TRANSPORTATION 

SECURITY

Action Needed to 

Strengthen TSA's 

Security Threat 

Assessment Process

Report to the Ranking Member, 

Committee on Homeland Security, 

House of Representatives

July 2013

GAO-13-629

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-629, a report to the 

Ranking Member, Committee on Homeland 

Security, House of Representatives

July 2013

TRANSPORTATION SECURITY

Action Needed to Strengthen TSA's Security Threat 

Assessment Process

Why GAO Did This Study

TSA implements programs that, for 

example, ensure individuals with 

unescorted access to secure areas of 

the nation’s critical transportation 

infrastructure do not pose a security 

threat. Key to these programs are 

security threat assessments that 

screen individuals for links to terrorism, 

criminal history, and immigration 

status. TSA’s Adjudication Center 

serves as the primary operational 

component in this process. GAO was 

asked to examine the performance and 

staffing strategy of the center. This 

report addresses the extent to which 

1) TSA has measured performance for 

the center and what the data show; 

2) TSA offices have coordinated to 

meet security threat assessment 

workload; and 3) TSA addressed 

potential risks posed by using a mix of 

government employees and 

contractors to adjudicate security 

threat assessments. GAO analyzed 

TSA data describing the center’s 

performance since October 2010; 

reviewed documentation, including 

staffing plans; and interviewed TSA 

officials about data measurement and 

staffing practices.

What GAO Recommends

GAO recommends that TSA, among 

other things: direct the Adjudication 

Center to calculate an accuracy rate 

that includes adjudicator performance 

for cases where applicants were both 

approved and disqualified; share 

adjudicator staffing plans among key 

program offices; and update its 

Adjudication Center workforce 

conversion plan and provide it to DHS 

for review and approval. DHS 

concurred with our recommendations.

What GAO Found

The Transportation Security Administration’s (TSA) Adjudication Center 

performance data show mixed results, and the center’s performance 

measurement practices have limitations. The Adjudication Center relies on 

contractors to adjudicate security threat assessments and uses three primary 

measures to evaluate their performance—timeliness for completing adjudication, 

adjudication accuracy, and caseload status. GAO found that the Adjudication 

Center contractor met its timeliness and accuracy measures, but faced 

challenges in meeting its caseload measure. The Adjudication Center’s 

timeliness and accuracy measures did not capture key data. According to TSA 

officials, the Adjudication Center’s accuracy rate is based on a review of all cases 

where adjudicators had disqualified an applicant. However, this calculation 

generally does not include the accuracy rate for those applicants adjudicators 

had approved—which account for roughly 90 percent of the Adjudication Center’s 

caseload. In this way, the accuracy rate provides a limited assessment of 

adjudicator performance. By developing an accuracy rate that includes data on 

both incorrectly disqualified and incorrectly approved applicants, TSA can better 

identify and addresses performance issues among its workforce. 

Two TSA offices that share responsibility for implementing security threat 

assessments—the Program Management Division in the Office of Intelligence 

and Analysis and the Adjudication Center in the Office of Law 

Enforcement/Federal Air Marshal Service—can improve coordination on 

workforce planning. While the offices share information on workload completion, 

they do not have a process in place to ensure that information in the Adjudication 

Center’s staffing plan—which the Adjudication Center periodically updates to 

reflect caseload projections and associated staffing needs—reflects the mutual 

understanding of both offices. For example, program managers in the Office of 

Intelligence and Analysis reported to GAO that they were unfamiliar with the 

staffing plan and they disagreed with workload projections in the plan. 

Establishing a mechanism for the offices to share and reconcile information in the 

plan can help better support the Adjudication Center’s workforce planning. 

TSA has been delayed in addressing risks posed by using contractors to 

adjudicate security threat assessments. In October 2011 TSA’s Balanced 

Workforce Strategy Working Group completed its assessment for the 

Adjudication Center and determined that an excessive risk exists by allowing 

contractors to make security threat assessment approvals without sufficient 

federal oversight. The Working Group recommended that TSA convert to an all 

government workforce. According to a May 2012 implementation plan, TSA 

planned to convert this workforce by the end of calendar year 2013. However, 

delays have rendered the timelines and cost information in its plan outdated and 

TSA has not updated the plan or determined a revised implementation schedule. 

Completing this review and updating the plan would help TSA and Department of 

Homeland Security (DHS) decision makers by providing a roadmap for moving 

forward. Finally, providing this plan to DHS for review will be important to help 

ensure TSA can begin its conversion and mitigate identified risks of using 

contract adjudicators to conduct security threat assessments.

View GAO-13-629. For more information, 

contact Jennifer A. Grover at (202) 512-7141 

or groverj@gao.gov.
Page i GAO-13-629 Transportation Security

Letter 1 

Background 7

Adjudication Center Performance Data Show Mixed Results, 

Accuracy Measures Are Limited, and Performance Measurement 

Practices Are Not Fully Documented 15

TSA Offices Can Strengthen Coordination to Ensure Effective 

Adjudication Center Workload Planning 26

TSA Has Made Limited Progress in Addressing Risks Posed by 

Using Contract Employees to Adjudicate Security Threat 

Assessments 29

Conclusions 33

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 36

Appendix I TSA Organizational Chart with Key Offices with 

Responsibility for Implementing Security Threat Assessments 39

Appendix II Comments from the Department of Homeland Security 40

Appendix III GAO Contact and Staff Acknowledgments 43

Figures

Figure 1: TSA TWIC, HME, and Aviation Worker Program 

Processes and Contractor and TSA Staff Functions in 

Security Threat Assessment Process at the Adjudication 

Center 11

Figure 2: Caseload Levels for TWIC, HME, and Aviation Worker 

Programs, October 2010 through January 2013 19

Figure 3 TSA Organization Chart Showing Key Offices Responsible 

for Managing and Implementing Transportation Security 

Threat Assessment Programs, as of May 2013. 39

Contents 
Page ii GAO-13-629 Transportation Security

Abbreviations

BWS Balanced Workforce Strategy

BW PMO Balanced Workforce Strategy Program 

 Management Office

DHS Department of Homeland Security

FBI Federal Bureau of Investigation

HME Hazardous Materials Endorsement

MTSA Maritime Transportation Security Act

OIA Office of Intelligence and Analysis

OLE/FAMS Office of Law Enforcement/Federal Air Marshal 

 Service

TIM Technology Infrastructure Modernization

TSA Transportation Security Administration

TWIC Transportation Worker Identification Credential

USA PATRIOT Uniting and Strengthening America by Providing 

 Appropriate Tools Required to Intercept and 

 Obstruct Terrorism

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

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Page 1 GAO-13-629 Transportation Security

441 G St. N.W.

Washington, DC 20548

July 19, 2013

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Dear Mr. Thompson:

Securing the nation’s transportation systems and facilities requires 

balancing security to address potential threats while facilitating the 

legitimate flow of people and goods that are critical to the U.S. economy 

and international commerce. Within the Department of Homeland Security 

(DHS), the Transportation Security Administration (TSA) is responsible for 

managing vetting and credentialing programs to ensure that individuals 

that transport hazardous materials or have unescorted access to secure 

or restricted areas of transportation facilities at maritime ports and TSAregulated airports1 do not pose a security threat.2 Key to these programs 

are background checks—known as security threat assessments—which 

are TSA reviews of applicant information and searches of government 

databases to determine whether the applicant has known ties to terrorism 

and whether the applicant may be otherwise precluded from obtaining an 

endorsement, credential, access and/or privilege (hereafter called a 

 

1

Under Coast Guard maritime security regulations, a secure area, in general, is an area 

on board a vessel or at a facility over which the owner/operator has implemented security 

measures for access control in accordance with a Coast Guard-approved security plan. 

See 33 C.F.R. § 101.105. For most maritime facilities, the secure area is generally any 

place inside the outer-most access control point. For a vessel or outer continental shelf 

facility, such as off-shore petroleum or gas production facilities, the secure area is 

generally the whole vessel or facility. Under TSA aviation security regulations, the secured 

area of an airport includes, generally, those portions of an airport, specified in the airport 

security program, in which TSA-mandated security measures are conducted and within 

which air carriers operating under TSA-approved security programs enplane and deplane 

passengers and sort and load baggage. See 49 C.F.R §1540.5.

2

TSA regulations define the term security threat to mean an individual whom TSA 

determines or suspects of posing a threat to national security; to transportation security; or 

of terrorism. See 49 C.F.R. § 1570.3. Depending on the program, TSA may not be 

responsible for issuing the credentials to applicants for whom it has completed security 

threat assessments. 

 
 

Page 2 GAO-13-629 Transportation Security

credential) based on, among other factors, their immigration status and 

criminal history.

Multiple TSA offices coordinate in implementing security threat 

assessments, with TSA’s Adjudication Center serving as the primary 

operational component by reviewing derogatory applicant background 

information to determine if applicants are eligible to obtain credentials for 

12 TSA programs, including the Transportation Worker Identification 

Credential (TWIC) program for maritime workers, Hazardous Materials 

Endorsement (HME) program for commercially licensed drivers, and the 

Aviation Worker program.3 These efforts are intended to reduce the 

probability of a successful terrorist or other criminal attack on the nation’s 

transportation systems, which include approximately 360 seaports and 

450 TSA-regulated airports.

As we have previously reported, TSA’s Adjudication Center has faced 

recurring challenges in meeting its security threat assessment 

performance requirements and has attributed these challenges in part to 

its reliance on a contractor workforce. For example, in December 2011, 

we reported that insufficient federal staffing had hampered the 

Adjudication Center’s ability to meet its workload requirements and 

ensure necessary oversight of the credential decision-making process.4 In 

particular, TSA attributed Adjudication Center backlogs to turnover among 

its contractor workforce. At the time, TSA reported that it had initiated but 

not yet completed an assessment through the DHS Balanced Workforce 

 

3 TSA officials reported that the TWIC, HME, and Aviation Worker programs accounted for 

approximately 95 percent of security threat assessment cases processed by the 

Adjudication Center. The remaining 5 percent of cases are from a number of smaller 

programs, including general and commercial aviation and air cargo. According to TSA 

data, in calendar year 2012, the Adjudication Center processed about 404,000 new TWIC, 

HME, and Aviation Worker security threat assessment applications.

4 We discuss the recommendation we made to TSA later in this report. See: GAO, 

Transportation Security: Actions Needed to Address Limitations in TSA’s Transportation 

Worker Security Threat Assessments and Growing Workload, GAO-12-60 (Washington, 

DC: Dec. 8, 2011). 
 

Page 3 GAO-13-629 Transportation Security

Strategy (BWS)5 to determine if (1) the Adjudication Center’s reliance on 

a largely contractor workforce to conduct security threat assessment 

adjudication was appropriate, or if the work is an inherently governmental 

function requiring a government workforce6 and (2) if there would be a 

cost savings resulting from conversion of the contract positions to 

government personnel positions. According to the Federal Acquisition 

Regulation, inherently governmental functions include activities that 

require either the exercise of discretion in applying government authority, 

or value judgments in making decisions for the government, and therefore 

should be performed by government employees, not contractors. Further, 

federal procurement policy explains that a function is not appropriately 

performed by a contractor where the contractor’s involvement is or would 

be so extensive, or the contractor’s work product so close to a final 

agency product, as to effectively preempt the federal officials’ decisionmaking process, discretion or authority.7 Thus, determining whether TSA 

is using an appropriate Adjudication Center workforce, and addressing 

the potential risks associated with its use of contractors, is important for 

TSA to ensure it effectively implements security threat assessments.

 

5 The BWS is the process used by DHS to manage its workforce and achieve the proper 

mix of federal and contractor skills to meet mission needs. DHS developed its BWS 

pursuant to, among other authorities, the Omnibus Appropriations Act, 2009, which 

required federal agencies to “devise and implement guidelines and procedures to ensure 

that consideration is given to using, on a federal basis, federal employees to perform new 

functions and functions that are performed by contractors and could be performed by 

federal employees.” See Pub. L. No. 111-8, Div. D, § 736, 123 Stat. 524, 689-91 (2009). 

See also Pub. L. No. 111-117, Div. C, § 743, 123 Stat. 3034, 3216-29 (2009) (requiring 

executive agencies to prepare an annual inventory of their service contracts and to 

analyze the inventory to, among other things, identify contracts that should be considered 

for conversion to performance by federal employees of the agency). 

6

An inherently governmental function is, as a matter of policy, a function that is so 

intimately related to the public interest as to require performance by government 

employees and includes activities that require either the exercise of discretion in applying 

government authority, or value judgments in making decisions for the government. See 48 

C.F.R. § 2.101. The Federal Acquisition Regulation lists examples of functions considered 

to be inherently governmental or that should be treated as such. See 48 C.F.R. § 7.503(c).

In addition, closely associated with inherently governmental functions are those that while 

not inherently governmental, may approach the category because of the nature of the 

function, the manner in which the contractor performs the contract, or the manner in which 

the government administers contractor performance. See 48 C.F.R. § 7.503(d).

7

Office of Management and Budget, Office of Federal Procurement Policy, Policy Letter 

11-01, Performance of Inherently Governmental and Critical Functions, 76 Fed. Reg. 

56,227 (Sept. 12, 2011).
 

Page 4 GAO-13-629 Transportation Security

You requested that we review the performance and staffing capacity of 

the Adjudication Center. This report addresses the following questions:

• To what extent has TSA measured performance for the Adjudication 

Center, and what do these data show?

• To what extent have TSA offices coordinated to ensure that the 

Adjudication Center effectively meets an evolving security threat 

assessment workload?

• To what extent has TSA addressed potential risks posed by using a 

mix of government employees and contractors to adjudicate security 

threat assessments?

To determine the extent to which TSA has measured performance for the 

Adjudication Center, and what these data show, we focused our review 

on Adjudication Center performance in processing cases for the TWIC, 

HME, and Aviation Worker programs. We selected and obtained 

Adjudication Center performance in processing cases for these three 

programs because TSA reported these programs accounted for 

approximately 95 percent of its security threat assessment caseload. 

Therefore, we considered Adjudication Center performance in processing 

the caseload for these three programs to generally reflect the 

performance of the Adjudication Center as a whole. We analyzed 

pertinent laws and regulations related to TSA’s security threat 

assessments and program requirements for the TWIC, HME, and Aviation 

Worker programs, including provisions enacted through the Uniting and 

Strengthening America by Providing Appropriate Tools Required to 

Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001,8 the 

Aviation and Transportation Security Act,9 and the Maritime 

Transportation Security Act (MTSA) of 2002.10 We also reviewed TSA 

program documentation that included performance standards and 

requirements for the Adjudication Center and its contractor, such as 

 

8

See Pub. L. No. 107-56, § 1012, 115 Stat. 272, 396-98 (2001) (codified as amended at 

49 U.S.C. § 5103a).

9

See Pub. L. No. 107-71, § 138, 115 Stat. 597, 639-40 (2001) (amending 49 U.S.C. § 

44936).

10See Pub. L. No 107-295, § 102(a), 116 Stat. 2064, 2073-74 (2002) (codified as 

amended at 46 U.S.C. § 70105). 
 

Page 5 GAO-13-629 Transportation Security

Standard Operating Procedures for Case Management and contract 

documentation which included performance standards and requirements 

for the Adjudication Center and its contractor, such as the Adjudication 

Center’s Quality Assurance Surveillance Plan and Evaluation and 

Performance Reports. Through our review, we determined TSA used 

three key performance metrics to measure the performance of the 

Adjudication Center in processing security threat assessments: (1) 

timeliness for completing initial adjudication of a case, (2) caseload size, 

and (3) adjudication accuracy. We obtained and analyzed performance 

data for these programs and measures for the period of October 2010 

through January 2013 because this time period covers the operations of 

the Adjudication Center’s current contractor.11 We assessed the reliability 

of these data by reviewing TSA’s data management practices and 

questioning knowledgeable officials about the data and the systems that 

produced the data. On the basis of our assessments, we determined that 

some of the data were sufficiently reliable for the purposes of this report, 

but that other data were not. In particular, we found that TSA’s Aviation 

Worker caseload size data had been unreliable since April 2012—so as 

we describe later in this report, we did not include data after that time in 

our analysis. We evaluated Adjudication Center performance 

measurement practices against criteria outlined in Standards for Internal 

Control in the Federal Government.

12 Finally, we interviewed officials from 

various TSA offices with responsibilities for implementing aspects of 

security threat assessments or measuring performance of the 

Adjudication Center. These included officials from the Office of Law 

Enforcement/Federal Air Marshal Service (OLE/FAMS) Adjudication 

Center and the Office of Intelligence and Analysis (OIA), including the (1) 

Technology Infrastructure Modernization (TIM) program, (2) Program 

Management Division which is responsible for managing TSA’s maritime, 

surface, and aviation credentialing programs, which include the TWIC, 

HME, and Aviation Worker programs, and (3) Office of Technology, which 

is responsible for managing TSA’s case management systems. In 

addition, we interviewed officials with the American Association of Airport 

Executives, to obtain information about their role as a vendor in TSA’s 

 

11 TSA implemented its most recent adjudication center workforce contract in 2010; 

however, officials reported that technical challenges in establishing its performance 

measurement system had limited their ability to track data until February 2011. 

12GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
 

Page 6 GAO-13-629 Transportation Security

Designated Aviation Channeler program, which TSA uses to transmit 

Aviation Worker case information with TSA-regulated airport authorities.13

To determine the extent to which TSA offices have coordinated to ensure 

that the Adjudication Center meets evolving security threat assessment 

workload demand, we reviewed and compared staffing related 

information in TSA documents, including the Adjudication Center’s 

October 2012 staffing plan which details staffing levels and workload 

projections for current and future year needs, as well as Adjudication 

Center workload and performance reports and project management 

reports. We interviewed TSA officials, including OIA officials responsible 

for implementing maritime, surface, and aviation security programs and, 

OLE/FAMS Adjudication Center officials responsible for workforce 

planning and operations at the Adjudication Center. We evaluated TSA’s 

reported collaboration practices in relation to those identified in Standards 

for Internal Controls in the Federal Government

14 and the Government 

Performance and Results Act, as amended.

15

To determine the extent to which TSA has addressed potential risks 

posed by using a mix of government employees and contractors to 

adjudicate security threat assessments, we reviewed DHS and TSA 

documents detailing the results of the Adjudication Center BWS 

assessment, including DHS and TSA plans and memorandums for 

addressing risks identified in the BWS Assessment. We analyzed DHS 

BWS guidance detailing the roles and responsibilities of the DHS BWS 

Program Management Office (BW PMO) and department components for 

implementing the BWS, and compared TSA actions against this 

guidance. We also interviewed DHS and TSA officials responsible for 

implementing the BWS, including officials from the DHS Office of the 

Chief Human Capital Officer, and the Executive Director and staff of the 

DHS BWPMO, which is responsible for developing, implementing, and 

overseeing department implementation of the BWS. We also interviewed 

TSA officials responsible for implementing the BWS for the Adjudication 

Center, including officials from the Office of Acquisition, which serves as 

 

13TSA Designated Aviation Channelers transfer airport worker biographical and fingerprint 

information to TSA. 

14GAO/AIMD-00-21.3.1.

15See, e.g., 31 U.S.C. § 1115(b)(7) (requiring that agency performance plans provide a 

basis for comparing actual program results with the established performance goals).
 

Page 7 GAO-13-629 Transportation Security

the lead for the effort, the Office of Human Capital, the Office of the Chief 

Counsel, and from OLE/FAMS, the Business Management Office and the 

Adjudication Center.

We conducted this performance audit from October 2012 to July 2013 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

TSA is responsible for administering background checks—known as 

security threat assessments—for maritime, surface, and aviation 

transportation security programs that have vetted approximately 15 

million applicants since 2003, according to TSA officials.16 Security threat 

assessments are designed to ensure that only eligible individuals are 

granted TSA-related credentials, such as a TWIC. Specifically, security 

threat assessments focus on identifying threats posed by individuals 

seeking to obtain an endorsement, credential, access, and/or privilege 

for, among other purposes, unescorted access to secure or restricted 

areas of transportation facilities at maritime ports and TSA-regulated 

airports, and for commercial drivers transporting hazardous materials. 

Implementing these programs is a shared responsibility among multiple 

TSA offices, including the OIA Program Management Division which 

manages the programs, and the Adjudication Center within OLE/FAMS, 

which serves as the primary operational component for conducting 

security threat assessments for 12 of TSA’s 17 aviation, maritime, and 

surface transportation credentialing programs—with the TWIC, HME and 

Aviation Worker programs accounting for a reported 95 percent of the 

 

16According to TSA officials, this number refers to the total number of names TSA 

reported vetting through its security threat assessment programs since 2003. While these 

programs include varying purposes, standards, or agency responsibilities, they include 

some or all of the following components: enrollment, security threat assessments, 

credential issuance, verification, renewal, and revocation.

Background 

TSA Security Threat 

Assessments and 

Responsible Offices
 

Page 8 GAO-13-629 Transportation Security

Adjudication Center’s workload.17 (See appendix I for a TSA organization 

chart showing TSA offices responsible for implementing transportation 

security threat assessment programs.)

The security threat assessment process includes reviewing information to 

determine if applicants are disqualified to possess a credential based on 

criminal offenses, immigration status, or a link to terrorism. The security 

threat assessment involves two key components:

• Automated watchlist and related vetting: The initial automated 

vetting process is conducted to determine whether any derogatory 

information is associated with the name and fingerprints submitted by 

an applicant during the enrollment process. Among the checks 

conducted by TSA, one is against criminal history records maintained 

by or available through the Federal Bureau of Investigation (FBI). 

These records contain information from federal, state and local 

sources in the FBI’s National Crime Information Center database and 

the FBI’s Integrated Automated Fingerprint Identification 

System/Interstate Identification Index, which maintain criminal records 

and related fingerprint submissions. A check is also conducted 

against the Terrorist Screening Database, which is the federal 

government’s consolidated terrorist watchlist and from which the 

Selectee and No-Fly lists, among others, are compiled.18 To 

determine an applicant’s immigration/citizenship status, applicant 

information is checked against the Systematic Alien Verification for 

Entitlements system. If the applicant is a U.S.-born citizen with no 

related derogatory information, the system can approve the 

individual’s application for a credential with no further review of the 

applicant or human intervention.

 

17For example, the TSA OIA manages the three largest programs: the TWIC program for 

maritime workers; the HME program for truckers seeking a commercial driver’s license 

endorsement to carry hazardous materials; and the Aviation Workers program for airport 

workers seeking unescorted access into airport secured areas. The Adjudication Center 

within OLE/FAMS is responsible for security threat assessment adjudication services to 

meet the workload needs of TSA credentialing programs. 

18TSA’s Colorado Springs Operations Center within OIA is responsible for conducting the 

terrorism related checks in the security threat assessment process. The Selectee List 

contains information on individuals who must undergo additional security screening before 

being permitted to board an aircraft. The No Fly List contains information on individuals 

who are prohibited from boarding an aircraft. 
 

Page 9 GAO-13-629 Transportation Security

• Adjudication Center review: A manual, second level review is 

conducted as part of an individual’s security threat assessment if (1) 

the automated vetting uncovers any derogatory information, such as a 

criminal offense19 or (2) the applicant has identified himself or herself 

to be a non-U.S.-born citizen or national. As such, not all applicants 

will be subjected to a second-level review.20 The Adjudication Center 

plays an integral role in the security threat assessment process by 

adjudicating cases for which an initial automated check finds potential 

links to criminal history or immigration eligibility issues. Adjudication 

Center staff review the program applicant’s enrollment file to 

determine if derogatory or other information may be potentially 

disqualifying. The applicant’s files are processed from credentialing 

program enrollment centers through two-web enabled case 

management systems, called the Screening Gateway and 

Consolidated Screening Gateway. Adjudication Center staff use the 

Screening Gateways as their tool for gathering, viewing, and 

synthesizing the information needed to conduct security threat 

assessments. 

Since its establishment in 2005, the Adjudication Center has relied 

primarily upon contractor staff to complete its security threat assessment 

workload, and a smaller number of federal government staff to conduct 

oversight and other functions.21 Contractor staff performs initial 

adjudication of cases, and may either approve applications if they 

determine an applicant is eligible to obtain a credential or refer the 

application to a federal (that is, TSA) adjudicator for further review if they 

determine the applicant to be ineligible. Federal staff review cases of 

 

19Criminal history record checks, which are fingerprint-based, require an adjudicator to 

review the applicant’s criminal history for a designated time frame and compare this 

information against a set of disqualifying criminal offenses identified in statute and 

corresponding regulations in order to make a determination of eligibility. See, e.g., 49 

U.S.C. § 44936 (listing criminal offenses that, if committed at least within the most recent 

10-year period, would disqualify an applicant from obtaining, for example, unescorted 

access to the secure area of an airport); see also 49 C.F.R. §§ 1542.209, 1544.229. 

20According to TSA data about 42 percent of applicants are identified through automated 

vetting as having some derogatory information therefore requiring Adjudication Center 

review. 

21The Adjudication Center is located in Herndon, Virginia at a contractor-leased facility. 

TSA’s most recent contract for operating the Adjudication Center began in February 2010. 

TSA estimates the Adjudication Center operating costs for the first 3 years of the current 

contract (February 2010 to February 2013) at $20.2 million and the costs for the contract’s 

fourth year (February 2013 to February 2014) at $7.2 million. 
 

Page 10 GAO-13-629 Transportation Security

potential ineligibility, issue Preliminary Determination of Ineligibility letters 

to applicants, and conduct redress actions, among other things.22 As of 

May 2013, TSA reported that about two-thirds (37 of 55) of Adjudication 

Center staff were contractors.

Figure 1 shows the TSA credentialing process for the TWIC, HME, and 

Aviation Worker programs from enrollment through credential issuance, 

and the functions of the Adjudication Center’s TSA and contract staff in 

the security threat assessment process.

 

22If TSA determines an applicant meets one or more disqualifying criteria, the agency 

issues a Preliminary Determination of Ineligibility letter (formerly referred to as an Initial 

Determination of Threat Assessment) to the applicant. An applicant who receives such a 

letter may take steps to appeal the determination as instructed by TSA and consistent with 

applicable regulations—known as the redress process. See, e.g., 49 C.F.R. §§1572.15(d), 

1572.21(d) (addressing final dispositions and opportunity to appeal for the HME and TWIC 

programs, respectively); see also §§ 1515.5, 1515.9 (addressing appeals of 

determinations based on criminal convictions, immigration status, mental capacity, or 

other analyses). In some instances, an applicant disqualified based on criminal offenses, 

immigration status, or mental capacity standards may seek a waiver of this determination 

provided the applicant is not determined to oppose a security threat. See 49 C.F.R. § 

1515.7.
 

Page 11 GAO-13-629 Transportation Security

Figure 1: TSA TWIC, HME, and Aviation Worker Program Processes and Contractor and TSA Staff Functions in Security 

Threat Assessment Process at the Adjudication Center

a

TSA uses the Designated Aviation Channeler program to transmit Aviation Worker case information 

between TSA and TSA-regulated airport authorities. 

b

If TSA determines an applicant meets one or more disqualifying criteria, the agency issues a 

Preliminary Determination of Ineligibility letter to the applicant. An applicant who receives such a letter 

may take steps to appeal the determination as instructed by TSA and consistent with applicable 

regulations—known as the redress process.
 

Page 12 GAO-13-629 Transportation Security

Federal agencies face a complicated set of decisions in finding the right 

mix of government and contractor personnel to conduct their missions. 

While contractors, when properly used, can play an important role in 

helping agencies accomplish their missions, our prior work has shown 

that agencies face challenges with increased reliance on contractors to 

perform core agency missions.23 Consistent with Office of Management 

and Budget procurement policy, agencies should provide a greater 

degree of scrutiny when contracting for professional and management 

support, program evaluation, and other services that can affect the 

government’s decision-making authority—functions that may be 

considered as being closely associated with inherently governmental 

functions.24 Contractors can provide services that closely support 

inherently governmental functions, but agencies must provide greater 

scrutiny and enhanced management oversight to ensure that the 

contractors’ work does not limit the authority, accountability, and 

responsibilities of government employees.25

The DHS BWS refers to the department’s effort to identify the appropriate 

balance of federal and contractor employees required to support critical 

agency functions. Consistent with our recommendations26 and in

 

23See, for example, GAO, Defense Acquisitions: Further Actions Needed to Address 

Weaknesses in DOD’s Management of Professional and Management Support Contracts, 

GAO-10-39 (Washington, D.C. Nov. 20, 2009) and Department of Homeland Security: 

Improved Assessment and Oversight Needed to Manage Risk of Contracting for Selected 

Services, GAO-07-990 (Washington, DC.: Sept. 17, 2007). 

24Office of Management and Budget, Office of Federal Procurement Policy, Policy Letter 

11-01, Performance of Inherently Governmental and Critical Functions, 76 Fed. Reg. 

56,227 (Sept. 12, 2011).

25For example, the Federal Acquisition Regulation identifies services that can approach 

being inherently governmental, based on the nature of the function or the manner in which 

the work is performed or administered. See 48 C.F.R. § 7.503(d). Without proper 

management and oversight of contractors’ work, such services may unduly influence a 

federal agency’s control over and accountability for decisions.

26GAO-07-990. 

Use of Contractor 

Personnel and the DHS 

Balanced Workforce 

Strategy
 

Page 13 GAO-13-629 Transportation Security

accordance with the Omnibus Appropriations Act, 200927 DHS adopted 

the BWS in August 2010 to undertake risk analyses that are to enable the 

department to achieve the appropriate mix of Federal employees and 

contractors to accomplish its mission while minimizing mission risk that 

may result from an over-reliance on contractors.28 DHS uses an 

automated tool to help components—such as TSA—perform the 

necessary analysis to categorize work as appropriate for use of a 

contractor, inherently governmental, or closely associated with an 

inherently governmental function. The assessment tool is intended to 

facilitate an assessment of mission risk, level of contractor oversight 

needed, risk mitigation strategies, and cost analysis. Based on 

component responses, the tool is to provide a recommended sourcing 

decision on whether the work is appropriate for federal or contractor 

performance, or both. For example, should the BWS assessment find that 

a function is inherently governmental, the component would recommend 

the function be insourced to government employees, whereas a 

determination that the function was closely associated with an inherently 

governmental function would require the agency to either insource the 

function (also known as federalizing), or strengthen oversight of the 

contractor workforce.29

 

27See Pub. L. No. 111-8, Div. D, § 736, 123 Stat. 524, 689-91 (2009); see also Pub. L. 

No. 111-117, Div. C, § 743, 123 Stat. 3034, 3216-29 (2009) (requiring executive agencies 

to prepare an annual inventory of their service contracts and to analyze the inventory to, 

among other things, identify contracts that should be considered for conversion to 

performance by federal employees of the agency. According to the DHS FY 2011 Service 

Contract Inventory Analysis report, DHS components have used the BWS process to 

review a total of 248 contracts through the end of fiscal year 2011. According to this 

report, the total amount obligated to these 248 contracts is approximately $800,115,993. 

DHS reported that it had not yet completed its report of the FY 2012 Service Contract 

Inventory, as of March 2012. 

28According to DHS Balanced Workforce Strategy guidance, the purpose of the BWS is to 

(1) ensure compliance with applicable statutes, regulations, and policies, through a 

repeatable documented decision-making process; (2) determine the proper workforce 

balance for each component activity; and (3) reduce mission risk while, as practicable, 

reducing or controlling costs. 

29A sourcing decision is the determination of the appropriate workforce balance to perform 

a function. The sourcing decision may include a recommendation to either insource or 

outsource a government function. Insourcing is a decision and related functions to use 

federal employees to perform activities that are presently performed by contractors. 

Outsourcing is the use of contractors to perform new, unrestricted activities or to perform 

unrestricted activities currently performed by federal employees. 
 

Page 14 GAO-13-629 Transportation Security

In December 2011, we reported that the Adjudication Center had faced 

recurring challenges in meeting its security threat assessment workload 

requirements and largely attributed these challenges to its reliance on a 

contractor workforce.30 Specifically, the Adjudication Center had 

experienced recurring backlogs in completing its caseload, and 

Adjudication Center officials attributed these backlogs to staffing 

limitations caused by contractor turnover. Officials at the time reported 

that the challenge was that the Adjudication Center had used three 

different contractors since establishing the Adjudication Center in 2005, 

and on each occasion the contract adjudicator turnover had led to 

backlogs as adjudicators were hired and trained. TSA reported that it did 

not consider the risks of acquiring contractor support services to provide 

adjudication services before awarding its first contract in 2005. Rather, 

TSA reported that it chose to use contract adjudicators when the 

Adjudication Center was created because, at the time, it considered them 

to be the most readily available workforce and effective way to augment 

federal staff with skilled resources. TSA reported that the agency had 

initiated an assessment in March 2011 through the DHS BWS process to 

determine whether the adjudication functions were appropriate to be 

performed by a contractor workforce, whether the work was inherently 

governmental and whether there would be cost savings resulting from 

conversion of the contract positions to government positions. We 

recommended TSA develop a workforce staffing plan with timelines 

articulating how the Adjudication Center will effectively and efficiently 

meet its current and emerging workload requirements, and incorporate 

the results of TSA’s study examining the appropriateness and costs and 

benefits of using contractors. TSA concurred with our recommendation 

and reported that it had begun taking steps to implement it.

 

30GAO-12-60. 

Adjudication Center 

Contractor Related 

Performance Challenges
 

Page 15 GAO-13-629 Transportation Security

TSA has evaluated the Adjudication Center largely based on contractor 

performance in meeting established metrics and data shows mixed 

performance since 2011; however the Adjudication Center’s performance 

measures and practices are limited. We found that the Adjudication 

Center contractor met two of its three performance measures—for 

timeliness and accuracy—but did not do so for its caseload size 

measure.31 Further, these measures and practices were limited. For 

example, the Adjudication center’s methodology for calculating contractor 

adjudicator accuracy was limited because it did not include key 

information. Moreover, the Adjudication Center has not documented key 

elements of its performance measurement practices.

TSA has used performance data for three primary metrics to measure the 

performance of the Adjudication Center in conducting security threat 

assessments for the TWIC, HME, and Aviation Worker programs. The 

three metrics are timeliness for completing initial adjudication, caseload 

size, and adjudication accuracy. According to TSA Adjudication Center 

officials, these performance measures were established to evaluate the 

performance-based contract for adjudication services at the Adjudication 

Center.32

Timeliness. The Adjudication Center contractor met timeliness standards 

for completing initial adjudication of its TWIC, HME, and Aviation Worker 

caseloads (see figure 1 for a description of this process). TSA requires 

that its contract adjudicator workforce complete initial adjudication of 95 

 

31Based in part on these data, TSA evaluated and awarded performance based fees. The 

award fees are based on the contractor’s performance in meeting its caseload, timeliness, 

and accuracy rates. As of August 2012, TSA had awarded performance based fees to the 

Adjudication Center contractor totaling roughly $312,000 for work performed since 

October 2010. According to Adjudication Center officials, contractor employees were not 

formally evaluated on performance standards for the first six months of the contract, 

allowing them time to become familiar with Adjudication Center operations. When the 

Adjudication Center started to formally evaluate contractor performance after the 6 month 

period, technical limitations delayed analysis of some of the metrics.

32The Adjudication Center contract is performance-based. Based on the evaluations, the 

Adjudication Center provides its contractor with a varying award fee based on the extent 

to which the contractor meets performance measures, known as Acceptable Quality 

Levels. These Acceptable Quality Levels are documents in TSA’s contract for the 

Adjudication Center. 

Adjudication Center 

Performance Data 

Show Mixed Results, 

Accuracy Measures 

Are Limited, and 

Performance 

Measurement 

Practices Are Not 

Fully Documented

Two Performance 

Measures Showed Mixed 

Results 
 

Page 16 GAO-13-629 Transportation Security

percent of cases within 7 calendar days of the case entering TSA’s 

Screening Gateway case management systems for TWIC, HME, and 

Aviation Worker cases.33 According to TSA data, from August 2011 to 

January 2013, the adjudicator workforce met this standard for TWIC, 

HME, and Aviation Worker cases.34

While the Adjudication Center’s timeliness measure shows the 

Adjudication Center’s contractor met TSA’s standard for completing initial 

adjudication, the measure does not show the extent to which the agency 

has communicated its adjudication decision to the applicant in a timely 

manner—key statutory and TSA policy requirements for its credentialing 

programs—and TSA officials reported they did not maintain such 

documentation. For example, as specified in statute, TSA shall review an 

initial TWIC application and provide a response to the applicant, as 

appropriate, within 30 days of receiving the initial application.35 Moreover, 

officials with the OIA Program Management Division and Adjudication 

Center reported that TSA had established internal requirements for the 

agency to meet 30 day and 14 day applicant response times for HME and 

Aviation Worker applicants. Officials from the OIA Program Management 

Division reported tracking this measure through weekly Adjudication 

Center performance reports and identifying and addressing those cases 

 

33 According to TSA documentation, the Screening Gateway system provides an ondemand turnaround time report that details the number and timing of cases that are 

initially adjudicated. The turnaround time report counts the number of days it takes for 

cases to make their first move from when the case was received for adjudication to the 

time when the initial adjudication was made for either approving or disqualifying an 

applicant. 

34 Adjudication Center management officials told us that they track adjudicator 

performance for Aviation Worker cases differently than for the TWIC and HME programs. 

According to these officials, Aviation Worker cases are simpler and to adjudicate because 

the Adjudication Center is responsible for adjudicating the immigration status of an 

applicant, but is not responsible for adjudicating criminal history records. This is because, 

unlike with the TWIC and HME programs, local authorities (airport operators and aircraft 

operators) are responsible for adjudicating the results of TSA-provided FBI criminal history 

records, to determine whether applicants have potentially disqualifying records. 

35 See 46 U.S.C. § 70105(p) (providing further that, to the greatest extent practicable, a 

written decision or request for additional information shall be provided to an applicant in 

response to an applicant’s written request for an appeal or waiver within 30 days of 

receiving the request, and that for applicants required to submit additional information, a 

written decision shall, to the greatest extent practicable, be sent to the applicant within 30 

days after receipt of all requested information). See also, e.g., 72 Fed. Reg. 3,492, 3,556 

(Jan 25, 2007) (indicating that, as a general rule, security threat assessments and 

issuance of a TWIC should take no longer than 30 days). 
 

Page 17 GAO-13-629 Transportation Security

that do not meet applicant response time standards. However, officials 

reported that they did not maintain documentation showing the extent to 

which TSA had responded to applicants within their applicant response 

timeframe requirements. Officials reported that maintaining such 

performance data would be of use, but noted it was rare that they did not 

meet their initial adjudication standards and respond to applicants on or 

within established applicant response time requirements. Officials noted 

that functional limitations in TSA’s Screening Gateway reporting system 

limits their ability to efficiently run reports showing the extent to which 

TSA responds to applicants within required timeframes. A senior OIA 

Program Management Division official reported it was her understanding 

that the division would have to obtain the capability to automatically run 

applicant response time reports from TSA’s Technology Infrastructure 

Modernization program, known as TIM.36 However, we reviewed TIM 

program documentation and did not find this data management capability 

requirement in TIM planning documents. We raised this issue with TSA 

TIM program officials, and in response to our inquiry, in May 2013, the 

TIM program added documentation of this requirement to its plans and 

reported that the capability would be available to the Adjudication Center 

beginning in March 2014 for TWIC program cases, and by 2016 for 

surface and aviation program cases.37

Caseload size. The Adjudication Center generally did not meet its 

contract caseload performance standards and experienced backlogs for 

its TWIC and HME program caseloads the majority of the time between 

 

36Among other things, the TIM program seeks to consolidate and standardize the 

processes and systems for TSA screening and credentialing programs and populations, 

including for the TWIC, HME, and Aviation Workers programs. According to TSA, the TIM 

design and development contract was awarded in August 2012 and is budgeted for $48.7 

million in fiscal year 2014. TSA estimates the program to have a lifecycle cost of $631.2 

million through 2025 to be funded through fees and appropriations. GAO has previously 

reported on the TIM program. For more information on the TIM program, see GAO, 

Transportation Security Infrastructure Modernization May Enhance DHS Screening 

Capabilities, but It Is Too Early to Assess Results, GAO-12-192R (Washington, D.C. Dec. 

8, 2011).

37TSA officials reported that the TIM program is in the development process with initial 

operational capability planned for March 2014 and full operational capability in 2016. 

According to officials, after March 2014, the TWIC program will be migrated to the TIM 

platform and Adjudication Center officials will review cases via the TIM system. Officials 

reported that the surface and aviation programs are scheduled for migration to TIM in 

2015 and 2016, respectively. The Screening Gateway systems are scheduled to be 

replaced in 2016. 
 

Page 18 GAO-13-629 Transportation Security

October 2010 and January 2013. According to TSA contractor evaluation 

and performance reports, the Adjudication Center requires its contract 

workforce to maintain a total number of new TWIC, HME, and Aviation 

Workers cases at or below 1,500 cases—and Adjudication Center 

officials told us that a caseload above this threshold was considered a 

backlog. Adjudication Center data we reviewed for the period of October 

2010 through January 2013 showed that the Adjudication Center had a 

backlog of HME cases approximately 60 percent of the time and TWIC 

cases approximately 61 percent of the time. In addition, the Adjudication 

Center had a backlog of Aviation Worker cases approximately 15 percent 

of the time from October 2010 through March 2012.38 Moreover, many of 

these backlogs were far higher than the Adjudication Center’s 1,500 

caseload standard. For example, the Adjudication Center had a backlog 

of more than 4,000 HME cases roughly 16 percent of the time (20 of 122 

weeks) during this period. Figure 2 shows Adjudication Center caseload 

levels for TWIC, HME, and Aviation Worker cases from October 2010 

through January 2013.

 

38TSA data for the period of October 2010 through January 2013 includes 122 weeks of 

evaluation data. However, for the Aviation Worker program, our analysis covered the time 

period of October 2010 through March 2012—78 of 122 weeks. TSA officials reported 

TSA has not had have reliable Aviation Worker caseload data since April 2012. TSA 

reported that these data were unreliable because of technical problems TSA has 

experienced with its Designated Aviation Channeler program for processing Aviation 

Worker program security threat assessment applications submitted by airport authorities. 

TSA has reported experiencing technical problems with one of its three approved 

Designated Aviation Channeler vendors since April 2012. TSA Office of Intelligence and 

Analysis officials reported they were working with the vendor to resolve the causes for its 

data reliability limitations and were in the process of updating policies and procedures to 

address the issues.
 

Page 19 GAO-13-629 Transportation Security

Figure 2: Caseload Levels for TWIC, HME, and Aviation Worker Programs, October 2010 through January 2013

a

TSA identified the Aviation Worker caseload size data as being unreliable since April 2012. TSA 

reported that these data were unreliable because of technical problems TSA has experienced with its 

Designated Aviation Channeler program TSA used to process Aviation Worker security threat 

assessment applications. TSA reported it had yet to resolve the causes for its data reliability 

limitations and continues to seek a solution from the vendor experiencing technical problems. 

According to Adjudication Center officials and TSA documentation we 

reviewed, technical issues and a lack of sufficiently trained contract 

adjudicators contributed to the workload backlogs at the Adjudication 
 

Page 20 GAO-13-629 Transportation Security

Center.39 First, the Adjudication Center operations manager reported that 

technical problems with its case reporting systems had contributed to 

both challenges in assessing workload backlogs and, in some cases, 

growth in the backlog itself. For example, the Screening Gateway 

systems, which the Adjudication Center relies on for processing applicant 

cases and communicating results to TSA enrollment centers, has 

experienced periodic technical errors that have delayed the Adjudication 

Center’s ability to process new cases. According to TSA evaluation and 

performance reports we reviewed, between February 2012 and August 

2012, TSA was unable to evaluate contractor performance in meeting its 

workload on several occasions, including approximately 3 months, 

because of technical problems with its case management systems. 

Adjudication Center officials reported that TSA’s Office of Technology 

was pursuing a solution to the technical errors with a solution expected by 

May 2012; however, as of May 2013 this had not been corrected. They 

also reported that TSA plans to replace this system with a more functional 

system through its TIM program, but as noted earlier, according to TSA’s 

schedule for the program and TSA officials, this system is not scheduled 

to be fully operational until 2016. In addition, since April 2012 TSA has 

experienced technical problems related to the Designated Aviation 

Channeler program that TSA uses to process Aviation Worker program 

cases into the Screening Gateway systems. According to TSA officials, 

technical problems with one of its vendors were delaying processing of 

cases and returning previously adjudicated cases into the Adjudication 

Center’s new caseload queue and not distinguishing between the two 

sets of cases. This was delaying processing time and Adjudication Center 

management was unable to determine the true extent of its new 

caseload. TSA officials responsible for managing the Designated Aviation 

Channeler program reported that they had been in discussions with the 

vendor since April 2012 to address the technical processing issues, and 

 

39The Adjudication Center program manager also reported on other factors that had 

contributed to workload backlogs. The official told us that enrollment for the TWIC, HME, 

and Aviation Worker programs experienced peaks and lulls at different times of the year, 

depending on the program, and that this had accounted for some of the larger spikes in its 

backlogs over the past few years. For example, TWICs, in general, are to expire 5 years 

after the date of issuance. See 49 C.F.R. § 1572.23. With respect to HMEs, each state 

must require that hazardous material endorsements be renewed every 5 years or less so 

that individuals are subject to a TSA security threat assessment at least every 5 years. 

See, e.g., 72 Fed. Reg. 3,492, 3,495 (Jan. 25, 2007) (providing that a security threat 

assessment is valid for 5 years).
 

Page 21 GAO-13-629 Transportation Security

as of May 2013, the vendor was in the process of implementing corrective 

actions.

Another factor contributing to growth in the workload backlog according to 

TSA Adjudication Center management officials and a contractor 

performance report we reviewed has been the lack of trained adjudicators 

provided by the contractor.40 According to a senior Adjudication Center 

official, the contractor lacked a sufficient number of staff who had been 

certified as self approvers, and this had required the Center’s limited 

federal staff to assume additional responsibilities and reduced the 

Center’s progress in meeting its caseload.41 Adjudication Center officials 

reported that they were working with the contractor to address this issue.

We discuss the Adjudication Center’s contractor-related staffing issues, 

and actions to address them, in more detail later in this report.

 

40For example, according to a TSA Adjudication Center contractor evaluation and 

performance report we reviewed, contractor performance in meeting this measure was 

unsatisfactory because the contractor did not have a sufficient number of trained initial 

adjudicators to meet case load and overall production requirements.

41According to Adjudication Center Standard Operating Procedures, initial adjudicators 

are required to meet acceptable case production and accuracy rates before they can be 

nominated by the contract program manager for self-approval rights for those cases that 

are approved (no determination of threat). 
 

Page 22 GAO-13-629 Transportation Security

For its third key performance measure, TSA requires its contract 

adjudicators to maintain an average accuracy rate of at least 95 percent.42

According to Adjudication Center data, from August 2011 to December 

2012, the Adjudication Center’s contract workforce met TSA’s accuracy 

standard for the TWIC, HME, and Aviation Worker programs.43 However, 

the accuracy rate is not a complete representation of Adjudicator contract 

accuracy because it does not include evaluation of a key population of 

cases. According to Adjudication Center officials, the Adjudication 

Center’s average accuracy rate is generally based on error rates 

identified from a daily review of all cases where adjudicators found an 

applicant was disqualified, but reviewers found an applicant should not 

have been (i.e., incorrectly disqualified). However, according to officials, 

this calculation generally does not include those cases where 

adjudicators had approved applicants, but reviewers found they should 

have been disqualified (i.e., incorrectly approved). For example, 

according to our analysis of TSA data, approvals comprised over 90 

percent of the Adjudication Center’s TWIC and HME caseload from 

August 2011 to January 2013—and TSA reviewed roughly 7 percent of 

these approvals. In this way, the average accuracy rate TSA uses to 

evaluate the performance of its contractor is incomplete and limited 

because it does not include the extent contract adjudicators incorrectly 

approved applicants.44

The Adjudication Center official responsible for reporting the accuracy 

rate told us that the accuracy rate of the contract workforce includes only 

 

42According to TSA, adjudication accuracy is measured weekly by compiling daily 

contractor and government mid-level adjudicator production reports to calculate the total 

number of (1) cases reviewed; (2) cases with incorrect errors; and (3) cases with 

incomplete errors. Incorrect errors are either those cases approved when the applicant 

should have been disqualified or cases where an adjudicator found an applicant was 

disqualified when the applicant had no disqualifying factors. Incomplete errors refer to 

leaving any element of the case not adjudicated that should have been part of the initial 

adjudication, such as administrative errors. 

43According to our analysis of TSA data, the Adjudication Center had accuracy rates of 

approximately 99 percent for HME and TWIC cases. TSA reported a 99 percent accuracy 

rate for Aviation Worker cases. For Aviation Worker cases, the Adjudication Center 

reviews only immigration history, and transmits the results of this review to airports which 

are responsible for adjudicating criminal history for aviation workers. 

44Adjudication Center program managers reported that the accuracy rate includes errors 

found occasionally in cases when reviewers are reconciling administrative errors in the 

Screening Gateway systems. If errors are found, officials said these errors are calculated 

into the average accuracy rate. 

The Adjudication Center’s 

Contractor Met TSA’s 

Accuracy Rate, but the 

Rate Does not Include Key 

Information 
 

Page 23 GAO-13-629 Transportation Security

those cases that were incorrectly found to have disqualifying factors 

because that is how the contract evaluation standards were established.

The official noted that the Adjudication Center processes included a 

review of all trainee adjudicators approved cases and a separate quality 

assurance review process to spot check approved cases45 to identify 

errors among all adjudicators who are certified to approve cases without 

further review.46 However, the official reported that these performance 

measurement practices were not documented and that a lack of staffing 

capacity had limited the extent to which the Adjudication Center 

conducted the quality assurance spot checks—with the Center meeting 

only about two-thirds of its 10 percent goal for the number of cases 

selected for spot checking. Nonetheless, the results of this quality 

assurance review are not factored into the rate TSA uses to measure 

contractor accuracy performance and award funds to its contractor.

Standards for Internal Control in the Federal Government specifies the 

need to comprehensively identify risks and consider all significant 

interactions. Once risks have been identified, they should be analyzed for 

possible effect. Moreover, internal control and all transactions and other 

significant events need to be clearly documented, and the documentation 

should be readily available for review.47 The overall accuracy rate 

calculated by the Adjudication Center is generally limited to incorrectly 

disqualified cases and does not include incorrectly approved cases. In 

this way, TSA does not have a representative assessment of the 

Adjudication Center’s average accuracy rate. If error rates for approved 

 

45According to Adjudication Center officials, all cases in which the contract adjudicator 

workforce determines an applicant had committed disqualifying offenses within applicable 

time frames (i.e. applicant would not pass a security threat assessment) are verified by 

TSA employees. However, contract adjudicators that determine an applicant had not 

committed a disqualifying offense within applicable time frames may approve that case 

without this second level of review if the contract adjudicator has been certified by 

Adjudication Center management as a “self-approver” and is no longer considered a 

trainee. Those cases approved by adjudicators certified as self approvers are subject to 

the Adjudication Center’s quality assurance check. According to Adjudication Center 

officials, cases with errors found in these two processes are corrected before the 

Adjudication Center informs the applicant of the results of the security threat assessment. 

46According to Adjudication Center officials, the quality assurance checks are a way to 

ensure that cases are being adjudicated properly and that the Adjudication Center does 

not incorrectly approve applicants with disqualifying offenses, while also identifying and 

addressing performance issues among its contract adjudicator workforce.

47GAO/AIMD-00-21.3.1.
 

Page 24 GAO-13-629 Transportation Security

cases were included in its evaluation, the Adjudication Center’s reported 

average accuracy rate may ultimately be higher or lower than it has 

reported—but it will remain unclear until the Adjudication Center captures 

this information in its accuracy rate. Determining the performance of the 

workforce in adjudicating security threat assessments for this population 

is important for overseeing adjudicator performance and identifying cases 

where the Adjudication Center is incorrectly approving applicants. By 

developing and documenting an accuracy rate measure that includes 

data on both types of incorrectly adjudicated cases (approved and 

disqualified), the Adjudication Center can determine an accuracy rate that 

comprehensively captures accuracy performance and enables 

Adjudication Center management to more effectively identify and address 

performance issues among its workforce.

Since beginning operations in 2005, Adjudication Center management 

officials told us that they have used a complex, manual process to track 

the performance data of its contract adjudicator workforce. In particular, 

because of functional limitations of TSA’s Screening Gateway systems, 

officials reported that the Adjudication Center lacks an automated process 

for tracking adjudicator performance of the estimated 7,500 to 10,000 

security threat assessment cases that adjudicators process each week.48

As a result, Adjudication Center management has used a cumbersome, 

manual process to track case production and performance of its contract 

adjudicator workforce.49 For example, each week, one adjudication center 

official is responsible for reviewing contractor reported caseload 

information, compiling spreadsheets summarizing contractor 

performance, verifying and reconciling the information with the contractor, 

and preparing weekly summary reports for distribution to TSA 

credentialing program stakeholders. Adjudication Center management 

 

48According to Adjudication Center officials, the cases requiring Adjudication Center 

review are forwarded, through the automated Screening Gateway process, to the 

Adjudication Center. The Operations Manager then assigns cases to individual contractor 

adjudicators. 

49For example, according to officials, a single case can change hands 50 times among 

Adjudication Center staff during the adjudication process and therefore the Gateways 

record different start and stop dates for each time and record these as separate cases. 

Therefore, the Gateways cannot track a single case as it progresses through the 

adjudication process, and that is why data such as initial adjudication duration have to be 

tracked manually. 

The Adjudication Center’s 

Manual Performance 

Management Process is 

not Documented
 

Page 25 GAO-13-629 Transportation Security

told us that it has used these reports to measure Adjudication Center 

performance and support oversight of its contract adjudicator workforce.

The manual process exists because, according to Adjudication Center 

officials, TSA’s Screening Gateway case management systems were not 

designed to meet the functional requirements of the Adjudication Center 

for tracking contractor operational performance, and TSA has been 

unsuccessful to date in developing a technical solution to do so.50 TSA 

officials recognized that the system did not meet the needs of the 

Adjudication Center and reported that the agency’s TIM program would 

replace the Screening Gateway systems and enable the adjudication 

center to automate its case tracking and performance requirements. 

However, as noted earlier, TSA officials reported that this new system is

not scheduled to be fully operational until 2016.

In the meantime, however, Adjudication Center management officials 

reported that they had not documented the manual process currently in 

use. Adjudication Center management officials told us that they had 

placed some information on an internal web sharing system in the past, 

but that this information was neither thorough nor updated to reflect the 

case management reporting system that the Adjudication Center has 

used since 2010—when TSA began its most recent contract for 

Adjudication Center staff. According to Adjudication Center officials, time 

constraints in meeting the Adjudication Center’s workload of security 

threat assessments had been a factor that had prevented the Operations 

Manager from updating or developing new documentation of the 

procedures in recent years. Further, given the complexity of the process 

and that two officials were familiar it, a senior Adjudication Center 

management official said that documenting this process would be of value 

should the two officials be unavailable.

Standards for Internal Control in the Federal Government specifies the 

need for appropriate documentation of transactions and internal control. 

 

50According to Adjudication Center officials, efforts to incorporate these functional 

requirements into the system were unsuccessful. TSA officials reported that while they 

had explored several options, including the use of off the shelf technologies, the system 

TSA currently had in place was not compatible, and that these technical limitations and 

the cost considerations for using other technical solutions were contributing factors. The 

key obstacle, according to Office of Technology officials, was that the Screening Gateway 

case management system was designed without the capability for absorbing the 

Adjudication Center’s case management requirements.
 

Page 26 GAO-13-629 Transportation Security

Internal control and all transactions and other significant events need to

be clearly documented, and the documentation should be readily 

available for review.51 The documentation should be included in 

directives, policies, or manuals to help ensure operations are carried out 

as intended. Documenting the Adjudication Center’s case reporting 

performance measurement practices is important to allow someone 

unfamiliar with this process to assume responsibilities in the event of 

attrition by the Adjudication Center managers. This is particularly 

important considering the complexity of the Adjudication Center’s case 

performance reporting process and TSA’s need to ensure effective 

performance and operational continuity in its security threat assessments.

Implementing credentialing-related programs is a shared responsibility 

between the Program Management Division in TSA’s OIA and the 

Adjudication Center in OLE/FAMS. Officials from these offices reported 

taking various actions to ensure its offices coordinate information related 

to security threat assessment adjudication workload planning and 

performance. These include:

Sharing weekly Adjudication Center performance reports: These 

reports include information for the TWIC, Aviation Worker, and HME 

programs such as the number of cases the Adjudication Center receives 

for each of these programs during the prior week, the number of cases 

ready for adjudication, and the number of applicants who have sought 

redress based on initial determinations of ineligibility. The three program 

managers for TSA’s maritime, aviation, and surface credentialing 

programs reported that they rely on these reports to ensure the program 

offices are meeting workload demands for the various credentialing 

programs TSA supported, and to identify and develop strategies to 

address performance challenges.

Convening monthly program management review meetings: These 

meetings are used to share information relating to changes that may 

impact the Adjudication Center’s workload.52 As part of these meetings, 

 

51GAO/AIMD-00-21.3.1. 

52According to a senior Adjudication Center official, those invited to attend include TSA 

offices from the Office of Acquisition, OLE/FAMS, the Office of Human Capital, and 

credentialing program offices. 

TSA Offices Can 

Strengthen 

Coordination to 

Ensure Effective 

Adjudication Center 

Workload Planning
 

Page 27 GAO-13-629 Transportation Security

the Adjudication Center contractor provides a monthly report which 

provides details pertaining to contractor staffing levels and changes, 

training status, contractor accuracy rates, and challenges in need of 

resolution.

Developing spend plans: Adjudication Center and the OIA Program 

Management Division officials meet to develop a spend plan to support 

the credentialing programs’ annual budgets and discuss population 

projections for the programs that would affect Adjudication Center 

workload. For example, the Aviation Worker program manager reported 

that the workload had increased by about 5 percent annually, and that 

this information was used to inform the Adjudication Center’s spend plan.

Notwithstanding these actions, opportunities exist for the Adjudication 

Center and OIA Program Division to strengthen their coordination. While 

officials with the two offices coordinate on a routine basis to share 

information on workload completion, they do not have a process in place 

to ensure that information in the Adjudication Center’s staffing plan—such 

as caseload projections and associated staffing needs—reflects the 

mutual understanding of both Adjudication Center and credentialing 

program management officials.53 For instance, Adjudication Center 

management officials have periodically updated a staffing plan that they 

use to guide Adjudication Center workforce planning. However, an 

Adjudication Center program management official reported that while the 

staffing plan had been shared with credentialing program managers in the 

past, it had not been shared in recent years. He reported that a prior plan 

had been shared with the OIA Program Management Division to 

communicate staffing needs, and said that sharing the updated versions 

of the staffing plan with the Program Management Division may be 

valuable for guiding decisions on workforce planning.

OIA Program Management Division officials reported that they were 

unfamiliar with the Adjudication Center’s staffing plan and questioned 

workload projections in the Adjudication center’s current staffing plan. For 

example, the current Adjudication Center staffing plan cites an anticipated 

regulation that will address the security threat assessment process and 

that according to the plan would double the Adjudication Center’s security 

 

53Adjudication Center management officials develop and periodically update a staffing 

plan that identifies current and future year caseload projections and estimated workforce 

needs, as well as performance challenges.
 

Page 28 GAO-13-629 Transportation Security

threat assessment workload from 500,000 to 1 million per year by the end 

of fiscal year 2014, and triple the workload by the end of fiscal year 

2015.54 In October 2012, we shared this staffing plan with the OIA 

Program Management Division Manager responsible for Aviation 

programs and that official questioned the accuracy of the aviation worker 

workload increase projections in the staffing plan. The official said that 

TSA had yet to issue this regulation and that the timeline for doing so 

would take longer than officials had initially planned. Thus, the projected 

workload increases in the Adjudication Center’s staffing plan would not be 

realized, and the plan would need to be revised. However, as of March 

2013, the Adjudication Center’s staffing plan had not been updated.

According to key collaboration practices that we have identified, federal 

agencies engaged in collaborative efforts need to create the means to 

monitor and evaluate their efforts to enable them to identify areas for 

improvement.55 Reporting on these activities can help key decision 

makers within the agencies, as well as clients and stakeholders, obtain 

feedback for improving both policy and operational effectiveness. Such 

reporting mechanisms can then be used to modify plans. Moreover, a 

focus on results, as envisioned by the Government Performance and 

Results Act, as amended, implies that federal programs contributing to 

the same or similar results should collaborate to ensure that goals are 

consistent and, as appropriate, program efforts are mutually reinforcing.56

In this way, ensuring these components have access to respective 

workforce planning documents by establishing a mechanism for OIA 

Program Management Division and Adjudication Center officials to share 

and reconcile information included in the Adjudication Center’s staffing 

plan updates, such as timelines for anticipated workload growth, will help 

ensure TSA is using accurate workload projections to guide the 

Adjudication Center’s workforce planning.

 

54TSA officials reported that the agency is engaged in a rulemaking effort under which, 

among other things, TSA would assume responsibility for the adjudication of criminal 

background checks for airport and aircraft operator workers, for which airport and air 

carrier operators are currently responsible. TSA officials reported that this additional 

responsibility would account for a considerable increase in the workload of the 

Adjudication Center. 

55GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, DC: Oct. 21, 2005).

56See, e.g., 31 U.S.C. § 1115(b)(7).
 

Page 29 GAO-13-629 Transportation Security

Between January 2011 and September 2011, TSA conducted and 

completed its DHS required BWS assessment for the Adjudication Center 

contract and determined that the adjudicator position represented work 

that is “closely associated with inherently governmental functions” and 

that an excessive risk exists by allowing contractors to make security 

credential approvals without sufficient federal oversight. According to the 

assessment, the adjudicator functions performed by the contractor are 

critical to TSA’s accomplishment of the security threat assessment 

process to ensure terrorist and other security threats are identified and 

prevented from gaining credentialed access to critical U.S. transportation 

system infrastructure.57 The assessment found that TSA was reliant upon 

contractors for making decisions regarding criminal history and 

immigration status for a majority of applicants and if contractors were to 

continue performing the adjudicator function, the government would need 

to provide continuous and substantive oversight of them to ensure 

successful performance.58 However, the assessment found that the 

Adjudication Center did not have an effective oversight process in place 

to do so—noting that the federal government staffing at the Adjudication 

Center is not sufficient to adequately oversee contractor case processing 

for quality control, as contract staff have independent decision making 

 

57According to DHS BWS guidance, a critical function is a function that is necessary to the 

department being able to effectively perform and maintain control of its mission and 

operations. 

58Out of a scale of 1 to 10, the assessment rated the need for continuous and substantive 

oversight of the contractors as a 10, the highest level.

TSA Has Made 

Limited Progress in 

Addressing Risks 

Posed by Using 

Contract Employees 

to Adjudicate Security 

Threat Assessments

TSA Assessment Identified 

Risks in the Adjudication 

Center’s Use of 

Contractors 
 

Page 30 GAO-13-629 Transportation Security

ability on the majority of cases.59 Further, the assessment noted that the 

Adjudication Center’s use of a mixed contractor and government 

workforce was inefficient. For example, according to the assessment, for 

every contractor work hour, a federal government employee must check 

that work and this had led federal government staff to work more than 

2,500 overtime and compensation hours over the preceding year—an 

inefficient and duplicative process that would not be necessary if the 

workforce were all federal government officers.60

In light of these factors, in October 2011, TSA’s BWS Departmental 

Working Group determined that the adjudicator function was closely 

associated with inherently governmental functions and recommended 

TSA end the Adjudication Center’s reliance on a contract workforce and 

convert to an all federal employee workforce.61 The working group 

reported that doing so was designed to improve the Adjudication Center’s 

security threat assessment processing by having a better oversight 

process, streamlining overall operations, reducing training requirements, 

and better managing resources.

TSA has been delayed in implementing the proposed workforce 

conversion at the Adjudication Center. According to TSA’s May 2012 

Adjudication Center conversion plan, TSA offices were to take several 

actions before the Adjudication Center may begin implementing its 

conversion plan and hiring a new federal employee workforce; however, 

these steps have generally not been implemented. For instance, as of 

May 2013, responsible stakeholders in TSA’s BWS effort, including the 

Office of Human Capital and OLE/FAMS, reportedly had not approved the 

 

59The assessment found that the department did not have the resources or capability to 

give heightened management attention to the contractor performance to ensure such 

performance does not expand to include inherently governmental functions, limit or guide 

the contractor’s exercise of discretion, and ensure reasonable identification of contractor 

products. 

60The assessment also noted that there was a duplication of government and contract 

management staff, and that some of the redundancies could be eliminated with a single, 

federal government workforce. 

61Officials from several TSA offices are responsible for conducting, reviewing and 

approving the BWS implementation plan. These components include: the Office of 

Acquisition, which serves as the lead for the effort, as well as the Office of Human Capital, 

Office of Finance and Administration, and from OLE/FAMS, the Business Management 

Office and Adjudication Center. 

TSA Has Been Delayed in 

Implementing Workforce 

Conversion 
 

Page 31 GAO-13-629 Transportation Security

plan—necessary steps before the plan can proceed to TSA leadership, 

and ultimately, DHS for review. According to the conversion plan, TSA 

proposed to convert to a government adjudicator workforce by hiring TSA 

employees during fiscal years 2013 and 2014—with the hiring to be 

completed by the end of calendar year 2013. However, as of May 2013, 

TSA had not begun hiring its new federal workforce and TSA officials 

reported that the agency had not determined new timelines to do so.

TSA officials attributed the agency’s delays in implementing the 

Adjudication Center conversion plan to its prioritization on implementing 

agency reorganization efforts. According to a senior TSA official, 

implementing the BWS assessment was delayed because TSA was 

undergoing a large reorganization and agency resources were prioritized 

to that effort.62 With this reorganization completed in January 2013, the 

official reported that implementing the conversion plan would become a 

greater priority.

TSA’s delay in acting on the recommendations of Adjudication Center 

conversion has rendered the implementation timelines and key hiring 

level and cost information in its May 2012 conversion plan outdated or 

unclear and TSA has not updated the plan to reflect these changes. In 

particular, TSA’s plan to convert to an all-federal Adjudication Center 

workforce has not been updated although information in this plan, such as 

the timeline for hiring federal employees and cost information, is no 

longer valid or is unclear. For example:

• The implementation schedule in TSA’s plan is no longer valid.

TSA officials responsible for managing the conversion effort 

acknowledged that the timelines for implementing its plan had been 

delayed, and that TSA would not complete its workforce conversion 

by the end of calendar year 2013 as proposed in its plan. TSA officials 

reported that determining a revised schedule for the Adjudication 

Center conversion was dependent on various factors, such as when 

responsible TSA offices completed their respective reviews, and when 

 

62Since December 2011, TSA has implemented two reorganizations affecting security 

threat assessment program offices. First, in December 2011, TSA transferred the 

Adjudication Center from the Transportation Threat Assessment and Credentialing Office 

to OLE/FAMS. Second, in January 2013, TSA realigned its transportation industry vetting 

program management functions, responsibilities, positions, and funding from the Office of 

Security Policy and Industry Engagement to OIA.

TSA Has Not Updated and 

Approved the Conversion 

Plan and Key Plan 

Elements are Unclear
 

Page 32 GAO-13-629 Transportation Security

OLE/FAMS approved the plan and sent it to TSA leadership for 

review. TSA officials reported that TSA did not have timelines for 

when this would occur.

• Implementing the in-sourcing plan may present a cost saving 

opportunity to TSA, but TSA is unclear on extent of those 

savings. According to an August 2012 OLE/FAMS memorandum, 

converting from contractor to federal employees at the Adjudication 

Center would save the federal government over $5.4 million in fiscal 

years 2013 and 2014.63 However, TSA’s May 2012 conversion plan 

reports that the conversion plan would result in approximately $1 

million in savings, rather than the $5.4 million cited in an August 2012 

OLE/FAMS memorandum. According to the May 2012 plan, TSA used 

the DHS Modular Cost Table to determine the potential cost savings 

from converting to a federal employee workforce at the Adjudication 

Center.64 TSA budget officials reported that they could not determine 

why the cost savings estimates varied between the May 2012 

conversion plan and the August 2012 memorandum. The officials 

reported that the cost savings estimate was still speculative and that 

TSA would need to revisit its calculations. As of May 2013, TSA had 

provided no further information.

TSA officials involved in the BWS Adjudication Center conversion noted 

that the delays in implementing the plan may pose challenges for TSA. 

For example, TSA’s contract for the Adjudication Center is a 

performance-based contract, with 1 option year remaining that would 

begin in February 2014 and run to January 2015.65 The official reported 

that continuing the contract would delay TSA from potential cost savings, 

while the cost to TSA continuing the contract increases 3 percent per 

 

63Adjudication operations are funded through numerous sources, including TWIC and 

HME fee collections and amounts appropriated for aviation security.

64The DHS Modular Cost Standards were developed to enable program managers to 

calculate the true cost of a new Federal position. These standards can be used to identify 

salaries and expenses as well as one-time and recurring costs associated with 

establishing new positions.

65The contract includes a 1-year base period with four, 1-year options. According to a TSA 

official, at the conclusion of this contract TSA would have to recomplete the contract in 

accordance with federal acquisition guidelines if it were to continue with a contract 

workforce.
 

Page 33 GAO-13-629 Transportation Security

option year.66 Officials reported that if they did not begin hiring new 

federal employees by August 2013, they would need to begin the process 

to recompete the Adjudication Center staffing contract to ensure 

continuity of operations in the case that TSA does not implement its 

conversion plan.

According to DHS BWS guidance, the more important the function, the 

more important it is to have internal capability to maintain control of the 

department’s mission and operations. TSA’s BWS assessment found that 

(1) TSA lacked sufficient internal capacity to control its use of contractors 

in Adjudication Center mission and operations, (2) TSA’s reliance on a 

contractor workforce carried excessive risk, (3) the adjudicator functions 

were closely associated with inherently governmental functions, and (4) 

that the positions should be insourced.

This assessment was made almost 2 years ago. While senior TSA 

Adjudication Center management officials support implementation of the 

plan, collectively, TSA has not mitigated the risks and operational 

inefficiencies identified in the DHS BWS assessment. Moreover, TSA has 

not completed its internal review of the conversion plan, including 

determining a revised implementation schedule as well hiring target levels 

and cost information. Completing this review, determining this 

information, and updating the conversion plan to ensure the plan reflects 

current conditions and an estimation of cost savings will help TSA and 

DHS decision makers by providing a roadmap for moving forward. Finally, 

implementing TSA’s Adjudication Center workforce conversion will be 

important to ensure TSA has sufficient and appropriate adjudication 

personnel to make the decisions that may deny or allow individuals 

unescorted access to the nation’s critical transportation infrastructure.

TSA’s Adjudication Center plays a critical role by conducting security 

threat assessments to ensure individuals posing security threats are 

identified and are not granted TSA-related credentials for, among other 

things, unescorted access to secure areas of the nation’s transportation 

systems. However, the Adjudication Center has faced challenges in 

 

66According to TSA officials, once the plan is approved by TSA and DHS, implementing 

the workforce conversion—from posting the federal positions to completing hiring of new 

staff—would take approximately 18 months. Training the new workforce may take up to 12 

months according to the Adjudication Center staffing plan.

Conclusions 
 

Page 34 GAO-13-629 Transportation Security

fulfilling this role. First, while the Adjudication Center uses three key 

measures to evaluate the performance of the Adjudication Center’s 

contract workforce, it has not documented its methods and two of its 

measures are limited. For example, TSA’s timeliness measure does not 

capture the extent to which the agency has communicated its adjudication 

decision to the applicant in a timely manner—a key TSA requirement for 

its credentialing programs—and TSA officials reported they did not 

maintain such documentation. Ensuring that the TIM program provides 

the capability for Adjudication Center officials to efficiently prepare and 

document applicant response time reports would help ensure TSA meets 

standards and decisionmakers identify and address performance 

challenges. In addition, the Adjudication Center’s accuracy rate generally 

does not include cases in which contract adjudicators incorrectly 

approved an applicant—and these constitute roughly 90 percent of the 

Adjudication center’s caseload. Developing, documenting and 

implementing an accuracy rate that includes this information will provide 

TSA with a more complete assessment of the performance of its 

workforce—regardless of whether the members of that workforce are 

contractors or TSA employees.

Second, because of functional limitations in its case reporting systems, 

Adjudication Center management uses an undocumented, manual, 

process to track adjudicator performance. Documenting the Adjudication 

Center’s case reporting performance measurement practices is important 

to ensure continuity of operations in the event of attrition by the two 

Adjudication Center officials familiar with this process. Third, the 

Adjudication Center relies on its staffing plan to guide its workload 

planning decisions but has not shared updated versions of this plan with 

the credentialing program offices that it serves. Establishing a mechanism 

for the Adjudication Center to share and reconcile information included in 

the staffing plan updates, such as timelines for anticipated workload 

growth, would help improve internal coordination and support the 

Adjudication Center’s workload planning efforts.

Fourth, TSA’s 2011 BWS assessment for the Adjudication Center found 

that the adjudicator function is closely associated with inherently 

governmental functions and recommended that TSA insource its 

Adjudication Center workforce to mitigate the risks that contractors were 

making security credential approvals without sufficient federal oversight. 

Taking additional steps to end its use of contract adjudicators and convert 

to an all-federal employee adjudicator workforce would help TSA mitigate 

such risks, but it has been delayed in doing so. Completing its internal 

review and updating and documenting the conversion plan to ensure the 
 

Page 35 GAO-13-629 Transportation Security

plan reflects current condition conditions, including timelines for hiring, 

planned hiring numbers, and cost information would help TSA and DHS 

decision makers by providing a roadmap for moving forward. Finally, 

providing this plan to TSA and DHS leadership for review are important 

steps to help ensure TSA addresses the risks identified in the 2011 BWS 

assessment and has an appropriate workforce to make the decisions that 

may ultimately deny or allow individuals credentials for unescorted access 

to the nation’s critical transportation infrastructure.

We recommend that the Secretary of Homeland Security direct the TSA 

Administrator to take the following 5 actions:

• To ensure that the Adjudication Center accuracy rate effectively 

captures the center’s accuracy in completing security threat 

assessments, the Adjudication Center should develop an accuracy 

rate measure that includes accuracy data for cases where 

adjudicators both approved and disqualified applicants, document this 

methodology, and implement the process.

• To ensure continuity of case reporting, the Adjudication Center should 

document its case reporting performance management processes.

• To ensure workforce planning is based on accurate workload 

projections, establish a mechanism for TSA’s OIA Program 

Management Division and OLE/FAMS Adjudication Center to share 

and reconcile information included in the Adjudication Center’s 

staffing plan updates, such as timelines for anticipated workload 

growth.

• To advance efforts to address risks identified in the Adjudication 

Center BWS assessment,

• update and document its Adjudication Center insourcing 

conversion plan to reflect revised schedule timeframes, cost and 

hiring level information, and

• review the updated Adjudication Center insourcing conversion 

plan, and provide it to TSA and DHS leadership for review and 

implementation approval.

Recommendations for 

Executive Action
 

Page 36 GAO-13-629 Transportation Security

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

in written comments received July 2, 2013, concurred with all five of the

recommendations in the report and identified actions taken, planned, or 

under way to implement the recommendations. Written comments are 

summarized below, and official DHS comments are reproduced in 

appendix II. In addition, DHS provided written technical comments, which 

we incorporated into the report, as appropriate. 

In commenting on the draft report, DHS described efforts underway or 

planned to address our recommendations. DHS also noted that the 

Adjudication Center’s caseload performance measure of keeping 

backlogs below 1,500 cases is a self-imposed standard that TSA 

established to provide the best possible customer service to applicants. 

We agree that the Adjudication Center’s caseload performance 

measurement was developed by TSA. Regardless of source, however, 

TSA’s caseload standard is a contractual requirement and our analysis of 

TSA data found that the Adjudication Center contractor generally did not 

meet this requirement between October 2010 and January 2013. In 

addressing our recommendations, DHS concurred with our first 

recommendation that TSA should develop an accuracy rate that includes 

accuracy data for both cases where an applicant is approved and cases 

where an applicant is disqualified, document this methodology, and 

implement the process. DHS stated that TSA OIA will modify its current 

quality control process to include both approved and disqualified cases 

that will more accurately reflect the adjudications performed. 

Furthermore, DHS reported that it will develop, document, and formalize 

an accuracy rate measure that includes review of approved and 

disqualified cases. Such actions will ensure that the Adjudication Center’s 

accuracy rate measure provides a more comprehensive assessment of 

adjudicator performance. 

DHS also concurred with our second recommendation that TSA should 

document the Adjudication Center’s case reporting performance 

management processes. DHS stated that while TSA anticipates that the 

current manual process will be phased out and replaced by an automated 

process as the TIM program is implemented, TSA OIA will document the 

current manual performance management process. DHS stated that 

documenting the process will confirm the Adjudication Center’s 

performance is accurately tracked and will also ensure continuity in the 

event of personnel turnover. These actions, if implemented effectively, 

should address the intent of our recommendation.

Agency Comments 

and Our Evaluation 
 

Page 37 GAO-13-629 Transportation Security

Regarding our third recommendation that OIA’s Program Management 

Division and the OLE/FAMS Adjudication Center should establish a 

mechanism to share and reconcile information included in the 

Adjudication Center’s staffing plan updates, such as timelines for 

anticipated workload growth, DHS concurred. DHS reported that the OIA 

Program Management Division and the OLE/FAMS Adjudication Center 

were already working to resolve the issues and had begun coordination to 

ensure security threat assessment workload estimates and the staffing 

plan are updated. DHS stated that TSA will formalize a quarterly review 

process between the Program Management Division and the Adjudication 

Center to meet and discuss these issues. 

DHS concurred with our fourth recommendation to update and document 

the Adjudication Center’s insourcing conversion plan to reflect revised 

schedule timeframes and cost and hiring level information. In its 

comments, DHS stated that OIA is working with the DHS Office of the 

Chief Human Capital Officer to address any potential issues posed by 

using a mix of government employees and contractors. Furthermore, 

DHS reported that TSA will update its insourcing conversion plan to 

reflect current timelines, costs, and hiring levels. Such actions should 

improve TSA’s ongoing insourcing efforts. Lastly, DHS concurred with our 

fifth recommendation that TSA review the updated Adjudication Center 

insourcing conversion plan and provide it to TSA and DHS leadership for 

review and implementation approval. DHS stated that OIA has already 

begun updating the insourcing conversion plan and intends to provide it 

for review and approval. We will continue to monitor DHS’s efforts. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan on no further distribution of this report until 30 days after 

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

Secretary of Homeland Security, the Assistant Secretary for the 

Transportation Security Administration, and appropriate congressional 

committees. In addition, this report is available at no charge on the GAO 

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

If you or your staff have any questions about this report, please contact 

me at (202) 512-7141 or groverj@gao.gov. Contact points for our Offices 
 

Page 38 GAO-13-629 Transportation Security

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

page of this report. Key contributors to this report are acknowledged in 

appendix III.

Sincerely yours,

Jennifer A. Grover

Acting Director, Homeland Security and Justice Issues
Appendix I: TSA Organizational Chart with Key 

Offices with Responsibility for Implementing 

Security Threat Assessments

Page 39 GAO-13-629 Transportation Security

Figure 3 shows that responsibility for carrying out programs related to 

issuing credentials for transportation workers is divided among multiple 

Transportation Security Administration (TSA) offices. In particular, the 

TSA Office of Intelligence and Analysis manages transportation security 

credentialing programs—including the three largest programs: the 

Transportation Worker Identification Credential (TWIC) program for 

maritime workers; the Hazardous Materials Endorsement (HME) program 

for truckers seeking a commercial driver’s license endorsement to carry 

hazardous materials; and the Aviation Worker program. Within the Office 

of Law Enforcement/Federal Air Marshal Service, the Adjudication Center 

is responsible for providing security threat assessment adjudication 

services to meet the workload needs of TSA programs.

Figure 3 TSA Organization Chart Showing Key Offices Responsible for Managing and Implementing Transportation Security 

Threat Assessment Programs, as of May 2013.

Appendix I: TSA Organizational Chart with 

Key Offices with Responsibility for 

Implementing Security Threat Assessments
Appendix II: Comments from the Department 

of Homeland Security

Page 40 GAO-13-629 Transportation Security

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 41 GAO-13-629 Transportation Security
Appendix II: Comments from the Department

of Homeland Security

Page 42 GAO-13-629 Transportation Security
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 43 GAO-13-629 Transportation Security

Jennifer A. Grover, (202) 512-7141 or groverj@gao.gov

In addition to the contact names above, David Bruno (Assistant Director), 

Jason Berman (Analyst-in-Charge), Carl Barden, Melissa Bogar, Jennifer 

Dougherty, Eric Hauswirth, Richard Hung, Thomas Lombardi, Stephen M. 

Lord, Steve Morris, Jessica Orr, Minette Richardson, Katherine Trimble, 

and Jonathan Tumin made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441108)
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