Federal Facility Security: Selected Agencies Should Improve Methods for Assessing and Monitoring Risk
Released: 2017-10-26T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: Protecting federal employees and facilities from security threats is of critical importance. Most federal agencies are generally responsible for their facilities and have physical security programs to do so.

GAO was asked to examine how federal agencies assess facilities' security risks. This report examines: (1) how selected agencies' assessment methodologies align with the ISC's risk management standard for identifying necessary countermeasures and (2) what management challenges, if any, selected agencies reported facing in conducting physical security assessments and monitoring the results.

GAO selected four agencies—CBP, FAA, ARS, and the Forest Service—based on their large number of facilities and compared each agency's assessment methodology to the ISC Standard; analyzed facility assessment schedules and results from 2010 through 2016; and interviewed security officials. GAO also visited 13 facilities from these four agencies, selected based on geographical dispersion and their high risk level.

section_title: What GAO Found
paragraphs: None of the four agencies GAO reviewed—U.S. Customs and Border Protection (CBP), the Federal Aviation Administration (FAA), the Agricultural Research Service (ARS), and the Forest Service—used security assessment methodologies that fully aligned with the Interagency Security Committee's Risk Management Process for Federal Facilities standard (the ISC Standard). This standard requires that methodologies used to identify necessary facility countermeasures—such as fences and closed-circuit televisions—must:

1. Consider all of the undesirable events (i.e., arson and vandalism) identified by the ISC Standard as possible risks to facilities.

2. Assess three factors—threats, vulnerabilities, and consequences—for each of these events and use these three factors to measure risk.

All four agencies used methodologies that included some ISC requirements when conducting assessments. CBP and FAA assessed vulnerabilities but not threats and consequences. ARS and the Forest Service assessed threats, vulnerabilities, and consequences, but did not use these factors to measure risk. In addition, the agencies considered many, but not all 33 undesirable events related to physical security as possible risks to their facilities. Agencies are taking steps to improve their methodologies. For example, ARS and the Forest Service now use a methodology that measures risk and plan to incorporate the methodology into policy. Although CBP and FAA have updated their methodologies, their policies do not require methodologies that fully align with the ISC standard. As a result, these agencies miss the opportunity for a more informed assessment of the risk to their facilities.

All four agencies reported facing management challenges in conducting physical security assessments or monitoring assessment results. Specifically, CBP, ARS, and the Forest Service have not met the ISC's required time frame of every 3 years for conducting assessments. For example, security specialists have not conducted required reassessments of two ARS and one Forest Service higher-level facilities. While these three agencies have plans to address backlogs, CBP's plan does not balance conducting risk assessments with other competing security priorities, such as updating its policy manual, and ARS and the Forest Service lack a means to monitor completion of future assessments. Furthermore, CBP, ARS, and the Forest Service did not have the data or information systems to monitor assessment schedules or the status of countermeasures at facilities, and their policies did not specify such data requirements. For example, ARS and the Forest Service do not collect and analyze security-related data, such as countermeasures' implementation. FAA does not routinely monitor the performance of its physical security program. Without improved monitoring, agencies are not well equipped to prioritize their highest security needs, may leave facilities' vulnerabilities unaddressed, and may not take corrective actions to meet physical security program objectives. This is a public version of a sensitive report that GAO issued in August 2017. Information that the agencies under review deemed sensitive has been omitted.

section_title: What GAO Recommends
paragraphs: GAO recommends: (1) that CBP and FAA update policies to require the use of methodologies fully aligned with the ISC Standard; (2) that CBP revise its plan to eliminate the assessments backlog; and (3) that all four agencies improve monitoring of their physical security programs. All four agencies agreed with the respective recommendations.

section_title: Letter
paragraphs: Several incidents—such as armed citizens taking over a federal wildlife  refuge in Oregon for about 40 days in 2016; the active shooter incident at  the Washington Navy Yard in Washington, D.C., in 2013 that resulted in  several deaths; and the fatal shooting at the Anderson Federal Building in  Long Beach, California, in 2012—demonstrate that government facilities  and their employees continue to be targets of potential harm. In light of  these incidents and other emergent threats, it is important that agencies  use risk-based methodologies to assess the physical security needs of  the approximately 113,000 executive-branch, non-military federal  buildings. Security assessments of facilities can uncover vulnerabilities  and threats and recommend protective measures—called  countermeasures—such as fences, access control systems, and closed- circuit television systems to mitigate those threats.

At least 30 federal agencies are responsible for protecting about 45  percent of civilian federal facilities and their occupants from potential  threats. To help federal agencies protect and assess risks to their  facilities, the Interagency Security Committee (ISC), an organization  chaired by the Department of Homeland Security (DHS), developed  physical security standards for non-military federal facilities in the United  States.

One particular standard, called The Risk Management Process for  Federal Facilities, defines the criteria and process executive agencies  and departments must follow when assessing risks to their facilities.  However, our past work found that some federal agencies used this  standard to varying degrees leaving agencies’ facilities, workforce, and  visitors exposed to risk. You asked us to examine how federal agencies  with protective responsibilities use risk management to protect their  facilities with countermeasures that meet their security needs. This report  examines (1) how selected agencies’ assessment methodologies align  with the ISC risk management standard to identify necessary  countermeasures, and (2) what management challenges, if any, selected  agencies reported facing in conducting physical security assessments  and monitoring the results.

This product is a public version of a sensitive report that we issued in  August 2017. DHS deemed some of the information in our August report  to be sensitive, including information about facility locations, risk  assessment results, and undesirable events not assessed for federal  facilities physical security. Therefore, this report omits that information  which must be protected from public disclosure. Although the information  provided in this report is more limited, the report addresses the same  objectives as the sensitive report and uses the same methodology.

To address the objectives, we selected four agencies with responsibility  for assessing their own facilities—DHS’s U.S. Customs and Border  Protection (CBP); the Department of Transportation’s Federal Aviation  Administration (FAA); and the United States Department of Agriculture’s  (USDA) Agricultural Research Service (ARS) and Forest Service. To  determine how these agencies’ assessment methodologies align with The  Risk Management Process for Federal Facilities (the ISC Standard), we  compared facility security policies and procedures from the departments  and agencies to the criteria and process in the ISC Standard. In addition,  we selected 13 facilities within these 4 agencies for site visits based on  geographical dispersion and high levels of risk. For each of the selected  facilities, we reviewed assessment reports, toured the facilities, and  identified the status of recommended countermeasures. We interviewed  officials from the ISC, 3 departments, 4 agencies, and the 13 facilities to  understand security standards, policies, and procedures; agency-specific  assessment processes; management challenges; and guidance for  prioritizing physical security needs. We did not independently determine  what constitutes a management challenge, but relied on these facility  managers and agency security staff to identify their concerns as defined  in their own policies and procedures. We reviewed Standards for Internal  Control in the Federal Government (Standards for Internal Control)  regarding risk management criteria and the use of quality information for  our evaluation of the agencies’ abilities to monitor their physical security  program. The results of our review of the selected agencies are not  generalizable to all the ISC member agencies but provide illustrative  examples of risk assessments and how the facilities addressed needed  countermeasures. See appendix I for more details on our scope and  methodology and appendix II for a list of the 13 selected facilities visited.

The performance audit upon which this report is based was conducted  from June 2016 to August 2017 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. We  subsequently worked with DHS, DOT, and USDA from August 2017 to  October 2017 to prepare this version of the sensitive report for public  release. This public version was also prepared in accordance with these  standards.
subsections: section_title: Background
paragraphs: Risk management, as applied to security of federal facilities, entails a  continuous process of applying a series of mitigating actions—assessing  risk through the evaluation of threats, vulnerabilities, and consequences;  responding to risks with appropriate countermeasures; and monitoring  risks using quality information (see fig. 1).

In 1995, Executive Order 12977 established the ISC after the bombing of  the Oklahoma City Alfred P. Murrah Federal Building in April 1995. The  ISC’s mandate is to enhance the quality and effectiveness of security in  and protection of federal facilities in the United States occupied by federal  employees for nonmilitary activities. The order directs the ISC to  develop and evaluate security standards for federal facilities, develop a  strategy to ensure executive agencies and departments comply with such  standards, and oversee the implementation of appropriate security  measures in federal facilities. The ISC has released a body of standards,  including the ISC Standard, designed to apply to the physical security  efforts of all federal, non-military agencies. The ISC Standard prescribes  a process for agencies to follow in developing their risk assessment  methodologies (see fig. 2).

Most federal departments and agencies are generally responsible for  protecting their own facilities and have physical security programs in  place to do so. The ISC Standard requires executive departments and  agencies to follow the risk-management process when conducting risk  assessments for each of their facilities. That process begins with  determining the facility security level, ranging from level I (lowest risk) for  facilities generally having 100 or fewer employees to level V (highest risk)  for the most critical facilities and generally having greater than 750  employees. The security level designation determines the facility’s baseline countermeasures. For each facility, departments and agencies  are required to (a) consider all of the “undesirable events” that could pose  a risk to their facilities— such as active shooters, vandalism, and  explosions—and (b) assess three factors of risk (threats, vulnerabilities,  and consequences) to specific undesirable events. Subsequently,  agencies are to combine all three factors to yield a measurable level of  risk for each undesirable event (see app. III). Based on the results of  these assessments, agencies should customize (either increase or  decrease) the countermeasures to adequately reflect the assessed level  of risk.

In addition, as part of planning for physical security resources within an  agency’s budget process, the ISC has identified the need to balance  allocations for countermeasures with other operational needs and with  competing priorities. The ISC Best Practices have some similarities with  leading practices in capital decision-making. For example, both state that  the allocation of resources should be integrated into the agency’s  mission, objectives, goals, and budget process. However, beyond the ISC  Best Practices, the Office of Management and Budget and we have  developed more comprehensive leading practices in capital decision- making that provide agencies with guidance for prioritizing budget  decisions such as for countermeasure projects. The Office of  Management and Budget and our guidance also emphasize evaluating a  full range of alternatives, informed by agency asset inventories that  contain condition information, to bridge any identified performance gap.  Furthermore, the guidance calls for a comprehensive decision-making  framework to review, rank, and select from among competing project  proposals. Such a framework should include the appropriate levels of  management review, and selections should be based on the use of  established criteria.

The following describes the mission and physical security program  characteristics for the agencies in our review:

CBP, the nation’s largest law enforcement agency, has responsibility  for securing the country’s borders. It also has responsibility for  conducting security assessments at about 1,200 facilities, including  approximately 215 federally owned and agency-controlled higher-level  facilities (facility security levels III and IV). These facilities include  border patrol stations with holding cells for people detained at the  border, office buildings, and canine-training centers. CBP conducts  these assessments.

FAA’s mission is to provide a safe and efficient aerospace system for  the country. According to agency data, FAA has 55 federally owned  and agency-controlled higher-level facilities—including critical air  traffic control towers. According to FAA officials, FAA specialists  conduct security assessments.

ARS conducts research related to agriculture and disseminates  information to ensure high-quality safe food and to sustain a  competitive agricultural economy. According to agency data, ARS has  security responsibility for four domestic federally owned and agency- controlled higher-level facilities—including laboratories for research to  improve food and crop quality, office buildings, and warehouses. ARS  security personnel have responsibility for conducting security  assessments.

The Forest Service sustains the health, diversity, and productivity of  the nation’s forests and grasslands. According to agency officials, the  Forest Service has one federally owned and agency-controlled higher- level facility—a regional headquarters office building. The Forest  Service’s security officials have responsibility for conducting security  assessments, but at the time of our review, USDA security officials  conducted the assessment at Forest Service’s one higher-level  facility.

section_title: Selected Agencies’ Assessment Methodologies Do Not Fully Align with the ISC’s Risk Management Standard
paragraphs: None of the four selected agencies’ security assessment methodologies  fully aligned with the ISC Standard. The ISC gives agencies some  flexibility to design their own security-assessment methodologies for  identifying necessary countermeasures as long as the chosen  methodology adheres to fundamental principles of a sound risk- management methodology. Specifically, methodologies must:  consider all of the undesirable events identified in the ISC Standard  as possible risks to federal facilities, and assess three factors of risk (threats, vulnerabilities, and  consequences) for each of the events.

Furthermore, the ISC Standard requires executive departments and  agencies to document decisions that deviate from the ISC Standard.  Agencies’ policies and methodologies reference the ISC Standard.  However, none of the agencies’ methodologies considered all of the  undesirable events during assessments although they used some type of  risk assessment methodology. In addition, the agencies did not always  adhere to these principles of risk management (see table 1).

At the time of our review, CBP’s methodology did not fully align with the  ISC Standard because it did not consider all of the 33 undesirable events  nor assess threat and consequence. CBP security specialists assessed  vulnerabilities at building entrances and exits, in interior rooms, and  around the perimeter using a yes/no checklist during the assessment  process. However, assessment reports showed that specialists did not  assess the threats and consequences of undesirable events at each  facility. According to security officials, the gap occurred because they  designed the checklist to meet requirements in the 2009 CBP Security  Policy and Procedures Handbook, which predates the first edition of the  ISC Standard issued in 2010. CBP officials told us that as of January  2017, they began using an improved methodology to assess the threats,  vulnerabilities, and consequences for 30 of 33 undesirable events— omitting three now identified in the November 2016 revision to the ISC  Standard. However, CBP has not yet updated its handbook to align with  the ISC Standard, even though it started this effort over 3 years ago in  December 2013. CBP officials did not provide a draft of its updated  handbook, but they provided a plan with milestone dates for issuing the  handbook by September 2018. CBP officials also told us that updates to  the handbook may have to wait due to competing priorities, including  efforts to address the backlog of assessments (which we discuss later in  this report). Delays in updating the handbook mean that CBP’s policy will  continue to not align with the ISC Standard. Furthermore, although CBP  security officials told us that all of the agency’s security specialists have  been trained to use the improved assessment methodology, without  documentation of the methodology in agency policy, there may be greater  risk of its inconsistent application. Standards for Internal Control  emphasize the importance of agencies developing and documenting  policies to ensure agency-wide objectives are met. Documentation serves  to retain institutional knowledge over time when questions about previous  decisions arise. Without an updated policy handbook that requires a  methodology that assesses all undesirable events consistent with the ISC  Standard, CBP cannot reasonably ensure that its facilities will have levels  of protection commensurate to their risk.

FAA’s methodology does not fully align with the ISC Standard because it  does not consider all of the 33 undesirable events nor does it assess all  three factors of risk. FAA security specialists assess vulnerabilities to the  site perimeter, entryways, and interior rooms using a yes/no checklist, but  the checklist does not assess the consequences from each of the  undesirable events at each facility. With respect to threat, FAA applies the  ISC’s baseline threat—a general federal facilities threat level that relates  directly to a set of baseline countermeasures—across all its higher-level  facilities because FAA policy states that there is no agency-specific threat  that exceeds the current baseline threat. According to FAA officials, the  baseline threat standardizes the security needs across their facilities  rather than addressing the security needs of individual facilities from  specific threats. When necessary, FAA policy allows specialists to modify  countermeasures based on an evaluation of conditions at the facility.

FAA realized that this approach was no longer appropriate given the  agency-wide goal to make risk-based decisions, a review of the  assessment process after a 2014 Chicago fire incident that destroyed  critical FAA equipment, and an awareness of ISC initiatives to assess  compliance. To address the resulting methodological gaps, FAA hired a  contractor to design, develop, test, and validate an improved risk- assessment methodology. Subsequently, FAA improved its methodology  in January 2017 to assess the threats, vulnerabilities, and consequences  for 30 of the 33 undesirable events identified in the November 2016  revision to the ISC Standard —and tested the methodology at lower-  and higher-level facilities. This revised methodology addresses the need  to assess individual facility needs rather than using a standardized  baseline approach. In April 2017, FAA officials told us of their plan for  implementing this methodology and provided tentative milestone dates to  conduct further testing, training, and analysis before deciding to use the  improved methodology, which they expect to complete by January 2018.  However, their plan lacks the necessary information to ensure successful  implementation, such as detail on how many facilities they will test and  how they will use the results of testing, training, and analysis to  implement the improved methodology within the identified 9-month time  frame. Furthermore, the improved methodology does not address  undesirable events for which ISC issued countermeasures in May 2017.  Without a detailed implementation plan to assess the methodology’s  impact on its security program, FAA cannot reasonably ensure that its  facilities have the proper countermeasures. With ongoing changes to its  security program, FAA has an opportunity to fully align its improved  methodology with the ISC Standard by including all 33 undesirable events  and to update its policy requiring the use of such a methodology.

Unlike CBP and FAA—which developed their own methodologies  separate from their parent departments (Department of Homeland  Security (DHS) and Department of Transportation (DOT), respectively)— ARS and the Forest Service follow an assessment methodology  developed by USDA. USDA’s methodology does not fully align with the  ISC Standard because it does not consider all of the 33 undesirable  events for which ISC issued countermeasures in May 2017. Security  specialists from USDA headquarters typically assess ARS’s and the  Forest Service’s higher-level facilities using a risk-based methodology  that considers the 31 undesirable events listed in the previous version of  the ISC Standard dated August 2013. However, until recently, USDA did  not assign ratings to each of the three risk factors—threat, vulnerability,  and consequence—and then combine these ratings to yield a measurable  level of risk for each undesirable event. USDA security officials said that  they have revised the assessment-reporting format to include this risk  calculation and trained their specialists to measure risk in this way. USDA  officials provided us with a new assessment template that addresses all  33 undesirable events and includes measuring risk. Additionally, USDA  officials said that they are revising their outdated physical security manual  and expect to complete it by April 2018. With a revised manual and  application of the new assessment template, USDA should be better  positioned to assess risk at its facilities.

When agencies do not use methodologies that fully align with the ISC  Standard, they could face deleterious effects, ranging from facilities  having inappropriate levels of protection to agencies having an inability to  make informed resource allocation decisions for their physical security  needs. Specifically, the ISC Standard states that facilities may face the  effect of either having (1) less protection than needed resulting in  inadequate security or (2) more protection than needed resulting in an  unnecessary use of resources. The ISC Standard also states that these  effects can be negated by determining the proper protection according to  a risk assessment. Identified excess resources in one risk area then can  be reallocated to underserved areas, thus ensuring the most cost- effective security program is implemented. As an illustration of such  potential effects, we found that two agencies assessing two higher-level  facilities came to two different conclusions in terms of their need for X-ray  machines to screen for guns, knives, and other prohibitive items in federal  facilities. Specifically, one agency based its decision on a policy that does  not deviate from the ISC’s baseline set of countermeasures, and the other  agency based its decision on professional judgement that deviated from  the ISC’s baseline set of countermeasures. Neither agency based its  decision on a risk assessment nor documented its decision—both ISC  requirements, specifically:

Without conducting a risk assessment, FAA recently expanded a  policy requirement calling for all higher-level facilities to have X-ray  machines and magnetometers. This new requirement poses a  potentially sizeable investment for the agency with an estimated cost  of X-ray machines of about $24,000 and magnetometers of about  $4,000 each. FAA may need such equipment at all its higher-level  facilities. However, the ISC Standard requires that agencies conduct  risk assessments first to justify their needs. Without conducting risk  assessments, FAA managers could unnecessarily use resources by  installing such equipment in all higher-level air traffic facilities when  there may be higher priority needs

A USDA security specialist decided, despite an ISC baseline  requirement that higher–level facilities have X-ray machines, not to  recommend an X-ray machine at a higher-level Forest Service facility.  The specialist reasoned that unlike other federal buildings with  numerous unknown visitors, this facility receives mostly known  individuals and a limited number of visitors. The ISC Standard allows  for professional judgement; however, the ISC requires that agencies  document deviations from the baseline set of countermeasures.  Reducing the facility’s level of protection without documenting an  assessment of risk could result in no record of the basis of the  decision for current and future facility managers and security officials  to review or use as justification in the case of a question of  compliance.

In another case, we found that one higher-level facility did not have  access control for employees or visitors nor did it have armed guard  patrols. The facility manager told us that intelligence and a history  without incidents gave leadership reason to believe that these measures  were not needed and that therefore the agency did not require and would  not fund such protective measures for this facility—in effect, accepting the  risks to the facility. Security officials said they also had the same  understanding and did not document the matter in the assessment report  even though agency policy and the ISC Standard require written  documentation when officials deviate from the baseline requirement.

Without security assessments that fully align with the ISC Standard and  provide measureable levels of risk, agencies do not have the information  they need to determine priorities and make informed resource allocation  decisions. For example, they may not be able to assess whether to  acquire or forego costly physical-security countermeasures—such as, X- ray machines, access control systems, and closed-circuit television  systems—for facilities. Additionally, after determining the need to acquire  a countermeasure, agencies must fund the countermeasure. As  previously discussed, leading practices in capital decision-making include  a comprehensive framework to review, rank, and select from competing  project proposals for funding. In conducting risk assessments that do  not fully align with the ISC Standard (i.e., not assessing threats,  vulnerabilities, and consequences and measuring risks), agencies miss  the opportunity for more informed funding decisions. Three of the four  agencies (CBP, ARS, and the Forest Service) currently prioritize funding  for operational needs over physical security needs (see table 2) when  agencies’ priorities might be different if they based their decisions on an  aligned risk assessment.

section_title: Selected Agencies Reported Facing Challenges in Conducting Security Assessments and Monitoring Results
subsections: section_title: Agencies Have Not Conducted Timely Security Assessments
paragraphs: Standards for Internal Control state that agencies should use quality  information on an ongoing basis as a means to monitor program activities  and take corrective action, as necessary. The ISC requires that agencies  assess higher-level facilities at least once every 3 years—an interval  requirement to identify and address evolving risks. We found that three of  the four agencies (CBP, ARS, and the Forest Service) did not meet this  requirement. Officials reported various challenges including (1)  assessments competing with other security activities, (2) an insufficient  number of qualified staff to conduct assessments when compared to the  number of facilities, or (3) not knowing of the required assessment  schedule.

An “information system” is the people, processes, data, and technology that  management organizes to obtain, communicate, or dispose of information. that had not been reassessed since 2010. CBP security officials attributed  the backlog to (1) having too few security specialists assigned to assess  about 1,200 facilities and (2) the specialists working on competing  priorities, such as revising the security handbook, conducting technical  inspections, and reviewing new construction designs and renovation  projects. According to CBP security officials, they have developed a plan  to eliminate the backlog by the end of fiscal year 2018 by prioritizing the  completion of assessments. While we found the plan comprehensive, the  schedule did not seem feasible. For example, the plan assumes that one  specialist can complete six assessments in 3 consecutive days and that  another specialist can complete three assessments in 1 day. In contrast,  security officials told us specialists take about 20 work hours (or 2½ days)  to conduct an on-site assessment of one facility. CBP officials said that  they believe they can meet the time frames of the plan because they have  set aside other priorities and have a thorough understanding of the scope  of work involved at the facilities. They added that it will not be easy to  meet the timeline, but they can accomplish it with a motivated and  committed workforce, adequate financial resources, and absent activities  that would otherwise require shifting of resources. We question the  feasibility of setting aside important priorities, such as updating the policy  manual and reviewing physical security elements in new construction  designs, as well as the workload assumptions for completing the  assessments. Further, these other priorities are also key to securing  facilities. Without balancing assessments with competing priorities, CBP’s  time frames for completing the assessments by the end of fiscal year  2018 may not be feasible and may also result in the agency’s not  addressing other important physical security responsibilities.

Since the ISC issued its standard in 2010, ARS and the Forest Service  have assessed their higher-level facilities at least once. However, these  agencies have not reassessed all of their higher-level facilities within the  3-year interval requirement. Specifically, security specialists have not  conducted required reassessments of two ARS and one Forest Service  higher-level facilities. The ARS headquarters official explained that the  agency had not reassessed the two facilities due to competing priorities  and insufficient internal resources. During the course of our review, ARS  headquarters officials said they began assessing one of the two ARS  facilities in May 2017 and will begin assessing the second facility in  October 2017. The Forest Service official explained that the agency  missed its security reassessment of the regional office because the  facility staff had not requested one. During our visit, facility staff  responsible for security told us that they were not aware of the ISC’s 3- year interval requirement. Facility staff requested a reassessment, and  security officials told us that they expected to complete it by mid-June  2017. Completing this one-time assessment may address the facility’s  security needs temporarily. However, ARS and the Forest Service have  not implemented a long-term schedule with key milestones and lack a  means to monitor completion of assessments of higher-level facilities at  least once every 3 years. Consequently, these agencies cannot  reasonably ensure that they have full knowledge of the risks to their  facilities.

FAA data from 2010 through 2016 show that FAA has assessed its 55  higher-level facilities at least once every 3 years. FAA policy requires  that specialists schedule assessments of higher-level facilities every 12– 18 months depending on whether the facility has met FAA physical  security standards.

section_title: Data Limitations Affect Agencies’ Ability to Fully Monitor Security Activities
paragraphs: The ISC Standard states that to make appropriate resource decisions,  agencies need information, such as what is being accomplished, what  needs management attention, and what is performing at expected levels.  We found that agencies’ methods of collecting and storing security  information had limitations that affected agency and facility officials’  oversight of the physical security of their facilities (see table 3).

Without having long-term, agency-wide information to monitor whether  assessments are conducted on schedule, ARS and the Forest Service  may not meet the ISC Standard, resulting in not adequately protecting  their facilities and employees.

The ISC Standard also states that agencies should measure their security  program’s capabilities and effectiveness to demonstrate the need to fund  facility security and to make appropriate decisions for allocating  resources. However, the agencies in our review were unable to  demonstrate appropriate oversight of their physical security programs  because:

CBP’s handbook does not include requirements for data collection  and analysis for monitoring physical-security program activities.  Facility managers and security officials do not enter assessment  results, such as the countermeasures recommended for facilities, in  the real property database. Consequently, they do not have  comprehensive data to manage their security program, assess overall  performance, and take any necessary corrective actions. A CBP  official told us that a comprehensive database would allow CBP to set  priorities for addressing countermeasures. Without including data  collection and analysis requirements in its updated handbook, CBP  may be unable to monitor the performance of its physical security  program.

FAA’s policy does not require ongoing monitoring of physical security  information, such as the status of recommended countermeasures or  assessment schedules. As a result, FAA officials do not proactively  use physical security information to assess the overall performance of  its physical security program and take corrective actions before an  incident occurs. Without a policy requiring ongoing monitoring of  information—an internal control activity, FAA may be unable to assess  the overall performance of its security program and take necessary  corrective actions.

USDA has a decentralized security program and places the  responsibility on agencies to create their physical security programs.  Security officials from ARS and the Forest Service told us that USDA  does not have a policy for collecting and managing agency-wide  information; however, they said that USDA is drafting a new  departmental regulation and manual that will specify (1) the roles and  responsibilities of agency and facility managers and (2) electronic- data-reporting requirements for monitoring the performance of the  physical security program. USDA officials provided a draft of USDA’s  regulation and manual for our review. The draft regulation did not  mention data reporting and monitoring, while the draft manual only  contained a table of contents that included a section entitled “Facility  Tracking Database.” USDA officials expect to issue new policies  sometime between October 2017 and April 2018. In the absence of  new departmental regulation and manual, USDA and Forest Service  officials told us that they have begun to develop a Forest Service  system for storing electronic copies of agency-wide assessments and  that they plan to expand the use of this system to track site specific  assessment dates and status of recommended countermeasures.  Forest Service officials provided milestone dates and described the  capabilities for a future information system, which they expect to  complete in September 2017. However, we could not determine  whether the manual will have information system requirements to  monitor agencies’ physical security program, an internal control  activity. Without USDA’s including data collection and analysis  requirements in its manual, its agencies may not be able to monitor  the performance of their physical security programs.

section_title: Selected Agencies Vary in Addressing Recommended Corrective Actions
paragraphs: Without agencies having information to monitor security activities, they  were unable to provide us information on the status of countermeasures  across their entire portfolio. In order to better understand the status of  countermeasures implemented and facilities’ experiences when  implementing countermeasures, we determined the status of  countermeasures at 13 facilities we visited.

As previously noted, risk management, as it pertains to physical security,  involves agency officials monitoring their physical security programs.  During our visits to 13 selected facilities, we found the four agencies  differed in the number of countermeasures that they had not  implemented. Facility officials provided us with some information on why  countermeasures had not been implemented, specifically:

CBP had a significant number of recommended countermeasures  from 2010 through 2016 that remained open at the eight selected  CBP facilities. CBP facility officials gave reasons why recommended  countermeasures had not been implemented. At one facility, officials  did not know about the recommended countermeasures from its last  2010 assessment because the individuals previously knowledgeable  about the assessments left the organization without communicating  the results. By taking action to improve facility security, they  implemented some needed countermeasures. However, at the time of  our review, a large number of the recommendations remained open.  At another facility, officials told us that they too had not known (for the  same reason mentioned above) of their 2010 assessment, which  contained recommended countermeasures. However, these officials  told us that they submitted a funding request a few weeks before our  visit to address all except one of the open countermeasures.  In  other cases, facilities have not implemented needed countermeasures  due to resource constraints or physical site limitations.

FAA had a large number of recommended countermeasures from  2010 through 2016 that remained open at the time of our review for  the two FAA facilities visited. In this case, the most recent security  assessment, completed in late 2016, resulted in one facility’s having  little time to implement countermeasures by the time we conducted  our analysis.

While ARS had closed almost all recommended countermeasures at  two facilities at the time of our review, one Forest Service facility had  not yet implemented a recommendation (to secure its entrance doors)  that was identified in a 2013 security assessment (see bottom center  photo, fig. 3). This countermeasure remained open because facility  officials said they continued to explore alternatives to address the  recommendation.

Figure 3 shows examples of countermeasures not fully implemented at  selected facilities we visited.

During our site visits and discussions with facility staff, we found that  physical site limitations or other priorities can make it difficult for facility  managers to implement countermeasures. For example, a  countermeasure might involve correcting a clear zone violation—that is,  moving an object (such as a brick wall) a certain distance away from the  facility’s perimeter fence to prevent a potential intruder from using the  object to climb over the fence. However, when the object near the fence  is a building and the property outside of the fence is not federally owned  (see bottom right photo, fig. 3), it may not be cost effective to correct the  clear zone violation. In this situation, the agency bears the responsibility  for exploring ways to address the vulnerability. In following the ISC  Standard, as previously noted, managers are required to justify and  document why they could not implement recommended  countermeasures—what the ISC calls risk acceptance.

section_title: Conclusions
paragraphs: Selected agencies carry a great responsibility for protecting facilities that  support border protection activities, provide safe and efficient air traffic  around the country, and protect the quality of the nation’s food supply.  With this responsibility comes the need to appropriately assess risk to  ensure the security of these agencies’ facilities. However, 7 years after  the ISC issued its initial risk-management process standard, each of four  selected agencies continued to use assessment methodologies that did  not fully align with this standard. During our review, agencies improved  their methodologies to better align with the ISC Standard, but the  agencies had not yet incorporated the methodologies into their policies  and procedures. Without updated policies and procedures requiring a  methodology that adheres to the ISC Standard (including all 33  undesirable events now identified in the November 2016 revision to the  ISC Standard), agencies may not collect the information needed to  assess risk and determine priorities for improved security. This situation  could hamper the agencies’ ability to make informed resource allocation  decisions or to recommend countermeasures commensurate to the needs  at specific facilities. To address challenges in conducting timely  assessments, agencies that had a backlog developed plans to address  them, but the assumptions used in CBP’s plans and time frames did not  appear to fully reflect the agency’s competing priorities and actual  experience. Additionally, ARS and Forest Service have not implemented  a long-term assessment schedule with key milestones to ensure that  higher-level facilities are reassessed at least once every 3 years. Further,  in cases where the agencies may have had risk assessment information,  CBP, ARS, and the Forest Service lack the means to collect, store, and  analyze this information in order to monitor the status of a facility’s  security. Without these key aspects of a comprehensive security  program—a methodology that meets the standard, policies, and  procedures that incorporate that methodology; the ability to complete  assessments on time; and information to perform monitoring—agencies  remain vulnerable to substantial security risks.

section_title: Recommendations for Executive Action
paragraphs: To improve agencies’ physical security programs’ alignment with the ISC  Risk Management Process for Federal Facilities and Standards for  Internal Control in the Federal Government for information and  monitoring, we recommend that the   Commissioner of U.S. Customs and Border Protection take the following  three actions: with regard to the updated Security Policy and Procedures Handbook,  the ISC’s Risk Management Process for Federal Facilities  requirement to assess all undesirable events, consider all three  factors of risk, and document deviations from the standard, and data collection and analysis requirements for monitoring the  performance of CBP’s physical security program.  revise the assumptions used in the plan to address the backlog to  balance assessments with competing priorities, such as updating the  policy manual and reviewing new construction design, to develop a  feasible time frame for completing the assessment backlog.

Secretary of Transportation direct the FAA Administrator to take the  following three actions: develop a plan that provides sufficient details on the activities needed  and time frames within the date when FAA will implement an  improved methodology; update FAA’s policy to require the use of a methodology that fully  aligns with the ISC’s Risk Management Process for Federal Facilities  for assessing all undesirable events, considering all three factors of  risk, and documenting all deviations from the standard  countermeasures; and update FAA’s policy to include ongoing monitoring of physical security  information.

Secretary of Agriculture take the following two actions:  include data collection and analysis requirements for monitoring the  performance of agencies’ physical security programs, in the  department’s revised physical-security manual, and direct the Administrator of the Agricultural Research Service and the  Chief of the Forest Service to  implement and monitor a long-term assessment schedule with key  milestones to ensure that higher-level facilities are reassessed at  least once every 3 years.

section_title: Agency Comments
paragraphs: We provided a draft of this report to the Departments of Homeland  Security, Transportation, and Agriculture for review and comment. All  three departments agreed with the findings and recommendations for  their respective agencies. DHS agreed with our recommendations and  provided actions and timeframes for completion. With regard to our  recommendation to update the Security Policy and Procedures  Handbook, DHS stated that CBP is updating the handbook to include: (1)  a discussion and diagram of the ISC risk management process and its  application within CBP’s assessment processes; (2) specific guidance for  conducting risk assessments in accordance with the ISC’s Risk  Management Process for Federal Facilities; and (3) a requirement and  guidance for data collection and analysis in support of a robust physical  security program. With regard to our recommendation to revise the  assumptions used in the plan to address the assessment backlog, DHS  stated that CBP has reevaluated current priorities and believes the  current plan to eliminate the risk assessment backlog by the end of fiscal  year 2018 is achievable. DHS also provided technical comments, which  we incorporated as appropriate. DHS’s official written response is  reprinted in appendix IV.

DOT also agreed with our recommendations and by e-mail requested that  we publish the response to the sensitive version of this report. DOT  stated that FAA continues to refine its policy and develop processes that  address the ISC threats, vulnerabilities, and consequences. Further, DOT  stated that FAA would either validate that current mitigation strategies  address those risks or apply additional appropriate countermeasures.  DOT stated that it will provide a detailed response to each  recommendation within 60 days from the date of this report. DOT’s official  written response is reprinted in appendix V.

USDA agreed with our recommendations and provided the agency-wide  actions for completion. USDA provided a plan to ensure compliance with  the ISC’s Risk Management Process for Federal Facilities by  development of a standard physical-security assessment process and by  initiation of a compliance program to track assessments and monitor the  installation of countermeasures. In an e-mail, USDA provided milestone  dates and planned completion by January 2019. USDA’s official written  response is reprinted in appendix VI.

If you or your staff has any questions about this report, please contact me  at (202) 512-2834 or RectanusL@gao.gov. GAO staff who made key  contributions to this report are listed in appendix VI.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines: (1) how selected agencies’ assessment  methodologies align with the Interagency Security Committee’s (ISC) risk  management standard for identifying necessary countermeasures and (2)  what management challenges, if any, selected agencies reported facing  in conducting physical security assessments and monitoring the results.

To determine how selected agencies’ assessment methodologies align  with ISC standards for identifying the necessary countermeasures, we  identified federal executive branch departments and agencies reported by  the Department of Homeland Security (DHS) to have received  delegations of authority to protect their own buildings. We reviewed the  Federal Real Property Council’s data on the Federal Real Property Profile  to identify federally owned and agency-controlled buildings. We  determined that these data were sufficiently reliable for the purpose of our  reporting objectives based upon our recent report that reviewed these  data fields. We selected four agencies based upon their large quantity of  reported federally owned and agency-controlled buildings: DHS, U.S.  Customs and Border Protection (CBP); Department of Transportation  (DOT), Federal Aviation Administration (FAA); United States Department  of Agriculture (USDA), Agricultural Research Service (ARS) and USDA’s  United States Forest Service (Forest Service). This methodology  purposely does not include federal buildings protected by FPS and under  the control of the General Services Administration as well as other  agencies that we reported on in our previous work. We obtained and  reviewed one particular ISC standard, The Risk Management Process for  Federal Facilities (the ISC Standard) and its related appendices for  assessing physical security and providing recommended  countermeasures at federal facilities. We obtained and analyzed the  selected departments’ and agencies’ facility-security policies and  procedures for a risk assessment methodology. According to the ISC  Standard, agencies’ risk assessment methodologies must:  consider all of the undesirable events identified in the ISC Standard  as possible risks to federal facilities as listed in appendix III; assess the threat, consequences, and vulnerability to specific produce similar or identical results when applied by various security provide sufficient justification for deviations from the ISC-defined  security baseline.

We limited the scope of this review to the first two standards above  because agencies’ adherence to these standards could be objectively  verified by reviewing and analyzing agency documentation and  interviewing agency officials, and their adherence to the two additional  standards could not be verified in this manner. We did not conduct risk  assessments with independent security professionals to evaluate: 1) the  results from prior agency evaluations and 2) the sufficiency of  justifications for deviations from the ISC-defined security baseline, as  both evaluations were outside of the scope of the engagement.  Therefore, for the purposes of this report, risk assessment policies,  procedures and resulting methodology that align with ISC standards are  those that consider all of the undesirable events and assess the threats,  consequences, and vulnerabilities to specific undesirable events. We  reviewed and analyzed information to answer the following five questions:  1.   Do the policies and procedures mention the ISC standards?  2.  Do the policies and procedures consider all of the undesirable  events?  3.  Do the policies and procedures assess the threat of specific  undesirable events?  4.  Do the policies and procedures assess the consequences of specific  undesirable events?  5.  Do the policies and procedures assess the vulnerability to specific  undesirable events?

We answered each of these questions as either a “Yes” or “No” for our  selected agencies. The “No” answer to questions 3, 4, and 5 includes the  following two possibilities: (a) the agency’s threat, consequence, or  vulnerability ratings are not tied to specific undesirable events, or (b) the  agency does not have a framework or formalized steps within which it  collects and analyzes threat-, consequence-, or vulnerability-related  information. If the answer to each of the five questions was “Yes,” then  the agency’s overall risk assessment methodology aligns with ISC risk  assessment standards for the purposes of this report. If the answer to one  or more of the five questions was “No”, then the agency’s methodology  does not to align with ISC standards for the purposes of this report.

We interviewed security officials at ISC; three departments (DHS, DOT,  and USDA); and four agencies (CBP, FAA, ARS, and the Forest Service).  We obtained and analyzed agency guidance on prioritizing physical  security needs and interviewed agencies’ facility maintenance and budget  officials. We reviewed the ISC’s best practices for planning for physical  security resources within an agency budget process. Additionally, we  reviewed the Office of Management and Budget’s and our leading  practices in capital decision-making that provide agencies with guidance  for prioritizing budget decisions such as “countermeasure projects.” We  also reviewed Standards for Internal Control in the Federal Government  because internal controls play a significant role in helping agencies  achieve their mission-related responsibilities. Our findings from our  review of the selected agencies are not generalizable to all ISC member  agencies, but provide insight into and illustrative examples about selected  agencies’ facility risk-assessment methodologies.

To determine what management challenges selected agencies reported  facing in conducting physical security assessments and monitoring  results, we interviewed agencies’ security, maintenance, and budget  officials. We requested agency security officials to provide portfolio- wide  data on facility security assessments for our review in order to select sites  to visit and analyze data for dates of assessments and the status of  findings. We assessed the reliability of this data through interviews with  knowledgeable agency staff and a review for completeness and any  unexpected values. We compiled information from physical security  assessments when no portfolio-wide agency data were available. We  determined that these data were sufficient for the purpose of our reporting  objectives and selected geographically dispersed sites with buildings with  higher reported security levels per the ISC Standard, as these higher  security levels have greater requirements and therefore the potential for  greater resource needs. See appendix II for the 13 sites we selected. For  these selected sites, we interviewed agency staff concerning the  assessment process, site-specific findings, recommendations, justification  for deviations from ISC’s baseline standards, and management  challenges faced in addressing physical security needs. We observed  and photographed the status of the findings from the site physical security  assessments. We did not independently determine what constitutes a  management challenge or a physical security finding. Rather, we relied  on these stakeholders to determine these physical security concerns as  defined in their own standards and guidance. The information from our  selected sites is illustrative and cannot be generalized to sites agency- wide.

The performance audit upon which this report is based was conducted  from June 2016 to August 2017 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. We  subsequently worked with DHS, DOT and USDA from August 2017 to  October 2017 to prepare this version of the original report for public  release. This public version was also prepared in accordance with these  standards.

section_title: Appendix II: Selected Facilities GAO Visited

section_title: Appendix III: The Interagency Security Committee’s Undesirable Events

section_title: Appendix IV: Comments from the Department of Homeland Security

section_title: Appendix V: Comments from the Department of Transportation
paragraphs: Error! No text of specified style in document.

section_title: Appendix VI: Comments from the Department of Agriculture
paragraphs: Error! No text of specified style in document.

section_title: Appendix VII: GAO Contact and Staff Acknowledgments
paragraphs: Appendix VII: GAO Contact and Staff  Acknowledgments Error! No text of specified style in document.
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Amelia Shachoy (Assistant  Director), Steve Martinez (Analyst-in-Charge), Jennifer Clayborne,  George Depaoli, Geoffrey Hamilton, Joshua Ormond, Alison Snyder,  Amelia Michelle Weathers, and Elizabeth Wood made key contributions  to this report.


Question-summary annotations: questions: question: What did GAO's review of the CBP, FAA, ARS, and the Forest Service reveal?
answer: None of the four agencies GAO reviewed—U.S. Customs and Border Protection (CBP), the Federal Aviation Administration (FAA), the Agricultural Research Service (ARS), and the Forest Service—used security assessment methodologies that fully aligned with the Interagency Security Committee's Risk Management Process for Federal Facilities standard (the ISC Standard).
child_questions: question: What does the ISC Standard require?
answer: This standard requires that methodologies used to identify necessary facility countermeasures—such as fences and closed-circuit televisions—must:

questions: question: How are the four agencies' methodologies similar?
answer: All four agencies used methodologies that included some ISC requirements when conducting assessments.
child_questions: question: How do the four agencies' methodologies differ?
answer: CBP and FAA assessed vulnerabilities but not threats and consequences. ARS and the Forest Service assessed threats, vulnerabilities, and consequences, but did not use these factors to measure risk. In addition, the agencies considered many, but not all 33 undesirable events related to physical security as possible risks to their facilities.

question: What steps are agencies taking to improve their methodologies?
answer: Agencies are taking steps to improve their methodologies. For example, ARS and the Forest Service now use a methodology that measures risk and plan to incorporate the methodology into policy.
child_questions: question: Despite improvements, what issues still exist?
answer: Although CBP and FAA have updated their methodologies, their policies do not require methodologies that fully align with the ISC standard. As a result, these agencies miss the opportunity for a more informed assessment of the risk to their facilities.

questions: question: What did all four agencies report facing challenges in?
answer: All four agencies reported facing management challenges in conducting physical security assessments or monitoring assessment results.
child_questions: question: How does the data GAO analyzed support this?
answer: Specifically, CBP, ARS, and the Forest Service have not met the ISC's required time frame of every 3 years for conducting assessments. For example, security specialists have not conducted required reassessments of two ARS and one Forest Service higher-level facilities.

question: How is this demonstrated by the agencies' plans to address backlogs?
answer: While these three agencies have plans to address backlogs, CBP's plan does not balance conducting risk assessments with other competing security priorities, such as updating its policy manual, and ARS and the Forest Service lack a means to monitor completion of future assessments.

question: How is this issue exacerbated by the agencies' lack of data or information systems?
answer: Furthermore, CBP, ARS, and the Forest Service did not have the data or information systems to monitor assessment schedules or the status of countermeasures at facilities, and their policies did not specify such data requirements. For example, ARS and the Forest Service do not collect and analyze security-related data, such as countermeasures' implementation. FAA does not routinely monitor the performance of its physical security program.
child_questions: question: What issues might a lack of monitoring cause?
answer: Without improved monitoring, agencies are not well equipped to prioritize their highest security needs, may leave facilities' vulnerabilities unaddressed, and may not take corrective actions to meet physical security program objectives.

question: How does this report differ from its sensitive counterpart?
answer: This is a public version of a sensitive report that GAO issued in August 2017. Information that the agencies under review deemed sensitive has been omitted.