	Background

In June 2015, DHS delivered its CBRNE Functions Review Report to  Congress which proposed consolidating the agency’s core CBRNE  functions (see fig. As described in figure 2, the new CBRNE Office would be  comprised of Chemical, Biological, Nuclear, and Explosives mission  support divisions. DHS Considered Several Key Factors, but Has Limited Analyses and Documentation Underlying the Benefits and Limitations of Its CBRNE Consolidation Proposal

The CBRNE report and summaries provide some insights into factors  considered, but did not include associated underlying data or  methodological information, such as how benefits and costs were  compared or the extent to which stakeholders were consulted. Specifically, DHS’s consolidation  proposal:  Identified strategic outcomes and goals and considered  problems to be solved, but did not fully assess and document  potential problems that could result from consolidation. For example, in a November 2014  letter from the Secretary of Homeland Security to a congressional  committee chair, the Secretary states that consolidation will provide a  clearer focal point for external and DHS component engagement on  CBRNE issues, among other things. Did not conduct and document a comparison of benefits and  costs. DHS  conducted limited external stakeholder outreach in developing the  consolidation proposal, and thus the proposal may not sufficiently  account for stakeholder concerns. Additionally, attention to the key  questions identified from our analysis of previous organizational  consolidations would help provide DHS, Congress, and other  stakeholders with assurance that important aspects of effective  organizational change, including a consideration of the plan’s benefits  and limitations, are addressed as part of the agency’s CBRNE  reorganization decision-making process. Key Mergers and Organizational Transformation Practices Could Benefit DHS Moving Forward If Congress Approves the CBRNE Consolidation

Should Congress approve its plan to consolidate, DHS could benefit from  incorporating change management approaches such as the key practices  and implementation steps derived from organizational transformations  undertaken by large private and public sector organizations identified in  our previous work. The Consolidated Appropriations Act, 2016, provides that none of  the funds appropriated may be used to establish an Office of CBRNE  Defense until Congress has authorized such establishment and, as of  July 2016, Congress had not approved the proposed consolidation. As DHS was formed, we reported in July 2003 on key practices and  implementation steps for mergers and organizational transformations. However, should DHS receive this  approval to reorganize its CBRNE functions, consulting each of these  practices would ensure that lessons learned from other organizations are  considered. In addition, the practices will be helpful in a consolidated CBRNE  environment. For example, overall employee morale differs among the  components to be consolidated, as demonstrated by the difference in the  2015 employee satisfaction and commitment scores of DNDO and  S&T, making employee involvement to gain their ownership for the  transformation a key step to consider. Also, given the range of activities  conducted by the consolidated entities, establishing a coherent mission  and integrated strategic goals to guide the transformation will be  important. Recommendations for Executive Action

To better provide Congress and affected stakeholders with assurance  that important aspects of effective organizational change are addressed  as part of the agency’s CBRNE reorganization decision-making process,  we recommend that the Secretary of Homeland Security direct the  Assistant Secretary for the Office of Policy to complete, document, and  make available analyses of key questions related to its consolidation  proposal, including: what problems, if any, consolidation may create; a comparison of the benefits and costs the consolidation may entail; a broader range of external stakeholder input including a discussion of  how it was obtained and considered. If DHS’s proposed CBRNE program consolidation is approved by  Congress, we recommend that the Secretary of Homeland Security direct  the Assistant Secretary for the Office of Policy to use, where appropriate,  the key mergers and organizational transformation practices identified in  our previous work to help ensure that a CBRNE consolidated office  benefits from lessons learned from other organizational transformations. Based on our review of DHS’s proposal, the  department did not fully consider similar potential expenses or up-front  costs in developing its proposal. However, according to DHS,  the passage of the Consolidated Appropriations Act, 2016 (P.L.
Why GAO Did This Study

Committee reports accompanying the Consolidated and Further Continuing Appropriations Act, 2013, directed DHS to undertake an in-depth review of the department's weapons of mass destruction programs, including potential consolidation of CBRNE mission functions. DHS conducted its review, and in June 2015 provided a report to Congress, including a proposal to consolidate the agency's core CBRNE functions. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it.
GAO was asked to review the proposed consolidation of DHS's CBRNE programs. This report discusses: (1) the extent to which DHS's proposal assessed the benefits and limitations of consolidation and (2) GAO's key practices from past organizational transformations that could benefit DHS, should Congress approve the proposed consolidation.

What GAO Found

The Department of Homeland Security's (DHS) documentation related to its proposed consolidation of Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) programs offers some insights into benefits and limitations considered, but the information provided to GAO did not include several key factors to consider when evaluating an organizational consolidation. While developing its consolidation plan, DHS identified strategic goals, such as eight near-term goals to be achieved within the first two years. DHS also considered problems its consolidation is intended to solve, including providing a clearer focal point for external and DHS component engagement on CBRNE issues. However, DHS:
Did not fully assess and document potential problems that could result from consolidation.
Did not include a comparison of benefits and costs.
Conducted limited external stakeholder outreach in developing the consolidation proposal and thus the proposal may not sufficiently account for stakeholder concerns.
Attention to the these key areas, identified from GAO's analysis of previous organizational consolidations, would help provide DHS, Congress, and other stakeholders with assurance that important aspects of effective organizational change are addressed as part of the agency's CBRNE reorganization decision-making process.
Key mergers and organizational transformation practices identified in previous GAO work could benefit DHS if Congress approves the proposed CBRNE consolidation. GAO reported in July 2003 on key practices and implementation steps for mergers and organizational transformations that range from ensuring top leadership drives the transformation to involving employees in the implementation process to obtain their ideas and gain their ownership for the transformation. In addition, the practices would be helpful in a consolidated CBRNE environment. For example, overall employee morale differs among the components to be consolidated, making the key practice of employee involvement to gain their ownership for the transformation a crucial step. Also, given the wide range of activities conducted by the consolidated entities, the key practice of establishing a coherent mission and integrated strategic goals to guide the transformation will be important. The Consolidated Appropriations Act, 2016, prohibits DHS from using funds to establish a CBRNE office until Congress approves it, and, as of June 2016, Congress had not approved DHS's consolidation proposal. However, should DHS receive this approval, consulting GAO's key practices would help ensure that lessons learned from other organizations are considered.

What GAO Recommends

GAO recommends that DHS complete, document, and make available analyses associated with identifying: (1) unintended problems, if any, that consolidation may create; (2) a comparison of the consolidation's benefits and costs; and (3) a broader range of external stakeholder input. Although DHS did not concur, GAO continues to believe that findings documented in the report support the recommendation. DHS concurred with GAO's additional recommendation that should Congress approve DHS's plan, the department use key mergers and organizational transformation practices identified in previous GAO work.