Countering Overseas Threats: Gaps in State Department Management of Security Training May Increase Risk to U.S. Personnel
GAO-14-360
Published: Mar 10, 2014. Publicly Released: Mar 10, 2014.
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Highlights
What GAO Found
Using data from multiple sources, GAO determined that 675 of 708 Department of State (State) personnel and all 143 U.S. Agency for International Development (USAID) personnel on assignments longer than 6 months (assigned personnel) in the designated high-threat countries on March 31, 2013, were in compliance with the Foreign Affairs Counter Threat (FACT) training requirement. GAO found that the remaining 33 State assigned personnel on such assignments had not complied with the mandatory requirement. For State and USAID personnel on temporary duty of 6 months or less (short-term TDY personnel), GAO was unable to assess compliance because of gaps in State's data. State does not systematically maintain data on the universe of U.S. personnel on short-term TDY status to designated high-threat countries who were required to complete FACT training. This is because State lacks a mechanism for identifying those who are subject to the training requirement. These data gaps prevent State or an independent reviewer from assessing compliance with the FACT training requirement among short-term TDY personnel. According to Standards for Internal Control in the Federal Government , program managers need operating information to determine whether they are meeting compliance requirements.
State's guidance and management oversight of personnel's compliance with the FACT training requirement have weaknesses that limit State's ability to ensure that personnel are prepared for service in designated high-threat countries. These weaknesses include the following:
- State's policy and guidance related to FACT training—including its Foreign Affairs Manual , eCountry Clearance instructions for short-term TDY personnel, and guidance on the required frequency of FACT training—are outdated, inconsistent, or unclear. For example, although State informed other agencies of June 2013 policy changes to the FACT training requirement, State had not yet updated its Foreign Affairs Manual to reflect those changes as of January 2014. The changes included an increase in the number of high-threat countries requiring FACT training from 9 to 18.
- State and USAID do not consistently verify that U.S. personnel complete FACT training before arriving in designated high-threat countries. For example, State does not verify compliance for 4 of the 9 countries for which it required FACT training before June 2013.
- State does not monitor or evaluate overall levels of compliance with the FACT training requirement.
State's Foreign Affairs Manual notes that it is the responsibility of employees to ensure their own compliance with the FACT training requirement. However, the manual and Standards for Internal Control in the Federal Government also note that management is responsible for putting in place adequate controls to help ensure that agency directives are carried out. The gaps in State oversight may increase the risk that personnel assigned to high-threat countries do not complete FACT training, potentially placing their own and others' safety in jeopardy.
Why GAO Did This Study
U.S personnel engaged in efforts overseas have faced numerous threats to their security. To mitigate these threats and prepare U.S. personnel for work in high-threat environments, State established a mandatory requirement that specified U.S. executive branch personnel under chief-of-mission authority and on assignments or short-term TDY complete FACT security training before arrival in a high-threat environment. This report examines (1) State and USAID personnel's compliance with the FACT training requirement and (2) State's and USAID's oversight of their personnel's compliance. GAO reviewed agencies' policy guidance; analyzed State and USAID personnel data from March 2013 and training data for 2008 through 2013; reviewed agency documents; and interviewed agency officials in Washington, D.C., and at various overseas locations. This public version of a February 2014 sensitive report excludes information that State has deemed sensitive.
Recommendations
GAO is making several recommen-dations to improve oversight of compliance with the FACT training requirement. These include identifying a mechanism to readily determine the universe of U.S. personnel subject to the requirement, updating State's policy manual to reflect changes made to the requirement in June 2013, consistently verifying that all U.S. civilian personnel have completed FACT training before arriving in designated high-threat countries, and monitoring compliance with the requirement. State concurred with the recommendations and stated that it will take steps to address them. USAID did not specifically agree or disagree but noted it plans to take additional steps.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of State | To ensure that State's policy guidance reflects the June 2013 mandatory FACT training requirements and provides clear information to U.S. agencies on which personnel are required to take FACT training, the Secretary of State should update the Foreign Affairs Manual to reflect the nine additional countries that were added in June 2013. |
In April 2014, State updated the FAM, noting that the list of posts currently designated as high-threat is maintained by the Bureau of Diplomatic Security and that personnel should contact their human resources assignments officer or check with their bureau's executive directorate for current high-threat posts subject to mandatory FACT training.
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| Department of State | To ensure that State's policy guidance reflects the June 2013 mandatory FACT training requirements and provides clear information to U.S. agencies on which personnel are required to take FACT training, the Secretary of States should update the Foreign Affairs Manual to reflect the requirement for all eligible family members assigned or on short-term TDY to the designated high-threat countries to complete FACT training before deployment. |
The State Department concurred with our recommendation and issued a memorandum in July 2014 that updated FACT training requirements. In this memorandum, State specified the conditions that indicate whether eligible family members must complete the course. For example, eligible family members who were offered employment before arriving at post are required to complete FACT training. Further, in September 2015, State updated the FAM to clarify, among other things, the FACT training requirement for eligible family members. Specifically, the revised FAM clarified that the requirements for FACT certification apply to both employees and employed eligible family members assigned to a FACT-mandatory post.
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| Department of State | To ensure that State's policy guidance reflects the June 2013 mandatory FACT training requirements and provides clear information to U.S. agencies on which personnel are required to take FACT training, the Secretary of State should update the Foreign Affairs Manual to indicate that short-term TDY personnel who spend more than 45 cumulative days in a calendar year at one or more of the designated posts are required to complete FACT training. |
In April 2014, State updated the FAM, noting that all personnel under chief of mission authority or who will be present at one or a combination of high-threat posts for more than 45 cumulative days in a calendar year are required to take FACT training.
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| Department of State | To ensure that State's policy guidance reflects the June 2013 mandatory FACT training requirements and provides clear information to U.S. agencies on which personnel are required to take FACT training, the Secretary of State should update the Foreign Affairs Manual to clarify whether FACT training completion must be valid during an employee's entire assignment or short-term TDY visit. |
State concurred with our recommendation. In response, in July 2014, State issued a guidance memorandum that described the length of validity for FACT training. Specifically, the new policy guidance states that, ?employees or employed eligible family members (EFMs) assigned to a FACT-mandatory post will be required to have a certificate valid at minimum through the date of arrival at post for their tour of duty. Employees and employed EFMs are strongly encouraged to ensure their certificate is valid through the tour of duty.? Additionally, the new policy guidance further clarifies that employees with FACT certification expiring before arrival to post are required to take FACT as well as individuals whose FACT training expires while at post, if she or he has 180 days left at post. Further, in September 2015, State updated the FAM to clarify, among other things, the length of validity for a FACT training completion certificate. The changes clarified that employees and employed eligible family members assigned to a FACT-mandatory post must have a FACT certificate that is valid through their date of arrival at post, and if their FACT certification expires during their tour of duty and they have at least 180 days remaining in their assignment, they must complete FACT training during their next official travel to Washington, D.C.
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| Department of State |
Priority Rec.
To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should identify a mechanism to readily determine the universe of assigned U.S. civilian personnel under chief-of-mission authority who are required to complete FACT training. |
At the time of our report, FACT training was required for selected high-threat posts, and State had difficulty readily determining the universe of assigned personnel who were required to complete FACT training. State fundamentally concurred with GAO's recommendation. In responding to our recommendation, State updated its policy guidance regarding FACT training requirements, contained within its Foreign Affairs Manual. As a result State has improved State's visibility into the universe of U.S. assigned personnel who are required to complete FACT training.
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| Department of State | To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should identify a mechanism to readily determine the universe of short-term TDY U.S. civilian personnel who are required to complete FACT training--specifically, required personnel who have spent 45 days or more in the designated high-threat countries in a calendar year. |
State concurred with the recommendation and stated that it will take steps to address it. In response to GAO's recommendation, as of March 2015, State took several steps to update the current electronic Country Clearance (eCC) application to readily determine the universe of short-term TDY personnel who are required to complete FACT training. For instance, the eCC system requires personnel traveling to High Threat, High Risk Posts to certify FACT training, with radio buttons for the following: (1) whether the stay is greater than 45 days; (2) whether the traveler has spent more than 45 total days at a High Threat, High Risk Post within the last 365-days; and (3) whether the traveler has completed FACT. If the eCC user responds that the traveler has not taken FACT, he or she must provide a justification.
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| Department of State | To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should ensure that eCountry Clearance instructions regarding the documentation of the FACT training requirement for short-term TDY personnel are consistent for all designated high-threat countries. |
State agreed with the recommendation, and on July 7, 2014--subsequent to our report issuance and addressing this recommendation --State issued a memo to all agencies that now requires FACT completion dates to be included on the eCC for approval prior to travel to post. Further, as of March 2015, State has taken steps to update the current eCC application to ensure consistent instructions. For instance, the eCC system requires personnel traveling to High Threat, High Risk Posts to certify whether they have completed FACT and to provide the completion date. When the eCC user enters this information, he or she is prompted with a box that instructs him or her to "provide documentation of FACT Training (e.g. Certificate) upon arrival at Post" and to click OK to continue.
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| Department of State |
Priority Rec.
To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should take steps to ensure that management personnel responsible for assigning personnel to designated high-threat countries consistently verify that all assigned U.S. civilian personnel under chief-of-mission authority who are required to complete FACT training have completed it before arrival in the designated high-threat countries. |
State concurred with this recommendation. In response, in 2014, State issued a memo to all agencies that states that it is the responsibility of each agency to ensure its employees are in compliance with FACT training requirements prior to travel to the relevant posts. The memo also required employees to provide a FACT completion certificate to posts upon request. In 2016, State officials reported that State had developed an internal site to allow designated users to verify FACT training completion for State personnel. However, in November 2017, State officials told us that State had discontinued this effort because the internal site was not being used or maintained. In early 2020, State issued revised guidance to management personnel regarding their responsibility for ensuring personnel who are required to complete FACT training have completed it before arrival at their assigned posts. State also developed tools to help management personnel fulfill this responsibility, including a compliance report and checklist. Taken together, these steps help ensure personnel have taken the required FACT training and are better prepared to face threats
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| Department of State |
Priority Rec.
To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should take steps to ensure that management personnel responsible for granting country clearance consistently verify that all short-term TDY U.S. civilian personnel under chief-of-mission authority who are required to complete FACT training have completed it before arrival in the designated high-threat countries. |
In response to GAO's recommendation, State has taken several steps to ensure that the electronic Country Clearance (eCC) is easier for personnel to use. For instance, State updated the current eCC to require personnel traveling to High Threat, High Risk Posts to certify FACT training, with radio buttons for the following: (1) whether the stay is greater than 45 days; (2) whether the traveler has spent more than 45 total days at a High Threat, High Risk Post within the last 365-days; and (3) whether the traveler has completed FACT. If the eCC user responds that the traveler has not taken FACT, he or she must provide a justification. In addition, the eCC system requires personnel traveling to High Threat, High Risk Posts to certify whether they have completed FACT and to provide the completion date. When the eCC user enters this information, he or she is prompted with a box that instructs him or her to "provide documentation of FACT Training (e.g. Certificate) upon arrival at Post" and to click OK to continue. As of November 2017, according to State officials, the agency is reinforcing this requirement by sending out an All Diplomatic and Consular Posts cable that will specifically state that whoever is responsible for granting country clearance to a short-term TDY employee is responsible for ensuring that the eCC request has a FACT training completion date as well as updating the travel information section of the eCC guidance on an annual basis.
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| Department of State |
Priority Rec.
To strengthen State's ability to ensure that U.S. civilian personnel are in compliance with the FACT training requirement, the Secretary of State should monitor or evaluate overall levels of compliance with the FACT training requirement among U.S. civilian personnel under chief-of-mission authority who are subject to the requirement. |
State concurred with this recommendation. In November 2017, State officials indicated that State plans to monitor and evaluate overall levels of compliance with the FACT training requirement through generating a report on an annual basis on assigned personnel's compliance with the requirement. In August 2019, State reported the department was developing a report that would allow management to monitor overall levels of compliance with the FACT requirement. State uses the report to inform routine internal meetings between the Bureau of Human Resources and the Bureau of Diplomatic Security on personnel compliance with the FACT requirement. In January 2020, State officials also briefed senior management officials on compliance. Taken together, these steps help ensure State management are monitoring the number of personnel overseas who are in compliance with FACT training requirements.
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| U.S. Agency for International Development | The USAID Administrator should take steps to ensure that all USAID short-term TDY personnel who are required to take FACT training complete the training before arrival in the designated high-threat countries, as USAID has done for its assigned personnel. |
In comments about a draft version of our report, USAID did not specifically agree or disagree with the recommendation but indicated that it planned to take some steps to assist employees in tracking their compliance with the requirement. Subsequently, in April 2015, USAID notified its direct-hire employees, including those on short-term TDY, that they are required to (1) self-certify in the eCountry Clearance system that they have completed mandatory personal security training before arrival at a designated high-threat post and (2) provide the respective training certificate with their travel authorizations in the E2 system.
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