oversight

Federal Law Enforcement Training Center: Capacity Planning and Management Oversight Need Improvement

Published by the Government Accountability Office on 2003-07-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States General Accounting Office

GAO          Report to Congressional Requesters




July 2003
             FEDERAL LAW
             ENFORCEMENT
             TRAINING CENTER
             Capacity Planning and
             Management
             Oversight Need
             Improvement




GAO-03-736
                                                July 2003


                                                FEDERAL LAW ENFORCEMENT
                                                TRAINING CENTER

Highlights of GAO-03-736, a report to           Capacity Planning and Management
Congressional Requesters
                                                Oversight Need Improvement



The Federal Law Enforcement                     FLETC’s overall capacity to provide training at the Glynco and Charleston
Training Center (FLETC) provides                campuses is currently strained, while Artesia has been underutilized, and
federal law enforcement training                Cheltenham is being upgraded and cannot operate at full capacity. FLETC is
for 75 Partner Organizations                    developing a Master Plan to address how to overcome the long-term capacity
(agencies) primarily at four                    challenges, but questions exist regarding the assumptions and
domestic facilities located at
Glynco, Ga; Artesia, N. Mex.;
                                                methodologies used, contingency planning, cost estimation and budgeting,
Charleston, S.C.; and Cheltenham,               and the need to address capacity shortfalls sooner than planned. Department
Md.. Given the post-terrorist attack            of Homeland Security officials intend to review the new department’s
security environment, coupled with              training needs and capacities, and update the plan to reflect its vision for law
the increased demand for training,              enforcement training. Within the context of its strained training capacity,
concerns have been raised about                 FLETC uses a predominantly manual scheduling process that does not
FLETC’s continued ability to meet               ensure the efficient use of training resources and poses internal control risks
this training demand. The visual                due to potential loss of scheduling materials and the lack of backup
below demonstrates the sharp                    documentation. Although FLETC has begun the process to acquire a fully
increase since the September 11,                automated scheduling system, FLETC officials have yet completed important
2001, attacks. Because of these                 risk management activities and are not using recognized best practices for
concerns, GAO was asked to issue
a report on (1) how FLETC plans to
                                                acquiring commercial off-the-shelf-based systems associated with this type
meet the projected demand for                   of acquisition. Furthermore, FLETC’s solicitation activities have not
training; (2) FLETC’s ability to                adequately addressed security requirements. FLETC faces additional
efficiently coordinate and schedule             challenges regarding its governance structure in that the status of FLETC’s
training activities; and (3) whether            Board of Directors is unclear, and its membership, roles and responsibilities,
oversight and governance                        and past practices are not fully consistent with prevailing governance best
structures provide the guidance it              practices.
needs to address its capacity and
planning challenges.                            Partner Organization Training Projections Compared to Current Optimum Combined
                                                Campus Capacity (in student weeks)

                                                PO - Projected
GAO recommends that the                         student weeks
Secretary of the Department of                  300,000
                                                                                                                        Demand surge
Homeland Security improve                                                                                                          283,106
                                                                                                                         265,848
capacity planning, periodically
assess the condition of training                250,000
                                                                                                                                             232,221   230,089   228,142   224,385
facilities and infrastructure,                                                   6-day/8-hour capacity = 238,000
                                                             Overcapacity
improve the acquisition process for                             zone
an automated scheduling system,                 200,000                         5-day/8-hour capacity = 199,000
and enhance the governance and
oversight capabilities of FLETC’s                                               160,871
                                                                                          154,362             150,355
Board of Directors. The                         150,000               140,322
                                                            130,069                                 132,470
department and FLETC generally
concurred with GAO’s
recommendations.                                100,000


                                                      0
www.gao.gov/cgi-bin/getrpt?GAO-03-736.                      1997    1998        1999      2000      2001      2002        2003     2004      2005      2006      2007      2008
                                                            Fiscal year
To view the full product, including the scope                                                      9-11-01
and methodology, click on the link above.                                 Pre 9-11-01                                                  Post 9-11-01
                                                                                               Terrorist attacks
For more information, contact Richard M.        Source: GAO analysis of FLETC data.
Stana, 202-512-8777, Stanar@GAO.gov.
                                                Note: A “student week” is defined as 5 days of training for 1 student.
Contents


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



               Page i                             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



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          Page ii                                    GAO-03-736 Federal Law Enforcement Training
United States General Accounting Office
Washington, DC 20548




                                   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).



                                   Page 1                                        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 2                                     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 3                              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
Results in Brief   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 POs6 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.




                   Page 4                                       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 5                                     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 3-½ 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 6                                    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
Background   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 weeks9 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].




             Page 7                                      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 8                                 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

FLETC                                                     FLETC
Fiscal Year 2003 Budget Enactment                         Fiscal Year 2004 President’s Request
(in thousands)                                            (in thousands)



                   21%                $35,766                          16%              $23,679
                                      Facilitiesa                                       Facilitiesa



          79%                         $136,109                   84%                    $122,379
                                      Human Capitalb                                    Human Capitalb


                                      Total                                             Total
                                      $171,875                                          $146,058


Source: GAO analysis of FLETC data.
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.




Page 9                                                 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 10                                    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) “follow-
on 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 11                              GAO-03-736 Federal Law Enforcement Training
                            FLETC’s overall 5-day/8-hour capacity to provide training at the Glynco
FLETC’s Training            and Charleston campuses is currently strained, while the Artesia campus
Capacity is Strained,       has been underutilized. The Cheltenham campus is being upgraded and is
                            not fully operational, thus its contribution to FLETC’s overall capacity is
and Its Planning for        limited. POs offered a variety of views about the effect of the strained
Adding Capacity             capacity on the training of their personnel—for example, former Justice
                            POs now in DHS believed that the quality of the training had suffered,
Raises Concerns             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.


FLETC’s Training Capacity   Primarily as the collective result of the surge in Border Patrol personnel
Is Strained at the Glynco   levels begun in the mid-1990s and the surge in overall federal law
and Charleston Campuses     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 demand13
                            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.




                            Page 12                                    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)

                                                                                                                        Difference
                                                                                                                          between
                                                                                                                         projected
                                                                            Fiscal year 2003 FLETC estimated          demand and
                                      Optimum 5-day/8- Optimum 6-day/8-            projected actual attendance          estimated
 Campus                                   hour capacity    hour capacity            demand       (as of 4/30/03)       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 13                                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 best-
case 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 14                              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)

                          PO - Projected
                          student weeks
                                                                                                  Demand surge
                          300,000
                                                                                                             283,106
                                                                                                   265,848


                          250,000
                                                                                                                       232,221   230,089   228,142   224,385
                                                           6-day/8-hour capacity = 238,000
                                       Overcapacity
                                          zone
                          200,000                         5-day/8-hour capacity = 199,000

                                                          160,871
                                                                    154,362             150,355
                          150,000               140,322
                                      130,069                                 132,470



                          100,000


                                0
                                      1997    1998        1999      2000      2001      2002        2003     2004      2005      2006      2007      2008
                                      Fiscal year
                                                                             9-11-01
                                                    Pre 9-11-01                                                  Post 9-11-01
                                                                         Terrorist attacks
                          Source: GAO analysis of FLETC data.


                          Note: This graph includes the Glynco, Artesia, and Charleston campuses.



Artesia Campus Has Been   While capacity at the Glynco and Charleston campuses has been strained,
Underutilized             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



                          Page 15                                                       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 16                              GAO-03-736 Federal Law Enforcement Training
                              Figure 4: FLETC Campus at Artesia, New Mexico




FLETC Has Generally Met       Despite its strained capacity, FLETC has nevertheless been able to
PO Needs for Basic            generally meet its POs’ demand for basic training principally by, among
Training                      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.



                              Page 17                              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.


PO Views about the Effect    POs offered a variety of views about the effect of FLETC’s strained
of the Capacity Strains on   capacity on their training, in terms of, among other things, trainee
Their Personnel              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


                             Page 18                              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.


Capacity Strains Have       FLETC’s implementation of 6-day, multiple-shift training at Glynco to help
Impacted the Condition of   alleviate the capacity constraints at that campus has led to the intensive
Facilities and Supporting   scheduling of its facilities. Such above-average usage of facilities places
                            additional loads and strains on their systems and components, increasing
Infrastructure              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.




                            Page 19                                  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.


FLETC Master Plan            The Master Plan’s recommendations for renovation and expansion of
Intended to Help Alleviate   existing, and the construction of new facilities are arrayed in three, partly
Capacity Constraints         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.




                             Page 20                               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.


FLETC’s Planning to    The FLETC Master Plan’s assumptions and methodologies in particular,
Address Its Capacity   and FLETC’s plan to address its capacity constraints in general, raise a
Constraints Raises     number of concerns. First, the plan assumes that the Border Patrol will
                       shift its basic training from the Charleston campus to the Artesia campus
Concerns               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).




                       Page 21                                         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 22                             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.


FLETC Does Not Have a     Adding to the long-term challenge of addressing its capacity constraints,
Contingency Plan to       FLETC does not currently have a formal written training contingency plan
Address Capacity          independent of the Master Plan for addressing its immediate training
                          capacity challenges, or the challenges leading up to when the plan’s
Constraints and Has Not   recommendations are expected to come on line in 2008. FLETC officials
Routinely Utilized        said that although they would like to have a written training contingency
Alternative Assets to     plan, and had been developing a contingency planning process, they were
Provide Basic Training    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 off-
                          site 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


                          Page 23                              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 Is Reviewing FLETC’s     DHS officials said that the department was in the process of reviewing the
Master Plan, but Considers   Master Plan, to be followed by an OMB review. Without offering details,
It of Limited Future Use     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
FLETC’s Current              process poses internal control risks. FLETC relies on a predominantly
Scheduling System Is         manual scheduling process that does not ensure the efficient use of
                             training resources and poses internal control risks due to potential loss of
at Risk and Its              scheduling materials and the lack of backup documentation. FLETC has
Acquisition of an            recognized these risks and is in the process of acquiring an automated
                             system, SASS, to address them. Although FLETC’s plans and activities for
Automated System             acquiring SASS generally include performance of certain key acquisition
Raises Concerns              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-


                             Page 24                             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.


Current Scheduling System    FLETC’s current system for scheduling training places efficient delivery of
Places the Delivery of       training services at risk. FLETC’s scheduling system is predominantly
Training Services at Risk    manual and only partly automated. The manual part of the system
                             involves, among other things, the use of large desk calendars, colored
and Does Not Maximize        markers, and color-coded post-it notes to schedule things such as student
Use of Existing Facilities   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 four17 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.




                             Page 25                                   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 26                                   GAO-03-736 Federal Law Enforcement Training
Background on the SASS     The SASS acquisition project began in 1999, when Congress provided
Acquisition                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 Has Yet to Address   FLETC’s plans and activities for acquiring SASS generally include the
Important SASS             performance of certain key acquisition management functions, such as
Acquisition Issues         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


                           Page 27                            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.

Certain Acquisition Functions   Carnegie Mellon University’s Software Engineering Institute (SEI),
Are Being Performed             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®
                                Version 1.03, CMU/SEI-2002-TR-010 (Pittsburgh, PA: March 2002).




                                Page 28                                 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 package20 (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 29                                   GAO-03-736 Federal Law Enforcement Training
Acquisition Risk Management   SEI’s acquisition model also recognizes the need to manage acquisition
Is Not Being Performed        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 COTS-
                              based solution). The result is a reduced probability of delivering promised
                              SASS capabilities on time and within budget.

Approach to Performing        Notwithstanding the fact that FLETC is performing key SASS acquisition
Acquisition Functions Lacks   functions, it is deficient in its performance of these functions in two ways.
Two Key Elements              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.




                              Page 30                              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 198722 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 31                                     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 cost-
effective approaches.




Page 32                                    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®, 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.


FLETC Is Exploring the   During our work, we learned that the Border Patrol Academy, in
Use of an Existing       conjunction with INS’s Immigration Officers Academy and the Customs
Automated Scheduling     Academy, were in the process of adding an automated scheduling module
                         to their ACMS. The Border Patrol and Immigration Officer Academies
System                   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



                         Page 33                             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
The Status of FLETC’s     membership, roles and responsibilities, and past practices are not fully
Board of Directors Is     consistent with prevailing governance and management control best
                          practices. Moreover, given its recent transition into DHS, FLETC needs
Unclear, and DHS Has      guidance and oversight to address its transformational challenges. A DHS
Begun to Provide          official said that DHS has recently assumed responsibility for FLETC and
                          has begun to work with its officials on ways to address these challenges.
Oversight and             The official also said DHS also recognizes the role an effective FLETC
Guidance                  Board could play in enhancing governance.


The Status of the FLETC   Prior to its most recent meeting in November 2002, FLETC’s Board of
Board of Directors Is     Directors had not met for 3-½ years, according to a FLETC official.
Unclear                   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.




                          Page 34                                   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.


Board’s Membership, Roles   Notwithstanding the uncertainty surrounding its status, the Board’s
and Responsibilities, and   membership, roles and responsibilities, and past practices are not fully
Past Practices Are Not      consistent with prevailing best practices for governance and internal and
                            management control.27
Fully Consistent with
Prevailing Governance and   Membership. Regarding the size of a board, prevailing governance best
Management Control Best     practices consider smaller boards to be often more cohesive and to work
Practices                   more effectively—in this regard, the FLETC Board is composed of eight
                            members. Specifically, FLETC’s Board presently has five term-
                            representatives 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.




                            Page 35                                   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 Enterprise28 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 36                                  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 37                             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 38                                   GAO-03-736 Federal Law Enforcement Training
DHS Has Begun to Provide    DHS has the opportunity to help FLETC face its challenges during the
Oversight and Guidance to   current period of transformational change. DHS officials said that other
FLETC                       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
Conclusions                 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,



                            Page 39                             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 40                             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
Recommendations for   recommend that the Secretary of Homeland Security instruct the Director
Executive Action      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




                      Page 41                              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 42                              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
Agency Comments      Attorney General for comment. We received comments from the Under
and Our Evaluation   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


                     Page 43                             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 44                              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 45                             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




Page 46                             GAO-03-736 Federal Law Enforcement Training
                 Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
                 Methodology



Methodology

                 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



                 Page 47                              GAO-03-736 Federal Law Enforcement Training
                          Appendix I: Objectives, Scope, and
                          Methodology




                          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
Capacity, Planning,       projected demand for training, how FLETC is planning to meet the
and Coordination          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.



                          Page 48                              GAO-03-736 Federal Law Enforcement Training
                          Appendix I: Objectives, Scope, and
                          Methodology




                          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
Scheduling and            coordinating and scheduling training activities, and whether FLETC plans
Coordination of           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
Training Activities       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



                          Page 49                              GAO-03-736 Federal Law Enforcement Training
                      Appendix I: Objectives, Scope, and
                      Methodology




                      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 systems2 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
Governance and        to which these structures are providing guidance to FLETC as it addresses
Oversight Structure   its capacity and planning challenges during a period of transformational
                      change, we reviewed FLETC’s 1970 MOU establishing, among other things,
and Guidance          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 ®
                      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).




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Methodology




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.




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              Appendix II: FLETC’s 75 Partner
Appendix II: FLETC’s 75 Partner
              Organizations



Organizations

              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




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Appendix II: FLETC’s 75 Partner
Organizations




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




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Appendix II: FLETC’s 75 Partner
Organizations




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



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Appendix II: FLETC’s 75 Partner
Organizations




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




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Appendix II: FLETC’s 75 Partner
Organizations




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




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              Appendix III: Training Programs and
Appendix III: Training Programs and
              Seminars Provided by FLETC



Seminars Provided by FLETC

              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



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Seminars Provided by FLETC




    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.




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             Appendix IV: Comments from the Department
Appendix IV: Comments from the
             of Homeland Security



Department of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




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of Homeland Security




Page 70                                GAO-03-736 Federal Law Enforcement Training
                  Appendix V: GAO Contacts and Staff
Appendix V: GAO Contacts and Staff
                  Acknowledgments



Acknowledgments

                  Richard M. Stana (202) 512-8777
GAO Contacts      Seto J. Bagdoyan (202) 512-8658


                  In addition to those named above, the following teams and individuals
Staff             contributed to this report: Wendy C. Simkalo, Jared Hermalin,
Acknowledgments   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.




(440125)
                  Page 71                              GAO-03-736 Federal Law Enforcement Training
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