Federal Protective Service: DHS Should Take Additional Steps to Evaluate Organizational Placement
Fast Facts
The Federal Protective Service protects about 9,000 federal facilities and their occupants.
FPS is part of the Department of Homeland Security, but it's been moved to two "parent agencies" within the department in the last 15 years. Reorganization can affect an agency's performance; after each move, FPS faced new duties and challenges.
But where's the best fit? We reviewed 8 potential parent agencies and found benefits and trade-offs for each.
Homeland Security is also assessing the issue, and should follow best practices for doing so. For example, we recommended setting goals and expectations for a move.
An officer in the Federal Protective Service monitors security camera footage.
An officer is looking at security camera footage on four large screens.
Highlights
What GAO Found
In considering organizational placement options for the Department of Homeland Security's (DHS) Federal Protective Service (FPS), GAO found that none of the eight agencies GAO selected met all the key organizational placement criteria; thus, any of the organizational placement options could result in both benefits and trade-offs. For example, keeping FPS in DHS's National Protection and Programs Directorate (NPPD) could provide FPS some benefits because FPS and NPPD have missions that include the protection of infrastructure or specific facilities, facility protection responsibilities, and access to and sharing of information related to national homeland security. However, unlike FPS, NPPD does not perform both physical security and law enforcement activities, which is a potential trade-off. In another example, the General Services Administration (GSA) and the United States Marshals Service (Marshals) could provide benefits because they currently coordinate with FPS on facility protection. However, Marshals does not have a mission or goals that explicitly focus on the protection of infrastructure or facilities and GSA does not perform law enforcement, which are potential trade-offs.
Comparison of Selected Agencies and the Federal Protective Service (FPS) to Three Key Criteria for Organizational Placement
The eight selected agencies are the Department of Homeland Security (DHS); U.S. Customs and Border Protection (CBP); U.S. Immigration and Customs Enforcement (ICE); National Protection and Programs Directorate (NPPD); United States Secret Service (USSS); General Services Administration (GSA); Department of Justice (Justice); and the U.S. Marshals Service (Marshals). GAO 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. For this report, GAO continues to refer to this agency as NPPD.
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Three selected key criteria for evaluating organizational placement |
Selected agencies that met the key criteria |
Selected agencies that did not meet the key criteria |
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DHS NPPD USSS GSA |
These agencies are similar to FPS in that their mission statements or goals include an explicit focus on the protection of infrastructure or specific facilities.a |
CBP ICE Justice Marshals |
These agencies do not have missions or goals that focus explicitly on infrastructure or facility protection. |
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Facility protection responsibilities |
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DHS CBP NPPD USSS GSA Justice Marshals
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Similar to FPS, DHS, nearly all of the selected agencies within DHS, GSA, Justice, and the Marshals have facility protection responsibilities.
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ICE |
ICE does not have any facility protection responsibilities because it pays FPS to protect its facilities. |
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Physical security and law enforcement activities |
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DHS CBP USSS Justice Marshals |
These agencies are similar to FPS because they perform both physical security and law enforcement activities. |
ICE NPPD GSA |
These agencies perform either physical security or law enforcement activities, but not both. |
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Contract guard responsibilities |
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Marshals |
Marshals, like FPS, employ and oversee a large number of contract guards. |
DHS CBP ICE NPPD USSS GSA Justice |
These agencies use FPS's contract guards, procure a limited number of guards, or use their own federal officers for facility protection. |
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Information sharing |
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DHS CBP ICE NPPD USSS Justice Marshals |
DHS, all of the selected agencies in DHS, Justice and the Marshals, like FPS, have access to and can share information related to national homeland security. |
GSA |
GSA does not have access to information related to national homeland security. However, GSA has access to information pertinent to the security of government facilities. |
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Coordination of activities |
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GSA Justice Marshals
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GSA and FPS have joint responsibility for protecting facilities, and these two agencies and Marshals have joint responsibility for protecting courthouses. |
DHS CBP ICE NPPD USSS
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These agencies do not have joint responsibilities for coordinating facility protection with FPS. |
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Source: GAO analysis of agency documents and interviews with stakeholders; GAO (images). I GAO-19-122
Note: The organizational culture and mission support criteria are discussed in the report.
a GSA has a statutory facility protection mission. See, e.g., 6 U.S.C. § 232(a).
DHS has not taken key steps to fully assess potential placement options. Specifically, DHS has not assessed the organizational structure of FPS, such as its placement in NPPD, even though FPS and NPPD have evolved since FPS was placed in NPPD in 2010. Standards for Internal Control state that agency management should establish an organizational structure to achieve the agency's objectives and that an effective management practice for attaining this outcome includes periodically evaluating the structure to ensure that it has adapted to changes. Additionally, because DHS did not analyze FPS's current placement in NPPD, DHS does not have a benchmark for comparison to other agencies. DHS recently established a working group to assess the placement of FPS. However, the group's planned activities are limited in several ways. For example, the group's draft charter does not indicate that the working group will describe what DHS expects to achieve by changing FPS's placement. Further, the draft charter does not indicate that the working group will evaluate the benefits and trade-offs of placement options. GAO has previously identified these and other steps as key to successful organizational change or analysis of alternatives. These steps would help DHS address the 2018 legislation to review placement options for FPS—including, how DHS considered the results of GAO's review. Regardless of the legislation, DHS may not be positioning itself to make an informed decision as to what organization best supports FPS.
Why GAO Did This Study
FPS, within DHS's NPPD, conducts physical security and law enforcement activities for about 9,000 federal facilities and the millions of employees or visitors who work in or visit these facilities. FPS moved from GSA to DHS's ICE in 2003 and to NPPD in 2009. GAO has reported that FPS faced challenges in each location. Legislation enacted in November 2018 requires DHS to review placement options for FPS and could result in FPS moving again within DHS or to another executive branch agency.
GAO was asked to review issues related to organizational placement options for FPS. This report examines (1) the potential effects of FPS's placement in selected agencies and (2) steps DHS has taken to assess placement options for FPS. GAO identified five key organizational placement criteria based on prior work and identified eight agencies as potential placement options. The agencies were selected because they have the largest number of law enforcement officers or perform physical security, among other reasons. GAO reviewed documentation and interviewed officials from FPS, selected agencies, and key stakeholders. GAO compared agencies to FPS to determine if they meet the organizational placement criteria. An agency meets the criteria if it has similarities to FPS.
Recommendations
DHS should identify the expectations for changing FPS's placement and take steps to fully evaluate placement options. DHS concurred with the recommendations and outlined steps it plans to take to address them.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
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| Department of Homeland Security | The Secretary of Homeland Security—in consultation with NPPD and FPS—should identify the specific goals of a change in FPS's placement—that is, what DHS expects to achieve by moving FPS to another agency. (Recommendation 1) |
Closed – Implemented
In November 2018, legislation was enacted that required the Department of Homeland Security (DHS) to determine the appropriate organizational placement of its Federal Protective Service (FPS) within DHS and begin transfer of FPS to that entity. Throughout FPS's different organizational placements in DHS, GAO has reported that FPS faced persistent challenges meeting its mission to protect federal facilities. In January 2019, GAO reported that DHS established a working group in August 2018 to evaluate placement options for FPS. At the time the workgroup was created, FPS was located within the National Protection and Programs Directorate (NPPD), which was later renamed the Cybersecurity and Infrastructure Security Agency. The working group identified criteria to evaluate FPS's placement on topics such as mission and resources. GAO reported that establishing the group and identifying criteria were positive steps in assessing FPS's placement, but that the working group's draft charter did not indicate what changing FPS's placement was expected to achieve. This factor is particularly important given that each placement option has its benefits and trade-offs and that stakeholders' opinions of the options varied. GAO has previously reported that a key practice of organizational change is to identify and agree on the specific goals of the change-that is, what the agency expects to achieve by making the change-that can help decision makers reach a shared understanding of what challenges need to be addressed. In the absence of identifying what it expects to achieve by moving FPS, DHS may not be positioning itself to make an informed decision on what organization best supports FPS. To address this problem, GAO recommended that DHS-in consultation with NPPD and FPS-identify the specific goals of changing FPS's placement. In May 2019, the Acting Secretary of DHS made the decision to move FPS from NPPD to DHS's Management Directorate. FPS provided GAO information on the analysis the working group used to assess agencies that were placement options for FPS. FPS officials confirmed that DHS's working group-consisting of officials from FPS, NPPD, and other agencies from DHS-identified specific goals of changing FPS's placement. For example, FPS officials told GAO that one goal of changing FPS's placement was to strengthen the mission of protecting all federal buildings, federal employees, and the people conducting business at federal facilities. Another goal was to allow law enforcement agencies that were placement options (e.g. DHS's U.S. Customs and Border Protection, United States Secret Service) to remain focused on their critical operations, without the distraction of expected transition issues that would occur if FPS was placed in those agencies. As a result of identifying specific goals, DHS was better positioned to make an informed decision as to what organization best supports FPS.
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| Department of Homeland Security | The Secretary of Homeland Security—in consultation with NPPD, FPS, and other agencies as relevant—should 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 discussed in this report. (Recommendation 2) |
Closed – Implemented
In November 2018, legislation was enacted that required the Department of Homeland Security (DHS) to determine the appropriate organizational placement of its Federal Protective Service (FPS) within DHS and begin transfer of FPS to that entity. Throughout FPS's different organizational placements in DHS, GAO has reported that FPS faced persistent challenges meeting its mission to protect federal facilities. In January 2019, GAO reported that DHS established a working group in August 2018 to evaluate placement options for FPS. At the time the workgroup was created, FPS was located within the National Protection and Programs Directorate (NPPD), which was later renamed the Cybersecurity and Infrastructure Security Agency. The working group-which consisted of officials from DHS, NPPD, and FPS-identified criteria, such as on the topics of mission and resources that the group would use to evaluate FPS's placement. GAO reported that establishing the group and identifying criteria were positive steps in assessing FPS's placement. However, the group's planned activities did not include describing what DHS expected to achieve by changing FPS's placement or evaluating the benefits and trade-offs of placement options for FPS. Previously, GAO has reported that best practices for evaluating alternatives includes assessing the current environment to provide a basis for comparison with other alternatives and identifying and assessing the benefits and trade-offs of each alternatives. Without conforming to the best practices, DHS would not have assurance that the working group recommends the alternative that best meets mission needs. To address this problem, GAO recommended that DHS-in consultation with NPPD, FPS, and other agencies as relevant-fully evaluate placement options based on: (1) what DHS expects to achieve by changing FPS's placement, (2) an assessment of FPS's placement in NPPD, and (3) other best practices such as an analysis of alternatives that assess the benefits and trade-offs that GAO discussed in the report. In May 2019, the Acting Secretary of DHS made the decision to move FPS from NPPD to DHS's Management Directorate. FPS provided GAO information on the analysis the working group used to assess agencies that were placement options for FPS NPPD was among the nine agencies the working group considered and the group performed an analysis of alternatives that assessed the benefits and trade-offs of placement options. Some of the criteria used to assess benefits and trade-offs (e.g. mission and culture) were the same criteria that GAO identified in its report. FPS officials also confirmed that the working group evaluated placement options based on the specific goals of changing FPS's placement. FPS officials also said that the Homeland Security Operational Analysis Center, a Federally Funded Research and Development Center operated by Rand Corporation, conducted an independent verification and validation of the working group's proposed goals, methodology, and evaluation criteria. As a result, DHS was better positioned to determine what it expected to achieve by moving FPS and to identify the organization that best supports FPS.
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