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Homeland Security: DHS's Chemical, Biological, Radiological, Nuclear and Explosives Program Consolidation Proposal Could Better Consider Benefits and Limitations

GAO-16-603 Published: Aug 11, 2016. Publicly Released: Sep 12, 2016.
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Highlights

What GAO Found

The Department of Homeland Security's (DHS) documentation related to its proposed consolidation of Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) programs offers some insights into benefits and limitations considered, but the information provided to GAO did not include several key factors to consider when evaluating an organizational consolidation. While developing its consolidation plan, DHS identified strategic goals, such as eight near-term goals to be achieved within the first two years. DHS also considered problems its consolidation is intended to solve, including providing a clearer focal point for external and DHS component engagement on CBRNE issues. However, DHS:

  • Did not fully assess and document potential problems that could result from consolidation.
  • Did not include a comparison of benefits and costs.
  • Conducted limited external stakeholder outreach in developing the consolidation proposal and thus the proposal may not sufficiently account for stakeholder concerns.

Attention to the these key areas, identified from GAO's analysis of previous organizational consolidations, would help provide DHS, Congress, and other stakeholders with assurance that important aspects of effective organizational change are addressed as part of the agency's CBRNE reorganization decision-making process.

Key mergers and organizational transformation practices identified in previous GAO work could benefit DHS if Congress approves the proposed CBRNE consolidation. GAO reported in July 2003 on key practices and implementation steps for mergers and organizational transformations that range from ensuring top leadership drives the transformation to involving employees in the implementation process to obtain their ideas and gain their ownership for the transformation. In addition, the practices would be helpful in a consolidated CBRNE environment. For example, overall employee morale differs among the components to be consolidated, making the key practice of employee involvement to gain their ownership for the transformation a crucial step. Also, given the wide range of activities conducted by the consolidated entities, the key practice of establishing a coherent mission and integrated strategic goals to guide the transformation will be important. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it, and, as of June 2016, Congress had not approved DHS's consolidation proposal. However, should DHS receive this approval, consulting GAO's key practices would help ensure that lessons learned from other organizations are considered.

Why GAO Did This Study

Committee reports accompanying the Consolidated and Further Continuing Appropriations Act, 2013, directed DHS to undertake an in-depth review of the department's weapons of mass destruction programs, including potential consolidation of CBRNE mission functions. DHS conducted its review, and in June 2015 provided a report to Congress, including a proposal to consolidate the agency's core CBRNE functions. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it.

GAO was asked to review the proposed consolidation of DHS's CBRNE programs. This report discusses: (1) the extent to which DHS's proposal assessed the benefits and limitations of consolidation and (2) GAO's key practices from past organizational transformations that could benefit DHS, should Congress approve the proposed consolidation.

Recommendations

GAO recommends that DHS complete, document, and make available analyses associated with identifying: (1) unintended problems, if any, that consolidation may create; (2) a comparison of the consolidation's benefits and costs; and (3) a broader range of external stakeholder input. Although DHS did not concur, GAO continues to believe that findings documented in the report support the recommendation. DHS concurred with GAO's additional recommendation that should Congress approve DHS's plan, the department use key mergers and organizational transformation practices identified in previous GAO work.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Homeland Security To better provide Congress and affected stakeholders with assurance that important aspects of effective organizational change are addressed as part of the agency's chemical, biological, radiological, nuclear and explosives (CBRNE) reorganization decision-making process, the Secretary of Homeland Security should direct the Assistant Secretary for the Office of Policy to complete, document, and make available analyses of key questions related to its consolidation proposal, including: (1) what problems, if any, consolidation may create; (2) a comparison of the benefits and costs the consolidation may entail; and (3) a broader range of external stakeholder input including a discussion of how it was obtained and considered.
Closed – Not Implemented
We found that the Department of Homeland Security's (DHS) documentation related to its proposed consolidation of Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) programs offers some insights into benefits and limitations considered, but the information provided to GAO did not include several key factors to consider when evaluating an organizational consolidation. Specifically, DHS did not fully assess and document potential problems that could result from consolidation; did not include a comparison of benefits and costs; and conducted limited external stakeholder outreach in developing the consolidation proposal. As a result, we recommended that DHS complete, document, and make available analyses associated with identifying: (1) unintended problems, if any, that consolidation may create; (2) a comparison of the consolidation's benefits and costs; and (3) a broader range of external stakeholder input. DHS did not concur with this recommendation and, in November 2016 correspondence, stated that DHS continues to consider this recommendation resolved and that addressing the recommendation would be duplicative, unnecessary, and potentially disruptive to ongoing deliberations. However, we continue to believe that considering the key factors we identified in our report as part of the decision-making process for potential organizational consolidation is important as it would provide Congress and the executive branch the information needed to help effectively evaluate how the proposal will lead to an integrated, high-performance organization.
Department of Homeland Security If DHS's proposed CBRNE program consolidation is approved by Congress, the Secretary of Homeland Security should direct the Assistant Secretary for the Office of Policy to use, where appropriate, the key mergers and organizational transformation practices identified in our previous work to help ensure that a CBRNE consolidated office benefits from lessons learned from other organizational transformations.
Closed – Implemented
We found that key mergers and organizational transformation practices identified in our previous work could benefit DHS if Congress approved the proposed CBRNE consolidation. We reported in July 2003 on key practices and implementation steps for mergers and organizational transformations that range from ensuring top leadership drives the transformation to involving employees in the implementation process to obtain their ideas and gain their ownership for the transformation. In addition, we found that the practices would be helpful in a consolidated CBRNE environment. Therefore, we recommended that DHS, where appropriate, use the key mergers and organizational transformation practices to help ensure that a CBRNE consolidated office benefits from lessons learned from other organizational transformations. In December 2018, Congress authorized the consolidation via the Countering Weapons of Mass Destruction Act, which moved CBRNE offices into a new entity called the Countering Weapons of Mass Destruction Office (CWMD). In response to our recommendation, DHS notified Congress in October 2017 that it planned to determine where to apply our key mergers and organizational transformation practices to the CWMD reorganization. Subsequently, CWMD officials provided us with documentation demonstrating how the practices were considered. For example, to address the practice of involving employees to obtain their ideas and gain their ownership for the transformation, CWMD required all staff employed by the CWMD to participate in the transition by joining at least one related working group. At least 17 employee working groups were created to gather employee perspectives on the reorganization, according to CWMD documentation. For the practice of dedicating an implementation team to manage the consolidation process, CWMD launched a leadership team in January 2018 tasked with overall reorganization strategy, among other things. In another example, for the practice of establishing a communication strategy to create shared expectations and report related progress, CWMD created an internal communications strategy early in the reorganization process and implemented it via various outreach mechanisms to employees. These actions are consistent with our recommendation. However, despite considering our key practices, significant challenges remain at the CWMD office, such as low employee morale and questions about the efficacy of some CWMD programs. As of November 2020, we are evaluating these issues as part of ongoing work.

Full Report

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Christopher P. Currie
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Topics

Biological weaponsChemical weaponsDecision makingDocumentationExplosivesFederal agency reorganizationLessons learnedNuclear weaponsRadiological warfareStrategic planningWeapons of mass destruction