project 28. In February 2007, we 

reported that SBInet representatives expressed concern about finding an 

adequate number of program office staff with the right expertise. We 

subsequently reported in February 2008 that the SBInet program office 

staffing level had reached 305 positions out of a staffing goal of 470 by the 

end of fiscal year 2008.

35 CBP representatives expressed concerns that 

staffing shortfalls could affect the agency’s capacity to provide adequate 

contractor oversight. ACE program officials also indicated they were 

significantly understaffed, which prevented them from fully defining the 

requirements for ACE Task Order 23. Officials told us the investment had 

less than 10 percent of the staff they needed at the time the requirements 

were being defined. 

In its fiscal year 2007 departmentwide performance-based service 

acquisition management plan, DHS also emphasized the importance of 

filling program and contracting vacancies with staff experienced in 

developing and implementing the required elements of performance-based 

acquisitions. Contracting and program management staff for TSA’s 

Screening Partnership and Electronic Baggage Screening programs stated 

that their previous experience helped them to develop well-defined 

requirements and measurable performance standards. In these cases, 

contracts were on budget and contract performance met or exceeded the 

government’s requirements. Representatives from Coast Guard, CBP, and 

TSA noted success in supplementing expertise through acquisition support 

offices, also known as centers of excellence, to improve acquisition 

planning. Component representatives told us this support could help 

acquisition staff improve the quality of contract documents, including 

performance work statements. These support offices can serve as a force 

multiplier, allowing their high-demand skill-sets to be used across 

contracts and helping to improve contracting outcomes across the 

component. 

According to CPO representatives, hiring knowledgeable acquisition staff 

has been difficult due to a limited pool of qualified acquisition 

professionals and intense competition between the government and the 

private sector for those professionals.36 The CPO has the following ongoing

departmentwide initiatives to recruit, train, and define its acquisition 

workforce that have the potential to better position DHS to address 

acquisition workforce challenges. These include: 

 35GAO-08-508T. 

36We have ongoing work on DHS’s acquisition workforce and plan to report on these issues

in the final product for that engagement. 

Page 20 GAO-08-263 DHS Service Acquisitions 
• centralize recruiting activities across the department; 

• institute an acquisition intern program; 

• employ direct hire authority37 and rehire annuitants;38

• reemphasize training opportunities and establishing a centralized 

acquisition workforce training fund; and 

• conduct workforce planning. 

The need for improved collaboration among the acquisition workforce is 

also a recurrent theme in our work on acquisition management. We have 

noted that acquisition groups should have procedures in place that 

empower staff to collaborate when procuring goods and services and have 

controls and incentives to ensure collaboration occurs.39 In particular, 

leading organizations generally employ a multifunctional approach 

including contracting, finance, legal, and other participants as needed to 

help develop cost-effective acquisition approaches and help ensure 

financial accountability. When requirements are dynamic, as was the case 

for some of the investments we studied, there is a greater need for more 

sophisticated collaboration—a point echoed by CBP and TSA 

representatives who emphasize the importance of early collaboration for 

complex acquisitions. OFPP guidance also emphasizes that performancebased service acquisition is a collective responsibility involving 

representatives from budget, technical, contracting, logistics, legal, and 

program offices. 

For the eight major investments we reviewed, program and contracting 

offices jointly approved the acquisition plans, and representatives for 

several of the contracts we studied indicated they worked together 

effectively. However, at the component level, senior acquisition staff at 

 37Services Acquisition Reform Act of 2003, Div. A, Title XIV, National Defense Authorization 

Act for Fiscal Year 2004, Pub. L. No. 108-136, § 1413 (2003) allowed federal agencies to 

exercise direct hire authority in accordance with regulations issued by the Office of 

Personnel Management. This authority was extended to September 30, 2012, by the

National Defense Authorization Act for Fiscal Year 2008, Pub. L. No. 110-181, Div. A, Title 

VIII, § 853 (2008). 

38General Services Administration Modernization Act, Pub. L. No. 109-313, § 4 (2006)

granted agency heads authority, in consultation with the OPM and OFPP, to approve

reemployment of annuitants in fields related to acquisition management. 

39GAO-05-218G. 

Page 21 GAO-08-263 DHS Service Acquisitions 
TSA and CBP indicated that collaboration between contracting and 

program offices in general has been challenging. For example, they cited 

poor timing when bringing together key stakeholders in the contracting 

process, and in some cases, the program offices’ preference for 

prescriptive requirements rather than a more outcome-oriented approach.

Coast Guard and TSA acquisition representatives we spoke with indicated

they have ongoing efforts to promote greater collaboration. 

Limited Data Inhibits 

DHS’s Ability to Oversee 

Its Service Acquisitions 

While DHS contracting and program representatives told us they use a

performance-based approach to the maximum extent practicable, DHS 

does not have reliable data, either from FPDS-NG or at a departmentwide 

level, to systematically monitor or evaluate service acquisitions, including 

those that are performance-based acquisitions. Reliable data are essential

to overseeing and assessing the implementation of contracting 

approaches, acquisition outcomes, and making informed management 

decisions. 

Our review of 138 contracts at the Coast Guard, CBP, ICE, and TSA coded 

in FPDS-NG as performance-based illustrates the difficulty in identifying 

such contracts.40 According to contracting representatives at the Coast 

Guard, CBP, ICE, and TSA, only 42, about 30 percent, of these contracts 

could be confirmed as containing the required performance-based 

elements—a performance work statement, measurable performance 

standards, and a method of assessing contractor performance against 

performance standards. About 18 percent had some but not all of the 

required performance-based acquisition elements, and about 51 percent—

totaling about $347.3 million—had none of the required elements (see 

table 3). This analysis indicates that the FPDS-NG data are not reliable for 

reporting on the performance target for eligible service obligations. For 

example, in fiscal year 2006, DHS reported awarding performance-based 

contracts for 21 percent of eligible service contract dollars. However, due

to unreliable data, DHS is likely farther away from meeting the 

governmentwide target than previously reported. In addition, in July 2006 

OFPP requested all agencies to report in their 5-year management plan on

the use of performance-based contracts by service types—ranging from 

basic, such as janitorial and landscaping, to complex, such as information 

technology or systems development. The Acquisition Advisory Panel and 

 40The 138 contracts were awarded in fiscal years 2005 or 2006 with obligations greater than 

$1 million, totaling about $1.3 billion.

Page 22 GAO-08-263 DHS Service Acquisitions 
DHS’s CPO also have raised concerns regarding the accuracy of the 

performance-based designation in FPDS-NG. The Acquisition Advisory 

Panel reported from its review at 10 federal agencies that 42 percent of the

performance-based contracts it reviewed had been incorrectly coded.

41

Table 3: Review of Performance-Based Elements on Selected Contracts 

Performance-based

elements 

Coast 

Guard

Customs and

Border 

Protection

Immigration and 

Customs 

Enforcement

Transportation 

Security 

Administration

Total

contracts

Percent of

total contracts

All elements 18 3 0 21 42 30.4

Some elements 16 0 5 4 25 18.1

No elements 20 5 34 12 71 51.5

Total 54 8 39 37 138 100

Source: GAO analysis of DHS review of 138 contracts coded as performance-based in FPDS-NG. 

According to DHS contracting representatives, contracts were miscoded 

as performance-based for several reasons. Contracting staff may have 

coded contracts as performance-based without the presence of the 

required elements. Contracting staff also may not have followed data 

validation procedures. Finally, there are technical FPDS-NG issues. For 

example, DHS contracting and program staff said FPDS-NG automatically

applies the same designation to all orders issued under the master 

contract although some individual orders may or may not be performancebased.42 While DHS officials acknowledged this can occur, they stated that 

the data field in FPDS-NG could still be edited for orders issued under the 

master contract and that it was incumbent on DHS contracting

representatives to review the designation for every contract action to 

ensure they are coded correctly. 

Inaccurate federal procurement data is a long-standing governmentwide 

concern. Our prior work and the work of the General Services 

Administration’s Inspector General have noted issues with the accuracy 

 41Report of the Acquisition Advisory Panel to the Office of Federal Procurement Policy and 

the United States Congress, January 2007. 

42Known as Indefinite Delivery Indefinite Quantity (IDIQ) contracts, these contracts

provide for an indefinite quantity of supplies or services within stated limits during a fixed

period of time. The government places orders for individual requirements. 

Page 23 GAO-08-263 DHS Service Acquisitions 
and completeness of FPDS and FPDS-NG data.43 The Office of 

Management and Budget has stressed the importance of submitting timely 

and accurate procurement data to FPDS-NG and issued memos on this 

topic in August 2004 and March 2007. 

Accurate FPDS-NG data could facilitate the CPO’s departmentwide 

oversight of service acquisitions, including those that are performancebased. For example, the selection of a contract type is the principal means 

agencies have for allocating financial risk between the government and the 

contractor. For performance-based services, federal law establishes a 

preference for using firm fixed-price as opposed to cost reimbursable or 

time and materials contracts.44 In addition, the CPO has instructed 

components to avoid using time-and-material contracts for services. We 

reviewed the contract type for the 42 contracts DHS confirmed were 

performance-based. Our analysis showed that DHS awarded about 70 

percent of these 42 contracts as fixed-price; these actions represented 

about 42 percent of total obligations for these awards. About 37 percent of 

total obligations were awarded as cost-reimbursable, and 7 percent were 

awarded as time and materials contracts (see fig. 1). 

 43GAO, Reliability of Federal Procurement Data, GAO-04-295R (Washington, D.C.: Dec. 30, 

2003); GAO, Improvements Needed to the Federal Procurement Data System-Next

Generation, GAO-05-960R (Washington, D.C.: Sept. 27, 2005); and General Services

Administration Inspector General, Review of the Federal Procurement Data System-Next

Generation (FPDS-NG), Report Number A040127/O/T/F06016 (March 2006). 

44For fixed price contracts, a specified price is paid regardless of the contractor’s costs,

minimizing the financial risk to the government. For cost reimbursable and time and 

materials contacts, the government generally assumes the risk of cost overruns. For 

example, cost reimbursable contracts provide for the government to pay reasonable, 

allowable and allocable costs incurred by the contractor up to the contract’s price ceiling. 

Time and materials contracts provide for acquiring services on the basis of fixed costs for 

labor hours and materials at the stated contract ceiling price. In time and materials 

contracts, if services delivered do not meet contract requirements and the government

exercises its right to have the contractor correct the deficiencies, the government pays the

additional labor and material costs to do so, excluding profit. 

Page 24 GAO-08-263 DHS Service Acquisitions 
Figure 1: Percent of Contracts and Obligations by Contract Type for 42 DHS 

Performance-Based Service Acquisitions (Fiscal Years 2005 and 2006) 

0

10

20

30

40

50

60

70

80

Othera Time and

materials/labor hours

Fixed price Cost reimbursable

Percent

Source: GAO analysis of DHS confirmed performance-based service acquisitions.

Contracts

Obligations

69.0

41.9

9.5

37.0

11.9

6.7

9.5

14.4

a

“Other” includes contracts for which the contract type field in FDPS-NG was blank, designated as

being none of the contract types listed within FPDS-NG, or coded with more than one contract type.

At a departmentwide level, CPO representatives responsible for 

acquisition oversight indicated they have not conducted systematic 

assessments including costs, benefits, and other outcomes of a 

performance-based approach. To improve the implementation of 

performance-based acquisitions, CPO representatives established a work 

group in May 2006 to leverage knowledge among DHS components. They 

also noted that they are working with OFPP to develop a best practices 

guide on measurable performance standards and to gather good examples 

of performance-based contracts. In addition, the CPO has implemented a 

departmentwide acquisition oversight program that is intended to assess 

(1) compliance with federal acquisition guidance, (2) contract 

administration, and (3) business judgment. This program was designed 

with the flexibility to address specific procurement issues, such as 

Page 25 GAO-08-263 DHS Service Acquisitions 
performance-based service acquisitions, and is based on a series of 

component-level reviews.45 However, this oversight program has not yet 

included an evaluation of the outcomes of this acquisition method. 

As part of its expansive homeland security mission, DHS spends billions of 

dollars on service acquisitions for critical trade, transportation, and border 

security investments. Consistent with federal procurement policy, DHS 

has emphasized a performance-based approach to improve service 

acquisition outcomes. However, in keeping with our prior findings, DHS’s 

designation of a service acquisition as performance-based was not as 

relevant as the underlying contract conditions. Sound acquisition 

practices, such as clearly defining requirements; establishing 

complementary measurable performance standards; and planning and 

conducting surveillance in order to take corrective actions are all 

hallmarks of successful service acquisitions. In the cases we reviewed, as 

well as in prior findings lacking these key elements, DHS did not always 

achieve successful acquisition outcomes. To improve DHS’s acquisition 

management, the CPO is taking steps to address departmentwide 

workforce and oversight needs. However, improved data accuracy and

systematic evaluation of contracting methods and outcomes are also key 

to successful oversight efforts. Continued emphasis on these areas is 

required to prevent less than expected acquisition outcomes for the 

department’s critical mission. 

To increase DHS’s ability to achieve improved outcomes for its service 

acquisitions, including those that are performance-based, we recommend 

that the Secretary of Homeland Security implement the following three 

actions: 

Conclusions 

Recommendations for 

Executive Action 

• routinely assess requirements for major, complex investments to 

ensure they are well-defined and develop consistently measurable 

standards linked to those requirements; 

• at a departmentwide level, systematically evaluate the outcomes of 

major investments and relevant contracting methods; and 

 45GAO-07-900. 

Page 26 GAO-08-263 DHS Service Acquisitions 
• continuously improve the quality of FPDS-NG data to facilitate the 

ability to accurately identify and assess the use and outcomes of 

various contracting methods. 

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

comment. In written comments, DHS generally concurred with our 

findings and recommendations and provided some information on efforts 

under way to improve acquisition management. The department’s 

comments are reprinted in appendix II. OMB did not comment on the 

findings or conclusions of this report. DHS and OMB each provided 

technical comments, which we incorporated as appropriate and where 

supporting documentation was provided. 

Agency Comments 

and Our Evaluation 

In response to our recommendations that DHS (1) routinely assess 

requirements for major, complex investments to ensure they are welldefined, and develop consistently measurable standards linked to those 

requirements, and (2) systematically evaluate the outcomes of major 

investments and relevant contracting methods, DHS stated that the CPO is

working to strengthen acquisition and procurement. For example, DHS 

noted that the CPO is revising the investment review process; reviewing 

major programs and investments; and building the capability to manage 

complex efforts by ensuring program offices are properly structured and 

staffed with the right people and skills. To assist in accomplishing these 

goals, DHS noted that the CPO has established a new division to provide 

oversight and support for acquisition programs. We have ongoing work at 

DHS reviewing the results of DHS’s oversight of major acquisitions and 

plan to report on these initiatives in the final product for that engagement.

Improving acquisition management has been an ongoing challenge since 

the department was established and requires sustained management 

attention. However, DHS’s response did not address how the CPO’s 

process and organizational changes will impact component-level 

management and assessment of complex acquisitions to improve 

outcomes. 

Concerning the third recommendation, that DHS continuously improve the 

quality of FPDS-NG data to facilitate the ability to accurately identify and

assess the use and outcomes of various contracting methods, DHS stated 

that as part of the CPO’s oversight reviews, the accuracy of the FPDS-NG 

data is validated for the review sample, including whether contracts have

been properly coded as performance-based. DHS also added that the CPO 

is an active member of the OFPP group working to improve FPDS-NG and 

has established a governance board whereby the CPO reaches out to DHS 

Page 27 GAO-08-263 DHS Service Acquisitions 
components to improve data collection. While these initiatives may be 

steps in the right direction, DHS’s response did not present the results of 

the oversight reviews, or state how these coordination efforts address the 

causes of miscoding or how they will improve the quality of FPDS-NG data 

in the future. 

DHS also noted other initiatives to improve the acquisition workforce, 

including working to obtain qualified acquisition professionals and 

conducting staffing studies to better define the department’s needs. We 

also have ongoing work at DHS on the acquisition workforce and plan to 

report on the results of DHS’s efforts in the final product for that 

engagement.

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

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

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

Homeland Security, the Director of the Office of Management and Budget, 

and other interested congressional committees. We will also make copies

available to others upon request. In addition, this report will also be 

available at no charge on GAO’s Web site at http://www.gao.gov. 

If you have questions about this report or need additional information, 

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

for our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. 

John P. Hutton, Director 

Acquisition and Sourcing Management 

Page 28 GAO-08-263 DHS Service Acquisitions 
Appendix I: Scope and Methodology 

Page 29 GAO-08-263 DHS Service Acquisitions 

Appendix I: Scope and Methodology 

To evaluate selected Department of Homeland Security (DHS) 

components’ implementation of a performance-based approach in the 

context of service acquisitions for major investments, we conducted a

detailed file review of eight judgmentally selected performance-based 

contracts for major, complex investments with a total value greater than

$100 million.1

 To identify the components with the highest obligations 

using a performance-based approach in fiscal years 2005 and 2006, we 

used the Federal Procurement Data System-Next Generation (FPDS-NG) 

and selected four components—Coast Guard, Customs and Border 

Protection (CBP), Immigration and Customs Enforcement (ICE), and the 

Transportation Security Administration (TSA).2

 We excluded the Federal

Emergency Management Agency (FEMA) from our review because of 

atypical fiscal year 2006 spending on Gulf Coast hurricane relief efforts. 

To identify contracts for major investments, we utilized several different 

approaches.3

 Three issues required us to modify our plans—the lack of 

information in FPDS-NG, inaccurate DHS contracting data on major 

investments, and inaccurate information provided by one DHS component.

Because the FPDS-NG major program field was typically blank, we were 

unable to use this field to identify contracts associated with DHS major 

investments. As a result, we asked DHS to provide us with a list of 

performance-based contracts associated with the four components’ major 

investments. DHS provided a list including 76 contracts for 16 major 

investments. Due to data inaccuracies related to the contract numbers on 

DHS’s list, we were only able to identify performance-based contracts 

associated with two major investments. We selected one contract from 

CBP’s Automated Commercial Environment and one from TSA’s Secure 

Flight that had the highest obligations. To obtain additional contracts to 

review, we met with CBP and TSA contracting representatives and they

identified five other major investments with performance-based contracts, 

and we included one from each investment in our review. Coast Guard 

 1

DHS has categorized major investments as Levels 1 and 2 and Level 3 (information 

technology). For the purposes of our review, we focused on Level 1 investments. A Level 1 

major investment is defined in DHS Management Directive 1400 as an investment with 

greater than $100 million in total acquisition costs including planning, or for information 

technology investments, a life-cycle cost greater than $200 million. 

2

During our review TSA was exempt from the FAR and followed the Acquisition 

Management System, developed by the Federal Aviation Administration, which included 

acquisition policy providing that service contracts should incorporate performance-based 

contracting methods. 

3

We selected eight major investments and reviewed either a performance-based contract or 

selected orders on a performance-based contract associated with each investment. 
Appendix I: Scope and Methodology 

contracting representatives told us none of their major investments used 

performance-based contracts. However, we randomly selected and 

reviewed four contracts and seven orders at the Coast Guard from DHS’s 

list of major investments, and found that five of them were performancebased. Of these, we selected three performance-based orders from one 

contract for one major Coast Guard investment—the Response BoatMedium—to include in our review. Lastly, ICE contracting representatives 

also reported that none of their major investments used a performancebased approach and provided us with their best examples of a 

performance-based contract. We reviewed these examples and found that

none of them were associated with a major investment. As a result, we 

excluded ICE from our contract review. 

For the selected contracts, with a combined estimated value of $1.53

billion, we reviewed documentation, including acquisition plans, 

performance work statements and statements of objectives, quality 

assurance surveillance plans, and government or contractor performance 

reports where available. Performance-based service acquisitions were 

difficult to identify and were not clearly distinct from other service 

acquisitions because they did not always include all required elements. 

Therefore, we reviewed prior GAO and DHS Inspector General reports to 

provide a broader context for service acquisition and other DHS major 

investments. We reviewed public laws, federal and agency acquisition 

regulations, and the Office of Management and Budget’s Office of Federal

Procurement Policy (OFPP) memoranda and best practices. We also 

interviewed procurement and program representatives to determine the 

extent to which the performance-based planning process influenced 

expected outcomes. 

To identify management challenges that may affect DHS’s successful

implementation of service acquisitions for major investments, including those 

that use a performance-based approach, we analyzed management 

documents and plans; staffing data; and oversight mechanisms, including 

the Federal Procurement Data System-Next Generation (FPDS-NG), the 

governmentwide database for procurement spending. From FPDS-NG, we 

judgmentally selected 138 contracts for primarily basic services coded as 

performance-based and awarded in fiscal years 2005 or 2006 at Coast 

Guard, CBP, ICE, and TSA with obligations greater than $1 million dollars 

and asked the components to verify whether these contracts included the 

required performance-based elements outlined in FAR subpart 37.6. Finally,

we interviewed contracting and program management staff and DHS Chief 

Procurement Office (CPO) representatives and met with representatives 

from the Office of Management and Budget’s Office of Federal

Procurement Policy (OFPP). To evaluate the extent to which DHS used

Page 30 GAO-08-263 DHS Service Acquisitions 
Appendix I: Scope and Methodology 

different contract types for performance-based acquisitions, we reviewed the

contract type on all contracts DHS verified as performance-based.

We conducted this performance audit from January 2007 to April 2008 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 31 GAO-08-263 DHS Service Acquisitions 
Appendix II: Comments from the Department 

of Homeland Security

Page 32 GAO-08-263 DHS Service Acquisitions 

Appendix II: Comments from the Department 

of Homeland Security 

U.S.Department of Homeland Security 

Washington,DC 20528

Homeland

Security

April 1,2008

Mr. John P.

Director

Acquisitionand Sourcing Management

U.S. Government AccountabilityOffice

441 G Street, NW

Washington, DC 20548

Dear Mr.

you for the opportunity to review and comment on the Government Accountability

Office's report GAO-08-263 entitled DEPARTMENT OF HOMELAND

SECURITY: Better Planning and Assessment Needed to Improve Outcomes for Complex

Service Acquisitions. Technical comments have been provided under separate cover.

The Department of Homeland Security (DHS) generally concurs with the findings and

recommendations in the draft report and offers the following with respect to the report's 

three recommendations:

GAO Recommendation Routinely assess requirements for major, complex 

investments to ensure they are well-defined and develop consistently measurable 

standards linked to those requirements.

GAO Recommendation #2: At a department-wide level, systematically evaluate the 

outcomes of major investments and relevant contracting methods.

DHS Response to Recommendations and #2: DHS is in the midst of many crucial

acquisitions that are vital to its success. The Chief Procurement Officer (CPO) is

working to strengthen acquisition and procurement by institutionalizing solid processes,

including the following actions: 

A. Strengthening the requirements and investment review processes by improving the

joint requirements council and Investment Review Board (IRB) process. We are

preparing to initiate a new Department-wide requirements process and have 

reinvigorated our investment review process;

B. Reviewing the major programs and investments to ensure that the requirements are 

clear, cost estimates are valid, technology risks are properly assessed, schedules are 
Appendix II: Comments from the Department 

of Homeland Security

realistic, contract vehicles are proper, and the efforts are well managed. We have

held one formal Deputy Secretary IRB and are projecting one per month. We are

also beginning the processes to conduct paper and Deputy for

Management IRBs, as well as establishing Acquisition Program Baselines 

and authorizing execution to the APB for all Level 1 and 2 programs;

C. Building the capability to manage complex efforts by ensuring that program offices

are properly structured and staffed with the right people and to ensure

efficient and effective program management and oversight; and to aggressively hire 

where we have known shortages; and

D. Examining best practice in use by other departments with the intent to start

implementation this year.

The Acquisition Program Management Division (APMD) of the Office of the

Chief Procurement Officer (OCPO) began operations in August 2007. The division was

established to provide oversight and support for acquisition programs. To date, APMD

has performed Quick Look assessments of 37 Level 1 programs and has overseen Deep 

Dive reviews of the and Advance Spectroscopic Portal (ASP) programs. APMD

has provided advice and guidance to a number of programs, particularly in the area of

cost benefit analysis. Currently the APMD team is focused on an aggressive Investment

& Acquisition process re-engineering effort. The effort includes replacing DHS

Management Directive InvestmentReview Process, establishing revised investment

and acquisition decision procedures, as well as processes for acquisition program

baselining, periodic reporting, acquisition of services, and other initiatives as they are

identified.

CPO is also to assure that DHS obtains qualified acquisition 

professionalsat the right time with the right Competition for these professionals 

is intense within the Washington, D.C. area. To resolve our personnel shortages, we are

intensifying our human capital planning efforts to minimize skill and competency gaps as

well as minimize our critical vacancies and reliance on contractors. For example, in

response to the OMB 1102 Contracting Workforce Competency Gap Survey, we

developed a training plan that spans the next three years. This training plan targets the 

contracting functional area within the DHS Acquisition Workforce, but it will also 

benefit other acquisition career fields including program management and Contracting 

Officer's Technical Representatives.

CPO is also currently conducting staffing studies to better define our acquisition 

workforce needs. Currently our workforce includes program managers and contract 

specialists. As part of our human capital planning efforts, we will be identifying other 

required acquisition career fields such as test and evaluation, systems engineering, 

logistics, and cost estimating. We are aggressively to ensure that each 

acquisition position, upon definition, is encumbered by an acquisition professional

trained and certified at the appropriate level. To this end, we are continuously reviewing

and updating our Acquisition Training Program, the underpinning of a good certification

Page 33 GAO-08-263 DHS Service Acquisitions 
Appendix II: Comments from the Department 

of Homeland Security

program. We are utilizing the Defense Acquisition Workforce Improvement Act 

framework to develop DHS certification standards. We have also centralized a number

of recruiting activities including issuing Department-wide vacancy announcements. Our 

centralized recruitment efforts to date have focused primarily on contracting

professionals. Expansion to other acquisition career fields will occur as each series is

defined and Department-wide needs are identified. This initiative supplements our

Components' on-going recruitment efforts with a goal of recruiting the best candidates

available. In 2005, the Department commenced the Acquisition Fellows Program. The

goal of the Fellows Program was to attract new talent at the entry level into our 

acquisition positions, and retain and train them through a professional career

development program. Building on the success of the Acquisition Fellows Program, CPO

formalized and modeled it to further resemble the highly successful Department of 

Defense program. This year CPO received funding for the Acquisition Professional

Career Program and 33 of the requested 66 positions were funded. In FY 2009, the plan

provides for a total of 100 positions to be Our inaugural class in the Acquisition

Professional Career Program began in January 2008 and a second class will begin in June

2008. Our goal is to grow this program to 300 positions by FY 2011 to fill our critical

acquisition positions. 

GAO Recommendation #3: Continuously improve the quality of Federal Procurement

Data System-Next Generation (FPDS-NG) data to facilitate the ability to accurately

identify and assess the use and outcomes of various contracting methods.

DHS Response to Recommendation As part of oversight reviews, the

accuracy of the FPDS data is validated for the review sample, including whether the

contract has been properly coded as a performance based contract. In addition, OCPO is

an active member of the Office of Federal Procurement Policy group that is working to

improve FPDS. OCPO has also established a Governance Board whereby CPO reaches

out to the DHS Components to improve data collection. 

Thank you again for the opportunityto comment on this draft report and we look forward

to working with you on future homeland security issues.

Penelope G.

Acting Director

Departmental Audit Liaison

Page 34 GAO-08-263 DHS Service Acquisitions 
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 35 GAO-08-263 DHS Service Acquisitions 

Appendix III: GAO Contact and Staff 

Acknowledgments 

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

In addition to the individual named above key contributors to this report 

were Amelia Shachoy, Assistant Director; Don Springman; Jeffrey 

Hartnett; Sean Seales; Alex Winograd; Karen Sloan; Julia Kennon; Lynn 

Milan; Art James; Marie Ahearn; and Kenneth Patton. 

GAO Contact 

Staff 

Acknowledgments 

(120602) 
GAO’s Mission The Government Accountability Office, the audit, evaluation, and 

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

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

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

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “E-mail Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, DC 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

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

Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, DC 20548 

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

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

Washington, DC 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER