oversight

Department of Homeland Security: Efforts to Assess Realignment of Its Field Office Structure

Published by the Government Accountability Office on 2012-09-28.

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

United States Government Accountability Office
Washington, DC 20548



          September 28, 2012

          The Honorable Joseph Lieberman
          Chairman
          The Honorable Susan Collins
          Ranking Member
          Committee on Homeland Security and
            Governmental Affairs
          United States Senate

          The Honorable Candice S. Miller
          Chairman
          The Honorable Henry Cuellar
          Ranking Member
          Subcommittee on Border and
            Maritime Security
          Committee on Homeland Security
          House of Representatives

          Subject: Department of Homeland Security: Efforts to Assess Realignment of Its Field Office
          Structure

          This letter formally transmits a summary of oral briefings we gave on September 19 and 21,
          2012 (see enc. 1), and subsequent agency comments. We provided this briefing in response
          to a request from you to examine issues surrounding the Department of Homeland
          Security’s (DHS) regional/field office realignment efforts. Our work focused on DHS
          realignment efforts beginning in 2004, when DHS submitted a report to Congress stating
          that it would implement a “Regional Concept” to improve coordination with external partners
          and integrate internal DHS functions within departmental regions. Specifically, we
          addressed

                   (1) the extent to which DHS has assessed the realignment of its key operational
                       components’ regional/field office structures since submitting its initial plan to
                       Congress in 2004, 1 and

                   (2) the challenges, if any, DHS and its key operational components have identified in
                       the department’s efforts to realign into a single DHS regional/field office structure,
                       and what, if any, alternative actions have been identified.


          1
           DHS officials identified the following as the key DHS operational components: Transportation Security
          Administration, U.S. Customs and Border Protection, U.S. Citizenship and Immigration Services, U.S.
          Immigration and Customs Enforcement, U.S. Secret Service, Federal Emergency Management Agency, and the
          U.S. Coast Guard.



          Page 1                                       GAO-12-185R DHS Realignment Efforts
Scope and Methodology
To address the first objective, we analyzed available reports and other documentation
related to DHS’s efforts to realign the regional/field office structure of its key operational
components since 2004. These efforts included DHS’s 2004 Operational Integration Staff (I–
Staff) effort, which focused on planning a DHS regional structure, and a recommendation
from the 2010 DHS Bottom-Up Review (BUR) Report to realign component regional
configurations into a single DHS regional structure. 2 We selected this period for review
because in 2004 DHS submitted a report to Congress stating that the department would
implement a “Regional Concept” and study other consolidation and colocation opportunities.
We also interviewed and corresponded with cognizant DHS headquarters and operational
component officials about past regionalization assessments, the current status of any
regionalization efforts, and any related potential future studies—including the extent to
which, if at all, any regionalization initiatives/recommendations were implemented, and the
basis for those decisions. Given the passage of time since the I-Staff effort, we also
interviewed a former department official who managed this effort.

To address the second objective, we interviewed and corresponded with cognizant DHS
headquarters and component officials to obtain their perspectives on the challenges or
drawbacks of regionalization in relation to the potential benefits. In these interviews and
correspondences, we also discussed alternatives to regionalization (such as colocation,
consolidation, or integration) that could better integrate component operations in the
region/field and achieve cost savings and efficiencies. We will initiate a follow-on effort to
examine the operational impacts of select smaller-scale alternatives (e.g., colocation,
consolidation, and integration) in more detail.

We conducted this performance audit from February 2012 through September 2012, in
accordance with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Summary
DHS reported taking some steps to assess the realignment of its regional/field office
structure. Since submitting an initial plan to Congress in 2004 that outlined regionalization,
consolidation, and colocation opportunities, DHS officials said the agency considered the
potential implementation of a unified regional field office structure through two major
initiatives—the 2004 I-Staff review and the department’s 2010 BUR. However, the I-Staff
Regional Concept of Operations was not finalized or adopted, and in April 2012 a senior
DHS official involved in the BUR effort stated that DHS no longer intends to implement the
BUR recommendation related to regionalization because it is no longer the department’s
preferred approach. DHS had limited or no documentation related to either of these reviews,
including the resulting key decisions from the efforts. As a result, we are unable to


2
 The BUR report identified 43 initiatives/recommendations, such as strengthening aviation security and enhancing
the department’s risk management capability, to strengthen DHS’s mission performance, improve departmental
management, and increase accountability. I-Staff personnel were responsible for assisting the Department
Leadership Team in the coordination and integration of cross-organizational operational missions, activities, and
programs at the DHS headquarters level.



Page 2                                                                  GAO-12-185R DHS Realignment Efforts
determine the extent to which DHS has fully considered the realignment of its regional/field
office structure, including costs and benefits, since 2004. Standards for Internal Control in
the Federal Government calls for clear documentation of significant events, which include
assumptions and methods surrounding key decisions, and the standards also state that this
documentation should be readily available for examination. 3 DHS officials acknowledged the
lack of documentation and plan to better document any future realignment efforts.

DHS and component officials stated that operational and current budgetary constraints were
key challenges to establishing a single DHS regional/field office structure, but they are
exploring smaller-scale alternatives. DHS and component officials identified several
challenges related to large-scale regionalization, including concerns that the initiative would
be disruptive to DHS and component workforce, missions, and operations. DHS officials
also said that such realignment efforts would likely divert staff from their normal mission-
focused duties. Another challenge cited was the cost associated with relocating facilities and
terminating leases. While officials acknowledged that long-term cost savings and efficiencies
could exceed the costs of initial investments in some cases, they stated that the short-term
implementation costs remain a significant barrier to the implementation of a regional
structure. Given the identified challenges of implementing a single, unified field office
structure, DHS officials said the department’s current thinking on harmonizing component
regional configurations is best reflected in the Department of Homeland Security Strategic
Plan: Fiscal Years 2012–2016. 4 Specifically, the department plans to “explore virtual
approaches to regional and functional coordination.” However, without having adequate,
specific documentation related to its regionalization assessments, decision makers at DHS
are in a weaker position to assess the strengths and weaknesses of related policy options or
alternatives.

Agency Comments
We provided a draft of this report to DHS for review and comment. We received written
comments from DHS, which are reproduced in enclosure II.

In commenting on this report, the department agreed with our findings and acknowledged
that its efforts to assess regionalization, colocation, consolidation, and operational
integration options could have been better documented. In addition, DHS stated that its
leadership is committed to better documenting any future examinations of regional/field
office realignment, as appropriate.

Although DHS stated in its agency comments letter that it appreciated GAO’s
acknowledgement that short-term implementation costs remain a significant barrier to
establishing a regional structure, it is important to note that we did not independently assess
any such costs. High implementation costs were identified to us by DHS and component
officials as one of several challenges to creating a regional structure. As noted throughout
the briefing, however, the department lacked documentation that would have allowed us to
evaluate its current position that the costs of developing a regional structure outweigh the



3
 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.:
November 1999).
4
 DHS, Department of Homeland Security Strategic Plan: Fiscal Years 2012-2016 (Washington, D.C.: February
2012).



Page 3                                                            GAO-12-185R DHS Realignment Efforts
benefits. Additionally, we received technical comments from DHS, which were incorporated
where appropriate.


We are sending copies of this report to the appropriate congressional committees, the
Secretary of Homeland Security, and other interested parties. This report is also available at
no charge on our website at http://www.gao.gov. Should you or your staffs have any
questions concerning this report, please contact me at (202) 512-9610 or
caldwells@gao.gov. Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. Key contributors to this report were
Dawn Hoff, Assistant Director; Charles Bausell; Tracey King; David Lutter; Frederick Lyles,
Jr.; Jessica Orr; and Cynthia Saunders.




Stephen L. Caldwell
Director
Homeland Security and Justice

Enclosures (2)




Page 4                                                     GAO-12-185R DHS Realignment Efforts
Enclosure I: Briefing for Congressional Committees




      Department of Homeland Security: Efforts to
     Assess Realignment of Its Field Office Structure



                        Prepared for the
         Senate Committee on Homeland Security and
      Governmental Affairs and the House Subcommittee on
          Border and Maritime Security, House Committee on
                      Homeland Security




   For more information, contact Stephen Caldwell, at (202) 512-9610 or caldwells@gao.gov.         Page 1




             Page 5                                                     GAO-12-185R DHS Realignment Efforts
Contents


•   Introduction

•   Objectives

•   Scope and Methodology

•   Results in Brief

•   Background

•   Findings

•   Appendix I




                                                       Page 2




          Page 6            GAO-12-185R DHS Realignment Efforts
 Introduction

•      DHS was created from 22 separate legacy agencies, and is currently the third largest
       federal department. DHS inherited the legacy regional/field office structures of many of its
       components. According to DHS officials, the department’s seven key operational
       components—each with a unique set of geographic regions and system of field offices that
       allow components to carry out their missions and deliver services across the country—are
       the
                    (1) Transportation Security Administration (TSA),
                    (2) U.S. Customs and Border Protection (CBP),
                    (3) U.S. Citizenship and Immigration Services (USCIS),
                    (4) U.S. Immigration and Customs Enforcement (ICE),
                    (5) U.S. Secret Service (USSS),
                    (6) Federal Emergency Management Agency (FEMA), and the
                    (7) U.S. Coast Guard (USCG).1
•      See appendix 1 for DHS’s organizational structure as of August 2012.
1TSA protects the nation’s transportation systems to ensure freedom of movement for people and commerce. CBP protects the nation’s borders to prevent terrorists and terrorist weapons

from entering the United States. while facilitating the flow of legitimate trade and travel. USCIS processes millions of applications and petitions for immigrant and nonimmigrant-related
benefits for persons seeking to study, work, visit, or live in the United States. ICE, the largest investigative arm of DHS, identifies and mitigates vulnerabilities in the nation’s border,
economic, transportation, and infrastructure security. USSS protects the President and other high-level officials and investigates counterfeiting and other financial crimes and computer-based
attacks on the nation’s financial, banking, and telecommunications infrastructure. FEMA prepares the nation for hazards, manages federal response and recovery efforts following any
national incident, and administers the National Flood Insurance Program. USCG protects the public, the environment, and U.S. economic interests in the nation’s ports and waterways, along
the coast, on international waters, and in any maritime region as required to support national security.

                                                                                                                                                                                 Page 3




                    Page 7                                                                                                    GAO-12-185R DHS Realignment Efforts
 Introduction (cont.)

•        The Homeland Security Act of 2002 required DHS to submit a plan to Congress for
         consolidating or colocating certain components’ regional or field offices, among other
         things.2

•        In response to this requirement, in 2004 DHS submitted a seven page document to
         Congress that presented the department’s actions and its proposed high-level approach to
         developing a consolidation and colocation plan. This report also stated the department
         would implement a “Regional Concept” to establish DHS regional directors in specific
         geographic areas to better integrate components, reduce unnecessary duplication, and
         improve coordination with external partners.




2Pub.   L. No. 107-296, § 706, 116 Stat. 2135, 2220 (2002).


                                                                                                  Page 4




                     Page 8                                          GAO-12-185R DHS Realignment Efforts
Introduction (cont.)

•   When discussing the department’s realignment efforts, DHS officials defined and used the
    following terms:

     1. Regionalization refers to full-scale realignment of DHS’s regional/field office structure,
        which includes the establishment of a single, commonly defined set of regions for all
        components.

     2. Colocation refers to the sharing of space, buildings, property, or other physical assets
        by components.

     3. Consolidation refers to the merging of organizational functions.

     4. Integration refers to the coordination of functions across components without
        consolidation or merger.
•   Given the magnitude and breadth of DHS’s operations and assets, potential changes to
    DHS’s regional/field office structure and also its physical footprint can have profound
    budgetary impacts—both costs and savings—as well as impacts on how the department
    carries out its homeland security missions.
                                                                                            Page 5




          Page 9                                                 GAO-12-185R DHS Realignment Efforts
Objectives

•         This briefing addresses the following questions:

          o      To what extent has DHS assessed the realignment of the regional/field office structure
                 of its key operational components since submitting its initial consolidation and
                 colocation plan to Congress in 2004?3

          o      What challenges, if any, have DHS and its key operational components identified in
                 DHS’s efforts to realign into a single DHS regional/field office structure, and what, if
                 any, alternative actions have been identified?




3DHS   officials identified the following as the key DHS operational components: TSA, CBP, USCIS, ICE, USSS, FEMA, and USCG.

                                                                                                                                                  Page 6




                   Page 10                                                                                             GAO-12-185R DHS Realignment Efforts
 Scope and Methodology

•         To address the first objective, we analyzed available reports and other documentation on
          DHS’s efforts to realign its regional/field office structure since 2004. This included DHS’s
          2004 Operational Integration Staff (I–Staff) effort, which focused on establishing a single
          DHS regional structure, and the 2010 DHS Bottom-Up Review (BUR) Report
          recommendation to realign component regional configurations into a single DHS
          regional structure.4 We selected this time frame because in 2004, in response to a
          legislative requirement, DHS submitted a report to Congress on office consolidation and
          colocation. We interviewed and corresponded with cognizant DHS headquarters and
          component officials about past regionalization assessments, the current status of any
          related efforts, and potential future studies—including the extent to which, if at all, any
          regionalization initiatives were implemented, and the basis for those decisions. Given the
          passage of time since the I-Staff effort, we also interviewed a former department official
          who managed that effort.




4The BUR report identified priority initiatives, such as strengthening aviation security and enhancing the department’s risk management capability, to strengthen DHS’s mission

performance, improve departmental management, and increase accountability. I-Staff personnel were responsible for assisting the Department Leadership Team in the
coordination and integration of cross-organizational operational missions, activities, and programs at the DHS headquarters level.

                                                                                                                                                                                  Page 7




                   Page 11                                                                                                    GAO-12-185R DHS Realignment Efforts
Scope and Methodology (cont.)

•   To address the second objective, we interviewed and corresponded with cognizant DHS
    headquarters and component officials to obtain their perspectives on regionalization
    challenges in relation to potential benefits. We also obtained DHS headquarters and
    component officials’ views regarding alternatives to regionalization (such as colocation,
    consolidation, or integration) that could better integrate component operations in the
    region/field and achieve cost savings and efficiencies.

•   We will initiate a follow-on effort to examine the operational impacts of select smaller-scale
    alternatives to regionalization (e.g., colocation, consolidation, and integration) in more
    detail.

•   We conducted this performance audit from February 2012 through September 2012, in
    accordance with generally accepted government auditing standards. Those standards
    require that we plan and perform the audit to obtain sufficient, appropriate evidence to
    provide a reasonable basis for our findings and conclusions based on our audit objectives.
    We believe that the evidence obtained provides a reasonable basis for our findings and
    conclusions based on our audit objectives.
                                                                                           Page 8




         Page 12                                                GAO-12-185R DHS Realignment Efforts
Results in Brief

DHS Regionalization Efforts
• DHS reported taking some steps to assess the realignment of its regional/field office
  structure. Since submitting an initial plan to Congress in 2004, DHS officials said the
  department considered the potential implementation of a unified regional field office
  structure through two major initiatives—the 2004 I-Staff effort and the department’s 2010
  BUR. However, the I-Staff Regional Concept of Operations was not finalized or adopted,
  and a senior DHS official involved with the creation of the BUR stated in April 2012 that DHS
  no longer intends to implement the BUR recommendation related to regionalization because
  it is not the department’s preferred approach.

•   DHS had limited documentation related to these reviews, including the resulting key
    decisions from the efforts. As a result, we are unable to determine the extent to which DHS
    has fully considered the realignment of its regional/field office structure, including costs and
    benefits, since 2004. Standards for Internal Control in the Federal Government calls for
    clear documentation of significant events, which include assumptions and methods
    surrounding key decisions, and the standards also state that this documentation should be
    readily available for examination.5 DHS officials acknowledged the lack of documentation
    and plan to better document any future regionalization efforts.
5GAO,   Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).


                                                                                                                                                      Page 9




                    Page 13                                                                                               GAO-12-185R DHS Realignment Efforts
Results in Brief (cont.)


DHS Identified Challenges to Regionalization

•   DHS headquarters and component officials identified operational and current budgetary
    constraints as key challenges to implementing a single DHS regional/field office
    structure, but said they are exploring smaller-scale alternatives. According to these
    officials, regionalization challenges include the following:

       o DHS components each have a different regional or field office structure based on
         unique mission needs.
       o Disruptions to DHS and component workforce, missions, and operations. Such a
         move would likely divert staff from their normal mission-focused duties.
       o Costs associated with relocating facilities and terminating leases.
       o Statutory provisions affecting DHS’s authority to reorganize.




                                                                                         Page 10




         Page 14                                               GAO-12-185R DHS Realignment Efforts
 Results in Brief (cont.)


 DHS Identified Challenges to Regionalization
 •          Given the challenges identified with implementing a single, unified field office structure, a
            senior DHS official said the department’s current thinking on harmonizing component
            regional configurations is best reflected in the Department of Homeland Security Strategic
            Plan: Fiscal Years 2012–2016.6

                 o Specifically, the department plans to “explore virtual approaches to regional and
                   functional coordination,” which according to the strategic plan includes using models
                   established in the interagency counternarcotics infrastructure.


 •          However, as previously noted, without having adequate documentation related to its
            regionalization assessments, decision makers at DHS have incomplete information to
            evaluate related policy options or alternatives.


6DHS,   Department of Homeland Security Strategic Plan: Fiscal Years 2012-2016 (Washington, D.C.: February 2012).


                                                                                                                                              Page 11




                     Page 15                                                                                        GAO-12-185R DHS Realignment Efforts
Results in Brief (cont.)


DHS Identified Alternatives to Regionalization

•   DHS and some components have studied alternatives to regionalization to improve the
    effectiveness and efficiency of their regional/field office operations through smaller-scale
    efforts such as colocation, consolidation, and integration. However, without adequate
    documentation on its regionalization assessments, DHS decision makers have limited
    information about the relative costs and benefits of regionalization versus these
    alternatives.

•   If DHS decides to revisit regionalization options in the future, it could improve the
    analytical foundation of its decisions through better documentation, including the basis for
    those decisions. Better documentation of regionalization options would also help DHS
    decision makers evaluate regionalization challenges and weigh the relative costs and
    benefits of alternatives, including smaller-scale alternatives, such as colocation,
    consolidation, and integration. In commenting on a draft of this briefing, DHS has agreed
    to better document any future examinations of regional/field office realignment, as
    appropriate.


                                                                                          Page 12




         Page 16                                                GAO-12-185R DHS Realignment Efforts
 Background

•        The Homeland Security Act of 2002 established DHS—combining 22 federal agencies
         specializing in various disciplines (such as law enforcement, border security, biological
         research, computer security, and disaster mitigation)—eventually resulting in seven major
         operational components with real property.7 When the legacy agencies were combined
         under DHS, they each brought with them their own field office structures and locations.

•        The seven key DHS operational components—TSA, CBP, USCIS, ICE, USSS, FEMA, and
         USCG—each have their own unique regional structures and systems of field offices. For
         example:

           o      Under FEMA’s structure, North Carolina is grouped with Southeastern states under a
                  FEMA regional office in Atlanta, GA, while under USCG’s structure, North Carolina is
                  grouped with Mid-Atlantic states under a USCG district office in Portsmouth, VA.

           o      Multiple components may maintain field offices in the same geographic location.
                  Seattle, for example, is the site of a major district/regional/field office for USCG,
                  FEMA, and CBP, respectively.
7Pub.   L. No. 107-296, 116 Stat. 2135 (2002).

                                                                                                     Page 13




                   Page 17                                                 GAO-12-185R DHS Realignment Efforts
    Background (cont.)

•    The inefficiences associated with each operational component having a different area of
     responsibility prompted some in DHS to promote the idea of a single, unified DHS
     regional/field office structure, sometimes referred to as regionalization.

       o   This concept would include a common set of boundaries for components’ regional
           operations, and the establishment of a DHS regional office within each of those
           regions headed by a regional director.

       o   Proponents believe that this system of DHS regional offices could better integrate the
           operations of multiple components, making DHS as a whole more responsive and
           better prepared to counter man-made or natural threats. Proponents also see
           opportunities for cost savings through the sharing of assets, including office space.

• Within the separate regional/field office structures that currently exist, DHS manages a
  portfolio of real property assets utilized by its multiple components. DHS reported that in
  fiscal year 2011, DHS managed a global real property portfolio of approximately 38,000
  assets, spanning all 50 states and 7 U.S. territories. These assets included approximately
  16,000 buildings, 19,000 structures (e.g., docks, airfields, and communication systems), and
  3,000 land assets.


                                                                                           Page 14




           Page 18                                               GAO-12-185R DHS Realignment Efforts
 Background (cont.)

•      In addition to broad efforts to realign the regional/field office structure, DHS and its
       components have focused more narrowly on individual assets and specific operations,
       including opportunities for colocation, consolidation, and integration.

•      In 2010, as part of a governmentwide effort to dispose of unneeded federal real estate
       and cut operating costs,8 DHS implemented its FY 2011 Cost Savings and Innovation
       Plan. Among other things, the plan includes proposals to consolidate certain assets.




8Presidential
            Memorandum: Disposing of Unneeded Federal Real Estate–Increasing Sales Proceeds, Cutting Costs, and Improving Energy Efficiency,
June 10, 2010.

                                                                                                                                               Page 15




                Page 19                                                                                  GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure

•            Since first reporting to Congress on this issue in 2004, DHS officials said that the
             department considered the potential implementation of a unified regional/field office
             structure through two major initiatives—the department’s I-Staff review in 2004, and the
             BUR process in 2010.9 Table 1 on the next slide provides a summary of these efforts and
             illustrates how at two different times—in 2004 and 2010—the department concluded that
             regionalization was a worthwhile endeavor, but then was not able to follow through with
             implementation for a variety of reasons.

•            Congress did not appropriate funds to implement the I-Staff’s Regional Concept in fiscal
             year 2006, and committee reports accompanying the appropriations act note a lack of
             specific planning by DHS.10




    9Another   significant DHS-wide structural review was the 2006 Second Stage Review, but this review did not explicitly examine field office regionalization.
    10S.   Rep. No. 109-083, at 11 (2005); H.R. Rep. No. 109-079, at 7 (2005).



                                                                                                                                                                   Page 16




                      Page 20                                                                                         GAO-12-185R DHS Realignment Efforts
Objective 1

Table 1: Major DHS Assessments of Regionalization since
2004
     Assessment efforts                             Description                         Conclusion or recommendation                 Implementation status


 Draft DHS Regional             The I-Staff was tasked with the development and       The draft 2004 Regional Concept of     Not implemented—Congress did not
 Concept of Operations,         implementation of a Regional Concept of               Operations called for the              appropriate funds to implement the
 2004                           Operations for a unified DHS regional/field office    establishment of common regions,       Regional Concept in fiscal year 2006,
                                structure.                                            each with a regional headquarters      and committee reports
                                                                                      led by a regional director. DHS        accompanying the appropriations act
                                                                                      requested about $50 million in its     noted a lack of specific planning by
                                                                                      fiscal year 2006 budget request to     DHS. In addition, DHS was not able
                                                                                      implement the Regional Concept.        to provide GAO with documentation
                                                                                                                             to further justify this budget request
                                                                                                                             or explain why the Regional Concept
                                                                                                                             was not finalized or implemented.


 Bottom-Up Review Report,       The BUR included an assessment of the                 The BUR contained a                    Not implemented—DHS officials said
 2010a                          organizational alignment of the department with       recommendation for DHS to realign      there was no documentation to
                                homeland security missions set forth in the           its component regional                 support why the BUR realignment
                                Quadrennial Homeland Security Review Report           configurations into a single DHS       recommendation was included in the
                                (QHSR), including the department’s organizational     regional structure.                    BUR, or documentation to support
                                structure.b                                                                                  why it is no longer being pursued.


Source: GAO analysis of documents provided by DHS.
aDHS, Bottom-Up Review Report, Washington, D.C., July 2010.

bThe BUR Report contains 43 recommendations. The Implementing Recommendations of the 9/11 Commission Act of 2007 required DHS to provide a comprehensive

examination of the U.S. homeland security strategy every 4 years. 6 U.S.C. § 347. In response, DHS issued its first QHSR report in February 2010 and a BUR report in
July 2010, to identify initiatives to implement the QHSR.




                                                                                                                                                        Page 17




                 Page 21                                                                                      GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

I-Staff Effort

•    In 2004, the I-Staff was established to assist DHS leadership to coordinate and integrate
     department missions and operational activities, including the development and
     implementation of a single, unified DHS regional/field office structure. According to senior
     DHS officials, the goal of this structure was to increase national homeland security
     functions through greater coordination and integration—not just among DHS headquarters
     and components—but also among other federal, state, local, tribal, international, and
     private stakeholders.

•    To this end, in 2004 the I-Staff developed a draft Regional Concept of Operations, which
     included regionalization pilot exercises, and a phased implementation timeline for eight
     regional locations. The draft Regional Concept of Operations also included a detailed
     description of regional concept legal authorities, mission, and staff structure. The draft
     Regional Concept of Operations delineated roles and responsibilities for DHS
     headquarters and regional offices in seven key areas:

    o    (1) Communication and coordination; (2) planning and analysis; (3) situational
         awareness; (4) integration; (5) preparedness, training, and exercises; (6) routine
         operations; and (7) contingency operations.
                                                                                           Page 18




          Page 22                                                GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

I-Staff Effort

•    The draft plan outlined the roles of DHS regional directors and identified their particular
     authorities and relationships with DHS headquarters and component officials. The
     Regional Concept of Operations contained an implementation timeline to establish the
     DHS regions over a period of approximately 2 years. In 2005, then-secretary Thomas
     Ridge publicaly praised the Regional Concept of Operations as the next logical step to
     support an integrated, unified national effort to secure the United States.

•    However, the I-Staff Regional Concept of Operations was not finalized or adopted. DHS
     requested about $50 million in its fiscal year 2006 budget submission to support the
     establishment of a unified regional structure, stating that the department anticipated that
     regionalization would improve program delivery and effectiveness, as well as achieve
     efficiencies through such things as the integration and consolidation of information
     technology, facilities, and operations centers. Congress did not appropriate funds for this
     purpose, however, and committee reports accompanying the appropriations act state that
     the committees did not yet have enough information about DHS’s plan. DHS did not
     provide us with any additional documentation that may have further justified this request
     for an appropriation.


                                                                                            Page 19




          Page 23                                                 GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

BUR Recommendation
•      The BUR was initiated in November 2009 as an immediate follow-on and complement to
       the DHS QHSR.11 Secretary Janet Napolitano noted that “the BUR provides the results of
       an unprecedented Department-wide assessment of DHS” to align its programs and
       organizational structure with the mission sets and goals contained in the QHSR. To help
       achieve this, the BUR contains 43 specific initiatives to be implemented over several years.
•      One BUR recommendation is for the department to “realign component regional
       configurations into a single DHS regional structure.” Specifically, the recommendation
       states:
                 “To streamline operations nationally, increase efficiencies, and enhance cross-
                 training and rotational assignments, DHS will align the seven separate regional
                 structures currently in use . . . to a single nation-wide regional structure.”
•      Despite the publication of this recommendation in the July 2010 BUR report, in April 2012
       a senior DHS official involved with the creation of the BUR stated that DHS has no plan to
       implement this recommendation because the department and its components no longer
       view regionalization as their preferred approach.
11InFebruary 2010, DHS issued its first QHSR, outlining a strategic framework for homeland security to guide the activities of homeland security
partners, including federal, state, local, and tribal government agencies; the private sector; and nongovernmental organizations.

                                                                                                                                                   Page 20




                  Page 24                                                                                        GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

•   Both the I-Staff effort and the BUR recommendation that directly focused on potential DHS
    actions to create a unified regional/field office structure have limited or incomplete
    analytical assessments to assist decision makers, or limited documentation to help explain
    or justify the decisions that DHS leadership ultimately made. Although DHS and other
    knowledgeable officials reported that significant effort and resources were invested in
    these reviews, DHS was not able to provide substantial documentation or analyses of their
    results, including evaluations of costs and benefits.

    o   According to DHS officials, the analysis underlying the I–Staff draft Regional Concept
        of Operations was fairly robust. However, the I-Staff’s draft Regional Concept of
        Operations document provided to us was incomplete—it contained placeholders for
        future analyses and component input, and actions that were never conducted,
        according to a senior DHS official.

    o   For the BUR, DHS could not provide any documentation or analyses to demonstrate:
        (1) how the BUR regional/field office initiative was initially developed and why it was
        included in the BUR report, and (2) how the decision was made subsequently to not
        implement the initiative.
                                                                                           Page 21




          Page 25                                                GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

       o      According to a senior DHS official, most of the deliberations about the BUR
              realignment recommendation were conducted orally and not documented. As a
              result, we are unable to determine the extent to which DHS has fully assessed the
              realignment of its regional/field office since 2004.

       o      In addition, the department has been unable to provide us with documentation
              underlying the key decisions resulting from both the I-Staff and BUR efforts,
              especially regarding the change in policy from supporting DHS regional/field offices
              in 2004 and 2010 to no longer supporting this concept.

•     Standards for Internal Control in the Federal Government calls for clear documentation of
      significant events, which includes assumptions and methods surrounding key decisions,
      and the standards also state that this documentation should be readily available for
      examination. All documentation and records should be properly managed and
      maintained.12

12GAO/AIMD-00-21.3.1.




                                                                                              Page 22




               Page 26                                              GAO-12-185R DHS Realignment Efforts
Objective 1

DHS Steps to Assess the Realignment of Its Regional/Field
Office Structure (cont.)

DHS Had Limited Documentation—I-Staff and BUR Efforts

•   DHS leadership ultimately decided that the costs and other challenges to develop and
    implement a unified regional field office structure outweighed the potential benefits. Since
    then a senior DHS official authorized to speak about departmental policy stated that the
    department has no plans to study regionalization options in the future.

•   In discussing the lack of documentation with DHS officials, they acknowledged that the
    documentation of earlier analyses, and the retention of such documentation, should have
    been better. They also stated that if the department undertakes another effort to study
    the costs and benefits of a unified regional structure, it will document any analyses and
    decisions in accordance with internal control standards and maintain such information in
    accordance with applicable DHS document retention policies—such as the Executive
    Level Records Schedule and the National Archives and Records Administration General
    Records Schedule. The department repeated this intention in its official response to our
    report.



                                                                                          Page 23




         Page 27                                                GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives
DHS Identified Challenges

•   Officials from DHS headquarters and key operational components commented on
    challenges to implementing a single DHS regional/field office structure. Identified
    challenges included

    o    variation in the geographic basis for operational component missions,
    o    potential disruption and negative impacts on components’ operations,
    o    potential large up-front costs of creating a single DHS regional office structure, and
    o    statutory provisions affecting DHS’s authority to reorganize.
•   Given these types of challenges, officials stated that DHS and its components are
    exploring alternatives to regionalization, such as colocation, consolidation, and
    integration.




                                                                                           Page 24




         Page 28                                                 GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)

DHS Identified Challenges


•   DHS components each have a different regional or field office structure based on
    unique mission needs. For example, FEMA’s 10 “regions” do not correspond to the
    USCG’s 9 “districts,” which do not correspond to CBP’s 20 Border Patrol “sectors.”
    Officials said that there were mission-based reasons for each of the components having
    different regional structures:

    o   According to DHS officials, it would be a challenge to establish criteria and determine
        a single set of regional office locations and geographic boundaries across all
        components. For example, a regional footprint that may make sense for CBP along
        the border may not be well suited to FEMA’s mission.




                                                                                         Page 25




         Page 29                                               GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)

DHS Identified Challenges

•   Potentially Disruptive to DHS and Component Workforce, Missions, and Operations

    o   DHS officials stated that a large-scale realignment effort would likely divert staff from
        their normal mission-focused duties.

    o   DHS officials also said that chain of command issues were a challenge to creating
        DHS regional offices that house multiple components. According to senior DHS
        officials, from the components’ viewpoint, they have certain authorities and mission
        obligations for which they are held accountable. Senior DHS officials stated that
        component heads largely objected, therefore, to a structure that would turn over any
        component authority to regional DHS officials.




                                                                                          Page 26




         Page 30                                                GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)
DHS Identified Challenges

•   Potentially Disruptive to DHS and Component Workforce, Missions, and Operations
    (cont.)

    o   Some component officials also commented that field office realignment could
        negatively affect their relationships with stakeholders. For example, FEMA officials
        said that state and local governments, along with private sector entities, “knew who to
        call” at FEMA, and that coordination between FEMA regions and stakeholders was
        generally good. FEMA officials said that adding another federal layer (e.g., a DHS
        regional office official) could complicate FEMA’s relationships with locals.

    o   Moving to a unified field office structure would also likely require operational sacrifices
        by some of the components. For example, different components have different public-
        facing “personas.” From a public relations perspective, it may not make sense to
        colocate USCIS’s customer service-oriented functions with ICE’s investigative
        functions, according to DHS officials.


                                                                                           Page 27




         Page 31                                                 GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)
DHS Identified
DHS Identified Challenges
               Challenges
•         Budgetary, Management, and Data Constraints Associated with Relocating
•         Potentially
          Facilities Disruptive to DHS and Component Workforce, Missions, and Operations
          (cont.)
           o DHS officials cited challenges due to the constrained budget environment, and the
               logistical
           o Some         issues involved
                       component     officialswith
                                               alsoDHS   components
                                                     commented         receiving
                                                                  that field officeappropriations   through
                                                                                    realignment could
               several  separate   funding    streams.
               negatively affect their relationships with stakeholders. For example, FEMA officials
               said that state and local governments, along with private sector entities, “knew who to
           o call”
               DHSat and   component
                        FEMA,   and that officials also cited
                                            coordination      costs FEMA
                                                           between  associated    withand
                                                                             regions   relocating facilities
                                                                                           stakeholders   wasand
               terminating   leases.  While   officials acknowledged     that large long-term  cost
               generally good. FEMA officials said that adding another federal layer (e.g., a DHS     avoidance
               may be achieved
               regional             through
                         office official) couldstreamlining
                                                  complicateand  reducing
                                                              FEMA’s         real estate,
                                                                       relationships      they
                                                                                       with    said
                                                                                            locals.
               implementation and maintenance costs of a regional structure could be significant.
          o       Moving
                  DHS officials  to a unified
                                          statedfieldand office
                                                            our priorstructure
                                                                          work has   would   foundalsothatlikelyDHS require       operational
                                                                                                                         real property            data  sacrifices
                                                                                                                                                           are
                  by    some ofand
                  unreliable           theinconsistent
                                            components.across      For example,
                                                                            components.     different      components
                                                                                                    13 Although         efforts   haveare different
                                                                                                                                              under way      public-
                                                                                                                                                                  to
                  facing
                  improve      “personas.”        From adifficult
                                   data, it remains            publicfor relations
                                                                              planners    perspective,
                                                                                               to identify itopportunities
                                                                                                                    may not make           forsense
                                                                                                                                                 office to
                  colocate
                  realignment.     USCIS’s customer service-oriented functions with ICE’s investigative
13
                  functions,
    We have identified                according
                       real property management acrossto
                                                       theDHS      officials.
                                                          federal government as a high-risk area. Many of the challenges highlighted in this work are applicable to
DHS’s portfolio management. See for example, GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011). Also see GAO, Federal Real Property:
DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges, GAO-07-658 (Washington, D.C.: June
22, 2007).

                                                                                                                                                      Page 27
                                                                                                                                                           28




                   Page 32                                                                                     GAO-12-185R DHS Realignment Efforts
Objective 2

DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)
DHS Identified Challenges
••     DHS’s authority
       Budgetary,                       to reorganize
                              management,               and datahas statutory
                                                                         constraints      limits.     According
                                                                                                associated            withto arelocating
                                                                                                                                  senior DHS            official,
                                                                                                                                                     facilities.
       the agency faces legal constraints to departmental reorganizations. The Homeland
       Security
        o DHSAct               provided
                           officials     cited thechallenges
                                                     Secretarydue      of Homeland
                                                                            to the constrained Security certain
                                                                                                              budget authorities
                                                                                                                            environment,        to “establish”
                                                                                                                                                     and the
       and “alter”          organizational           units    within     the   department.
                 logistical issues involved with DHS components receiving appropriations through
                                                                                                    14 However,            a   senior       DHS       official
       statedseveralthat the       authority       of the
                               separate funding streams.      department         to   create       a  unified       regional/field           office    structure
       remains limited. For example, by law USSS and USCG must be maintained as “distinct
       entities”
        o Costs        within      DHS.15 However,
                             associated          with relocating similar    limitations
                                                                          facilities     and existed
                                                                                                 terminating  at the     time ofWhile
                                                                                                                      leases.          the I-Staff
                                                                                                                                                officials  and
       BUR acknowledged
                  studies which did              not   prevent       these     efforts      from     recommending
                                            that large long-term cost avoidance may be achieved through                          a   unified      regional
       structure.streamlining and reducing real estate, they said implementation and maintenance
•      In part   costs
                     becauseof a regional
                                     of all of structure
                                                  these challenges,could be DHS  significant.
                                                                                           officials reported prioritizing other
       initiatives over a unified field office structure. These include smaller-scale colocation,
        o DHS officials
       consolidation,             and stated        and our
                                          integration       effortsprior   work
                                                                        that   arehas largelyfound ledthatby theDHScomponents.
                                                                                                                         real property data are
                 unreliable and inconsistent across components.14 Although efforts are underway to
•      However,  improve   as noted
                                 data, itpreviously          in this briefing,
                                              remains difficult          for planners  without      the benefit
                                                                                               to identify               of substantive
                                                                                                                  opportunities            for office
       documentation
                 realignment.       related      to regionalization           efforts,      DHS      decision        makers         may lack
       assurances that their decisions are based on sound analyses. For example, documenting
14     the
  We have      costs
          identified real and
                          propertybenefits       of regionalization
                                   management across                         and
                                                      the federal government as a highalternatives          could
                                                                                       risk area. Many of the         assist
                                                                                                              challenges          officials
                                                                                                                         highlighted in this workin
                                                                                                                                                  are applicable to
       evaluating
DHS’s portfolio management. a  range
                              See          of
                                   for example,field  office
                                                GAO, High-Risk  realignment
                                                               Series:                options.
                                                                       An Update, GAO-11-278    (Washington, D.C.: Feb. 2011). Also see GAO, Federal Real Property:
DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges, GAO-07-658 (Washington, D.C.: June
146 U.S.C. § 452.
22,
15182007).
     U.S.C. § 3056(g); 6 U.S.C. § 468.

                                                                                                                                                      Page 29
                                                                                                                                                           28




                 Page 33                                                                                        GAO-12-185R DHS Realignment Efforts
Objective 2


DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)
DHS Identified Alternatives to Regionalization
•        Given the challenges of implementing a single, unified field office structure, a senior DHS
         official said the department’s current thinking on harmonizing component regional
         configurations is best reflected in the DHS Strategic Plan: Fiscal Years 2012–2016.16
         o      Specifically, the department plans to “explore virtual approaches to regional and
                functional coordination,” which according to the strategic plan includes using models
                established in the interagency counternarcotics infrastructure. For example, USCG is
                establishing capabilities for some Interagency Operations Centers virtually—that is,
                sharing information and coordinating with port partners through an Internet web
                portal.17 In addition, DHS and some components have studied or taken actions to
                improve the effectiveness and efficiency of their regional/field office operations
                through actions such as colocation, consolidation, and integration.
         o      Table 2 provides an overview of initiatives that DHS identified as alternatives to
                regionalization. These reports or assessments were intended to identify opportunities
                to improve aspects of DHS’s regional/field office structure since 2004; however, not
16DHS,
                all recommendations were fully implemented as of August 2012.
       Department of Homeland Security Strategic Plan: Fiscal Years 2012–2016 (Washington, D.C.: February 2012).
17InteragencyOperations Centers are designed to, among other things, share maritime information with USCG’s port partners (other agencies and organizations it
coordinates with). See GAO, Maritime Security: Coast Guard Needs to Improve Use and Management of Interagency Operations Centers, GAO-12-202
(Washington, D.C.: Feb. 13, 2012).

                                                                                                                                                       Page 30




                 Page 34                                                                                       GAO-12-185R DHS Realignment Efforts
Objective 2

Table 2: DHS Reports and Assessments of Colocation,
Consolidation, and Integration Options since 2004
            Reports/assessments                                  Description                                                       Conclusion or recommendation
Department of Homeland Security, Homeland      Initial 2004 report responded to a statutory        Initial report did not identify any specific regional or field offices to consolidate or colocate;
Security Act of 2002 (P.L. 107-296); Section   requirement by presenting DHS’s actions to          rather it outlined the key steps to create such a plan.
706 Report to Congress on Office               date and approach to develop a consolidation
Consolidation and Co-locationa                 and colocation plan.                                Follow-on report stated that a “Regional Concept” referenced in the initial Section 706
                                                                                                   Report would address operational and coordination/integration concerns.
Follow-on Section 706 Congressional Report:    Follow-on report addressed operational
DHS Inquiry Response to the Subcommittee       coordination/integration.                           According to a senior DHS official, recommendations have not been fully implemented.
on Energy Policy, Natural Resources, and
Regulatory Affairsb, c
General Services Administration (GSA), Draft   Draft report provided information to DHS to         GSA identified 158 buildings in 42 cities for potential regional office sites.
DHS Regional Office Site Analysis,             assist it in establishing its regional structure—
Washington, D.C., 2004d                        included analyses on site and space selection.      According to a senior DHS official, recommendations have not been fully implemented.


Immigration and Customs Enforcement (ICE),     Congress directed ICE to submit a report on         The plan identified 56 consolidation projects in 55 cities to be completed from fiscal year
ICE Co-location Study Volumes 1 & 2e           the cost and schedule for colocating ICE            2008 through 2018.
                                               personnel within cities where ICE assets were
                                               located.                                            According to a senior DHS official, recommendations have not been fully implemented.

Department of Homeland Security, Real          2008 report focused on potential colocation         Recommended (1) Co-locate CBP, USCG and TSA at a new location near the Miami
Property Co-location Study: DHS-Wide Co-       scenarios in the Miami, Florida area.               International Airport; and (2) Co-locate CBP and USCG Port of Miami operations.
Location Feasibility Initiativef
                                                                                                   According to a senior DHS official, recommendations have not been fully implemented.


Source: GAO analysis of documents provided by DHS.
aDHS,  Homeland Security Act of 2002 (P.L. 107-296); Section 706 Report to Congress on Office Consolidation and Co-location, Washington, D.C., February 4, 2004.
bDHS,  Section 706 Congressional Report: DHS Inquiry Response to the Subcommittee on Energy Policy, Natural Resources, and Regulatory Affairs, Washington, D.C., 2004.
cBoth Section 706 Reports reference DHS regionalization. We did not include these reports in table 1 because they respond to Congressional inquiries primarily related to consolidation

and colocation.
dGSA, Draft DHS Regional Office Site Analysis, Washington, D.C., 2004.

eICE, ICE Co-location Study: Volume 1 (Rationale and Execution) & Volume 2 (Acquisition Strategy), Washington D.C., Sept. 12, 2008.

fDHS, Real Property Co-location Study: DHS-wide Co-location Feasibility Initiative, Washington, D.C., Mar. 18, 2008.



.
                                                                                                                                                                                       Page 31




                    Page 35                                                                                                       GAO-12-185R DHS Realignment Efforts
Objective 2


DHS Identified Challenges to a Single DHS Regional/Field Office
Structure, and Alternatives (cont.)
DHS Identified Alternatives to Regionalization
•  According to senior DHS officials, consolidation, colocation, or integration efforts have
   been initiated by one or more components based on local conditions and smaller-scale
   regionalization has occurred “organically” where it makes sense. For example, multiple
   DHS components and other stakeholders utilize colocation and intelligence integration to
   coordinate counternarcotics operations through JIATF South.18

•          DHS’s Chief Administrative Officer is accountable for managing DHS’s real estate
           portfolio. In addition, officials with the Program Analysis and Evaluation (PA&E) Division
           described past colocation studies conducted as part of the budget process. Specifically, in
           2009 PA&E identified 22 colocation opportunities for FEMA, ICE, USCG, and CBP offices.
           A parallel effort identified opportunities for USCG and CBP air asset co-location. No
           recommendations from these studies were implemented. However, DHS has requested
           funding for the ICE-wide colocation strategy in its fiscal year 2013 budget submission. A
           PA&E official said that it is now largely up to individual components to pursue their own
           opportunities for colocation, but resource constraints have limited such initiatives, given
           the expenses of lease consolidation.
    18JIATF South, located in Key West, Florida, serves as the catalyst for integrated and synchronized interagency counterdrug operations and is responsible for the detection and monitoring
    of suspect air and maritime drug activity in the Caribbean Sea, the Gulf of Mexico, and the eastern Pacific.


                                                                                                                                                                               Page 32




                      Page 36                                                                                                    GAO-12-185R DHS Realignment Efforts
Appendix I


Figure 1: DHS Agencies and Key Operational Components as
of August 2012




 Note: DHS officials identified the following as the key DHS operational components—Transportation Security Administration, U.S. Customs and Border Protection, U.S. Citizenship and
 Immigration Services, U.S. Immigration and Customs Enforcement, U.S. Secret Service, Federal Emergency Management Agency, and the U.S. Coast Guard.


                                                                                                                                                                       Page 33




                 Page 37                                                                                                  GAO-12-185R DHS Realignment Efforts
Enclosure II: Agency Comments




Page 38                         GAO-12-185R DHS Realignment Efforts
(441043)



Page 39    GAO-12-185R DHS Realignment Efforts
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