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GAO-12-192R: 

December 8, 2011: 

The Honorable John D. Rockefeller, IV:
Chairman:
Committee on Commerce, Science, and Transportation:
United States Senate: 

Subject: Transportation Security Infrastructure Modernization May 
Enhance DHS Screening Capabilities, but It Is Too Early to Assess 
Results: 

Dear Mr. Chairman: 

Securing transportation systems and facilities requires balancing 
security to address potential threats while facilitating the flow of 
people and goods that are critical to the U.S. economy and necessary 
for supporting international commerce. As we have previously reported, 
transportation systems and facilities are vulnerable and difficult to 
secure given their size, easy accessibility, large number of potential 
targets, and proximity to urban areas.[Footnote 1] The federal 
government has taken steps to ensure that transportation workers, 
particularly those who transport hazardous materials or seek 
unescorted access to secure areas of federally regulated maritime or 
aviation facilities, are properly vetted to identify whether they pose 
a security risk. These efforts are intended to reduce the probability 
of a successful terrorist or other criminal attack on the nation's 
transportation systems. 

To help enhance the security of the U.S. transportation system, the 
Department of Homeland Security (DHS) Transportation Security 
Administration's (TSA) Transportation Threat Assessment and 
Credentialing (TTAC) office[Footnote 2] is responsible for conducting 
background checks--known as security threat assessments--for various 
screening and credentialing programs established for maritime,surface, 
and aviation transportation workers.[Footnote 3] TSA's programs are 
largely focused on identifying security threats posed by those 
individuals seeking to obtain an endorsement, credential, access, and/ 
or privilege (hereafter called a credential) for unescorted access to 
secure or restricted areas of transportation facilities at maritime 
ports and airports, and for commercial drivers transporting hazardous 
materials. These screening and credentialing programs were created 
under various legal and regulatory authorities, and were established 
at different times. As a result, according to TSA, these programs and 
their supporting systems are made up of independent, stand-alone 
business processes and systems, making it difficult to adapt them to 
meet expected growth in demand, new requirements, and new capabilities. 

According to TSA, TTAC screens and/or provides credentials to an 
estimated 12.5 million individuals per year, and this number is 
estimated to increase to between 52.5 million to 62.5 million 
individuals by 2016. However, as indicated in the TTAC Infrastructure 
Modernization (TIM) program mission needs statement, TTAC does not 
currently have the capability to support these expanding populations 
in providing security threat assessment and credentialing services. 
[Footnote 4] To address this limitation, TTAC initiated TIM in 2008 to 
consolidate and standardize TSA's current screening and credentialing 
systems to better serve transportation worker populations, increase 
efficiencies, and reduce duplication.[Footnote 5] In April 2007, we 
reported that several DHS screening and credentialing programs--
including TSA programs--would benefit from additional coordination 
since they collect similar information, use similar background check 
processes, and operate separate enrollment facilities.[Footnote 6] We 
made three recommendations aimed at enhancing coordination and 
exploring options for coordinating and aligning background checks 
within DHS. DHS concurred and took actions that addressed these 
recommendations. For example, DHS established a credentialing 
framework initiative to help eliminate redundant activities across 
multiple screening and credentialing programs. This framework is also 
intended to guide screening and credentialing investments to improve 
DHS's ability to meet its mission by, among other things, leveraging 
investments across programs, reducing costs of implementing new 
capabilities, and seeking to coordinate DHS initiatives. 

DHS has an acquisition management process intended to, among other 
things, help ensure acquisition programs meet DHS mission needs. As 
part of this process, the DHS Acquisition Review Board is to conduct 
systematic reviews of acquisition programs and make recommendations on 
the appropriate direction for moving forward.[Footnote 7] The 
Acquisition Review Board is also expected to provide a consistent 
method for evaluating an acquisition's progress and status at critical 
points in the acquisition's life cycle, and is to work with the 
acquisition decision authority, a member of the Acquisition Review 
Board, to approve an acquisition to proceed to the next phase in its 
life cycle.[Footnote 8] 

Given the current efforts to coordinate DHS screening and 
credentialing programs on a departmentwide basis, you asked that we 
evaluate TSA's TIM implementation effort. Specifically, this report 
addresses how the TIM program is being implemented to leverage and 
enhance existing DHS screening and credentialing capabilities in 
accordance with DHS policy and acquisition directive and guidance. 

To address this objective, we reviewed pertinent DHS policies and 
guidance, such as DHS's acquisition management directive, capital 
planning and investment control guidance, and credentialing framework. 
[Footnote 9] We also reviewed TIM program documentation, such as the 
TIM mission needs statement (March 2009), TIM analysis of alternatives 
(March 2011), related life cycle cost estimates (March 2011 and August 
2011),[Footnote 10] and whitepaper on DHS partnering opportunities 
(August 2011).[Footnote 11] To further inform our understanding of 
DHS's TIM program oversight, we reviewed DHS Acquisition Review Board 
decision memoranda and associated DHS governance tools such as the DHS 
screening portfolio and related enterprise architecture[Footnote 12] 
efforts at the DHS Office of the Chief Information Officer. We also 
interviewed TIM program officials at TSA and officials in DHS's 
Acquisition Program Management Division,[Footnote 13] Screening 
Coordination Office, and Office of the Chief Information Officer. In 
assessing the TIM program approach, we reviewed the information 
obtained through these endeavors to assess the extent to which options 
for leveraging, streamlining, and coordinating DHS screening and 
credentialing services and capabilities were identified and 
considered, as well as controls were designed to ensure DHS resources 
are effectively utilized to enhance DHS screening and credentialing 
capabilities. 

We conducted this performance audit from April 2011 to December 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 objective. 

Results In Brief: 

While TSA initially focused on fixing gaps in TSA-managed screening 
and credentialing operations, it has since modified its TIM strategy 
to better leverage and enhance departmentwide capabilities, in 
accordance with DHS's credentialing framework and acquisition 
directive and guidance. For example, DHS required the TIM program to 
identify additional opportunities for leveraging DHS capabilities--or 
enterprise services--and identify cost efficiencies. TSA initially did 
not select a course of action that would leverage DHS capabilities 
beyond what TSA already had in place under its existing programs, such 
as using or establishing a consolidated enrollment service that could 
be used by TIM and other DHS components. During the course of our 
review, however, TSA began to identify capabilities that might be 
leveraged across DHS. For example, in accordance with DHS direction, 
in August 2011, the TIM program identified several opportunities for 
leveraging existing DHS background checking and vetting services. 
[Footnote 14] For instance, TSA is now working with DHS's Office of 
the Chief Information Officer and Screening Coordination Office to 
establish a common vetting service, which could reduce duplication 
among other DHS services. Eliminating redundant activities across 
multiple screening and credentialing programs could help support the 
goals of DHS's credentialing framework initiative. However, as of the 
date of this report, the programs that are to use this vetting service 
have not yet been determined. It is therefore too early to tell the 
extent to which, once implemented, these initiatives would enhance 
screening and credentialing capabilities across DHS. In commenting on 
a draft of this report, DHS did not state whether it concurred with 
the contents but noted that the TIM effort will capitalize on 
opportunities to leverage and, where possible, consolidate existing 
DHS capabilities. DHS also provided technical comments, which we have 
incorporated where appropriate. 

Background: 

Screening Coordination Office and the Credentialing Framework: 

Housed within DHS's Policy Directorate, the Screening Coordination 
Office was established in July 2006 in response to Homeland Security 
Presidential Directive 11 (HSPD-11), which announced a new U.S. policy 
to implement a coordinated and comprehensive approach to terrorist-
related screening.[Footnote 15] As we reported in April 2007, one of 
the office's goals includes identifying opportunities to harmonize and 
enhance screening and credentialing processes across DHS's screening 
programs.[Footnote 16] 

In December 2006, the Screening Coordination Office issued a report 
identifying common problems, challenges, and needed improvements in 
the credentialing programs and processes across DHS. For example, the 
office identified that there was inefficient information and data 
collection and inconsistent vetting processes for similar programs. 
Among others, that report recommended that: (1) DHS establish a 
preference for "enroll once, use many" environments to promote sharing 
and reuse of information within DHS, so that component agencies do not 
have to build interfaces to the same systems to get to the information 
they need; (2) DHS design credentials that support multiple licenses, 
privileges, or status, based on the risks associated with the 
environments in which they are used; and (3) vetting be associated 
with like uses and like risks. In July 2008, and in response to that 
report, DHS established a credentialing framework initiative with the 
stated goal, among others, of improving credentialing processes across 
DHS by eliminating redundant activities, leveraging investments across 
programs, and reducing the costs of implementing new capabilities. The 
framework identifies the following six credentialing phases, or 
capabilities: (1) registration and enrollment; (2) eligibility vetting 
and risk assessment; (3) issuance; (4) verification and use; (5) 
expiration and revocation; and (6) redress/waiver. It also included 
trend analytics as another important activity that is to occur across 
the credentialing capabilities. Trend analytics is the ability to 
identify unusual activities across a credentialing program by looking 
at the entire credentialing process rather than just one part. 

Overview of DHS Acquisition Review Process: 

DHS's Acquisition Review Board is to review and approve acquisition 
programs at key stages in their life cycles before the acquisition 
program can move to the next phase.[Footnote 17] The DHS acquisition 
guidance has established four phases that constitute the acquisition 
life cycle: 

(1) "need" phase--identify a capability need (concludes with the DHS 
Acquisition Review Board granting the acquisition program approval to 
proceed at Acquisition Decision Event 1); 

(2) "analyze/select" phase--analyze and select the means to provide 
that capability (concludes with the Acquisition Review Board granting 
the acquisition program approval to proceed at Acquisition Decision 
Event 2A); 

(3) "obtain" phase--obtain the capability (the Acquisition Review 
Board may review the acquisition program multiple times, at 
Acquisition Decision Events 2B, 2C, before granting the acquisition 
program approval to proceed with particular acquisition activities; 
the phase concludes with the Acquisition Review Board granting the 
program approval to proceed at Acquisition Decision Event 3); and: 

(4) "produce/deploy/support" phase--produce, deploy, and support the 
capability (the Acquisition Review Board does not have a standard, 
defined role in this phase, but may also conduct additional reviews as 
necessary). 

Figure 1 presents the four DHS acquisition phases, including the 
documents presented for review as defined in DHS's acquisition 
directive. 

Figure 1: Overview of the DHS Acquisition Phases: 

[Refer to PDF for image: illustration] 

Need: 
Define the problem: 
Review mission need statement. 

ADE 1. 

Analyze/Select: 
Identify the alternatives and resource requirements: 
Review planning documents, including operational requirements 
document, acquisition program baseline, and acquisition plan.  

DHS approves selected acquisition approach.  

ADE 2A. 

Obtain: 
Develop and evaluate capabilities: 
DHS approves supporting acquisitions including small scale production.  

ADE 2B. 

DHS approves the acquisition to go into production. 

ADE 3. 

Produce/Deploy/Support: 
Produce & maintain those capabilities. 

Legend: ADE - Acquisition Decision Event. 

Sources: GAO analysis of DHS Acquisition Management Directive 102-01; 
and An Explosion (clipart). 

[End of figure] 

As required by DHS's acquisition directive and guidance, during the 
"need" phase, key planning documents, such as the mission needs 
statement, are to be completed. The purpose of the mission needs 
statement is to identify the need to be addressed by the department or 
DHS component's acquisition. Further, during the "analyze and select" 
phase, key documents, such as the analysis of alternatives, 
operational requirements document, and acquisition program baseline, 
are to be completed. The purpose of the analysis of alternatives is to 
identify alternative solutions and analyze or compare the alternatives 
based on cost, risk, and capability. The operational requirements 
document is to select user requirements and identify key performance 
parameters for the acquisition. Lastly, the acquisition program 
baseline is to serve as an agreement between the program office and 
the acquisition review board regarding the capability that will be 
provided, the timeframe in which it will be provided, and how much it 
will cost. It is to be used to measure program performance, and 
summarizes critical cost, schedule, and performance parameters that 
must be met to accomplish the goals of the investment. The acquisition 
program baseline must trace directly back to the mission gap expressed 
in the mission needs statement and the requirements detailed in the 
operational requirements document. 

TIM Acquisition History: 

Table 1 summarizes key TIM program events through September 2011. 

Table 1: Key TIM Program Events over Time: 

Date: December 2008; 
Key TIM program events: TTAC initiated the development of the TIM 
program. 

Date: June 11, 2009;
Key TIM program events: TSA presented before the Acquisition Review 
Board on the status of the prototype. The program had an anticipated 
prototype deployment date of October 2009. The prototype was 
anticipated to be completed in fiscal year 2010. 

Date: February 18, 2010; 
Key TIM program events: The Acquisition Review Board approved the TIM 
program's transition from the "need" phase of the acquisition 
lifecycle to the "analyze/select" phase after approving the mission 
needs statement and determining there was a need for the program. The 
TIM program proceeded to conduct an analysis of alternatives; 
Subsequent to the Acquisition Review Board review, TSA terminated the 
TIM prototype after it proved unsuccessful due to unclear requirements 
definition. TSA proceeded with a new acquisition approach for TIM, 
which included pursuing full and open competition for a full scale 
development contract. TSA stated that this change in acquisition 
strategy resulted in a delay of over 6 to 8 months. TSA moved the 
anticipated date for awarding a full-scale development contract to 
fiscal year 2011. 

Date: March 11, 2011; 
Key TIM program events: TIM analysis of alternatives was completed. 
TSA subsequently endorsed the selection of the recommended alternative 
and forwarded it to DHS for concurrence. 

Date: May 6, 2011; 
Key TIM program events: TSA went before the Acquisition Review Board 
to obtain approval for the TIM program to issue a request for 
proposals. The program did not receive approval at that point to 
transition from the "analyze/select" phase of the acquisition 
lifecycle to the "obtain" phase. DHS directed the program to complete 
several actions in preparation for approval to move to the "obtain" 
phase. TSA moved the anticipated TIM contract award date to September 
or October 2011. 

Date: May 12, 2011; 
Key TIM program events: DHS granted TSA permission to release the 
request for proposals after incorporation of some specific changes. 

Date: May 23, 2011; 
Key TIM program events: TSA issued a request for proposals for the TIM 
program acquisition. The request for proposals closed on August 8, 
2011. 

Date: September 15, 2011; 
Key TIM program events: The Acquisition Review Board provided verbal 
approval for the program to proceed to the "obtain" phase of the 
acquisition lifecycle, giving TSA permission to move forward with 
awarding a contract for acquiring TIM, pending approval from the DHS 
Under Secretary for Management. The board also forwarded key documents 
such as the operational requirements document and the acquisition 
program baseline to DHS approving authorities for signature and 
approval. 

Source: GAO summary of TIM program events based on TTAC and DHS 
information. 

[End of table] 

TIM Program Is Taking Steps to Leverage and Enhance DHS Capabilities 
Consistent with DHS Policy, but Efforts Are Too Early to Assess: 

As TSA has progressed toward implementing the TIM program, it has 
modified its strategy to leverage and enhance existing DHS 
capabilities, consistent with the DHS credentialing framework 
initiative and acquisition directive and guidance. The credentialing 
framework initiative seeks to coordinate and harmonize the numerous 
and disparate credentialing initiatives within DHS by identifying 
potential areas for elimination of duplicative efforts, services with 
a high likelihood of reuse, and an approach to target the development 
of high-priority services. In accordance with DHS's acquisition 
guidance, the TIM program went before the DHS Acquisition Review Board 
in February 2010 at the end of its "needs" phase to gain approval to 
enter the "analyze/select" phase. TSA presented the TIM program 
mission needs statement, which focused on fixing gaps in TSA's 
screening and credentialing programs, to the Acquisition Review Board. 
The Acquisition Review Board granted the program approval to proceed 
to the "analyze/select" phase. 

The mission needs statement acknowledged DHS's broader departmentwide 
credentialing requirements, such as promoting the reuse of enterprise 
services and standardization across DHS screening and credentialing 
programs, and had a stated goal of maximizing the use of the DHS and 
federal infrastructure to the maximum extent possible. Further, in 
granting the approval to proceed to the next phase, the Acquisition 
Review Board and TSA agreed that the analysis of alternatives for the 
TIM program would look outside of TSA's credentialing programs to 
other DHS modernization programs, include costs and benefits analyses, 
and assess any potential cost savings. The board and TSA also agreed 
that the TIM program would continue to work with DHS's Screening 
Coordination Office to develop business processes for vetting 
screening services at an enterprise level and define how the TIM 
program fits into the overall screening capability for DHS. 

TSA initially did not select a course of action that would leverage 
DHS capabilities beyond what TSA already had in place under its 
existing programs. Although TSA was directed to consider non-TSA 
alternatives, and DHS's credentialing framework calls for the 
implementation of coordinated approaches to screening-related 
activities, the TIM program's March 2011 analysis of alternatives did 
not lead to a solution that leveraged or established DHS capabilities--
or enterprise services--beyond what TSA already had in place under its 
existing programs.As reported in the TIM's analysis of alternatives, 
the recommended alternative that TSA chose as the most effective 
involved using TSA's existing capabilities for eligibility vetting and 
risk assessment, and purchasing commercial off-the-shelf software to 
provide the framework for some of the other capabilities for TIM. 
[Footnote 18] In an effort to meet the Acquisition Review Board's 
direction at Acquisition Decision Event 1--for TSA to look across 
other DHS modernization efforts at Customs and Border Protection, U.S. 
Citizenship and Immigration Services, and US-VISIT for possible reuse 
of enterprise services--the analysis of alternatives considered two 
alternatives that looked at leveraging one DHS program at Customs and 
Border Protection for implementing TIM.[Footnote 19] 

However, TSA's analysis did not present an approach that would use or 
consolidate a mix of DHS enterprise services from across different DHS 
component's programs to meet TIM program and future DHS needs, such as 
enrollment enterprise services from one DHS component and redress and 
waiver enterprise services from another component. Further, the 
analysis gave less weight to improving credentialing processes across 
DHS, thereby giving less importance to eliminating redundant 
activities across DHS and maximizing the reuse of existing DHS 
investments. According to the TIM Program Manager, when the analysis 
was conducted, DHS did not have the technology infrastructure and 
architecture necessary to facilitate such an approach, which would 
have required a significant rework of existing systems and processes. 
The TIM Program Manager further noted that the exercise of completing 
the analysis of alternatives and ensuing reviews highlighted existing 
challenges for leveraging capabilities across DHS and illustrated the 
need for DHS and its components to work together to mature DHS's 
capabilities. 

During the course of our review, TSA began to identify capabilities 
that might be leveraged across DHS. After TSA conducted the March 2011 
analysis of alternatives and selected its approach for implementing 
the program, DHS required the TIM program to identify additional 
opportunities for leveraging DHS enterprise services and identifying 
cost efficiencies. For example, according to TIM program officials, 
DHS directed TSA to consider using a new DHS initiative known as DHS 
virtual cloud services.[Footnote 20]TSA subsequently incorporated 
virtual cloud services into the acquisition plans for the TIM program, 
allowing the program to leverage a pool of DHS information technology 
resources instead of having to purchase and invest in separate 
information technology systems, according to TIM program officials. A 
comparison of TSA's life cycle cost estimate for using DHS cloud 
technology versus purchasing technology systems shows an estimated 
reduction of approximately $137 million, or 20 percent, from $699 
million to $562 million.[Footnote 21] 

Further, on May 6, 2011, the TIM program went before the DHS 
Acquisition Review Board for approval to issue a request for proposal 
and Acquisition Decision Event 2A, approval to progress to the 
"obtain" acquisition phase. Approval for Acquisition Decision Event 2A 
was withheld pending the completion of specified action items. For 
example, the Acquisition Review Board required TSA to complete a 
strategy for leveraging other services and related systems 
architectures in DHS instead of developing new technologies or 
capabilities, and, among other things, to identify possible services 
that the TIM program may provide to the department before it would 
approve the program. The board further required that a department-
level executive steering committee with responsibility for governing 
the TIM program be established. To address the Acquisition Review 
Board's requirements, in August 2011 TSA issued a document titled DHS 
Services Reuse for TTAC Infrastructure Modernization, which identified 
several opportunities for partnering and reuse of existing DHS 
background checking and vetting services. The document did not 
identify opportunities to leverage non-background checking and vetting 
enterprise services--such as enrollment, credential issuance, and 
revocation--from other DHS screening and credentialing programs. 
However, the document identified that the TIM program's universal 
vetting and adjudication and redress service, especially its terrorist 
vetting component, has the potential for DHS-wide reuse as an 
enterprise service, or capability. TSA noted that it would continue to 
explore options to leverage existing credentialing services. 

Eliminating redundant activities across multiple screening and 
credentialing programs could help support the goals of DHS's 
credentialing framework initiative. According to DHS and TIM program 
officials, as of September 2011, the results of the DHS Services Reuse 
for TTAC Infrastructure Modernization have been used to inform the TIM 
program's implementation strategy and fit into DHS's screening and 
credentialing strategy. Specifically, TSA is working with the DHS 
Office of the Chief Information Officer and Screening Coordination 
Office to establish a common vetting enterprise service for use by TIM 
and other DHS programs, such as the U.S. Coast Guard and the Office of 
Infrastructure Protection housed in the National Program and 
Protection Directorate. However, according to Screening Coordination 
Office and TIM program officials, as of September 2011 the programs 
that are to use this vetting enterprise service have not yet been 
officially determined. Officials further stated that this capability 
is to replace stand-alone vetting services that are provided by 
various independent components, and DHS has not yet determined which 
component will be responsible for leading this effort, according to 
the officials. A Screening Governance Board is currently being 
established to look across DHS screening and credentialing programs to 
determine where existing capabilities can be leveraged so that 
efficiencies can be found. According to an official from the Screening 
Coordination Office, part of the board's role would be to help 
determine which programs could use the vetting enterprise service 
being developed as part of the TIM program, as well as which component 
would be responsible for leading the effort. However, the board does 
not have a charter and had not met as of the date of this report. 
According to an official from the Screening Coordination Office, the 
charter has been drafted and is expected to be finalized by the end of 
December, with the first official board meeting to take place by the 
beginning of calendar year 2012. DHS and TIM program officials believe 
that these efforts will produce increased efficiencies across DHS and 
reduce duplication and cost, but it is too soon to assess the results 
of these efforts. 

Concluding Observations: 

Given DHS's current budgetary environment, it is critical that new 
investments in screening and credentialing services capitalize on 
opportunities to leverage and, where possible, consolidate existing 
DHS capabilities. TSA has made progress in its recent efforts to work 
with DHS to establish a common vetting enterprise service across DHS 
in accordance with DHS's credentialing framework initiative, DHS 
acquisition guidance, and direction from the Acquisition Review Board. 
This effort could reduce the potential for duplication and enhance the 
effectiveness and efficiency of screening and credentialing 
initiatives across DHS. However, a number of uncertainties remain, 
including what programs will use the vetting enterprise service, who 
will lead it, and what capability will actually be obtained. It is 
therefore too early to tell whether, or to what extent, this service 
will be effective in leveraging and enhancing vetting capabilities 
across DHS and for the TIM program. As TSA moves forward in helping to 
implement the enterprise vetting service, it will be important for TSA 
to continue to partner with other DHS components to find any 
additional opportunities available for reuse by DHS and the TIM 
program. By exploring solutions that could eliminate duplication and 
increase efficiencies, TSA could help DHS achieve cost effective 
solutions to securing the nation. 

Agency Comments: 

We obtained written comments from DHS, which are reprinted in 
enclosure I. In its comments, DHS did not state whether it concurred 
with the contents of the draft report but noted that the TIM effort 
will capitalize on opportunities to leverage and, where possible, 
consolidate existing DHS capabilities. DHS also provided technical 
comments, which we have incorporated where appropriate. 

We are sending copies of this report to the Secretary of Homeland 
Security, appropriate congressional committees, and other interested 
parties. This report also is available at no charge on the GAO website 
at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-4379 or lords@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 enclosure II. 

Sincerely yours, 

Signed by: 

Stephen M. Lord:
Director, Homeland Security and Justice Issues: 

Enclosures - 2: 

[End of section] 

Enclosure I: Comments from the Department of Homeland Security: 

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

December 2, 2011: 

Mr. Stephen M. Lord:
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO-12-192R, "Transportation Security Infrastructure 
Modernization May Enhance DHS Screening Capabilities, but It Is Too 
Early to Assess Results" 

Dear Mr. Lord: 

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 GAO's positive recognition of the 
progress the Transportation Security Administration (TSA) has made in 
its recent efforts to establish a common vetting enterprise service 
across DHS. We also noted the report does not contain any 
recommendations. Please know the Department remains committed to 
continuing its work to enhance screening and credentialing 
capabilities. The following paragraphs provide additional insight 
along these lines. 

TSA employs an intelligence-driven risk-based approach to prevent 
terrorist attacks and to reduce the vulnerability of the Nation's 
transportation system to terrorism. TSA works collaboratively with 
industry partners to develop and implement programs that promote 
commerce, while enhancing security and mitigating risks to our 
Nation's transportation system. 

TSA conducts security threat assessments to determine whether an 
applicant seeking access to critical components of the Nation's 
transportation system poses or is suspected of posing a threat to 
transportation or national security. Perpetually vetting over 14 
million records per day, TSA's vetting responsibilities have grown 
significantly in recent years and TSA responded by developing and 
implementing efficient, reliable, and cost-effective screening 
programs to identify any terrorist threats. 

The Transportation Threat Assessment and Credentialing Infrastructure 
Modernization (TIM) program will deliver unified and scalable 
enterprise architecture to improve vetting and credentialing services 
to current and future populations. The program will reduce the cost, 
risk, and time associated with implementing new business capabilities 
and on-boarding new populations, while improving the robust nature of 
the architecture, as well as on-going operations and maintenance 
services. 

Implementing TIM will help TSA support emerging vetting and 
credentialing population requirements with the following new mission 
capabilities: 

* Business to Government Partner Portal Services — directly processes 
enrollment requests and shares status information with airport badging 
offices via a Web portal. 

* 3rd Party/External System Interface Management Services — allows 
system-to-system interfacing with the United States Visitor and 
Immigrant Status Indicator Automated Biometric Identification System 
for processing airport biometrics (fingerprints). 

* Integrated Customer Relationship Management Services — enables 
improved security threat assessment workflow and more responsive 
customer service. 

* Enterprise Service Management — supports the transformation of the 
new and legacy system components into reusable services. 

* Enterprise Performance Reporting Management Service — provides 
monitoring and performance management capability to support end-to-end 
applicant processing. 

The TIM program aligns with TSA's strategy for innovative use of 
analytical technologies and techniques that identify and manage 
information regarding potential threats to persons, cargo, and 
commerce in the transportation arena. TIM is the first program to take 
part in the new DHS initiative known as DHS virtual cloud services. 
This modernization effort will capitalize on opportunities to leverage 
and, where possible, consolidate existing DHS capabilities. In addition,
TIM has made progress while working with DHS to establish a common 
vetting enterprise service across DHS, in accordance with DHS's 
credentialing framework initiative. 

Again, thank you for the opportunity to review and comment on this 
draft report. General and technical comments were provided under 
separate cover. 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] 

Enclosure II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Stephen M. Lord, (202) 512-4379 or at lords@gao.gov. 

Staff Acknowledgments: 

In addition to the contact named above, Jessica Lucas-Judy, Assistant 
Director; David Alexander; Charles Bausell; Joseph P. Cruz; Chris 
Currie; Susan Czachor; Pawnee A. Davis; Geoffrey Hamilton; Richard 
Hung; Sairah Ijaz; Linda Miller; Sabine Paul; Nathan Tranquilli; and 
Rebecca Wilson made key contributions to this report. 

[End of section] 

Footnotes: 

[1] See GAO, Transportation Worker Identification Credential: Internal 
Control Weaknesses Need to Be Corrected to Help Achieve Security 
Objectives, [hyperlink, http://www.gao.gov/products/GAO-11-657] 
(Washington, D.C.: May 10, 2011). 

[2] According to TSA, the agency is making several enhancements to 
better align headquarters functions to enable its continued evolution 
to a high performance counterterrorism organization. This includes 
merging various TTAC functions with the Office of Intelligence to 
ensure vetting and intelligence informs daily operations. The TTAC 
Infrastructure Modernization program is to be housed under the TSA 
Office of Intelligence and Analysis while retaining the same program 
goals and objectives. 

[3] The security threat assessment includes a TSA review of applicant 
information and searches of domestic and international government 
databases to determine if the applicant meets specified eligibility 
requirements relating to, for example, immigration status and criminal 
history, as well as having known ties to terrorism. Screening and 
credentialing programs, as used in this report, is the entire process 
of determining a person's eligibility for a particular license, 
privilege, or status, from application for the privilege or credential 
through issuance, use, and expiration or potential revocation of the 
privilege or credential. According to TSA officials, TTAC also has the 
responsibility to provide security threat assessments for critical 
infrastructure workers, such as chemical plant workers. 

[4] For the purposes of this report, services refer to individual 
business services that one or more DHS components may have access to 
and use to support broader business capabilities, or DHS enterprise 
services. For example, criminal history checking is a service provided 
by the Federal Bureau of Investigation that may be used as part of 
vetting an individual. Multiple business services could be grouped 
together to provide a vetting capability, or enterprise business 
service for use by others across DHS. 

[5] Among others, the TIM program seeks to consolidate processes and 
systems for the following TTAC programs and populations: Hazardous 
Material Endorsement Threat Assessment Program (HTAP); Transportation 
Worker Identification Credential Program (TWIC); Alien Flight Student 
Program (AFSP); International Crew Vetting Program (CVP); and Aviation 
Programs, including the Indirect Air Carrier (IAC) Population, 
Aviation Workers (AW) Program, and the General Aviation (GA) 
Population. 

[6] See GAO, Transportation Security: DHS Efforts to Eliminate 
Redundant Background Check Investigations, [hyperlink, 
http://www.gao.gov/products/GAO-07-756] (Washington, D.C.: Apr. 26, 
2007). 

[7] The DHS Acquisition Review Board was renamed the Investment Review 
Board as of October 1, 2011. 

[8] The DHS acquisition management process designates its acquisitions 
to be a level 1, 2, or 3 acquisition based on the acquisition's cost 
and risk parameters. Level 1 acquisitions are deemed to have the 
highest cost or risk parameters, and level 3 acquisitions are 
identified as having lower cost or risk parameters. The TIM program is 
designated a level 2 acquisition, with the DHS Under Secretary for 
Management designated as the program's acquisition decision authority. 

[9] DHS, Capital Planning and Investment Control Guide (Aug. 2010); 
DHS, Acquisition Management Directive 102-01 (Jan. 20, 2010); DHS, 
Acquisition Instruction/Guidebook 102-01-001 (Nov. 7, 2008); and DHS, 
Credentialing Framework Initiative (July 3, 2008). 

[10] Life cycle cost estimate figures reported in this product were 
provided by TSA. We asked TSA to explain the steps taken to construct, 
verify and validate the life cycle cost estimate data. TSA stated that 
commercial-off-the-shelf pricing information and DHS data center 
catalogs were used to identify cost data. To help ensure that all 
relevant costs and inputs were considered, TSA said a standardized 
work breakdown structure was constructed and tailored to the TIM 
program. It was then compared to similar systems to identify whether a 
critical piece could have been omitted. Cost data were input into a 
spreadsheet where initial calculations were made. Next, an automated 
cost estimating integrated tool was used to verify the data. Finally, 
TSA said all calculations were verified by hand. TSA included sunk 
costs in the life cycle cost estimates, and divided these costs into 
two categories--expended and not expended. In the March estimate, the 
obligated expended sunk costs were included, but the obligated 
unexpended sunk costs were not. However, in the August 2011 estimate, 
both obligated sunk cost categories were included. It is unclear what 
effect not including unexpended sunk costs in both estimates has on 
the reported cost savings. To identify the appropriate probability 
distributions for purposes of conducting Monte Carlo simulations, TSA 
said a variety of methods were used to arrive at probability 
distributions, such as using salary ranges, technical ranges, and 
permitting the automated cost estimating integrated tool to specify 
some boundaries based on subjective boundaries. While we did not 
assess the cost estimates against GAO's best practices criteria, based 
on the steps described by TSA, we determined the life cycle cost 
estimate to be sufficiently reliable to illustrate TSA's effort to 
estimate costs for TIM program technology acquisition alternatives. 

[11] TSA, DHS Services Reuse for TTAC Infrastructure Modernization 
(August 2011). 

[12] An enterprise architecture is a corporate blueprint that serves 
as an authoritative frame of reference for information technology 
investment decision making. According to DHS guidance, DHS's 
enterprise architecture is a management practice for aligning programs 
and projects to improve business performance and help agencies better 
execute their core missions. Enterprise architecture describes the 
current and future state of the agency, and lays out a plan for 
transitioning from the current state to the desired future state. 

[13] DHS's Acquisition Program Management Division became part of the 
Program Accountability and Risk Management Office as of October 1, 
2011. 

[14] Background checking and vetting services refers primarily to the 
resolution of derogatory information--such as terrorism information, 
criminal history, or immigration violations--to evaluate whether the 
person applying for a DHS license, privilege, or status is known to 
have been, or is appropriately suspected of being, involved in a 
disqualifying activity. 

[15] See Homeland Security Presidential Directive 11: Comprehensive 
Terrorist-Related Screening Procedures (Aug. 27, 2004). HSPD-11 
defines terrorist-related screening as the collection, analysis, 
dissemination, and use of information related to people, cargo, 
conveyances, and other entities and objects that pose a threat to 
homeland security. It also includes risk assessment, inspection, and 
credentialing. 

[16] See [hyperlink, http://www.gao.gov/products/GAO-07-756]. 

[17] DHS Acquisition Directive 102-01 established the Acquisition 
Review Board as a cross component group within the department that 
determines whether a proposed acquisition has met the requirements of 
key phases in the acquisition life-cycle framework and is able to 
proceed to the next phase and eventual full production and deployment. 
The board is comprised of the Acquisition Decision Authority (chair), 
the Under Secretary for Management, the Under Secretary for Science 
and Technology, the Assistant Secretary for Policy, the General 
Counsel, the Chief Financial Officer, the Chief Procurement Officer, 
the Chief Information Officer, the Chief Human Capital Officer, the 
Chief Administrative Officer, the Chief Security Officer, user 
representatives from components sponsoring the capability, and other 
officials within the department determined to be appropriate to the 
subject matter by the Acquisition Decision Authority. 

[18] Capabilities that commercial-off-the-shelf software would provide 
include enrollment, expiration, revocation, redress, and waiver. 

[19] Of the eight alternatives considered, two looked at leveraging 
U.S. Customs and Border Protection's Global Enrollment System 
capabilities. One alternative proposed to maximize reusing existing 
DHS capabilities by having U.S. Customs and Border Protection provide 
all screening and credentialing capabilities for TSA. However, TSA did 
not consider the alternative viable because, among other things, the 
analysis determined that TSA and U.S. Customs and Border Protection 
have very different missions. Another alternative, which TSA 
considered to be viable, also focused on having U.S. Customs and 
Border Protection provide TSA's registration, enrollment, and issuance 
services, and TSA continuing to provide the background 
checking/eligibility vetting and risk assessment service. However, TSA 
did not rank this alternative as effective for the recommended 
alternative. 

[20] DHS is implementing a private cloud capability within its two 
enterprise data centers to enhance sharing sensitive information 
across the Department. According to the DHS Chief Information Officer 
in an October 6, 2011 hearing on cloud computing, cloud services 
enable convenient, on-demand network access to a shared pool of 
computing resources to multiple users from a centralized source. Cloud 
Computing: What are the Security Implications, Hearing Before the 
Committee on Homeland Security, Subcommittee on Cybersecurity, 
Infrastructure Protection, and Security Technologies, 112th Cong. 
(2011) (statement by Richard Spires, Chief Information Officer, U.S. 
Department of Homeland Security). 

[21] The stated life cycle cost estimate figures are presented as 
reported by TIM program officials. As reported by TSA, these costs 
represent estimates at the 80 percent confidence levels and are 
reported in fiscal year 2011 dollars. Further, the life cycle costs 
were calculated for a 17-year period from Fiscal Year 2009 to 2025. We 
asked TSA officials to explain the steps taken to construct, verify, 
and validate the life cycle cost estimate data. While we did not 
assess the cost estimates against GAO's best practices criteria, based 
on the steps described by TSA, we determined the life cycle cost 
estimate to be sufficiently reliable to illustrate TSA's effort to 
estimate costs for TIM program technology acquisition alternatives. 

[End of section] 

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