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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Committee on Homeland Security, House of 
Representatives: 

July 2011: 

Federal Protective Service: 

Progress Made but Improved Schedule and Cost Estimate Needed to 
Complete Transition: 

GAO-11-554: 

GAO Highlights: 

Highlights of GAO-11-554, a report to the Ranking Member, Committee on 
Homeland Security, House of Representatives. 

Why GAO Did This Study: 

Events such as the February 2010 attack on the Internal Revenue 
Service offices in Texas, and the shooting in the lobby of the Nevada 
federal courthouse, demonstrate the vulnerabilities of federal 
facilities and the safety of the federal employees who occupy them. 
The Federal Protective Service (FPS) is the primary agency responsible 
for the security of over 9,000 federal government facilities across 
the country. The fiscal year 2010 DHS appropriations act transferred 
FPS from Immigration and Customs Enforcement (ICE) to the National 
Protection and Programs Directorate (NPPD), within the Department of 
Homeland Security (DHS). This report addresses (1) the extent to which 
the FPS transition has been implemented and any remaining related 
challenges, and (2) the extent to which the transition will help 
address previously identified challenges to protecting federal 
facilities. GAO reviewed the 2009 FPS-NPPD transition plan; agreements 
between FPS, NPPD, and ICE, and best practices for scheduling and cost 
estimating; and interviewed DHS officials. 

What GAO Found: 

Since October 2009, FPS’s facility protection mission and 13 of 18 
mission-support functions have transferred from ICE to NPPD; however, 
the transition schedule for the 5 remaining mission-support functions 
has been delayed. For example, while functions such as human capital 
and budget formulation have been transferred, information technology 
(IT) services, business continuity and emergency preparedness, 
facilities, personnel security, and equal employment opportunity have 
not. In August 2009, DHS reported to Congress that the transition of 
these functions would be completed by October 2010. DHS now reports 
that it plans to complete the transfer of 4 of the 5 remaining mission-
support functions by September or October 2011, and estimates that the 
transfer of IT services will not be complete until October 2012. DHS 
developed a transition plan to guide the planning and execution of the 
transfer. Among other things, the plan called for schedules with 
detailed tasks and end dates to be developed for all mission-support 
functions to ensure critical path activities were identified, managed, 
and resourced. DHS also developed a detailed schedule to manage the 
transfer of IT services, as called for in the transition plan. 
However, GAO’s analysis of the schedule found that it did not reflect 
GAO’s best practices for scheduling such as capturing, sequencing, and 
assigning resources to all activities necessary to accomplish the 
work. When a schedule does not accurately reflect the project, it will 
not serve as an appropriate basis for analysis and may result in 
unreliable completion dates and delays. As of May 2011, DHS estimated 
that it would cost $6.2 million to complete the IT transition. GAO’s 
analysis of this cost estimate found it did not meet all the 
characteristics of a reliable cost estimate. For example, the estimate 
was not well documented because it was not supported by detailed 
explanation describing how the estimate was derived and did not 
include sufficient detail so that GAO could corroborate it. By 
incorporating cost estimation best practices for the IT transition 
cost estimate, DHS could enhance the estimate’s reliability and better 
inform decisions about the cost to complete the transition. 

The transfer of FPS to NPPD could provide DHS the opportunity to 
better advance progress towards addressing FPS’s challenges to 
protecting federal facilities that have been previously identified by 
GAO. Since 2007, GAO has reported that FPS faces significant 
challenges with protecting federal facilities. The transition plan 
noted that the transfer of FPS to NPPD would improve the mission 
effectiveness of both agencies. NPPD officials explained that the 
agency has undertaken actions that serve as a foundation for 
integrating FPS into NPPD. For example, FPS has begun to develop a new 
strategic plan to align FPS’s activities and resources to support NPPD 
mission-related outcomes. Additionally, NPPD is assisting FPS in 
developing a human capital strategic plan, as recommended by GAO in 
July 2009. These steps are encouraging, but it is too early to tell if 
these planned actions will help address challenges previously 
identified by GAO. 

What GAO Recommends: 

GAO recommends that DHS improve the schedule for transferring IT 
services to reflect scheduling best practices, and update the IT 
transition cost estimate, in accordance with cost-estimating best 
practices. DHS concurred with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-11-554] or key 
components. For more information, contact David C. Maurer at (202) 512-
9627 or maurerd@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

DHS Transferred FPS's Mission and Most Support Functions to NPPD, but 
Could Benefit from a Revised Schedule and Cost Estimate for 
Transferring IT Services: 

Transition May Provide Opportunity to Address Previously Identified 
FPS Challenges, but It Is Too Early to Tell Its Impact: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Homeland Security: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Extent to Which FPS Mission-Support Functions Have 
Transferred to NPPD or Other DHS Components as of May 2011: 

Table 2: FPS Mission-Support Functions That Have Experienced Delays as 
of May 2011: 

Table 3: Description of GAO Scheduling Best Practices: 

Table 4: DHS's Incorporation of Best Practices into the FPS IT 
Transition Schedule: 

Table 5: Original and Revised FPS Transition Cost Estimates and Actual 
Costs Incurred: 

Table 6: DHS's Incorporation of Best Practices into the FPS IT 
Transition Cost Estimate: 

Figures: 

Figure 1: DHS Organizational Chart Showing FPS's Movement from ICE to 
NPPD: 

Figure 2: FPS Transition Implementation Team Organization: 

Figure 3: Location of FPS within NPPD's Organizational Structure: 

Abbreviations: 

CIO: Chief Information Officer: 

COMSEC: Communication Security: 

DHS: Department of Homeland Security: 

EEO: Equal Employment Opportunity: 

FOIA: Freedom of Information Act: 

FPS: Federal Protective Service: 

GSA: General Services Administration: 

ICE: Immigration and Customs Enforcement: 

IPAC: Intra-Governmental Payment and Collection: 

IT: Information Technology: 

MOA: Memorandum of Agreement: 

MOU: Memorandum of Understanding: 

NPPD: National Protection and Programs Directorate: 

OGC: Office of the General Counsel: 

OMB: Office of Management and Budget: 

OPLA: Office of the Principal Legal Advisor: 

PBS: Public Buildings Service: 

SES: Senior Executive Service: 

SLA: Service Level Agreement: 

US-VISIT: United States Visitor and Immigrant Status Indicator 
Technology: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 15, 2011: 

The Honorable Bennie G. Thompson: 
Ranking Member: 
Committee on Homeland Security: 
House of Representatives: 

Dear Mr. Thompson: 

Events such as the February 2010 attack on the Internal Revenue 
Service offices in Texas, and the January 2010 shooting in the lobby 
of the Nevada federal courthouse, demonstrate the vulnerability of 
federal facilities and the threat to the safety of federal employees 
who occupy them. These events also highlight the continued challenges 
involved in protecting the over 1 million government employees who 
work in federal facilities, and members of the public who visit such 
facilities each year. The Federal Protective Service (FPS), 
established in 1971 as the uniformed protection force of the General 
Services Administration (GSA), is the primary agency responsible for 
the security of over 9,000 federal government facilities across the 
country, including buildings; grounds; and property owned, occupied, 
or secured by the federal government.[Footnote 1] 

FPS was transferred from GSA's Public Buildings Service to the 
Department of Homeland Security (DHS), with enactment of the Homeland 
Security Act of 2002.[Footnote 2] Within DHS, FPS was originally a 
part of Immigration and Customs Enforcement (ICE).[Footnote 3] 
However, the fiscal year 2010 DHS appropriations act transferred FPS 
from ICE to the National Protection and Programs Directorate (NPPD), 
within DHS, and the transfer became effective when the act was signed 
into law on October 28, 2009.[Footnote 4] DHS proposed this transfer 
to better align FPS's facility protection mission with NPPD's broader 
critical infrastructure protection mission. 

In light of FPS's critical role of protecting federal facilities 
against the threat of terrorism and other criminal activity, it is 
important that FPS's transfer to NPPD be successful. In addition to 
the inherent challenges any organization would face in becoming part 
of another agency, our prior work reviewing the operations of FPS and 
its ability to protect federal facilities has shown that FPS brings a 
set of unique operational, management, and funding challenges to NPPD 
that have a bearing on its ability to accomplish its mission.[Footnote 
5] The challenges include managing its contract guard force, 
establishing a comprehensive human capital strategy, evaluating its 
funding structure, and developing a risk management framework that 
links threats and vulnerabilities to resource requirements. Over the 
past 5 years, we have made numerous recommendations to address these 
challenges. For example, we recommended FPS improve its long-term 
human capital planning, develop and implement performance measures in 
various aspects of its operations, and improve its data collection and 
quality across its operations. While FPS has generally agreed with all 
of our recommendations, it has not completed many related corrective 
actions. If not properly planned and effectively implemented, the 
transition could not only hamper FPS's ability to carry out its 
mission, but impede its progress in addressing its long-standing 
challenges. 

DHS prepared a transition plan for the realignment of FPS that 
describes the department's ongoing planning efforts, cost estimates, 
and a timeline for the planning and execution process, but members of 
Congress raised questions about whether the plan provided sufficient 
information about how the department would address FPS's 
challenges.[Footnote 6] You requested that we review the department's 
transition efforts. This report addresses (1) the extent to which the 
FPS transition has been implemented and any challenges FPS and NPPD 
face in implementing the transition; and (2) the extent to which the 
transition will help address previously identified challenges to 
protecting federal facilities. 

To answer the first objective, we reviewed relevant documents, 
including the August 2009 FPS-NPPD Transition Plan, transition plan 
updates, the Memorandum of Agreement (MOA), the Memorandum of 
Understanding (MOU), and all service level agreements (SLA)[Footnote 
7] signed among FPS, NPPD, and ICE.[Footnote 8] We interviewed members 
of the senior-level working group, as well as members of all working 
groups that were established to carry out the transition in 18 mission-
support functions, to discuss the extent to which the mission-support 
functions had transferred from ICE to NPPD.[Footnote 9] In addition, 
we interviewed the FPS Deputy Director, Chief of Staff, regional and 
deputy regional directors, and mission support chiefs from 6 of the 11 
FPS regions around the country on a range of issues related to the 
transition of FPS to NPPD. We compared the FPS information technology 
(IT) transition schedule, the IT transition cost estimate, and related 
documents to the practices in our Cost Estimating and Assessment 
Guide.[Footnote 10] We did a detailed analysis of the IT services 
mission-support function because it required a significant commitment 
of resources, oversight, and time by DHS to complete the transition. 
We also obtained and analyzed financial documentation from the 
components' accounting systems to identify transition costs.[Footnote 
11] To assess the reliability of this documentation, we (1) performed 
electronic testing for obvious errors in accuracy and completeness, 
(2) compared the data with other sources of information, such as cost 
data from the ICE Office of Financial Management and documentation 
from the Intra-Governmental Payment and Collection (IPAC) system, and 
(3) interviewed agency officials knowledgeable about financial 
management and budgeting at all three agencies to understand the data 
and to identify any data problems.[Footnote 12] When we found 
discrepancies (such as data entry errors) we brought them to the 
officials' attention and worked with them to correct discrepancies 
before concluding our analysis. We determined that the data were 
sufficiently reliable for the purposes of this report. 

To answer the second objective, we reviewed our prior work on 
challenges facing FPS in its efforts to protect federal facilities. We 
also reviewed and analyzed documentation, such as the transition plan, 
testimony from key senior leaders in FPS and NPPD provided for a 
hearing on the FPS transition, FPS's strategic plan, and NPPD's 
strategic activities report. Finally, we interviewed the Senior 
Counselor to the Under Secretary of NPPD, and FPS Deputy Director for 
Operations and Chief of Staff and discussed actions underway or 
planned to further address FPS's challenges. 

We conducted this performance audit from October 2010 through July 
2011 in accordance with generally accepted 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 the 
evidence provides a reasonable basis for our findings and conclusions 
based on our audit objectives. Appendix I contains more details on our 
scope and methodology. 

Background: 

FPS was established in 1971 as the uniformed protection force of GSA 
government-occupied facilities. The mission of FPS is to render 
federal properties safe and secure for federal employees, officials, 
and visitors in a professional and cost-effective manner by deploying 
a highly trained and multi-disciplined police force. FPS was 
originally located within GSA's Public Buildings Service (PBS). As 
part of PBS, FPS was responsible for providing law enforcement and 
security services to GSA's tenants and the public at federal buildings 
nationwide. 

The Homeland Security Act of 2002 established DHS to prevent and 
mitigate the damage from terrorist attacks within the United States, 
which includes terrorism directed at federal facilities. Under the 
act, FPS was transferred from the GSA to DHS. DHS later placed it 
within ICE. The President's fiscal year 2010 budget requested the 
transfer of FPS from ICE to NPPD. Language in the budget request 
stated that FPS responsibilities, such as providing physical security 
and policing of federal buildings, establishing building security 
policy, and ensuring compliance, are outside the scope of ICE's 
immigration and customs enforcement mission and are better aligned 
with NPPD's mission. The transfer of FPS to NPPD became effective when 
the fiscal year 2010 DHS appropriations act was signed into law on 
October 28, 2009. Figure 1 shows FPS's move within DHS from ICE to 
NPPD. 

Figure 1: DHS Organizational Chart Showing FPS's Movement from ICE to 
NPPD: 

[Refer to PDF for image: Organizational Chart] 

Department of Homeland Security: 

Top level: 

Secretary/Deputy Secretary: 
Chief of Staff: 
* Executive Secretariat; 
* Military Advisor. 

Second level, reporting to Secretary/Deputy Secretary: 
* Management: 
- Chief Financial Officer; 
* Science & Technology; 
* National Protection & Programs [Refer to Figure 3]; 
* Policy; 
* General Counsel; 
* Legislative Affairs; 
* Public Affairs; 
* Inspector General; 

Third level, reporting to Secretary/Deputy Secretary: 
* Health Affairs; 
* Intelligence & Analysis; 
* Operations Coordination & Planning; 
* Citizenship & Immigration Services Ombusman; 
* Civil Rights & Civil Liberties; 
* Chief Privacy Officer; 
* Counter-Narcotics Enforcement. 

Fourth level, reporting to Secretary/Deputy Secretary: 
* Intergovernmental Affairs; 
* Federal law Enforcement Training Center; 
* Domestic Nuclear Detection Office. 

Fifth level, reporting to Secretary/Deputy Secretary: 
* Transportation Security Administration; 
* U.S. Customs & Border Protection; 
* U.S. Citizenship & Immigration Services; 
* U.S. Immigration & Customs Enforcement [Move your computer mouse 
pointer over the ‘Highlighted’ organizations in the chart to see more 
information]; 
* U.S. Secret Service; 
* Federal Emergency Management Agency; 
* U.S. Coast Guard. 

Source: DHS. 

[End of figure] 

To accomplish its mission, in 2011 FPS has a total budget authority of 
about $1 billion, currently employs 1,225 federal staff, and about 
13,000 contract guard staff to secure over 9,000 GSA owned or leased 
facilities. FPS conducts law enforcement activities as well as risk 
assessments to reduce facility vulnerability to criminal and terrorist 
threats and helps to ensure that facilities are secure and occupants 
are safe. 

For the transition, FPS, NPPD, ICE, and DHS headquarters components 
formed a Senior Working Group, co-chaired by the Senior Counselor to 
the Under Secretary of NPPD, the ICE Deputy Assistant Secretary for 
Management, and the FPS Director.[Footnote 13] DHS developed a 
transition plan, the August 2009 FPS-NPPD Transition Plan, which 
describes DHS's overall transition planning process and milestones for 
completing the transition, among other things. The plan shifted FPS's 
mission and responsibility for all of its mission-support functions, 
with the exception of financial accounting services and firearms and 
tactical training, from ICE to NPPD or other DHS components. While FPS 
has its own law enforcement personnel to perform its mission 
responsibilities, it does not perform all of its mission-support 
functions such as payroll, travel services, and contracting. For this 
reason, FPS has traditionally relied on GSA and ICE to carry out these 
functions. For example, while under GSA, FPS's contracting functions 
were handled by the contracting component of GSA's Public Buildings 
Service, and under ICE, by its Office of Acquisition. 

The transition plan noted that most transition tasks would be 
completed by October 2010. In addition, the transition plan noted 
staff-level working groups were formed that consisted of subject 
matter experts from each of the agencies, FPS, NPPD, and ICE, to plan 
in detail the transfer of FPS's mission and each mission-support 
function. The working groups were tasked with planning, tracking 
issues related to the FPS transition, and reporting progress on the 
transition. Initially, 16 working groups were formed to carry out the 
transition in 18 mission-support functions, as reflected in figure 2. 
[Footnote 14] 

Figure 2: FPS Transition Implementation Team Organization: 

[Refer to PDF for image: illustration] 

Senior Working Group: 
* Senior Working Group Co-Chairs: 
- Senior Counselor to the Under Secretary of NPPD; 
- ICE Deputy Assistant Secretary for Management; 
- FPS Director. 

Staff Level Working Groups (18 mission-support functions): 

Human Capital; 
Procurement Management and Operations; 
Security Integrity and Personnel Security; 
Facilities; 
Employee and Labor Relations; 
Equal Employment Opportunity; 
Budget Formulation and Performance; 
Information Operations; 
Training, Professional Development and Education; 
Operations; 
Public Affairs; 
Legislative Affairs; 
Legal Services; 
Logistics and Asset Management; 
Business Continuity and Emergency Preparedness; 
Financial Management; 
Acquisitions; 
Information Management. 

Source: GAO analysis of NPPD data. 

[End of figure] 

According to the transition plan, until the transition is complete, 
ICE is to continue to provide necessary management and operational 
services through continued agreements in support of FPS or until 
individual MOAs, MOUs, or SLAs are concluded with NPPD and other DHS 
headquarters components. For example, for fiscal year 2010, FPS and 
NPPD signed 12 SLAs with ICE, covering services such as training and 
development, security management, and IT services, 1 MOA for legal 
services, and 1 MOU for financial services. These agreements were 
meant to ensure that there were no lapses in services while mission-
support functions were being transferred to either NPPD or DHS 
headquarters components. 

DHS Transferred FPS's Mission and Most Support Functions to NPPD, but 
Could Benefit from a Revised Schedule and Cost Estimate for 
Transferring IT Services: 

FPS's Facility Protection Mission Has Transferred to NPPD without 
Disruption: 

In October 2009, FPS's facility protection mission transferred and its 
reporting channels were shifted from ICE to NPPD. The Under Secretary 
of NPPD--through delegation from the Secretary of Homeland Security-- 
assumed operational control of FPS and its mission from ICE with the 
enactment of the fiscal year 2010 DHS appropriations act.[Footnote 15] 
Similarly, the Under Secretary delegated the authority and 
responsibility to the Director of FPS to continue FPS's physical 
security and law enforcement services mission,[Footnote 16] consistent 
with the law enforcement authority for the protection of federal 
property.[Footnote 17] Upon its transition to NPPD, FPS became a 
component within the directorate.[Footnote 18] Figure 3 shows the 
location of FPS within NPPD's organizational structure. 

Figure 3: Location of FPS within NPPD's Organizational Structure: 

[Refer to PDF for image: Organizational Structure] 

National Protection and Programs Directorate (NPPD): 

Top level: 
Under Secretary/Deputy Under Secretary: 
* Office of the Chief of Staff: 
- Information Management(ExecSec/FOIA/GAO/Records Mgmt); 
* Office of Cyber+Strategy (Senior Counselor); 
* Senior Counselor (NPPD Integration + FPS Transition). 

Second level: Reporting to Under Secretary/Deputy Under Secretary: 
* Office of Resource Administration; 
* Office of Budget, Finance and Acquisition; 
* Office of the Chief Information Officer; 
* Office of Communications and Public Affairs; 
* Office of Privacy. 

Third level: Reporting to Under Secretary/Deputy Under Secretary: 
* Office of Infrastructure Protection; 
* Office of Cybersecurity and Communications; 
* United States Visitor and Immigrant Status Indicator Technology; 
* Office of Risk Management and Analysis; 
* Federal Protective Service. 

Source: DHS. 

Note: FOIA refers to the Freedom of Information Act. 

[End of figure] 

According to FPS headquarters and regional officials we interviewed, 
the transition of FPS's mission from ICE to NPPD occurred without 
degradation to the mission, and there has been minimal, if any, 
disruption to FPS's field operations. Moreover, the regional officials 
said that the transition has not had an impact on the way FPS performs 
its mission on a daily basis. FPS officials stated that FPS continued 
to lead DHS's security and law enforcement services at more than 9,000 
GSA facilities nationwide, and its operational activities, such as 
conducting facility security assessments, conducting criminal 
investigations, and responding to critical incidents, continued 
uninterrupted during and after the transition.[Footnote 19] 

NPPD Has Experienced Delays in Assuming Some FPS Mission-Support 
Functions: 

Since taking operational control of FPS in October 2009, NPPD and 
other DHS components have assumed responsibility for 13 of 18 FPS 
mission-support functions, but the transfer of the remaining 5 mission-
support functions from ICE to NPPD or other DHS components has been 
delayed. In August 2009, DHS reported to Congress that the transition 
would be completed by October 2010 and estimated it would cost $14.6 
million.[Footnote 20] However, DHS now reports that the transfer of 4 
functions will not be completed until the end of fiscal year 2011 or 
start of fiscal year 2012 and one of these functions will not be 
transferred until October 2012. For the delayed functions, ICE 
continues to provide mission support to FPS, and new or revised SLAs 
were developed to articulate the continuing time frames and services 
that ICE would provide to FPS. The 18 mission-support functions and 
their transfer status are presented in table 1. 

Table 1: Extent to Which FPS Mission-Support Functions Have 
Transferred to NPPD or Other DHS Components as of May 2011: 

FPS mission-support function: Operations; 
Status: Completed; 
Description: Information on critical incidents is passed directly to 
the NPPD Under Secretary, concurrent with notification to the DHS 
National Operations Center. 

FPS mission-support function: Human Capital; 
Status: Completed; 
Description: NPPD and FPS human capital management staffing and 
functions have been consolidated. NPPD human resources conducts 
personnel services functions in support of FPS[A]. 

FPS mission-support function: Employee and Labor Relations; 
Status: Completed; 
Description: A new Employee and Labor Relations Office was established 
at NPPD and a new director was hired. All FPS disciplinary, adverse, 
and performance-based actions have been transferred to the NPPD 
Employee and Labor Relations Office. 

FPS mission-support function: Training, Professional Development, and 
Education; 
Status: Completed; 
Description: All non-law enforcement training for FPS employees is 
being managed through NPPD's Office of Professional Development and 
Training, in coordination with FPS's regional training coordinators. 
NPPD also has an agreement with ICE and the Federal Law Enforcement 
Training Center for transfer of Academic Course Management System 
database records. 

FPS mission-support function: Budget Formulation and Performance; 
Status: Completed; 
Description: NPPD coordinated the FPS fiscal year 2011 budget 
submission and plans to coordinate all future year budget formulation 
and submissions. 

FPS mission-support function: Financial Management; 
Status: Completed; 
Description: ICE will provide financial management services to FPS 
indefinitely as there is no economical or efficient way for NPPD to 
replicate these services. However, NPPD has assumed financial 
management reporting responsibilities, internal controls, and audit 
response and coordination responsibilities. 

FPS mission-support function: Procurement Management and Operations; 
Status: Completed; 
Description: DHS Office of Procurement Operations has assumed 
contracting authority and oversight of FPS procurement activities. 

FPS mission-support function: Logistics and Asset Management; 
Status: Completed; 
Description: NPPD has migrated and currently manages the NPPD motor 
fleet within FPS management operations, and FPS asset management and 
logistics have fully transferred from ICE to NPPD. 

FPS mission-support function: Acquisitions; 
Status: Completed; 
Description: All acquisition support services have been transferred to 
DHS Office of Procurement Operations. NPPD also assumed component 
acquisition executive oversight of FPS investment programs. 

FPS mission-support function: Legislative Affairs; 
Status: Completed; 
Description: FPS legislative affairs are coordinated through the NPPD 
Legislative Affairs Director and DHS Office of Legislative Affairs. 

FPS mission-support function: Public Affairs; 
Status: Completed; 
Description: The DHS Office of Public Affairs has detailed a senior 
public affairs staffer to FPS to manage and facilitate public affairs 
activities. 

FPS mission-support function: Information Management; 
Status: Completed; 
Description: FPS executive correspondence and reports have been 
integrated with the NPPD Office of the Executive Secretariat. 
Management of the FPS Freedom of Information Act (FOIA) caseload 
transferred to NPPD's FOIA Office. Additionally, coordination of GAO 
and DHS Office of the Inspector General audit work transferred to 
NPPD's Audit Liaison Office. 

FPS mission-support function: Legal Services; 
Status: Completed; 
Description: DHS officials indicated that the DHS Office of the 
General Counsel (OGC) has completed the transition of legal services 
from ICE Office of the Principal Legal Advisor (OPLA) to OGC in early 
fiscal year 2011. OGC currently has nine attorneys dedicated to 
providing legal services to FPS and anticipates having the remaining 
two attorneys in place by the end of fiscal year 2011. According to 
DHS officials, for continuity purposes, OPLA continues to manage legal 
actions that were ongoing at the time of transition, primarily in the 
areas of employment and tort litigation. 

FPS mission-support function: Information Operations (IT services); 
Status: Not completed; 
Description: Although FPS's Communication Security (COMSEC) function 
has transferred to NPPD COMSEC networks and related oversight of 
tactical communications systems has transferred to NPPD Office of the 
Chief Information Officer, DHS headquarters and NPPD are in the 
process of establishing the IT infrastructure and field support 
necessary to support FPS's geographically dispersed IT business needs 
and requirements. In the meantime, the ICE Office of Chief Information 
Officer continues to provide IT services such as engineering and 
operations. DHS and NPPD plan to complete the transfer of IT services 
by October 2012. 

FPS mission-support function: Business Continuity and Emergency 
Preparedness; 
Status: Not completed; 
Description: FPS is fully integrated with NPPD with respect to 
Business Continuity and Emergency Preparedness planning and operations; 
however, FPS plans to continue to use an ICE Continuity of Operations 
Emergency Relocation Site until NPPD completes the building of another 
relocation site. NPPD officials stated this would be complete by 
October 2011. 

FPS mission-support function: Security Integrity and Personnel 
Security; 
Status: Not completed; 
Description: New DHS-level badges and credential cards for law 
enforcement personnel were issued to the FPS workforce early in the 
transition process. According to an NPPD official, a personnel 
security function has not yet been built-out at the NPPD level due to 
delegation of authorities issues, overarching resource requirements, 
and the detailed coordination required as NPPD evolves into a more 
operationally focused organization. NPPD is in the process of 
establishing an Office of Compliance and Security, which NPPD 
officials hope to complete by October 2011; 
however, until the programs within the office are established, the ICE 
Office of Professional Responsibility, Personnel Security Unit 
continues to provide personnel security services to FPS. 

FPS mission-support function: Facilities; 
Status: Not completed; 
Description: FPS continues to rely on the ICE Office of Asset 
Management for facilities management services such as planning, 
design, and construction activities. According to DHS officials, NPPD 
has hired three of the five positions that were created to support FPS 
facilities management. The existing personnel are working with ICE to 
transfer projects and expect that all projects will transfer by the 
end of fiscal year 2011. 

FPS mission-support function: Equal Employment Opportunity (EEO); 
Status: Not completed; 
Description: The ICE Office of Equal Employment Opportunity (EEO) 
continues to perform all the FPS EEO program responsibilities to 
include counseling and advisory services, processing complaints, 
alternative dispute resolution, and compliance oversight for 
settlement actions. According to DHS officials, ICE will continue to 
provide EEO services through September 2011. 

Source: GAO analysis of NPPD transition information. 

Note: For the purposes of this report, the transfer of a mission- 
support function is complete when SLAs or MOUs among FPS, NPPD, and 
ICE have expired and services have been transferred to NPPD or other 
DHS components. 

[A] FPS receives medical and lab services such as medical, 
psychological, and fitness exams, and pre-employment drug screening 
through a third party vendor. 

[End of table] 

According to DHS officials responsible for executing the FPS 
transition, the transfer of the 5 mission-support functions will take 
longer than originally reported to Congress due to a number of 
factors, including unanticipated costs associated with building the 
infrastructure within NPPD and other DHS components to support areas 
such as IT services. As reflected in table 2, the delays in the 
transition schedule for the delayed mission-support functions range 
from almost 1 to 2 years. DHS officials explained that the transfer of 
four mission-support functions--business continuity and emergency 
preparedness, personnel security, facilities, and Equal Employment 
Opportunity (EEO)--are on track to transfer by the end of fiscal year 
2011 or start of fiscal year 2012. Specifically, DHS officials 
explained the following: 

* All activities for the transfer of business continuity and emergency 
preparedness have been completed but are waiting on NPPD to complete 
the building of a continuity of operations site, which according to 
NPPD officials, will be complete by October 2011. 

* NPPD has moved a Senior Executive Service (SES)-level director into 
position, and is in the process of establishing an Office of 
Compliance and Security, which will provide compliance investigations, 
program review, personnel security, interior physical security, 
information security, and special security program services throughout 
NPPD. According to the Acting Director of the Office of Compliance and 
Security, the goal is to establish this office by October 2011. 

* NPPD has hired three of the five positions that were created to 
support FPS facilities management. These personnel, according to the 
officials, are working with ICE to transfer projects and all of them 
are expected to transfer by the end of fiscal year 2011. 

* The only activity required for the transfer of EEO services is to 
hire staff needed to support FPS within NPPD, which should be 
completed by the end of fiscal year 2011. 

Table 2: FPS Mission-Support Functions That Have Experienced Delays as 
of May 2011: 

Mission support services: IT Services; 
Initial estimated transition date as reported in the August 2009 
transition plan: October 2010; 
Estimated transition date as of May 2011: October 2012; 
Delay in months: 24. 

Mission support services: Business Continuity and Emergency 
Preparedness; 
Initial estimated transition date as reported in the August 2009 
transition plan: November 2009; 
Estimated transition date as of May 2011: October 2011; 
Delay in months: 23. 

Mission support services: Personnel Security; 
Initial estimated transition date as reported in the August 2009 
transition plan: January 2010; 
Estimated transition date as of May 2011: October 2011; 
Delay in months: 21. 

Mission support services: Facilities; 
Initial estimated transition date as reported in the August 2009 
transition plan: April 2010; 
Estimated transition date as of May 2011: September 2011; 
Delay in months: 17. 

Mission support services: Equal Employment Opportunity; 
Initial estimated transition date as reported in the August 2009 
transition plan: October 2010; 
Estimated transition date as of May 2011: September 2011; 
Delay in months: 11. 

Source: GAO analysis of NPPD transition documents. 

[End of table] 

FPS's Transition Schedule for the Transfer of the IT Services Function 
Could Be Enhanced: 

While DHS has successfully transferred FPS's mission and the majority 
of its mission-support functions, deficiencies in the transition 
schedule for the transfer of IT services could limit DHS's ability to 
ensure the timely transition of this important function. DHS's 
transition plan called for working groups to develop comprehensive 
project management plans (i.e., detailed schedules) with detailed 
tasks and end dates for the individual mission-support functions to 
ensure critical path activities were identified, managed, and 
resourced. DHS did not develop these schedules for all the mission-
support functions since, according to DHS officials, in some cases the 
transfer of a function was relatively easy and did not need a 
schedule, such as public affairs and legislative affairs. However, the 
transfer of FPS's nationwide IT infrastructure and field support is 
more complex. Because of the complexity of transferring IT services, 
DHS developed a detailed schedule to manage the transfer of IT 
services, as called for in the transition plan. 

As we have previously reported, the success of fielding any program 
depends in part on having a reliable schedule that defines, among 
other things, when work activities will occur, how long they will 
take, and how they are related to one another.[Footnote 21] As such, 
the schedule not only provides a road map for systematic execution of 
a program, but also provides a means by which to gauge progress, 
identify and address potential problems, and promote accountability. 
Among other things, best practices and related federal guidance cited 
in our cost estimation guide call for a program schedule to be program-
wide in scope, meaning that it should include the integrated breakdown 
of the work to be performed, and expressly identify and define 
relationships and dependencies among work elements and the constraints 
affecting the start and completion of work elements. Table 3 presents 
a summary of best practices we have identified for applying a schedule 
as part of program management. 

Table 3: Description of GAO Scheduling Best Practices: 

Scheduling best practice: Capturing all activities; 
Explanation: The schedule should reflect all activities (steps, 
events, outcomes, etc.) as defined in the program's work breakdown 
structure to include activities to be performed by both the government 
and its contractors. 

Scheduling best practice: Sequencing all activities; 
Explanation: The schedule should sequence activities in the order that 
they are to be implemented. In particular, activities that must finish 
prior to the start of other activities (i.e., predecessor activities), 
as well as activities that cannot begin until other activities are 
completed (i.e., successor activities) should be identified. 

Scheduling best practice: Assigning resources to all activities; 
Explanation: The schedule should reflect who will do the work 
activities, whether all required resources will be available when they 
are needed, and whether any funding or time constraints exist. 

Scheduling best practice: Establishing the duration of all activities; 
Explanation: The schedule should reflect the duration of each 
activity. These durations should be as short as possible and have 
specific start and end dates. 

Scheduling best practice: Integrating schedule activities horizontally 
and vertically; 
Explanation: The schedule should be horizontally integrated, meaning 
that it should link the products and outcomes associated with 
sequenced activities. The schedule should also be vertically 
integrated, meaning that traceability exists among varying levels of 
activities and supporting tasks and subtasks. 

Scheduling best practice: Establishing the critical path for all 
activities; 
Explanation: The critical path represents the chain of dependent 
activities with the longest total duration in the schedule. 

Scheduling best practice: Identifying float between activities; 
Explanation: The schedule should identify a reasonable amount of 
float--the time that a predecessor activity can slip before the delay 
affects successor activities--so that schedule flexibility can be 
determined. As a general rule, activities along the critical path 
typically have the least amount of float. 

Scheduling best practice: Conducting a schedule risk analysis; 
Explanation: A schedule risk analysis is used to predict the level of 
confidence in the schedule, determine the amount of time contingency 
needed, and identify high-priority schedule risks. 

Scheduling best practice: Updating the schedule using logic and 
durations to determine the dates for all key activities; 
Explanation: The schedule should use logic and durations in order to 
reflect realistic start and completion dates, be continually monitored 
to determine differences between forecasted completion dates and 
planned dates, and avoid logic overrides and artificial constraint 
dates. 

Source: GAO, GAO Cost Estimating and Assessment Guide: Best Practices 
for Developing and Managing Capital Program Costs, GAO-09-3SP 
(Washington, D.C.: March 2009). 

[End of table] 

Our analysis of the IT schedule found that it did not reflect our best 
practices for scheduling, as seen in table 4. 

Table 4: DHS's Incorporation of Best Practices into the FPS IT 
Transition Schedule: 

Schedule best practice: Capturing all activities; 
Extent best practice met: Partially met; 
Assessment: Twenty-two percent of all activities in the schedule were 
missing resource assignments, therefore it was unclear from the 
schedule if all activities were included and who should perform the 
work. Further, the schedule does not reflect a valid work breakdown 
structure, which is a valuable communication tool because it provides 
a clear picture of how the work will be done, and is therefore an 
essential element in identifying activities in a schedule. 

Schedule best practice: Sequencing all activities; 
Extent best practice met: Not met; 
Assessment: Almost all (99 percent) of the activities identified in 
the schedule were not sequenced; 
that is, activities that needed to finish prior to the start of other 
activities (i.e., predecessor activities), and activities that could 
not begin until other activities were completed (i.e., successor 
activities), were not identified. In addition, the activities were not 
logically sequenced--that is, logically linked in the order in which 
they are to be carried out. Sequencing all activities in a schedule 
helps ensure that interdependencies among such activities can be 
established in such a way that when changes occur, the 
interdependencies among the activities can be used as a basis for 
guiding the work. Without such interdependencies, the credibility of 
the calculated dates in the schedule is questionable. 

Schedule best practice: Assigning resources to all activities; 
Extent best practice met: Minimally met; 
Assessment: The schedule did not fully identify the resources needed 
to do the work or their availability. In regard to labor resources, 
the schedule identifies 31 resources (i.e., individuals and agencies) 
needed to do the work. Of the 31 resources, 19 are over allocated. 
Over allocation means that more people are needed to do the work than 
assigned to activities, which means that the work will not be done in 
the time allocated and the schedule will most likely slip. In regard 
to material resources, the schedule did not identify material or 
equipment costs needed to do the work. 

Schedule best practice: Establishing the duration of all activities; 
Extent best practice met: Partially met; 
Assessment: The schedule included duration figures (i.e., information 
on how long each activity is expected to take to execute); 
however, 46 percent of the activities identified in the schedule are 1-
day tasks. According to scheduling best practices, if there are a 
large number of 1-day duration activities, planners should recognize 
that these tasks typically take longer than 1 day to complete as 
people rarely complete 8 hours of work in a typical work day. In 
addition, the schedule identified 19 activities with durations ranging 
from 66 to 242 days. Best practices in scheduling note that, in 
general, estimated activity durations should be less than 2 working 
months or approximately 44 working days because activities that are 
too long in duration make it difficult for management to gauge 
progress. Activities identified in the schedule were based on a 
standard 40 hour work week that does not account for holidays. This 
assumes resources for conducting IT transition activities are 
available to work every day of the year. Since FPS is a federal 
agency, the schedule should reflect a calendar that accounts for 
federal holidays. 

Schedule best practice: Integrating schedule activities horizontally 
and vertically; 
Extent best practice met: Minimally met; 
Assessment: The schedule was generally vertically integrated, meaning 
that some dates for starting and completing activities were aligned 
with the dates for supporting tasks and subtasks. However, the 
schedule is not horizontally integrated because it does not reflect 
links to other sequenced activities. Therefore, any activity whose 
duration is extended beyond the planned duration will simply extend 
indefinitely with no effect on other sequenced activities or the 
project end date. 

Schedule best practice: Establishing the critical path for all 
activities; 
Extent best practice met: Not met; 
Assessment: The schedule did not sequence all activities; 
therefore, it is not possible to calculate a valid critical path. 
Without a valid critical path, management cannot determine the effects 
of what any activity slipping will have on the project finish date. 

Schedule best practice: Identifying reasonable float between 
activities; 
Extent best practice met: Not met; 
Assessment: The amount of float, which is an indicator of the amount 
of flexibility in the schedule, cannot be determined because 99 
percent of activities did not identify predecessor or successor 
activities. 

Schedule best practice: Conducting a schedule risk analysis; 
Extent best practice met: Not met; 
Assessment: We found no evidence that DHS officials performed a 
schedule risk analysis. Because a schedule risk analysis was not 
conducted, DHS cannot determine: the likelihood of the project 
completion date, how much schedule risk contingency is needed to 
provide an acceptable level of certainty by a specific date, which 
risks are most likely to delay the project, how much contingency 
reserve each of these risks require, and which paths are most likely 
to delay the project. 

Schedule best practice: Updating the schedule using logic and 
durations to determine dates; 
Extent best practice met: Minimally met; 
Assessment: According to the schedule, 6 milestones and 10 detail 
activities are marked as 100% complete. However, while the program 
began in June 2010, only 4 percent of the activities scheduled to 
occur in 2010 have been completed. This means that 96 percent of all 
detail activities in 2010 are either still in-progress or have yet to 
start. In addition, the schedule has no status date, which represents 
the status of the completed work as of the current day and denotes 
completed versus remaining effort. Because no effort has been made 
within the schedule to status actual progress, it is impossible to 
tell what activities have been completed, what activities are in 
progress, what activities are late, and what activities are planned to 
start on time. 

Source: GAO analysis of FPS IT transition schedule. 

Note: Not met--DHS provided no evidence that satisfies any of the 
criterion; Minimally met--DHS provided evidence that satisfies a small 
portion of the criterion; Partially met--DHS provided evidence that 
satisfies about half of the criterion; Substantially met--DHS provided 
evidence that satisfies a large portion of the criterion; and Met--DHS 
provided complete evidence that satisfies the entire criterion. 

[End of table] 

We shared the results of our analysis with responsible DHS IT 
transition officials, who stated that they have taken note of the 
deficiencies and are taking steps to improve the schedule using the 
scheduling practices. According to these officials, they plan to work 
closely with staff in another NPPD component agency with the expertise 
necessary to improve the IT transition schedule. Nevertheless, if the 
schedule does not fully and accurately reflect the project, it will 
not serve as an appropriate basis for analysis and may result in 
unreliable completion dates, time extension requests, and delays. With 
regard to the transfer of the IT services function, it would be 
difficult for DHS to accurately predict the completion date for the IT 
transition without a more reliable schedule. Moreover, completing 
projects within projected time frames helps ensure agencies do not 
incur additional costs, which is especially important in a fiscally 
constrained environment. Ultimately, incorporating scheduling best 
practices into the IT transition schedule could help DHS better manage 
the completion of the transition and help provide reasonable assurance 
that the transfer is complete within its projected timeframe. 

Incorporating Cost Estimating Best Practices in the IT Transition Cost 
Estimate Could Enhance the Reliability of, and Better Inform, 
Decisions about the Cost to Complete the Transition: 

According to best practices for cost estimates, in addition to a 
reliable schedule, a reliable cost estimate is critical to the success 
of any program.[Footnote 22] A reliable cost estimate provides the 
basis for informed investment decision making, realistic budget 
formulation and program resourcing, meaningful progress measurement, 
proactive course correction when warranted, and accountability for 
results. Such an estimate is important for any agency, but especially 
an agency like FPS that is solely fee funded[Footnote 23] and has 
faced projected shortfalls in fee collections to cover operational 
costs.[Footnote 24] 

Federal financial accounting standards state that reliable information 
on the costs of federal programs and activities is crucial for 
effective management of government operations and recommend that full 
costs of programs or activities be reported so that decision makers 
have information necessary to make informed decisions on resources for 
programs, activities, and outputs, and to help ensure that they get 
expected and efficient results.[Footnote 25] Drawing from federal cost-
estimating organizations and industry, our cost estimation best 
practices list four characteristics of a high-quality and reliable 
cost estimate that management can use for making informed decisions-- 
comprehensive, well-documented, accurate, and credible.[Footnote 26] 
In July 2008, the DHS Under Secretary for Management signed a 
memorandum stating DHS will standardize its cost-estimating process by 
using the best practices we identified. 

To implement the FPS transition, DHS, in 2009, estimated it would cost 
$14.6 million to complete the transition of FPS from ICE to NPPD. 
DHS's estimate provided for costs into three categories--personnel, 
financial management, and IT services. In 2011, the department revised 
the estimate for each of the three categories, which totaled $18.5 
million. At the time of our review, FPS had spent about $1.9 million 
of its operating revenue for transition-related expenses. Table 5 
reflects estimated and actual costs for personnel, financial 
management services, and IT services associated with the FPS 
transition. 

Table 5: Original and Revised FPS Transition Cost Estimates and Actual 
Costs Incurred: 

Cost category: Personnel: 
Original estimate in August 2009: $6.6 million; 
Revised estimate as of May 2011: $10.1 million; 
Amount spent at the time of our review: $0.6 million[A]. 

Cost category: Financial management services; 
Original estimate in August 2009: $2.4 million; 
Revised estimate as of May 2011: $2.2 million; 
Amount spent at the time of our review: $1.3 million[B]. 

Cost category: IT services; 
Original estimate in August 2009: $5.6 million; 
Revised estimate as of May 2011: $6.2 million; 
Amount spent at the time of our review: $0.0[C]. 

Cost category: Total; 
Original estimate in August 2009: $14.6 million; 
Revised estimate as of May 2011: $18.5 million; 
Amount spent at the time of our review: $1.9 million. 

Source: GAO analysis of DHS data. 

[A] FPS paid $630,000 to fund salaries and benefits for 25 new 
personnel hired to provide services previously provided by ICE. 

[B] FPS expects to incur $950,000 more in additional financial 
management services costs for fiscal year 2010. According to DHS 
officials, the transfer of FPS prompted ICE to assign financial 
management services costs to FPS in a manner consistent with other 
external customers. As a result, FPS's financial management services 
costs increased by $2.2 million between fiscal years 2009 and 2010. 
According to DHS officials, a bill for the remaining balance will be 
submitted to FPS when NPPD signs a modified MOU, which was under 
review as of May 2011. 

[C] According to DHS officials, FPS has not yet incurred costs for the 
IT transition. 

[End of table] 

DHS has successfully transferred the majority of mission-support 
functions, which includes oversight of financial management services, 
and, according to DHS officials, is on track to hire most of the 
remaining new personnel by the beginning of fiscal year 2012 to 
provide services previously provided by ICE. However, DHS has not yet 
transferred IT services and does not expect to complete the transfer 
until October 2012. Having a reliable and valid cost estimate is 
important for enabling managers to make informed decisions and 
facilitate tracking progress against estimates to effectively manage 
the transfer of IT services. While DHS committed to using GAO's best 
practices in preparing cost estimates in July 2008, our analysis of 
the cost estimate for the transfer of IT services found that it only 
partially met one of the four characteristics of a reliable cost 
estimate and minimally met the other three, as table 6 illustrates. 

Table 6: DHS's Incorporation of Best Practices into the FPS IT 
Transition Cost Estimate: 

Best practice: Comprehensive; 
Explanation: The cost estimate should include all costs. It should 
also provide an appropriate level of detail to ensure that cost 
elements are neither omitted nor double-counted and include 
documentation of all cost-influencing ground rules and assumptions; 
Extent best practice met: Partially met; 
Assessment: DHS estimated aggregate costs of $6.2 million for 
hardware, labor, and travel for the IT services transfer--$3.4 million 
for hardware and $2.8 million for labor and travel costs. However, the 
estimate does not detail costs for the scope of activities identified 
in the IT transition schedule. For example, the estimate does not 
detail possible costs for a pilot project at one representative FPS 
office and 26 other sample sites. In its report to the Office of 
Management and Budget (OMB) in January 2011, DHS noted that FPS has 
nearly 160 locations ranging from small remote sites to large mega-
centers, each with different IT configurations and needs potentially 
requiring different solutions and that a pilot project was needed to 
test whether initial technical solutions to these challenges will 
actually work. DHS further noted that one of the significant items was 
the transition of on-site technical support from ICE to a DHS Field 
Support contract; however, the estimate did not detail costs for the 
transition. Including such level of detail helps to ensure that no 
cost elements are omitted or double counted. 

Best practice: Well documented; 
Explanation: The cost estimates should capture in writing such things 
as source data used and their significance, the calculations performed 
and their results, and the rationale for choosing a particular 
estimating method. Moreover, this information should be captured in 
such a way that the data used to derive the estimate can be traced 
back to, and verified against, their sources. The final cost estimate 
should be reviewed and accepted by management; 
Extent best practice met: Minimally met; 
Assessment: The cost estimate is not supported by detailed 
documentation that describes how it was derived and how the expected 
funding will be spent in order to achieve the IT transfer. DHS did not; 
* document the formulas it used to calculate costs for the IT 
transition or prepare a summary explaining the sources and methods 
used to create the estimate; 
* clearly outline the cost estimate results, including information 
about cost drivers and high-risk areas, or; 
* include in the estimate the underlying data on which the estimate 
was based, which can cause an estimate's credibility to suffer because 
the rational supporting the specific costs is not clear. 
As a result, documentation was insufficient to allow us to corroborate 
the estimate. Providing such detail serves as an audit trail for clear 
tracking of cost estimates over time. Without a well-documented cost 
estimate, DHS will have difficulty presenting a convincing argument of 
the estimate's validity, and answering decision makers' and oversight 
groups' questions. 

Best practice: Accurate; 
Explanation: The cost estimate results should be unbiased, and not 
overly conservative or optimistic and based on an assessment of most 
likely costs. Further, the estimate should be regularly updated to 
reflect significant changes in the program so that it always reflects 
current status. Moreover, variances between planned and actual costs 
should be documented, explained, and reviewed; 
Extent best practice met: Minimally met; 
Assessment: An uncertainty analysis was not performed on the revised 
estimate; therefore, we cannot assess whether the cost estimate is 
unbiased, overly conservative, or optimistic based on an assessment of 
most likely costs. In addition, while the IT transition cost estimate 
has been revised from $5.6 million to $6.2 million, the cost estimate 
is not regularly updated according to program officials. Moreover, the 
revised estimate did not provide a track back to the original estimate 
of $5.6 million and did not discuss any reasons for why there was a 
variance. Although we found no mistakes in the costs that were 
presented, the estimate was prepared at such a high level that we were 
unable to confirm that the calculations were accurate. 

Best practice: Credible; 
Explanation: The cost estimate should discuss any limitations in the 
analysis performed due to uncertainty surrounding data or assumptions. 
Further, the estimate's derivation should provide for varying any 
major assumptions and recalculating outcomes based on sensitivity 
analyses, and their associated risks/uncertainty should be disclosed; 
Extent best practice met: Minimally met; 
Assessment: In December 2010, OMB expressed concerns to DHS about the 
practicality of the FPS IT transition plan, including whether DHS's IT 
system (DHS ONENet) was capable of supporting FPS operations across 
the country. OMB also expressed concern to DHS about the dramatic 
increase for IT services associated with the transition. In its 
January 2011 response to OMB, DHS indicated that in order to reduce 
risk, a pilot project would be performed at one of FPS's 
representative offices. The results of the pilot may not provide 
enough information for estimating risks related to the IT transition 
at the remaining offices that range from small remote sites to large 
mega-centers and have different configuration requirements. However, 
DHS did not conduct a risk and sensitivity analysis to examine the 
effects of changing assumptions and ground rules on the cost and 
schedule of the transition. The IT transfer requires technical 
decisions on changes in physical hardware and software, and system 
configurations in the routers and switches, along with decisions on 
any needs for new data circuits and routings. As DHS noted in its 
response to OMB, these decisions are numerous in the presence of FPS 
offices across the continent and are not currently matched by NPPD 
service locations. To be considered credible, cost estimates should 
discuss limitations in the analysis performed due to risk, 
uncertainty, or biases surrounding the data or assumptions. 

Source: GAO analysis of FPS IT transition cost data. 

Note: Not met--DHS provided no evidence that satisfies any of the 
criterion; Minimally met--DHS provided evidence that satisfies a small 
portion of the criterion; Partially met--DHS provided evidence that 
satisfies about half of the criterion; Substantially met--DHS provided 
evidence that satisfies a large portion of the criterion; and Met--DHS 
provided complete evidence that satisfies the entire criterion. 

[End of table] 

DHS officials stated that there are no plans to revise the IT 
transition estimate. According to DHS officials, rather than revising 
the estimate, the department plans to report actual costs once the 
transition is complete. However, incorporating cost estimating best 
practices into the IT transition cost estimate could provide an 
improved basis for remaining IT transition investment decisions and 
could facilitate tracking of actual costs against estimates, both of 
which are fundamental to effectively managing the transfer of IT 
services. 

Transition May Provide Opportunity to Address Previously Identified 
FPS Challenges, but It Is Too Early to Tell Its Impact: 

Since 2007, we have reported that FPS faces significant challenges 
with protecting federal facilities, and in response, FPS has started 
to take steps to address some of them. For example, our July 2009 and 
April 2010 reports on FPS's contract guard program identified a number 
of challenges that the agency faces in managing its contract guard 
program, including ensuring that the 15,000 guards that are 
responsible for helping to protect federal facilities have the 
required training and certification to be deployed at a federal 
facility.[Footnote 27] In response to our July 2009 report, FPS took a 
number of immediate actions with respect to contract guard management, 
including increasing the number of guard inspections it conducts at 
federal facilities in some metropolitan areas and revising its guard 
training. Further, in our April 2010 report, we recommended, among 
other things, that the Secretary of Homeland Security direct the Under 
Secretary of NPPD and the Director of FPS to develop a mechanism to 
routinely monitor guards at federal facilities outside metropolitan 
areas and provide building-specific and scenario-based training and 
guidance to its contract guards. As of August 2010, FPS was in the 
process of implementing this recommendation. 

Additionally, in July 2009 we reported that FPS did not have a 
strategic human capital plan to guide its current and future workforce 
planning efforts.[Footnote 28] Among other things, we recommended that 
FPS develop and implement a long-term strategic human capital plan 
that will enable the agency to recruit, develop, and retain a 
qualified workforce. DHS concurred with our recommendation and is 
taking action to address it. In June 2008, we reported on FPS's 
funding challenges, and the adverse implications its actions taken to 
address them had on its staff, such as low morale among staff, 
increased attrition, and the loss of institutional knowledge.[Footnote 
29] We recommended that FPS evaluate whether its use of a fee-based 
system or alternative funding mechanism was the most appropriate 
manner to fund the agency. FPS concurred with our recommendation; 
however, as of May 2011, FPS had not begun such an analysis. Finally, 
in our 2009 High-Risk Series, and again in 2011, we designated federal 
real property as a high-risk area, in part, because FPS has made 
limited progress and continues to face challenges in securing real 
property.[Footnote 30] 

If successfully managed, the transfer of FPS to NPPD could provide DHS 
the opportunity to better advance progress towards addressing FPS's 
challenges. The Under Secretary of NPPD and the former FPS Director, 
in written statements for the November 2009 congressional hearing on 
the FPS transfer, noted that the transition to NPPD would better 
leverage and align infrastructure protection resources and 
competencies to maximize their value. Further, the transition plan 
noted that the transfer would improve the mission effectiveness of 
both FPS and NPPD. According to NPPD officials, the agency has 
undertaken actions that serve as a foundation for integrating FPS into 
NPPD. 

First, NPPD officials explained that efforts undertaken by the senior 
working group and the staff working groups have served to move the 
transition forward, and integrate the FPS organization into the larger 
NPPD structure. These officials explained that FPS has been 
established as a component within NPPD, thereby aligning FPS's 
infrastructure protection mission within NPPD's critical 
infrastructure protection mission. As noted in the transition plan, 
NPPD chairs the operations of the Interagency Security Committee, a 
group that includes the physical security leads for all major federal 
agencies and whose key responsibility is the establishment of 
governmentwide security policies for federal facilities. As further 
noted in the transition plan, these missions are complementary and 
mutually supportive, and the alignment resulting from the transfer 
improves and advances the mission effectiveness of both FPS and NPPD. 

Second, NPPD officials stated that FPS has begun to develop a new 
strategic plan to align FPS's activities and resources to support NPPD 
mission-related outcomes. Our work has shown that in successful 
organizations, strategic planning is used to determine and reach 
agreement on the fundamental results the organization seeks to 
achieve, the goals and measures it will set to assess programs, and 
the resources and strategies needed to achieve its goals. Third, NPPD 
officials noted that NPPD has monthly meetings with FPS to review open 
GAO recommendations and is assisting FPS in closing out these 
recommendations. For example, in consultation with NPPD, FPS is 
developing a human capital strategic plan. A human capital strategic 
plan, flowing out of a new strategic plan, could help facilitate 
efforts to address previously identified challenges. Further, as we 
have previously reported, strategic human capital planning that is 
integrated with broader organizational strategic planning is critical 
to ensuring agencies have the talent they need for future challenges. 
[Footnote 31] 

Finally, according to the Senior Counselor to the Under Secretary of 
NPPD, NPPD has established a Field Force Integration Working Group 
among a set of five other integration working groups to pursue 
integration activities across the new and larger NPPD, and across DHS 
as a whole. In addition, the Senior Counselor noted that the purpose 
of the group is to examine capabilities and resources from across the 
NPPD components to gain efficiencies and economies of scale in support 
of all NPPD field operations. The official further noted that the 
FPS's workforce and regional structure is by far the largest and most 
established of the NPPD components. FPS's field structure and 
capabilities will be used as comparative models and resources as NPPD 
works toward continued integration of its operating entities. While 
these are encouraging steps, it is too early to tell if these planned 
actions will help address the challenges we have previously identified. 

Conclusions: 

With its critical role in protecting federal facilities against the 
threat of terrorism and other criminal activity, it is important that 
FPS's transfer to NPPD and its related integration are successful. DHS 
has implemented a number of scheduling and cost estimating best 
practices in the FPS transition and has successfully transferred 13 of 
the 18 mission support functions. Nevertheless, DHS could better 
manage the transfer of the IT services mission-support function, and 
help inform DHS, NPPD, FPS, and congressional investment decision 
making. Establishing a reliable schedule and incorporating cost 
estimation best practices in the estimate for the transfer of IT 
services could help provide DHS enhanced assurance that this delayed 
function will be transferred in accordance with its projected time 
frames. 

Recommendations for Executive Action: 

To help ensure that DHS and Congress have reliable, accurate 
information on the timeframes and costs of transferring FPS from ICE 
to NPPD, we recommend that the Secretary of Homeland Security direct 
the Under Secretary for NPPD, in consultation with the Director of FPS 
and the Director of ICE, to: 

* improve the schedule for transferring IT services, in accordance 
with the transition plan, and to reflect scheduling best practices, 
and: 

* update the IT transition cost estimate, in accordance with cost- 
estimating best practices. 

Agency Comments: 

We received written comments on a draft of this report from DHS. DHS 
concurred with our recommendations and stated that it is currently 
taking actions to implement them. With respect to improving the 
schedule for transferring IT services, DHS indicated that NPPD held 
working sessions with subject matter experts from DHS, ICE, and FPS 
Chief Information Officer (CIO) teams to capture all transition 
activities in greater detail and identify areas for implementation of 
best practices into schedule updates. DHS also noted that NPPD 
consulted with NPPD/United States Visitor and Immigrant Status 
Indicator Technology (US-VISIT) and adopted recommendations for 
schedule improvements, leveraging US-VISIT's lessons learned toward 
better alignment with GAO best practices, acquisition of scheduling 
expertise, and acquisition of specific software tools, among other 
things. Regarding updating the IT transition cost estimate, DHS noted 
that NPPD is researching and resolving cost-estimating deficiencies 
identified in the GAO report in collaboration with the DHS CIO. The 
department also noted that NPPD plans to identify an alternative 
network design solution that may reduce transition cost, and will 
refine the cost estimate after discussing network design discussions 
with subject matter experts and incorporating cost-estimating best 
practices. Written comments from DHS are reprinted in appendix II. 

As agreed with your office, unless you publicly announce the contents 
of the report, we plan no further distribution for 30 days from the 
report date. At that time, we will send copies of this report to the 
Secretary of Homeland Security, the Under Secretary of the National 
Protection and Programs Directorate, the Director of the Federal 
Protective Service, the Director of the Immigration and Customs 
Enforcement, and appropriate congressional committees. In addition, 
this report will be available at no charge on the GAO web site at 
[hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact David C. Maurer at (202) 512-9627 or maurerd@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Key contributors to this 
report are listed in appendix III. 

Sincerely yours, 

Signed by: 

David C. Maurer, Director: 
Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

We examined the transition of the Federal Protective Service (FPS) 
from Immigration and Customs Enforcement (ICE) to the National 
Protection and Programs Directorate (NPPD). We address the following 
questions: (1) to what extent has the FPS transition been implemented 
and what related challenges, if any, did FPS and NPPD face in 
implementing the transition and (2) to what extent will the transition 
help address previously identified challenges to protecting federal 
facilities? 

To determine the extent to which the FPS transition has been 
implemented and what challenges, if any, FPS and NPPD faced in 
implementing the transition, we reviewed documents related to the 
transition, including the August 2009 FPS-NPPD Transition Plan, all 
transition plan updates, DHS delegations of authority related to the 
execution and administration of FPS, and Memorandum of Agreement, 
Memorandum of Understanding, and all service level agreements signed 
among FPS, NPPD, and ICE. We interviewed FPS officials directly 
affected by the transition--including the FPS Deputy Director and 
Chief of Staff headquartered in Washington, D.C., and in each of 6 of 
FPS's 11 regional offices, the Regional Director, Deputy Director for 
Operations, and Mission Support Chief. We chose these offices on the 
basis of geographical dispersion. They included: the Northwest/Arctic 
Region (Federal Way, Washington); the Greater Southwest Region (Grand 
Prairie, Texas); the Heartland Region (Kansas City, Missouri); the 
Great Lakes Region (Chicago, Illinois); the National Capital Region 
(Washington, D.C.); and the New England Region (Boston, 
Massachusetts). Among other things, we asked questions about their 
experiences regarding the transition of FPS's mission and mission-
support functions from ICE to NPPD. While the results of these 
interviews provided examples of FPS officials' experiences and 
perspectives, they cannot be generalized beyond those we interviewed 
because we did not use statistical sampling techniques in selecting 
the regional offices, headquarters officials, and regional staff. 

Additionally, we met with members of the transition senior working 
group, including the NPPD Senior Counselor to the Under Secretary and 
the FPS Director, as well as interviewed members of all 16 staff-level 
working groups to discuss the extent to which FPS's 18 mission-support 
functions had transferred from ICE to NPPD. The working groups 
included officials from FPS, NPPD, ICE, and in some groups, DHS 
headquarters. We compared the FPS information technology (IT) 
transition schedule, the IT transition cost estimate, and related 
documents to the practices in our Cost Estimating and Assessment 
Guide.[Footnote 32] We focused on the IT mission-support function 
because it required a significant commitment of resources, oversight, 
and time by DHS to complete the transition. For the IT transition 
schedule and the cost estimate, we scored each best practice as either 
being Not met--DHS provided no evidence that satisfies any of the 
criterion; Minimally met--DHS provided evidence that satisfies a small 
portion of the criterion; Partially met--DHS provided evidence that 
satisfies about half of the criterion; Substantially met--DHS provided 
evidence that satisfies a large portion of the criterion; and Met--DHS 
provided complete evidence that satisfies the entire criterion. We 
provided the results of our schedule and cost analyses to DHS 
officials and met with them to confirm the results. Based on the 
interviews and additional documentation provided by DHS officials, we 
updated the results of our analyses, as needed. 

We reviewed financial documentation provided by all three components 
reflecting transition costs such as salaries, benefits, and expenses 
for new personnel hired to support the FPS transition, financial 
management services provided by ICE, and IT deployment. To assess the 
reliability of this documentation, we (1) performed electronic testing 
for obvious errors in accuracy and completeness; (2) compared the data 
with other sources of information, such as payroll reports to payroll 
data, cost data from the ICE Office of Financial Management and 
documentation from the Intra-Governmental Payment and Collection 
(IPAC) system; and (3) interviewed agency officials knowledgeable 
about financial management and budgeting at all three agencies to 
discuss transition-related expenses incurred at the time of our 
review, and to identify any data problems. When we found discrepancies 
(such as data entry errors) we brought them to the officials' 
attention and worked with them to correct discrepancies before 
concluding our analysis. We found the cost data to be sufficiently 
reliable for the purposes of this review. 

To determine the extent to which the transition will help address 
previously identified challenges to protect federal facilities, we 
reviewed prior GAO reports and testimonies related to FPS's facility 
protection efforts, and spoke with NPPD officials about FPS's ongoing 
challenges in this regard.[Footnote 33] We also reviewed and analyzed 
documentation, such as the transition plan, testimony from key senior 
leaders in NPPD and FPS provided for a hearing on the FPS transition, 
FPS's strategic plan, and NPPD's strategic activities report. Finally, 
we interviewed the Senior Counselor to the Under Secretary of NPPD, 
and FPS Deputy Director for Operations and Chief of Staff, and 
discussed actions underway or planned to further integrate FPS into 
NPPD. 

We conducted this performance audit from October 2010 through July 
2011 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. 

[End of section] 

Appendix II: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

July 8, 2011: 

Mr. David C. Maurer: 
Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
4441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO 11-554, "Federal Protective Service: Progress 
Made but Improved Schedule and Cost Estimate Needed to Complete 
Transition" 

Dear Mr. Maurer: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note the report's positive acknowledgment 
that DHS has successfully transferred the majority of the Federal 
Protective Service's (FPS's) mission support functions to the National 
Protection and Programs Directorate (NPPD) or other DHS
Components. The report also recognizes that DHS has implemented a 
number of scheduling and cost estimating best practices during the 
transition. To accomplish this, senior representatives and subject 
matter experts (SMEs) from NPPD, U.S. Immigration and Customs 
Enforcement (ICE), and FPS built a comprehensive transition plan that 
was flexible enough to be adjusted when necessary as new hurdles or 
roadblocks to the transition became apparent. For example, NPPD senior 
leadership made deliberate decisions to delay the build-out of NPPD-
level capacity in Facilities Management, Security Integrity and 
Personnel Security, and Equal Employment Opportunity support. With the 
exception of the Information Technology (IT) transition, on which work 
is continuing, the FPS transition to NPPD has been implemented on 
time, under projected budget, and with no adverse impact on the field 
operations of FPS's law enforcement and security personnel as they 
work to secure federal facilities and federal workers across the
United States. 

The draft report contained two recommendations with which DHS concurs, 
as discussed below. Specifically, to help ensure that DHS and Congress 
have reliable, accurate information on the timeframes and costs of 
transferring FPS from ICE to NPPD. GAO recommended that the Secretary 
of Homeland Security direct the Director of FPS, in consultation with 
the Assistant Secretary of ICE and the Undersecretary for NPPD to: 

Recommendation 1: Improve the schedule for transferring IT services, 
in accordance with the transition plan, and to reflect scheduling best 
practices. 

Response: Concur. NPPD is currently taking steps to implement this 
recommendation. Details on actions taken to date follow: 

* Using the March 2009 GAO Cost Estimating and Assessment Guide (GAO-
09-3SP), NPPD in June 2011 held working sessions with SMEs from the 
DHS, ICE, and FPS Chief Information Officer (CIO) teams to capture all 
transition activities in greater detail and to identify areas for 
implementation of best practices into schedule updates. These working 
sessions allowed NPPD to provide logical sequencing and establish 
durations and dependencies for all transition activities, allowing the 
organization to generate a critical path for all activities. 

The NPPD CIO consulted with NPPD/United States Visitor and Immigrant 
Status Indicator Technology (US-VISIT) and adopted recommendations for 
schedule improvements, leveraging US-VISIT's lessons learned toward 
better alignment with the GAO best practices, acquisition of 
scheduling expertise, and acquisition of specific software tools. An 
updated draft of the schedule was distributed to the FPS IT Transition 
Integrated Project Team (IPT) and SMEs for review and confirmation of 
the resource assignments. An SME IPT was also established as a sub-
group of the FPS IT Transition IPT to evaluate alternative technical 
methods that could increase automation and reduce cost. 

* Over the last 2 months, NPPD has also updated the schedule by 
holding working sessions with SMEs from the DIIS, ICE, and FPS CIO 
teams to capture all transition activities in greater detail and 
identify the current IT services provided by ICE CIO. NPPD is 
conducting periodic schedule reviews during weekly FPS IT Transition 
IPT meetings to provide visibility to all major stakeholders. 

The working sessions separated functions and services into the areas 
of business applications project management and system development, IT 
infrastructure support, IT field operations support, applications 
hosting environments, enterprise architecture, and telecommunications. 
The primary intent of this ongoing effort is to find alternative 
methods that will allow increased automation and deflect non-required 
activities from the critical path. 

* NPPD also plans to take action to hire additional SMEs to guide 
these scheduling efforts. In particular, NPPD plans to acquire the 
services of a Master Scheduler to provide ongoing scheduling expertise 
to the NPPD CIO organization and augment FPS IT branch staff. The 
Master Scheduler will be responsible for managing and monitoring all 
NPPD IT initiatives, including the FPS IT Transition. This need will 
be met by a government full-time employee, detailee, or contractor 
support. Additionally, the August 2009 FPS-NPPD Transition Plan 
identified eight additional staff required for FPS IT branch support 
in the areas of IT, cost estimation, logistics, information security, 
and mission support. Hiring actions are underway, and three of the 
eight positions have already been filled. 

Recommendation 2: Update the IT transition cost estimate, in 
accordance with cost-estimating best practices. 

Response: Concur. NPPD is taking steps to update and improve the cost 
estimate using best practices, To accomplish this, NPPD is researching 
and resolving cost-estimating deficiencies identified in the GAO 
report in collaboration with the DHS CIO. The original cost estimate 
was based on worst case transition and considered full replacement 
costs and customized migrations.Consultation with other groups that 
have been transitioned by ICE (namely U.S. Citizenship and Immigration 
Services) and detailed technical discussions suggest a new transition 
scenario in which only selective replacement of infrastructure may be 
required and the labor-intensive customized migration of individual 
users and their workstations would likely be minimal. This in turn as 
has resulted in an ongoing refinement of the cost basis; however, some 
regional and site differences would still exist and are being 
categorized. The results of the detailed analysis of the technical 
alternative will likely establish a new basis for the cost estimation. 

NPPD also plans to identify an alternate network design solution that 
may reduce transition cost. Alternative network designs, based on the 
evolution of the DHS network infrastructure (ONENET) and the 
introduction and establishment of trusted network zones within DHS, are
likely available. These designs could reduce the complexity of the 
network migration as well as the need for additional network equipment 
to support the previous requirements of the ONENET infrastructure. 
NPPD will also refine the cost estimate after discussing network 
design discussions with SMEs and incorporating cost-estimating best 
practices. 

Again, thank you for the opportunity to review and comment on this 
draft report. We look forward to working with you on future Homeland 
Security issues. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David C. Maurer at (202) 512-9627 or at maurerd@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Sandra Burrell, Assistant 
Director, and Valerie Kasindi, Analyst-in-Charge, managed this 
assignment. Don Kiggins made significant contributions to the work. 
Gary Mountjoy provided expertise on IT issues and Jack Warner provided 
expertise on financial management issues. Tracey King provided legal 
support. Michele Fejfar assisted with design and methodology and Karen 
Richey provided expertise on cost estimation and scheduling best 
practices. Katherine Davis provided assistance in report preparation 
and Robert Robinson developed the report's graphics. 

[End of section] 

Footnotes: 

[1] The GSA Administrator established FPS in January 1971 through an 
administrative order. 

[2] Pub. L. No. 107-296, § 403, 116 Stat. 2135, 2178 (2002) (codified 
at 6 U.S.C. § 203). 

[3] ICE is the principle investigative arm of DHS and the second 
largest investigative agency in the federal government. ICE's primary 
mission is to promote homeland security and public safety through the 
criminal and civil enforcement of federal laws governing border 
control, customs, trade, and immigration. 

[4] Pub. L. No. 111-83, 123 Stat. 2142, 2156-57 (2009). NPPD was 
formed by the Secretary of Homeland Security after enactment of the 
Post-Katrina Emergency Management Reform Act of 2006, and its goal is 
to advance DHS's risk-reduction mission. NPPD works to reduce risks to 
the nation through five mission areas: protect the nation's citizens 
and visitors against dangerous people and goods; protect the nation's 
physical infrastructure; protect and strengthen the nation's cyber and 
communications infrastructure; strengthen DHS's risk management 
platform; and strengthen partnerships and foster collaboration and 
interoperability. 

[5] See for example, GAO, Budget Issues: Better Fee Design Would 
Improve Federal Protective Service's and Federal Agencies' Planning 
and Budgeting for Security, [hyperlink, 
http://www.gao.gov/products/GAO-11-492] (Washington, D.C.: May 20, 
2011); Homeland Security: Addressing Weaknesses with Facility Security 
Committees Would Enhance Protection of Federal Facilities, [hyperlink, 
http://www.gao.gov/products/GAO-10-901] (Washington, D.C.: Aug. 5, 
2010); and Homeland Security: Federal Protective Service's Contract 
Guard Program Requires More Oversight and Reassessment of Use of 
Contract Guards, [hyperlink, http://www.gao.gov/products/GAO-10-341] 
(Washington, D.C.: Apr. 13, 2010). 

[6] Department of Homeland Security. FPS-NPPD Transition Plan: A 
Proposed Organizational Transition Fiscal Year 2009 Report to Congress 
(Aug. 21, 2009). 

[7] The MOU is a document that describes broad concepts of mutual 
understanding, goals and plans shared by the parties. The MOA is a 
document describing in detail the specific responsibilities of, and 
actions to be taken by, each of the parties so that their goals may be 
accomplished. The SLAs are agreements that define customer service 
expectations and responsibilities between two or more parties and are 
used to communicate baseline mission service requirements. 

[8] The SLAs established the scope of services ICE would provide to 
FPS during the transition period of October 2009 to September 2010, 
and in some cases into fiscal year 2011. 

[9] The 18 mission-support functions are: operations; human capital; 
employee and labor; training, professional development, and education; 
budget formulation and performance; financial management; procurement 
management and operations; logistics and asset management; 
acquisitions; legislative affairs; public affairs; information 
management; legal services; information operations (information 
technology services); business continuity and emergency preparedness; 
security integrity and personnel security; facilities; and equal 
employment opportunity. 

[10] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: Mar. 2009). 

[11] DHS officials define transition cost as the increase in the cost 
of mission-support functions as a result of FPS's transfer. 

[12] The IPAC system is designed to transfer funds between government 
agencies and provide the capability to include descriptive information 
related to each transaction. 

[13] The DHS headquarters organization includes Departmental 
Management and Operations, which provides leadership, direction and 
management to DHS and is comprised of separate appropriations 
including: the Office of the Secretary and Executive Management 
(OSEM); the Under Secretary for Management (USM); the Office of the 
Chief Financial Officer (OCFO); and the Office of Chief Information 
Officer (OCIO) and DHS Headquarters (HQ) Consolidation. 

[14] The August 2009 FPS-NPPD Transition Plan initially identified 17 
mission support functional areas. However, in the July 15, 2010 
Transition Update, acquisitions was separated from the procurement 
management and operations mission support functional area and became 
the 18TH mission support function. 

[15] Department of Homeland Security, Delegation Number: 17007, 
Delegation for Administration of the Federal Protective Service (Dec. 
18, 2009). 

[16] Department of Homeland Security, Delegation Number: 17001.001, 
Delegation to the Director for the Federal Protective Service (Dec. 
24, 2009). 

[17] 40 U.S.C. § 1315(e). 

[18] The other NPPD component offices include the Office of 
Cybersecurity, the Office of Infrastructure Protection, the Office of 
Risk Management and Analysis, and the Office of U.S. Visitor and 
Immigrant Status Indicator Technology. 

[19] A building security assessment is a comprehensive risk assessment 
that examines credible threats to federal buildings and the 
vulnerabilities and consequences associated with those threats. 
Credible threats include things such as crime activity or potential 
terrorism acts. 

[20] To implement the FPS transition, DHS estimated $14.6 million in 
three cost categories. These categories were (1) $6.6 million for 
salaries, benefits, and expenses for additional staff DHS plans to 
hire as a result of FPS's transfer, (2) $ 2.4 million for various 
costs associated with financial management services, and (3) $5.6 
million for IT requirements. 

[21] See, for example, GAO, Nuclear Waste: Actions Needed to Address 
Persistent Concerns with Efforts to Close Underground Radioactive 
Waste Tanks at DOE's Savannah River Site, [hyperlink, 
http://www.gao.gov/products/GAO-10-816] (Washington, D.C.: Sept. 14, 
2010); Transportation Worker Identification Credential: Progress Made 
in Enrolling Workers and Activating Credentials but Evaluation Plan 
Needed to Help Inform the Implementation of Card Readers, [hyperlink, 
http://www.gao.gov/products/GAO-10-43] (Washington, D.C.: Nov. 18, 
2009); and Nuclear Weapons: National Nuclear Security Administration 
Needs to Better Manage Risk Associated with Modernization of Its 
Kansas City Plant, [hyperlink, http://www.gao.gov/products/GAO-10-115] 
(Washington, D.C.: Oct. 23, 2009). 

[22] [hyperlink, http://www.gao.gov/products/GAO-09-3SP]. 

[23] FPS is a reimbursable organization and is fully funded by 
collecting security fees from tenant agencies. To fund its operations, 
FPS charges each tenant agency a basic security fee per square foot of 
space occupied in a GSA facility. In 2010, the basic security fee was 
66 cents per square foot and covered services such as patrolling, 
monitoring of building perimeter alarms, and dispatching of law 
enforcement response through its control centers. FPS also collects an 
administrative fee it charges tenant agencies for building specific 
security services such as access control to facilities' entrances and 
exists; employee and visitor checks; and the purchase, installation, 
and maintenance of security equipment. In addition to these security 
fees, FPS provides agencies with additional services upon request, 
which are funded through reimbursable Security Work Authorizations, 
for which FPS charges an administrative fee. 

[24] See for example, GAO, Homeland Security: The Federal Protective 
Service Faces Several Challenges That Hamper Its Ability to Protect 
Federal Facilities, [hyperlink, 
http://www.gao.gov/products/GAO-08-683] (Washington, D.C.: June 11, 
2008). 

[25] Statement of Federal Financial Accounting Standards No. 4, 
Managerial Cost Accounting Concepts and Standards for the Federal 
Government, establishes standards for managerial cost accounting 
information at federal agencies. 

[26] [hyperlink, http://www.gao.gov/products/GAO-09-3SP]. 

[27] [hyperlink, http://www.gao.gov/products/GAO-10-341] and GAO, 
Homeland Security: Preliminary Results Show Federal Protective 
Service's Ability to Protect Federal Facilities Is Hampered By 
Weaknesses in Its Contract Security Guard Program, [hyperlink, 
http://www.gao.gov/products/GAO-09-859T] (Washington, D.C.: July 8, 
2009). 

[28] GAO, Homeland Security: Federal Protective Service Should Improve 
Human Capital Planning and Better Communicate with Tenants, 
[hyperlink, http://www.gao.gov/products/GAO-09-749] (Washington, D.C.: 
July 30, 2009). 

[29] [hyperlink, http://www.gao.gov/products/GAO-08-683]. 

[30] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February 
2011); and High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January 
2009). 

[31] GAO, Interagency Collaboration: Key Issues for Congressional 
Oversight of National Security Strategies, Organizations, Workforce, 
and Information Sharing, [hyperlink, 
http://www.gao.gov/products/GAO-09-904SP] (Washington, D.C.: Sept. 25, 
2009). 

[32] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[33] See, for example, GAO, Homeland Security: Addressing Weaknesses 
with Facility Security Committees Would Enhance Protection of Federal 
Facilities, [hyperlink, http://www.gao.gov/products/GAO-10-901] 
(Washington, D.C.: Aug. 5, 2010); Homeland Security: Federal 
Protective Service's Contract Guard Program Requires More Oversight 
and Reassessment of Use of Contract Guards, [hyperlink, 
http://www.gao.gov/products/GAO-10-341] (Washington, D.C.: Apr. 13, 
2010); Homeland Security: Ongoing Challenges Impact the Federal 
Protective Service's Ability to Protect Federal Facilities, 
[hyperlink, http://www.gao.gov/products/GAO-10-506T] (Washington, 
D.C.: Mar. 16, 2010); Homeland Security: Federal Protective Service 
Has Taken Some Initial Steps to Address Its Challenges, but 
Vulnerabilities Still Exist, [hyperlink, 
http://www.gao.gov/products/GAO-09-1047T] (Washington, D.C.: Sept. 23, 
2009); Homeland security: Preliminary Results Show Federal Protective 
Service's Ability to Protect Federal Facilities Is Hampered by 
Weaknesses in Its Contract Security Guard Program, [hyperlink, 
http://www.gao.gov/products/GAO-09-859T] (Washington, D.C.: July 8, 
2009); and Homeland Security: Federal Protective Service Should 
Improve Human Capital Planning and Better Communicate with Tenants, 
[hyperlink, http://www.gao.gov/products/GAO-09-749] (Washington, D.C.: 
July 30, 2009). 

[End of section] 

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