Federal Protective Service: Challenges with Oversight of Contract Guard Program Still Exist, and Additional Management Controls Are Needed
Published: 2013-09-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: FPS relies on a privately contracted guard force (about 13,500 guards) to provide security to federal facilities under the custody and control of the General Services Administration. In 2010 and 2012, GAO reported that FPS faced challenges overseeing its contract guard program, specifically in ensuring guards' qualifications.
GAO was asked to update the status of FPS's contract guard oversight. This report examines (1) how FPS's requirements for contract guards compare to those of selected federal agencies and challenges, if any, that FPS faces in ensuring its requirements are met; (2) the extent to which guard companies have documented compliance with FPS's guard requirements; and (3) the management controls FPS uses to ensure compliance with its guard requirements. GAO reviewed 31 FPS guard contracts, and analyzed guard files from 11 contracts, selected based on geographic diversity; interviewed officials from guard companies, FPS headquarters, and 4 of 11 FPS regions; and reviewed the contract guard requirements and processes at six federal agencies, selected for their comparability to FPS.
section_title: What GAO Found
paragraphs: Several of the Department of Homeland Security's (DHS) Federal Protective Service's (FPS) guard requirements are generally comparable to those of the six selected agencies GAO reviewed, but FPS faces challenges in some aspects of guards' training. FPS and the six selected agencies GAO reviewed require basic, firearms, and screener (x-ray and magnetometer equipment) training for their armed guards. However, GAO found that providing screener training remains a challenge for FPS. For example, officials from one of FPS's contract guard companies stated that 133 (about 38 percent) of its approximately 350 guards have never received this training. Similarly, according to officials at five guard companies, some of their contract guards have not received training on how to respond during incidents involving an active shooter. Additionally, while contract guard industry guidance states that all training should be done with a certified instructor, GAO found that FPS does not require guard instructors to be certified to provide basic and refresher training, which represents the majority of guards' training. According to six guard companies, the lack of a requirement has led to having to retrain some guards, potentially increasing costs to FPS.
Twenty-three percent of contract guard files GAO reviewed did not have required training and certification documentation. GAO reviewed 276 randomly selected (non-generalizable) guard files maintained by 11 of the 31 guard companies GAO interviewed and found that 212 files (77 percent) contained the required training and certification documentation, but 64 files (23 percent) were missing one or more required documents. For example, the 64 files were missing items such as documentation of initial weapons and screener training and firearms qualifications. Although FPS has taken steps to address its challenges in this area, GAO's previous recommendations concerning monitoring guard companies' performance are a guide to furthering FPS's efforts. According to FPS officials, it plans to address GAO's recommendations in the near future. FPS continues to lack effective management controls to ensure its guards have met its training and certification requirements. For instance, although FPS agreed with GAO's 2010 and 2012 recommendations that it develop a comprehensive and reliable system for managing information on guards' training, certifications, and qualifications, it still does not have such a system. According to FPS officials, it plans to address this recommendation in the near future.
FPS also lacks sufficient management controls to ensure consistency in its monthly guard file review process (its primary management control for ensuring that guards are trained and certified), raising questions about the utility of this process. In the absence of specific guidance regarding how files are to be selected, FPS's 11 regions varied in how they conducted the monthly file reviews. For example, FPS officials from three regions stated that they randomly select their files for review, while officials from one guard company in another region stated that FPS asks the guard company to select the files for review. Allowing contract guard company officials to select files for review by FPS could result in selection bias and affect the results of FPS's review. FPS also lacks guidance on reviewing and verifying the results of its guard-file reviews. Without such guidance, FPS may not be able to determine the accuracy of its monthly file review results or if its contract guard companies are complying with the guard training and certification requirements.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretary of DHS direct FPS to take immediate steps to determine which guards have not had screener or active-shooter scenario training and provide it to them; require that guard instructors be certified to teach basic and refresher training; and develop and implement guidance for selecting guard files and verifying the results. DHS concurred with GAOs recommendations.

section_title: Letter
paragraphs: The Department of Homeland Security’s (DHS) Federal Protective  Service (FPS) is the primary agency responsible for providing law  enforcement and related security services for the approximately 9,600  federal facilities under the control and custody of the General Services  Administration (GSA). These facilities house 1.1 million occupants and  average 1.4 million visitors per day. To help accomplish the mission of  protecting federal facilities, FPS obligated about $767 million in fiscal year  2012 for contract guard companies to provide about 13,500 guards at  over half of GSA’s facilities. In recent years, we have reported on the  challenges FPS faces overseeing its contract guard program. Specifically,  in August 2012, we reported that FPS had no centralized database to  ensure that guards have completed required training and have the  appropriate certifications and qualifications to be deployed at federal  facilities. In 2010, we reported that FPS’s contract guard program  required more oversight and that FPS should reassess its use of contract  guards. We recommended, among other things, that FPS develop and  implement a comprehensive guard management system capable of  providing reliable, comprehensive data on its contract guard program on a  real time basis, and that FPS provide guards with building-specific and  scenario-based training and guidance. Our 2010 and 2012 reports  contained 13 recommendations. DHS agreed with all of our  recommendations and is in the process of implementing two of them (see  app. I for a list of recommendations and status).
You asked us to update the status of FPS’s management of its contract  guard program. This report provides information and analysis on (1) how  FPS’s guard training, certification, and qualification requirements for  contract guards compare to those of other selected federal agencies and  challenges, if any, that FPS faces in ensuring those requirements are  met; (2) the extent to which FPS’s guard companies have documented  compliance with training and certification requirements; and (3) the  management controls FPS and its guard companies use to ensure  compliance with training, certification, and qualification requirements.
To determine FPS’s training, certification, and qualification requirements  for contract guards, we analyzed selected guard services contracts active  as of September 2012 and FPS’s Security Guard Information Manual. We  drew a non-generalizable sample of 31 contracts from FPS’s 117 guard  services contracts (one contract for every guard company with which FPS  has contracted for non-emergency guard services). Eleven of the 31  guard contracts were chosen based on geographic diversity and  geographic density of contracts within FPS regions to allow us to conduct  file reviews for multiple contracts during each of four site visits that we  conducted. For each of these 11 contracts, we reviewed the contracts as  well as a random sample of guard files associated with each contract.  The remaining 20 guard services contracts we selected were the most  recent contract for each of the remaining guard companies that FPS had  contracted with as of November 2012. We also interviewed officials from  each of the 31 contract guard companies and industry stakeholders,  including the National Association of Security Companies (NASCO), the  Commission on Accreditation for Law Enforcement Academies (CALEA),  the Federal Law Enforcement Training Accreditation Board (FLETA), and  the Department of Homeland Security’s (DHS) Interagency Security  Committee (ISC). To determine how FPS’s requirements compare to  those of other agencies that contract for guard services, we selected six  federal agencies that contract for guard services and reviewed their  requirements and processes for managing their contract guards.
Agencies were selected based on survey responses regarding use of  contract guards for a previous GAO report and discussions with guard  companies and industry stakeholders. Specifically, we reviewed policies  and interviewed officials from the Department of Energy (DOE), the  National Aeronautics and Space Administration (NASA), the Department  of Defense’s Pentagon Force Protection Agency (PFPA), the Department  of State (State), the John F. Kennedy Center for the Performing Arts  (Kennedy Center), and the U.S. Holocaust Memorial Museum (Holocaust  Museum). Our findings from our review of these agencies’ practices are  not generalizeable to other agencies that contract for guard services.  However, the six agencies we selected are comparable to FPS because  they also are responsible for protecting and providing guard services to a  large number and wide variety of federal facilities such as public buildings  and museums.
To determine the extent to which contract guard companies documented  compliance with FPS’s guard training and certification requirements, we  examined documentation related to our non-generalizeable sample of 11  contracts, as previously discussed. From these 11 contracts, we  randomly selected 276 guard files to review for compliance with FPS  requirements. For each guard file, we compared the file documents to a  list of requirements contained in FPS’s Administrative Audit and  Protective Security Officer File Review Forms, which FPS uses to  conduct its monthly guard file reviews.
To identify the management controls and processes FPS and the guard  companies use to ensure compliance with training, certification, and  qualification requirements, we reviewed FPS’s procedures for (1)  conducting monthly guard file reviews; (2) documenting compliance with  guard training, certification, and qualification requirements; and (3)  monitoring performance. We also visited 4 of FPS’s 11 regions to discuss  how regional officials ensure that guards are qualified to be deployed to  federal facilities. We selected the 4 regions to provide geographic density  of contracts in the region to facilitate reviews of guard files, diversity in the  size of guard companies, and geographic diversity. During regional visits,  we interviewed FPS regional managers, contract guard program  managers, contracting officers, contracting officer’s representatives, and  inspectors regarding oversight policies and practices and challenges to  ensuring compliance with requirements. In addition, we interviewed  officials from each of FPS’s 31 guard companies regarding their policies  and procedures for complying with FPS’s guard training and certification  requirements. While the results of our work are not generalizeable, about  40 percent of the GSA facilities with guards are located in the four regions  where we conducted our site visits and our review of guard files involved  11 of FPS’s 31 guard companies. To assess the extent to which FPS  monthly guard file review results identified files with missing  documentation of training, certifications, and qualifications, we compared  FPS’s monthly file review results from the month in which we conducted  our file review for each of the 11 contracts to identify guard files that were  included in both our review and FPS’s monthly review. We identified any  discrepancies between the reviews and used FPS’s file review forms to  examine the discrepancies.
We conducted this performance audit from August 2012 through  September 2013 in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient, appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: FPS is responsible for protecting federal employees and visitors in  approximately 9,600 federal facilities under the custody and control of  GSA. The level of security FPS provides at each of the facilities (including  whether guards are deployed) varies depending on the building’s facility  security level.
To fund its operations, FPS charges fees for its security services to  federal tenant agencies in GSA-controlled facilities. For fiscal year 2013,  FPS expects to receive $1.3 billion in fees. FPS has about 1,200 full-time  employees and about 13,500 contract security guards deployed at  approximately 5,650 (generally level III and IV facilities) of GSA’s 9,600  facilities. Figure 1 shows the location of FPS’s 11 regions and the  approximate number of guards serving under contracts in each of these  regions.
FPS’s contract guard program is the most visible component of the  agency’s operations, and the agency relies on its guards to be its “eyes  and ears” while performing their duties. Contract guards are responsible  for controlling access to facilities; conducting screening at access points  to prevent the introduction of prohibited items, such as weapons and  explosives; enforcing property rules and regulations; detecting and  reporting criminal acts; and responding to emergency situations involving  facility safety and security. In general, guards may only detain, not arrest,  individuals, and guards’ authorities typically do not extend beyond the  facility. However some guards may have arrest authority under conditions  set forth by the individual states.
According to FPS’s contract for guard service, its private-sector contract  guard companies have primary responsibility for training and ensuring  that guards have met certification and qualification requirements;  however, FPS is ultimately responsible for oversight of the guards. FPS  relies on its Contracting Officer Representatives (COR) and inspectors  located in its 11 regions to inspect guard posts and verify that training,  certifications, and time cards are accurate, among other responsibilities.  CORs are individuals appointed by the contracting officer to assist in the  monitoring or administration of a contract including monitoring contractor  performance, receiving reports and other documentation, performing  inspections, and maintaining contact with both the contract guard  company and the contracting officer.for providing and maintaining all guard services as described in the  contract statement of work, including management, supervision, training,  equipment, supplies, and licensing.
section_title: Several of FPS’s Guard Requirements Are Generally Comparable to Selected Agencies, but FPS Faces Challenges in Other Aspects of Guards’ Training
subsections: section_title: FPS Has Several Guard Training Requirements That Are Generally Comparable to Other Selected Agencies
paragraphs: Before guards are assigned to a post or an area of responsibility at a  federal facility, FPS requires that they all have contractor employee  fitness determinations (the employee’s fitness to work on behalf of the  government based on character and conduct) and complete  approximately 120 hours of training provided by the contractor and FPS,  including basic training, firearms training, and screener (X-ray and  magnetometer) training. Guards must also pass an FPS-administered  written examination and possess the necessary certificates, licenses, and  permits as required by the contract. Additionally, FPS requires its guards  to complete 40 hours of refresher training every 3 years. Some states and  localities require that guards obtain additional training and certifications.  See table 1 for a detailed list of FPS’s guard training, certification, and  qualification requirements.
We found similarities in the ways that FPS and six federal agencies we  reviewed ensure that contract guards have received required training,  certifications, and qualifications. Similar to FPS, each of the six agencies  we examined—DOE, NASA, PFPA, State, the Kennedy Center, and the  Holocaust Museum—depend largely on the contract guard companies to  ensure guards are trained, certified, and qualified. They also depend on  the guard companies to document compliance with contract  requirements. All six agencies and FPS require basic, firearms, and  screener (x-ray and magnetometer) training for their armed guards. In  addition, FPS and five of the six agencies we reviewed require refresher  training.
section_title: FPS Continues to Face Challenges in Some Aspects of Guards’ Training
subsections: section_title: FPS Is Not Providing Required Screener Training to All Guards
paragraphs: FPS continues to experience difficulty providing required screener (x-ray  and magnetometer equipment) training to all guards. In 2009 and 2010,  we reported that FPS had not provided screener training to 1,500 contract  guards in one FPS region. In response to our reports, FPS stated that it  planned to implement a program to train its inspectors to provide screener  training to all of its contract guards. Under this program, FPS planned to  first provide x-ray and magnetometer training to its inspectors who would  subsequently be responsible for training the guards. However, FPS  continues to have guards deployed to federal facilities without this  training.
As noted in table 1, FPS requires all guards to receive 8 hours of initial  screener training provided by FPS. Screener training is important  because guards control access points at federal facilities and thus must  be able to properly operate x-ray and magnetometer machines and  understand their results. However, 3 years after our 2010 report, guards  are deployed to federal facilities who have never received this training.  For example, an official at one contract guard company stated that 133 of  its approximately 350 guards (about 38 percent) on three separate FPS  contracts (awarded in 2009) have never received their initial x-ray and  magnetometer training from FPS. The official stated that some of these  guards are working at screening posts without having received the  training. Further, officials at another guard company in a different FPS  region stated that, according to their records, 78 of 295 guards (about 26  percent) deployed under their contract have never received FPS’s x-ray  and magnetometer training. These officials stated that FPS’s regional  officials were informed of the problem, but allowed guards to continue to  work under this contract, despite not having completed required training.  Because FPS is responsible for this training, according to guard company  officials, no action was taken against the company. In May 2013, FPS  headquarters officials stated that they were unaware of any regions in  which guards had not received screener training.
In July 2013, according to FPS officials, the agency began designing a  “train-the-trainer” pilot program with four guard companies. Through this  pilot program, contract guard company instructors, in addition to FPS  inspectors, will be certified to provide screener training to guards. FPS  officials stated that they plan to implement the pilot program in the first  quarter of 2014. According to FPS officials, once implemented, FPS’s  train-the-trainer program should increase the number of certified  instructors capable of providing screener training nationwide. If this  program is fully implemented, FPS screener training could be provided  largely by the guard companies. This is the method by which four of the  six agencies we spoke with provide their guards with screener training. In  addition, officials from 13 of the 31 guard companies that we interviewed  stated that responsibility for x-ray and magnetometer training should be  shifted to the guard companies to alleviate scheduling problems, while  officials from 7 companies stated that FPS should retain this  responsibility. The remaining 11 guard companies did not state an opinion  on this issue. FPS’s train-the-trainer program could provide resources to  address the challenges it faces in providing screener training to guards.  However, the program is in its beginning stages and there are still guards  deployed to federal facilities who have not received required screener  training. Screener training is essential to helping prevent unauthorized  individuals and items from entering federal facilities. Thus, it is critical that  FPS immediately provide this training to those guards who have not  received it.
According to FPS officials, the agency requires its guards to receive  training on how to respond to an active-shooter scenario, but we found  that some guards have not received it. According to DHS, an active  shooter is an individual killing or attempting to kill people in a confined  and populated area. Since June 2009 there have been several incidents  involving active-shooters at government facilities. For instance, in 2010  an active-shooter opened fire in the Lloyd D. George Federal Courthouse  in Las Vegas, Nevada, killing a security officer and wounding a deputy  U.S. Marshal.
According to FPS officials, since 2010, it has provided training on how  guards should respond during an active-shooter incident to guards as part  of the 8-hour FPS-provided orientation training guards receive. FPS  officials were not able to specify how much time is devoted to this  training, but said that it is a small portion of the 2-hour special situations   In addition, officials stated that guards hired before 2010 should  training.have received this information during guard-company-provided training on  the guards’ post orders (which outline the duties and responsibilities  associated with each guard post and include information on responding to  an active-shooter situation) during basic and refresher training.
However, when we asked contract guard company officials if their guards  had received training on how guards should respond during active- shooter incidents, responses varied. For example, of the 16 contract  guard companies we interviewed about this topic: eight contract guard company officials stated that their guards have  received active-shooter scenario training during orientation,  five guard company officials stated that FPS has not provided active- shooter scenario training to their guards, and  three guard companies stated that FPS had not provided active- shooter scenario training to their guards during the FPS-provided  orientation training, but that the topic was covered in one of the  following ways: during guard company-provided basic training or refresher training,
FPS provided on-the-job instruction on the topic during post
FPS provided a link to an active-shooter training video, which the  company shows its guards.
The six agencies we reviewed—State, the Holocaust Museum, NASA,  PFPA, the Kennedy Center, and DOE—also recognize this threat and five  of them require active-shooter response training for their contract guards.  According to officials at DOE, the agency is in the process of requiring  guards to complete active-shooter response training to ensure they are  capable of addressing this threat and protecting facility occupants.  Similarly, Holocaust Museum officials stated that they require this training  because current trends in law enforcement warrant active-shooter  response training for guards.
In May 2013, an FPS official stated that the agency is collaborating with  its guard companies to develop a standardized national lesson plan for  guards and revising the Security Guard Information Manual (SGIM). FPS  officials stated that the lesson plan being developed is meant to  standardize the training guards receive. However, according to the  official, FPS has not yet decided whether the national lesson plan will  specify countermeasures necessary to mitigate threats from active  shooters. FPS does not have a timeline for developing or implementing a  national lesson plan for guards. Until it develops one, some guards may  continue to go without training on how guards should respond to incidents  at federal facilities involving an active shooter.
FPS requires some contract guard company instructor certifications, but  does not require guard company instructors to be certified to teach basic  or refresher training or have any training in basic instructional techniques.  According to ISC guidance, training is a critical component of developing  a well-qualified guard force and all training should be done with a certified  instructor or training organization. Similarly, Federal Law Enforcement  Training Accreditation Board (FLETA)training programs have an instructor development course and review  process to ensure that instructors provide consistent, quality instruction.  FPS requires that guard instructors be certified to provide training in CPR,  first aid, AED, and firearms and have a minimum of 2 years of law  enforcement, military, or security training experience. However, FPS has  no certification requirements for instructors teaching the guards’ basic  and refresher training, nor does FPS require instructors to be  knowledgeable in instructional techniques. Basic training, which  represents 64 hours of the initial 120 hours of training that guards receive,  and the 40-hour refresher class cover topics included in the SGIM, such  as access control and crime detection and response.
In contrast to FPS, three of the six selected agencies that we reviewed  (NASA, DOE, and the Holocaust Museum) require guard instructors to  attend instructor training or to be certified by the agency. For example,  NASA requires contract guard company instructors to be certified by a  NASA training academy. NASA stated that instructor certification  requirements have reduced legal liabilities, ensured standardization of  training, and led to greater efficiency of its training programs throughout  the agency. Under NASA’s instructor certification program, instructors  must meet the following requirements, among others:  completed training from the Federal Law Enforcement Training Center  (FLETC);
2-week internship as a student instructor to observe and work with an  established instructor, including an evaluation; physical fitness requirements;  re-evaluation every 2 years to ensure instructors are effective and  follow required lesson plans; and annual workshop for instructors on curriculum development.
Similarly, DOE requires that in addition to specific certifications for the  level of training they provide, instructors must complete a basic instructor  training course and be evaluated for competency at least once every 36  months.
According to some of FPS’s guard companies, the absence of an  instructor certification requirement has affected the quality of training  provided to some guards. For example, 6 of FPS’s 31 contract guard  companies stated that they have experienced problems related to training  quality when taking over a contract from a previous guard company and  employing guards who had worked for the previous company. The  companies stated that they either retrained or did not hire guards who  they believed had been inadequately trained by the previous company. In  these situations, costs may be passed on to FPS via increased rates for  guard services to account for the increased training costs to guard  companies. Four of the 31 guard companies stated that they already have  additional requirements or training for instructors. However, such  additional requirements and training are on a company-by-company basis  and do not necessarily conform to any standards. Sixteen of the guard  companies and officials from FLETA and CALEA stated that FPS should  standardize instructor training and certification requirements or require  FPS certification for guard instructors. Such standardization would help  ensure quality and consistency in the training received by guards  providing protective services across GSA’s federal buildings. FPS officials  stated that FPS reviews each instructor’s resume to ensure that  instructors have the minimum qualifications necessary to provide guard  instruction.
section_title: Twenty-three Percent of Contract Guard Files We Reviewed Did Not Have Required Training and Certification Documentation
paragraphs: Some contract guard files we reviewed did not contain all required  documentation. We reviewed 276 randomly selected (non-generalizeable)  guard files maintained by 11 of the 31 guard companies we interviewed  and found that 212 files (77 percent) contained the required training and  certification documentation, but 64 files (23 percent) were missing one or  more required documents. See table 2 for information on the results of  our review. These 64 files were maintained by 9 of the 11 companies.  According to FPS’s policies and contracts for guard service, each contract  guard company must maintain a file for each guard to document that all  FPS training, certification, and qualification requirements have been met  and are current. We examined the files against the required training,  certification, and qualification documentation listed by FPS on the forms it  uses to conduct its monthly file reviews.
As shown in table 2, the 64 guard files were missing 117 total documents.  For example:
Three files were missing documentation of basic training, and 15 were  missing documentation of refresher training, both of which cover the  guards’ roles and responsibilities and duties such as access control.
Five files were missing documentation of screener training, which as  mentioned above, is meant to prepare guards to prevent prohibited  items from being brought into federal facilities.
Seventeen files were missing documentation of initial weapons  training, which indicates guards have passed the 40-hour weapons  training, including 32 hours of firearms training.
One file was missing the form that certifies that a guard has not been  convicted of a crime of domestic violence.
In addition to the 117 missing documents, there was no indication that  FPS had monitored firearms qualifications in 68 of the 276 guard files  reviewed. The other 208 files had a current firearms qualification form  with an indication (such as initials or a signature) that FPS witnessed the  qualification. The FPS Protective Security Officer (PSO) File Review  Form lists documentation requirements as “Firearms Qualifications  Witnessed by an FPS Employee,” but is not clear regarding whether  documentation of the FPS witness is required in the file. Although FPS  has taken some steps to address its challenges in this area, our previous  recommendations are a guide to furthering its efforts. For example, we  recommended that FPS rigorously and consistently monitor contract  guard companies’ performance and step up enforcement against guard  companies that are not complying with the terms of the contract. Although  FPS agreed with this recommendation, it has yet to implement it.  According to FPS officials, it plans to address this recommendation in the  near future.
section_title: FPS Still Lacks Effective Management Controls to Ensure Guards Have Met Training and Certification Requirements
subsections: section_title: FPS Continues to Lack a Comprehensive System to Effectively Manage Guard Training, Certification, and Qualification Data
paragraphs: DHS agreed with our 2010 and 2012 recommendations to develop a  comprehensive and reliable system for contract guard oversight, but it still  does not have such a system. Without a comprehensive guard  management system, FPS has no independent means of ensuring that its  contract guard companies have met contract requirements, such as  providing qualified guards to federal facilities. According to FPS officials, it  plans to address this recommendation in the near future. GAO’s  Standards for Internal Control in the Federal Government also states that  program managers need access to data on agency operations to  determine whether they are meeting goals for the effective and efficient  use of resources. The standards state that such information should be  captured and distributed in a form that permits officials to perform their  duties efficiently.
In the absence of a comprehensive guard-data-management system,  FPS requires its guard companies to maintain files containing guard  training and certification information and to submit a monthly report with  this information to their CORs. FPS headquarters officials stated that the  monthly reports are primarily to ensure that regional managers have  access to training and certification information, although there are no  requirements for regional officials to use or analyze the monthly reports.  The officials stated that regions are occasionally asked to supply these  reports to FPS headquarters as a check to ensure regions and guard  companies are sharing this information, but that headquarters officials do  not analyze the data.
Although FPS does not have a system to track guard data, 13 of FPS’s  31 guard companies maintain training, certification, and qualification data  in either proprietary or commercially available software programs with  various management capabilities. For example, one system used by  multiple companies tracks the training and certification status of each  guard and prevents the company from scheduling the guard to work if the  guard is not in compliance with requirements. Virginia’s Department of  Criminal Justice Services (DCJS) has a database system that also allows  training academies, guards, and guard companies to upload training and  certification documentation so that DCJS can track the training and  certification status of guards. According to industry stakeholders and  contract guard company officials, a comprehensive guard management  system could: provide FPS direct access for updating guard training, certification,  and qualification data while performing post inspections and other  oversight activities such as file reviews; enable FPS and guard company officials to more easily develop  reports and identify trends in data to recognize areas that need  attention;  store training, certification, and qualification documentation, that could  reduce the need to obtain documentation from a prior guard company  when a new company takes over a contract; and help identify guards working under more than one FPS contract and  verify that they do not work more than the maximum of 12 hours in  one day.
section_title: FPS Management Controls Do Not Ensure Consistency in Monthly File Review Process
paragraphs: FPS’s monthly reviews of contract guard companies’ guard files are its  primary management control for ensuring that the companies are  complying with contractual requirements for guards’ training, certification,  and qualifications. FPS’s directive for monthly file reviews requires, for  example, that:
Ten percent of the guard files for each contract are to be selected  randomly for the monthly review.
Selected files should be compared to the data in the reports provided  to FPS by the contract guard company that month.
FPS reviewers must note any deficiencies in which the file  documentation and dates do not match the data included in the  monthly report and promptly notify the guard company, COR, and  FPS regional program manager of the deficiencies.
If there are deficiencies in 40 percent or more of the reviewed files,  the region must immediately initiate an audit of 100 percent of the  company’s guard files.
Results should be recorded in FPS’s Administrative Audit Form and  individual Protective Security Officer File Review Forms.
An effort should be made to exclude files that have been reviewed  within the last 6 months from the selection process.
FPS’s directive on its monthly file reviews does not include specific  information about the importance of randomly selecting guard files and  ensuring contract guard company personnel do not know which files will  be reviewed. In the absence of specific guidance regarding how files are  to be selected, the four regions we visited varied in how they conducted  the monthly file reviews. For example, three of the four regions we visited  told us that they review randomly selected files either at the guard  company’s office or the guard company gives them electronic access to  the files for review. In contrast, officials in the fourth FPS region stated  that they submit a list of the selected guard files to the guard company 24  to 48 hours before the file review and request that the files be delivered  either electronically or in hard copy to the regional office. As such,  contract guard company officials in that region stated that they can review  the selected files to ensure that they comply with requirements prior to  delivering them to FPS. FPS headquarters officials stated that this  indicates that guard company officials are performing due diligence to  ensure the file is up to date. However, this practice decreases the utility of  randomly selecting files for review and reduces the ability of FPS  reviewers to accurately assess the guard company’s ongoing ability to  keep all of its guard files up to date. Additionally, officials at a contract  guard company in another FPS region stated that the COR occasionally  asks the guard company to select the files for review and bring them to  the regional office. FPS stated that this is not standard practice. Allowing  contract guard company officials to select files for review by FPS could  result in selection bias and affect the results of FPS’s review.
FPS headquarters officials stated that monthly file review results are  reported to headquarters and that the data are combined into a  spreadsheet, summarizing the number of deficiencies by contract, region,  and nationally. Officials stated that these data are used to identify  possible trends in vendor documentation and to determine if corrective  actions need to be taken at the regional level. However, if file review  results are affected by selection bias or by guard company actions to alter  the contents of the files selected for review, these data may not lead to an  accurate understanding of trends or the need for corrective action.
section_title: FPS Lacks Guidance on Reviewing and Verifying File Review Results
paragraphs: The Government Performance and Results Act Modernization Act of 2010  requires agencies to develop an approach to validation and verification in  order to assess the reliability of performance data. However, FPS’s  directive regarding monthly file reviews, discussed above, does not  include requirements for reviewing and verifying the results of the file  reviews. From March 2012 through March 2013, FPS reviewed more than  23,000 guard files as part of its monthly review process. FPS found that a  majority of the guard files had the required documentation but more than  800 (about 3 percent) did not. FPS’s file reviews for that period showed  files missing, for example, documentation of screener training, initial  weapons training, CPR certification, and firearms qualifications. However,  without an approach to reviewing and verifying results, FPS is not able to  use these results to accurately assess the performance of its contract  guard companies in complying with training and certification  requirements.
As part of its monthly file reviews for November 2012 through March  2013, FPS reviewed some of the same guard files we examined, but our  results differed substantially from what FPS found. Specifically, we  compared the results of FPS’s file reviews for the 11 contracts for which  we conducted file reviews; we found that 29 of the 276 files we reviewed  had also been reviewed by FPS. FPS’s review and our examination of  each file occurred in the same month. For each of the 29 files, FPS did  not identify any missing documentation. In contrast, we found that 6 of the  29 files did not have the required training and certification documentation  (and some were missing more than one required document). In 4 of the 6  guard files, FPS’s review indicated that required documentation was  present, but we were not able to find documentation of training and  certification, such as initial weapons training, DHS orientation, and pre- employment drug screenings. We also identified files with expired  documentation. For example, 2 of the 6 files had expired refresher- training documentation and another guard file had expired firearms  qualification documentation. Since we used FPS’s file review checklist to  conduct our file review, it is unclear why the results differed. FPS officials  were unsure about the reasons for this, but stated that human error and  contract requirements that differ from the requirements listed on  administrative audit forms may have been factors.
Additionally, differing results may be due to differences in the type of  documentation accepted by GAO and FPS. For example, in our review of  FPS monthly file review records for one contract, we identified 2 files for  which, according to the PSO file review form, the FPS reviewer accepted  documentation of CPR and AED training that we did not accept as valid.  While FPS guard contracts require guard files to contain a copy of the  CPR and AED certification card, the FPS reviewer accepted a roster of  individuals who attended the training. However, the roster did not indicate  whether attendees had passed the course or been officially certified and  was not signed by an instructor.
FPS can take action against guard companies if it determines that a  contract guard company has not complied with contractual requirements,  but it may not have accurate information to do so. FPS’s contracts for  guard services state that if guard companies do not comply with contract  requirements (e.g., guard training, certification, and qualification  requirements), FPS may require the contractor to take actions to ensure  compliance in the future and also may reduce the contract price to reflect  the reduced value of the service provided. Determining the extent to  which FPS took actions against guard companies for not complying with  guard training and certification requirements was not within the scope of  our engagement. However, the results of our comparison of FPS’s guard  file reviews to our reviews raises questions about whether FPS has  effective management controls in place to identify areas in which guard  companies have not complied with requirements.
section_title: Conclusions
paragraphs: FPS continues to lack the management controls to ensure that its  approximately 13,500 contract guards have the required training,  certification, and qualifications, which are central to effectively protecting  employees and visitors in federal facilities. FPS agreed with the  recommendations in our 2010 and 2012 reports. We recommended,  among other things, that FPS develop and implement a comprehensive  system for guard oversight. Without such a system, among other things,  FPS has no independent means of ensuring that its 13,500 guards  deployed to federal facilities are properly trained and qualified. As such,  we strongly encourage FPS to continue addressing the challenges we  identified in our prior work and to be more proactive in managing its  contract guard workforce. Although FPS has taken steps to address some  of our prior recommendations, we found that FPS still has challenges  providing screener training to some guards. Consequently, some guards  deployed to federal facilities may be using x-ray and magnetometer  equipment that they are not qualified to use. This raises questions about  the capability of some guards to screen access control points at federal  facilities─one of their primary responsibilities.
According to FPS officials, the agency has recently decided to make  changes to its guard program, including developing a national lesson  plan. We agree with this decision, given the problems that we have  identified. A national lesson plan could help FPS standardize and ensure  consistency in its training efforts. For example, without ensuring that all  guards receive training on how to respond to incidents at federal facilities  involving an active shooter, FPS has limited assurance that its guards are  prepared for this threat. Similarly, the lack of certification requirements for  instructors who teach basic and refresher training may ultimately affect  guards’ ability to perform their duties.
Finally, inconsistencies in how FPS regional officials conduct monthly file  reviews (which are FPS’s primary management control for ensuring  compliance with the guard contract requirements) indicate that the current  guidance for monthly file reviews is insufficient to ensure that, for  instance, guard companies do not have the opportunity to select files for  review and thus affect the results of the file reviews. Further, our work  raises questions about the reliability and quality of FPS’s monthly file  reviews. These findings are of particular concern given that FPS  continues to pay guard companies over half a billion dollars annually to  provide qualified guards yet it appears that some guards have been  deployed to federal facilities without meeting all of the training,  certification, and qualification requirements.
section_title: Recommendations for Executive Action
paragraphs: To improve the management and oversight of FPS’s contract guard  program, we recommend that the Secretary of Homeland Security direct  the Under Secretary of NPPD and the Director of FPS to take the  following three actions:  take immediate steps to determine which guards have not had  screener or active-shooter scenario training and provide it to them  and, as part of developing a national lesson plan, decide how and  how often these trainings will be provided in the future require that contract guard companies’ instructors be certified to teach  basic and refresher training courses to guards and evaluate whether a  standardized instructor certification process should be implemented;  and develop and implement procedures for monthly guard-file reviews to  ensure consistency in selecting files and verifying the results.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DHS for review and comment. DHS  concurred with our recommendations and provided written comments that  are reprinted in appendix II. DHS also provided technical comments,  which we incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to appropriate  congressional committees, the Secretary of Homeland Security, and other  interested parties. In addition, the report will be available at no charge on  GAO’s web site at http//www.gao.gov.
If you have any questions about this report, please contact me at (202)  512-2834 or goldsteinm@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix III.
section_title: Appendix I: Status of GAO’s 2010 and 2012 Recommendations to the Department of Homeland Security’s Federal Protective Service
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 name above, Tammy Conquest, Assistant  Director; Antoine Clark; Colin Fallon; Kathleen Gilhooly; Katherine Hamer;  Amanda Miller; Ramon Rodriguez; William Woods; and Gwyneth  Woolwine made key contributions to this report.