oversight

Federal Protective Service's Organizational Placement: Considerations for Transition to the DHS Management Directorate

Published by the Government Accountability Office on 2019-06-11.

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

                           United States Government Accountability Office
                           Testimony
                           Before the Subcommittee on Oversight,
                           Management and Accountability,
                           Committee on Homeland Security,
                           House of Representatives
For Release on Delivery
Expected at 2:00 p.m. ET
Tuesday, June 11, 2019
                           FEDERAL PROTECTIVE
                           SERVICE'S
                           ORGANIZATIONAL
                           PLACEMENT
                           Considerations for
                           Transition to the DHS
                           Management Directorate
                           Statement of Lori Rectanus
                           Director, Physical Infrastructure




GAO-19-605T
                                                June 11, 2019

                                                FEDERAL PROTECTIVE SERVICE’S
                                                ORGANIZATIONAL PLACEMENT
                                                Considerations for Transition to the DHS
Highlights of GAO-19-605T, a testimony before
                                                Management Directorate
the Subcommittee on Oversight, Management
and Accountability, Committee on Homeland
Security, House of Representatives



Why GAO Did This Study                          What GAO Found
FPS conducts physical security and law
enforcement activities for about 9,000          In its January 2019 report, GAO identified five key criteria relevant for evaluating
federal facilities and the millions of          placement options for the Federal Protective Service (FPS) within the
employees or visitors who work in or            Department of Homeland Security’s (DHS) or other federal agencies. (See table.)
visit these facilities. Legislation enacted
in November 2018 required DHS to                Key Criteria for Evaluating Placement Options for the Federal Protective Service (FPS)
determine the appropriate placement for
                                                 Key criteria                      Description
FPS. The legislation also gave the               Misssion, goals, and objectives   An agency’s ability to function well is dependent upon having a
Secretary of DHS authority to move FPS                                             clear mission, goals and objectives.
within DHS. In May 2019, DHS                     Responsibilities                  In order for an agency to perform its duties, it needs to have
announced its decision to place FPS                                                clear responsibilities and the capacity to do them. Agency
within the DHS Management Directorate                                              responsibilities generally stem from the objectives outlined in
as a direct report to the Under Secretary                                          strategic plans and can take the form of Memoranda of
                                                                                   Agreement or agency directives.
for Management.                                  Organizational culture            Organizational culture includes the underlying beliefs, values,
                                                                                   attitudes, and expectations that influence the behaviors of
GAO has reported that FPS faces                                                    agency employees.
persistent challenges in meeting its             Information sharing and           An agency’s ability to share information related to national
mission to protect facilities, and, as of        coordination                      homeland security is necessary for the protection of federal
                                                                                   facilities. Coordination refers to working with other agencies to
2019, physical security continues to be                                            provide this protection.
part of GAO’s federal real property              Mission support                   Mission support includes training, financial management, human
management high-risk area. For                                                     capital, and information technology (IT) to support the agency in
example, FPS has not yet fully                                                     fulfilling its mission.
implemented its guard management                Source: GAO. | GAO-19-605T
system. Thus, FPS is unable to obtain
information to assess its guards’         Placing FPS, in the DHS Management Directorate was not an option GAO
capability to address physical security
                                          assessed in its January 2019 report. However, GAO did assess the option of
risks across its portfolio.
                                          making FPS a “standalone” entity reporting directly to the Deputy Secretary of
This statement describes considerations
                                          DHS. GAO found that this placement met the first criteria (mission, goals, and
for FPS’s placement in DHS’s              objectives)   and the third criteria (organizational culture) but did not completely
Management Directorate based upon         meet   the other  criteria. For example, FPS had joint responsibility for coordinating
five key organizational placement         facility protection  with other federal agencies. DHS did not have joint
criteria GAO identified, as well as steps responsibility for coordinating facility protection with FPS. GAO recommended
to transition FPS based upon GAO’s        DHS fully evaluate placement options for FPS. DHS concurred, and officials
prior work on organizational change.      stated they conducted an assessment. GAO has not yet received DHS’s
                                          assessment of placement options.
This testimony is based on reports GAO
issued from 2002 through 2019,                  GAO’s prior work on implementing an organizational change provides valuable
particularly, GAO’s January 2019 report         insights for making any transition regarding FPS. These insights include key
on FPS’s organizational placement.              questions to consider such as: “What are the goals of the consolidation?” “How
Detailed information on the scope and           have stakeholders been involved in the decision-making?” In addition, GAO has
methodology for this work can be found
                                                identified key practices for organizational transformation, practices that include
in these published products, cited
                                                ensuring that top leadership drives the transformation and establishing a
throughout this testimony.
                                                communication strategy to create shared expectations, among others. These
                                                questions and practices could provide insights to DHS and FPS as they
                                                implement FPS’s new placement.
View GAO-19-605T. For more information,
contact Lori Rectanus at (202) 512-2834 or
rectanusl@gao.gov.
                                                ______________________________________ United States Government Accountability Office
Letter
         Letter




         Madam Chairwoman Torres Small, Ranking Member Crenshaw, and
         Members of the Subcommittee:

         I am pleased to be here today to discuss considerations related to the
         Federal Protective Service’s (FPS) organizational placement. For almost
         50 years, FPS has been charged with protecting federal facilities and the
         millions of employees and individuals who work in or visit them. FPS
         provides physical-security and law-enforcement services at about 9,000
         facilities, a majority of which are held 1 or leased by the General Services
         Administration (GSA).

         The organizational placement of an office or agency can affect its
         performance and ability to meet its mission. Our prior work has found that
         during FPS’s previous organizational placements in GSA and two
         agencies within the Department of Homeland Security (DHS), it
         experienced a number of operational, management, and funding
         challenges, which had a bearing on its ability to accomplish its mission.
         Most recently, in January 2019, we reported that FPS had made progress
         in addressing some of these challenges, but others persisted. We also
         identified criteria DHS should consider in evaluating organizational
         placement options for FPS. 2

         In May 2019, DHS announced its decision to transfer FPS from its
         Cybersecurity and Infrastructure Security Agency (CISA) to its
         Management Directorate, and to report to the Under Secretary for
         Management. We have also previously reported on practices to consider
         in implementing organizational transformations or reorganizations. 3 In
         light of DHS’s decision, this testimony describes (1) considerations for
         FPS’s placement in DHS’s Management Directorate, and (2) steps to
         transition FPS.

         This statement is primarily based on our January 2019 report. For that
         report, we reviewed our 2002 work related to organizational
         1
             GSA-held facilities are federally-owned facilities under the custody and control of GSA.
         2
          GAO, Federal Protective Service: DHS Should Take Additional Steps to Evaluate
         Organizational Placement, GAO-19-122 (Washington, D.C.: Jan. 8, 2019).
         3
          GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and
         Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003) and GAO,
         Streamlining Government: Questions to Consider When Evaluating Proposals to
         Consolidate Physical Infrastructure and Management Functions, GAO-12-542
         (Washington, D.C.: May 23, 2012).




         Page 1                                                                           GAO-19-605T
transformation, which we conducted prior to the creation of DHS. 4 From
this prior work, we identified five key criteria for assessing potential
placement options for FPS and we applied those key criteria to eight
agencies that we identified as potential organizational placement options
for FPS. 5 For each criterion, we also identified elements (i.e.,
characteristics) that were specific to FPS based on our review of FPS
documents, our prior work on topics related to the criterion, as well as our
discussions with federal officials, an association representing federal law
enforcement officers, and a former high-ranking official in the former
National Protection and Programs Directorate (NPPD)—now reorganized
as CISA—with knowledge of FPS. We identified placement options at
agencies inside and outside of DHS that have similar responsibilities,
where FPS was previously placed, or that reflected FPS’s management
preference. We also reviewed our prior work on organizational change
and Standards for Internal Control in the Federal Government for relevant
management responsibilities. 6

Our January 2019 report includes further details on the scope and
methodology of our work.

We conducted the work on which this statement is based 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



4
 GAO-19-122 and GAO, Homeland Security: Critical Design and Implementation Issues,
GAO-02-957T (Washington D.C.: July 17, 2002).
5
  GAO-02-957T identified criteria topics that include four overall purpose and structure
questions, and seven organizational and accountability questions. We selected the most
relevant questions to develop criteria for FPS’s organizational placement. The eight
selected agencies are the Department of Homeland Security (DHS); U.S. Customs and
Border Protection; U.S. Immigration and Customs Enforcement (ICE); National Protection
and Programs Directorate (NPPD); United States Secret Service; General Services
Administration (GSA); Department of Justice (Justice); and the U.S. Marshals Service
(Marshals). We assumed that FPS would be a standalone entity in DHS, GSA, or Justice.
At the end of GAO’s review, in November 2018, NPPD was renamed the Cybersecurity
and Infrastructure Security Agency (CISA). In its January report, GAO referred to this
agency as NPPD.
6
 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D. C.: Sept. 10, 2014).




Page 2                                                                      GAO-19-605T
             provides a reasonable basis for our findings and conclusions based on
             our audit objectives. 7


             While the core mission of protecting federal facilities has remained
Background   constant as FPS has moved from one agency to another, its
             responsibilities have changed. In the 1970s, GSA created FPS as part of
             its Public Buildings Service (PBS). While in GSA’s PBS, FPS was
             responsible for protecting GSA’s held or leased facilities, providing both
             physical security and law enforcement services. To protect buildings, FPS
             officers developed physical security risk assessments, installed security
             equipment, and oversaw contract guard services. As a part of its law
             enforcement services, among other duties, FPS officers enforced laws
             and regulations aimed at protecting federal facilities and the persons in
             such facilities and conducted criminal investigations.

             Following the attacks on September 11, 2001, the Homeland Security Act
             of 2002 8 was enacted. It created DHS and moved FPS from GSA to the
             new department, effective in March 2003. Within DHS, FPS was placed in
             U. S. Immigration and Customs Enforcement (ICE), where its
             responsibilities grew beyond solely protecting GSA buildings to include
             homeland security activities such as implementing homeland security
             directives and providing law-enforcement, security, and emergency-
             response services during natural disasters and special events.

             In 2009, DHS proposed transferring FPS from ICE to NPPD. In explaining
             this transfer in DHS’s fiscal year 2010 budget justification to Congress,
             DHS stated that having FPS and NPPD’s Office of Infrastructure
             Protection in the same organization would further solidify NPPD as DHS’s
             lead for critical infrastructure protection. 9 FPS was placed in NPPD and
             continued to lead physical security and law enforcement services at GSA-
             held or GSA-leased facilities and continued its efforts in homeland
             security activities. In November 2018, legislation was enacted that
             reorganized NPPD to an organization that had a greater statutory focus

             7
               Detailed information on the scope and methodology of the GAO reports cited throughout
             this testimony can be found in these published products.
             8
                 Pub. L. No. 107-296, 116 Stat. 2135.
             9
              Fiscal year 2010 FPS funding was provided as part of the NPPD appropriations. See
             Department of Homeland Security Appropriations Act, 2010, Pub. L. No. 111-83, 123 Stat.
             2142, 2156-57 (2009).




             Page 3                                                                     GAO-19-605T
on managing cyber risks and authorized the Secretary of Homeland
Security to determine the appropriate placement for FPS within DHS and
begin transfer of FPS to that entity. 10

Throughout FPS’s organizational placements in DHS, we have reported
on persistent challenges it faced in meeting its mission to protect facilities.
In 2011, we reported on FPS’s challenges in transferring mission support
functions from ICE to NPPD. 11 While FPS was in NPPD, we reported on
FPS’s challenges related to managing and overseeing contract guards
and collaborating with GSA and the United States Marshals Service
(Marshals) on facility security. 12 We made recommendations to help
address these challenges and FPS has made progress on some of these
recommendations. For example, in September 2018, FPS and GSA
established a formal agreement on roles and responsibilities related to
facility protection, as we recommended. However, in our January 2019
report, we identified challenges related to other aspects of overseeing
contract guards and collaboration with other agencies on physical security
that had persisted. As of June of 2019, FPS continues to work on
establishing a contract guard-management system. However, FPS is
unable to assess its guards’ capabilities across its portfolio because the
system is not fully implemented nor does it interact with its training
system. As of 2019, federal physical security continues to be part of our
federal real-property management’s high-risk area. 13


10
  Cybersecurity and Infrastructure Security Agency Act of 2018, Pub. L. No. 115-278, 132
Stat. 4168.
11
  GAO, Federal Protective Service: Progress Made but Improved Schedule and Cost
Estimate Needed to Complete Transition, GAO-11-554 (Washington, D. C.: July 15,
2011).
12
   GAO, Federal Protective Service: Actions Needed to Assess Risk and Better Manage
Contract Guards at Federal Facilities, GAO-12-739 (Washington, D.C.: Aug. 10, 2012);
Federal Protective Service: Challenges with Oversight of Contract Guard Program Still
Exist, and Additional Management Controls Are Needed, GAO-13-694 (Washington, D.C.:
Sept. 17, 2013); Homeland Security: FPS and GSA Should Strengthen Collaboration to
Enhance Facility Security, GAO-16-135 (Washington, D.C.: Dec. 16, 2015); DHS
Management: Enhanced Oversight Could Better Ensure Programs Receiving Fees and
Other Collections Use Funds Efficiently, GAO-16-443 (Washington, D.C.: July 21, 2016)
and Federal Courthouses: Actions Needed to Enhance Capital Security Program and
Improve Collaboration, GAO-17-215 (Washington, D.C.: Feb.16, 2017). FPS is fully
funded by fees collected from federal agencies that use FPS for facility protection.
13
  GAO, High-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on
High-Risk Areas, GAO-19-157SP (Washington, D.C.: Mar. 6, 2019).




Page 4                                                                     GAO-19-605T
Key Criteria for Evaluating               In 2002, we reported on organizational and accountability criteria for
Placement Options                         establishing DHS. From this prior work, we identified key criteria that are
                                          relevant to assessing potential placement options for FPS, as shown in
                                          table 1. 14

Table 1: Key Criteria for Evaluating Placement Options for the Federal Protective Service (FPS)

Key criteria                            Description
                                        An agency’s ability to function well is dependent upon having a clear mission, goals and
                                        objectives. In that respect, similarities in agency mission, goals and objectives between
                                        FPS and any other organization could affect the extent to which FPS’s missions and goals
                                        are carried out effectively. Agency strategic plans describe the mission, goals, and
                                        objectives covering the major functions and operations of an agency.



                                        In order for an agency to perform its duties, it needs to have clear responsibilities and the
                                        capacity to do them. As a result, similarities in responsibilities between FPS and any other
                                        organization could affect the extent to which FPS’s responsibilities are prioritized. Agency
                                        responsibilities generally stem from the objectives outlined in strategic plans and can take
                                        the form of Memorandums of Agreement or agency directives.




                                        Having a cohesive culture is critical to organizational success. Organizational culture
                                        includes the underlying beliefs, values, attitudes, and expectations that influence the
                                        behaviors of agency employees. Similarities in organizational cultures between FPS and
                                        any other organization could facilitate FPS’s ability to meld and operate in another agency.




                                        An agency’s ability to share information is critical to its successful operation. This criterion
                                        includes sharing information related to national homeland security and necessary for the
                                        protection of federal facilities. Coordination refers to working with other agencies to provide
                                        this protection. Similarities between FPS and any other organization in information sharing
                                        and coordination could help ensure that FPS obtains the information it needs to perform its
                                        mission and activities.




                                          14
                                            GAO-02-957T. As described above, we selected criteria that were most relevant to
                                          FPS’s organizational placement. See GAO-19-122 for more information.




                                          Page 5                                                                           GAO-19-605T
Key criteria                           Description
                                       An agency requires effective mission support in order to carry out its duties. Mission
                                       support includes training, financial management, human capital, and information
                                       technology (IT) to support the agency in fulfilling its mission. The mission support made
                                       available to FPS by any organizational placement may affect FPS’s operations.




Source: GAO. I GAO-19-605T.




                                         For our January 2019 report, we applied these key criteria for evaluating
Considerations for                       organizational placement to eight agencies that could be potential
FPS’s Placement in                       placement options for FPS. We found that none of the selected agencies
                                         met all the organizational placement criteria; thus, any of the
DHS’s Management                         organizational placement options could result in both benefits and trade-
Directorate                              offs. In instances where placing FPS within DHS met our criteria (that is,
                                         instances where DHS was similar to FPS), FPS could experience
                                         benefits. In those instances where the criteria were not met, we reported
                                         it would be incumbent upon any agency to consider and address any
                                         potential trade-offs in order to ensure the decision was successful.

                                         We reviewed FPS as a “standalone” entity reporting directly to the Deputy
                                         Secretary of DHS and found this placement option met several key
                                         criteria. Table 2 below summarizes our analysis.

Table 2: Comparison of the Department of Homeland Security (DHS) and the Federal Protective Service (FPS) in Key Criteria
for Organizational Placement

Key criteria                        FPS as a standalone agency in DHS                                                Met/
                                                                                                                     Did not Meet
                                    DHS is similar to FPS in that their mission statements and goals include an      Met
                                    explicit focus on the protection of infrastructure or specific facilities.




                                         Page 6                                                                         GAO-19-605T
Key criteria                 FPS as a standalone agency in DHS                                                  Met/
                                                                                                                Did not Meet
                             Facility protection responsibilities                                               Met
                             Similar to FPS, DHS has facility protection responsibilities.

                             Physical security and law enforcement activities                                   Met
                             DHS is similar to FPS because it performs both physical security and law
                             enforcement activities.

                             Contract guard responsibilities                                           Did not meet
                             FPS employs and oversees a large number of contract guards. DHS only uses
                             a limited number of contract guards.
                             DHS has a similar culture to FPS in that it is a law enforcement agency.           Met




                             Information sharing                                                                Met
                             DHS, like FPS, has access to and can share information related to national
                             homeland security.

                             Coordination of activities                                                         Did not meet
                             FPS and GSA have joint responsibility for protecting facilities, and FPS, GSA,
                             and the U.S. Marshals have joint responsibility for protecting courthouses.
                             DHS does not have joint responsibility for coordinating facility protection with
                             FPS.
                             Financial management                                                            Did not meet
                             FPS collects monies from other federal agencies to support its operations.
                             DHS does not collect fees from other federal agencies to support its operation.

                             Human capital
                             DHS has the authority to fill competitive service jobs that could support FPS      Met
                             needs.

                             Information technology – financial management systems
                                                                                                        Met
                             FPS owns many of its operational and business-related IT systems and
                             applications but does not own some systems, such as a financial management
                             system. DHS has financial management systems that can support FPS.

                             Law enforcement training
                             FPS has access to DHS’s Federal Law Enforcement Training Centers for law
                             enforcement training.                                                              Met
Source: GAO. I GAO-19-605T




                                  Page 7                                                                          GAO-19-605T
Notes: For the purposes of our comparison of DHS to FPS, we assumed that FPS was independent
of DHS.


For the first four criteria—(1) mission, goals, and objectives; (2)
responsibilities; (3) organizational culture; and (4) information sharing and
coordination—we determined that DHS met the criteria if the agency or its
subcomponents had any similarities to FPS. For the last criterion—
mission support—we determined that DHS met the criterion if the agency
or its subcomponents had similarities to FPS or could provide FPS
needed mission support.

Mission, Goals, and Objectives. In January 2019, we reported that
FPS’s mission focused on the protection of federal facilities and the
people working in and visiting those facilities. DHS was similar to FPS in
that its mission statement and goals as stated in its strategic plan include
an explicit focus on the protection of infrastructure or specific facilities.
Our prior work found that placing an agency into an organization that has
a similar mission might help ensure that the agency’s mission receives
adequate funding, attention, visibility, and support. 15 Our January 2019
work reported that one of DHS’s goals—as noted in its strategic plan
covering fiscal years 2014 to 2018—was to reduce risk to the nation’s
critical infrastructure. DHS and FPS share objectives that focus on
mitigating risks and responding to incidents.

Responsibilities. In January 2019, we reported that FPS has facility-
protection and physical-security responsibilities and law-enforcement, and
contract-guard oversight responsibilities. DHS was similar to FPS as it
had responsibilities for physical security and performed law enforcement
functions. As a part of its physical security activities, FPS conducted
facility security assessments, 16 identified countermeasures (e.g.,
equipment and contract guards) best suited to secure a facility, and
oversaw contract guards. As a part of its law enforcement activities, FPS
proactively patrolled facilities, responded to incidents, and conducted
criminal investigations. FPS also provided additional operational law
enforcement support, at the direction of the Secretary of Homeland
Security, to address emerging threats and homeland security incidents.
One of FPS’s most critical activities was overseeing about 13,500
contract guards who were posted at federal facilities and were
15
     GAO-02-957T.
16
   These assessments consist of identifying and assessing threats and vulnerabilities of a
facility.




Page 8                                                                          GAO-19-605T
responsible for controlling access to facilities, responding to emergency
situations involving facility safety and security, and performing other
duties. FPS was responsible for ensuring, among other things, that these
guards are performing their assigned duties and have the necessary
training and certifications. DHS, however, only used a limited number of
contract guards and therefore had less responsibility. At the time of our
review, DHS officials told us they procured about 130 guards.

Organizational Culture. In January 2019, we reported that while there
are many areas relevant to organizational culture, law enforcement was a
key aspect of FPS’s organizational culture, according to officials we
interviewed from an association of security companies and a former, high-
ranking official in NPPD. DHS had a similar culture in that it was a law
enforcement agency.

Information Sharing and Coordination. In January 2019, we reported
that Component Intelligence Programs (CIP) were organizations in DHS
that collected, gathered, processed, analyzed, produced, or disseminated
information related to national homeland security. In 2016, DHS
designated a division within FPS as a CIP, a move that allowed FPS
more access to information on threats other DHS agencies have identified
and actions they plan to take. While DHS, like FPS, had access to and
could share information related to national homeland security, DHS did
not have joint responsibility for coordinating facility protection with FPS.
Rather, FPS shared this responsibility with GSA, and these two agencies
and Marshals had joint responsibility for protecting courthouses. FPS has
faced challenges with coordinating with these agencies in the past. For
example, in September 2011, we reported that FPS, Marshals, and other
agencies involved in protecting courthouses (i.e., GSA and the
Administrative Office of the U.S. Courts) faced challenges related to
coordination, such as in the implementation of roles and responsibilities
and the use or participation in existing collaboration mechanisms. 17

Mission Support. In January 2019, we reported that mission support was
comprised of financial management, human capital, information
technology systems for financial management, and law enforcement

17
   We recommended that these entities address these issues by updating a memorandum
of agreement that, among other things, clarifies roles and responsibilities. GAO, Federal
Courthouses: Improved Collaboration Needed to Meet Demands of a Complex Security
Environment, GAO-11-857 (Washington, D.C.: Sept. 28, 2011). An updated memorandum
was drafted but had yet to be signed by all parties.




Page 9                                                                      GAO-19-605T
training. FPS owned and used many of the key operational and business-
related information technology (IT) systems and applications it needs to
carry out its mission. However, FPS received some mission support
services from other agencies in DHS, such as human capital and some
aspects of information technology. We found that if FPS changed its
organizational placement it would need mission support in these areas.
For example, FPS did not have delegated examining authority to allow it
to fill competitive civil service jobs and relied on NPPD to provide this
service. 18 DHS had the authority to fill competitive service jobs that could
support FPS needs. Further, FPS used a financial management IT
system owned by ICE. DHS could provide FPS access to financial
management systems that can support FPS. Finally, FPS offered its own
training courses and would still need access to DHS’s Federal Law
Enforcement Training Centers.

In our January 2019 report, we did not assess FPS as a placement within
DHS’s Management Directorate. 19 Further, we recommended DHS (1)
identify the specific goals of a change in FPS’s placement—that is, what
DHS expects to achieve by moving FPS to another agency, and (2) fully
evaluate placement options for FPS based on what DHS expects to
achieve by changing FPS’s placement, an assessment of FPS’s current
placement, and other best practices such as an analysis of alternatives
assessing the benefits and trade-offs. DHS agreed with our
recommendations. In May 2019, FPS officials told us that the Acting
Secretary’s decision to place FPS within the Management Directorate
was based upon an assessment of placement options within DHS using
criteria and analyzing the trade-offs. GAO has not yet received DHS’s
assessment of placement options. We will assess the actions DHS has


18
   Delegated examining authority is an authority that allows federal executive branch
agencies to fill competitive civil service jobs through a delegation from the Office of
Personnel Management. Agencies with this authority fill the civil service jobs by
performing activities such as recruiting and hiring.
19
   DHS’s Management Directorate ensures that the Department’s over 240,000
employees have well-defined responsibilities and that managers and their employees
have efficient means of communicating with one another, with other governmental and
nongovernmental bodies, and with the public they serve. The Management Directorate is
responsible for budget, appropriations, expenditure of funds, accounting and finance;
procurement; human resources and personnel; information technology systems; biometric
identification services; facilities, property, equipment, and other material resources; and
identification and tracking of performance measurements relating to the responsibilities of
the Department.




Page 10                                                                         GAO-19-605T
                      taken in response to our recommendations when we receive DHS’s
                      assessment.


                      Our prior work offers valuable insights for agencies to consider when
Steps to Transition   evaluating or implementing a reorganization or transformation, and can
FPS                   provide insights for making any transition regarding FPS. These include
                      considering (1) key questions for consolidations and (2) leading practices
                      when implementing an organizational change.

                      Two sets of considerations for organizational transformations provide
                      insights for making any FPS organizational placement. First, in May 2012,
                      we reported on key questions for agency officials to consider when
                      evaluating and implementing an organizational change that involves
                      consolidation. 20 Table 3 provides a summary of these key questions.
                      Answering these questions would help provide FPS with assurance that
                      important aspects of effective organizational change are addressed.

                      Table 3: Key Questions to Consider When Evaluating and Implementing
                      Consolidation

                       Key questions
                       What are the goals of the consolidation? What opportunities will be addressed through
                       the consolidation and what problems will be solved? What problems, if any, will be
                       created?
                       What will be the likely costs and benefits of the consolidation? Are sufficiently reliable
                       data available to support a business-case analysis or cost-benefit analysis?
                       How can the up-front costs associated with the consolidation be funded?
                       Who are the consolidation’s stakeholders, and how will they be affected? How have the
                       stakeholders been involved in the decision, and how have their views been considered?
                       On balance, do stakeholders understand the rationale for consolidation?
                       To what extent do plans show that change management practices will be used to
                       implement the consolidation?
                      Source: GAO. | GAO-19-605T



                      Second, we reported in July 2003 on key practices and implementation
                      steps for mergers and organizational transformations. 21 The practices we
                      noted are intended to help agencies transform their cultures so that they


                      20
                           GAO-12-542.
                      21
                           GAO-03-669.




                      Page 11                                                                           GAO-19-605T
                                                  can be more results oriented, customer focused, and collaborative in
                                                  nature (see table 4).

Table 4: Key Practices and Implementation Steps for Mergers and Organizational Transformations

Key practices                                     Implementation step
Ensure top leadership drives the                  •   Define and articulate a succinct and compelling reason for change.
transformation.                                   •   Balance continued delivery of services with merger and transformation activities.
Establish a coherent mission and                  •   Adopt leading practices for results-oriented strategic planning and reporting.
integrated strategic goals to guide the
transformation.
Focus on a key set of principles and              •   Embed core values in every aspect of the organization to reinforce the new culture.
priorities at the outset of the transformation.
Set implementation goals and a timeline to        •   Make public implementation goals and timeline.
build momentum and show progress from             •   Seek and monitor employee attitudes and take appropriate follow-up actions.
day one.
                                                  •   Identify cultural features of merging organizations to increase understanding of
                                                      former work environments.
                                                  •   Attract and retain key talent.
                                                  •   Establish an organization-wide knowledge and skills inventory to exchange
                                                      knowledge among merging organizations.
Dedicate an implementation team to                •   Establish networks to support implementation team.
manage the transformation process.                •   Select high-performing team members.
Use the performance management system             •   Adopt leading practices to implement effective performance management systems
to define responsibility and assure                   with adequate safeguards.
accountability for change.
Establish a communication strategy to             •   Communicate early and often to build trust.
create shared expectations and report             •   Ensure consistency of message.
related progress.
                                                  •   Encourage two-way communication.
                                                  •   Provide information to meet specific needs of employees.
Involve employees to obtain their ideas and       •   Use employee teams.
gain their ownership for the transformation.      •   Involve employees in planning and sharing performance information.
                                                  •   Incorporate employee feedback into new policies and procedures.
                                                  •   Delegate authority to appropriate organizational levels.
Build a world-class organization.                 •   Adopt leading practices to build a world-class organization.
Source: GAO. | GAO-16-605T



                                                  In summary, the questions and practices for organizational change that
                                                  we previously identified could provide insights to DHS and FPS for any
                                                  transition.
                                                  .
                                                  Madam Chairwoman Torres Small, Ranking Member Crenshaw, and
                                                  Members of the Subcommittee, this concludes my prepared statement. I
                                                  would be pleased to respond to any questions that you may have at this
                                                  time.


                                                  Page 12                                                                      GAO-19-605T
                   If you or your staff has any questions concerning this testimony, please
GAO Contacts and   contact Lori Rectanus at 202-512-2834 or rectanusl@gao.gov. Contact
Staff              points for our Offices of Congressional Relations and Public Affairs may
                   be found on the last page of this statement. In addition to the contacts
Acknowledgments    named above: Amelia Bates Shachoy (Assistant Director); Roshni Davé;
                   George Depaoli (Analyst-in-Charge); Geoffrey Hamilton; Kelly Rubin;
                   Sarah Veale; and Amelia Michelle Weathers made key contributions to
                   the testimony. Other staff who made contributions to the reports cited in
                   the testimony are identified in the source products.




(103576)
                   Page 13                                                         GAO-19-605T
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.
                         The Government Accountability Office, the audit, evaluation, and investigative
GAO’s Mission            arm of Congress, exists to support Congress in meeting its constitutional
                         responsibilities and to help improve the performance and accountability of the
                         federal government for the American people. GAO examines the use of public
                         funds; evaluates federal programs and policies; and provides analyses,
                         recommendations, and other assistance to help Congress make informed
                         oversight, policy, and funding decisions. GAO’s commitment to good government
                         is reflected in its core values of accountability, integrity, and reliability.

                         The fastest and easiest way to obtain copies of GAO documents at no cost is
Obtaining Copies of      through GAO’s website (https://www.gao.gov). Each weekday afternoon, GAO
GAO Reports and          posts on its website newly released reports, testimony, and correspondence. To
                         have GAO e-mail you a list of newly posted products, go to https://www.gao.gov
Testimony                and select “E-mail Updates.”

Order by Phone           The price of each GAO publication reflects GAO’s actual cost of production and
                         distribution and depends on the number of pages in the publication and whether
                         the publication is printed in color or black and white. Pricing and ordering
                         information is posted on GAO’s website, https://www.gao.gov/ordering.htm.
                         Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
                         TDD (202) 512-2537.
                         Orders may be paid for using American Express, Discover Card, MasterCard,
                         Visa, check, or money order. Call for additional information.

                         Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Connect with GAO         Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.
                         Visit GAO on the web at https://www.gao.gov.

                         Contact FraudNet:
To Report Fraud,
                         Website: https://www.gao.gov/fraudnet/fraudnet.htm
Waste, and Abuse in
                         Automated answering system: (800) 424-5454 or (202) 512-7700
Federal Programs
                         Orice Williams Brown, Managing Director, WilliamsO@gao.gov, (202) 512-4400,
Congressional            U.S. Government Accountability Office, 441 G Street NW, Room 7125,
Relations                Washington, DC 20548

                         Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
Public Affairs           U.S. Government Accountability Office, 441 G Street NW, Room 7149
                         Washington, DC 20548

                         James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707
Strategic Planning and   U.S. Government Accountability Office, 441 G Street NW, Room 7814,
External Liaison         Washington, DC 20548




                            Please Print on Recycled Paper.