Federal Law Enforcement Training Center:

Capacity Planning and Management Oversight Need Improvement

GAO-03-736: Published: Jul 24, 2003. Publicly Released: Jul 24, 2003.

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The Federal Law Enforcement Training Center (FLETC) provides federal law enforcement training for 75 Partner Organizations (agencies) primarily at four domestic facilities located at Glynco, Ga; Artesia, N. Mex.; Charleston, S.C.; and Cheltenham, Md.. Given the post-terrorist attack security environment, coupled with the increased demand for training, concerns have been raised about FLETC's continued ability to meet this training demand. Because of these concerns, GAO was asked to issue a report on (1) how FLETC plans to meet the projected demand for training; (2) FLETC's ability to efficiently coordinate and schedule training activities; and (3) whether oversight and governance structures provide the guidance it needs to address its capacity and planning challenges.

FLETC's overall capacity to provide training at the Glynco and Charleston campuses is currently strained, while Artesia has been underutilized, and Cheltenham is being upgraded and cannot operate at full capacity. FLETC is developing a Master Plan to address how to overcome the long-term capacity challenges, but questions exist regarding the assumptions and methodologies used, contingency planning, cost estimation and budgeting, and the need to address capacity shortfalls sooner than planned. Department of Homeland Security officials intend to review the new department's training needs and capacities, and update the plan to reflect its vision for law enforcement training. Within the context of its strained training capacity, FLETC uses a predominantly manual scheduling process that does not ensure the efficient use of training resources and poses internal control risks due to potential loss of scheduling materials and the lack of backup documentation. Although FLETC has begun the process to acquire a fully automated scheduling system, FLETC officials have yet completed important risk management activities and are not using recognized best practices for acquiring commercial off-the-shelf-based systems associated with this type of acquisition. Furthermore, FLETC's solicitation activities have not adequately addressed security requirements. FLETC faces additional challenges regarding its governance structure in that the status of FLETC's Board of Directors is unclear, and its membership, roles and responsibilities, and past practices are not fully consistent with prevailing governance best practices.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To address FLETC's capacity constraints and planning challenges, the Secretary of Homeland Security should instruct the Director of FLETC to develop a formal contingency plan that incorporates both physical and human resource solutions for at least the major potential constraints or choke points that can impede the law enforcement training delivery system.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: The FLETC Director chartered a Mission Contingency Planning Team to develop a process approach to contingency planning. The team completed its task, and in so doing enumerated the key contingency planning factors that need to be taken into consideration if FLETC is to successfully meet the demand for increased federal agency training(specifically, more appropriate handling of: capacity and throughput issues, scheduling and allocation, facilities, human resources, and systems and constraints management). As illustrations of its progress forward, FLETC is moving away from paper and pencil scheduling to contracting for the development of an automated Student Administration and Scheduling System; Artesia, NM and Cheltenham, MD have been developed as alternative training facilities; and FLETC is adopting planning and forecasting functions to better deal with facility, instructor, housing, and other constraints.

    Recommendation: To address FLETC's capacity constraints and planning challenges, the Secretary of Homeland Security should instruct the Director of FLETC to consider alternative approaches to estimating future facility construction needs in its Master Plan, including (a) specification of a range of training workload scenarios, and (b) after consultation with experts, application of risk analysis techniques.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: FLETC is moving forward in considering alternative approaches by implementing the FLETC Capital Planning and Investment Control (FCPIC) process, consistent with OMB and DHS guidance. The FCPIC requires that investment requests in excess of $100K, including construction projects, be subjected to a three-tiered review system. Each investment consideration must meet technical feasibility criteria, master planning, procurement, facilities, procurement, IT, and security management considerations, in addition to a risk analysis. Approved technical feasibility investment requests are to be included in FLETC's Master Plan.

    Recommendation: To address FLETC's capacity constraints and planning challenges, the Secretary of Homeland Security should instruct the Director of FLETC to develop plans for the use of alternative or additional law enforcement training campuses should circumstances limit or prohibit the use of available facilities.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: At the time of the report, concerns were raised about whether the Federal Law Enforcement Training Center (FLETC)had the capacity to meet increased federal agency demands for training. Glynco, the FLETC headquarters training site in Brunswick, Georgia, was already operating on a 6-day training week. To provide greater training alternatives, FLETC increased the utilization of its Artesia training site and further developed its Cheltenham MD facility (which now provides indoor firing ranges, a vehicle operations range, and meeting and classroom space). Further, in becoming a part of the Department of Homeland Security (DHS), FLETC gained greater scheduling flexibility by having access to an increased number of additional DHS training assets (more than 20 facilities are described in the provided document, "Facility Information: History and Mission of DHS Training Facilities.") FLETC has also developed contingency plans to address various needs at its own four training facilities. Each Federal Law Enforcement Training Center (FLETC) facility also now has a Continuity of Operations Plan (COOP Plan) that has been created in accordance with several executive branch standards (including Presidential Decision Directive 67, Enduring Constitutional Government and Continuity of Government Operations; and Department of Homeland Security Management Directive 9300.1, Continuity of Operations Programs and Continuity of Government Functions). These COOP plans provide contingency planning for major catastrophic events, including hurricane responses. FLETC considers the corrective actions taken as the result of this recommendation as completed

    Recommendation: To enable FLETC to monitor and reduce the risk associated with the degradation of FLETC facilities and infrastructure, FLETC should closely monitor overall facility conditions through establishment of periodic facility condition assessments of mission critical facilities and infrastructure and use of a computerized backlog of maintenance and repair.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: Closed Implemented: The Federal Law Enforcement Training Center (FLETC) provided sufficient evidence to the Physical Infrastructure team stakeholder that it was closely monitoring overall facility conditions through a facility condition index (FCI) assessment and use of a computerized backlog of maintenance and repair. According to DHS officials, FLETC contracted with the Navy to develop a FCI which can be used to monitor facility maintenance and cyclical repair needs, according to report completed in March 2004.

    Recommendation: To enable FLETC to monitor and reduce the risk associated with the degradation of FLETC facilities and infrastructure, FLETC should adopt a performance measurement, such as the Facility Condition Index, to monitor the trend of FLETC facilities condition and to also offer a benchmark indicator for comparison to industry standards.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: Due to concerns raised by Congress regarding the sudden influx of the large numbers of law enforcement personnel to FLETC, following the 9/11/01 terrorist attacks against the U.S., we reviewed FLETC's oversight and governance structures for addressing its capacity and planning challenges during a period of this increasing change. We identified challenges FLETC faced in monitoring and reducing the risk associated with the degradation of FLETC facilities and infrastructure. We recommended that FLETC should adopt a performance measurement, such as the Facility Condition Index (FCI), to monitor the trends of FLETC facilities' condition. Completed in March 2004, FLETC contracted with the Navy to develop a FCI which can be used to monitor facility maintenance and cyclical repair needs. FLETC has provided CD-ROMS as evidence and support of their development of a more sophisticated performance-based measurement assessment period.

    Recommendation: To increase the chances of Student Administration and Scheduling System (SASS) success, the Secretary of Homeland Security should instruct the Director of FLETC to make proceeding with the SASS acquisition conditional upon improvements in SASS acquisition management activities. Further, these improvements, at a minimum, should include adding risk management as a SASS acquisition function and ensuring that this function provides for the identification and documentation of risks.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Not Implemented

    Comments: In October 2003, FLETC completed a Student Administration and Scheduling System (SASS) Risk Management Plan and subsequently awarded a contract for the SASS implementation in 2006. The risk management plan defines a multi-step approach to determining, assessing, and reporting risk. It also details a methodology for assessing risks that have been identified, including how to define a risk's likelihood and impact. The June 2006 update to this plan continues to require that risk be identified, assessed, and reported. However, FLETC has yet to provide any evidence of risk management activities carried about between 2003 and 2006 or since the 2006 update to the plan.

    Recommendation: To increase the chances of SASS success, the Secretary of Homeland Security should instruct the Director of FLETC to make proceeding with the SASS acquisition conditional upon improvements in SASS acquisition management activities. Further, these improvements, at a minimum, should include adding risk management as a SASS acquisition function and ensuring that this function provides for the categorization of risk severity based on probability of occurrence and potential impact.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Not Implemented

    Comments: In October 2003, FLETC completed a Student Administration and Scheduling System (SASS) Risk Management Plan and subsequently awarded a contract for the SASS implementation in 2006. The risk management plan provides a methodology for categorizing risk severity based on probability, which can be high, medium, or low. The plan describes how to calculate the probability of occurrence by determining in the risk's likelihood and impact and then using a risk scale matrix which provides the overall evaluation of the risk. The June 2006 update to this plan continues to specify this same methodology. However, FLETC has yet to provide any evidence of ongoing risk management activities between 2003 and 2006 or since the 2006 update to the plan.

    Recommendation: To increase the chances of SASS success, the Secretary of Homeland Security should instruct the Director of FLETC to make proceeding with the SASS acquisition conditional upon improvements in SASS acquisition management activities. Further, these improvements, at a minimum, should include adding risk management as a SASS acquisition function and ensuring that this function provides for the development and implementation of risk mitigation strategies.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Not Implemented

    Comments: In October 2003, FLETC completed a Student Administration and Scheduling System (SASS) Risk Management Plan and subsequently awarded a contract for the SASS implementation in 2006. The risk management plan addresses the need for each identified risk to include a mitigation strategy and current status of the management of that risk. The June 2006 update to this plan continues to require the development and implementation of risk mitigation strategies. However, FLETC has yet to provide any evidence of ongoing risk management activities or the implementation of risk mitigation strategies between 2003 and 2006 or since the 2006 update to the plan.

    Recommendation: To increase the chances of SASS success, the Secretary of Homeland Security should instruct the Director of FLETC to make proceeding with the SASS acquisition conditional upon improvements in SASS acquisition management activities. Further, these improvements, at a minimum, should include adding risk management as a SASS acquisition function and ensuring that this function provides for the reporting of risk status, including progress in implementing mitigation strategies.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Not Implemented

    Comments: In October 2003, FLETC completed a Student Administration and Scheduling System (SASS) Risk Management Plan and subsequently awarded a contract for the SASS implementation in 2006. The risk management plan identifies the need for a risk assessment report to be used by the project team, senior management, and business owners to understand the risks identified and allocate necessary resources to correct or reduce potential damages. The plan also includes an initial risk inventory that includes the status of implementing the mitigation strategy for each risk. The June 2006 update to this plan also reports an inventory of risks. However, the updated plan does not identify progress in implementing any mitigation strategies and FLETC has yet to provide any evidence of risk management activities or the implementation of risk mitigation strategies between 2003 and 2006 or since the 2006 update to the plan.

    Recommendation: The improvements in SASS acquisition management activities should also treat known risks in acquiring commercial off-the-shelf-based systems (COTS) as SASS-specific risks, including volatility of the commercial market and an organization's resistance to the business process changes introduced by a COTS-based solution.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: The 2003 FLETC Student Administration and Scheduling System (SASS) Risk Management Plan includes an initial risk assessment that identifies a number of risks associated with acquiring commercial off-the-shelf-based systems (COTS). For example, the plan cites the risk of implementing COTS products that are tightly coupled and highly customized, which may be difficult to upgrade in the future, resulting in technological obsolescence. The plan states that this risk will be mitigated by using modular design and development and avoiding COTS customizations unless they are critical to meeting business requirements. The plan also cites the risk of new business processes that are too complicated to be easily automated and FLETC not changing policies or procedures to simplify those processes, possibly resulting in project failure. This risk will be mitigated by including business process reengineering in the overall SASS program and changing policies to support simplification of business practices. Finally, the plan cites the risk of not obtaining the support of instructors and employees, as well as its Partner Organizations. The mitigation strategy for this risk is to include change management in the overall SASS approach and communicating with stakeholders early and on a regular basis throughout the program.

    Recommendation: The improvements in SASS acquisition management activities should also ensure that security is made a clear, explicit, and visible component of system requirements in the SASS solicitation package.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: The FLETC Student Administration and Scheduling System (SASS) acquisition program has identified security as a key component of the acquisition and has reflected this throughout its solicitation package. FLETC has completed a SASS Security Plan that discusses management controls, operational controls, and technical controls. The SASS Statement of Objectives lists a number of security-related technical objectives and the Source Selection Plan identifies security as a required technical objective. Additionally, the SASS Functional Statement of Need identifies stringent security controls as a required component of the SASS solution. Finally, the selected vendor's statement of work acknowledges security as a technical objective.

    Recommendation: The improvements in SASS acquisition management activities should also ensure that COTS-based system acquisition best practices are made a clear, explicit, and visible aspect of all acquisition functions, particularly with respect to continuously assessing the tradeoffs among system requirements, FLETC's architectural environment, the project's cost and schedule constraints, and the commercially available system products and components.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Not Implemented

    Comments: The FLETC Student Administration and Scheduling System (SASS) acquisition program included COTS-based considerations in its acquisition planning documents. For example, the SASS Risk Management Plan identifies several risks associated with the acquisition of a COTS-based product and the SASS Acquisition Plan noted the program's preference for selecting COTS components. Further, both the SASS Feasibility Study and Alternatives Analysis note that no COTS product could meet the requirements of FLETC's scheduling system, resulting in the need to allow vendor proposals that utilized modified COTS. However, FLETC has yet to provide any documentation that demonstrated the requirement for the acquisition program to continuously assess the tradeoffs among system requirements, the architectural environment, cost and schedule constraints, and the commercially available system products and components.

    Recommendation: To help provide sustained oversight and enhance accountability, the Secretary of Homeland Security should retain the FLETC Board of Directors. Further, working with FLETC's Partner Organizations, their parent departments and agencies, and the Board's current members, the Secretary of Homeland Security should review the Board's mission, roles and responsibilities, and functions and practices to better align them with prevailing standards of governance and internal and management control.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Federal Law Enforcement Training Center

    Status: Closed - Implemented

    Comments: FLETC agreed to retain its Board of Directors and held a Board of Directors meeting on August 26, 2003. FLETC concurred with our recommendation pertaining to governance improvements and already has under development in August 2003, an overview of prospective duties and responsibilities of the reconstituted Board of Directors. This included making the FLETC director a voting Board member and drawing on the advice and expertise of a wide group of Board members. The Board will be involved in the discussions of its role, responsibilities, and membership.

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