As of March 1, 2003, INS ceased to exist as an agency. It is now in the process of being incorporated into DHS. INS’s multi-faceted mission includes securing the borders; enforcing immigration laws; and providing immigration services, such as work permits, naturalization, and asylum. Under DHS, the INS mission has been split between three bureaus within the department, and the INS procurement organization will continue to procure goods and services under the Bureau of Immigration and Customs Enforcement. In fiscal year 2002, INS contracted for $1.7 billion in goods and services. The headquarters procurement office is responsible for procuring information technology, as well as goods and services of a general nature that are used agencywide. DHS continues to operate the three INS administrative centers (Dallas, Texas; Laguna Niguel, California; and Burlington, Vermont) that were formerly a part of INS. The administrative centers have responsibility for awarding and managing INS’s detention center management contracts and contracts for goods and services for INS field offices. Figure 1 shows the breakdown of procurement responsibility between INS headquarters and the administrative centers in fiscal year 2002. INS also has more than 600 field offices across the United States. The field offices’ authority to award contracts is generally limited to $25,000 for open market purchases and $100,000 for delivery orders against existing contracts. Field office contract obligations totaled $66.5 million in fiscal year 2002. DHS officials are currently working out the details of how to merge the procurement functions of the incoming agencies, including INS. A Chief Procurement Officer was recently appointed and will report to the Under Secretary for Management. In preparing to implement DHS-specific procurement policies, a working group is drafting a DHS supplement to the Federal Acquisition Regulation (FAR). DHS officials are currently assessing the incoming agencies’ (1) major procurements to determine whether duplication exists and to identify ways of maximizing the DHS’s purchasing power by consolidating like procurements where feasible; (2) procurement and financial systems to determine whether any of the existing systems are adequate to meet the department’s future needs; and (3) acquisition workforce to identify gaps and the need for DHS-specific training requirements. INS does not have in place a basic infrastructure to effectively manage its contracts. INS procurement managers lack leverage to ensure that employees comply with procurement policies, and managers cannot make strategic procurement decisions due to the absence of comprehensive and reliable information about the goods and services being procured across the agency. Further, INS’s acquisition workforce is not adequate to manage the agency’s increased mission requirements. INS has not developed a strategic acquisition workforce plan to help ensure that acquisition personnel across the agency have the right skills and that gaps in the workforce are addressed proactively. INS procurement managers have little oversight and control over procurement activities throughout the agency, a situation that increases the risk that taxpayers are not getting the best value for their dollars. Our prior work has identified a number of factors that promote efficient, effective, and accountable procurement. We found that successful, leading companies had reengineered their procurement practices to move from a fragmented approach to a more coordinated and strategically oriented approach. By elevating the procurement function in the structure of the organization and establishing strong oversight mechanisms, these companies were able to make and implement strategic decisions to improve companywide outcomes. In addition, the companies ensured that the procurement function was integrated across the organization through the use of cross-functional teams, consisting of procurement, program, and financial personnel. Responsibility for acquiring goods and services is dispersed throughout INS headquarters, administrative centers, and field offices. Headquarters procurement managers have responsibility for some agencywide functions, such as providing policy, overseeing compliance with procurement laws and regulations, and preparing required reports on agencywide procurement activities. These managers also review proposed administrative center contracts of more than $500,000. However, they have little insight into transactions conducted by INS’s field offices. Headquarters procurement managers were only able to provide us summary data for field office transactions, because they do not have information on the number and dollar amount of individual transactions. In addition, the headquarters procurement office is placed far down in the organizational structure, buried under several layers of management. This placement increases the likelihood that the procurement function will not receive attention from the highest levels of the organization. As illustrated in figure 2, the Bureau Procurement Chief reports at a lower organizational level than Files and Forms Management. At the administrative centers, the procurement function is combined with property management. INS headquarters procurement managers lack the leverage to ensure that administrative center and field office contracting personnel follow INS procurement directives and policies. While contracting officers in these offices derive their contracting authority from headquarters, they report through the administrative center or field office chain of command, not to headquarters procurement managers. This situation has been especially problematic in the field offices, which rely heavily on “collateral duty” contracting officers who perform contracting duties in addition to their mission-related responsibilities and who are not career contracting officers. The performance appraisals of the collateral duty contracting officers reflect only their mission-related duties and do not address their procurement activities. For example, the performance rating of a Border Patrol agent, who is a collateral duty contracting officer, is based on whether he accomplishes the Border Patrol’s mission and does not take into account whether he follows INS’s procurement procedures. Further, according to the Assistant Commissioner for Administration, the procurement office has little leverage to stop employees from entering into unauthorized commitments. In fiscal year 2002, INS had 60 unauthorized commitments valued at more than $700,000. For example, an employee arranged for a vendor to conduct a training class without first contacting the procurement office to award a contract for this service, for which INS ended up paying $15,800. In another case, an employee asked a subcontractor to provide $3,181 in computer upgrade services. While these services may have been necessary, only warranted contracting officers have authority to enter into and modify contracts with vendors. Unauthorized commitments are counterproductive in that they require additional time and effort from procurement personnel to ratify the commitments and to work with the parties involved to avoid future occurrences. Procurement officials have attempted to educate and train employees about proper procedures, but the officials expressed frustration that unauthorized commitments continue to occur. INS has made limited use of internal controls, such as internal reviews and performance goals and measures, that could help monitor procurement activity across the agency. For example, while some officials said that the Office of Internal Audit’s periodic reviews are helpful in identifying problem areas, others noted that these reviews are not thorough or frequent enough (each office is scheduled for review once every 3 years). In addition, while headquarters and administrative centers established performance goals and measures to help evaluate the effectiveness of the procurement function, these efforts have not been effective. A consulting firm helped the INS headquarters procurement office set goals, such as obligating funds in a timely manner; providing clear, consistent customer guidance; maximizing private and public sector resources; and complying with statutory requirements. Similarly, the administrative centers attempted to standardize processes and establish time frames for various procurement services. However, INS headquarters officials told us that they were unable to monitor whether they achieved their goals because the data and analyses necessary to track progress were unavailable. Administrative center procurement managers said that the time frames they were given were not meaningful, as the targets set were very low. Further, INS has not made effective use of cross-functional teams— consisting of procurement, program, legal, budget, and financial representatives—throughout the acquisition process. Stakeholders outside of the procurement offices are often involved only on an ad hoc basis. Personnel across the agency told us that the relationship between program and procurement officials has been particularly problematic and that these offices often have not worked collaboratively to define project requirements and perform other acquisition-related functions. In fact, in some cases, the relationship has been adversarial. One INS procurement official said the program offices sometimes “throw the requirements over the transom,” leaving the procurement office to try to meet the program office’s needs in a vacuum. Procurement managers said that they have difficulty getting program offices to comply with procurement requirements such as planning acquisitions, monitoring contractor performance, and attending required training. Some managers attributed the problem to INS’s culture, where program offices have traditionally been highly independent. On the other hand, program officials stated that procurement personnel are not customer-oriented or proactive in finding ways to meet program needs. Program officials said that they are unsure of their roles and responsibilities in the procurement process and that they lack needed procurement guidance. For example, one program manager said that procurement personnel expect her office to choose a contract type or to complete independently contracting-related paperwork. She believes this responsibility is best left to personnel with procurement expertise. INS managers are unable to make strategic procurement decisions because they do not have sufficient information about the goods and services being procured across the agency and who their major vendors are. In the past, we have reported that when leading companies obtain improved knowledge about the goods and services that are being procured, these companies can create significant cost savings and service improvements. Agencies need the capability to analyze how much is being spent on each good and service—through the use of interfaced procurement and financial systems—so the agencies can identify opportunities to reduce costs, improve service, and better manage their suppliers. INS procurement personnel primarily use two mechanisms to collect procurement data. The Intelligent Procurement System (IPRO) is an automated system used to generate solicitation and contract documents and to track basic procurement data such as requisition numbers, obligations, date of contract awards, and the amount of time to process requisitions. Procurement personnel also use a variety of informal data collection tools—including manual entry logbooks, spreadsheets, and stand-alone databases—to track administrative information, such as contract status, and to provide data to the Federal Procurement Data System. However, the data collected through these means are not comprehensive or reliable.