Federal Law Enforcement Training Center: Capacity Planning and
Management Oversight Need Improvement (24-JUL-03, GAO-03-736).
The Federal Law Enforcement Training Center (FLETC) provides
federal law enforcement training for 75 Partner Organizations
(agencies) primarily at four domestic facilities located at
Glynco, Ga; Artesia, N. Mex.; Charleston, S.C.; and Cheltenham,
Md.. Given the post-terrorist attack security environment,
coupled with the increased demand for training, concerns have
been raised about FLETC's continued ability to meet this training
demand. Because of these concerns, GAO was asked to issue a
report on (1) how FLETC plans to meet the projected demand for
training; (2) FLETC's ability to efficiently coordinate and
schedule training activities; and (3) whether oversight and
governance structures provide the guidance it needs to address
its capacity and planning challenges.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-736
ACCNO: A07688
TITLE: Federal Law Enforcement Training Center: Capacity
Planning and Management Oversight Need Improvement
DATE: 07/24/2003
SUBJECT: Counterterrorism
Employment or training programs
Law enforcement
Law enforcement agencies
Law enforcement personnel
Police training
Strategic planning
Training utilization
******************************************************************
** This file contains an ASCII representation of the text of a **
** GAO Product. **
** **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced. Tables are included, but **
** may not resemble those in the printed version. **
** **
** Please see the PDF (Portable Document Format) file, when **
** available, for a complete electronic file of the printed **
** document's contents. **
** **
******************************************************************
GAO-03-736
Report to Congressional Requesters
United States General Accounting Office
GAO
July 2003 FEDERAL LAW ENFORCEMENT TRAINING CENTER
Capacity Planning and Management Oversight Need Improvement
GAO- 03- 736
FLETC*s overall capacity to provide training at the Glynco and Charleston
campuses is currently strained, while Artesia has been underutilized, and
Cheltenham is being upgraded and cannot operate at full capacity. FLETC is
developing a Master Plan to address how to overcome the long- term
capacity challenges, but questions exist regarding the assumptions and
methodologies used, contingency planning, cost estimation and budgeting,
and the need to address capacity shortfalls sooner than planned.
Department of Homeland Security officials intend to review the new
department*s training needs and capacities, and update the plan to reflect
its vision for law enforcement training. Within the context of its
strained training capacity, FLETC uses a predominantly manual scheduling
process that does not
ensure the efficient use of training resources and poses internal control
risks due to potential loss of scheduling materials and the lack of backup
documentation. Although FLETC has begun the process to acquire a fully
automated scheduling system, FLETC officials have yet completed important
risk management activities and are not using recognized best practices for
acquiring commercial off- the- shelf- based systems associated with this
type of acquisition. Furthermore, FLETC*s solicitation activities have not
adequately addressed security requirements. FLETC faces additional
challenges regarding its governance structure in that the status of
FLETC*s Board of Directors is unclear, and its membership, roles and
responsibilities, and past practices are not fully consistent with
prevailing governance best practices. Partner Organization Training
Projections Compared to Current Optimum Combined Campus Capacity (in
student weeks)
100,000 150,000
0 200,000
1997
130,069 140,322
160,871 154,362 132,470
150,355
1998 1999
Pre 9- 11- 01
Fiscal year
Post 9- 11- 01
2000 2001
9- 11- 01 Terrorist attacks
2002 2003 2004 2005 2006 2007 2008 250,000
300,000 PO - Projected
student weeks
Source: GAO analysis of FLETC data. 5- day/ 8- hour capacity = 199,000
265,848 283,106
232,221 230,089 228,142 224,385 Demand surge
6- day/ 8- hour capacity = 238,000 Overcapacity
zone
Note: A *student week* is defined as 5 days of training for 1 student. The
Federal Law Enforcement Training Center (FLETC) provides
federal law enforcement training for 75 Partner Organizations (agencies)
primarily at four domestic facilities located at Glynco, Ga; Artesia, N.
Mex.; Charleston, S. C.; and Cheltenham, Md.. Given the post- terrorist
attack security environment, coupled with
the increased demand for training, concerns have been raised about FLETC*s
continued ability to meet
this training demand. The visual below demonstrates the sharp increase
since the September 11, 2001, attacks. Because of these concerns, GAO was
asked to issue a report on (1) how FLETC plans to meet the projected
demand for training; (2) FLETC*s ability to efficiently coordinate and
schedule
training activities; and (3) whether oversight and governance structures
provide the guidance it needs to address its capacity and planning
challenges.
GAO recommends that the Secretary of the Department of Homeland Security
improve capacity planning, periodically assess the condition of training
facilities and infrastructure, improve the acquisition process for
an automated scheduling system, and enhance the governance and oversight
capabilities of FLETC*s
Board of Directors. The department and FLETC generally concurred with
GAO*s recommendations.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 736. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Richard M. Stana, 202- 512- 8777, Stanar@ GAO. gov.
Highlights of GAO- 03- 736, a report to
Congressional Requesters
July 2003
FEDERAL LAW ENFORCEMENT TRAINING CENTER
Capacity Planning and Management Oversight Need Improvement
Page i GAO- 03- 736 Federal Law Enforcement Training Letter 1 Results in
Brief 4 Background 7 FLETC*s Training Capacity is Strained, and Its
Planning for Adding Capacity Raises Concerns 12 FLETC*s Current Scheduling
System Is at Risk and Its Acquisition
of an Automated System Raises Concerns 24 The Status of FLETC*s Board of
Directors Is Unclear, and DHS Has Begun to Provide Oversight and Guidance
34 Conclusions 39 Recommendations for Executive Action 41 Agency Comments
and Our Evaluation 43 Appendix I Objectives, Scope, and Methodology 47
Capacity, Planning, and Coordination 48 Scheduling and Coordination of
Training Activities 49 Governance and Oversight Structure and Guidance 50
Appendix II FLETC*s 75 Partner Organizations 52
Appendix III Training Programs and Seminars Provided by FLETC 57
Appendix IV Comments from the Department of Homeland Security 59
Appendix V GAO Contacts and Staff Acknowledgments 71 GAO Contacts 71 Staff
Acknowledgements 71 Tables
Table 1: Capacity and Demand at the FLETC Campuses (in student weeks) 13
Contents
Page ii GAO- 03- 736 Federal Law Enforcement Training Table 2: Potential
Campus Capacities Following Completion of Phase I Master Plan Projects (in
student weeks) 21 Figures
Figure 1: Various FLETC Training Activities 8 Figure 2: FLETC Fiscal Year
2003 Budget Enactment and Fiscal Year 2004 Budget Request 9 Figure 3:
Partner Organization Training Projections Compared to Current Combined
Campus Optimum Capacity (in student weeks) 15 Figure 4: FLETC Campus at
Artesia, New Mexico 17 Abbreviations
ACMS Academy Class Management System ATF Bureau of Alcohol, Tobacco,
Firearms and Explosives COTS commercial off- the- shelf- based systems DHS
Department of Homeland Security FAM Federal Air Marshals FCI Facility
Condition Index FLETC Federal Law Enforcement Training Center FTE full-
time equivalent INS Immigration and Naturalization Service IT information
technology MOU memorandum of understanding O& M operation and maintenance
OMB Office of Management and Budget PO Partner Organization RFP request
for proposals SASS student administration and scheduling system SEI
Software Engineering Institute TSA Transportation Security Administration
This is a work of the U. S. Government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. It may contain
copyrighted graphics, images or other materials. Permission from the
copyright holder may be necessary should you wish to reproduce copyrighted
materials separately from GAO*s product.
Page 1 GAO- 03- 736 Federal Law Enforcement Training July 24, 2003 The
Honorable Harold Rogers Chairman, Subcommittee on Homeland Security
Committee on Appropriations House of Representatives
The Honorable Jack Kingston The Honorable Ernest J. Istook, Jr. House of
Representatives
Since its inception in the early 1970s, the Federal Law Enforcement
Training Center (FLETC), now a component of the Department of Homeland
Security (DHS), 1 has played a vital role in training personnel from
federal, state and local, and foreign law enforcement agencies. FLETC is
responsible for providing basic, advanced, specialized, and refresher
training for law enforcement officers from 75 federal law enforcement
agencies. 2 Following the September 11, 2001, terrorist attacks against
the United States, FLETC*s role and continued ability to provide law
enforcement training in a timely manner is critical in the war against
terrorism. For fiscal year 2003, according to the Director of FLETC, 65
percent of its projected training workload will come from 9 agencies
transferred to DHS.
The sudden influx of the large numbers of law enforcement personnel to
FLETC, coupled with the post- terrorist attack security environment, has
revived past concerns about the strain placed on its capacity to meet the
training demand. 3 Most recently beginning in the mid- 1990s, these
influxes
1 FLETC transferred to DHS on March 1, 2003, pursuant to the Homeland
Security Act of 2002 (P. L. 107- 296, 116 Stat. 2135). Previously, FLETC
was part of the Enforcement Division of the Department of the Treasury. 2
It should be noted that not all federal law enforcement agencies receive
their training at
FLETC. For example, the Federal Bureau of Investigation and the Drug
Enforcement Administration have their own training facilities in Quantico,
Va. 3 For this report, capacity is defined as the resources required, such
as instructors, facilities, and equipment, to achieve the optimum level of
training. Its measurement depends upon the following factors: type of
operation schedule (e. g., 5- day/ 8- hour schedule), the campus (e. g.,
Glynco), the time frame (e. g., a given fiscal year), and special
considerations (e. g., changes in training priority, mission, or policy).
United States General Accounting Office Washington, DC 20548
Page 2 GAO- 03- 736 Federal Law Enforcement Training were the result of
increases in the personnel levels of the U. S. Border Patrol; 4 the
increases were a function of initiatives to control illegal
immigration along U. S. borders. FLETC, in cooperation with the
Immigration and Naturalization Service (INS), established a separate,
temporary campus in Charleston, South Carolina, in fiscal year 1996 to
handle the demand for training Border Patrol agents because the main FLETC
campus at Glynco, Georgia, could not accommodate this influx. The current
influx has raised concerns also about the relevance, quality, and
timeliness of training provided by FLETC. These concerns, in turn, have
prompted some federal law enforcement agencies that use FLETC for their
basic training to periodically consider establishing their own facilities,
tailored to their unique training needs and philosophy. At the same time,
however, Treasury and FLETC officials have said that the consolidated
approach to federal law enforcement training has provided economy- of-
scale savings annually, although these officials could not establish the
actual amount of recent savings. According to the FLETC officials, most of
the savings accrued from (1) achieving economies of scale that enabled
them to charge training participants lower per diem rates at FLETC
facilities than those participants would have incurred at
their own training facilities and (2) avoiding the need for maintaining
redundant or duplicate training facilities elsewhere.
The issue of consolidated federal law enforcement training is of
particular interest to you and the Appropriations Committee, which is on
record as being fully committed to the principle of such training. This
report responds to an April 2002 request by Representatives Istook and
Kingston; the House Appropriations Subcommittee on Homeland Security
joined the request when it assumed jurisdiction over FLETC in Spring 2003.
On the basis of discussions with your offices, we are addressing the
following objectives:
Determine the extent to which FLETC is able to meet the current and
projected demand for training, how FLETC is planning to meet the demand,
and the associated costs; and the extent to which FLETC coordinates or
uses existing, non- FLETC government training assets, and any associated
costs.
4 On March 1, 2003, the border protection functions of the Border Patrol,
and the border protection responsibilities of certain other agencies, such
as the U. S. Customs Service and INS, were transferred to the Bureau of
Customs and Border Protection within DHS. Since they each have their own
training programs and academies at FLETC campuses, we use the terms Border
Patrol, Customs, and INS to identify these agencies throughout this
report.
Page 3 GAO- 03- 736 Federal Law Enforcement Training Examine FLETC*s
current organizational structures and processes for coordinating and
scheduling training activities and whether FLETC plans
any changes to these structures and processes. Review FLETC*s oversight
and governance structures and the extent to
which these structures are providing guidance to FLETC as it addresses its
capacity and planning challenges during a period of transformational
change.
You also asked us to review the final version of FLETC*s Master Plan.
However, DHS did not give us the final plan for FLETC in time to be
included in this report, citing its need to review the plan. Accordingly,
we based our analysis of FLETC*s planning for future facilities on the
final draft version of the plan, submitted to us in April 2003, and the
analyses of the other issues on the most recent information available. As
agreed with your offices, once the final version of the Master Plan is
provided to us
(DHS estimated that it might provide the plan in late summer 2003), and
the status of the training projections, system acquisition, and FLETC
governance becomes more apparent, we will complete our analyses and brief
you on any additional observations.
To develop our information, we visited the FLETC campuses in Glynn County,
Ga. (commonly referred to as *Glynco*); Charleston, S. C.; Artesia, N.
Mex.; and Cheltenham, Md. At the campuses, we observed training
activities; met with FLETC managers and officials in charge of training,
scheduling, information technology support, and infrastructure facilities,
and held meetings with officials from various agencies, known as Partner
Organizations (PO)* such as the Border Patrol and the Bureau of Alcohol,
Tobacco, Firearms, and Explosives (ATF)* that use these campuses. We
reviewed relevant documents, including the 1970 memorandum of
understanding (MOU) that established FLETC*s roles and responsibilities in
providing training to law enforcement agencies that are signatories to the
MOU; FLETC budget requests and related justifications; PO and FLETC
historical training statistics and projections for future training;
FLETC*s 1989 Master Plan, the 1996 Master Plan update; the 2003 draft
final Master Plan for facilities assessment, construction, and renovation;
and best practices related to facilities and information technology
acquisition and governance and internal and management control. In
addition to those we interviewed at the FLETC campuses, we met with
headquarters officials at DHS; and the Departments of the Treasury,
Justice, and Transportation and their components; and with staff from the
Office of Management and Budget (OMB). We also met with a
Page 4 GAO- 03- 736 Federal Law Enforcement Training representative of the
architectural and engineering firm in Norfolk, Virginia, retained by FLETC
to help with its future planning. 5 We
conducted our work from May 2002 through June 2003 in accordance with
generally accepted government auditing standards. Appendix I provides more
detailed information about the scope and methodology of our work.
Fueled initially by the growth in Border Patrol personnel that began in
the mid- 1990s, and currently by the surge in overall federal law
enforcement personnel levels in response to the September 2001 terrorist
attacks, the overall 5- day/ 8- hour capacity to provide training at the
Glynco and Charleston campuses is strained, while the Artesia campus has
been underutilized, and the Cheltenham campus is being upgraded and is not
fully operational (e. g., the U. S. Capitol Police is conducting limited
training using classrooms and several physical venues). FLETC has been
able to generally meet POs* needs for basic training (the training
provided to new
recruits) by, among other things, operating a 6- day schedule at the
Glynco campus and deferring POs* advanced classes (those provided to
experienced personnel). POs offered a variety of views about the effect of
the strained capacity on the training of their personnel* for example,
former Justice POs 6 noted that the quality of the training had suffered;
other POs said that although their students and instructors were fatigued
and stressed, the quality of the training was still good. FLETC officials
disputed the view that capacity constraints had a negative impact on PO
training* these officials said that based on FLETC*s own data, student
scores, for example, had not declined. The strained capacity has had an
adverse effect on the condition of FLETC facilities and the infrastructure
that supports them. Continued use of these facilities at an accelerated
rate without maintenance and renovation would likely lead to further
deterioration and exacerbate capacity challenges. FLETC has worked with an
architectural and engineering firm to develop a Master Plan to help
address long- term capacity challenges. The planning process raises
several concerns about the assumptions and methodologies
5 The firm, Clark Nexsen, Architecture and Engineering, was retained to
develop an updated Master Plan and assist in establishing a strategy to
analyze existing facilities and programs and handle future growth.
6 The POs who expressed their opinions to us about the impact of the
capacity constraints on their personnel were, at the time of our meetings,
still part of the Department of Justice. On March 1, 2003, most of these
POs moved to DHS. Results in Brief
Page 5 GAO- 03- 736 Federal Law Enforcement Training used to develop the
plan*s recommendations, and the extent to which they allow for
contingencies, such as potential future surges or declines in
demand for training; cost estimating and budgeting; and the extent to
which the plan*s recommendations would be implemented in time to help
alleviate the capacity constraints. DHS officials told us they intend to
review the plan, but might not adopt substantial parts of it, as the
department is formulating its vision for federal law enforcement training
in general and FLETC in particular* these officials said that while useful
in some respects (e. g., it contains a comprehensive inventory of the
condition of FLETC training facilities), the plan was essentially dated in
its assumptions. FLETC does not have a formal contingency plan for
addressing its capacity challenges during the period up to when facilities
recommended by the Master Plan begin coming on line and, as a practice,
has not routinely utilized alternative training assets (e. g., off- site
training
and e- learning) to provide basic training for POs. In addition to
strained training capacity challenges, FLETC faces a challenge to automate
the scheduling of training for its POs. Specifically, FLETC*s scheduling
process uses a predominantly manual scheduling process that does not
ensure the efficient use of training resources and poses internal control
risks due to potential loss of scheduling materials and the lack of backup
documentation. FLETC has recognized these risks and is in the process of
acquiring an automated student administration and scheduling system (SASS)
to address them. Although FLETC*s plans and activities for acquiring the
SASS generally include performance of certain key acquisition management
functions, FLETC has yet to address
important risk management issues associated with its SASS acquisition. 7
Moreover, with the exception of its SASS solicitation, FLETC*s plans and
activities do not incorporate recognized best practices for acquiring
commercial off- the- shelf- based systems (COTS). Furthermore, FLETC*s
solicitation activities have not adequately addressed SASS security
requirements. Taken as a whole, this means that FLETC*s SASS acquisition
is currently at risk of not delivering a system solution to best meet its
needs. Although FLETC continues to develop documentation for the SASS
proposal, at our urging, it is also working with the Border Patrol to
determine whether its existing Academy Class Management System (ACMS),
which is being enhanced with a scheduling module, can be used
7 Managing project risk means proactively identifying facts and
circumstances that increase the probability of failing to meet project
commitments and taking steps to prevent this from occurring.
Page 6 GAO- 03- 736 Federal Law Enforcement Training instead of acquiring
SASS. According to FLETC officials, if it chooses ACMS, FLETC could save
the cost of the SASS solicitation and the
system*s estimated $10 million cost over 5 years, while spending
considerably less to adopt the ACMS scheduling module.
FLETC faces challenges in its governance structure because (1) the status
of its Board of Directors is unclear as FLETC, its individual board
members, and DHS consider the Board*s future; and (2) the Board*s
membership, roles and responsibilities, and past practices are not fully
consistent with prevailing governance and internal and management control
best practices. For example, according to a FLETC official the Board did
not meet for a period of 3- 1/2 years, prior to its most recent meeting in
November 2002, even though it is required by its own charter to meet at
least quarterly; and, according to governance best practices, the
*typical* board of directors meets about eight times a year. 8 A DHS
official said that DHS has recently assumed responsibility for FLETC and
recognizes the need to provide guidance and oversight to FLETC; DHS has
begun to work with FLETC to provide guidance related to its demand and
capacity challenges. In addition, DHS recognizes the role an effective
FLETC board could play in enhancing governance. Without effective internal
and external governance and oversight, FLETC could be at risk of not
effectively addressing the transformational challenges it faces.
Because of the importance to FLETC*s ability to meet its considerable
challenges, we are making recommendations to the Secretary of DHS to
improve capacity planning, periodically assess the condition of training
facilities and associated infrastructure through the use of performance
measures, improve the acquisition process for an automated scheduling
system, and enhance the governance and oversight capabilities of FLETC*s
Board of Directors. We provided a draft of this report to DHS and to the
Department of Justice for comment. In its response, from the Under
Secretary for Border and Transportation Security, DHS generally agreed
with our conclusions and recommendations and outlined actions it either
had taken or was planning to take to implement the recommendations. DHS
also provided technical comments and clarifications, including updated
information on FLETC*s SASS acquisition; we have incorporated them in this
report where
8 However, according to our review of Board minutes, the Board did not
meet for a period of 5 years (from November 1997 to November 2002).
Page 7 GAO- 03- 736 Federal Law Enforcement Training appropriate. Justice
did not submit formal written comments; the Associate Assistant Attorney
General for Federal Law Enforcement
Training submitted an email with two general comments related to the
issues of FLETC training capacity and governance, respectively.
The September 2001 attacks spurred a significant surge in the numbers of
federal law enforcement personnel to respond to the threat posed by
terrorism. This surge, in turn, resulted in an influx of a large number of
law enforcement personnel into FLETC*s campuses around the country, over
and above their historical enrollment. Preceding the attacks, in fiscal
year 2001, over 21, 000 students spent over 101,000 student weeks 9
training at FLETC*s domestic campuses. In fiscal year 2002, primarily as a
result of the post- attack surge, over 28,000 students spent about 157,000
weeks training at these campuses. Placing the training statistics in
historical context, the weeks spent by students at FLETC in fiscal year
2002, for example, represented a 267- percent increase over the level in
fiscal year 1983 (the earliest year for which complete data were
available) and a
72- percent increase from the level of as recently as fiscal year 1999.
FLETC*s most recent adjusted domestic student training projections for
fiscal year 2003 call for about 49,000 students to train for about 259,000
student weeks, with PO projections rising to all- time highs of over
57,000 students and about 283,000 student weeks in fiscal year 2004.
FLETC was established as a consolidated interagency training facility in
the Department of the Treasury by a Treasury order dated March 2, 1970.
Subsequent to the Treasury order, an MOU between FLETC and its POs
was established in September 1970. As of June 2003, FLETC was working to
revise its MOU with its POs to reflect the move to DHS, which occurred in
March 2003, according to a FLETC official. The original MOU, which was
revised in 1977 and again in 1984, states that FLETC is responsible for,
among other things, providing recruit (basic), advanced, specialized, and
refresher training for designated criminal law enforcement personnel;
specialized law enforcement training for state and local government
personnel if space is available; facilities and student support services
necessary for specialized training conducted at FLETC by a PO; updated
9 *Student week* is the statistical measure of capacity for training;
FLETC has defined a student week as 5 days of training for one student.
For example, if 100 students receive training during a fiscal year, of
which 25 receive 3 weeks of training, 40 receive 6 weeks of training, and
the remaining 35 receive 8 weeks of training, the campus would be
providing 595 student weeks of training during that fiscal year [( 25 X 3)
+ (40 X 6) + (35 X 8) = 595]. Background
Page 8 GAO- 03- 736 Federal Law Enforcement Training training methods and
curriculum content in response to the common needs of the participating
law enforcement agencies; and dormitory space,
food service, travel, and support services; and facilities for students
trained at FLETC. The original POs were the Departments of the Interior,
Justice, State, and Treasury; OMB; the U. S. Civil Service Commission*
now the Office of Personnel Management; the U. S. Postal Service; and the
Smithsonian Institution. FLETC*s original MOU was expanded over time to
currently include the training of law enforcement personnel from 75 POs. A
list of these 75 POs appears in appendix II.
Figure 1: Various FLETC Training Activities
As shown in figure 2, for fiscal year 2003, FLETC had an enacted budget of
about $172 million, about 79 percent of which was for salaries and
expenses and 21 percent for acquisition, construction, improvements, and
Page 9 GAO- 03- 736 Federal Law Enforcement Training related expenses.
That year, FLETC had 878 full- time equivalent (FTE) permanent staff
authorized. For fiscal year 2004, the budget request
totaled about $146 million, of which about 84 percent was for operating
expenses (formerly classified as *salaries and expenses*) and about 16
percent for capital acquisition (formerly classified as *acquisition,
construction, improvements, and related expenses*). For fiscal year 2004,
the budget request calls for 754 FTE permanent staff.
Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004
Budget Request
a *Facilities* refers to *acquisition, construction, improvements and
related expenses* in fiscal year 2003 and *capital acquisition* in fiscal
year 2004. No funding was requested for major construction in fiscal year
2004. b *Human capital* refers to *salaries and expenses* in fiscal year
2003 and *operating expenses* in
fiscal year 2004. FLETC provides training at four domestic campuses. 10
Specifically, FLETC*s largest campus, which also serves as its
headquarters, is located in Glynn County, Georgia (referred to as
*Glynco*), and was established in 1975. Most of FLETC*s POs conduct their
law enforcement basic training
at the Glynco campus. FLETC*s second campus, established in 1989, is
located in Artesia, New Mexico. The resident agencies at Artesia are the
Border Patrol (for advanced training only), the Bureau of Indian Affairs,
Indian Police Academy (basic and advanced), the INS Officers Academy, the
Transportation Security Administration*s (TSA) Federal Air Marshals
10 FLETC also has oversight responsibility on behalf of DHS for the
International Law Enforcement Academy at Gabarone, Botswana.
Source: GAO analysis of FLETC data.
FLETC Fiscal Year 2003 Budget Enactment
(in thousands)
FLETC Fiscal Year 2004 President*s Request
(in thousands)
79% $136,109
21% $35,766
84% $122,379
16% $23,679 Facilities a
Human Capital b Facilities a
Human Capital b
Total $171,875 Total
$146,058
Page 10 GAO- 03- 736 Federal Law Enforcement Training (FAM), and the U. S.
Secret Service Uniformed Division. FLETC*s third campus is a former naval
base in Cheltenham, Maryland, that was
transferred to FLETC in May 2001. FLETC intends to use the Cheltenham
campus primarily as a driving and firearm re- qualification center for POs
based in Washington, D. C., and its metropolitan area. At the time of our
review, the campus was being upgraded and was not fully operational.
According to FLETC officials, the Cheltenham campus will have, among other
things, an indoor, 108- point, state- of- the- art firing range, and a
multiuse, topographically varied driving course. Currently, over 12
federal, including the U. S. Capitol Police, and state and local law
enforcement agencies are using the campus. FLETC officials at Cheltenham
anticipate that approximately 61POs will use the campus* firearms and
driving
re- qualification center. The fourth domestic campus is the Border Patrol
Academy in Charleston, South Carolina. FLETC officials said that to date,
this academy has not been placed under FLETC*s authority; however, FLETC
provides technical support to the campus for the Border Patrol training.
The campus was established in 1996 at a former naval base as a temporary
facility to handle the surge in the number of Border Patrol agent recruits
that were the result of a hiring initiative to control illegal immigration
along U. S. borders. The existing FLETC campuses could not accommodate the
Border Patrol*s surge in the resulting demand for training. In October
2002, Public Law 107- 248 directed that the Secretary of the Navy transfer
administrative jurisdiction of Charleston, in effect, to DHS, although it
is not clear whether FLETC would control the facilities. 11 In February
2003, Public Law 108- 7 established the Charleston *law
enforcement training facility* as a permanent training facility. 12 The
campus has been extensively remodeled and outfitted to provide basic
training to the Border Patrol*s agent recruits; while it was originally
scheduled to close in fiscal year 2004, if control of the Charleston
facility transfers to FLETC, it intends to keep the campus open to help
provide training capacity, regardless of who receives training there. In
addition to the training provided directly by FLETC, a number of POs, such
as the
former Customs and INS, the U. S. Marshals Service, and the Internal
Revenue Service, maintain their own *academies* at the FLETC campuses to
provide agency- specific instruction to their recruits.
FLETC offers predominantly four types of training programs* recruit
(basic), specialized, advanced, and refresher training. Appendix III
11 Department of Defense Appropriations Act, 2003 (P. L 107- 248, 116
Stat. 1519 (2002)). 12 Consolidated Appropriations Resolution, 2003 (P. L.
108- 7, 117 Stat. (2003)).
Page 11 GAO- 03- 736 Federal Law Enforcement Training provides a detailed
description of the variations of training programs and seminars FLETC
offers. Basic training (i. e., training provided to new
recruits) has represented the greatest demand for FLETC*s resources of all
four types of programs given the increase in Border Patrol and the surge
in federal law enforcement hiring since the September 11 attacks. Basic
training is mandatory for entry- level federal law enforcement personnel,
such as those hired by the Border Patrol, and is usually provided during
the first year of employment to familiarize recruits with law enforcement
skills and operations. Basic training also extensively uses FLETC*s
training facilities, including firearm and driver training facilities, in
addition to classrooms and other physical education facilities.
For specialized training programs, such as agency- specific basic training
programs (i. e., training provided by agencies immediately following
FLETC*s basic training), FLETC has the responsibility for providing
instructors for the parts of the program that are standard to FLETC*s
curriculum, while the agency provides the part of the curriculum more
specific to its mission. For example, FLETC provides the instructors for
the Courtroom Testimony Lecture and shares responsibility with the Border
Patrol for the Courtroom Testimony Laboratory. ATF and the Environmental
Protection Agency, in addition to the Border Patrol are examples of
agencies requiring specific programs as part of their basic training
program. For the sections of the program that are not designated as a
FLETC responsibility, the PO must provide instructors. FLETC also
evaluates these programs to ensure that PO training objectives are being
met.
Advanced training is usually provided to junior and senior- level law
enforcement personnel as part of their continuing professional
development. An agency that maintains its own academy at a FLETC campus,
such as the Border Patrol, will typically use its own instructors for
advanced training. If it has instructors available, FLETC may sometimes
assist an academy with advanced training. Advanced training includes (1)
training of inspectors or agents to be instructors; (2) *followon basic*
training, where skills particular to an agency mission are taught; and (3)
in- service training, which is typically an intensive seminar on a current
issue or the development of a law enforcement or management skill.
FLETC also provides refresher training for its POs. For example, law
enforcement personnel in the Washington, D. C., area will be able to
receive refresher training in firearms and vehicle operation re-
qualification at FLETC*s Cheltenham campus.
Page 12 GAO- 03- 736 Federal Law Enforcement Training FLETC*s overall 5-
day/ 8- hour capacity to provide training at the Glynco and Charleston
campuses is currently strained, while the Artesia campus
has been underutilized. The Cheltenham campus is being upgraded and is not
fully operational, thus its contribution to FLETC*s overall capacity is
limited. POs offered a variety of views about the effect of the strained
capacity on the training of their personnel* for example, former Justice
POs now in DHS believed that the quality of the training had suffered,
while other POs said that although their students and instructors were
fatigued and stressed, they believed that the quality of the training was
still good. The strained capacity has had an adverse effect also on the
condition of FLETC facilities and the infrastructure that supports them;
further deterioration could exacerbate capacity challenges. FLETC has
worked with an architectural and engineering firm to develop a Master Plan
to help overcome the long- term capacity challenges, although DHS
officials said that the plan might no longer be germane to the
department*s vision for law enforcement training. The planning process
raises several concerns about the assumptions and methodologies used to
develop the plan*s recommendations, and the extent to which they allow for
contingencies, such as future surges or declines in demand; cost
estimating and budgeting; and the extent to which the plan*s
recommendations would be implemented in time to help alleviate the
capacity constraints. FLETC does not have a formal contingency plan for
addressing its capacity challenges during the period up to when facilities
recommended by the Master Plan begin coming on line and, as a practice,
has not routinely utilized alternative training assets to provide basic
training for POs. Primarily as the collective result of the surge in
Border Patrol personnel levels begun in the mid- 1990s and the surge in
overall federal law enforcement personnel following the September 2001
terrorist attacks, the overall capacity to provide basic training at
Glynco and Charleston is strained. As shown in table 1, the latest
available PO- projected demand 13 exceeds the 5- day/ 8- hour capacity for
fiscal year 2003, at these two
training campuses. The combined capacity for a 5- day/ 8- hour workweek at
13 FLETC uses PO projections of demand for training as part of its
capacity planning. In March/ April of each year, POs submit to FLETC their
projections for training. These projections are generally a function of
the need for personnel and expected funding levels. In June of each year,
FLETC, in consultation with POs, adjusts the projections, in recent years
by less than 5 percent. In addition to the projections they submit,
throughout the year, POs may submit requests to add, defer, or cancel
classes. FLETC*s Training
Capacity is Strained, and Its Planning for Adding Capacity Raises Concerns
FLETC*s Training Capacity Is Strained at the Glynco and Charleston
Campuses
Page 13 GAO- 03- 736 Federal Law Enforcement Training the three FLETC
campuses is about 67,000 student weeks short of projected demand, and for
a 6- day/ 8- hour workweek about 28,000 student weeks short of the
projected demand. Table 1: Capacity and Demand at the FLETC Campuses (in
student weeks)
Campus Optimum 5- day/ 8- hour capacity Optimum 6- day/ 8-
hour capacity Fiscal year 2003
projected demand
FLETC estimated actual attendance
(as of 4/ 30/ 03) Difference between
projected demand and
estimated attendance
Glynco 192,494 148,311 44,183 November 2002 120,000 144,000 March 2003
(temporary
increase in capacity) 135,000 162,000 Charleston 37,000 44,000 41,259
33,816 7,443 Artesia 27,000 32,000 32,095 18,556 13,539
Total 199,000 238,000 265,848 200,683 65,165
Source: GAO analysis of FLETC data.
However, also as shown in table 1, FLETC is estimating (as of April 30,
2003) that the actual number of student weeks spent at the three campuses
will total 200,683 student weeks, or 25 percent less than the fiscal year
2003 projected levels. A FLETC official said that it is not unusual for
actual attendance to fall short of projections because of factors such as
recruiting shortfalls, funding reallocations, and classes that begin with
less than their full complement. In fact, actual attendance (in student
weeks)
fell short of projections as recently as fiscal year 2001, when attendance
was about 76 percent of the projected level. In fiscal year 2002, actual
attendance was about 112 percent of the projected level.
The FLETC official attributed the difference in fiscal year 2003 to three
principal factors. First, changes in TSA*s projections* TSA originally
projected about 49,000 student weeks of training primarily for airport
security officers, and for *flight deck officers* (i. e., airline pilots
trained to carry firearms in cockpits) and FAMs. However, the TSA
projections have not materialized to date, with the estimated actual
attendance totaling
about 10,000 student weeks. Second, changes to the Border Patrol*s
projections* the Border Patrol originally projected about 46,000 student
weeks of training for agents. However, the estimated actual attendance
totals about 33,000 student weeks. Third, changes to the former INS*s
projections* INS originally projected about 50,000 student weeks of
training for inspectors and agents. However, the estimated actual
Page 14 GAO- 03- 736 Federal Law Enforcement Training attendance totals
about 40,000 student weeks. A FLETC official cautioned that the final
actual attendance for fiscal year 2003 might be different than the
estimates based on additional requests, DHS reorganization training
guidelines, attrition, and additional hiring budgets. For example, there
is a possibility that if funding is restored, TSA may yet end up needing a
number of the student weeks it originally projected.
Even if the fiscal year 2003 projections do not ultimately materialize,
FLETC*s 5- day/ 8- hour capacity would still be strained. Specifically,
the total estimated actual attendance of 200,683 student weeks will exceed
the combined 5- day/ 8- hour capacity of 199,000 student weeks by about
1,700 student weeks. In discussing the capacity strains facing FLETC, we
note that *student weeks* provides FLETC with a statistical measure of
optimum throughput, or best case, training capacity (see footnote 3). This
measure assumes that all of the requisite facilities, instructors, and
equipment will be available to provide training when needed. However,
capacity is ultimately a function of facilities, instructors, and
equipment that are actually available to provide training at a point in
time. Accordingly, while a number of student weeks may appear to be
*available* (for example, as in the case of the Charleston campus, where
estimated actual attendance is about 3,000 student weeks below the
campus*s 5- day/ 8- hour capacity); at any given time, a number of
physical and human *choke points,* or training obstacles, either
individually or collectively result in capacity constraints. Thus, the
choke points essentially reduce the number of available student weeks from
the bestcase level.
In this regard, a number of choke points are causing the capacity strains
that the Glynco and Charleston campuses are experiencing. Specifically,
according to FLETC, the principal choke points that are collectively
causing the capacity strain at Glynco are the firearms ranges, driving
ranges, practical exercise facilities, the dining hall, classrooms,
dormitories, and a shortage of instructors and support staff. At
Charleston, the choke points include the firearms ranges, driving ranges,
and a shortage of instructors* illustrating the effect of choke points on
capacity at Charleston, during fiscal year 2003, the Border Patrol had to
defer 3 classes of agent training because the campus*s emergency response
driving range had to be taken off- line for resurfacing. According to
FLETC officials, had these classes actually taken place, Charleston*s 5-
day/ 8- hour capacity would have been met or exceeded.
On the basis of the latest PO projections for training demand, FLETC*s
overall capacity strain is expected to continue for fiscal year 2004.
Page 15 GAO- 03- 736 Federal Law Enforcement Training However, for fiscal
years 2005 through 2008, PO projections show a relatively stable decrease
in demand from fiscal year 2004 peak levels, but projected demand still
exceeds FLETC*s fiscal year 2003 5- day/ 8- hour
capacity and is approaching the current 6- day/ 8- hour capacity. Figure 3
shows the difference between combined projected demand and combined
current capacity of FLETC facilities for fiscal years 1997 through 2008.
Figure 3: Partner Organization Training Projections Compared to Current
Combined Campus Optimum Capacity (in student weeks)
Note: This graph includes the Glynco, Artesia, and Charleston campuses.
While capacity at the Glynco and Charleston campuses has been strained,
the Artesia campus has been underutilized following the completion of
FAM*s ramped- up training during fiscal year 2002. In this regard, as
shown in table 1, Artesia has an annual capacity of 27,000 student weeks
for a 5- day/ 8- hour schedule and 32,000 student weeks for a 6- day/ 8-
hour schedule. In fiscal year 2002, PO trainees spent 19, 188 student
weeks at Artesia, well short of capacity. Although PO demand projections
of 32,095 student weeks initially suggested that the Artesia campus would
experience some minor capacity strains in fiscal year 2003, it is not
clear that the campus will be fully utilized. Specifically, based on year-
to- date attendance data through April 2003, FLETC estimated that 18, 556
student Artesia Campus Has Been Underutilized
100,000 150,000
0 200,000
1997
130,069 140,322
160,871 154,362 132,470
150,355
1998 1999
Pre 9- 11- 01
Fiscal year
Post 9- 11- 01
2000 2001
9- 11- 01 Terrorist attacks
2002 2003 2004 2005 2006 2007 2008 250,000
300,000 PO - Projected
student weeks
Source: GAO analysis of FLETC data. 5- day/ 8- hour capacity = 199,000
265,848 283,106
232,221 230,089 228,142 224,385 Demand surge
6- day/ 8- hour capacity = 238,000 Overcapacity
zone
Page 16 GAO- 03- 736 Federal Law Enforcement Training weeks will actually
be spent at Artesia, well short of the levels originally projected by POs.
As discussed earlier, according to FLETC officials, the shortfall is
primarily caused by TSA*s original projections for training not
materializing* part of this training was to be held at the Artesia campus.
FLETC officials cautioned, however, that the final actual attendance might
be different than the April 2003 estimate, and could be somewhat closer to
the original projection based on additional PO requests, DHS
reorganization training guidelines, attrition, and additional hiring
budgets. In addition to Artesia*s underutilized housing and firearms
ranges, the live- fire shoot houses and three Boeing 727s, specially
configured for terrorism training, have not been used since the FAMs
completed their training (see figure 4). A FLETC official indicated that
it is conducting marketing and other types of activities to attract a
number of additional users to the campus. In this regard, several POs told
us that they considered Artesia to be too remote of a location to send
their recruits and, especially, their instructors for training. The FLETC
officials stressed that the Artesia campus could not, as currently
configured, and discussed
later, handle the transfer of the Border Patrol*s basic training from the
Charleston campus to Artesia, as proposed in the Master Plan. If the
transfer were to occur, the Border Patrol*s projected fiscal year 2003
demand for training would exceed Artesia*s 5- day/ 8- hour capacity by at
least 6,000 student weeks and up to 14,000 student weeks, depending on the
schedule adopted.
Page 17 GAO- 03- 736 Federal Law Enforcement Training Figure 4: FLETC
Campus at Artesia, New Mexico Despite its strained capacity, FLETC has
nevertheless been able to generally meet its POs* demand for basic
training principally by, among
other things, operating on a 6- day, multiple- shift training week at
its Glynco campus to overcome constrained resources; deferring some
training programs for certain POs that were not originally projected and
that were made late in the year* for example, the Secret
Service, Customs, and the General Services Administration*s Federal
Protective Service made such requests; canceling or deferring some of
the POs* advanced training classes
following the September 2001 attacks* FLETC rescheduled about 5 percent of
these classes within the fiscal year; continuing to schedule and conduct
Border Patrol*s basic training at the
Charleston campus, in cooperation with the Bureau of Customs and Border
Protection/ Border Patrol; rotating instructors to most needed areas of
work; and converting buildings and trailers that had been previously
utilized for
office space into training facilities such as raid houses, mat rooms,
classrooms, and firearms simulations. FLETC Has Generally Met PO Needs for
Basic
Training
Page 18 GAO- 03- 736 Federal Law Enforcement Training We note that while
this approach may have helped mitigate the capacity constraints in the
short term, deferring or canceling training may
exacerbate any potential future strains on FLETC capacity* this training
would likely need to be made up sometime in the future* and result in law
enforcement personnel not being available for duty when needed.
POs offered a variety of views about the effect of FLETC*s strained
capacity on their training, in terms of, among other things, trainee
attrition, the quality and timeliness of instruction, and instructor
morale and retention. For example, representing the views of Justice POs
(prior to their transition to DHS), a senior Justice official said that
the strained capacity* and especially the need to train 6 days a week at
Glynco* had resulted in higher attrition rates for trainees and fatigue,
burnout, and low morale for instructors. In addition, according to this
official, the quality of instruction, and thus that of the training
received, had suffered. Further, a
May 2002 internal Justice report on FLETC training issues noted that one
of its component agencies had to cancel all of its *badly needed* advanced
training due to the lack of space at FLETC. In commenting on a draft of
this report, FLETC said that the PO was actually asked to shift its
training within the fiscal year but declined to do so. The Justice report
also noted that the 6- day training arrangement caused additional problems
for Justice POs, including having to pay overtime and having difficulty in
attracting and retaining instructors. Separately, a former Treasury PO
reported that FLETC had to defer basic training for 168 agent recruits
because of
capacity constraints* since they could not be trained, and thus not
deployed, these recruits were assigned nonagent, desk work. Basic training
for recruits hired by September 2002 was to be completed in about 11
weeks. However, capacity strains caused FLETC to train the recruits in
stages, with some not completing their training until February 2003. FLETC
officials disputed the POs views that capacity constraints had had a
negative impact on training. These officials said that based on FLETC*s
own data for the period of the capacity constraints, overall student test
scores had not declined in a statistically significant manner over time,
and student surveys continued to show a high level of satisfaction with
FLETC*s training services. Regarding the aforementioned example of the
Treasury PO deferral, FLETC said that the PO*s request was for 240
students and was not initially projected. FLETC also said that it was
actually able to accommodate immediately 72 of the students.
Other POs indicated that while their instructors and students generally
experienced greater fatigue and stress as a result of FLETC*s capacity
constraints, the quality of the training had not suffered significantly.
For PO Views about the Effect
of the Capacity Strains on Their Personnel
Page 19 GAO- 03- 736 Federal Law Enforcement Training example, one PO said
that although there was a slight decline in student test scores, it was
unclear whether this decline could be attributed
exclusively to the capacity strain. The same PO reported that the extended
hours resulting from the constraints actually allowed its trainees to
complete their training in 9 weeks instead of 11, allowing them to be
deployed to duty assignments sooner.
FLETC*s implementation of 6- day, multiple- shift training at Glynco to
help alleviate the capacity constraints at that campus has led to the
intensive scheduling of its facilities. Such above- average usage of
facilities places additional loads and strains on their systems and
components, increasing the need for maintenance and repair. 14 Maintenance
programs and renovation projects are often deferred, according to FLETC
officials, due to the lack of funding or an ability to only schedule
facility *down time* for maintenance in the evenings and on Sundays.
Cheltenham, for example, has an electrical system that is subject to
failure at any time and a chlorination system that has failed, resulting
in the need to provide bottled water for drinking. At the time of our site
visits, utility upgrades were needed at Glynco, Cheltenham, and Artesia,
and road and parking upgrades were needed at Glynco and Cheltenham; many
facilities at Glynco are now only available for maintenance during evening
hours or on Sundays. Although not quantifiable at this point, continued
deterioration of facilities would likely lead to increased capital
requirements in the future and adversely affect employee working
conditions and retention. 15 FLETC has considered the degradation issue in
some of its internal
reports; however, FLETC does not have any immediate contingency plans to
address facility degradation. Such planning would be vital to help address
the potential impact of facility degradation on FLETC*s already strained
capacity. Many organizations use periodic facility condition assessments
to establish baseline facility data and to aid in planning for short- and
long- range facility maintenance and repair needs. Currently, FLETC does
not have detailed information about the condition of its facilities. A
*Facility Condition Index* (FCI) would help to address the degradation
issue by giving measurable performance data about its facilities rather
than relying on anecdotal information. An FCI is the ratio
14 National Research Council, *Stewardship of Federal Facilities* A
Proactive Strategy for Managing the Nation*s Public Assets,* (Washington,
D. C.: National Academy Press, 1998). 15 Ibid. Capacity Strains Have
Impacted the Condition of Facilities and Supporting Infrastructure
Page 20 GAO- 03- 736 Federal Law Enforcement Training of the cost of
maintenance and repair deficiencies to the facility*s current replacement
value. A FCI value of less than 0.05 is generally considered to
represent a *good* facility condition. The draft final version of the
Master Plan concluded that although FLETC had done a commendable job in
handling the ever- increasing demand for training, it had done so at a
price. Part of this price has been the degradation of its facilities*
funding has been focused on building new facilities to alleviate choke
points, while maintenance and renovation have been continuously deferred
due to the lack of funding. Echoing our own concerns about this issue, the
firm that developed the plan concluded that continuation of this cycle
will eventually result in building element or critical infrastructure
failures and made recommendations for renovations and expansion as part of
its broader three- phase approach for improving
and expanding FLETC*s capacity. The Master Plan*s recommendations for
renovation and expansion of existing, and the construction of new
facilities are arrayed in three, partly overlapping, 5- 7 year
construction phases for each of the campuses (except Charleston, which
FLETC had, at the time the Master Plan was being developed, assumed would
close by 2004). The first phase of construction extends at maximum from
2006 to 2011, the second from 2009 to 2015, and the third from 2013 to
2019. Each phase includes a mix of renovation and expansion projects, as
well as the construction of new facilities. According to FLETC, the extent
of additional capacity, in terms of student weeks, would depend on the
completion of the construction projects, the programmatic mix, and other
factors (e. g., the requisite staffing being available). As shown in table
2, if the plan*s prioritized list of construction projects for phase 1
were to be completed, and the programmatic mix and other factors did not
change, the capacities of Glynco and Artesia would increase as follows:
for Glynco, 193,500 student weeks for the 5- day/ 8- hour schedule,
232,000 student weeks for the
6- day/ 8- hour schedule, and 278,000 student weeks for the 6- day/ 12-
hour schedule; for Artesia, 55,000 student weeks for the 5- day/ 8- hour
schedule, 66,000 student weeks for the 6- day/ 8- hour schedule, and
79,000 student
weeks for the 6- day/ 12- hour schedule. The Cheltenham campus is not
included since it is being upgraded and FLETC currently does not intend to
use the campus as a residential facility. FLETC Master Plan
Intended to Help Alleviate Capacity Constraints
Page 21 GAO- 03- 736 Federal Law Enforcement Training Table 2: Potential
Campus Capacities Following Completion of Phase I Master Plan Projects (in
student weeks) Campus 5- day/ 8- hour 6- day/ 8- hour 6- day/ 12- hour
Glynco 193,500 232,000 278,000 Artesia 55,000 66,000 79,000
Total 248,500 298,000 357,000
Source: GAO analysis of FLETC data.
The April 2003 final draft of the plan estimates the combined cost of the
three phases to be about $907 million; the estimate includes costs for
construction and furnishings and fixtures but excludes operation and
maintenance (O& M) costs. O& M costs are estimated separately for the
period of 2008 through 2040 from the project costs and total about $269
million.
The FLETC Master Plan*s assumptions and methodologies in particular, and
FLETC*s plan to address its capacity constraints in general, raise a
number of concerns. First, the plan assumes that the Border Patrol will
shift its basic training from the Charleston campus to the Artesia campus
and that the Charleston campus will close. 16 However, as indicated
earlier, the Consolidated Appropriations Resolution, 2003 (Public Law 108-
7), established the Charleston *law enforcement training facility* as a
permanent training facility. While the Department of Defense
Appropriations Act, 2003 (Public Law 107- 248) directed the Secretary of
the Navy to transfer administrative jurisdiction of the Charleston law
enforcement training facility to, in effect, the DHS, it is not clear
whether FLETC will be the entity within the department to assume
responsibility of the facility, and which FLETC POs, if any, will receive
training there.
16 There were, in the past, some congressional committee expectations that
the temporary training facility at Charleston would close. In 1998, for
example, a House Appropriations Committee report, citing a commitment to
the principle of consolidated federal law enforcement training through
FLETC, expressed an expectation that the administration would strive to
close the temporary training facility at Charleston. H. R. Rep. No. 105-
592 (1998). In March 2000, the then Director of FLETC testified before the
Senate Committee on Appropriations, Treasury and General Government
Subcommittee, that plans, at that time, called for Charleston to be closed
by the fiscal year 2004 time frame, once the training requirements for the
new Border Patrol hires were completed and/ or new facilities became
available to accommodate the training at FLETC*s permanent locations. S.
Hrg. 106- 712 at 152 (March 30, 2000). FLETC*s Planning to
Address Its Capacity Constraints Raises Concerns
Page 22 GAO- 03- 736 Federal Law Enforcement Training Second, the Master
Plan assumes that the training schedule at Glynco will return to a 5- day/
8- hour week, but a FLETC official acknowledged that a
return to such a shift for basic training is unlikely in at least fiscal
year 2004, given the current and projected demands for training at the
campus. Third, the plan assumes a set of baseline projections of future
demand for training for each of the campuses from which future facility
needs are generated. These Master Plan projections are lower than the
latest projected attendance levels that FLETC is currently facing.
Specifically, while several baseline workload scenarios were originally
considered, only one was actually utilized to estimate the future need for
facilities. Using a single baseline is questionable because it excludes
accounting for possible future increases or decreases in the demand for
training that would render the original baseline obsolete.
Fourth, the plan assumes constant (or straight- line) growth rates in
projecting the need for additional facilities at each FLETC campus.
However, these growth rates are based on historical precedent and do not
fully take into account recent events such as today*s new security
environment and the resulting surge in the demand for training of law
enforcement personnel, and do not take into account future events such as
potential further surges, or declines, in training demand, or changes in
the attrition of federal law enforcement personnel. Finally, the plan does
not assume potential efficiencies that might result from FLETC*s planned
automation of its system for scheduling training (discussed below). Use of
such an automated system could result in more efficient scheduling of
facilities. The firm that developed the plan acknowledges that if
efficiencies were to be achieved through the automation of scheduling, the
plan would need to be revised.
Concerns about FLETC*s planning also involve the Master Plan*s cost
estimates and future budget requests for construction and the extent to
which the plan*s phase 1 recommendations would be implemented in time to
begin alleviating the capacity constraints. Regarding the cost estimates,
the Master Plan*s estimates should be treated with considerable caution.
Specifically, although we did not analyze the plan*s estimates in detail,
we note two broad concerns. First, because the plan*s recommendations have
not proceeded beyond the conceptual or early design stage, the cost
estimates are likely to be very *soft,* with considerable potential upside
tendency* at the conceptual stage; costs are likely to vary by as much as
50 percent. Second, the plan*s recommendations and their design may be
altered by DHS as part of its ongoing review of the plan (discussed
later),
thus changing the estimated costs. Further, a FLETC official said he
identified a number of cost errors as part of his review of the April 2003
Page 23 GAO- 03- 736 Federal Law Enforcement Training version of the final
draft of the plan* these errors involved life cycle- costs, O& M costs,
and architectural and engineering fees. We also found, and
brought to FLETC*s attention, cost discrepancies between the 90- percent
and final draft versions of the plan*s phase 1 construction totaling over
$100 million. For the entire plan, the discrepancies totaled over $200
million. A FLETC official concurred that there were discrepancies and told
us that FLETC was working to resolve them. In terms of future budget
requests for construction, the estimated costs for the first phase of the
Master Plan are more than five times the total appropriated amounts for
new facilities and renovations for fiscal years 2001 through 2003 and the
request for fiscal year 2004. A FLETC budget official said that in terms
of lead time to fund the plan*s recommendations, FLETC, in keeping with
its past practice, would likely request the entire amount up front for all
approved projects. Based on capital acquisition best practices, this
approach is not unusual in the construction field. In this regard, a DHS
official said that a request for construction expenditures for training
facilities was not expected until the fiscal year 2005 budget cycle.
In terms of the timely implementation of the Master Plan*s
recommendations, construction of the projects recommended in the plan*s
first phase would not begin to be completed until 2008 at the earliest,
leaving a gap of at least 5 years of continued strained capacity that
would need to be addressed through other means.
Adding to the long- term challenge of addressing its capacity constraints,
FLETC does not currently have a formal written training contingency plan
independent of the Master Plan for addressing its immediate training
capacity challenges, or the challenges leading up to when the plan*s
recommendations are expected to come on line in 2008. FLETC officials said
that although they would like to have a written training contingency plan,
and had been developing a contingency planning process, they were
operating in an essentially reactive mode to address the more immediate
issue of responding to continuing surges in the demand for training. In
this regard, a FLETC official said that in this regard it would consider
adding
more shifts to the Glynco campus if needed. Further, FLETC neither has, as
a routine practice, utilized alternative training assets to provide basic
training for its federal POs (including offsite training locations, e-
linkages, and satellite communications), nor does it have a formal plan
for doing so. FLETC officials indicated that these measures were to be
given more consideration in the future as a means of addressing campus
capacity strains. FLETC officials explained that they FLETC Does Not Have
a
Contingency Plan to Address Capacity Constraints and Has Not Routinely
Utilized Alternative Assets to Provide Basic Training
Page 24 GAO- 03- 736 Federal Law Enforcement Training had been reluctant
to provide PO training in facilities they did not own because they could
not control the training schedule, given the absence of
ongoing arrangements with the owners of such facilities. Instead,
according to FLETC officials, on a limited and informal basis, FLETC
facilitated the use of alternative training facilities by some law
enforcement agencies when it could not immediately accommodate their
training needs. A FLETC working group initiated by DHS is currently
reviewing the extent to which training assets* in addition to the FLETC
campuses* owned by DHS component agencies can be used for training. DHS
officials said that the department was in the process of reviewing the
Master Plan, to be followed by an OMB review. Without offering details,
they also said that although useful in some respects, the plan might not
be germane as the department develops its vision of law enforcement
training for FLETC. These officials said they considered the plan useful
as a tool in identifying the condition of existing FLETC facilities and
the need for expansion. However, they did not view the plan as a roadmap
for the future. A DHS official expected the review process of the plan to
be completed by mid July 2003.
In concert with its review of the Master Plan, DHS has tasked FLETC to
chair a working group* the Training Academy Charter Committee* comprised
of department component agencies to inventory their training assets and
develop a coordinated strategy so that these assets are used effectively
to provide training. FLETC*s specific task is to develop a survey
instrument, collect and analyze the survey results, and play a role in
developing recommendations. A FLETC official expects the committee*s work
to be completed by July 2003.
Within the context of strained training capacity, FLETC*s scheduling
process poses internal control risks. FLETC relies on a predominantly
manual scheduling process that does not ensure the efficient use of
training resources and poses internal control risks due to potential loss
of scheduling materials and the lack of backup documentation. FLETC has
recognized these risks and is in the process of acquiring an automated
system, SASS, to address them. Although FLETC*s plans and activities for
acquiring SASS generally include performance of certain key acquisition
management functions, FLETC officials have yet to address important risk
management issues associated with its SASS acquisition. Moreover, with the
exception of its SASS solicitation, FLETC*s plans and activities do not
incorporate recognized best practices for acquiring commercial off- the
DHS Is Reviewing FLETC*s
Master Plan, but Considers It of Limited Future Use
FLETC*s Current Scheduling System Is at Risk and Its Acquisition of an
Automated System Raises Concerns
Page 25 GAO- 03- 736 Federal Law Enforcement Training shelf- based
systems. FLETC*s solicitation activities have not adequately addressed
SASS security requirements. Taken as a whole, this means that
FLETC*s SASS acquisition is currently at risk of not delivering a system
solution to best meet its needs. While FLETC continues to develop the SASS
request for proposals (RFP)* at our urging, it is also working with the
Border Patrol to determine whether its existing ACMS can be used instead
of acquiring SASS.
FLETC*s current system for scheduling training places efficient delivery
of training services at risk. FLETC*s scheduling system is predominantly
manual and only partly automated. The manual part of the system involves,
among other things, the use of large desk calendars, colored markers, and
color- coded post- it notes to schedule things such as student classes,
student housing, classrooms, instructors, language and computer
laboratories, firing ranges, driving ranges, and mat rooms. As schedules
change, for example, the notes are moved on the calendar to different
dates; cut- and- pasting is also used to change schedules. Markers are
used to color blocks of dates for training by particular POs. FLETC*s
scheduling subsystems at three of the four 17 campuses are also
predominantly manual systems that require labor- intensive corrections if
even one course is changed. In addition, the scheduling subsystems do not
interface with one another, thus requiring time- consuming efforts to
communicate.
The paper- intensive nature of the system raises issues of internal
control. FLETC*s ability to adequately schedule training for most of its
75 POs at its campuses is further hampered by its reliance on certain key
schedulers to keep the system functioning. The campuses in Charleston and
Artesia each
have a single scheduler to handle all of the scheduling, without any
backup. Further, at the Glynco campus, the loss of key scheduling
documents that are currently kept in a single *master binder* without a
backup could significantly hamper FLETC*s scheduling. FLETC schedulers
said that if this binder were to be lost or destroyed, they would have to
undertake a time- consuming process to manually recreate most of the
training schedules by soliciting relevant information from affected POs.
In this regard, according to the Comptroller General*s standards for
internal 17 At FLETC*s fourth campus, in Cheltenham, Maryland, the Capitol
Police reports its daily student throughput to FLETC*s Cheltenham
Scheduling Office and schedules use of buildings and grounds. Current
Scheduling System
Places the Delivery of Training Services at Risk and Does Not Maximize Use
of Existing Facilities
Page 26 GAO- 03- 736 Federal Law Enforcement Training control, 18
vulnerable assets, in this case the master binder, should be subject to
secure physical control in order to be safeguarded against loss;
in addition, a disaster recovery plan helps recover from a loss. The
standards also call for the accurate and timely recording and
documentation of transactions and significant events, in this case the
scheduling of training. According to the standards, documentation of
transactions and events needs to be complete and accurate to facilitate
tracing from initiation to completion. FLETC has acknowledged the manual
scheduling system*s shortcomings
and its implications for efficiency and risk management. FLETC officials
told us that its scheduling system does not provide for the optimal use of
existing facilities, especially for sequencing classes. For example, only
one class can use a 4- course driving range at any given time; while the
class completes one course, the other three remain idle. More efficient
scheduling would enable four classes to rotate through the driving range*s
courses. The Master Plan*s analysis also suggests that automating the
scheduling could help gain efficiencies in the use of existing facilities.
FLETC officials have recognized the need for a fully automated system that
can address FLETC*s vast scheduling needs, including quickly incorporating
any changes once a schedule has been prepared. In this regard, FLETC
listed in its draft SASS RFP the challenges, and their effects, associated
with its manual system. The draft RFP stated that current business
processes in support of FLETC*s student administration and scheduling were
complex, not integrated, and were often performed
manually. Historically, according to the draft RFP, this has resulted in
(1) FLETC schedulers reacting to ever- changing training projections; (2)
a manual, paper- laden, and slow student scheduling and registration
process requiring student information to be entered into multiple data
systems; and (3) inconsistent student information processed throughout the
system and numerous changes caused by ever- changing projections in the
demand for training. A FLETC official also said that a manual
recalculation and
distribution of class schedules each time a change is made to a single
class.
18 See U. S. General Accounting Office, Internal Control Standards:
Internal Control Management and Evaluation Tool, GAO- 01- 1008G
(Washington, D. C.: Aug. 2001).
Page 27 GAO- 03- 736 Federal Law Enforcement Training The SASS acquisition
project began in 1999, when Congress provided FLETC with $350, 000 to
begin planning for automating its scheduling
process. After completing requirements definition in December 2000 and its
market research activities in December 2001, FLETC decided to expand the
project to provide a training management system, rather than just a
scheduling system. In researching SASS alternatives, FLETC officials
determined that utilizing commercially available components or products
was its preferred alternative. Accordingly, FLETC decided to pursue a
COTS. FLETC began developing its request for vendor proposals in 2001 and
in May 2002 FLETC issued a request for proposals, a solicitation package
that included background on the project, project objectives, system
requirements, and other information. However, according to FLETC
officials, vendors were concerned about the time and expense required to
submit an adequate proposal as well as the criteria proposed to evaluate
potential solutions. As a result, FLETC withdrew the solicitation
and is currently revising it to address these concerns. According to a
FLETC official, issuance of the SASS RFP has been delayed, pending the
outcome of an effort to determine whether a similar system being developed
separately by the Border Patrol, Customs, and INS can be used by FLETC.
This effort is discussed in the following sections.
FLETC plans to implement SASS within a 1- year period after signing a
contract, and officials estimate an approximate 5- year cost of $10
million (1 base- year and 4 option- years, including maintenance). SASS is
a subproject within an overall FLETC information technology (IT)
modernization project. Because FLETC intends to encourage vendors to be
innovative in offering possible solutions, the system requirements to be
included in the solicitation are for information purposes only. For
example, FLETC officials said that SASS may or may not be physically
located at FLETC*s Glynco campus, depending on the selected solution, but
all four facilities should have access to the system.
FLETC*s plans and activities for acquiring SASS generally include the
performance of certain key acquisition management functions, such as
acquisition planning, solicitation, requirements management, and project
management. However, first, FLETC has yet to focus on another key
acquisition function* risk management. Second, with the exception of
solicitation, FLETC*s attempt to obtain a COTS- based system lacks some
acquisition best practices. These practices call for continuous tradeoff
among such interdependent acquisition variables as system requirements,
commercially available system products and components, cost and schedule
constraints, and the architectural environment within which the Background
on the SASS Acquisition
FLETC Has Yet to Address Important SASS Acquisition Issues
Page 28 GAO- 03- 736 Federal Law Enforcement Training system will operate.
Third, FLETC solicitation activities have not adequately addressed SASS
security requirements. Taken as a whole, this
means that FLETC*s SASS acquisition is currently at risk of not delivering
a system solution to best meet FLETC*s needs.
Carnegie Mellon University*s Software Engineering Institute (SEI),
recognized for its expertise in acquiring software- intensive systems, has
published an acquisition management model that defines key acquisition
functions and assigns them to five incremental stages of maturity. 19
According to SEI, the following acquisition functions are part of a
minimum set that need to be practiced in order for software- intensive
systems to be acquired in a repeatable, effective manner: acquisition
planning, solicitation, requirements management, and project management.
On its SASS acquisition, FLETC is performing these functions in a manner
that is generally consistent with SEI*s maturity model, as described
later. According to FLETC officials, these functions are being performed
because they are following agency IT guidance that specifies processes and
procedures for acquiring and managing IT investments. By performing them,
FLETC is providing a margin of assurance that SASS will be effectively
acquired.
Acquisition planning. The purpose of acquisition planning is to ensure
that reasonable planning for the acquisition is conducted and that all
elements of the project are included. Among other things, this involves
assigning project responsibilities and documenting an acquisition strategy
that specifies, for example, acquisition objectives and methods, project
constraints, contract types and terms, and schedule and cost estimates.
For SASS, FLETC is performing these activities. Responsibility for the
acquisition has been assigned to IT and contracting personnel. FLETC has
also documented an acquisition strategy that defines acquisition
objectives and methods (e. g., maximum use of commercial products) and
project constraints (e. g., FLETC*s right to inspect all services
provided). FLETC has also defined a contract type and terms, (5- year,
fixed cost with award fee), and it estimates that the selected system will
be implemented within 1 year of contract award and cost about $10 million
over the 5- year contract period.
19 Software Engineering Institute, Software Acquisition Capability
Maturity Model(R) Version 1.03, CMU/ SEI- 2002- TR- 010 (Pittsburgh, PA:
March 2002). Certain Acquisition Functions
Are Being Performed
Page 29 GAO- 03- 736 Federal Law Enforcement Training Solicitation. The
purpose of solicitation is to prepare a documentation package that
identifies acquisition needs and selects the best provider and
solution to meet those needs. Examples of solicitation practices include
educating end users and others about the planned solicitation and engaging
them in developing a solicitation package that includes objectives;
technical and other product evaluation criteria; and contract acceptance
procedures, criteria, and payments. FLETC has done this for the SASS
acquisition. The SASS project office has engaged FLETC*s training
divisions in developing the package and educated them about business
process changes that may need to accompany the system*s implementation.
Further, the solicitation package 20 (i. e., RFPs) contains FLETC*s
objectives for the overall acquisition; evaluation criteria; and
acceptance procedures, criteria, and payment methods.
Requirements management. The purpose of requirements management is to
establish a common and unambiguous definition of requirements that is
understood by users, the project team, and suppliers. Requirements
management includes, among other things, establishing the project scope,
assigning specific responsibilities for managing the requirements,
collecting end- user input, and establishing a baseline set of
requirements before releasing the solicitation. FLETC has done this. For
example, FLETC has defined the project scope to be a total system solution
for student registration and scheduling. FLETC has also assigned
requirements management responsibilities to an integrated process team,
obtained user input by canvassing FLETC training divisions and having them
verify the system requirements, and established a baseline requirements
set in a December 2000 software requirements specification. Project
Management. The purpose of project management is to manage
project office activities and support units to ensure a timely, efficient,
and effective acquisition. Examples of project management practices are
defining project responsibilities, engaging user organizations, and
identifying project costs and schedules. FLETC has performed each of
these. Namely, an IT project manager, supported by a staff project office,
is in place, training division heads are participating in the project, and
cost and schedule estimates have been developed.
20 FLETC issued a SASS RFP in 2002. However, because of vendor complaints
about the potential costs involved in preparing their respective
proposals, FLETC withdrew the request and is now revising it.
Page 30 GAO- 03- 736 Federal Law Enforcement Training SEI*s acquisition
model also recognizes the need to manage acquisition risks. Moreover, many
software acquisition experts consider risk
management to be one of the most important acquisition areas. The purpose
of risk management is to identify risks as early as possible, manage those
risks, and develop and implement a risk management process. Risk
management includes identifying risks and categorizing them based on
probability and impact, developing risk mitigation strategies,
implementing the strategies, and tracking and reporting on progress.
During our review, FLETC officials told us they had yet to begin risk
management activities, or establish any type of risk management function,
and they did not plan to begin such activities until they receive the
vendors* proposals. Following our inquiry, officials told us they (1)
recognize that risk management is important to overall project success;
(2) have a rough draft of a risk management plan; and (3) in May 2003,
developed a project risk assessment plan for SASS. FLETC has not
provided us with these documents, and not having completed these actions
at this point is not consistent with SEI guidance, which advocates early
and continuous management of risks so as to minimize the chances
of risks becoming actual problems (i. e., system cost, schedule, and
capability shortfalls). By waiting to manage risks, FLETC is not
proactively mitigating known SASS risks; such as those that SEI reports to
be inherent in a COTS- based acquisition (e. g., volatility of the
commercial market and
organizational resistance to business process changes required by a
COTSbased solution). The result is a reduced probability of delivering
promised SASS capabilities on time and within budget.
Notwithstanding the fact that FLETC is performing key SASS acquisition
functions, it is deficient in its performance of these functions in two
ways. First, its solicitation package does not adequately address system
security. Second, with the exception of solicitation, FLETC has not
adequately provided for the use of COTS- based system acquisition best
practices in performing these functions. According to FLETC officials, the
former is an oversight that they have hired a security manager to address,
and the latter is a byproduct of their focus to date on solicitation
activities. They added that they plan to incorporate COTS- based system
acquisition best
practices in their performance of other SASS acquisition function as soon
as the solicitation is released. Until they do, the SASS acquisition is at
risk of not delivering FLETC users with a secure, long- term, cost-
effective system to support FLETC*s mission needs. Acquisition Risk
Management
Is Not Being Performed Approach to Performing Acquisition Functions Lacks
Two Key Elements
Page 31 GAO- 03- 736 Federal Law Enforcement Training Security. Since
1997, we have designated information security as a governmentwide, high-
risk area because of significant and pervasive
agency weaknesses in controls over computerized operations, due, in part,
to the government*s increasing reliance on commercially available
information technology. 21 Addressing these risks requires that agencies
ensure that adequate security controls are part of every new system
acquisition and deployment. In the case of SASS, this means that FLETC
needs to, among other things, adequately specify its security requirements
in the SASS solicitation package. However, FLETC has not done so. For
example, the SASS security requirements reference the Computer Security
Act of 1987 22 but do not specify relevant National Institute of Standards
and Technology guidelines. 23 These guidelines, for example, specify
authorization and access controls. After we brought this to the attention
of FLETC officials, they said that this was an oversight, that they have
hired a
security manager to address this area of concern, and that the revised
solicitation package will include missing security requirements. If it
does not, FLETC risks acquiring and deploying a system that will not be
secure.
COTS- based System Acquisition Practices. SEI research shows that the
market- driven capabilities embedded in commercial products and components
necessitate that organizations not be overly requirements focused when
acquiring COTS- based systems. Rather, SEI advocates that organizations
plan and execute these acquisitions in a manner that recognizes the
competing interests* and necessary tradeoffs* among four acquisition
variables: system requirements, the organization*s architectural
environment (current and future) that the system needs to operate within,
21 U. S. General Accounting Office, High Risk Series: Protecting
Information Systems Supporting the Federal Government and the Nation*s
Critical Infrastructures,
GAO- 03- 121 (Washington, D. C.: Jan. 2003). 22 The Computer Security Act
of 1987, as amended, (P. L. 100- 235, 101 Stat. 1724 (1988) requires
federal agencies with computer systems that process sensitive information
to identify and develop security plans for the systems and to provide
periodic computer security training to personnel managing, using, and
operating these systems. The Act defines sensitive information as any
information that if lost, misused, or accessed or
modified without proper authorization could adversely affect either the
national interest or conduct of federal programs, or the privacy to which
individuals are entitled under the Privacy Act of 1974 (P. L. 93- 579).
23 See, for example, National Institute of Standards and Technology,
Guidelines to Federal Organizations on Security Assurance and Acquisition/
Use of Tested/ Evaluated Products: Recommendations of the National
Institute of Standards and Technology, NIST SP 800- 23 (Aug. 2000) and
Guide For Developing Security Plans for Information Technology Systems,
NIST SP 800- 18 (Dec. 1998).
Page 32 GAO- 03- 736 Federal Law Enforcement Training the cost and
schedule constraints that limit the system acquisition, and the
commercially available system products and components (current and
future). 24 According to SEI, analyzing and understanding the tradeoffs
among these variables are vital to informed decision- making and thus
should be addressed early and continuously throughout a project*s life
cycle. As such, provision for performing this fundamental tradeoff
analysis and decision- making should be embedded in each acquisition
function, including the ones that we reviewed for SASS.
To FLETC*s credit, its solicitation plans and activities provide for
employing these COTS- based system practices. For example, the
solicitation does not prescribe a solution that is based upon customized,
*must- have* requirements. Rather, FLETC provided *information- only*
requirements, intended to provide an understanding of the nature of its
scheduling process needs and environment so as to maximize the flexibility
afforded vendors in proposing approaches to meet these needs. 25 However,
FLETC*s SASS acquisition planning, requirements management,
and project management efforts do not similarly provide for performing
these COTS- based system acquisition practices. For example, the SASS
acquisition strategy does not describe how FLETC will evaluate the
tradeoffs among the four acquisition variables. Also, the SASS
requirements document, although specifying requirements in a manner to
provide prospective offerors flexibility, does not address the FLETC
architectural environment (current and future) that the SASS solution will
need to operate within. According to FLETC officials, they have not
addressed this variable because they want the proposed SASS solution to
drive this environment. Last, SASS project management planning does not
include, for example, designated resources or a specific analytical
approach and tool for performing the tradeoff analysis. Following our
inquiries, FLETC officials told us that they have yet to incorporate these
COTS- based system best practices into each SASS acquisition function
because they have focused on the solicitation function. However, they
added they recognize the need to address these issues and plan to complete
them after the solicitation package is released. They also noted
24 Software Engineering Institute, Evolutionary Process for Integrating
COTS- Based Systems (EPIC): An Overview, CMU/ SEI- 2002- TR- 009
(Pittsburgh, PA: July 2002). 25 FLETC*s solicitation utilizes a
performance- based statement of objectives methodology that provides high-
level business needs and describes the objectives that prospective
offerors will be expected to achieve. FLETC officials said that this is
intended to allow offerors to prepare their own statements of work and to
propose innovative and costeffective approaches.
Page 33 GAO- 03- 736 Federal Law Enforcement Training that while they had
followed the best acquisition practices as defined by the SEI*s Software
Acquisition Capability Maturity Model(R), they had not documented these
efforts, but would do so in the future. We agree that
FLETC has followed some, but not all of these best practices. As we stated
earlier, FLETC has not followed software acquisition risk management best
practices. In addition, SEI has issued best practices for acquiring COTS-
based systems that FLETC is not following. Until they do,
the SASS acquisition will be at risk of not meeting its cost, schedule,
and performance commitments.
During our work, we learned that the Border Patrol Academy, in conjunction
with INS*s Immigration Officers Academy and the Customs Academy, were in
the process of adding an automated scheduling module to their ACMS. The
Border Patrol and Immigration Officer Academies currently use this system
for processing non scheduling- related class management activities. We
asked a Border Patrol Academy official, who brought the acquisition of the
ACMS scheduling module to our attention, whether the module the academy
was acquiring would potentially
duplicate the scheduling functions of the proposed SASS that FLETC was
about to acquire. The Border Patrol official said he did not know whether
there would be any duplication between the systems. He also said that the
Border Patrol Academy was acquiring its own system because it did not want
to wait until FLETC acquired its system, suggesting that this process was
moving too slowly. Furthermore, he said that the three academies had found
an economically feasible way to add an automated scheduling module to
ACMS.
We encouraged academy officials, and a FLETC official involved in FLETC*s
SASS acquisition, to meet and discuss the feasibility of FLETC using the
ACMS scheduling module instead of acquiring its SASS. Although FLETC
stated that it evaluated ACMS two years ago, these officials met and
according to one FLETC official, agreed FLETC could, instead of
potentially spending over $10 million in the cost of implementing SASS,
invest considerably less to merge FLETC*s requirements into the ACMS
automated scheduling module, which is still under development. Separately,
according to FLETC, as a result of a request of the DHS Chief Information
Officer, a FLETC- chaired working group looking at capacity issues within
DHS was tasked to seek input on the SASS from its participants. That
review was to obtain input toward identifying an enterprise- wide solution
to training scheduling for all of the DHS. Another FLETC official said
that the FLETC- chaired working group was FLETC Is Exploring the
Use of an Existing Automated Scheduling System
Page 34 GAO- 03- 736 Federal Law Enforcement Training considering whether
to recommend SASS as the standard training scheduler, or, possibly, use
ACMS as the standard.
As of late July 2003, FLETC was in the process of obtaining its
procurement and legal approvals to conduct a benchmark test on ACMS*s
scheduling module, once it is completed and tested, to determine whether
ACMS*s module could provide at least about 80 percent of the functions
that the proposed SASS system could provide. 26 If ACMS was able to
provide the needed functionality, FLETC would cancel its SASS RFP and
merge into ACMS*s automated scheduling system, thus saving money while
also meeting FLETC*s considerable training scheduling needs of its 75 POs.
The status of FLETC*s Board of Directors is unclear. Further, the Board*s
membership, roles and responsibilities, and past practices are not fully
consistent with prevailing governance and management control best
practices. Moreover, given its recent transition into DHS, FLETC needs
guidance and oversight to address its transformational challenges. A DHS
official said that DHS has recently assumed responsibility for FLETC and
has begun to work with its officials on ways to address these challenges.
The official also said DHS also recognizes the role an effective FLETC
Board could play in enhancing governance.
Prior to its most recent meeting in November 2002, FLETC*s Board of
Directors had not met for 3- 1/2 years, according to a FLETC official.
However, according to our review of Board minutes, the Board had not met
for a period of 5 years prior to its November 2002 meeting (the last
recorded meeting was held in November 1997). According to the agenda of
its November 2002 meeting, the Board was to address, among other things,
26 According to a FLETC official, ACMS*s scheduling component does not
have two
elements that SASS would provide; he also said that the absence of these
functions could either be overcome or were acceptable to FLETC. The first
element is a *conflict resolution* capability to help resolve the
sequencing of classes. According to the FLETC official, this could be
resolved by using ACMS*s *priority* capability, under which schedulers
would be able to schedule classes and facilities by placing them in
priority order. For example, legal classroom training would have a higher
priority than the subsequent mock courtroom training and, accordingly,
would be scheduled before the courtroom training. The second element is
speed* ACMS is not as fast as SASS would be. The FLETC official said that
ACMS*s slower speed was acceptable because it was still
faster than the current paper- intensive process. The Status of FLETC*s
Board of Directors Is
Unclear, and DHS Has Begun to Provide Oversight and Guidance
The Status of the FLETC Board of Directors Is Unclear
Page 35 GAO- 03- 736 Federal Law Enforcement Training its roles and
responsibilities, the fiscal year 2003 and 2004 budgets, and FLETC*s
Master Plan. The draft minutes from that meeting indicate that
the Board discussed, in broad terms, Justice Department concerns about
FLETC*s training services, including the availability of on- campus
dormitory space. The Board also discussed the status of the FLETC MOU and
the Master Plan, respectively, but did not discuss budget matters.
Subsequent to the November meeting, a FLETC official who attended the
meeting informed us that within the context of debating the Board*s roles
and responsibilities, the matter of whether the Board would continue as an
ongoing entity became unclear.
In June 2003, a DHS official said an effective FLETC Board was important
to the overall governance of FLETC activities. He also pointed out that
DHS was in the process of determining how the training mission was to be
managed in the new department. Issues under consideration include how PO
training needs would be identified, where training would be offered, and
how capacity and demand issues would be addressed. Determining the status,
roles and responsibilities of the FLETC Board will be done within this
context. Nevertheless, the DHS official acknowledged that having an
effective Board would help FLETC to address its challenges.
Notwithstanding the uncertainty surrounding its status, the Board*s
membership, roles and responsibilities, and past practices are not fully
consistent with prevailing best practices for governance and internal and
management control. 27 Membership. Regarding the size of a board,
prevailing governance best
practices consider smaller boards to be often more cohesive and to work
more effectively* in this regard, the FLETC Board is composed of eight
members. Specifically, FLETC*s Board presently has five
termrepresentatives who are voting members (one of whom has a 2- year
rotational term) and three nonvoting members. FLETC*s Director serves as
the nonvoting Executive Secretary of the Board. As of June 2003, the
27 To identify the relevant prevailing best practices, we relied primarily
on the May 2002
Principles of Corporate Governance by the Business Roundtable, an
association of chief executive officers of leading U. S. corporations;
GAO*s 2001 Internal Control Standards: Internal Control Management and
Evaluation Tool, (GAO- 01- 1008G, Washington, D. C.: Aug. 2001); and OMB*s
1995 Circular No. A- 123, Management Accountability and
Control. We also drew from our August 2002 report (unnumbered
correspondence), on the governance of the U. S. Capitol Police, titled
Information on Capitol Police Board Roles and Responsibilities,
Operations, and Alternative Structures.
Board*s Membership, Roles and Responsibilities, and Past Practices Are Not
Fully Consistent with Prevailing Governance and Management Control Best
Practices
Page 36 GAO- 03- 736 Federal Law Enforcement Training Board*s five voting
members were DHS*s Under Secretary for Border and Transportation Security,
Justice*s Acting Assistant Attorney General for
Administration, the Department of the Interior*s Deputy Assistant Attorney
for Law Enforcement, the General Services Administration*s Inspector
General, and the Administrator of TSA. The three nonvoting members of the
Board are the Office of Personnel Management*s Senior Advisor for Learning
and Knowledge, OMB*s Associate Director for General Government Programs,
and the U. S. Capitol Police Board*s Chairman.
Regarding the composition of the Board*s membership, there are two
departures from governance best practices. First, the Director of FLETC is
not a member of the Board, but, rather, its nonvoting Executive Secretary.
Under governance best practices, the head of the organization being
overseen by a board of directors is a full member of that board and, in
fact, in many cases also serves as the chair of the board. There is
currently a strong debate about this point. On the one hand, the Business
Roundtable best practices view this dual role as serving as a bridge
between an organization*s management and its board, ensuring that they
both act with a common purpose. On the other hand, the Conference Board
Commission on the Public Trust and Private Enterprise 28 recommends
splitting the role of chief executive and chairman of the board to ensure
an *appropriate
balance* between the board and chief executive. Second, there is not a
substantial degree of independence of FLETC Board members from its
operations. As currently configured, all Board members are either related
to a FLETC PO (e. g., TSA and Capitol Police) and/ or have a role in
reviewing and/ or setting its budget (OMB) or policies (Office of
Personnel Management). Governance best practices stress that a substantial
part* in most cases, a majority* of a board*s membership should be
independent of the entity it is overseeing. Such independence could help
avoid, among other things, potential conflicts of interest. Further,
independent board members, knowledgeable of information about the
organization they are overseeing, can provide a useful perspective on the
significant risks and challenges facing that organization 28 See, for
example, a report by The Conference Board Commission on Public Trust and
Private Enterprise titled Findings and Recommendations, New York, New
York, January
2003. The Conference Board is a leading business network that creates and
disseminates knowledge about management and the marketplace. According to
its report, the Conference Board created the Commission to help address
the causes of declining public and investor trust in companies, their
leaders, and capital markets. The 12- member commission included a former
Comptroller General of the United States and the current Secretary of the
Treasury.
Page 37 GAO- 03- 736 Federal Law Enforcement Training and help ensure the
exercise of independent judgment that is at the core of a board*s
oversight function. The 1970 FLETC MOU that established the Board allows
for the expansion* and, implicitly, a change in its
composition* of its membership by a majority vote of its members.
Roles and Responsibilities. The 1970 FLETC MOU, as amended, enumerates the
Board*s *final authority* over training policy, programs, criteria, and
standards of FLETC for resolving matters of conflicting training
requirements. This authority includes (1) establishing priority systems
governing the scheduling of courses and use of training facilities; (2)
establishing policy as to student residence requirements, leave, and other
matters relating to student administration; (3) reviewing FLETC*s budget
as to whether it meets its mission and making budget recommendations to,
now, the Secretary of DHS; and (4) evaluating the effectiveness of the
overall training program. The Board also has authority to establish
criteria for the selection of the FLETC Director and to approve the
selection; it may also recommend the removal of the Director to, now, the
Secretary of DHS.
Current FLETC officials have implemented the Board*s roles and
responsibilities under the MOU as pertaining only to training issues, and
not operational issues concerning FLETC, such as the budget and the
selection of the FLETC Director. In this regard, the current FLETC
Director who was appointed by the Secretary of the Treasury was selected
independently of the Board because, at the time, it was dormant. Under
governance best practices, however, the selection and oversight of an
organization*s head is a board*s paramount duty to help ensure competent
and ethical operation. As discussed earlier, under the FLETC MOU, the
Board has the authority to establish criteria for the selection of the
FLETC Director and to approve the selection. Additional oversight
responsibilities for boards include reviewing and monitoring the
implementation of strategic plans; reviewing annual operating plans and
budgets; advising management on significant issues facing the
organization; reviewing and approving significant actions; and nominating
directors, and overseeing effective governance, including the composition,
structure, practices, and evaluation of the Board. Past Practices. As
discussed earlier, our review of minutes from past
Board meetings showed that the Board did not meet for 5 years prior to its
November 2002 meeting. The Board has not met since November 2002,
Page 38 GAO- 03- 736 Federal Law Enforcement Training pending a decision
on its status. 29 In this regard, FLETC*s own MOU stipulates that the
Board shall meet quarterly, and at such other times as
may be determined by a majority of the Board or its presiding officer.
Further, governance best practices call for boards to meet as frequently
as needed in order for members to discharge properly their
responsibilities.
In this regard, the *typical* board of a large publicly traded corporation
meets about eight times a year.
Other than what is broadly described in the FLETC MOU, the Board*s
functions and processes implementing its roles and responsibilities are
not documented. According to the relevant governance best practices, it is
important that each board review its policies and practices on governance
matters* the standard defers the formalization of such policies and
practices in written form to the boards themselves, depending on the
circumstances they face. On one hand, the standard points out that
insufficient formalization often leads to a lack of clarity, while on the
other hand, it cautions that over- formalization can lead to rigidity*
emphasizing form over substance. GAO and OMB standards for internal and
management control respectively, stress the need for written
documentation. GAO*s standards for internal control require that an
agency*s policies, directives, and operating procedures be clearly
documented and available for examination. OMB*s standards for management
control state that an organization*s authority, responsibility, and
accountability should be defined and documented.
The Board did not periodically review its structure, functions, and
processes. According to governance best practices, boards should, from
time to time, review their own structure, governance principles,
composition, agenda, and processes to consider whether they are
functioning well in view of their responsibilities and help ensure sound
governance and oversight. GAO and OMB standards broadly suggest that
periodic external evaluations of, among other things, an organization*s
structure and functions help ensure that they are responsive to changing
conditions. In this regard, FLETC is facing significant changes in its
environment* the post- September 11 surge in demand for its services and
its transition to DHS.
29 FLETC officials said that at the conclusion of the Board*s November
2002 meeting, a follow- up meeting was planned for January 2003. However,
by early December 2002, the decision had been made to transfer FLETC to
the newly created DHS. They said that taskings resulting from the
transition delayed decisions regarding the Board. FLETC officials,
however, said they would review the duties and purview of the Board.
Page 39 GAO- 03- 736 Federal Law Enforcement Training DHS has the
opportunity to help FLETC face its challenges during the current period of
transformational change. DHS officials said that other
competing priorities, such as building the organizational structure of the
new department and addressing its role in the ongoing war on terrorism,
did not permit them to focus extensively on providing policy or other
guidance to FLETC about planning, scheduling, and governance (e. g.,
oversight and accountability). A DHS official said that the department had
recently started focusing on specific FLETC issues. In this regard, DHS
plans to begin focusing on a broad range of issues, including the Master
Plan and the FLETC Board of Directors.
With respect to the Master Plan, the DHS officials said that in general,
they viewed the plan as a useful document but not as the department*s
guiding plan for the future of FLETC and its facilities. One official said
that DHS was considering a new business plan for FLETC, one that would
make DHS *more than just a landlord* regarding federal law enforcement
training. This official further said* and a FLETC official separately
corroborated* that DHS*s vision for FLETC would include expanding its
authority on decisions related to federal law enforcement training.
Overall, FLETC and DHS find themselves at a crossroads for defining and
planning for the future of federal law enforcement training. The demands
placed on FLETC and DHS by the new security environment facing the country
are considerable. Yet, we note that while demand for training continues to
surge, the fiscal year 2004 budget request for FLETC is about $26 million
less than the fiscal year 2003 enacted level; the request for staffing
calls for about 120 fewer permanent positions than those enacted for
fiscal year 2003. The decline in resources risks exacerbating FLETC*s
already- strained capacity to provide training.
To meet the demands placed upon them, collective planning and execution by
FLETC and its many stakeholders, and active and sustained oversight and
guidance by DHS, are necessary to achieve a proper balance between the
surging demand for training and the
necessary capacity to meet it; schedule vital training in an efficient
and timely manner; and provide for effective governance and oversight
that ensures that all
stakeholders* interests are addressed. Despite the capacity constraints,
FLETC generally received good marks from POs about its ability to meet
their basic training needs. However, DHS Has Begun to Provide
Oversight and Guidance to FLETC
Conclusions
Page 40 GAO- 03- 736 Federal Law Enforcement Training FLETC is facing
considerable challenges in responding to the demand for training in a
systematic manner. For example, FLETC*s overall planning effort is
essentially reactive, rather than proactive. Specifically, FLETC
does not currently have a formal contingency plan to help guide management
decision- making with respect to capacity planning, although it has
developed some planning documents (i. e., its 1989 Master Plan with
updates and the current Master Plan). Although having an updated Master
Plan to guide short- and long- term planning is a step in the right
direction and may help provide some guidance to DHS, the final draft of
the plan has methodological limitations and inaccurate cost estimates. In
addition, FLETC has taken very limited action thus far in planning for the
use of alternative training such as off- site training and e- learning.
FLETC*s capacity challenges are likely to be compounded during its
transition into DHS. This transformational change for FLETC and a number
of its POs will likely bring considerable uncertainty, as the new
department is equally likely to redefine the POs* missions to focus on
homeland security. The redefined mission could result in the need for
updated training programs and modules that, in turn, would require new or
modified training facilities. A further uncertainty involves the type and
scale of future terrorist attacks and the response by the federal
government. A comprehensive planning process, encompassing, among other
things, sound methodologies and contingency planning, is essential to help
meet the current capacity challenges facing FLETC, and also will help
position it to meet future challenges.
FLETC faces a challenge to automate the scheduling of training for its 75
POs. Notwithstanding its performance of certain important system
acquisition functions, FLETC is not doing enough to ensure that it
acquires a system that will optimally support its current and future
mission needs.
Without instituting a proactive risk management function, FLETC increases
the risk that avoidable potential problems will become costly actual
problems, meaning they would result in a less capable system being
delivered late and/ or over budget. Further, and equally important, delays
in making both security and COTS- based acquisition best practices
integral
to its SASS project could exacerbate potential problems. Without
adequately addressing both, FLETC increases the risk of the system not
being adequately protected against unauthorized access and corruption, not
being available when needed, and not performing as intended. It is
important that FLETC address its SASS acquisition management weaknesses
before the project advances much farther. Although FLETC is in the initial
stages of acquiring SASS, we are encouraged that through in part our
intervention, it is also in consultation with the Border Patrol
Page 41 GAO- 03- 736 Federal Law Enforcement Training whether its ACMS,
with some modification, might serve FLETC scheduling needs, thus saving an
estimated $10 million cost over 5 years, while
spending considerably less to adopt the ACMS. Reconvening the FLETC Board
of Directors in November 2002, albeit briefly, was a step in the right
direction; however, the Board*s status is unclear. Given FLETC*s recent
transition into DHS, the Board, consistent with its mandate under the
FLETC MOU, needs to be retained in order to offer sustained governance and
oversight to ensure transparency and
accountability. In this regard, governance, in the form of boards of
directors, has the important role of overseeing management performance and
ensuring independent and objective decision- making. As FLETC considers
revising its MOU, it has an opportunity to incorporate prevailing
governance and internal and management control best practices about the
functioning of the Board to help FLETC address its challenges and achieve
transformational change. To address FLETC*s capacity constraints and
planning challenges, we
recommend that the Secretary of Homeland Security instruct the Director of
FLETC to develop a formal contingency plan that incorporates both
physical and
human resource solutions for at least the major potential constraints or
choke points that can impede the law enforcement training delivery system;
consider alternative approaches to estimating future facility
construction needs in its Master Plan, including (a) specification of a
range of training workload scenarios, and (b) after consultation with
experts, application of risk analysis techniques; and
develop plans for the use of alternative or additional law enforcement
training campuses should circumstances limit or prohibit the use of
available facilities.
To enable FLETC to monitor and reduce the risk associated with the
degradation of FLETC facilities and infrastructure, we recommend that
FLETC
closely monitor overall facility conditions through establishment of
periodic facility condition assessments of mission critical facilities and
Recommendations for
Executive Action
Page 42 GAO- 03- 736 Federal Law Enforcement Training infrastructure and
use of a computerized backlog of maintenance and repair and adopt a
performance measurement, such as FCI, to monitor the trend of
FLETC facilities condition and to also offer a benchmark indicator for
comparison to industry standards.
To increase the chances of SASS success, we recommend that the Secretary
of Homeland Security instruct the Director of FLETC to make proceeding
with the SASS acquisition conditional upon improvements in SASS
acquisition management activities. We further recommend that these
improvements, at a minimum, include adding risk management as a SASS
acquisition function and ensuring that this function provides for
the identification and documentation of risks; the categorization of
risk severity based on probability of occurrence and
potential impact; the development and implementation of risk mitigation
strategies; and the reporting of risk status, including progress in
implementing mitigation
strategies. We further recommend that the improvements in SASS acquisition
management activities should also
treat known risks in acquiring COTS- based systems as SASS- specific
risks, including volatility of the commercial market and an organization*s
resistance to the business process changes introduced by a COTS- based
solution;
ensure that security is made a clear, explicit, and visible component of
system requirements in the SASS solicitation package; and
ensure that COTS- based system acquisition best practices are made a
clear, explicit, and visible aspect of all acquisition functions,
particularly with respect to continuously assessing the tradeoffs among
system requirements, FLETC*s architectural environment, the project*s cost
and schedule constraints, and the commercially available system products
and components.
To help provide sustained oversight and enhance accountability, we
recommend that the Secretary of Homeland Security retain the FLETC
Page 43 GAO- 03- 736 Federal Law Enforcement Training Board of Directors.
We further recommend that working with FLETC*s POs, their parent
departments and agencies, and the Board*s current
members, the Secretary of Homeland Security review the Board*s mission,
roles and responsibilities, and functions and practices to better align
them with prevailing standards of governance and internal and management
control.
We provided a draft of this report to the Secretary of DHS and the
Attorney General for comment. We received comments from the Under
Secretary of DHS for Border and Transportation Security that are reprinted
in appendix IV and discussed later. In addition to DHS*s written comments,
FLETC provided technical comments and clarifications,
including updates on its SASS acquisition, which are incorporated in this
report where appropriate. Justice did not provide formal written comments;
the Associate Assistant Attorney General for Federal Law Enforcement
Training submitted an email with two general comments about the issues of
FLETC training capacity and governance, respectively. In their comments,
DHS and FLETC generally agreed with the information
presented in the report and with our conclusions and recommendations, and
outlined actions they either had taken or were planning to take to
implement the recommendations. DHS noted, for example, that the issues
related to capacity, scheduling, and governance discussed in the report
were already being considered by the department and would be given its
full attention. Regarding specific actions to implement our
recommendations, FLETC said that it was developing a formal contingency
plan to respond to future capacity constraints and choke points and to
identify alternative or additional training assets that could help in this
response. Also, FLETC indicated that it had taken action to reconstitute
the Board of Directors; FLETC also indicated that it was taking action to
determine the prospective membership, and roles and responsibilities of
the reconstituted Board.
At the same time, FLETC expressed some concerns regarding the report. In
its general comments, FLETC said, first, that it *strongly disagreed* with
the report*s title, asserting that it implied broader concerns about
capacity planning and management oversight than the report*s contents
supported. We believe that the report clearly and exhaustively describes
the challenges FLETC faces in planning for future capacity and articulates
the importance of sustained management oversight of, among other things,
the planning effort to help ensure its success, and that the report*s
title accurately reflects these challenges. Second, FLETC said that the
report Agency Comments
and Our Evaluation
Page 44 GAO- 03- 736 Federal Law Enforcement Training did not point out
that the flow of federal law enforcement personnel was not constrained by
training capacity, but by the inability of POs to recruit
such personnel. We note that because it was beyond the scope of our work,
the report did not address recruitment as a distinct issue, but did point
out that shortfalls in POs* recruiting contributed to projected demand for
training not materializing. We also note that the core issue is FLETC*s
ability to train those personnel who actually need to be trained. In this
regard, the report clearly describes how FLETC*s 5- day/ 8- hour
capacity is strained; accordingly, additional recruits would only serve to
exacerbate FLETC*s capacity challenges. Third, FLETC said that the report
did not adequately recognize the *extraordinary success* of FLETC and the
POs in meeting critical law enforcement training requirements. We believe
that the report clearly recognizes that FLETC has been able to generally
meet its POs* demands for basic training during a time of constrained
capacity and surging demand, and highlights the actions FLETC has taken to
accomplish this. Fourth, FLETC said that projected workloads (i. e.,
demand for training) were so dynamic that some of those cited in the
report were already obsolete and urged caution in their treatment. We note
that during our work we repeatedly corroborated* through interviews with
FLETC officials and related documentary verification* the currency and
validity of the projected workloads as presented in the report; further,
FLETC did not provide us with any updated workload projections as part of
its written comments. Fifth, FLETC said that the report implied that it
was accountable for variables beyond its control, such as the timeliness
of recruitment, operational needs, class cancellations, shifts in training
strategies, and funding, all of which impact capacity planning. We believe
that the report adequately describes these factors as contributing to the
level of training actual attendance, and does not imply that FLETC is
accountable for them.
In its technical comments, FLETC acknowledged that its predominantly
manual scheduling process was time- consuming and required modernization.
FLETC questioned, however, that automating the scheduling process would
result in significant increases in capacity. We note that, first, FLETC*s
own Master Plan indicated that if the scheduling
process were to be automated, capacity efficiencies would likely result
and the plan would need to be revised, and second, FLETC*s documentation
related to the SASS acquisition indicated that automation would result in
capacity efficiencies. In commenting on our use of an example to
illustrate the effect of choke points, FLETC said that resurfacing the
Charleston campus* emergency response driving range did not result in the
cancellation of any Border Patrol classes. We note that a
FLETC official cited the resurfacing as a specific example of a capacity-
Page 45 GAO- 03- 736 Federal Law Enforcement Training constraining choke
point that resulted in the cancellation of three Border Patrol classes,
which have not been rescheduled. In commenting on the
possible use of ACMS as an alternative to its proposed acquisition of
SASS, FLETC said, among other things, that the evaluation of ACMS*s
scheduling component was in the preliminary stages. Accordingly, it was
too early to tell whether ACMS*s scheduling component would meet FLETC*s
requirements, and whether significant cost savings would be realized. We
note that a FLETC official involved in the evaluation of ACMS, in
responding to our questions, provided a written response, stating that if
ACMS provided about 80 percent of the functionality sought by FLETC it
could be adopted as the scheduling system at considerably less cost than
the estimated $10 million cost of SASS.
In its comments, regarding training capacity, Justice stated that if
FLETC*s Glynco campus (as well as the Charleston) campus were used to
provide basic training and the Artesia Campus was used to provide advanced
and specialized training, then FLETC would be able to achieve a better
balance in the utilization of its campuses and mitigate the capacity
strains it is experiencing. Regarding governance, Justice stated that the
FLETC Board of Directors would work well as currently configured, if it
were allowed to function under its original mandate as defined in the MOU
that created
FLETC. We are sending copies of this report to the Chairmen and Ranking
Minority Members of the Senate and House Committees on Appropriations. In
addition, we are sending copies to the Secretaries of Homeland Security
and the Interior; the Attorney General of the United States; and the
Director of OMB. We will also make copies available to others on request.
In addition, the report will be available at no charge on GAO*s Web site
at http:// www. gao. gov.
Page 46 GAO- 03- 736 Federal Law Enforcement Training If you have any
questions about this report or wish to discuss it further, please contact
me at (202) 512- 8777 or Seto J. Bagdoyan, Assistant
Director, at (202) 512- 8658. Key contributors to this report are listed
in appendix V. Richard M. Stana
Director, Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and Methodology
Page 47 GAO- 03- 736 Federal Law Enforcement Training Given concerns about
whether the Federal Law Enforcement Training Center (FLETC) can continue
to meet the rising training demands of its
75 federal partner organizations (PO) following the September 11th
attacks, the House Appropriations Committee asked us to develop
information on the following topics:
The extent to which FLETC is able to meet the current and projected
demand for training, how FLETC is planning to meet the demand, and the
associated costs and the extent to which FLETC coordinates or uses
existing, non- FLETC government training assets, and any associated costs.
FLETC*s current organizational structures and processes for coordinating
and scheduling training activities and whether FLETC plans any changes to
these structures and processes.
FLETC*s oversight and governance structures and the extent to which
these structures are providing guidance to FLETC as it addresses its
capacity and planning challenges during a period of transformational
change.
Overall, to develop the information in this report, we conducted our work
at FLETC, the Office of Management and Budget (OMB), Clark Nexsen (the
architectural/ engineering firm retained by FLETC to develop a Master
Plan for facilities development at FLETC- owned campuses), and at the
following selected departments and agencies engaged in federal law
enforcement training. The Department of Justice (the Immigration &
Naturalization Service, the Border Patrol, the Federal Bureau of Prisons,
and the U. S. Marshals
Service), The Department of the Treasury (the Bureau of Alcohol,
Tobacco,
Firearms, and Explosives, the Internal Revenue Service, the U. S. Customs
Service, and the U. S. Secret Service), and The Department of
Transportation (the Transportation Security
Administration, the Federal Air Marshals, and the U. S. Coast Guard). The
Department of Homeland Security (DHS) was created during our work. Many of
the FLETC POs* identified above as components of other departments* moved
to DHS* temporary headquarters after January 24, 2003* see appendix II for
a listing of the POs now in DHS. We interviewed officials from DHS,
including the Director of Operations for Border and Transportation
Security. We also interviewed FLETC and PO officials in Washington, D. C.,
and at each of the four domestic training campuses Appendix I: Objectives,
Scope, and
Methodology
Appendix I: Objectives, Scope, and Methodology
Page 48 GAO- 03- 736 Federal Law Enforcement Training where FLETC POs
train: Brunswick, Ga. (commonly referred to as *Glynco,* for Glynn
County); Artesia, N. Mex.; Charleston, S. C.; and
Cheltenham, Md. We reviewed applicable public laws and regulations;
memorandums of understanding (MOU); best practices and guidelines related
to facilities and information technology acquisition, governance, and
management and internal control; various drafts of the Master Plan, and
supporting documentation; budget submissions and justifications; training
curriculum and accreditation documents; and various reports related to
FLETC and federal law enforcement training.
We conducted our work between May 2002 and June 2003 in accordance with
generally accepted government auditing standards. We requested comments on
a draft of this report from the Secretary of Homeland Security and the
Attorney General. (See appendix IV for DHS* comments.)
To determine the extent to which FLETC is able to meet the current and
projected demand for training, how FLETC is planning to meet the demand,
and the associated costs; and the extent to which FLETC coordinates or
uses existing, non- FLETC government training assets, and any associated
costs, we interviewed FLETC, OMB, Clark Nexsen, and
department and component agency officials regarding specific training
demand and availability issues, including agency training projections and
the factors influencing these projections, physical and human resource
*choke points* (or training obstacles) at the training campuses, agency
satisfaction levels with the current delivery of training services, and
the resources needed to meet future demands for training. We did not
evaluate the quality or the effectiveness of the training programs nor
reviewed how agencies assessed the training provided. We also reviewed the
following documents obtained from FLETC and other officials:
Aggregate agency training projections for both basic and advanced
courses for fiscal years 1997- 2008 and FLETC*s adjustments to some of
these projections. Agency training projections for FLETC participants
interviewed during our
site visits. The actual student attendance statistics at the FLETC
training campuses
for fiscal years 1983- 2002. The 35-, 65-, 90- percent, and final draft
submittals of FLETC*s Master Plan. The June 1989 Master Plan and its
April 1996 update. The latest FLETC 5- year construction plan
allocation. FLETC, Treasury, and DHS budget documents and related
justifications. FLETC research and development studies on particular
training issues. Capacity, Planning,
and Coordination
Appendix I: Objectives, Scope, and Methodology
Page 49 GAO- 03- 736 Federal Law Enforcement Training In addition, we
reviewed the extent to which FLETC*s current infrastructure was supporting
the delivery of training at each of the
campuses and whether infrastructure (e. g., water supply, sewage, and
power grid) concerns were being addressed in FLETC*s Master Plan. We did
this by reviewing relevant sections of the plan, conducting campus visits
and observing infrastructure, and interviewing facilities management
officials. We also determined whether Master Plan proposals regarding
infrastructure were aligned with FLETC*s Strategic Plan and recent budget
enactments and requests. Further, we determined whether FLETC has any
contingency plans to address potential sudden surges in demand for
training (e. g., Border Patrol hiring in the mid- 1990s and the recent PO
training ramp- up following the September 11th attacks).
To determine FLETC*s current organizational structures and processes for
coordinating and scheduling training activities, and whether FLETC plans
any changes to these structures and processes, we interviewed FLETC and PO
officials in Washington, D. C., and at each of the four training campuses
regarding their perceptions of the training programs and their views about
FLETC*s ability to schedule and coordinate training activities. In
addition, we interviewed FLETC officials about the status of the computer
automation process for scheduling training. We observed how FLETC staff
perform their scheduling activities. Also, we reviewed the following
documents:
Provisions of the 1970 Treasury order creating FLETC. The Treasury and
FLETC Strategic Plans of FY2000- 2005, which identify FLETC*s latest
mission statements, goals, and objectives.
FLETC*s organizational chart. FLETC*s request for proposals on
computer automation. Records of interviews conducted by Clark Nexsen
regarding POs* training
needs. Further, we reviewed FLETC*s MOUs with several of the larger
agencies to obtain an understanding of FLETC*s formal management and
coordination responsibilities with respect to the POs.
To determine whether FLETC has effective controls in place for acquiring a
new student administration and scheduling system (SASS) by focusing on
whether the center was performing five key acquisition management
functions: acquisition planning, solicitation, requirements management,
project management, and risk management. We reviewed these areas
Scheduling and
Coordination of Training Activities
Appendix I: Objectives, Scope, and Methodology
Page 50 GAO- 03- 736 Federal Law Enforcement Training because they are
critical to successfully acquiring systems. These practices were derived
from the work and research of Carnegie Mellon
University*s Software Engineering Institute (SEI). 1 In addition, we
reviewed whether FLETC was incorporating SEI best practices for acquiring
COTS- based systems 2 in these five functions. In conducting our review,
we interviewed SASS project officials and other FLETC staff involved in
the acquisition, including staff from the information systems division,
the procurement division, legal counsel, and the training analysis and
coordination division. We also interviewed potential SASS users from two
FLETC training divisions.
To determine whether FLETC was performing these acquisition management
functions, we compared the center*s actions to those defined by SEI as key
in establishing at least basic acquisition management controls for the
five functions. In addition, we compared the center*s actions to those SEI
has redefined as being key to effectively leveraging the COTS- based
systems. To document FLETC*s actions, in addition to interviewing staff,
we reviewed documentation including SASS program documentation such as
contractor reports; the SASS solicitation package, including the SASS
software and database requirements; training model
schedule templates; the 2002 master class schedule; information technology
modernization 2004 capital asset plan; National Institute of Standards and
Technology security publications; and fiscal year 2000 congressional
reports.
To determine FLETC*s oversight and governance structures and the extent to
which these structures are providing guidance to FLETC as it addresses its
capacity and planning challenges during a period of transformational
change, we reviewed FLETC*s 1970 MOU establishing, among other things, its
Board of Directors, and governance and management and internal control
best practices* these were the Business Roundtable*s 2002
Principles of Corporate Governance and a 2003 report by the Conference
Board*s Commission on Public Trust and Private Enterprise titled
Findings and Recommendations; and GAO*s 1999 Standards for Internal
Control in the Federal Government and OMB*s 1995 Circular No. A- 123,
1 Software Engineering Institute, Software Acquisition Capability Maturity
Model (R) Version 1.03, CMU/ SEI- 2002- TR- 010 (Pittsburgh, PA: March
2002). 2 Software Engineering Institute, Evolutionary Process for
Integrating COTS- Based Systems (EPIC): An Overview, CMU/ SEI- 2002- TR-
009 (Pittsburgh, PA: July 2002). Governance and
Oversight Structure and Guidance
Appendix I: Objectives, Scope, and Methodology
Page 51 GAO- 03- 736 Federal Law Enforcement Training Management
Accountability and Control. We drew from our August 2002 report on the
governance of the U. S. Capitol Police, *Information on Capitol Police
Board Roles and Responsibilities, Operations, and
Alternative Structures.* We discussed governance issues in general and the
Board in particular, including its mission, roles and responsibilities,
current and past practices, and its status with cognizant FLETC and DHS
officials. We compared the governance and management and internal control
best practices with those of the Board to determine the extent to which
they were consistent.
Appendix II: FLETC*s 75 Partner Organizations
Page 52 GAO- 03- 736 Federal Law Enforcement Training Following is a
listing of the current (as of June 2003) Federal Law Enforcement Training
Center (FLETC) partner organizations (PO).
Agriculture
Forest Service Office of Inspector General
Amtrak
Northeast Corridor Police
Central Intelligence Agency
Office of Inspector General Office of Security
Commerce
National Institute of Standards and Technology National Marine Fisheries
Service Bureau of Industry and Security Office of Inspector General Office
of Security
Defense
Pentagon Force Protection Agency Naval Criminal Investigative Service
National Security Agency
Defense Criminal Investigative Service Office of Inspector General Air
Force Office of Special Investigations
Education
Office of Inspector General
Energy
Office of Inspector General Appendix II: FLETC*s 75 Partner
Organizations
Appendix II: FLETC*s 75 Partner Organizations
Page 53 GAO- 03- 736 Federal Law Enforcement Training Environmental
Protection Agency Office of Criminal Investigations
Federal Deposit Insurance Corporation
Office of Inspector General
General Services Administration
Office of Inspector General
Health and Human Services
Food and Drug Administration National Institutes of Health Office of
Inspector General
Homeland Security
Customs and Border Protection (includes Customs, INS, and Agriculture*s
Animal and Plant Health Quarantine inspectors, and the Border Patrol, a
division of CBP) Federal Emergency Management Agency Immigration and
Customs Enforcement (includes Federal Protective Service) Federal
Protective Service) Transportation Security Administration
U. S. Coast Guard U. S. Secret Service Office of Inspector General
Housing and Urban Development
Office of Inspector General
Appendix II: FLETC*s 75 Partner Organizations
Page 54 GAO- 03- 736 Federal Law Enforcement Training Interior
Bureau of Indian Affairs Bureau of Land Management Bureau of Reclamation
National Park Service
U. S. Park Police Office of Inspector General Office of Surface Mining,
Reclamation and Enforcement U. S. Fish and Wildlife Service
Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives Bureau of Prisons Drug
Enforcement Administration Office of Inspector General U. S. Marshals
Service
Labor
Office of Inspector General
National Aeronautics and Space Administration
Office of Inspector General
Nuclear Regulatory Commission
Office of Inspector General
Office of Personnel Management
Office of Inspector General
Railroad Retirement Board
Office of Inspector General
Small Business Administration
Office of Inspector General
Appendix II: FLETC*s 75 Partner Organizations
Page 55 GAO- 03- 736 Federal Law Enforcement Training Smithsonian
National Zoological Park Office of Protection Services
Social Security Administration
Office of Inspector General
State
Agency for International Development - Office of Inspector General Bureau
of Diplomatic Security Department of State* Office of Inspector General
Supreme Court
Supreme Court Police
Tennessee Valley Authority
TVA Police Office of Inspector General
Transportation
Office of Inspector General
Treasury
Bureau of Engraving and Printing Financial Crimes Enforcement Network
Internal Revenue Service Office of Inspector General Treasury Inspector
General for Tax Administration U. S. Mint
Appendix II: FLETC*s 75 Partner Organizations
Page 56 GAO- 03- 736 Federal Law Enforcement Training U. S. Congress
Government Printing Office* Office of Security Library of Congress Police
Government Printing Office* Office of Inspector General U. S. Capitol
Police
U. S. Postal Service
Office of Inspector General Postal Inspection Service* Postal Police
Veterans Affairs
Office of Inspector General
Appendix III: Training Programs and Seminars Provided by FLETC
Page 57 GAO- 03- 736 Federal Law Enforcement Training FLETC offers eight
variations of training programs and seminars. A priority system is
employed to fund, schedule, and deliver these training
programs. FLETC basic training programs are delivered in two formats:
Center Basic followed by an Agency- Specific Basic either on or off site,
or a single Center Integrated Basic program that combines the Center Basic
and Agency- Specific Basic concepts into one program. A Center Integrated
Basic program is granted for those agencies that have such a unique
mission that their training requirements cannot be met in a Center Basic
program. The categories of training, in priority order, are:
1. Center Basic* law enforcement entry- level recruit training designed to
meet the training needs for multiple agencies. The job tasks and course
content are identified and validated by the participating agencies and 100
percent of the training is managed and delivered through FLETC staffing
resources. These staffing resources are comprised of approximately 50
percent of FLETC*s permanent staff and 50 percent of Partner Organization
staff. The three Center Basic programs offered by FLETC are the Criminal
Investigator Training Program, the Mixed Basic Police Training Program,
and the Natural Resource Police Training Program.
2. Center Integrated Basic*- law enforcement entry- level training
designed to meet the mission- specific or unique requirements of a single
agency. The job tasks and course content are identified and validated by
the user agency and the training is managed and delivered through the
combined efforts of the agency and FLETC staffing resources. Like the
Center Basic and Agency- Specific Basic, the Center Integrated Basic
provides both the foundational knowledge, skills, and abilities and the
specific mission requirements for that agency. FLETC is responsible for
teaching the common basic recruit training and the agency is responsible
for teaching the mission- specific courses. FLETC can and does provide
instructional resources when the agency does not have sufficient staffing.
FLETC currently offers 10 Center Integrated Basic programs. Some examples
are the United States Border Patrol Integrated, the United States Park
Police Integrated, and the United States Marshal Service Integrated.
3. Agency- Specific Basic* law enforcement entry- level training that
supplements and follows Center Basic training programs for individual
agencies. The job tasks and course content are identified by the user
agency and the training is managed and delivered by agency staffing
resources. However, FLETC does provide staffing resources as requested.
The program builds on the foundational knowledge, skills, and abilities
that were developed in the Center Basic program and Appendix III: Training
Programs and
Seminars Provided by FLETC
Appendix III: Training Programs and Seminars Provided by FLETC
Page 58 GAO- 03- 736 Federal Law Enforcement Training focuses on the
specific mission requirements of that law enforcement agency.
4. Center Advanced* center advanced training is developed, managed, and
delivered through FLETC staffing resources by the individual training
divisions to meet a specific or specialized need for instructor or
mission- specific training. These programs address the specialized and
instructor needs of the various Partner Organizations. Some examples of
Center Advanced training include the Firearms Instructor Training Program,
the Technical Investigative Equipment Training Program, and the Weapons of
Mass Destruction Training Program.
5. Agency Advanced* agency advanced training is developed, managed, and
delivered by the user agency and addresses the specialized training
requirements for that agency. These training courses are generally
conducted for mid- and senior- level law enforcement personnel.
6. State, local, and international training* state, local, and
international training is primarily delivered on an off- site basis. FLETC
collaborates with these entities to deliver a variety of training programs
and in support of various law enforcement initiatives.
7. Agencies without Partner Organization status participate in training in
a space available basis. Training programs are developed and delivered as
appropriate.
8. Conferences, seminars, and non law enforcement training are also
provided.
Appendix IV: Comments from the Department of Homeland Security Page 59
GAO- 03- 736 Federal Law Enforcement Training Appendix IV: Comments from
the
Department of Homeland Security
Appendix IV: Comments from the Department of Homeland Security Page 60
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 61
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 62
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 63
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 64
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 65
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 66
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 67
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 68
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 69
GAO- 03- 736 Federal Law Enforcement Training
Appendix IV: Comments from the Department of Homeland Security Page 70
GAO- 03- 736 Federal Law Enforcement Training
Appendix V: GAO Contacts and Staff Acknowledgments Page 71 GAO- 03- 736
Federal Law Enforcement Training Richard M. Stana (202) 512- 8777 Seto J.
Bagdoyan (202) 512- 8658
In addition to those named above, the following teams and individuals
contributed to this report: Wendy C. Simkalo, Jared Hermalin, Nettie
Richards, Elizabeth Lessmann, Grace A. Coleman, Brenda Rabinowitz, R.
Rochelle Burns, Kim Hutchens, Homeland Security and Justice; Terrell Dorn,
Physical Infrastructure; Carl L. Higginbotham, Dave Hinchman, Information
Technology; Susan Ragland, K. Scott Derrick, Trina Lewis, Strategic
Issues; Kenneth Bombara, Leo Barbour, Donna L. Miller, Evan Gilman,
Applied Research & Methodology; Jan B. Montgomery, Geoffrey Hamilton,
General Counsel; Susan Conlon, Shirley A. Perry, Product Assistance Group.
Appendix V: GAO Contacts and Staff
Acknowledgments GAO Contacts Staff Acknowledgments
(440125)
The General Accounting Office, the audit, evaluation and investigative arm
of Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability of
the federal government for the American people. GAO examines the use of
public funds; evaluates federal programs and policies; and provides
analyses, recommendations, and other assistance to help Congress make
informed oversight, policy, and funding decisions. GAO*s commitment to
good government is reflected in its core values of accountability,
integrity, and reliability.
The fastest and easiest way to obtain copies of GAO documents at no cost
is through the Internet. GAO*s Web site (www. gao. gov) contains abstracts
and fulltext files of current reports and testimony and an expanding
archive of older products. The Web site features a search engine to help
you locate documents using key words and phrases. You can print these
documents in their entirety, including charts and other graphics.
Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as *Today*s Reports,* on its
Web site daily. The list contains links to the full- text document files.
To have GAO e- mail
this list to you every afternoon, go to www. gao. gov and select
*Subscribe to e- mail alerts* under the *Order GAO Products* heading.
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent of
Documents. GAO also accepts VISA and Mastercard. Orders for 100 or more
copies mailed to a single address are discounted 25 percent. Orders should
be sent to: U. S. General Accounting Office 441 G Street NW, Room LM
Washington, D. C. 20548 To order by Phone: Voice: (202) 512- 6000
TDD: (202) 512- 2537 Fax: (202) 512- 6061
Contact: Web site: www. gao. gov/ fraudnet/ fraudnet. htm E- mail:
fraudnet@ gao. gov Automated answering system: (800) 424- 5454 or (202)
512- 7470 Jeff Nelligan, Managing Director, NelliganJ@ gao. gov (202) 512-
4800
U. S. General Accounting Office, 441 G Street NW, Room 7149 Washington, D.
C. 20548 GAO*s Mission Obtaining Copies of
GAO Reports and Testimony
Order by Mail or Phone To Report Fraud, Waste, and Abuse in Federal
Programs Public Affairs
*** End of document. ***