Federal Protective Service: Progress Made but Improved Schedule and Cost Estimate Needed to Complete Transition
Published: 2011-07-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Events such as the February 2010 attack on the Internal Revenue Service offices in Texas, and the shooting in the lobby of the Nevada federal courthouse, demonstrate the vulnerabilities of federal facilities and the safety of the federal employees who occupy them. The Federal Protective Service (FPS) is the primary agency responsible for the security of over 9,000 federal government facilities across the country. The fiscal year 2010 DHS appropriations act transferred FPS from Immigration and Customs Enforcement (ICE) to the National Protection and Programs Directorate (NPPD), within the Department of Homeland Security (DHS). This report addresses (1) the extent to which the FPS transition has been implemented and any remaining related challenges, and (2) the extent to which the transition will help address previously identified challenges to protecting federal facilities. GAO reviewed the 2009 FPS-NPPD transition plan; agreements between FPS, NPPD, and ICE, and best practices for scheduling and cost estimating; and interviewed DHS officials.
section_title: What GAO Found
paragraphs: Since October 2009, FPS's facility protection mission and 13 of 18 mission-support functions have transferred from ICE to NPPD; however, the transition schedule for the 5 remaining mission-support functions has been delayed. For example, while functions such as human capital and budget formulation have been transferred, information technology (IT) services, business continuity and emergency preparedness, facilities, personnel security, and equal employment opportunity have not. In August 2009, DHS reported to Congress that the transition of these functions would be completed by October 2010. DHS now reports that it plans to complete the transfer of 4 of the 5 remaining mission-support functions by September or October 2011, and estimates that the transfer of IT services will not be complete until October 2012. DHS developed a transition plan to guide the planning and execution of the transfer. Among other things, the plan called for schedules with detailed tasks and end dates to be developed for all mission-support functions to ensure critical path activities were identified, managed, and resourced. DHS also developed a detailed schedule to manage the transfer of IT services, as called for in the transition plan. However, GAO's analysis of the schedule found that it did not reflect GAO's best practices for scheduling such as capturing, sequencing, and assigning resources to all activities necessary to accomplish the work. When a schedule does not accurately reflect the project, it will not serve as an appropriate basis for analysis and may result in unreliable completion dates and delays. As of May 2011, DHS estimated that it would cost $6.2 million to complete the IT transition. GAO's analysis of this cost estimate found it did not meet all the characteristics of a reliable cost estimate. For example, the estimate was not well documented because it was not supported by detailed explanation describing how the estimate was derived and did not include sufficient detail so that GAO could corroborate it. By incorporating cost estimation best practices for the IT transition cost estimate, DHS could enhance the estimate's reliability and better inform decisions about the cost to complete the transition. The transfer of FPS to NPPD could provide DHS the opportunity to better advance progress towards addressing FPS's challenges to protecting federal facilities that have been previously identified by GAO. Since 2007, GAO has reported that FPS faces significant challenges with protecting federal facilities. The transition plan noted that the transfer of FPS to NPPD would improve the mission effectiveness of both agencies. NPPD officials explained that the agency has undertaken actions that serve as a foundation for integrating FPS into NPPD. For example, FPS has begun to develop a new strategic plan to align FPS's activities and resources to support NPPD mission-related outcomes. Additionally, NPPD is assisting FPS in developing a human capital strategic plan, as recommended by GAO in July 2009. These steps are encouraging, but it is too early to tell if these planned actions will help address challenges previously identified by GAO.
section_title: What GAO Recommends
paragraphs: GAO recommends that DHS improve the schedule for transferring IT services to reflect scheduling best practices, and update the IT transition cost estimate, in accordance with cost-estimating best practices. DHS concurred with GAO's recommendations.

section_title: Letter
paragraphs: Events such as the February 2010 attack on the Internal Revenue  Service offices in Texas, and the January 2010 shooting in the lobby of  the Nevada federal courthouse, demonstrate the vulnerability of federal  facilities and the threat to the safety of federal employees who occupy  them. These events also highlight the continued challenges involved in  protecting the over 1 million government employees who work in federal  facilities, and members of the public who visit such facilities each year.  The Federal Protective Service (FPS), established in 1971 as the  uniformed protection force of the General Services Administration (GSA),  is the primary agency responsible for the security of over 9,000 federal  government facilities across the country, including buildings; grounds; and  property owned, occupied, or secured by the federal government.
FPS was transferred from GSA’s Public Buildings Service to the  Department of Homeland Security (DHS), with enactment of the  Homeland Security Act of 2002. Within DHS, FPS was originally a part of  Immigration and Customs Enforcement (ICE). However, the fiscal year  2010 DHS appropriations act transferred FPS from ICE to the National  Protection and Programs Directorate (NPPD), within DHS, and the  transfer became effective when the act was signed into law on October  28, 2009. DHS proposed this transfer to better align FPS’s facility  protection mission with NPPD’s broader critical infrastructure protection  mission.
In light of FPS’s critical role of protecting federal facilities against the  threat of terrorism and other criminal activity, it is important that FPS’s  transfer to NPPD be successful. In addition to the inherent challenges any  organization would face in becoming part of another agency, our prior  work reviewing the operations of FPS and its ability to protect federal  facilities has shown that FPS brings a set of unique operational,  management, and funding challenges to NPPD that have a bearing on its  ability to accomplish its mission. The challenges include managing its  contract guard force, establishing a comprehensive human capital  strategy, evaluating its funding structure, and developing a risk  management framework that links threats and vulnerabilities to resource  requirements. Over the past 5 years, we have made numerous  recommendations to address these challenges. For example, we  recommended FPS improve its long-term human capital planning,  develop and implement performance measures in various aspects of its  operations, and improve its data collection and quality across its  operations. While FPS has generally agreed with all of our  recommendations, it has not completed many related corrective actions. If  not properly planned and effectively implemented, the transition could not  only hamper FPS’s ability to carry out its mission, but impede its progress  in addressing its long-standing challenges.
DHS prepared a transition plan for the realignment of FPS that describes  the department’s ongoing planning efforts, cost estimates, and a timeline  for the planning and execution process, but members of Congress raised  questions about whether the plan provided sufficient information about  how the department would address FPS’s challenges. You requested  that we review the department’s transition efforts. This report addresses  (1) the extent to which the FPS transition has been implemented and any  challenges FPS and NPPD face in implementing the transition; and (2)  the extent to which the transition will help address previously identified  challenges to protecting federal facilities.
To answer the first objective, we reviewed relevant documents, including  the August 2009 FPS-NPPD Transition Plan, transition plan updates, the  Memorandum of Agreement (MOA), the Memorandum of Understanding  (MOU), and all service level agreements (SLA) signed among FPS,  NPPD, and ICE. We interviewed members of the senior-level working  group, as well as members of all working groups that were established to  carry out the transition in 18 mission-support functions, to discuss the  extent to which the mission-support functions had transferred from ICE to  NPPD. In addition, we interviewed the FPS Deputy Director, Chief of  Staff, regional and deputy regional directors, and mission support chiefs  from 6 of the 11 FPS regions around the country on a range of issues  related to the transition of FPS to NPPD. We compared the FPS  information technology (IT) transition schedule, the IT transition cost  estimate, and related documents to the practices in our Cost Estimating  and Assessment Guide. We did a detailed analysis of the IT services  mission-support function because it required a significant commitment of  resources, oversight, and time by DHS to complete the transition. We  also obtained and analyzed financial documentation from the  components’ accounting systems to identify transition costs. To assess  the reliability of this documentation, we (1) performed electronic testing  for obvious errors in accuracy and completeness, (2) compared the data  with other sources of information, such as cost data from the ICE Office of  Financial Management and documentation from the Intra-Governmental  Payment and Collection (IPAC) system, and (3) interviewed agency  officials knowledgeable about financial management and budgeting at all  three agencies to understand the data and to identify any data  problems. When we found discrepancies (such as data entry errors) w brought them to the officials’ attention and worked with them to  correct  discrepancies before concluding our analysis. We determined that the  data were sufficiently reliable for the purposes of this report.
To answer the second objective, we reviewed our prior work on  challenges facing FPS in its efforts to protect federal facilities. We also  reviewed and analyzed documentation, such as the transition plan,  testimony from key senior leaders in FPS and NPPD provided for a  hearing on the FPS transition, FPS’s strategic plan, and NPPD’s strategic  activities report. Finally, we interviewed the Senior Counselor to the  Under Secretary of NPPD, and FPS Deputy Director for Operations and  Chief of Staff and discussed actions underway or planned to further  address FPS’s challenges.
We conducted this performance audit from October 2010 through July  2011 in accordance with generally accepted 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 the evidence  provides a reasonable basis for our findings and conclusions based on  our audit objectives. Appendix I contains more details on our scope and  methodology.
subsections: section_title: Background
paragraphs: FPS was established in 1971 as the uniformed protection force of GSA  government-occupied facilities. The mission of FPS is to render federal  properties safe and secure for federal employees, officials, and visitors in  a professional and cost-effective manner by deploying a highly trained  and multi-disciplined police force. FPS was originally located within GSA’s  Public Buildings Service (PBS). As part of PBS, FPS was responsible for  providing law enforcement and security services to GSA’s tenants and the  public at federal buildings nationwide.
The Homeland Security Act of 2002 established DHS to prevent and  mitigate the damage from terrorist attacks within the United States, which  includes terrorism directed at federal facilities. Under the act, FPS was  transferred from the GSA to DHS. DHS later placed it within ICE. The  President’s fiscal year 2010 budget requested the transfer of FPS from  ICE to NPPD. Language in the budget request stated that FPS  responsibilities, such as providing physical security and policing of federal  buildings, establishing building security policy, and ensuring compliance,  are outside the scope of ICE’s immigration and customs enforcement  mission and are better aligned with NPPD’s mission. The transfer of FPS  to NPPD became effective when the fiscal year 2010 DHS appropriations  act was signed into law on October 28, 2009. Figure 1 shows FPS’s move  within DHS from ICE to NPPD.
To accomplish its mission, in 2011 FPS has a total budget authority of  about $1 billion, currently employs 1,225 federal staff, and about 13,000  contract guard staff to secure over 9,000 GSA owned or leased facilities.  FPS conducts law enforcement activities as well as risk assessments to  reduce facility vulnerability to criminal and terrorist threats and helps to  ensure that facilities are secure and occupants are safe.
For the transition, FPS, NPPD, ICE, and DHS headquarters components  formed a Senior Working Group, co-chaired by the Senior Counselor to  the Under Secretary of NPPD, the ICE Deputy Assistant Secretary for  Management, and the FPS Director. DHS developed a transition plan,  the August 2009 FPS-NPPD Transition Plan, which describes DHS’s  overall transition planning process and milestones for completing the  transition, among other things. The plan shifted FPS’s mission and  responsibility for all of its mission-support functions, with the exception of  financial accounting services and firearms and tactical training, from ICE  to NPPD or other DHS components. While FPS has its own law  enforcement personnel to perform its mission responsibilities, it does not  perform all of its mission-support functions such as payroll, travel  services, and contracting. For this reason, FPS has traditionally relied on  GSA and ICE to carry out these functions. For example, while under  GSA, FPS’s contracting functions were handled by the contracting  component of GSA’s Public Buildings Service, and under ICE, by its  Office of Acquisition.
The transition plan noted that most transition tasks would be completed  by October 2010. In addition, the transition plan noted staff-level working  groups were formed that consisted of subject matter experts from each of  the agencies, FPS, NPPD, and ICE, to plan in detail the transfer of FPS’s  mission and each mission-support function. The working groups were  tasked with planning, tracking issues related to the FPS transition, and  reporting progress on the transition. Initially, 16 working groups were  formed to carry out the transition in 18 mission-support functions, as  reflected in figure 2.
According to the transition plan, until the transition is complete, ICE is to  continue to provide necessary management and operational services  through continued agreements in support of FPS or until individual MOAs,  MOUs, or SLAs are concluded with NPPD and other DHS headquarters  components. For example, for fiscal year 2010, FPS and NPPD signed 12  SLAs with ICE, covering services such as training and development,  security management, and IT services, 1 MOA for legal services, and 1  MOU for financial services. These agreements were meant to ensure that  there were no lapses in services while mission-support functions were  being transferred to either NPPD or DHS headquarters components.
section_title: DHS Transferred FPS’s Mission and Most Support Functions to NPPD, but Could Benefit from a Revised Schedule and Cost Estimate for Transferring IT Services
subsections: section_title: FPS’s Facility Protection Mission Has Transferred to NPPD without Disruption
paragraphs: In October 2009, FPS’s facility protection mission transferred and its  reporting channels were shifted from ICE to NPPD. The Under Secretary  of NPPD—through delegation from the Secretary of Homeland Security— assumed operational control of FPS and its mission from ICE with the  enactment of the fiscal year 2010 DHS appropriations act. Similarly, the  Under Secretary delegated the authority and responsibility to the Director  of FPS to continue FPS’s physical security and law enforcement services  mission, consistent with the law enforcement authority for the protection  of federal property. Upon its transition to NPPD, FPS became a  component within the directorate. Figure 3 shows the location of FPS  within NPPD’s organizational structure.
According to FPS headquarters and regional officials we interviewed, the  transition of FPS’s mission from ICE to NPPD occurred without  degradation to the mission, and there has been minimal, if any, disruption  to FPS’s field operations. Moreover, the regional officials said that the  transition has not had an impact on the way FPS performs its mission on  a daily basis. FPS officials stated that FPS continued to lead DHS’s  security and law enforcement services at more than 9,000 GSA facilities  nationwide, and its operational activities, such as conducting facility  security assessments, conducting criminal investigations, and responding  to critical incidents, continued uninterrupted during and after the  transition.
section_title: NPPD Has Experienced Delays in Assuming Some FPS Mission-Support Functions
paragraphs: Since taking operational control of FPS in October 2009, NPPD and other  DHS components have assumed responsibility for 13 of 18 FPS mission- support functions, but the transfer of the remaining 5 mission-support  functions from ICE to NPPD or other DHS components has been delayed.  In August 2009, DHS reported to Congress that the transition would be  completed by October 2010 and estimated it would cost $14.6 million.  However, DHS now reports that the transfer of 4 functions will not be  completed until the end of fiscal year 2011 or start of fiscal year 2012 and  one of these functions will not be transferred until October 2012. For the  delayed functions, ICE continues to provide mission support to FPS, and  new or revised SLAs were developed to articulate the continuing time  frames and services that ICE would provide to FPS. The 18 mission- support functions and their transfer status are presented in table 1.
According to DHS officials responsible for executing the FPS transition,  the transfer of the 5 mission-support functions will take longer than  originally reported to Congress due to a number of factors, including  unanticipated costs associated with building the infrastructure within  NPPD and other DHS components to support areas such as IT services.  As reflected in table 2, the delays in the transition schedule for the  delayed mission-support functions range from almost 1 to 2 years. DHS  officials explained that the transfer of four mission-support functions— business continuity and emergency preparedness, personnel security,  facilities, and Equal Employment Opportunity (EEO)—are on track to  transfer by the end of fiscal year 2011 or start of fiscal year 2012.  Specifically, DHS officials explained the following    All activities for the transfer of business continuity and emergency  preparedness have been completed but are waiting on NPPD to  complete the building of a continuity of operations site, which  according to NPPD officials, will be complete by October 2011.    NPPD has moved a Senior Executive Service (SES)-level director into  position, and is in the process of establishing an Office of Compliance  and Security, which will provide compliance investigations, program  review, personnel security, interior physical security, information  security, and special security program services throughout NPPD.  According to the Acting Director of the Office of Compliance and  Security, the goal is to establish this office by October 2011.    NPPD has hired three of the five positions that were created to  support FPS facilities management. These personnel, according to  the officials, are working with ICE to transfer projects and all of them  are expected to transfer by the end of fiscal year 2011.    The only activity required for the transfer of EEO services is to hire  staff needed to support FPS within NPPD, which should be completed  by the end of fiscal year 2011.
While DHS has successfully transferred FPS’s mission and the majority of  its mission-support functions, deficiencies in the transition schedule for  the transfer of IT services could limit DHS’s ability to ensure the timely  transition of this important function. DHS’s transition plan called for  working groups to develop comprehensive project management plans  (i.e., detailed schedules) with detailed tasks and end dates for the  individual mission-support functions to ensure critical path activities were  identified, managed, and resourced. DHS did not develop these  schedules for all the mission-support functions since, according to DHS  officials, in some cases the transfer of a function was relatively easy and  did not need a schedule, such as public affairs and legislative affairs.  However, the transfer of FPS’s nationwide IT infrastructure and field  support is more complex. Because of the complexity of transferring IT  services, DHS developed a detailed schedule to manage the transfer of  IT services, as called for in the transition plan.
As we have previously reported, the success of fielding any program  depends in part on having a reliable schedule that defines, among other  things, when work activities will occur, how long they will take, and how  they are related to one another. As such, the schedule not only provides  a road map for systematic execution of a program, but also provides a  means by which to gauge progress, identify and address potential  problems, and promote accountability. Among other things, best practices  and related federal guidance cited in our cost estimation guide call for a  program schedule to be program-wide in scope, meaning that it should  include the integrated breakdown of the work to be performed, and  expressly identify and define relationships and dependencies among work  elements and the constraints affecting the start and completion of work  elements. Table 3 presents a summary of best practices we have  identified for applying a schedule as part of program management.
Our analysis of the IT schedule found that it did not reflect our best  practices for scheduling, as seen in table 4.
We shared the results of our analysis with responsible DHS IT transition  officials, who stated that they have taken note of the deficiencies and are  taking steps to improve the schedule using the scheduling practices.  According to these officials, they plan to work closely with staff in another  NPPD component agency with the expertise necessary to improve the IT  transition schedule. Nevertheless, if the schedule does not fully and  accurately reflect the project, it will not serve as an appropriate basis for  analysis and may result in unreliable completion dates, time extension  requests, and delays. With regard to the transfer of the IT services  function, it would be difficult for DHS to accurately predict the completion  date for the IT transition without a more reliable schedule. Moreover,  completing projects within projected time frames helps ensure agencies  do not incur additional costs, which is especially important in a fiscally  constrained environment. Ultimately, incorporating scheduling best  practices into the IT transition schedule could help DHS better manage  the completion of the transition and help provide reasonable assurance  that the transfer is complete within its projected timeframe.
section_title: Incorporating Cost Estimating Best Practices in the IT Transition Cost Estimate Could Enhance the Reliability of, and Better Inform, Decisions about the Cost to Complete the Transition
paragraphs: According to best practices for cost estimates, in addition to a reliable  schedule, a reliable cost estimate is critical to the success of any  program. A reliable cost estimate provides the basis for informed  investment decision making, realistic budget formulation and program  resourcing, meaningful progress measurement, proactive course  correction when warranted, and accountability for results. Such an  estimate is important for any agency, but especially an agency like FPS  that is solely fee funded and has faced projected shortfalls in fee  collections to cover operational costs.
Federal financial accounting standards state that reliable information on  the costs of federal programs and activities is crucial for effective  management of government operations and recommend that full costs of  programs or activities be reported so that decision makers have  information necessary to make informed decisions on resources for  programs, activities, and outputs, and to help ensure that they get  expected and efficient results. Drawing from federal cost-estimating  organizations and industry, our cost estimation best practices list four  characteristics of a high-quality and reliable cost estimate that  management can use for making informed decisions—comprehensive,  well-documented, accurate, and credible. In July 2008, the DHS Under  Secretary for Management signed a memorandum stating DHS will  standardize its cost-estimating process by using the best practices we  identified.
To implement the FPS transition, DHS, in 2009, estimated it would cost  $14.6 million to complete the transition of FPS from ICE to NPPD. DHS’s  estimate provided for costs into three categories—personnel, financial  management, and IT services. In 2011, the department revised the  estimate for each of the three categories, which totaled $18.5 million. At  the time of our review, FPS had spent about $1.9 million of its operating  revenue for transition-related expenses. Table 5 reflects estimated and  actual costs for personnel, financial management services, and IT  services associated with the FPS transition.
DHS has successfully transferred the majority of mission-support  functions, which includes oversight of financial management services,  and, according to DHS officials, is on track to hire most of the remaining  new personnel by the beginning of fiscal year 2012 to provide services  previously provided by ICE. However, DHS has not yet transferred IT  services and does not expect to complete the transfer until October 2012.  Having a reliable and valid cost estimate is important for enabling  managers to make informed decisions and facilitate tracking progress  against estimates to effectively manage the transfer of IT services. While  DHS committed to using GAO’s best practices in preparing cost estimates  in July 2008, our analysis of the cost estimate for the transfer of IT  services found that it only partially met one of the four characteristics of a  reliable cost estimate and minimally met the other three, as table 6  illustrates.
DHS officials stated that there are no plans to revise the IT transition  estimate. According to DHS officials, rather than revising the estimate, the  department plans to report actual costs once the transition is complete.  However, incorporating cost estimating best practices into the IT  transition cost estimate could provide an improved basis for remaining IT  transition investment decisions and could facilitate tracking of actual costs  against estimates, both of which are fundamental to effectively managing  the transfer of IT services.
section_title: Transition May Provide Opportunity to Address Previously Identified FPS Challenges, but It Is Too Early to Tell Its Impact
paragraphs: Since 2007, we have reported that FPS faces significant challenges with  protecting federal facilities, and in response, FPS has started to take  steps to address some of them. For example, our July 2009 and April  2010 reports on FPS’s contract guard program identified a number of  challenges that the agency faces in managing its contract guard program,  including ensuring that the 15,000 guards that are responsible for helping  to protect federal facilities have the required training and certification to  be deployed at a federal facility. In response to our July 2009 report,  FPS took a number of immediate actions with respect to contract guard  management, including increasing the number of guard inspections it  conducts at federal facilities in some metropolitan areas and revising its  guard training. Further, in our April 2010 report, we recommended,  among other things, that the Secretary of Homeland Security direct the  Under Secretary of NPPD and the Director of FPS to develop a  mechanism to routinely monitor guards at federal facilities outside  metropolitan areas and provide building-specific and scenario-based  training and guidance to its contract guards. As of August 2010, FPS was  in the process of implementing this recommendation.
Additionally, in July 2009 we reported that FPS did not have a strategic  human capital plan to guide its current and future workforce planning  efforts. Among other things, we recommended that FPS develop and  implement a long-term strategic human capital plan that will enable the  agency to recruit, develop, and retain a qualified workforce. DHS  concurred with our recommendation and is taking action to address it. In  June 2008, we reported on FPS’s funding challenges, and the adverse  implications its actions taken to address them had on its staff, such as low  morale among staff, increased attrition, and the loss of institutional  knowledge. We recommended that FPS evaluate whether its use of a  fee-based system or alternative funding mechanism was the most  appropriate manner to fund the agency. FPS concurred with our  recommendation; however, as of May 2011, FPS had not begun such an  analysis. Finally, in our 2009 High-Risk Series, and again in 2011, we  designated federal real property as a high-risk area, in part, because FPS  has made limited progress and continues to face challenges in securing  real property.
If successfully managed, the transfer of FPS to NPPD could provide DHS  the opportunity to better advance progress towards addressing FPS’s  challenges. The Under Secretary of NPPD and the former FPS Director,  in written statements for the November 2009 congressional hearing on  the FPS transfer, noted that the transition to NPPD would better leverage  and align infrastructure protection resources and competencies to  maximize their value. Further, the transition plan noted that the transfer  would improve the mission effectiveness of both FPS and NPPD.  According to NPPD officials, the agency has undertaken actions that  serve as a foundation for integrating FPS into NPPD.
First, NPPD officials explained that efforts undertaken by the senior  working group and the staff working groups have served to move the  transition forward, and integrate the FPS organization into the larger  NPPD structure. These officials explained that FPS has been established  as a component within NPPD, thereby aligning FPS’s infrastructure  protection mission within NPPD’s critical infrastructure protection mission.  As noted in the transition plan, NPPD chairs the operations of the  Interagency Security Committee, a group that includes the physical  security leads for all major federal agencies and whose key responsibility  is the establishment of governmentwide security policies for federal  facilities. As further noted in the transition plan, these missions are  complementary and mutually supportive, and the alignment resulting from  the transfer improves and advances the mission effectiveness of both  FPS and NPPD.
Second, NPPD officials stated that FPS has begun to develop a new  strategic plan to align FPS’s activities and resources to support NPPD  mission-related outcomes. Our work has shown that in successful  organizations, strategic planning is used to determine and reach  agreement on the fundamental results the organization seeks to achieve,  the goals and measures it will set to assess programs, and the resources  and strategies needed to achieve its goals. Third, NPPD officials noted  that NPPD has monthly meetings with FPS to review open GAO  recommendations and is assisting FPS in closing out these  recommendations. For example, in consultation with NPPD, FPS is  developing a human capital strategic plan. A human capital strategic plan,  flowing out of a new strategic plan, could help facilitate efforts to address  previously identified challenges. Further, as we have previously reported,  strategic human capital planning that is integrated with broader  organizational strategic planning is critical to ensuring agencies have the  talent they need for future challenges.
Finally, according to the Senior Counselor to the Under Secretary of  NPPD, NPPD has established a Field Force Integration Working Group  among a set of five other integration working groups to pursue integration  activities across the new and larger NPPD, and across DHS as a whole.  In addition, the Senior Counselor noted that the purpose of the group is to  examine capabilities and resources from across the NPPD components to  gain efficiencies and economies of scale in support of all NPPD field  operations. The official further noted that the FPS’s workforce and  regional structure is by far the largest and most established of the NPPD  components. FPS’s field structure and capabilities will be used as  comparative models and resources as NPPD works toward continued  integration of its operating entities. While these are encouraging steps, it  is too early to tell if these planned actions will help address the challenges  we have previously identified.
section_title: Conclusions
paragraphs: With its critical role in protecting federal facilities against the threat of  terrorism and other criminal activity, it is important that FPS’s transfer to  NPPD and its related integration are successful. DHS has implemented a  number of scheduling and cost estimating best practices in the FPS  transition and has successfully transferred 13 of the 18 mission support  functions. Nevertheless, DHS could better manage the transfer of the IT  services mission-support function, and help inform DHS, NPPD, FPS, and  congressional investment decision making. Establishing a reliable  schedule and incorporating cost estimation best practices in the estimate  for the transfer of IT services could help provide DHS enhanced  assurance that this delayed function will be transferred in accordance with  its projected time frames.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that DHS and Congress have reliable, accurate  information on the timeframes and costs of transferring FPS from ICE to  NPPD, we recommend that the Secretary of Homeland Security direct the  Under Secretary for NPPD, in consultation with the Director of FPS and  the Director of ICE, to   improve the schedule for transferring IT services, in accordance with  the transition plan, and to reflect scheduling best practices, and    update the IT transition cost estimate, in accordance with cost- estimating best practices.
section_title: Agency Comments
paragraphs: We received written comments on a draft of this report from DHS. DHS  concurred with our recommendations and stated that it is currently taking  actions to implement them. With respect to improving the schedule for  transferring IT services, DHS indicated that NPPD held working sessions  with subject matter experts from DHS, ICE, and FPS Chief Information  Officer (CIO) teams to capture all transition activities in greater detail and  identify areas for implementation of best practices into schedule updates.  DHS also noted that NPPD consulted with NPPD/United States Visitor  and Immigrant Status Indicator Technology (US-VISIT) and adopted  recommendations for schedule improvements, leveraging US-VISIT’s  lessons learned toward better alignment with GAO best practices,  acquisition of scheduling expertise, and acquisition of specific software  tools, among other things. Regarding updating the IT transition cost  estimate, DHS noted that NPPD is researching and resolving cost- estimating deficiencies identified in the GAO report in collaboration with  the DHS CIO. The department also noted that NPPD plans to identify an  alternative network design solution that may reduce transition cost, and  will refine the cost estimate after discussing network design discussions  with subject matter experts and incorporating cost-estimating best  practices. Written comments from DHS are reprinted in appendix II.
As agreed with your office, unless you publicly announce the contents of  the report, we plan no further distribution for 30 days from the report date.  At that time, we will send copies of this report to the Secretary of  Homeland Security, the Under Secretary of the National Protection and  Programs Directorate, the Director of the Federal Protective Service, the  Director of the Immigration and Customs Enforcement, and appropriate  congressional committees. In addition, this report will be available at no  charge on the GAO web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  David C. Maurer at (202) 512-9627 or maurerd@gao.gov. Contact points  for our Offices of Congressional Relations and Public Affairs may be  found on the last page of this report. Key contributors to this report are  listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We examined the transition of the Federal Protective Service (FPS) from  Immigration and Customs Enforcement (ICE) to the National Protection  and Programs Directorate (NPPD). We address the following questions:  (1) to what extent has the FPS transition been implemented and what  related challenges, if any, did FPS and NPPD face in implementing the  transition and (2) to what extent will the transition help address previously  identified challenges to protecting federal facilities?
To determine the extent to which the FPS transition has been  implemented and what challenges, if any, FPS and NPPD faced in  implementing the transition, we reviewed documents related to the  transition, including the August 2009 FPS-NPPD Transition Plan, all  transition plan updates, DHS delegations of authority related to the  execution and administration of FPS, and Memorandum of Agreement,  Memorandum of Understanding, and all service level agreements signed  among FPS, NPPD, and ICE. We interviewed FPS officials directly  affected by the transition—including the FPS Deputy Director and Chief of  Staff headquartered in Washington, D.C., and in each of 6 of FPS’s 11  regional offices, the Regional Director, Deputy Director for Operations,  and Mission Support Chief. We chose these offices on the basis of  geographical dispersion. They included: the Northwest/Arctic Region  (Federal Way, Washington); the Greater Southwest Region (Grand  Prairie, Texas); the Heartland Region (Kansas City, Missouri); the Great  Lakes Region (Chicago, Illinois); the National Capital Region  (Washington, D.C.); and the New England Region (Boston,  Massachusetts). Among other things, we asked questions about their  experiences regarding the transition of FPS’s mission and mission- support functions from ICE to NPPD. While the results of these interviews  provided examples of FPS officials’ experiences and perspectives, they  cannot be generalized beyond those we interviewed because we did not  use statistical sampling techniques in selecting the regional offices,  headquarters officials, and regional staff.
Additionally, we met with members of the transition senior working group,  including the NPPD Senior Counselor to the Under Secretary and the  FPS Director, as well as interviewed members of all 16 staff-level working  groups to discuss the extent to which FPS’s 18 mission-support functions  had transferred from ICE to NPPD. The working groups included officials  from FPS, NPPD, ICE, and in some groups, DHS headquarters. We  compared the FPS information technology (IT) transition schedule, the IT  transition cost estimate, and related documents to the practices in our  Cost Estimating and Assessment Guide. We focused on the IT mission- support function because it required a significant commitment of  resources, oversight, and time by DHS to complete the transition. For the  IT transition schedule and the cost estimate, we scored each best  practice as either being Not met—DHS provided no evidence that  satisfies any of the criterion; Minimally met—DHS provided evidence that  satisfies a small portion of the criterion; Partially met—DHS provided  evidence that satisfies about half of the criterion; Substantially met—DHS  provided evidence that satisfies a large portion of the criterion; and Met— DHS provided complete evidence that satisfies the entire criterion. We  provided the results of our schedule and cost analyses to DHS officials  and met with them to confirm the results. Based on the interviews and  additional documentation provided by DHS officials, we updated the  results of our analyses, as needed.
We reviewed financial documentation provided by all three components  reflecting transition costs such as salaries, benefits, and expenses for  new personnel hired to support the FPS transition, financial management  services provided by ICE, and IT deployment. To assess the reliability of  this documentation, we (1) performed electronic testing for obvious errors  in accuracy and completeness; (2) compared the data with other sources  of information, such as payroll reports to payroll data, cost data from the  ICE Office of Financial Management and documentation from the Intra- Governmental Payment and Collection (IPAC) system; and (3)  interviewed agency officials knowledgeable about financial management  and budgeting at all three agencies to discuss transition-related expenses  incurred at the time of our review, and to identify any data problems.  When we found discrepancies (such as data entry errors) we brought  them to the officials’ attention and worked with them to correct  discrepancies before concluding our analysis. We found the cost data to  be sufficiently reliable for the purposes of this review.
To determine the extent to which the transition will help address  previously identified challenges to protect federal facilities, we reviewed  prior GAO reports and testimonies related to FPS’s facility protection  efforts, and spoke with NPPD officials about FPS’s ongoing challenges in  this regard. We also reviewed and analyzed documentation, such as the  transition plan, testimony from key senior leaders in NPPD and FPS  provided for a hearing on the FPS transition, FPS’s strategic plan, and  NPPD’s strategic activities report. Finally, we interviewed the Senior  Counselor to the Under Secretary of NPPD, and FPS Deputy Director for  Operations and Chief of Staff, and discussed actions underway or  planned to further integrate FPS into NPPD.
We conducted this performance audit from October 2010 through   July 2011 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.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Sandra Burrell, Assistant  Director, and Valerie Kasindi, Analyst-in-Charge, managed this  assignment. Don Kiggins made significant contributions to the work. Gary  Mountjoy provided expertise on IT issues and Jack Warner provided  expertise on financial management issues. Tracey King provided legal  support. Michele Fejfar assisted with design and methodology and Karen  Richey provided expertise on cost estimation and scheduling best  practices. Katherine Davis provided assistance in report preparation and  Robert Robinson developed the report’s graphics.