FPS also has about 13,500 contract security  guards deployed at approximately 5,650 of the almost 9,000 federal  facilities it protects. To make this determination, GSA required agencies to maintain program and financial data, which GSA  reviewed to determine whether to grant a delegation. FPS  lacks reliable data, as called for by federal Standards for Internal Control  in the Federal Government, for accurately identifying the total delegations  it is responsible for managing. In addition, FPS’s model for estimating the  costs associated with a delegation does not fully align with the relevant  leading practices outlined in GAO’s Cost Guide. The federal  Standards for Internal Control state that federal agencies should have  relevant, reliable, and timely information for decision-making and  external-reporting purposes. Without reliable data on existing delegations of authority, FPS  will face challenges effectively managing its delegations of authority  program. FPS’s Cost Model for Estimating Cost of Security Services Does Not Fully Align with Leading Practices

FPS’s cost estimation model that it is using to analyze the costs of  providing law enforcement or security services does not fully align with  leading practice identified in GAO’s Cost Guide. We found that FPS’s cost estimation model partially aligned with practices  for producing comprehensive estimates and minimally aligned with those  for producing well- documented and accurate estimates. Furthermore, the  model does not align with practices for producing credible cost estimates. In  addition, the model did not include a sensitivity analysis that identifies a  range of possible costs based on varying major assumptions. FPS Has Not Fully Followed Its Interim Plan in Reviewing Select Delegations of Authority

We analyzed the six requests for new or renewed delegations of authority  FPS reviewed from June 2012 through May 2014, and found that FPS did  not fully follow its Interim Plan when it reviewed five of the requests. Without conducting these analyses, FPS  does not have a sound basis to determine whether cost or security  considerations support its delegation of authority recommendations. Specifically, FPS conducted  the required cost analysis but did not conduct the required capabilities  analysis. FPS Did Not Fully Follow Its Interim Plan When It Renewed and Granted Delegations of Authority to Commerce, the Interior, State, and FTC

Regarding the other 4 requests for new or renewed delegations of  authority we reviewed, based on FPS’s recommendations, the Secretary  of DHS and the Under Secretary of NPPD renewed the delegations of  authority for the Department of Commerce’s NIST facilities for 5 years,  the Department of the Interior’s Hoover Dam for 2 years, and the State  Department’s Enterprise Service Operations Center facility for 2 years,  and granted FTC a new contract guard delegation for 3 years; but FPS  did not conduct cost or capabilities analyses prior to making these  recommendations as required by the Interim Plan. FPS officials explained  that FPS did not conduct these analyses, in part, because it was not able  to obtain comparable cost data or limited staff prevented it from  conducting the analyses before the delegations expired. FPS officials also  told us that the program is evolving and that it has yet to establish  management controls to ensure that the analyses are conducted. FPS officials stated that the  delegations program was being managed from FPS headquarters. Recommendations

To improve the management of FPS’s delegations of authority program,  we recommend that the Secretary of Homeland Security direct the  Director of FPS take the following three actions: develop and implement procedures to improve the accuracy of its  delegation of authority data; update FPS’s cost estimation model to align with leading practices to  ensure it produces comprehensive, well-documented, accurate, and  credible cost estimates; and establish management controls to ensure that FPS’s headquarters  and regional office staff conduct required cost and capability analyses  before FPS grants, renews, or rescinds a delegation of authority to a  federal agency. To determine the extent to which FPS’s delegations of authority program  meets select federal standards for effective program management, we  analyzed FPS’s 2012 Interim Plan and 2014 draft delegations of authority  directive—which outline the processes FPS is currently using to identify  delegations of authority granted when FPS was part of GSA and how  FPS is supposed to review delegations of authority to determine if they  should be granted, renewed or rescinded—against leading practices  identified in applicable federal standards.
Why GAO Did This Study

FPS's primary mission is to protect the almost 9,000 federal facilities that are held or leased by the General Services Administration. FPS also manages the Department of Homeland Security's (DHS) delegations of authority (delegations) program, which involves, among other things, reviewing requests by agencies to protect their own facilities instead of FPS and making recommendations to DHS about whether to grant, renew, or rescind such delegations. In response to direction in the conference report accompanying the Consolidated Appropriations Act, 2012, FPS prepared its Interim Plan that outlines FPS's process for reviewing existing and newly requested delegations.
GAO was asked to review FPS's management of this program. This report covers (1) the extent to which FPS's delegations program meets select federal standards and (2) whether FPS has followed its Interim Plan in reviewing delegations. GAO reviewed FPS's 2012 Interim Plan and data on delegations; compared FPS's Interim Plan to federal standards; and analyzed the six requests for new or renewed delegations FPS reviewed from June 2012 through March 2014.

What GAO Found

The Federal Protective Service's (FPS) delegations of authority program does not fully meet applicable federal standards GAO identified for effective program management.
FPS lacks reliable data, as called for by federal Standards for Internal Control, to accurately identify all the delegations FPS is responsible for managing and overseeing to ensure the protection of federal facilities. Specifically, of the 62 delegations of authority that FPS officials said were verified as active, GAO found that 12 had either expired or been rescinded. Standards for Internal Control state that federal agencies should have relevant, reliable, and timely information for decision-making and external- reporting purposes. FPS officials stated that poor recordkeeping contributed to the data's unreliability, but FPS has not established procedures to ensure data reliability. Without reliable data on delegations of authority, FPS will face challenges effectively managing this program.
FPS's model for estimating the costs associated with a delegation—set forth in its 2012 Interim Plan —does not fully align with the relevant leading practices outlined in GAO's Cost Estimating and Assessment Guide . These leading practices help ensure reliable cost estimates that are comprehensive, well documented, accurate, and credible. GAO found that FPS's cost estimation model partially aligned with practices for producing comprehensive estimates and minimally aligned with those for producing well-documented and accurate estimates. Furthermore, the model does not align with practices for producing credible cost estimates because, among other things, it does not include a sensitivity analysis, which identifies a range of possible costs based on varying assumptions. Without fully aligning the cost model with leading practices, FPS faces limitations developing reliable cost estimates that support its delegations of authority recommendations.
For five of the six agency requests for new or renewed delegations of authority that GAO analyzed, FPS did not conduct the required cost and security- capabilities analyses before making its recommendation to grant, renew, or rescind the delegation. The Interim Plan calls for these analyses to form the basis of FPS's recommendations. Specifically, FPS conducted the required analyses for only the delegation involving the Social Security Administration and did not conduct these analyses for the other five delegations involving facilities of the Departments of Commerce, Interior, and State; the Nuclear Regulatory Commission; and the Federal Trade Commission. According to FPS officials, they were not always able to obtain, from the agency requesting a delegation, comparable cost data to complete the cost model. FPS officials also acknowledged that FPS has yet to establish management controls to ensure that required analyses are conducted. Without these analyses, FPS does not have a sound basis to determine whether cost or security considerations support its delegations of authority recommendations.

What GAO Recommends

GAO recommends that the Secretary of DHS direct FPS (1) to improve the accuracy of its delegation data, (2) update its cost estimation model to align with leading practices, and (3) establish management controls to ensure that its staff conducts the required cost and capability analyses. DHS concurred with the recommendations.