Homeland Security: DHS's Chemical, Biological, Radiological, Nuclear and Explosives Program Consolidation Proposal Could Better Consider Benefits and Limitations
Published: 2016-08-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Committee reports accompanying the Consolidated and Further Continuing Appropriations Act, 2013, directed DHS to undertake an in-depth review of the department's weapons of mass destruction programs, including potential consolidation of CBRNE mission functions. DHS conducted its review, and in June 2015 provided a report to Congress, including a proposal to consolidate the agency's core CBRNE functions. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it.
GAO was asked to review the proposed consolidation of DHS's CBRNE programs. This report discusses: (1) the extent to which DHS's proposal assessed the benefits and limitations of consolidation and (2) GAO's key practices from past organizational transformations that could benefit DHS, should Congress approve the proposed consolidation.
section_title: What GAO Found
paragraphs: The Department of Homeland Security's (DHS) documentation related to its proposed consolidation of Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) programs offers some insights into benefits and limitations considered, but the information provided to GAO did not include several key factors to consider when evaluating an organizational consolidation. While developing its consolidation plan, DHS identified strategic goals, such as eight near-term goals to be achieved within the first two years. DHS also considered problems its consolidation is intended to solve, including providing a clearer focal point for external and DHS component engagement on CBRNE issues. However, DHS:
Did not fully assess and document potential problems that could result from consolidation.
Did not include a comparison of benefits and costs.
Conducted limited external stakeholder outreach in developing the consolidation proposal and thus the proposal may not sufficiently account for stakeholder concerns.
Attention to the these key areas, identified from GAO's analysis of previous organizational consolidations, would help provide DHS, Congress, and other stakeholders with assurance that important aspects of effective organizational change are addressed as part of the agency's CBRNE reorganization decision-making process.
Key mergers and organizational transformation practices identified in previous GAO work could benefit DHS if Congress approves the proposed CBRNE consolidation. GAO reported in July 2003 on key practices and implementation steps for mergers and organizational transformations that range from ensuring top leadership drives the transformation to involving employees in the implementation process to obtain their ideas and gain their ownership for the transformation. In addition, the practices would be helpful in a consolidated CBRNE environment. For example, overall employee morale differs among the components to be consolidated, making the key practice of employee involvement to gain their ownership for the transformation a crucial step. Also, given the wide range of activities conducted by the consolidated entities, the key practice of establishing a coherent mission and integrated strategic goals to guide the transformation will be important. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it, and, as of June 2016, Congress had not approved DHS's consolidation proposal. However, should DHS receive this approval, consulting GAO's key practices would help ensure that lessons learned from other organizations are considered.
section_title: What GAO Recommends
paragraphs: GAO recommends that DHS complete, document, and make available analyses associated with identifying: (1) unintended problems, if any, that consolidation may create; (2) a comparison of the consolidation's benefits and costs; and (3) a broader range of external stakeholder input. Although DHS did not concur, GAO continues to believe that findings documented in the report support the recommendation. DHS concurred with GAO's additional recommendation that should Congress approve DHS's plan, the department use key mergers and organizational transformation practices identified in previous GAO work.

section_title: Letter
paragraphs: Chemical, biological, radiological, and nuclear (CBRN) weapons, also  known as weapons of mass destruction (WMD), have the potential to kill  thousands of people in a single incident. The anthrax attacks of 2001  raised concerns that the United States is vulnerable to threats from CBRN  agents. The 2007 National Strategy for Homeland Security stated that  terrorists have declared their intention to acquire and use CBRN agents  as weapons to inflict catastrophic attacks against the United States.  Additionally, according to the Department of Homeland Security’s (DHS)  2014 Quadrennial Homeland Security Review report, chemical, biological,  radiological, and nuclear threats are enduring areas of concern and that  the consequences of such attacks are potentially high even though the  likelihood of their occurrence is relatively low.  Further, the February  2015 National Security Strategy noted that no threat poses as grave a  danger to our security and well-being as the potential use of nuclear  weapons and materials by irresponsible states or terrorists.
As noted by the House committee report accompanying the fiscal year  2013 DHS appropriations bill, across the U.S. Government, departments  and agencies have combined their CBRN programs into more centralized  offices. Consolidations such as the Federal Bureau of Investigation’s  (FBI) reorganization of its WMD-related activities into a single WMD  Directorate are intended to unify counterterrorism-related activities. To  this end, the House committee report, as well as the Senate explanatory  statement accompanying the Consolidated and Further Continuing  Appropriations Act, 2013, directed DHS to undertake an in-depth review  of the Department’s WMD programs, including potential consolidation of  CBRN mission functions, and provide a report of the review results to  Congress. DHS conducted its review, and in June 2015 provided a  report of its findings to Congress, including a proposal to consolidate the  agency’s core chemical, biological, radiological, nuclear and explosives  (CBRNE) functions.
You asked us to review the proposed consolidation of DHS’s CBRNE  programs. Specifically, this report discusses: (1) the extent to which  DHS’s proposal assessed the benefits and limitations of consolidation  and (2) GAO’s key practices from past organizational transformations that  could benefit DHS, should Congress approve the consolidation.
To address our first objective, we reviewed DHS’s June 2015 Chemical,  Biological, Radiological, and Nuclear Functions Review Report and  supporting documentation such as DHS’s Analysis of CBRNE  Organizational Alternatives, written testimony from DHS officials on  CBRNE threats, DHS’s FY 2017 Budget-In-Brief and fiscal year 2017  Congressional Budget Justification, among others. We also examined our  prior work on identifying useful practices and lessons learned from major  private and public sector mergers, acquisitions, and organizational  transformations and compared it against available documentation related  to DHS’s consolidation planning efforts. We also interviewed officials  from the DHS entities involved in the proposed CBRNE consolidation,  including officials from DHS’s Domestic Nuclear Detection Office (DNDO),  Office of Health Affairs (OHA), Office of Operations Coordination (OPS),  Science and Technology Directorate (S&T), Office of Bombing Prevention  (OBP), and the Office of Policy to obtain information on the review  process, subsequent decision-making process, benefits, and limitations of  the Secretary of Homeland Security’s reorganization decision. Further, we  reviewed the documents and information we gathered and evaluated  them against Standards for Internal Control in the Federal Government.  To address our second objective, we reviewed leading practices on  organizational transformation and program management from our prior  GAO work and assessed the applicability of these practices to the  proposed CBRNE consolidation.
We conducted this performance audit from September 2015 through  August 2016 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: In June 2015, DHS delivered its CBRNE Functions Review Report to  Congress which proposed consolidating the agency’s core CBRNE  functions (see fig. 1), into a new Office of CBRNE Defense.
According to DHS officials, the agency’s proposal to consolidate its  CBRNE functions adopts the primary recommendation from a previous  DHS study on CBRN consolidation conducted in 2013. At that time, DHS  assembled a review team to evaluate CBRN alignment options and  produced a report on its findings for the Secretary of Homeland Security.  According to DHS officials, the alignment options from the 2013 report  were updated in 2015 based on the Secretary’s Unity of Effort Initiative, to  include transferring CBRNE threat and risk assessment functions from  the DHS Science and Technology Directorate to the proposed CBRNE  Office, as well as including the DHS Office for Bombing Prevention from  the National Protection and Programs Directorate.
In December 2015, legislation that would amend the Homeland Security  Act of 2002 to establish within DHS a consolidated CBRNE Office was  passed in the House and referred to the Senate for consideration.  This  legislation, if approved, would direct the agency to create a new CBRNE  office led by an Assistant Secretary responsible for: (1) developing,  coordinating, and maintaining DHS’s overall CBRNE strategy and policy;  (2) developing, coordinating, and maintaining periodic CBRNE risk  assessments; (3) coordinating DHS’s CBRNE activities with other federal  agencies; (4) providing oversight for DHS's preparedness for CBRNE  threats; and (5) providing support for operations during CBRNE threats or  incidents.  As described in figure 2, the new CBRNE Office would be  comprised of Chemical, Biological, Nuclear, and Explosives mission  support divisions. As of July 2016, this legislation had not been taken up  by the Senate.
section_title: DHS Considered Several Key Factors, but Has Limited Analyses and Documentation Underlying the Benefits and Limitations of Its CBRNE Consolidation Proposal
paragraphs: The CBRNE report and summaries provide some insights into factors  considered, but did not include associated underlying data or  methodological information, such as how benefits and costs were  compared or the extent to which stakeholders were consulted. According  to DHS officials, DHS could not locate the underlying information  associated with analyses that informed the consolidation proposal due to  staff turnover. Without such underlying documentation, we could not fully  determine the extent to which DHS considered the benefits and  limitations of a CBRNE consolidation as part of its decision-making  process.
According to DHS’s report to Congress and the summary documents  provided to us, the department developed decision-making criteria,  identified as “desired outcomes” and “near-term goals” for its proposed  reorganization, and consulted with DNDO, OHA, S&T and leadership of  other DHS components, the Office of Management and Budget (OMB)  and National Security Council Staff. Also, according to an Office of Policy  official, DHS consulted with the Executive Office of the President as well  as Congressional staff on its consolidation plan. DHS considered five  alignment options, as shown in figure 3, and provided a general  assessment of the effects of reorganization on its CBRNE mission.
In May 2012, we reported on key questions for agency officials to  consider when evaluating an organizational change that involves  consolidation. Table 1 provides a summary of the key questions for  evaluating consolidation proposals from this previous work and a  summary of our assessment of whether documentation provided to us  and interviews with agency officials indicated whether each question was  addressed.
DHS’s June 2015 report to Congress and the supporting documentation  we reviewed included an evaluation of some, but not all, key questions  listed above in Table 1. As previously noted in our May 2012 report, these  questions are important to consider when evaluating an organizational  change that involves consolidation. Specifically, DHS’s consolidation  proposal:  Identified strategic outcomes and goals and considered  problems to be solved, but did not fully assess and document  potential problems that could result from consolidation. DHS’s  proposal and supporting documents identified eight near-term goals to  be achieved within two years of consolidation, such as providing  appropriate CBRN focus and visibility within the department and  preserving programs and activities that are currently operating  effectively, as shown in figure 3. DHS officials also indicated in  documents provided to us several problems that may be solved by a  CBRNE program consolidation. For example, in a November 2014  letter from the Secretary of Homeland Security to a congressional  committee chair, the Secretary states that consolidation will provide a  clearer focal point for external and DHS component engagement on  CBRNE issues, among other things. In addition, in a briefing to  Congress, DHS officials defined challenges a CBRNE consolidation  may address, such as inconsistent CBRN‐related messaging to DHS  stakeholders and confusion over a CBRN focal point within DHS and  for external stakeholders.
The proposal and supporting documents did not adequately address  problems that consolidation may create. Component officials we  interviewed provided several examples of potential problems due to  consolidation. For example, officials told us that merging staff into one  office could result in a need for additional support staff to manage  day-to-day functions such as human resources, contracting, and  financial management for a larger number of employees. Officials  further stated that they may not have sufficient staff to complete these  mission needs in a consolidated CBRNE unit. Additionally, component  officials expressed concern over the potential allocation of resources  in the consolidated office.  According to these officials, there is a  difference between components with missions that focus on potential  terrorism events that are more likely to occur but with limited  consequence versus components that focus on potential events that  are not as likely to occur but have the potential to be far more  catastrophic. These officials added that consolidating these  components may complicate resource allocation decisions due to the  varying degree to which certain CBRNE activities are seen as a  priority over others. According to a DHS official, Office of Policy  officials met with two of the five affected CBRNE components to  determine potential unintended problems and to develop mitigation  measures. However, not all affected components were included in the  discussions and the problems and measures were not documented.  According to our May 2012 report, the key to any consolidation  initiative is validating specific goals that have been evaluated against  a realistic assessment of how the consolidation can help achieve  these goals. In our past work, we have also found that it is important  for agencies to recognize that delays and disruptions are common  during consolidations, which can compromise or introduce new  problems during these initiatives. As such, it is key that agencies work  to anticipate and mitigate these issues or they risk seeing costs  increase.
Did not conduct and document a comparison of benefits and  costs. While committee report language directed DHS to include an  assessment of whether consolidation could produce cost savings, as  of May 2016, DHS had not documented a comparison of benefits and  costs for its consolidation plan.  DHS officials told us that in 2013  they developed a rough cost estimate for the consolidation option, but  provided no documentation or analysis supporting the estimate.  According to DHS’s proposal, additional analysis is required to  determine if budgetary efficiencies can be gained by the  recommended consolidation option. An Office of Policy official told us  that DHS has yet to conduct this additional analysis, noting that as a  result of an appropriations act restriction, officials decided to take few  concrete steps to plan for or move forward with the consolidation. Our  May 2012 report highlights the importance of benefits and cost  considerations as part of the decision- making process for potential  organizational consolidations. More specifically, given the potential  benefits and costs of consolidation, it is imperative that Congress and  the executive branch have the information needed to help effectively  evaluate consolidation proposals. Demonstrating that a consolidation  proposal is based on a clearly-presented business case or an analysis  of benefits and costs can show decision-makers why the initiative is  being considered. If agencies cannot reasonably conclude that  benefits will outweigh costs, the agency may need to consider  consolidation alternatives to meet its goals.
Did not fully identify or document consideration of up-front  costs. DHS considered potential up-front costs associated with a  CBRNE consolidation but did not document these costs or how they  were considered during the reorganization decision-making process.
For example, an Office of Policy official told us that DHS considered  some potential up-front costs associated with detailing 19 Office of  Bombing Prevention staff to DNDO. However, documentation we  reviewed did not describe the extent to which these up-front costs  were considered in the decision-making process. Additionally, DHS  officials stated they did not conduct an up-front cost estimate  associated with changes to physical infrastructure for the  consolidation proposal, because the agency intended to leverage  existing plans to move to a new location. According to an Office of  Policy official, to address the up-front costs associated with the  consolidation, DHS plans to take advantage of plans to move staff  and resources to the St. Elizabeth’s site in fiscal years 2017 and 2018  in an effort to reduce some of the expenses born out of the  consolidation. Even if some of the up-front costs are expected to be  covered through existing relocation plans, identifying and accounting  for the full amount of up-front funding is important to fully evaluate or  prepare for a consolidation. Our May 2012 report indicates that  consolidation initiatives often have up-front costs, and agencies must  pay them before they can realize any intended gains or savings. For  example, agencies may need to pay for equipment and furniture  moves or fund employee transfers and buyouts. Further, we also  found that a lack of up-front funding can prevent a potentially  beneficial initiative from getting off the ground or derail an initiative  already underway. Our review of DHS’s proposal does not indicate  that these potential expenses or any other up-front costs were fully  considered in developing the proposal.
Conducted limited external stakeholder consultations. DHS  conducted limited external stakeholder outreach in developing the  consolidation proposal, and thus the proposal may not sufficiently  account for stakeholder concerns. According to an Office of Policy  official, the review team consulted with OMB, National Security  Council Staff, the Executive Office of the President (EOP) and  Congressional staff. Among the six components involved in the  proposed consolidation, DHS officials stated that two of these  components, DNDO and OHA, have significant working relationships  with a wide range of external stakeholders including the Departments  of Defense, State, Energy, and Health and Human Services.  However, while the impact of consolidation to external stakeholders  was a consideration, agency officials did not solicit input directly from  the full range of interagency stakeholders associated with each of the  CBRNE components in developing the proposal.
According to a DHS Office of Policy official, DHS’s assessment of its  consolidation was that it was an internal reorganization with a goal to  improve outward-facing messaging and collaboration. This official also  indicated that both DNDO and OHA are considered useful sources  for identifying potential positive or negative consolidation impacts  for their stakeholders. DHS leadership was satisfied that discussions  with the EOP in addition to DNDO and OHA’s engagement with their  respective external stakeholders sufficiently accounted for the  perspectives of interagency partners, according to the DHS Office of  Policy official. However, DHS did not provide documentation of any  external stakeholder consultations, including the outcome of any  discussions related to the consolidation proposal or how this  information was used in the decision-making process.  In May 2012,  we reported that consolidation success depends on a wide range of  factors, including getting incentives right for those affected by the  consolidation. External stakeholders often view a consolidation as  working against their own interests. For example, agency clients and  customers may have concerns about potential reduction in service or  access to agency officials. Moreover, stakeholders frequently raise  valid concerns on the basis of their familiarity with an agency’s  operations, and the concerns need to be addressed openly and  objectively. Failure to effectively engage with external stakeholders  and understand and address their views can undermine or derail the  initiative. We have found that, as a result, it is critical that agencies  identify who the relevant external stakeholders are and develop a two- way communication strategy that both addresses their concerns and  conveys the rationale for and overarching benefits associated with a  consolidation initiative.
According to Standards for Internal Control in the Federal Government,  documenting management oversight of processes intended to improve  the effectiveness and efficiency of operations provides reasonable  assurance that the organization is addressing risks and being good  stewards of government resources and achieving results. DHS officials  acknowledged that without source documentation underlying the analysis  behind the consolidation proposal, the full extent to which the  reorganization options were considered is not discernable. By  documenting its decision-making process, DHS would provide a means to  retain organizational knowledge and mitigate the risk of having that  knowledge limited to a few personnel, as well as communicate that  knowledge as needed to affected parties. Additionally, attention to the key  questions identified from our analysis of previous organizational  consolidations would help provide DHS, Congress, and other  stakeholders with assurance that important aspects of effective  organizational change, including a consideration of the plan’s benefits  and limitations, are addressed as part of the agency’s CBRNE  reorganization decision-making process. Not fully considering these  factors could make the agency’s decision to consolidate vulnerable to risk  of failure, increased costs, or stakeholder skepticism.
section_title: Key Mergers and Organizational Transformation Practices Could Benefit DHS Moving Forward If Congress Approves the CBRNE Consolidation
paragraphs: Should Congress approve its plan to consolidate, DHS could benefit from  incorporating change management approaches such as the key practices  and implementation steps derived from organizational transformations  undertaken by large private and public sector organizations identified in  our previous work. Doing so would help ensure that DHS’s consolidation  initiative is results oriented, customer focused, and collaborative in  nature. The Consolidated Appropriations Act, 2016, provides that none of  the funds appropriated may be used to establish an Office of CBRNE  Defense until Congress has authorized such establishment and, as of  July 2016, Congress had not approved the proposed consolidation. As a  result of this restriction, DHS officials told us they have taken few  concrete steps to plan for or move forward with the consolidation.   However, if Congress passes authorizing legislation, DHS intends to  permanently establish the new CBRNE Office, transfer all requisite  personnel, and announce a new leader for the office, according to DHS  Office of Policy officials.
As DHS was formed, we reported in July 2003 on key practices and  implementation steps for mergers and organizational transformations.  The factors listed in Table 2 were built on the lessons learned from the  experiences of large private and public sector organizations.
The practices outlined in our July 2003 report are intended to help  agencies transform their cultures so that the federal government has the  capacity to deliver its promises, meet current and emerging needs,  maximize its performance, and ensure accountability. DHS has not  evaluated each of these practices. According to DHS officials, the agency  is awaiting congressional approval of the proposed consolidation before  developing implementation steps. However, should DHS receive this  approval to reorganize its CBRNE functions, consulting each of these  practices would ensure that lessons learned from other organizations are  considered. According to our prior work on organizational change,  implementing large-scale change management initiatives, such as  mergers and organizational transformations, are not simple endeavors  and require the concentrated efforts of both leadership and employees to  realize intended synergies and to accomplish new organizational goals.  In addition, the practices will be helpful in a consolidated CBRNE  environment. For example, overall employee morale differs among the  components to be consolidated, as demonstrated by the difference in the  2015 employee satisfaction and commitment scores of DNDO and  S&T, making employee involvement to gain their ownership for the  transformation a key step to consider. Also, given the range of activities  conducted by the consolidated entities, establishing a coherent mission  and integrated strategic goals to guide the transformation will be  important.
Given the critical nature of DHS’s CBRNE mission, considering key  factors from our previous work would help inform a consolidation effort  should Congress approve it. The lessons learned by other organizations  involved in substantial transformations could provide key insights for  agency officials if they implement reorganization and attention to the  factors we identified would improve the chances of a successful CBRNE  consolidation.
section_title: Conclusions
paragraphs: Preventing a terrorist attack in the United States remains the foundation  of homeland security, especially when CBRNE threats continue to be  enduring areas of concern. DHS’s CBRNE consolidation proposal is  intended to centralize CBRNE functions within DHS headquarters while  also becoming a focal point for CBRNE issues. However, limited  information and analysis related to assessing the benefits and limitations  of its consolidation plan prevent DHS from fully demonstrating how its  consolidation will lead to an integrated, high-performance organization.   Additionally, should Congress approve CBRNE consolidation at DHS, the  department could improve the likelihood of a successful consolidation  effort if lessons identified in our previous work are considered.
section_title: Recommendations for Executive Action
paragraphs: To better provide Congress and affected stakeholders with assurance  that important aspects of effective organizational change are addressed  as part of the agency’s CBRNE reorganization decision-making process,  we recommend that the Secretary of Homeland Security direct the  Assistant Secretary for the Office of Policy to complete, document, and  make available analyses of key questions related to its consolidation  proposal, including: what problems, if any, consolidation may create; a comparison of the benefits and costs the consolidation may entail; a broader range of external stakeholder input including a discussion of  how it was obtained and considered.
If DHS’s proposed CBRNE program consolidation is approved by  Congress, we recommend that the Secretary of Homeland Security direct  the Assistant Secretary for the Office of Policy to use, where appropriate,  the key mergers and organizational transformation practices identified in  our previous work to help ensure that a CBRNE consolidated office  benefits from lessons learned from other organizational transformations.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DHS for comment. DHS provided  technical comments, which we incorporated as appropriate. On July 14,  2016, DHS also provided written comments, reproduced in full in  appendix I. DHS concurred with one of our two recommendations, and  described actions planned to address it, but did not concur with the other.
DHS did not concur with our first recommendation that the Secretary of  Homeland Security direct the Assistant Secretary for the Office of Policy  to complete, document, and make available analyses of key questions  related to its consolidation proposal, including: what problems, if any, consolidation may create; a comparison of the benefits and costs the consolidation may entail; a broader range of external stakeholder input including a discussion of  how it was obtained and considered.
In its comments, DHS stated that completing a study to answer the  questions raised in our report and inform a decision that has already been  made is redundant.  According to DHS, our recommendation does not  acknowledge the extent to which these questions have been discussed  both internally within DHS and externally with Congress.  DHS indicated  that it considered the cost and benefits of reorganization within the  conduct of the 2013 study, the follow-on work in 2014, and senior  leadership meetings as part of the decision-making process. According to  DHS, the department reviewed its CBRNE programs and functions by  analyzing organizational models and identified several alignment options,  each with its own cost and benefits. As we stated in this report, committee  report language directed DHS to include an assessment of whether  consolidation could produce cost savings, and as of July 2016, DHS had  not documented a comparison of benefits and costs for its consolidation  plan. DHS officials told us that in 2013 they developed a rough cost  estimate for the consolidation option, but provided no documentation or  analysis supporting the estimate. Further, according to the CBRNE  consolidation proposal DHS submitted to Congress in June 2015,  additional analysis is required to determine if budgetary efficiencies can  be gained by the recommended consolidation option.  Based on our  review of available CBRNE consolidation documentation and our prior  work on evaluating consolidation proposals, we continue to believe that  considering benefits and costs as part of the decision-making process for  potential organizational consolidation is important as it would provide  Congress and the executive branch the information needed to help  effectively evaluate consolidation proposals.
Also in its comments, DHS stated that both monetary and non-monetary  costs associated with its proposed reorganization were considered.  According to DHS, monetary costs of the proposed consolidation were  within the current and planned budget of the affected organizations.  DHS  also indicated that non-monetary costs such as impact on appropriations  and staff morale would likely result in increased benefits to operational  effectiveness and efficiency and morale in the new office. Our report  acknowledges that DHS considered potential up-front costs associated  with a CBRNE consolidation; however, DHS did not document these  costs or how they were considered during the reorganization decision- making process. We previously reported in May 2012 that consolidation  initiatives often have up-front costs, and agencies must pay them before  they can realize any intended gains or savings. For example, agencies  may need to pay for equipment and furniture moves or fund employee  transfers and buyouts. Based on our review of DHS’s proposal, the  department did not fully consider similar potential expenses or up-front  costs in developing its proposal. Our prior work has shown that a lack of  up-front funding can prevent a potentially beneficial initiative from getting  off the ground or derail an initiative already underway. Until DHS  completes this analysis and documents its findings, we continue to  believe that these potential challenges have yet to be mitigated.
DHS commented that it consulted Congress on its proposed  consolidation. Specifically, DHS commented that it provided briefings to  the appropriate authorizing and appropriations committees on numerous  occasions. Although the Department of Homeland Security CBRNE  Defense Act of 2015 (H.R. 3875), which has passed the House, and the  President’s budget submission for fiscal year 2017 include DHS’s  proposed CBRNE reorganization, authorizing legislation has not been  enacted. Implementing our recommendation to complete, document, and  make available analyses of key questions related to DHS’s proposal  would provide additional information to help decision-makers understand  the basis and implications of the proposal. However, according to DHS,  the passage of the Consolidated Appropriations Act, 2016 (P.L. 114-113)  is a complicating factor. Specifically, DHS stated that the department is  concerned that conducting any reorganization-related activities, including  further study on the matter, may undermine the department’s original  reorganization recommendation with Congress and disrupt ongoing  authorizing legislation deliberations.  Section 521 of the Consolidated  Appropriations Act, 2016, provides that none of the funds appropriated  may be used to “establish” an Office of CBRNE Defense until Congress  has authorized such establishment. Although DHS cannot use  appropriated funds to establish a CBRNE office without authorization, we  believe that completing, documenting, and making available the analysis  supporting the reorganization recommendation will not disrupt, but rather  will assist in ongoing legislative deliberations by providing additional  information to decision-makers.
Also in its comments, DHS remarked that our report did not mention the  department’s headquarters realignment that occurred between FY 2014  and FY 2015 as part of Secretary of Homeland Security Jeh Johnson’s  Unity of Effort Initiative.  According to DHS, we did not acknowledge how  the proposed CBRNE consolidation would contribute to principal Unity of  Effort objectives such as integrating broad and complete DHS mission  spaces and empowering DHS components to effectively execute their  missions. However, while the department’s Unity of Effort initiative was  not the focus of our review, our report acknowledges that according to  DHS officials, the CBRNE alignment options from the department’s 2013  report were updated in 2015 based on the Secretary’s Unity of Effort  Initiative, to include transferring CBRNE threat and risk assessment  functions from the DHS Science and Technology Directorate to the  proposed CBRNE Office, as well as including the DHS Office for Bombing  Prevention from the National Protection and Programs Directorate.  Our  report also recognizes that DHS’s CBRNE consolidation proposal is  intended to centralize CBRNE functions within DHS headquarters while  also becoming a focal point for CBRNE issues. We believe that the  additional context provided by DHS, more closely tying its CBRNE  consolidation to the department’s larger headquarters realignment efforts,  further underscores the importance of our findings. As noted in our report,  limited information and analysis related to assessing the benefits and  limitations of its consolidation plan prevent DHS from fully demonstrating  how its proposal will lead to an integrated, high-performance organization.
DHS concurred with our second recommendation related to using, where  appropriate, the key mergers and organizational transformation practices  identified in our previous work to help ensure that a CBRNE consolidated  office benefits from lessons learned from other organizational  transformations. DHS stated that upon receiving congressional approval  for its CBRNE consolidation plan, it will use GAO’s report on evaluating  consolidation proposals as well as other resources to develop a detailed  implementation plan as appropriate.  These actions, if fully  implemented, should address the intent of the recommendation.
As agreed with your office, 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 to the Secretary of  Homeland Security and selected congressional committees. In addition,  the report will be available at no charge on the GAO website at  http://www.gao.gov.
Should you or your staff have any questions, please contact me at 404- 679-1875 or curriec@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 II.
section_title: Appendix I: Comments from the Department of Homeland Security
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Ben Atwater (Assistant  Director) and Landis Lindsey (Analyst-in-Charge) managed this audit  engagement. Chuck Bausell, Eric Hauswirth, Hayden Huang, Tracey  King, Tovah Rom, Sarah Veale and Josiah Williams made significant  contributions to this report.