Moving FPS to Any of the Selected Agencies Evaluated Would Result in Both Benefits and Trade- offs

We found that none of the selected agencies met all the organizational  placement criteria; thus, any of the organizational placement options  could result in both benefits and trade-offs. For example, for the  mission, goals, and objectives criterion, DHS, NPPD, and Secret Service  could provide benefits to FPS because, like FPS, their mission or goal  statements as noted in their strategic plans include an explicit focus on  the protection of infrastructure or specific facilities. Specifically, as discussed  above, placement in DHS, NPPD, or the Secret Service could provide  FPS benefits because these agencies have similar missions and  facility protection responsibilities, and have access to and share  information related to national homeland security that FPS needs to  carry out its mission. However, NPPD, for example, does not perform  law enforcement activities. DHS Has Not Taken Key Steps to Fully Assess Potential Placement Options

When managing an agency or considering an organizational change,  such as that of FPS’s placement within or outside of DHS, our prior work  has stated that an agency can benefit from periodically evaluating its  organizational structure, identifying what a change is expected to achieve,  and analyzing alternatives. Specifically, Standards for Internal Control in  the Federal Government states that agency management should  establish an organizational structure to achieve the agency’s objectives. According to the Standards, an effective management practice for  attaining this outcome includes periodically evaluating the organizational  structure to ensure that it meets its objectives and has adapted to  changes. However, 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 both have  evolved since FPS was placed in NPPD in 2010. Additionally, because DHS did not analyze FPS’s current placement in  NPPD, it does not have a benchmark for comparison to other agencies. While establishing this group and  identifying criteria are positive steps in assessing FPS’s placement, the  group’s planned activities are limited in several ways. For example, while  the charter is a draft, it does not indicate that the working group will  describe what changing FPS’s placement is expected to achieve. Further, the draft charter does not indicate that the working group will  evaluate agencies outside of DHS or incorporate best practices for  analyzing alternatives, such as evaluating FPS’s current placement in  NPPD and the benefits and trade-offs of placement options. In absence of these steps, DHS may not be  positioning itself to make an informed decision as to what organization  best supports FPS. DHS has established a working group to evaluate  placement options for FPS. These steps would help DHS address legislation enacted in November  2018 requiring the review of placement options for FPS—including how  DHS considered the results of our review. (Recommendation 1)
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. In its comments, reproduced in appendix IV, DHS concurred  with our recommendations and outlined steps it plans to take to address  them. We reviewed pertinent proposed and enacted legislation  related to DHS’s reauthorization and FPS. We also reviewed documentation and conducted interviews with  stakeholders including:  representatives from the Federal Law Enforcement Officers  Association;  representatives from the American Federation of Government  Employees Local 918 (the union that represents NPPD employees— including FPS);  representatives from two unions that represent a large number of  Protective Security Officers (i.e., contract guards),  the United Government Security Officers of America and Security  and
Security, Police and Fire Professionals Association of America;  representatives from the National Association of Security Companies  (an association of contract guard companies); officials from agencies that coordinate with or use FPS for facility  the Department of Justice for law enforcement coordination and  the Internal Revenue Service and the Social Security  Administration as large users of FPS facility protection;  staff from the Office of Management and Budget; and officials from DHS’s Interagency Security Committee, which develops  the security standards for non-military federal facilities. Marshals Service (Marshals). We evaluated whether  selected agencies that could be placement options for FPS met the key  organizational placement criteria. Similarly,  according to FPS officials, NPPD has not prioritized FPS’s law  enforcement activities because NPPD does not have a focus on law  enforcement.
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.

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.
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.

What GAO Recommends

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.