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GAO-10-802R: 

United States Government Accountability Office: 
Washington, DC 20548: 

June 14, 2010: 

The Honorable Robert C. Byrd: 
Chairman: 
The Honorable George Voinovich: 
Ranking Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
United States Senate: 

The Honorable David E. Price: 
Chairman: 
The Honorable Harold Rogers: 
Ranking Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
House of Representatives: 

Subject: Homeland Security: Preliminary Observations on the Federal 
Protective Service's Workforce Analysis and Planning Efforts: 

We have identified several workforce related challenges faced by the 
Federal Protective Service (FPS) since its transfer to the Department 
of Homeland Security (DHS) in 2003, including low morale among staff, 
increased attrition, and the loss of institutional knowledge. Our 
prior work has found that FPS continues to face challenges in 
identifying the optimal number of staff needed to adequately conduct 
its mission.[Footnote 1] 

In response to Congress's mandate in the House Report, which 
accompanied the DHS fiscal year 2009 Appropriations Act[Footnote 2] 
requiring GAO to evaluate the adequacy of FPS's workforce size, this 
report includes preliminary observations on the following questions: 

(1) What is the current status of FPS's efforts to determine its 
workforce requirements? 

(2) To what extent do FPS's efforts align with commonly used workforce 
analysis and planning practices? 

(3) What, if any, challenges may impede implementation of FPS's 
efforts? 

This correspondence includes the briefing we provided your staff on 
May 18, 2010 (see enclosure I). As agreed we will provide the 
committee with a final report when FPS's workforce analysis plan is 
finalized. 

Agency Comments and Our Evaluation: 

We provided a copy of this report to the National Protection and 
Programs Directorate (NPPD) of DHS for its review and comment. In his 
comments, the Under Secretary of NPPD indicated that the FPS Staffing 
Analysis Plan is currently in its final stage of approval at DHS and 
will soon be submitted to the Office of Management and Budget (OMB) 
for review. NPPD and FPS plan on implementing the plan after OMB 
review and final approval by the Secretary of DHS. Additionally, 
NPPD's comments indicated that FPS is optimistic that implementation 
of the plan will face fewer potential challenges than we envision in 
our analysis, and provided specific information on how FPS will 
address the six potential challenges enumerated in our briefing, 
including funding, data quality, performance measures, human capital 
planning, hiring processes, and training. NPPD's complete comments can 
be found in enclosure II. 

Scope and Methodology: 

The results of FPS's staffing analysis have not yet been finalized, 
therefore we reviewed the methodology FPS is using to conduct its 
analysis, we identified commonly used workforce analysis and planning 
practices to determine if FPS incorporated them in its methodology, 
and we identified challenges that may impede implementation of FPS's 
workforce analysis. Additional information about our scope and 
methodology is provided in enclosure I. We conducted this performance 
audit from January 2010 to June 2010 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. 

We are sending copies of this report to interested congressional 
committees and the Director of the Federal Protective Service. In 
addition, the report is available at no charge on the GAO Web site at 
[hyperlink http://www.gao.gov]. If you or your staffs have any 
questions about this report, please contact Mark L. Goldstein at (202) 
512-2834 or goldsteinm@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. 

Signed by: 

Mark L. Goldstein: 
Director, Physical Infrastructure Issues: 

Enclosures: 

Enclosure I: 

Homeland Security: Preliminary Observations on the Federal Protective 
Service's Workforce Analysis and Planning Efforts: 

Briefing to the Subcommittees on Homeland Security, Committees on 
Appropriations, U.S. Senate and House of Representatives: 

Preliminary Observations: 

Federal Protective Service's Workforce Analysis Efforts: 

May 18, 2010: 

Information provided in this briefing is based on preliminary 
observations. 

Introduction: 

Federal Protective Service (FPS) is mandated to maintain a staffing 
level of at least 1,200 employees, and currently has a workforce of 
about 1,225 employees. 

In June 2008 and July 2009 we recommended that FPS: 

* develop and implement a strategic approach to manage its staffing 
resources that, among other things, determines the optimum number of 
employees needed to accomplish its facility protection mission, and; 

* take steps to develop a strategic human capital plan to better 
manage its workforce needs. 

Objectives: 

The House Report which accompanied the Department of Homeland Security 
(DHS) fiscal year 2009 Appropriations Act mandated GAO to complete an 
analysis of the staffing resource levels required for FPS to be able 
to adequately protect federal facilities. 

Based upon discussions with your staff, we agreed to the following 
objectives: 

(1) What is the current status of FPS's efforts to determine its 
workforce requirements? 

(2) To what extent do FPS's efforts align with commonly used workforce 
analysis and planning practices? 

(3) What, if any, challenges may impede implementation of FPS's 
efforts? 

Scope and Methodology: 

To evaluate FPS's staffing analysis methodology we: 

* reviewed documents provided by FPS officials, including its 
workforce analysis methodology, its current staffing allocation, and 
projected staffing key assumptions; 

* conducted interviews with FPS headquarters' officials; 

* conducted interviews with FPS Region 10 officials and inspectors in 
Federal Way, WA. (Officials in region 10 were selected because they 
were instrumental in the development of FPS's workforce analysis); and; 

* conducted interviews with DHS's National Protection and Programs 
Directorate (NPPD) officials. 

We also met with officials from law enforcement entities with roles 
and responsibilities similar to FPS, such as protection of facilities, 
management of contract guards, and core law enforcement duties. These 
organizations included: 

* 5 federal organizations—U.S. Postal Inspection Service, U.S. Secret 
Service, Smithsonian Institution, AMTRAK, and U.S. Department of 
Veteran's Affairs. 

* 3 non-federal organizations—King County, WA, Sheriff's Office, 
University of Washington Police, and the St. Louis, MO, Police 
Department. 

To identify security and law enforcement industry workforce planning 
practices we obtained documents—such as staffing studies and published 
journal articles—-and conducted interviews with officials from several 
security and law enforcement organizations and academic experts, 
including: 

* International Associations of Chiefs of Police (IACP), 

* American Society for Industrial Security (ASIS), 

* BCD Associates, 

* Security Analysis and Risk Management Association (SARMA), 

* Washington Association of Sheriffs and Police Chiefs (WASPC), 

* National Law Enforcement Recruitment Association, and, 

* Michigan State School of Criminal Justice. 

Additionally, we reviewed GAO reports addressing best practices on 
workforce planning and management. 

1) What is the current status of FPS's efforts to determine its 
workforce requirements? 

FPS has taken steps to determine its workforce requirements, however, 
its workforce analysis plan is not finalized. 

* FPS is using a model for determining optimal workforce size based on 
workload, risk, and work standard assumptions. 

* As part of the FPS-NPPD transition plan, FPS stated it would "create 
a robust workforce staffing model that is scalable based on changes in 
risk, threat, and consequence." This model is intended to provide the 
basis for staffing recommendations in future budget requests. 

* According to FPS officials, the model contains elements of staffing 
models used by other federal law enforcement agencies, including the 
U.S. Marshals Service and the Secret Service. 

Figure: FPS's Workforce Analysis Model: 

[Refer to PDF for image: illustration] 

Historical and estimated workload: 

Multiplied by: 

Production rates and work standards: 

Equals: 

Required labor estimates. 

Required labor estimates: 

Divided by: 

Effective work year: 

Equals: 

Required staffing. 

Source: FPS. 

[End of figure] 

FPS's Workforce Analysis Model Components: 

Workload Data: Specific activities performed by FPS to ensure secure 
facilities and safe occupants. For example, for inspectors FPS used 
historical data and subject matter experts to determine how many hours
were spent conducting Facility Security Assessments (FSA), attending 
Facility Committee Meetings, mandatory training, pre-lease surveys, 
among other activities. 

Production Rates & Work Standards: The average hours required to 
complete each workload activity. 

For example, FPS based this on the frequency of specific activities 
such as FSAs and guard inspections, as required by federal regulation 
or agency standard operating procedures. 

Labor Estimate: Total number of annual hours required to complete all 
work for a specific activity identified in analysis of workload data. 

Effective Work Year: 2,080 hours per employee. 

FPS's Workforce Analysis Model Incorporates Some Risk Factors: 

In addition to workload analysis,. facility risk are the primary data 
used in FPS's workload analysis, including: 

* Number of facilities, 

* Facility Security Levels, 

* Number of security posts for each facility, and, 

* Number of contract guards per facility. 

Additional Risk Factors: 

* Geography (ire., the protected asset's location as it relates to 
response time during an incident). 

* DHS's Buffer Zone Protection Program study findings. This study is a 
DHS administered infrastructure protection grant program to help local 
law enforcement and first responders identity and mitigate 
vulnerabilities At the highest-risk critical infrastructure sites. A 
buffer zone is the area outside a facility that an adversary can use 
to conduct surveillance or launch an attack. 

* Regional intelligence data. 

Current Status of FPS's Workforce Staffing Model: 

According to NPPD officials, as of May 10, 2010, the FPS Workforce 
Staffing Plan is pre-decisional and there is no anticipated date for 
its finalization. 

* In January 2010, FPS completed its workforce analysis plan and 
provided a draft to NPPD for review and comment. 

* On May 7 2010 NPPD completed its final review, and has submitted it 
to DHS for review. 

* Once DHS's approval and consensus is reached, the plan will be sent 
to the Office of Management and Budget (OMB) for final approval before 
it is approved by the Secretary of DHS. 

2) To what extent do FPS's efforts align with commonly used workforce 
analysis and planning practices? 

FPS's staffing analysis methodology appears to incorporate commonly 
used industry practices and processes for conducting workforce 
analysis. For example, the methodology: 

* Identifies risk level and quantity of facilities and posts to be 
secured or protected. 

* Incorporates a workload analyses (identifying mission, tasks, and 
time to conduct activities). 

We found there are no widely used established criteria, formulas, or 
standards for determining the size of law enforcement and physical 
security workforces. However, officials in most organizations we spoke 
with told us that budget ultimately drives staffing decisions and is 
the primary consideration when making these decisions. 

3) What, if any, challenges may impede implementation of FPS's 
workforce analysis efforts? 

FPS may face several potential challenges to implementing its 
workforce analysis plan: 

* Funding: FPS charges federal agencies to fund its services, however, 
FPS officials have not told us how they intend to fund an increased 
staff size. FPS's security fee has increased over 100 percent since 
its transfer to DHS, and FPS customers are already concerned about 
cost and quality of security and in the past fee increases have been 
met with resistance from GSA and tenant
agencies. Additionally FPS did not request additional funding in its 
fiscal year 2011 budget. 

* Data Quality: The accuracy of FPS's workload analysis is unclear due 
to the quality of workload data used. For example, we have reported 
FPS does not accurately track key activities such as facility 
assessments and guard inspections. Additionally, with the 
implementation of a new automated risk assessment and management 
program, which may reduce the time a takes to conduct specific 
activities, the use of historical workload data may not be accurate. 

* Performance Measures: FPS does not have metrics in place to measure 
how changes to its workforce size, composition, and allocation are 
addressing its operational challenges. 

* Human Capital Planning – FPS has not developed a strategic human 
capital plan to aid in long-term workforce planning and management as 
GAO recommended. 

* Hiring Processes – FPS recently experienced difficulties hiring and 
on-boarding about 180 inspectors, therefore it is unclear how it plans 
on managing the hiring of any additional staff that may be needed as a 
result of its workforce analysis plan. Additionally, FPS is no longer 
using Custom and Border Patrol's established human capital recruiting 
and hiring services. According to the transition plan, these services 
will be transferred to the Office of Personnel Management. 

* Training – Continued backlogs at the Federal Law Enforcement 
Training Center (FLETC) will impact FPS's ability to provide training 
to new staff—subsequently, some of the approximately 180 inspectors 
hired last year have yet to complete all required training. 

Contact Information: 

If you or staff have any questions about this report, please contact 
Mark L. Goldstein at (202) 512-2834 or goldsteinm@gao.gov. 

Key Contributors: Tammy Conquest, Assistant Director; Tida Barakat, 
and Jennifer Clayborne. 

On the Web: 

Web site: [hyperlink, http://www.gao.gov/]. 

Contact: 

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

Copyright: 

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. 

[End of Enclosure I] 

Enclosure II: 

Comments from the Federal Protective Service: 

Office of the Under Secretary: 
National Protection and Program Director: 
U.S. Department of Homeland Security: 
Washington, DC 20528: 

June 9, 2010: 

Mark L. Goldstein: 
Director, Physical Infrastructure Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Goldstein: 

RE: GAO Briefing Slides (10-802R), Homeland Security: Preliminary 
Observations on the Federal Protective Service's Workforce Analysis 
and Planning Efforts (GAO Job Code 543258): 

The National Protection and Programs Directorate (NPPD) appreciates 
the opportunity to review and comment on the U.S. Government 
Accountability Office's (GAO) briefing slides for the engagement 
referenced above. 

This ongoing engagement is to review the NPPD Federal Protective 
Service (FPS) Staffing Analysis Plan (the Plan) and planning 
practices, and to identify challenges to its implementation. The Plan 
is in its final approval stage at the Department and will soon be 
submitted to the Office of Management and Budget (OMB) for review. 
NPPD/FPS will implement the Plan following OMB review and final 
approval by the Secretary of Homeland Security. 

As indicated in the staffing analysis methodology provided to GAO, the 
Plan is based on models of similar agencies that used a structured set 
of basic calculations to estimate direct labor and staffing 
requirements. The Plan represents a strategic approach to determine 
the optimum number of employees needed to accomplish the FPS facility 
protection mission and the allocation of those resources based on the 
Department's risk management principles and FPS's goals and 
performance measures. 

FPS leadership is optimistic that implementation of the Plan will face 
fewer potential challenges than the GAO envisions in its analysis. The 
Plan's development and review processes have afforded FPS a valuable 
opportunity to identify, analyze, and address anticipated challenges, 
including the six potential challenges enumerated in the GAO briefing 
materials: funding. data quality, performance measures, human capital 
planning, hiring processes, and training. 

With respect to funding, funding levels and issues are discussed in 
the full Plan and will be made available to GAO upon final approval. 

With respect to data quality, the foundation and integrity of the Plan 
rests on the quality of its data, and although the data has not been 
subjected to a rigorous scientific verification process, FPS has 
reviewed the processes used to collect and certify the data and 
believes it to be accurate, complete, and consistent with FPS mission 
essential functions and supporting tasks. Moreover, the Plan is 
undergoing rigorous Departmental review, which has enabled experts 
from several operational and administrative teams to provide their 
input and guidance as well. This holsters our confidence that the Plan 
will be well considered and feasible. 

With respect to performance measures, in addition to implementing 
policies to address operational challenges, FPS has developed more 
than 100 performance measures to include outcome measures, 
approximately 30 percent of which have already been implemented, as an 
initial test of the measure development and data collection processes. 
As additional technology systems are implemented, FPS will institute 
the appropriate associated measures. 

In addition, the final Plan will indicate the impact that changes in 
FPS's workforce size and composition will have on operational 
capabilities. These changes, along with ongoing efforts to address 
challenges, will result in improvements in operational effectiveness 
and efficiency. 

With respect to human capital planning, hiring processes, and 
training, FPS fully intends to finalize a human capital strategic plan 
after the staffing analysis is complete. We welcome any suggested best 
practices or sample plans that GAO would like to provide as exemplars. 
FPS and the NPPD Human Capital Office will collaborate to develop and 
employ a well defined and sound human capital strategy to recruit, 
train, allocate, and retain additional employees identified in the 
Plan. 

Finally, FPS intends to implement the Plan incrementally, and allow 
for modifications if appropriate, which should help facilitate its 
smooth and effective implementation. 

Again, we thank you for the opportunity to review the briefing 
materials. 

Sincerely yours, 

Signed by: 

Rand Beers: 
Under Secretary: 

[End of Enclosure II] 

Footnotes: 

[1] GAO, Homeland Security: The Federal Protective Service Faces 
Several Challenges That Hamper Its Ability to Protect Federal 
Facilities, [hyperlink, http://www.gao.gov/products/GAO-08-683] 
(Washington, D.C.: June 11, 2008), and GAO, Homeland Security: Federal 
Protective Service Should Improve Human Capital Planning and Better 
Communicate with Tenants, [hyperlink, 
http://www.gao.gov/products/GAO-09-749] (Washington, D.C.: July 30, 
2009). 

[2] H.R. No. 110-862, at 59 (2008). 

[End of section] 

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