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Report to Congressional Requesters:

United States General Accounting Office:

GAO:

July 2003:

Federal Law Enforcement Training Center:

Capacity Planning and Management Oversight Need Improvement:

GAO-03-736:

GAO Highlights:

Highlights of GAO-03-736, a report to Congressional Requesters

Why GAO Did This Study:


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. The visual below demonstrates 
the sharp increase since the September 11, 2001, attacks. 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.

What GAO Found:

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. 

What GAO Recommends:

GAO recommends that the Secretary of the Department of Homeland 
Security improve capacity planning, periodically assess the condition 
of training facilities and infrastructure, improve the acquisition 
process for an automated scheduling system, and enhance the governance 
and oversight capabilities of FLETC’s Board of Directors. The 
department and FLETC generally concurred with GAO’s recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-03-736.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Richard M. Stana, 202-
512-8777, Stanar@GAO.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

FLETC's Training Capacity is Strained, and Its Planning for Adding 
Capacity Raises Concerns:

FLETC's Current Scheduling System Is at Risk and Its Acquisition of an 
Automated System Raises Concerns:

The Status of FLETC's Board of Directors Is Unclear, and DHS Has Begun 
to Provide Oversight and Guidance:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Objectives, Scope, and Methodology:

Capacity, Planning, and Coordination:

Scheduling and Coordination of Training Activities:

Governance and Oversight Structure and Guidance:

Appendix II: FLETC's 75 Partner Organizations:

Appendix III: Training Programs and Seminars Provided by FLETC:

Appendix IV: Comments from the Department of Homeland Security:

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgements:

Tables:

Table 1: Capacity and Demand at the FLETC Campuses (in student weeks):

Table 2: Potential Campus Capacities Following Completion of Phase I 
Master Plan Projects (in student weeks):

Figures:

Figure 1: Various FLETC Training Activities:

Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004 
Budget Request:

Figure 3: Partner Organization Training Projections Compared to Current 
Combined Campus Optimum Capacity (in student weeks):

Figure 4: FLETC Campus at Artesia, New Mexico:

Abbreviations:

ACMS: Academy Class Management System:

ATF: Bureau of Alcohol, Tobacco, Firearms and Explosives:

COTS: commercial off-the-shelf-based systems:

DHS: Department of Homeland Security:

FAM: Federal Air Marshals:

FCI: Facility Condition Index:

FLETC: Federal Law Enforcement Training Center:

FTE: full-time equivalent:

INS: Immigration and Naturalization Service:

IT: information technology:

MOU: memorandum of understanding:

O&M: operation and maintenance:

OMB: Office of Management and Budget:

PO: Partner Organization:

RFP: request for proposals:

SASS: student administration and scheduling system:

SEI: Software Engineering Institute:

TSA: Transportation Security Administration:

United States General Accounting Office:

Washington, DC 20548:

July 24, 2003:

The Honorable Harold Rogers 
Chairman, Subcommittee on Homeland Security 
Committee on Appropriations 
House of Representatives:

The Honorable Jack Kingston 
The Honorable Ernest J. Istook, Jr. 
House of Representatives:

Since its inception in the early 1970s, the Federal Law Enforcement 
Training Center (FLETC), now a component of the Department of Homeland 
Security (DHS),[Footnote 1] has played a vital role in training 
personnel from federal, state and local, and foreign law enforcement 
agencies. FLETC is responsible for providing basic, advanced, 
specialized, and refresher training for law enforcement officers from 
75 federal law enforcement agencies.[Footnote 2] Following the 
September 11, 2001, terrorist attacks against the United States, 
FLETC's role and continued ability to provide law enforcement training 
in a timely manner is critical in the war against terrorism. For fiscal 
year 2003, according to the Director of FLETC, 65 percent of its 
projected training workload will come from 9 agencies transferred to 
DHS.

The sudden influx of the large numbers of law enforcement personnel to 
FLETC, coupled with the post-terrorist attack security environment, has 
revived past concerns about the strain placed on its capacity to meet 
the training demand.[Footnote 3] Most recently beginning in the mid-
1990s, these influxes were the result of increases in the personnel 
levels of the U.S. Border Patrol;[Footnote 4] the increases were a 
function of initiatives to control illegal immigration along U.S. 
borders. FLETC, in cooperation with the Immigration and Naturalization 
Service (INS), established a separate, temporary campus in Charleston, 
South Carolina, in fiscal year 1996 to handle the demand for training 
Border Patrol agents because the main FLETC campus at Glynco, Georgia, 
could not accommodate this influx. The current influx has raised 
concerns also about the relevance, quality, and timeliness of training 
provided by FLETC. These concerns, in turn, have prompted some federal 
law enforcement agencies that use FLETC for their basic training to 
periodically consider establishing their own facilities, tailored to 
their unique training needs and philosophy. At the same time, however, 
Treasury and FLETC officials have said that the consolidated approach 
to federal law enforcement training has provided economy-of-scale 
savings annually, although these officials could not establish the 
actual amount of recent savings. According to the FLETC officials, most 
of the savings accrued from (1) achieving economies of scale that 
enabled them to charge training participants lower per diem rates at 
FLETC facilities than those participants would have incurred at their 
own training facilities and (2) avoiding the need for maintaining 
redundant or duplicate training facilities elsewhere.

The issue of consolidated federal law enforcement training is of 
particular interest to you and the Appropriations Committee, which is 
on record as being fully committed to the principle of such training. 
This report responds to an April 2002 request by Representatives Istook 
and Kingston; the House Appropriations Subcommittee on Homeland 
Security joined the request when it assumed jurisdiction over FLETC in 
Spring 2003. On the basis of discussions with your offices, we are 
addressing the following objectives:

* Determine the extent to which FLETC is able to meet the current and 
projected demand for training, how FLETC is planning to meet the 
demand, and the associated costs; and the extent to which FLETC 
coordinates or uses existing, non-FLETC government training assets, and 
any associated costs.

* Examine FLETC's current organizational structures and processes for 
coordinating and scheduling training activities and whether FLETC plans 
any changes to these structures and processes.

* Review FLETC's oversight and governance structures and the extent to 
which these structures are providing guidance to FLETC as it addresses 
its capacity and planning challenges during a period of 
transformational change.

You also asked us to review the final version of FLETC's Master Plan. 
However, DHS did not give us the final plan for FLETC in time to be 
included in this report, citing its need to review the plan. 
Accordingly, we based our analysis of FLETC's planning for future 
facilities on the final draft version of the plan, submitted to us in 
April 2003, and the analyses of the other issues on the most recent 
information available. As agreed with your offices, once the final 
version of the Master Plan is provided to us (DHS estimated that it 
might provide the plan in late summer 2003), and the status of the 
training projections, system acquisition, and FLETC governance becomes 
more apparent, we will complete our analyses and brief you on any 
additional observations.

To develop our information, we visited the FLETC campuses in Glynn 
County, Ga. (commonly referred to as "Glynco"); Charleston, S.C.; 
Artesia, N. Mex.; and Cheltenham, Md. At the campuses, we observed 
training activities; met with FLETC managers and officials in charge of 
training, scheduling, information technology support, and 
infrastructure facilities, and held meetings with officials from 
various agencies, known as Partner Organizations (PO)--such as the 
Border Patrol and the Bureau of Alcohol, Tobacco, Firearms, and 
Explosives (ATF)--that use these campuses. We reviewed relevant 
documents, including the 1970 memorandum of understanding (MOU) that 
established FLETC's roles and responsibilities in providing training to 
law enforcement agencies that are signatories to the MOU; FLETC budget 
requests and related justifications; PO and FLETC historical training 
statistics and projections for future training; FLETC's 1989 Master 
Plan, the 1996 Master Plan update; the 2003 draft final Master Plan for 
facilities assessment, construction, and renovation; and best practices 
related to facilities and information technology acquisition and 
governance and internal and management control. In addition to those we 
interviewed at the FLETC campuses, we met with headquarters officials 
at DHS; and the Departments of the Treasury, Justice, and 
Transportation and their components; and with staff from the Office of 
Management and Budget (OMB). We also met with a representative of the 
architectural and engineering firm in Norfolk, Virginia, retained by 
FLETC to help with its future planning.[Footnote 5] We conducted our 
work from May 2002 through June 2003 in accordance with generally 
accepted government auditing standards. Appendix I provides more 
detailed information about the scope and methodology of our work.

Results in Brief:

Fueled initially by the growth in Border Patrol personnel that began in 
the mid-1990s, and currently by the surge in overall federal law 
enforcement personnel levels in response to the September 2001 
terrorist attacks, the overall 5-day/8-hour capacity to provide 
training at the Glynco and Charleston campuses is strained, while the 
Artesia campus has been underutilized, and the Cheltenham campus is 
being upgraded and is not fully operational (e.g., the U.S. Capitol 
Police is conducting limited training using classrooms and several 
physical venues). FLETC has been able to generally meet POs' needs for 
basic training (the training provided to new recruits) by, among other 
things, operating a 6-day schedule at the Glynco campus and deferring 
POs' advanced classes (those provided to experienced personnel). POs 
offered a variety of views about the effect of the strained capacity on 
the training of their personnel--for example, former Justice 
POs[Footnote 6] noted that the quality of the training had suffered; 
other POs said that although their students and instructors were 
fatigued and stressed, the quality of the training was still good. 
FLETC officials disputed the view that capacity constraints had a 
negative impact on PO training--these officials said that based on 
FLETC's own data, student scores, for example, had not declined. The 
strained capacity has had an adverse effect on the condition of FLETC 
facilities and the infrastructure that supports them. Continued use of 
these facilities at an accelerated rate without maintenance and 
renovation would likely lead to further deterioration and exacerbate 
capacity challenges.

FLETC has worked with an architectural and engineering firm to develop 
a Master Plan to help address long-term capacity challenges. The 
planning process raises several concerns about the assumptions and 
methodologies used to develop the plan's recommendations, and the 
extent to which they allow for contingencies, such as potential future 
surges or declines in demand for training; cost estimating and 
budgeting; and the extent to which the plan's recommendations would be 
implemented in time to help alleviate the capacity constraints. DHS 
officials told us they intend to review the plan, but might not adopt 
substantial parts of it, as the department is formulating its vision 
for federal law enforcement training in general and FLETC in 
particular--these officials said that while useful in some respects 
(e.g., it contains a comprehensive inventory of the condition of FLETC 
training facilities), the plan was essentially dated in its 
assumptions. FLETC does not have a formal contingency plan for 
addressing its capacity challenges during the period up to when 
facilities recommended by the Master Plan begin coming on line and, as 
a practice, has not routinely utilized alternative training assets 
(e.g., off-site training and e-learning) to provide basic training for 
POs.

In addition to strained training capacity challenges, FLETC faces a 
challenge to automate the scheduling of training for its POs. 
Specifically, FLETC's scheduling process 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. FLETC has 
recognized these risks and is in the process of acquiring an automated 
student administration and scheduling system (SASS) to address them. 
Although FLETC's plans and activities for acquiring the SASS generally 
include performance of certain key acquisition management functions, 
FLETC has yet to address important risk management issues associated 
with its SASS acquisition.[Footnote 7] Moreover, with the exception of 
its SASS solicitation, FLETC's plans and activities do not incorporate 
recognized best practices for acquiring commercial off-the-shelf-based 
systems (COTS). Furthermore, FLETC's solicitation activities have not 
adequately addressed SASS security requirements. Taken as a whole, this 
means that FLETC's SASS acquisition is currently at risk of not 
delivering a system solution to best meet its needs. Although FLETC 
continues to develop documentation for the SASS proposal, at our 
urging, it is also working with the Border Patrol to determine whether 
its existing Academy Class Management System (ACMS), which is being 
enhanced with a scheduling module, can be used instead of acquiring 
SASS. According to FLETC officials, if it chooses ACMS, FLETC could 
save the cost of the SASS solicitation and the system's estimated $10 
million cost over 5 years, while spending considerably less to adopt 
the ACMS scheduling module.

FLETC faces challenges in its governance structure because (1) the 
status of its Board of Directors is unclear as FLETC, its individual 
board members, and DHS consider the Board's future; and (2) the Board's 
membership, roles and responsibilities, and past practices are not 
fully consistent with prevailing governance and internal and management 
control best practices. For example, according to a FLETC official the 
Board did not meet for a period of 3-½ years, prior to its most recent 
meeting in November 2002, even though it is required by its own charter 
to meet at least quarterly; and, according to governance best 
practices, the "typical" board of directors meets about eight times a 
year.[Footnote 8] A DHS official said that DHS has recently assumed 
responsibility for FLETC and recognizes the need to provide guidance 
and oversight to FLETC; DHS has begun to work with FLETC to provide 
guidance related to its demand and capacity challenges. In addition, 
DHS recognizes the role an effective FLETC board could play in 
enhancing governance. Without effective internal and external 
governance and oversight, FLETC could be at risk of not effectively 
addressing the transformational challenges it faces.

Because of the importance to FLETC's ability to meet its considerable 
challenges, we are making recommendations to the Secretary of DHS to 
improve capacity planning, periodically assess the condition of 
training facilities and associated infrastructure through the use of 
performance measures, improve the acquisition process for an automated 
scheduling system, and enhance the governance and oversight 
capabilities of FLETC's Board of Directors.

We provided a draft of this report to DHS and to the Department of 
Justice for comment. In its response, from the Under Secretary for 
Border and Transportation Security, DHS generally agreed with our 
conclusions and recommendations and outlined actions it either had 
taken or was planning to take to implement the recommendations. DHS 
also provided technical comments and clarifications, including updated 
information on FLETC's SASS acquisition; we have incorporated them in 
this report where appropriate. Justice did not submit formal written 
comments; the Associate Assistant Attorney General for Federal Law 
Enforcement Training submitted an email with two general comments 
related to the issues of FLETC training capacity and governance, 
respectively.

Background:

The September 2001 attacks spurred a significant surge in the numbers 
of federal law enforcement personnel to respond to the threat posed by 
terrorism. This surge, in turn, resulted in an influx of a large number 
of law enforcement personnel into FLETC's campuses around the country, 
over and above their historical enrollment. Preceding the attacks, in 
fiscal year 2001, over 21,000 students spent over 101,000 student 
weeks[Footnote 9] training at FLETC's domestic campuses. In fiscal year 
2002, primarily as a result of the post-attack surge, over 28,000 
students spent about 157,000 weeks training at these campuses. Placing 
the training statistics in historical context, the weeks spent by 
students at FLETC in fiscal year 2002, for example, represented a 267-
percent increase over the level in fiscal year 1983 (the earliest year 
for which complete data were available) and a 72-percent increase from 
the level of as recently as fiscal year 1999. FLETC's most recent 
adjusted domestic student training projections for fiscal year 2003 
call for about 49,000 students to train for about 259,000 student 
weeks, with PO projections rising to all-time highs of over 57,000 
students and about 283,000 student weeks in fiscal year 2004.

FLETC was established as a consolidated interagency training facility 
in the Department of the Treasury by a Treasury order dated March 2, 
1970. Subsequent to the Treasury order, an MOU between FLETC and its 
POs was established in September 1970. As of June 2003, FLETC was 
working to revise its MOU with its POs to reflect the move to DHS, 
which occurred in March 2003, according to a FLETC official. The 
original MOU, which was revised in 1977 and again in 1984, states that 
FLETC is responsible for, among other things, providing recruit 
(basic), advanced, specialized, and refresher training for designated 
criminal law enforcement personnel; specialized law enforcement 
training for state and local government personnel if space is 
available; facilities and student support services necessary for 
specialized training conducted at FLETC by a PO; updated training 
methods and curriculum content in response to the common needs of the 
participating law enforcement agencies; and dormitory space, food 
service, travel, and support services; and facilities for students 
trained at FLETC. The original POs were the Departments of the 
Interior, Justice, State, and Treasury; OMB; the U.S. Civil Service 
Commission--now the Office of Personnel Management; the U.S. Postal 
Service; and the Smithsonian Institution. FLETC's original MOU was 
expanded over time to currently include the training of law enforcement 
personnel from 75 POs. A list of these 75 POs appears in appendix II.

Figure 1: Various FLETC Training Activities:

[See PDF for image]

[End of figure]

As shown in figure 2, for fiscal year 2003, FLETC had an enacted budget 
of about $172 million, about 79 percent of which was for salaries and 
expenses and 21 percent for acquisition, construction, improvements, 
and related expenses. That year, FLETC had 878 full-time equivalent 
(FTE) permanent staff authorized. For fiscal year 2004, the budget 
request totaled about $146 million, of which about 84 percent was for 
operating expenses (formerly classified as "salaries and expenses") and 
about 16 percent for capital acquisition (formerly classified as 
"acquisition, construction, improvements, and related expenses"). For 
fiscal year 2004, the budget request calls for 754 FTE permanent staff.

Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004 
Budget Request:

[See PDF for image]

[A] "Facilities" refers to "acquisition, construction, improvements and 
related expenses" in fiscal year 2003 and "capital acquisition" in 
fiscal year 2004. No funding was requested for major construction in 
fiscal year 2004.

[B] "Human capital" refers to "salaries and expenses" in fiscal year 
2003 and "operating expenses" in fiscal year 2004.

[End of figure]

FLETC provides training at four domestic campuses.[Footnote 10] 
Specifically, FLETC's largest campus, which also serves as its 
headquarters, is located in Glynn County, Georgia (referred to as 
"Glynco"), and was established in 1975. Most of FLETC's POs conduct 
their law enforcement basic training at the Glynco campus. FLETC's 
second campus, established in 1989, is located in Artesia, New Mexico. 
The resident agencies at Artesia are the Border Patrol (for advanced 
training only), the Bureau of Indian Affairs, Indian Police Academy 
(basic and advanced), the INS Officers Academy, the Transportation 
Security Administration's (TSA) Federal Air Marshals (FAM), and the 
U.S. Secret Service Uniformed Division. FLETC's third campus is a 
former naval base in Cheltenham, Maryland, that was transferred to 
FLETC in May 2001. FLETC intends to use the Cheltenham campus primarily 
as a driving and firearm re-qualification center for POs based in 
Washington, D.C., and its metropolitan area. At the time of our review, 
the campus was being upgraded and was not fully operational. According 
to FLETC officials, the Cheltenham campus will have, among other 
things, an indoor, 108-point, state-of-the-art firing range, and a 
multiuse, topographically varied driving course. Currently, over 12 
federal, including the U.S. Capitol Police, and state and local law 
enforcement agencies are using the campus. FLETC officials at 
Cheltenham anticipate that approximately 61 POs will use the campus' 
firearms and driving re-qualification center. The fourth domestic 
campus is the Border Patrol Academy in Charleston, South Carolina. 
FLETC officials said that to date, this academy has not been placed 
under FLETC's authority; however, FLETC provides technical support to 
the campus for the Border Patrol training. The campus was established 
in 1996 at a former naval base as a temporary facility to handle the 
surge in the number of Border Patrol agent recruits that were the 
result of a hiring initiative to control illegal immigration along U.S. 
borders. The existing FLETC campuses could not accommodate the Border 
Patrol's surge in the resulting demand for training. In October 2002, 
Public Law 107-248 directed that the Secretary of the Navy transfer 
administrative jurisdiction of Charleston, in effect, to DHS, although 
it is not clear whether FLETC would control the facilities.[Footnote 
11] In February 2003, Public Law 108-7 established the Charleston "law 
enforcement training facility" as a permanent training 
facility.[Footnote 12] The campus has been extensively remodeled and 
outfitted to provide basic training to the Border Patrol's agent 
recruits; while it was originally scheduled to close in fiscal year 
2004, if control of the Charleston facility transfers to FLETC, it 
intends to keep the campus open to help provide training capacity, 
regardless of who receives training there. In addition to the training 
provided directly by FLETC, a number of POs, such as the former Customs 
and INS, the U.S. Marshals Service, and the Internal Revenue Service, 
maintain their own "academies" at the FLETC campuses to provide agency-
specific instruction to their recruits.

FLETC offers predominantly four types of training programs--recruit 
(basic), specialized, advanced, and refresher training. Appendix III 
provides a detailed description of the variations of training programs 
and seminars FLETC offers. Basic training (i.e., training provided to 
new recruits) has represented the greatest demand for FLETC's resources 
of all four types of programs given the increase in Border Patrol and 
the surge in federal law enforcement hiring since the September 11 
attacks. Basic training is mandatory for entry-level federal law 
enforcement personnel, such as those hired by the Border Patrol, and is 
usually provided during the first year of employment to familiarize 
recruits with law enforcement skills and operations. Basic training 
also extensively uses FLETC's training facilities, including firearm 
and driver training facilities, in addition to classrooms and other 
physical education facilities.

For specialized training programs, such as agency-specific basic 
training programs (i.e., training provided by agencies immediately 
following FLETC's basic training), FLETC has the responsibility for 
providing instructors for the parts of the program that are standard to 
FLETC's curriculum, while the agency provides the part of the 
curriculum more specific to its mission. For example, FLETC provides 
the instructors for the Courtroom Testimony Lecture and shares 
responsibility with the Border Patrol for the Courtroom Testimony 
Laboratory. ATF and the Environmental Protection Agency, in addition to 
the Border Patrol are examples of agencies requiring specific programs 
as part of their basic training program. For the sections of the 
program that are not designated as a FLETC responsibility, the PO must 
provide instructors. FLETC also evaluates these programs to ensure that 
PO training objectives are being met.

Advanced training is usually provided to junior and senior-level law 
enforcement personnel as part of their continuing professional 
development. An agency that maintains its own academy at a FLETC 
campus, such as the Border Patrol, will typically use its own 
instructors for advanced training. If it has instructors available, 
FLETC may sometimes assist an academy with advanced training. Advanced 
training includes (1) training of inspectors or agents to be 
instructors; (2) "follow-on basic" training, where skills particular to 
an agency mission are taught; and (3) in-service training, which is 
typically an intensive seminar on a current issue or the development of 
a law enforcement or management skill.

FLETC also provides refresher training for its POs. For example, law 
enforcement personnel in the Washington, D.C., area will be able to 
receive refresher training in firearms and vehicle operation re-
qualification at FLETC's Cheltenham campus.

FLETC's Training Capacity is Strained, and Its Planning for Adding 
Capacity Raises Concerns:

FLETC's overall 5-day/8-hour capacity to provide training at the Glynco 
and Charleston campuses is currently strained, while the Artesia campus 
has been underutilized. The Cheltenham campus is being upgraded and is 
not fully operational, thus its contribution to FLETC's overall 
capacity is limited. POs offered a variety of views about the effect of 
the strained capacity on the training of their personnel--for example, 
former Justice POs now in DHS believed that the quality of the training 
had suffered, while other POs said that although their students and 
instructors were fatigued and stressed, they believed that the quality 
of the training was still good. The strained capacity has had an 
adverse effect also on the condition of FLETC facilities and the 
infrastructure that supports them; further deterioration could 
exacerbate capacity challenges. FLETC has worked with an architectural 
and engineering firm to develop a Master Plan to help overcome the 
long-term capacity challenges, although DHS officials said that the 
plan might no longer be germane to the department's vision for law 
enforcement training. The planning process raises several concerns 
about the assumptions and methodologies used to develop the plan's 
recommendations, and the extent to which they allow for contingencies, 
such as future surges or declines in demand; cost estimating and 
budgeting; and the extent to which the plan's recommendations would be 
implemented in time to help alleviate the capacity constraints. FLETC 
does not have a formal contingency plan for addressing its capacity 
challenges during the period up to when facilities recommended by the 
Master Plan begin coming on line and, as a practice, has not routinely 
utilized alternative training assets to provide basic training for POs.

FLETC's Training Capacity Is Strained at the Glynco and Charleston 
Campuses:

Primarily as the collective result of the surge in Border Patrol 
personnel levels begun in the mid-1990s and the surge in overall 
federal law enforcement personnel following the September 2001 
terrorist attacks, the overall capacity to provide basic training at 
Glynco and Charleston is strained. As shown in table 1, the latest 
available PO-projected demand[Footnote 13] exceeds the 5-day/8-hour 
capacity for fiscal year 2003, at these two training campuses. The 
combined capacity for a 5-day/8-hour workweek at the three FLETC 
campuses is about 67,000 student weeks short of projected demand, and 
for a 6-day/8-hour workweek about 28,000 student weeks short of the 
projected demand.

Table 1: Capacity and Demand at the FLETC Campuses (in student weeks):

Campus: Glynco: Fiscal year 2003 projected demand: 192,494; 
FLETC estimated actual attendance (as of 4/30/03): 148,311; Difference 
between projected demand and estimated attendance: 44,183.

November 2002; Optimum 5-day/8-hour capacity: 120,000; Optimum 
6-day/8-hour capacity: 144,000].

March 2003 (temporary increase in capacity); Optimum 5-day/8-
hour capacity: 135,000; Optimum 6-day/8-hour capacity: 162,000.

Campus: Charleston; Optimum 5-day/8-hour capacity: 37,000; Optimum 6-
day/8-hour capacity: 44,000; Fiscal year 2003 projected demand: 41,259; 
FLETC estimated actual attendance (as of 4/30/03): 33,816; Difference 
between projected demand and estimated attendance: 7,443.

Campus: Artesia; Optimum 5-day/8-hour capacity: 27,000; Optimum 6-day/
8-hour capacity: 32,000; Fiscal year 2003 projected demand: 32,095; 
FLETC estimated actual attendance (as of 4/30/03): 18,556; Difference 
between projected demand and estimated attendance: 13,539.

Campus: Total; Optimum 5-day/8-hour capacity: 199,000; Optimum 6-day/8-
hour capacity: 238,000; Fiscal year 2003 projected demand: 265,848; 
FLETC estimated actual attendance (as of 4/30/03): 200,683; Difference 
between projected demand and estimated attendance: 65,165.

Source: GAO analysis of FLETC data.

[End of table]

However, also as shown in table 1, FLETC is estimating (as of April 30, 
2003) that the actual number of student weeks spent at the three 
campuses will total 200,683 student weeks, or 25 percent less than the 
fiscal year 2003 projected levels. A FLETC official said that it is not 
unusual for actual attendance to fall short of projections because of 
factors such as recruiting shortfalls, funding reallocations, and 
classes that begin with less than their full complement. In fact, 
actual attendance (in student weeks) fell short of projections as 
recently as fiscal year 2001, when attendance was about 76 percent of 
the projected level. In fiscal year 2002, actual attendance was about 
112 percent of the projected level.

The FLETC official attributed the difference in fiscal year 2003 to 
three principal factors. First, changes in TSA's projections--TSA 
originally projected about 49,000 student weeks of training primarily 
for airport security officers, and for "flight deck officers" (i.e., 
airline pilots trained to carry firearms in cockpits) and FAMs. 
However, the TSA projections have not materialized to date, with the 
estimated actual attendance totaling about 10,000 student weeks. 
Second, changes to the Border Patrol's projections--the Border Patrol 
originally projected about 46,000 student weeks of training for agents. 
However, the estimated actual attendance totals about 33,000 student 
weeks. Third, changes to the former INS's projections--INS originally 
projected about 50,000 student weeks of training for inspectors and 
agents. However, the estimated actual attendance totals about 40,000 
student weeks. A FLETC official cautioned that the final actual 
attendance for fiscal year 2003 might be different than the estimates 
based on additional requests, DHS reorganization training guidelines, 
attrition, and additional hiring budgets. For example, there is a 
possibility that if funding is restored, TSA may yet end up needing a 
number of the student weeks it originally projected.

Even if the fiscal year 2003 projections do not ultimately materialize, 
FLETC's 5-day/8-hour capacity would still be strained. Specifically, 
the total estimated actual attendance of 200,683 student weeks will 
exceed the combined 5-day/8-hour capacity of 199,000 student weeks by 
about 1,700 student weeks. In discussing the capacity strains facing 
FLETC, we note that "student weeks" provides FLETC with a statistical 
measure of optimum throughput, or best case, training capacity (see 
footnote 3). This measure assumes that all of the requisite facilities, 
instructors, and equipment will be available to provide training when 
needed. However, capacity is ultimately a function of facilities, 
instructors, and equipment that are actually available to provide 
training at a point in time. Accordingly, while a number of student 
weeks may appear to be "available" (for example, as in the case of the 
Charleston campus, where estimated actual attendance is about 3,000 
student weeks below the campus's 5-day/8-hour capacity); at any given 
time, a number of physical and human "choke points," or training 
obstacles, either individually or collectively result in capacity 
constraints. Thus, the choke points essentially reduce the number of 
available student weeks from the best-case level.

In this regard, a number of choke points are causing the capacity 
strains that the Glynco and Charleston campuses are experiencing. 
Specifically, according to FLETC, the principal choke points that are 
collectively causing the capacity strain at Glynco are the firearms 
ranges, driving ranges, practical exercise facilities, the dining hall, 
classrooms, dormitories, and a shortage of instructors and support 
staff. At Charleston, the choke points include the firearms ranges, 
driving ranges, and a shortage of instructors--illustrating the effect 
of choke points on capacity at Charleston, during fiscal year 2003, the 
Border Patrol had to defer 3 classes of agent training because the 
campus's emergency response driving range had to be taken off-line for 
resurfacing. According to FLETC officials, had these classes actually 
taken place, Charleston's 5-day/8-hour capacity would have been met or 
exceeded.

On the basis of the latest PO projections for training demand, FLETC's 
overall capacity strain is expected to continue for fiscal year 2004. 
However, for fiscal years 2005 through 2008, PO projections show a 
relatively stable decrease in demand from fiscal year 2004 peak levels, 
but projected demand still exceeds FLETC's fiscal year 2003 5-day/8-
hour capacity and is approaching the current 6-day/8-hour capacity. 
Figure 3 shows the difference between combined projected demand and 
combined current capacity of FLETC facilities for fiscal years 1997 
through 2008.

Figure 3: Partner Organization Training Projections Compared to Current 
Combined Campus Optimum Capacity (in student weeks):

[See PDF for image]

Note: This graph includes the Glynco, Artesia, and Charleston campuses.

[End of figure]

Artesia Campus Has Been Underutilized:

While capacity at the Glynco and Charleston campuses has been strained, 
the Artesia campus has been underutilized following the completion of 
FAM's ramped-up training during fiscal year 2002. In this regard, as 
shown in table 1, Artesia has an annual capacity of 27,000 student 
weeks for a 5-day/8-hour schedule and 32,000 student weeks for a 6-day/
8-hour schedule. In fiscal year 2002, PO trainees spent 19,188 student 
weeks at Artesia, well short of capacity. Although PO demand 
projections of 32,095 student weeks initially suggested that the 
Artesia campus would experience some minor capacity strains in fiscal 
year 2003, it is not clear that the campus will be fully utilized. 
Specifically, based on year-to-date attendance data through April 2003, 
FLETC estimated that 18,556 student weeks will actually be spent at 
Artesia, well short of the levels originally projected by POs. As 
discussed earlier, according to FLETC officials, the shortfall is 
primarily caused by TSA's original projections for training not 
materializing--part of this training was to be held at the Artesia 
campus. FLETC officials cautioned, however, that the final actual 
attendance might be different than the April 2003 estimate, and could 
be somewhat closer to the original projection based on additional PO 
requests, DHS reorganization training guidelines, attrition, and 
additional hiring budgets.

In addition to Artesia's underutilized housing and firearms ranges, the 
live-fire shoot houses and three Boeing 727s, specially configured for 
terrorism training, have not been used since the FAMs completed their 
training (see figure 4). A FLETC official indicated that it is 
conducting marketing and other types of activities to attract a number 
of additional users to the campus. In this regard, several POs told us 
that they considered Artesia to be too remote of a location to send 
their recruits and, especially, their instructors for training. The 
FLETC officials stressed that the Artesia campus could not, as 
currently configured, and discussed later, handle the transfer of the 
Border Patrol's basic training from the Charleston campus to Artesia, 
as proposed in the Master Plan. If the transfer were to occur, the 
Border Patrol's projected fiscal year 2003 demand for training would 
exceed Artesia's 5-day/8-hour capacity by at least 6,000 student weeks 
and up to 14,000 student weeks, depending on the schedule adopted.

Figure 4: FLETC Campus at Artesia, New Mexico:

[See PDF for image]

[End of figure]

FLETC Has Generally Met PO Needs for Basic Training:

Despite its strained capacity, FLETC has nevertheless been able to 
generally meet its POs' demand for basic training principally by, among 
other things,

* operating on a 6-day, multiple-shift training week at its Glynco 
campus to overcome constrained resources;

* deferring some training programs for certain POs that were not 
originally projected and that were made late in the year--for example, 
the Secret Service, Customs, and the General Services Administration's 
Federal Protective Service made such requests;

* canceling or deferring some of the POs' advanced training classes 
following the September 2001 attacks--FLETC rescheduled about 5 percent 
of these classes within the fiscal year;

* continuing to schedule and conduct Border Patrol's basic training at 
the Charleston campus, in cooperation with the Bureau of Customs and 
Border Protection/Border Patrol;

* rotating instructors to most needed areas of work; and:

* converting buildings and trailers that had been previously utilized 
for office space into training facilities such as raid houses, mat 
rooms, classrooms, and firearms simulations.

We note that while this approach may have helped mitigate the capacity 
constraints in the short term, deferring or canceling training may 
exacerbate any potential future strains on FLETC capacity--this 
training would likely need to be made up sometime in the future--and 
result in law enforcement personnel not being available for duty when 
needed.

PO Views about the Effect of the Capacity Strains on Their Personnel:

POs offered a variety of views about the effect of FLETC's strained 
capacity on their training, in terms of, among other things, trainee 
attrition, the quality and timeliness of instruction, and instructor 
morale and retention. For example, representing the views of Justice 
POs (prior to their transition to DHS), a senior Justice official said 
that the strained capacity--and especially the need to train 6 days a 
week at Glynco--had resulted in higher attrition rates for trainees and 
fatigue, burnout, and low morale for instructors. In addition, 
according to this official, the quality of instruction, and thus that 
of the training received, had suffered. Further, a May 2002 internal 
Justice report on FLETC training issues noted that one of its component 
agencies had to cancel all of its "badly needed" advanced training due 
to the lack of space at FLETC. In commenting on a draft of this report, 
FLETC said that the PO was actually asked to shift its training within 
the fiscal year but declined to do so. The Justice report also noted 
that the 6-day training arrangement caused additional problems for 
Justice POs, including having to pay overtime and having difficulty in 
attracting and retaining instructors. Separately, a former Treasury PO 
reported that FLETC had to defer basic training for 168 agent recruits 
because of capacity constraints--since they could not be trained, and 
thus not deployed, these recruits were assigned nonagent, desk work. 
Basic training for recruits hired by September 2002 was to be completed 
in about 11 weeks. However, capacity strains caused FLETC to train the 
recruits in stages, with some not completing their training until 
February 2003. FLETC officials disputed the POs views that capacity 
constraints had had a negative impact on training. These officials said 
that based on FLETC's own data for the period of the capacity 
constraints, overall student test scores had not declined in a 
statistically significant manner over time, and student surveys 
continued to show a high level of satisfaction with FLETC's training 
services. Regarding the aforementioned example of the Treasury PO 
deferral, FLETC said that the PO's request was for 240 students and was 
not initially projected. FLETC also said that it was actually able to 
accommodate immediately 72 of the students.

Other POs indicated that while their instructors and students generally 
experienced greater fatigue and stress as a result of FLETC's capacity 
constraints, the quality of the training had not suffered 
significantly. For example, one PO said that although there was a 
slight decline in student test scores, it was unclear whether this 
decline could be attributed exclusively to the capacity strain. The 
same PO reported that the extended hours resulting from the constraints 
actually allowed its trainees to complete their training in 9 weeks 
instead of 11, allowing them to be deployed to duty assignments sooner.

Capacity Strains Have Impacted the Condition of Facilities and 
Supporting Infrastructure:

FLETC's implementation of 6-day, multiple-shift training at Glynco to 
help alleviate the capacity constraints at that campus has led to the 
intensive scheduling of its facilities. Such above-average usage of 
facilities places additional loads and strains on their systems and 
components, increasing the need for maintenance and repair.[Footnote 
14] Maintenance programs and renovation projects are often deferred, 
according to FLETC officials, due to the lack of funding or an ability 
to only schedule facility "down time" for maintenance in the evenings 
and on Sundays. Cheltenham, for example, has an electrical system that 
is subject to failure at any time and a chlorination system that has 
failed, resulting in the need to provide bottled water for drinking. At 
the time of our site visits, utility upgrades were needed at Glynco, 
Cheltenham, and Artesia, and road and parking upgrades were needed at 
Glynco and Cheltenham; many facilities at Glynco are now only available 
for maintenance during evening hours or on Sundays. Although not 
quantifiable at this point, continued deterioration of facilities would 
likely lead to increased capital requirements in the future and 
adversely affect employee working conditions and retention.[Footnote 
15]

FLETC has considered the degradation issue in some of its internal 
reports; however, FLETC does not have any immediate contingency plans 
to address facility degradation. Such planning would be vital to help 
address the potential impact of facility degradation on FLETC's already 
strained capacity. Many organizations use periodic facility condition 
assessments to establish baseline facility data and to aid in planning 
for short-and long-range facility maintenance and repair needs. 
Currently, FLETC does not have detailed information about the condition 
of its facilities. A "Facility Condition Index" (FCI) would help to 
address the degradation issue by giving measurable performance data 
about its facilities rather than relying on anecdotal information. An 
FCI is the ratio of the cost of maintenance and repair deficiencies to 
the facility's current replacement value. A FCI value of less than 0.05 
is generally considered to represent a "good" facility condition.

The draft final version of the Master Plan concluded that although 
FLETC had done a commendable job in handling the ever-increasing demand 
for training, it had done so at a price. Part of this price has been 
the degradation of its facilities--funding has been focused on building 
new facilities to alleviate choke points, while maintenance and 
renovation have been continuously deferred due to the lack of funding. 
Echoing our own concerns about this issue, the firm that developed the 
plan concluded that continuation of this cycle will eventually result 
in building element or critical infrastructure failures and made 
recommendations for renovations and expansion as part of its broader 
three-phase approach for improving and expanding FLETC's capacity.

FLETC Master Plan Intended to Help Alleviate Capacity Constraints:

The Master Plan's recommendations for renovation and expansion of 
existing, and the construction of new facilities are arrayed in three, 
partly overlapping, 5-7 year construction phases for each of the 
campuses (except Charleston, which FLETC had, at the time the Master 
Plan was being developed, assumed would close by 2004). The first phase 
of construction extends at maximum from 2006 to 2011, the second from 
2009 to 2015, and the third from 2013 to 2019. Each phase includes a 
mix of renovation and expansion projects, as well as the construction 
of new facilities. According to FLETC, the extent of additional 
capacity, in terms of student weeks, would depend on the completion of 
the construction projects, the programmatic mix, and other factors 
(e.g., the requisite staffing being available). As shown in table 2, if 
the plan's prioritized list of construction projects for phase 1 were 
to be completed, and the programmatic mix and other factors did not 
change, the capacities of Glynco and Artesia would increase as follows: 
for Glynco, 193,500 student weeks for the 5-day/8-hour schedule, 
232,000 student weeks for the 6-day/8-hour schedule, and 278,000 
student weeks for the 6-day/12-hour schedule; for Artesia, 55,000 
student weeks for the 5-day/8-hour schedule, 66,000 student weeks for 
the 6-day/8-hour schedule, and 79,000 student weeks for the 6-day/12-
hour schedule. The Cheltenham campus is not included since it is being 
upgraded and FLETC currently does not intend to use the campus as a 
residential facility.

Table 2: Potential Campus Capacities Following Completion of Phase I 
Master Plan Projects (in student weeks):

Campus: Glynco; 5-day/8-hour: 193,500; 6-day/8-hour: 232,000; 6-day/
12-hour: 278,000.

Campus: Artesia; 5-day/8-hour: 55,000; 6-day/8-hour: 66,000; 6-day/12-
hour: 79,000.

Campus: Total; 5-day/8-hour: 248,500; 6-day/8-hour: 298,000; 6-day/12-
hour: 357,000.

Source: GAO analysis of FLETC data.

[End of table]

The April 2003 final draft of the plan estimates the combined cost of 
the three phases to be about $907 million; the estimate includes costs 
for construction and furnishings and fixtures but excludes operation 
and maintenance (O&M) costs. O&M costs are estimated separately for the 
period of 2008 through 2040 from the project costs and total about $269 
million.

FLETC's Planning to Address Its Capacity Constraints Raises Concerns:

The FLETC Master Plan's assumptions and methodologies in particular, 
and FLETC's plan to address its capacity constraints in general, raise 
a number of concerns. First, the plan assumes that the Border Patrol 
will shift its basic training from the Charleston campus to the Artesia 
campus and that the Charleston campus will close.[Footnote 16] However, 
as indicated earlier, the Consolidated Appropriations Resolution, 2003 
(Public Law 108-7), established the Charleston "law enforcement 
training facility" as a permanent training facility. While the 
Department of Defense Appropriations Act, 2003 (Public Law 107-248) 
directed the Secretary of the Navy to transfer administrative 
jurisdiction of the Charleston law enforcement training facility to, in 
effect, the DHS, it is not clear whether FLETC will be the entity 
within the department to assume responsibility of the facility, and 
which FLETC POs, if any, will receive training there.

Second, the Master Plan assumes that the training schedule at Glynco 
will return to a 5-day/8-hour week, but a FLETC official acknowledged 
that a return to such a shift for basic training is unlikely in at 
least fiscal year 2004, given the current and projected demands for 
training at the campus. Third, the plan assumes a set of baseline 
projections of future demand for training for each of the campuses from 
which future facility needs are generated. These Master Plan 
projections are lower than the latest projected attendance levels that 
FLETC is currently facing. Specifically, while several baseline 
workload scenarios were originally considered, only one was actually 
utilized to estimate the future need for facilities. Using a single 
baseline is questionable because it excludes accounting for possible 
future increases or decreases in the demand for training that would 
render the original baseline obsolete.

Fourth, the plan assumes constant (or straight-line) growth rates in 
projecting the need for additional facilities at each FLETC campus. 
However, these growth rates are based on historical precedent and do 
not fully take into account recent events such as today's new security 
environment and the resulting surge in the demand for training of law 
enforcement personnel, and do not take into account future events such 
as potential further surges, or declines, in training demand, or 
changes in the attrition of federal law enforcement personnel. Finally, 
the plan does not assume potential efficiencies that might result from 
FLETC's planned automation of its system for scheduling training 
(discussed below). Use of such an automated system could result in more 
efficient scheduling of facilities. The firm that developed the plan 
acknowledges that if efficiencies were to be achieved through the 
automation of scheduling, the plan would need to be revised.

Concerns about FLETC's planning also involve the Master Plan's cost 
estimates and future budget requests for construction and the extent to 
which the plan's phase 1 recommendations would be implemented in time 
to begin alleviating the capacity constraints. Regarding the cost 
estimates, the Master Plan's estimates should be treated with 
considerable caution. Specifically, although we did not analyze the 
plan's estimates in detail, we note two broad concerns. First, because 
the plan's recommendations have not proceeded beyond the conceptual or 
early design stage, the cost estimates are likely to be very "soft," 
with considerable potential upside tendency--at the conceptual stage; 
costs are likely to vary by as much as 50 percent. Second, the plan's 
recommendations and their design may be altered by DHS as part of its 
ongoing review of the plan (discussed later), thus changing the 
estimated costs. Further, a FLETC official said he identified a number 
of cost errors as part of his review of the April 2003 version of the 
final draft of the plan--these errors involved life cycle-costs, O&M 
costs, and architectural and engineering fees. We also found, and 
brought to FLETC's attention, cost discrepancies between the 90-percent 
and final draft versions of the plan's phase 1 construction totaling 
over $100 million. For the entire plan, the discrepancies totaled over 
$200 million. A FLETC official concurred that there were discrepancies 
and told us that FLETC was working to resolve them. In terms of future 
budget requests for construction, the estimated costs for the first 
phase of the Master Plan are more than five times the total 
appropriated amounts for new facilities and renovations for fiscal 
years 2001 through 2003 and the request for fiscal year 2004. A FLETC 
budget official said that in terms of lead time to fund the plan's 
recommendations, FLETC, in keeping with its past practice, would likely 
request the entire amount up front for all approved projects. Based on 
capital acquisition best practices, this approach is not unusual in the 
construction field. In this regard, a DHS official said that a request 
for construction expenditures for training facilities was not expected 
until the fiscal year 2005 budget cycle.

In terms of the timely implementation of the Master Plan's 
recommendations, construction of the projects recommended in the plan's 
first phase would not begin to be completed until 2008 at the earliest, 
leaving a gap of at least 5 years of continued strained capacity that 
would need to be addressed through other means.

FLETC Does Not Have a Contingency Plan to Address Capacity Constraints 
and Has Not Routinely Utilized Alternative Assets to Provide Basic 
Training:

Adding to the long-term challenge of addressing its capacity 
constraints, FLETC does not currently have a formal written training 
contingency plan independent of the Master Plan for addressing its 
immediate training capacity challenges, or the challenges leading up to 
when the plan's recommendations are expected to come on line in 2008. 
FLETC officials said that although they would like to have a written 
training contingency plan, and had been developing a contingency 
planning process, they were operating in an essentially reactive mode 
to address the more immediate issue of responding to continuing surges 
in the demand for training. In this regard, a FLETC official said that 
in this regard it would consider adding more shifts to the Glynco 
campus if needed.

Further, FLETC neither has, as a routine practice, utilized alternative 
training assets to provide basic training for its federal POs 
(including off-site training locations, e-linkages, and satellite 
communications), nor does it have a formal plan for doing so. FLETC 
officials indicated that these measures were to be given more 
consideration in the future as a means of addressing campus capacity 
strains. FLETC officials explained that they had been reluctant to 
provide PO training in facilities they did not own because they could 
not control the training schedule, given the absence of ongoing 
arrangements with the owners of such facilities. Instead, according to 
FLETC officials, on a limited and informal basis, FLETC facilitated the 
use of alternative training facilities by some law enforcement agencies 
when it could not immediately accommodate their training needs. A FLETC 
working group initiated by DHS is currently reviewing the extent to 
which training assets--in addition to the FLETC campuses--owned by DHS 
component agencies can be used for training.

DHS Is Reviewing FLETC's Master Plan, but Considers It of Limited 
Future Use:

DHS officials said that the department was in the process of reviewing 
the Master Plan, to be followed by an OMB review. Without offering 
details, they also said that although useful in some respects, the plan 
might not be germane as the department develops its vision of law 
enforcement training for FLETC. These officials said they considered 
the plan useful as a tool in identifying the condition of existing 
FLETC facilities and the need for expansion. However, they did not view 
the plan as a roadmap for the future. A DHS official expected the 
review process of the plan to be completed by mid July 2003.

In concert with its review of the Master Plan, DHS has tasked FLETC to 
chair a working group--the Training Academy Charter Committee--
comprised of department component agencies to inventory their training 
assets and develop a coordinated strategy so that these assets are used 
effectively to provide training. FLETC's specific task is to develop a 
survey instrument, collect and analyze the survey results, and play a 
role in developing recommendations. A FLETC official expects the 
committee's work to be completed by July 2003.

FLETC's Current Scheduling System Is at Risk and Its Acquisition of an 
Automated System Raises Concerns:

Within the context of strained training capacity, FLETC's scheduling 
process poses internal control risks. FLETC relies on 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. 
FLETC has recognized these risks and is in the process of acquiring an 
automated system, SASS, to address them. Although FLETC's plans and 
activities for acquiring SASS generally include performance of certain 
key acquisition management functions, FLETC officials have yet to 
address important risk management issues associated with its SASS 
acquisition. Moreover, with the exception of its SASS solicitation, 
FLETC's plans and activities do not incorporate recognized best 
practices for acquiring commercial off-the-shelf-based systems. 
FLETC's solicitation activities have not adequately addressed SASS 
security requirements. Taken as a whole, this means that FLETC's SASS 
acquisition is currently at risk of not delivering a system solution to 
best meet its needs. While FLETC continues to develop the SASS request 
for proposals (RFP)--at our urging, it is also working with the Border 
Patrol to determine whether its existing ACMS can be used instead of 
acquiring SASS.

Current Scheduling System Places the Delivery of Training Services at 
Risk and Does Not Maximize Use of Existing Facilities:

FLETC's current system for scheduling training places efficient 
delivery of training services at risk. FLETC's scheduling system is 
predominantly manual and only partly automated. The manual part of the 
system involves, among other things, the use of large desk calendars, 
colored markers, and color-coded post-it notes to schedule things such 
as student classes, student housing, classrooms, instructors, language 
and computer laboratories, firing ranges, driving ranges, and mat 
rooms. As schedules change, for example, the notes are moved on the 
calendar to different dates; cut-and-pasting is also used to change 
schedules. Markers are used to color blocks of dates for training by 
particular POs. FLETC's scheduling subsystems at three of the 
four[Footnote 17] campuses are also predominantly manual systems that 
require labor-intensive corrections if even one course is changed. In 
addition, the scheduling subsystems do not interface with one another, 
thus requiring time-consuming efforts to communicate.

The paper-intensive nature of the system raises issues of internal 
control. FLETC's ability to adequately schedule training for most of 
its 75 POs at its campuses is further hampered by its reliance on 
certain key schedulers to keep the system functioning. The campuses in 
Charleston and Artesia each have a single scheduler to handle all of 
the scheduling, without any backup. Further, at the Glynco campus, the 
loss of key scheduling documents that are currently kept in a single 
"master binder" without a backup could significantly hamper FLETC's 
scheduling. FLETC schedulers said that if this binder were to be lost 
or destroyed, they would have to undertake a time-consuming process to 
manually recreate most of the training schedules by soliciting relevant 
information from affected POs. In this regard, according to the 
Comptroller General's standards for internal control,[Footnote 18] 
vulnerable assets, in this case the master binder, should be subject to 
secure physical control in order to be safeguarded against loss; in 
addition, a disaster recovery plan helps recover from a loss. The 
standards also call for the accurate and timely recording and 
documentation of transactions and significant events, in this case the 
scheduling of training. According to the standards, documentation of 
transactions and events needs to be complete and accurate to facilitate 
tracing from initiation to completion.

FLETC has acknowledged the manual scheduling system's shortcomings and 
its implications for efficiency and risk management. FLETC officials 
told us that its scheduling system does not provide for the optimal use 
of existing facilities, especially for sequencing classes. For example, 
only one class can use a 4-course driving range at any given time; 
while the class completes one course, the other three remain idle. More 
efficient scheduling would enable four classes to rotate through the 
driving range's courses. The Master Plan's analysis also suggests that 
automating the scheduling could help gain efficiencies in the use of 
existing facilities.

FLETC officials have recognized the need for a fully automated system 
that can address FLETC's vast scheduling needs, including quickly 
incorporating any changes once a schedule has been prepared. In this 
regard, FLETC listed in its draft SASS RFP the challenges, and their 
effects, associated with its manual system. The draft RFP stated that 
current business processes in support of FLETC's student administration 
and scheduling were complex, not integrated, and were often performed 
manually. Historically, according to the draft RFP, this has resulted 
in (1) FLETC schedulers reacting to ever-changing training projections; 
(2) a manual, paper-laden, and slow student scheduling and registration 
process requiring student information to be entered into multiple data 
systems; and (3) inconsistent student information processed throughout 
the system and numerous changes caused by ever-changing projections in 
the demand for training. A FLETC official also said that a manual 
recalculation and distribution of class schedules each time a change is 
made to a single class.

Background on the SASS Acquisition:

The SASS acquisition project began in 1999, when Congress provided 
FLETC with $350,000 to begin planning for automating its scheduling 
process. After completing requirements definition in December 2000 and 
its market research activities in December 2001, FLETC decided to 
expand the project to provide a training management system, rather than 
just a scheduling system. In researching SASS alternatives, FLETC 
officials determined that utilizing commercially available components 
or products was its preferred alternative. Accordingly, FLETC decided 
to pursue a COTS. FLETC began developing its request for vendor 
proposals in 2001 and in May 2002 FLETC issued a request for proposals, 
a solicitation package that included background on the project, project 
objectives, system requirements, and other information. However, 
according to FLETC officials, vendors were concerned about the time and 
expense required to submit an adequate proposal as well as the criteria 
proposed to evaluate potential solutions. As a result, FLETC withdrew 
the solicitation and is currently revising it to address these 
concerns. According to a FLETC official, issuance of the SASS RFP has 
been delayed, pending the outcome of an effort to determine whether a 
similar system being developed separately by the Border Patrol, 
Customs, and INS can be used by FLETC. This effort is discussed in the 
following sections.

FLETC plans to implement SASS within a 1-year period after signing a 
contract, and officials estimate an approximate 5-year cost of $10 
million (1 base-year and 4 option-years, including maintenance). SASS 
is a subproject within an overall FLETC information technology (IT) 
modernization project. Because FLETC intends to encourage vendors to be 
innovative in offering possible solutions, the system requirements to 
be included in the solicitation are for information purposes only. For 
example, FLETC officials said that SASS may or may not be physically 
located at FLETC's Glynco campus, depending on the selected solution, 
but all four facilities should have access to the system.

FLETC Has Yet to Address Important SASS Acquisition Issues:

FLETC's plans and activities for acquiring SASS generally include the 
performance of certain key acquisition management functions, such as 
acquisition planning, solicitation, requirements management, and 
project management. However, first, FLETC has yet to focus on another 
key acquisition function--risk management. Second, with the exception 
of solicitation, FLETC's attempt to obtain a COTS-based system lacks 
some acquisition best practices. These practices call for continuous 
tradeoff among such interdependent acquisition variables as system 
requirements, commercially available system products and components, 
cost and schedule constraints, and the architectural environment within 
which the system will operate. Third, FLETC solicitation activities 
have not adequately addressed SASS security requirements. Taken as a 
whole, this means that FLETC's SASS acquisition is currently at risk of 
not delivering a system solution to best meet FLETC's needs.

Certain Acquisition Functions Are Being Performed:

Carnegie Mellon University's Software Engineering Institute (SEI), 
recognized for its expertise in acquiring software-intensive systems, 
has published an acquisition management model that defines key 
acquisition functions and assigns them to five incremental stages of 
maturity.[Footnote 19] According to SEI, the following acquisition 
functions are part of a minimum set that need to be practiced in order 
for software-intensive systems to be acquired in a repeatable, 
effective manner: acquisition planning, solicitation, requirements 
management, and project management.

On its SASS acquisition, FLETC is performing these functions in a 
manner that is generally consistent with SEI's maturity model, as 
described later. According to FLETC officials, these functions are 
being performed because they are following agency IT guidance that 
specifies processes and procedures for acquiring and managing IT 
investments. By performing them, FLETC is providing a margin of 
assurance that SASS will be effectively acquired.

Acquisition planning. The purpose of acquisition planning is to ensure 
that reasonable planning for the acquisition is conducted and that all 
elements of the project are included. Among other things, this involves 
assigning project responsibilities and documenting an acquisition 
strategy that specifies, for example, acquisition objectives and 
methods, project constraints, contract types and terms, and schedule 
and cost estimates. For SASS, FLETC is performing these activities. 
Responsibility for the acquisition has been assigned to IT and 
contracting personnel. FLETC has also documented an acquisition 
strategy that defines acquisition objectives and methods (e.g., maximum 
use of commercial products) and project constraints (e.g., FLETC's 
right to inspect all services provided). FLETC has also defined a 
contract type and terms, (5-year, fixed cost with award fee), and it 
estimates that the selected system will be implemented within 1 year of 
contract award and cost about $10 million over the 5-year contract 
period.

Solicitation. The purpose of solicitation is to prepare a documentation 
package that identifies acquisition needs and selects the best provider 
and solution to meet those needs. Examples of solicitation practices 
include educating end users and others about the planned solicitation 
and engaging them in developing a solicitation package that includes 
objectives; technical and other product evaluation criteria; and 
contract acceptance procedures, criteria, and payments. FLETC has done 
this for the SASS acquisition. The SASS project office has engaged 
FLETC's training divisions in developing the package and educated them 
about business process changes that may need to accompany the system's 
implementation. Further, the solicitation package[Footnote 20] (i.e., 
RFPs) contains FLETC's objectives for the overall acquisition; 
evaluation criteria; and acceptance procedures, criteria, and payment 
methods.

Requirements management. The purpose of requirements management is to 
establish a common and unambiguous definition of requirements that is 
understood by users, the project team, and suppliers. Requirements 
management includes, among other things, establishing the project 
scope, assigning specific responsibilities for managing the 
requirements, collecting end-user input, and establishing a baseline 
set of requirements before releasing the solicitation. FLETC has done 
this. For example, FLETC has defined the project scope to be a total 
system solution for student registration and scheduling. FLETC has also 
assigned requirements management responsibilities to an integrated 
process team, obtained user input by canvassing FLETC training 
divisions and having them verify the system requirements, and 
established a baseline requirements set in a December 2000 software 
requirements specification.

Project Management. The purpose of project management is to manage 
project office activities and support units to ensure a timely, 
efficient, and effective acquisition. Examples of project management 
practices are defining project responsibilities, engaging user 
organizations, and identifying project costs and schedules. FLETC has 
performed each of these. Namely, an IT project manager, supported by a 
staff project office, is in place, training division heads are 
participating in the project, and cost and schedule estimates have been 
developed.

Acquisition Risk Management Is Not Being Performed:

SEI's acquisition model also recognizes the need to manage acquisition 
risks. Moreover, many software acquisition experts consider risk 
management to be one of the most important acquisition areas. The 
purpose of risk management is to identify risks as early as possible, 
manage those risks, and develop and implement a risk management 
process. Risk management includes identifying risks and categorizing 
them based on probability and impact, developing risk mitigation 
strategies, implementing the strategies, and tracking and reporting on 
progress.

During our review, FLETC officials told us they had yet to begin risk 
management activities, or establish any type of risk management 
function, and they did not plan to begin such activities until they 
receive the vendors' proposals. Following our inquiry, officials told 
us they (1) recognize that risk management is important to overall 
project success; (2) have a rough draft of a risk management plan; and 
(3) in May 2003, developed a project risk assessment plan for SASS. 
FLETC has not provided us with these documents, and not having 
completed these actions at this point is not consistent with SEI 
guidance, which advocates early and continuous management of risks so 
as to minimize the chances of risks becoming actual problems (i.e., 
system cost, schedule, and capability shortfalls). By waiting to manage 
risks, FLETC is not proactively mitigating known SASS risks; such as 
those that SEI reports to be inherent in a COTS-based acquisition 
(e.g., volatility of the commercial market and organizational 
resistance to business process changes required by a COTS-based 
solution). The result is a reduced probability of delivering promised 
SASS capabilities on time and within budget.

Approach to Performing Acquisition Functions Lacks Two Key Elements:

Notwithstanding the fact that FLETC is performing key SASS acquisition 
functions, it is deficient in its performance of these functions in two 
ways. First, its solicitation package does not adequately address 
system security. Second, with the exception of solicitation, FLETC has 
not adequately provided for the use of COTS-based system acquisition 
best practices in performing these functions. According to FLETC 
officials, the former is an oversight that they have hired a security 
manager to address, and the latter is a byproduct of their focus to 
date on solicitation activities. They added that they plan to 
incorporate COTS-based system acquisition best practices in their 
performance of other SASS acquisition function as soon as the 
solicitation is released. Until they do, the SASS acquisition is at 
risk of not delivering FLETC users with a secure, long-term, cost-
effective system to support FLETC's mission needs.

Security. Since 1997, we have designated information security as a 
governmentwide, high-risk area because of significant and pervasive 
agency weaknesses in controls over computerized operations, due, in 
part, to the government's increasing reliance on commercially available 
information technology.[Footnote 21] Addressing these risks requires 
that agencies ensure that adequate security controls are part of every 
new system acquisition and deployment. In the case of SASS, this means 
that FLETC needs to, among other things, adequately specify its 
security requirements in the SASS solicitation package. However, FLETC 
has not done so. For example, the SASS security requirements reference 
the Computer Security Act of 1987[Footnote 22] but do not specify 
relevant National Institute of Standards and Technology 
guidelines.[Footnote 23] These guidelines, for example, specify 
authorization and access controls. After we brought this to the 
attention of FLETC officials, they said that this was an oversight, 
that they have hired a security manager to address this area of 
concern, and that the revised solicitation package will include missing 
security requirements. If it does not, FLETC risks acquiring and 
deploying a system that will not be secure.

COTS-based System Acquisition Practices. SEI research shows that the 
market-driven capabilities embedded in commercial products and 
components necessitate that organizations not be overly requirements 
focused when acquiring COTS-based systems. Rather, SEI advocates that 
organizations plan and execute these acquisitions in a manner that 
recognizes the competing interests--and necessary tradeoffs--among 
four acquisition variables: system requirements, the organization's 
architectural environment (current and future) that the system needs to 
operate within, the cost and schedule constraints that limit the system 
acquisition, and the commercially available system products and 
components (current and future).[Footnote 24] According to SEI, 
analyzing and understanding the tradeoffs among these variables are 
vital to informed decision-making and thus should be addressed early 
and continuously throughout a project's life cycle. As such, provision 
for performing this fundamental tradeoff analysis and decision-making 
should be embedded in each acquisition function, including the ones 
that we reviewed for SASS.

To FLETC's credit, its solicitation plans and activities provide for 
employing these COTS-based system practices. For example, the 
solicitation does not prescribe a solution that is based upon 
customized, "must-have" requirements. Rather, FLETC provided 
"information-only" requirements, intended to provide an understanding 
of the nature of its scheduling process needs and environment so as to 
maximize the flexibility afforded vendors in proposing approaches to 
meet these needs.[Footnote 25] However, FLETC's SASS acquisition 
planning, requirements management, and project management efforts do 
not similarly provide for performing these COTS-based system 
acquisition practices. For example, the SASS acquisition strategy does 
not describe how FLETC will evaluate the tradeoffs among the four 
acquisition variables. Also, the SASS requirements document, although 
specifying requirements in a manner to provide prospective offerors 
flexibility, does not address the FLETC architectural environment 
(current and future) that the SASS solution will need to operate 
within. According to FLETC officials, they have not addressed this 
variable because they want the proposed SASS solution to drive this 
environment. Last, SASS project management planning does not include, 
for example, designated resources or a specific analytical approach and 
tool for performing the tradeoff analysis. Following our inquiries, 
FLETC officials told us that they have yet to incorporate these COTS-
based system best practices into each SASS acquisition function because 
they have focused on the solicitation function. However, they added 
they recognize the need to address these issues and plan to complete 
them after the solicitation package is released. They also noted that 
while they had followed the best acquisition practices as defined by 
the SEI's Software Acquisition Capability Maturity Model®, they had not 
documented these efforts, but would do so in the future. We agree that 
FLETC has followed some, but not all of these best practices. As we 
stated earlier, FLETC has not followed software acquisition risk 
management best practices. In addition, SEI has issued best practices 
for acquiring COTS-based systems that FLETC is not following. Until 
they do, the SASS acquisition will be at risk of not meeting its cost, 
schedule, and performance commitments.

FLETC Is Exploring the Use of an Existing Automated Scheduling System:

During our work, we learned that the Border Patrol Academy, in 
conjunction with INS's Immigration Officers Academy and the Customs 
Academy, were in the process of adding an automated scheduling module 
to their ACMS. The Border Patrol and Immigration Officer Academies 
currently use this system for processing non scheduling-related class 
management activities. We asked a Border Patrol Academy official, who 
brought the acquisition of the ACMS scheduling module to our attention, 
whether the module the academy was acquiring would potentially 
duplicate the scheduling functions of the proposed SASS that FLETC was 
about to acquire. The Border Patrol official said he did not know 
whether there would be any duplication between the systems. He also 
said that the Border Patrol Academy was acquiring its own system 
because it did not want to wait until FLETC acquired its system, 
suggesting that this process was moving too slowly. Furthermore, he 
said that the three academies had found an economically feasible way to 
add an automated scheduling module to ACMS.

We encouraged academy officials, and a FLETC official involved in 
FLETC's SASS acquisition, to meet and discuss the feasibility of FLETC 
using the ACMS scheduling module instead of acquiring its SASS. 
Although FLETC stated that it evaluated ACMS two years ago, these 
officials met and according to one FLETC official, agreed FLETC could, 
instead of potentially spending over $10 million in the cost of 
implementing SASS, invest considerably less to merge FLETC's 
requirements into the ACMS automated scheduling module, which is still 
under development. Separately, according to FLETC, as a result of a 
request of the DHS Chief Information Officer, a FLETC-chaired working 
group looking at capacity issues within DHS was tasked to seek input on 
the SASS from its participants. That review was to obtain input toward 
identifying an enterprise-wide solution to training scheduling for all 
of the DHS. Another FLETC official said that the FLETC-chaired working 
group was considering whether to recommend SASS as the standard 
training scheduler, or, possibly, use ACMS as the standard.

As of late July 2003, FLETC was in the process of obtaining its 
procurement and legal approvals to conduct a benchmark test on ACMS's 
scheduling module, once it is completed and tested, to determine 
whether ACMS's module could provide at least about 80 percent of the 
functions that the proposed SASS system could provide.[Footnote 26] If 
ACMS was able to provide the needed functionality, FLETC would cancel 
its SASS RFP and merge into ACMS's automated scheduling system, thus 
saving money while also meeting FLETC's considerable training 
scheduling needs of its 75 POs.

The Status of FLETC's Board of Directors Is Unclear, and DHS Has Begun 
to Provide Oversight and Guidance:

The status of FLETC's Board of Directors is unclear. Further, the 
Board's membership, roles and responsibilities, and past practices are 
not fully consistent with prevailing governance and management control 
best practices. Moreover, given its recent transition into DHS, FLETC 
needs guidance and oversight to address its transformational 
challenges. A DHS official said that DHS has recently assumed 
responsibility for FLETC and has begun to work with its officials on 
ways to address these challenges. The official also said DHS also 
recognizes the role an effective FLETC Board could play in enhancing 
governance.

The Status of the FLETC Board of Directors Is Unclear:

Prior to its most recent meeting in November 2002, FLETC's Board of 
Directors had not met for 3-½ years, according to a FLETC official. 
However, according to our review of Board minutes, the Board had not 
met for a period of 5 years prior to its November 2002 meeting (the 
last recorded meeting was held in November 1997). According to the 
agenda of its November 2002 meeting, the Board was to address, among 
other things, its roles and responsibilities, the fiscal year 2003 and 
2004 budgets, and FLETC's Master Plan. The draft minutes from that 
meeting indicate that the Board discussed, in broad terms, Justice 
Department concerns about FLETC's training services, including the 
availability of on-campus dormitory space. The Board also discussed the 
status of the FLETC MOU and the Master Plan, respectively, but did not 
discuss budget matters. Subsequent to the November meeting, a FLETC 
official who attended the meeting informed us that within the context 
of debating the Board's roles and responsibilities, the matter of 
whether the Board would continue as an ongoing entity became unclear.

In June 2003, a DHS official said an effective FLETC Board was 
important to the overall governance of FLETC activities. He also 
pointed out that DHS was in the process of determining how the training 
mission was to be managed in the new department. Issues under 
consideration include how PO training needs would be identified, where 
training would be offered, and how capacity and demand issues would be 
addressed. Determining the status, roles and responsibilities of the 
FLETC Board will be done within this context. Nevertheless, the DHS 
official acknowledged that having an effective Board would help FLETC 
to address its challenges.

Board's Membership, Roles and Responsibilities, and Past Practices Are 
Not Fully Consistent with Prevailing Governance and Management Control 
Best Practices:

Notwithstanding the uncertainty surrounding its status, the Board's 
membership, roles and responsibilities, and past practices are not 
fully consistent with prevailing best practices for governance and 
internal and management control.[Footnote 27]

Membership. Regarding the size of a board, prevailing governance best 
practices consider smaller boards to be often more cohesive and to work 
more effectively--in this regard, the FLETC Board is composed of eight 
members. Specifically, FLETC's Board presently has five term-
representatives who are voting members (one of whom has a 2-year 
rotational term) and three nonvoting members. FLETC's Director serves 
as the nonvoting Executive Secretary of the Board. As of June 2003, the 
Board's five voting members were DHS's Under Secretary for Border and 
Transportation Security, Justice's Acting Assistant Attorney General 
for Administration, the Department of the Interior's Deputy Assistant 
Attorney for Law Enforcement, the General Services Administration's 
Inspector General, and the Administrator of TSA. The three nonvoting 
members of the Board are the Office of Personnel Management's Senior 
Advisor for Learning and Knowledge, OMB's Associate Director for 
General Government Programs, and the U.S. Capitol Police Board's 
Chairman.

Regarding the composition of the Board's membership, there are two 
departures from governance best practices. First, the Director of FLETC 
is not a member of the Board, but, rather, its nonvoting Executive 
Secretary. Under governance best practices, the head of the 
organization being overseen by a board of directors is a full member of 
that board and, in fact, in many cases also serves as the chair of the 
board. There is currently a strong debate about this point. On the one 
hand, the Business Roundtable best practices view this dual role as 
serving as a bridge between an organization's management and its board, 
ensuring that they both act with a common purpose. On the other hand, 
the Conference Board Commission on the Public Trust and Private 
Enterprise[Footnote 28] recommends splitting the role of chief 
executive and chairman of the board to ensure an "appropriate balance" 
between the board and chief executive.

Second, there is not a substantial degree of independence of FLETC 
Board members from its operations. As currently configured, all Board 
members are either related to a FLETC PO (e.g., TSA and Capitol Police) 
and/or have a role in reviewing and/or setting its budget (OMB) or 
policies (Office of Personnel Management). Governance best practices 
stress that a substantial part--in most cases, a majority--of a board's 
membership should be independent of the entity it is overseeing. Such 
independence could help avoid, among other things, potential conflicts 
of interest. Further, independent board members, knowledgeable of 
information about the organization they are overseeing, can provide a 
useful perspective on the significant risks and challenges facing that 
organization and help ensure the exercise of independent judgment that 
is at the core of a board's oversight function. The 1970 FLETC MOU that 
established the Board allows for the expansion--and, implicitly, a 
change in its composition--of its membership by a majority vote of its 
members.

Roles and Responsibilities. The 1970 FLETC MOU, as amended, enumerates 
the Board's "final authority" over training policy, programs, criteria, 
and standards of FLETC for resolving matters of conflicting training 
requirements. This authority includes (1) establishing priority systems 
governing the scheduling of courses and use of training facilities; (2) 
establishing policy as to student residence requirements, leave, and 
other matters relating to student administration; (3) reviewing FLETC's 
budget as to whether it meets its mission and making budget 
recommendations to, now, the Secretary of DHS; and (4) evaluating the 
effectiveness of the overall training program. The Board also has 
authority to establish criteria for the selection of the FLETC Director 
and to approve the selection; it may also recommend the removal of the 
Director to, now, the Secretary of DHS.

Current FLETC officials have implemented the Board's roles and 
responsibilities under the MOU as pertaining only to training issues, 
and not operational issues concerning FLETC, such as the budget and the 
selection of the FLETC Director. In this regard, the current FLETC 
Director who was appointed by the Secretary of the Treasury was 
selected independently of the Board because, at the time, it was 
dormant. Under governance best practices, however, the selection and 
oversight of an organization's head is a board's paramount duty to help 
ensure competent and ethical operation. As discussed earlier, under the 
FLETC MOU, the Board has the authority to establish criteria for the 
selection of the FLETC Director and to approve the selection. 
Additional oversight responsibilities for boards include reviewing and 
monitoring the implementation of strategic plans; reviewing annual 
operating plans and budgets; advising management on significant issues 
facing the organization; reviewing and approving significant actions; 
and nominating directors, and overseeing effective governance, 
including the composition, structure, practices, and evaluation of the 
Board.

Past Practices. As discussed earlier, our review of minutes from past 
Board meetings showed that the Board did not meet for 5 years prior to 
its November 2002 meeting. The Board has not met since November 2002, 
pending a decision on its status.[Footnote 29] In this regard, FLETC's 
own MOU stipulates that the Board shall meet quarterly, and at such 
other times as may be determined by a majority of the Board or its 
presiding officer. Further, governance best practices call for boards 
to meet as frequently as needed in order for members to discharge 
properly their responsibilities. In this regard, the "typical" board of 
a large publicly traded corporation meets about eight times a year.

Other than what is broadly described in the FLETC MOU, the Board's 
functions and processes implementing its roles and responsibilities are 
not documented. According to the relevant governance best practices, it 
is important that each board review its policies and practices on 
governance matters--the standard defers the formalization of such 
policies and practices in written form to the boards themselves, 
depending on the circumstances they face. On one hand, the standard 
points out that insufficient formalization often leads to a lack of 
clarity, while on the other hand, it cautions that over-formalization 
can lead to rigidity--emphasizing form over substance. GAO and OMB 
standards for internal and management control respectively, stress the 
need for written documentation. GAO's standards for internal control 
require that an agency's policies, directives, and operating procedures 
be clearly documented and available for examination. OMB's standards 
for management control state that an organization's authority, 
responsibility, and accountability should be defined and documented.

The Board did not periodically review its structure, functions, and 
processes. According to governance best practices, boards should, from 
time to time, review their own structure, governance principles, 
composition, agenda, and processes to consider whether they are 
functioning well in view of their responsibilities and help ensure 
sound governance and oversight. GAO and OMB standards broadly suggest 
that periodic external evaluations of, among other things, an 
organization's structure and functions help ensure that they are 
responsive to changing conditions. In this regard, FLETC is facing 
significant changes in its environment--the post-September 11 surge in 
demand for its services and its transition to DHS.

DHS Has Begun to Provide Oversight and Guidance to FLETC:

DHS has the opportunity to help FLETC face its challenges during the 
current period of transformational change. DHS officials said that 
other competing priorities, such as building the organizational 
structure of the new department and addressing its role in the ongoing 
war on terrorism, did not permit them to focus extensively on providing 
policy or other guidance to FLETC about planning, scheduling, and 
governance (e.g., oversight and accountability). A DHS official said 
that the department had recently started focusing on specific FLETC 
issues. In this regard, DHS plans to begin focusing on a broad range of 
issues, including the Master Plan and the FLETC Board of Directors.

With respect to the Master Plan, the DHS officials said that in 
general, they viewed the plan as a useful document but not as the 
department's guiding plan for the future of FLETC and its facilities. 
One official said that DHS was considering a new business plan for 
FLETC, one that would make DHS "more than just a landlord" regarding 
federal law enforcement training. This official further said--and a 
FLETC official separately corroborated--that DHS's vision for FLETC 
would include expanding its authority on decisions related to federal 
law enforcement training.

Conclusions:

Overall, FLETC and DHS find themselves at a crossroads for defining and 
planning for the future of federal law enforcement training. The 
demands placed on FLETC and DHS by the new security environment facing 
the country are considerable. Yet, we note that while demand for 
training continues to surge, the fiscal year 2004 budget request for 
FLETC is about $26 million less than the fiscal year 2003 enacted 
level; the request for staffing calls for about 120 fewer permanent 
positions than those enacted for fiscal year 2003. The decline in 
resources risks exacerbating FLETC's already-strained capacity to 
provide training.

To meet the demands placed upon them, collective planning and execution 
by FLETC and its many stakeholders, and active and sustained oversight 
and guidance by DHS, are necessary to:

* achieve a proper balance between the surging demand for training and 
the necessary capacity to meet it;

* schedule vital training in an efficient and timely manner; and:

* provide for effective governance and oversight that ensures that all 
stakeholders' interests are addressed.

Despite the capacity constraints, FLETC generally received good marks 
from POs about its ability to meet their basic training needs. However, 
FLETC is facing considerable challenges in responding to the demand for 
training in a systematic manner. For example, FLETC's overall planning 
effort is essentially reactive, rather than proactive. Specifically, 
FLETC does not currently have a formal contingency plan to help guide 
management decision-making with respect to capacity planning, although 
it has developed some planning documents (i.e., its 1989 Master Plan 
with updates and the current Master Plan). Although having an updated 
Master Plan to guide short-and long-term planning is a step in the 
right direction and may help provide some guidance to DHS, the final 
draft of the plan has methodological limitations and inaccurate cost 
estimates. In addition, FLETC has taken very limited action thus far in 
planning for the use of alternative training such as off-site training 
and e-learning.

FLETC's capacity challenges are likely to be compounded during its 
transition into DHS. This transformational change for FLETC and a 
number of its POs will likely bring considerable uncertainty, as the 
new department is equally likely to redefine the POs' missions to focus 
on homeland security. The redefined mission could result in the need 
for updated training programs and modules that, in turn, would require 
new or modified training facilities. A further uncertainty involves the 
type and scale of future terrorist attacks and the response by the 
federal government. A comprehensive planning process, encompassing, 
among other things, sound methodologies and contingency planning, is 
essential to help meet the current capacity challenges facing FLETC, 
and also will help position it to meet future challenges.

FLETC faces a challenge to automate the scheduling of training for its 
75 POs. Notwithstanding its performance of certain important system 
acquisition functions, FLETC is not doing enough to ensure that it 
acquires a system that will optimally support its current and future 
mission needs. Without instituting a proactive risk management 
function, FLETC increases the risk that avoidable potential problems 
will become costly actual problems, meaning they would result in a less 
capable system being delivered late and/or over budget. Further, and 
equally important, delays in making both security and COTS-based 
acquisition best practices integral to its SASS project could 
exacerbate potential problems. Without adequately addressing both, 
FLETC increases the risk of the system not being adequately protected 
against unauthorized access and corruption, not being available when 
needed, and not performing as intended. It is important that FLETC 
address its SASS acquisition management weaknesses before the project 
advances much farther. Although FLETC is in the initial stages of 
acquiring SASS, we are encouraged that through in part our 
intervention, it is also in consultation with the Border Patrol whether 
its ACMS, with some modification, might serve FLETC scheduling needs, 
thus saving an estimated $10 million cost over 5 years, while spending 
considerably less to adopt the ACMS.

Reconvening the FLETC Board of Directors in November 2002, albeit 
briefly, was a step in the right direction; however, the Board's status 
is unclear. Given FLETC's recent transition into DHS, the Board, 
consistent with its mandate under the FLETC MOU, needs to be retained 
in order to offer sustained governance and oversight to ensure 
transparency and accountability. In this regard, governance, in the 
form of boards of directors, has the important role of overseeing 
management performance and ensuring independent and objective decision-
making. As FLETC considers revising its MOU, it has an opportunity to 
incorporate prevailing governance and internal and management control 
best practices about the functioning of the Board to help FLETC address 
its challenges and achieve transformational change.

Recommendations for Executive Action:

To address FLETC's capacity constraints and planning challenges, we 
recommend that the Secretary of Homeland Security 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;

* 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; and:

* develop plans for the use of alternative or additional law 
enforcement training campuses should circumstances limit or prohibit 
the use of available facilities.

To enable FLETC to monitor and reduce the risk associated with the 
degradation of FLETC facilities and infrastructure, we recommend that 
FLETC:

* 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 and:

* adopt a performance measurement, such as FCI, to monitor the trend of 
FLETC facilities condition and to also offer a benchmark indicator for 
comparison to industry standards.

To increase the chances of SASS success, we recommend that the 
Secretary of Homeland Security instruct the Director of FLETC to make 
proceeding with the SASS acquisition conditional upon improvements in 
SASS acquisition management activities. We further recommend that these 
improvements, at a minimum, include adding risk management as a SASS 
acquisition function and ensuring that this function provides for:

* the identification and documentation of risks;

* the categorization of risk severity based on probability of 
occurrence and potential impact;

* the development and implementation of risk mitigation strategies; 
and:

* the reporting of risk status, including progress in implementing 
mitigation strategies.

We further recommend that the improvements in SASS acquisition 
management activities should also:

* treat known risks in acquiring COTS-based systems 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;

* ensure that security is made a clear, explicit, and visible component 
of system requirements in the SASS solicitation package; and:

* 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.

To help provide sustained oversight and enhance accountability, we 
recommend that the Secretary of Homeland Security retain the FLETC 
Board of Directors. We further recommend that working with FLETC's POs, 
their parent departments and agencies, and the Board's current members, 
the Secretary of Homeland Security 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 Comments and Our Evaluation:

We provided a draft of this report to the Secretary of DHS and the 
Attorney General for comment. We received comments from the Under 
Secretary of DHS for Border and Transportation Security that are 
reprinted in appendix IV and discussed later. In addition to DHS's 
written comments, FLETC provided technical comments and clarifications, 
including updates on its SASS acquisition, which are incorporated in 
this report where appropriate. Justice did not provide formal written 
comments; the Associate Assistant Attorney General for Federal Law 
Enforcement Training submitted an email with two general comments about 
the issues of FLETC training capacity and governance, respectively.

In their comments, DHS and FLETC generally agreed with the information 
presented in the report and with our conclusions and recommendations, 
and outlined actions they either had taken or were planning to take to 
implement the recommendations. DHS noted, for example, that the issues 
related to capacity, scheduling, and governance discussed in the report 
were already being considered by the department and would be given its 
full attention. Regarding specific actions to implement our 
recommendations, FLETC said that it was developing a formal contingency 
plan to respond to future capacity constraints and choke points and to 
identify alternative or additional training assets that could help in 
this response. Also, FLETC indicated that it had taken action to 
reconstitute the Board of Directors; FLETC also indicated that it was 
taking action to determine the prospective membership, and roles and 
responsibilities of the reconstituted Board.

At the same time, FLETC expressed some concerns regarding the report. 
In its general comments, FLETC said, first, that it "strongly 
disagreed" with the report's title, asserting that it implied broader 
concerns about capacity planning and management oversight than the 
report's contents supported. We believe that the report clearly and 
exhaustively describes the challenges FLETC faces in planning for 
future capacity and articulates the importance of sustained management 
oversight of, among other things, the planning effort to help ensure 
its success, and that the report's title accurately reflects these 
challenges. Second, FLETC said that the report did not point out that 
the flow of federal law enforcement personnel was not constrained by 
training capacity, but by the inability of POs to recruit such 
personnel. We note that because it was beyond the scope of our work, 
the report did not address recruitment as a distinct issue, but did 
point out that shortfalls in POs' recruiting contributed to projected 
demand for training not materializing. We also note that the core issue 
is FLETC's ability to train those personnel who actually need to be 
trained. In this regard, the report clearly describes how FLETC's 5-
day/8-hour capacity is strained; accordingly, additional recruits would 
only serve to exacerbate FLETC's capacity challenges. Third, FLETC said 
that the report did not adequately recognize the "extraordinary 
success" of FLETC and the POs in meeting critical law enforcement 
training requirements. We believe that the report clearly recognizes 
that FLETC has been able to generally meet its POs' demands for basic 
training during a time of constrained capacity and surging demand, and 
highlights the actions FLETC has taken to accomplish this. Fourth, 
FLETC said that projected workloads (i.e., demand for training) were so 
dynamic that some of those cited in the report were already obsolete 
and urged caution in their treatment. We note that during our work we 
repeatedly corroborated--through interviews with FLETC officials and 
related documentary verification--the currency and validity of the 
projected workloads as presented in the report; further, FLETC did not 
provide us with any updated workload projections as part of its written 
comments. Fifth, FLETC said that the report implied that it was 
accountable for variables beyond its control, such as the timeliness of 
recruitment, operational needs, class cancellations, shifts in training 
strategies, and funding, all of which impact capacity planning. We 
believe that the report adequately describes these factors as 
contributing to the level of training actual attendance, and does not 
imply that FLETC is accountable for them.

In its technical comments, FLETC acknowledged that its predominantly 
manual scheduling process was time-consuming and required 
modernization. FLETC questioned, however, that automating the 
scheduling process would result in significant increases in capacity. 
We note that, first, FLETC's own Master Plan indicated that if the 
scheduling process were to be automated, capacity efficiencies would 
likely result and the plan would need to be revised, and second, 
FLETC's documentation related to the SASS acquisition indicated that 
automation would result in capacity efficiencies. In commenting on our 
use of an example to illustrate the effect of choke points, FLETC said 
that resurfacing the Charleston campus' emergency response driving 
range did not result in the cancellation of any Border Patrol classes. 
We note that a FLETC official cited the resurfacing as a specific 
example of a capacity-constraining choke point that resulted in the 
cancellation of three Border Patrol classes, which have not been 
rescheduled. In commenting on the possible use of ACMS as an 
alternative to its proposed acquisition of SASS, FLETC said, among 
other things, that the evaluation of ACMS's scheduling component was in 
the preliminary stages. Accordingly, it was too early to tell whether 
ACMS's scheduling component would meet FLETC's requirements, and 
whether significant cost savings would be realized. We note that a 
FLETC official involved in the evaluation of ACMS, in responding to our 
questions, provided a written response, stating that if ACMS provided 
about 80 percent of the functionality sought by FLETC it could be 
adopted as the scheduling system at considerably less cost than the 
estimated $10 million cost of SASS.

In its comments, regarding training capacity, Justice stated that if 
FLETC's Glynco campus (as well as the Charleston) campus were used to 
provide basic training and the Artesia Campus was used to provide 
advanced and specialized training, then FLETC would be able to achieve 
a better balance in the utilization of its campuses and mitigate the 
capacity strains it is experiencing. Regarding governance, Justice 
stated that the FLETC Board of Directors would work well as currently 
configured, if it were allowed to function under its original mandate 
as defined in the MOU that created FLETC.

We are sending copies of this report to the Chairmen and Ranking 
Minority Members of the Senate and House Committees on Appropriations. 
In addition, we are sending copies to the Secretaries of Homeland 
Security and the Interior; the Attorney General of the United States; 
and the Director of OMB. We will also make copies available to others 
on request. In addition, the report will be available at no charge on 
GAO's Web site at http://www.gao.gov.

If you have any questions about this report or wish to discuss it 
further, please contact me at (202) 512-8777 or Seto J. Bagdoyan, 
Assistant Director, at (202) 512-8658. Key contributors to this report 
are listed in appendix V.

Richard M. Stana 
Director, Homeland Security and Justice Issues:

Signed by Richard M. Stana: 

[End of section]

Appendix I: Objectives, Scope, and Methodology:

Given concerns about whether the Federal Law Enforcement Training 
Center (FLETC) can continue to meet the rising training demands of its 
75 federal partner organizations (PO) following the September 11th 
attacks, the House Appropriations Committee asked us to develop 
information on the following topics:

* The extent to which FLETC is able to meet the current and projected 
demand for training, how FLETC is planning to meet the demand, and the 
associated costs and the extent to which FLETC coordinates or uses 
existing, non-FLETC government training assets, and any associated 
costs.

* FLETC's current organizational structures and processes for 
coordinating and scheduling training activities and whether FLETC plans 
any changes to these structures and processes.

* FLETC's oversight and governance structures and the extent to which 
these structures are providing guidance to FLETC as it addresses its 
capacity and planning challenges during a period of transformational 
change.

Overall, to develop the information in this report, we conducted our 
work at FLETC, the Office of Management and Budget (OMB), Clark Nexsen 
(the architectural/engineering firm retained by FLETC to develop a 
Master Plan for facilities development at FLETC-owned campuses), and at 
the following selected departments and agencies engaged in federal law 
enforcement training.

* The Department of Justice (the Immigration & Naturalization Service, 
the Border Patrol, the Federal Bureau of Prisons, and the U.S. Marshals 
Service),

* The Department of the Treasury (the Bureau of Alcohol, Tobacco, 
Firearms, and Explosives, the Internal Revenue Service, the U.S. 
Customs Service, and the U.S. Secret Service), and:

* The Department of Transportation (the Transportation Security 
Administration, the Federal Air Marshals, and the U.S. Coast Guard).

The Department of Homeland Security (DHS) was created during our work. 
Many of the FLETC POs--identified above as components of other 
departments--moved to DHS' temporary headquarters after January 24, 
2003--see appendix II for a listing of the POs now in DHS. We 
interviewed officials from DHS, including the Director of Operations 
for Border and Transportation Security. We also interviewed FLETC and 
PO officials in Washington, D.C., and at each of the four domestic 
training campuses where FLETC POs train: Brunswick, Ga. (commonly 
referred to as "Glynco," for Glynn County); Artesia, N. Mex.; 
Charleston, S.C.; and Cheltenham, Md. We reviewed applicable public 
laws and regulations; memorandums of understanding (MOU); best 
practices and guidelines related to facilities and information 
technology acquisition, governance, and management and internal 
control; various drafts of the Master Plan, and supporting 
documentation; budget submissions and justifications; training 
curriculum and accreditation documents; and various reports related to 
FLETC and federal law enforcement training.

We conducted our work between May 2002 and June 2003 in accordance with 
generally accepted government auditing standards. We requested comments 
on a draft of this report from the Secretary of Homeland Security and 
the Attorney General. (See appendix IV for DHS' comments.):

Capacity, Planning, and Coordination:

To determine the extent to which FLETC is able to meet the current and 
projected demand for training, how FLETC is planning to meet the 
demand, and the associated costs; and the extent to which FLETC 
coordinates or uses existing, non-FLETC government training assets, and 
any associated costs, we interviewed FLETC, OMB, Clark Nexsen, and 
department and component agency officials regarding specific training 
demand and availability issues, including agency training projections 
and the factors influencing these projections, physical and human 
resource "choke points" (or training obstacles) at the training 
campuses, agency satisfaction levels with the current delivery of 
training services, and the resources needed to meet future demands for 
training. We did not evaluate the quality or the effectiveness of the 
training programs nor reviewed how agencies assessed the training 
provided. We also reviewed the following documents obtained from FLETC 
and other officials:

* Aggregate agency training projections for both basic and advanced 
courses for fiscal years 1997-2008 and FLETC's adjustments to some of 
these projections.

* Agency training projections for FLETC participants interviewed during 
our site visits.

* The actual student attendance statistics at the FLETC training 
campuses for fiscal years 1983-2002.

* The 35-, 65-, 90-percent, and final draft submittals of FLETC's 
Master Plan.

* The June 1989 Master Plan and its April 1996 update.

* The latest FLETC 5-year construction plan allocation.

* FLETC, Treasury, and DHS budget documents and related justifications.

* FLETC research and development studies on particular training issues.

In addition, we reviewed the extent to which FLETC's current 
infrastructure was supporting the delivery of training at each of the 
campuses and whether infrastructure (e.g., water supply, sewage, and 
power grid) concerns were being addressed in FLETC's Master Plan. We 
did this by reviewing relevant sections of the plan, conducting campus 
visits and observing infrastructure, and interviewing facilities 
management officials. We also determined whether Master Plan proposals 
regarding infrastructure were aligned with FLETC's Strategic Plan and 
recent budget enactments and requests. Further, we determined whether 
FLETC has any contingency plans to address potential sudden surges in 
demand for training (e.g., Border Patrol hiring in the mid-1990s and 
the recent PO training ramp-up following the September 11th attacks).

Scheduling and Coordination of Training Activities:

To determine FLETC's current organizational structures and processes 
for coordinating and scheduling training activities, and whether FLETC 
plans any changes to these structures and processes, we interviewed 
FLETC and PO officials in Washington, D.C., and at each of the four 
training campuses regarding their perceptions of the training programs 
and their views about FLETC's ability to schedule and coordinate 
training activities. In addition, we interviewed FLETC officials about 
the status of the computer automation process for scheduling training. 
We observed how FLETC staff perform their scheduling activities. Also, 
we reviewed the following documents:

* Provisions of the 1970 Treasury order creating FLETC.

* The Treasury and FLETC Strategic Plans of FY2000-2005, which identify 
FLETC's latest mission statements, goals, and objectives.

* FLETC's organizational chart.

* FLETC's request for proposals on computer automation.

* Records of interviews conducted by Clark Nexsen regarding POs' 
training needs.

Further, we reviewed FLETC's MOUs with several of the larger agencies 
to obtain an understanding of FLETC's formal management and 
coordination responsibilities with respect to the POs.

To determine whether FLETC has effective controls in place for 
acquiring a new student administration and scheduling system (SASS) by 
focusing on whether the center was performing five key acquisition 
management functions: acquisition planning, solicitation, requirements 
management, project management, and risk management. We reviewed these 
areas because they are critical to successfully acquiring systems. 
These practices were derived from the work and research of Carnegie 
Mellon University's Software Engineering Institute (SEI).[Footnote 30] 
In addition, we reviewed whether FLETC was incorporating SEI best 
practices for acquiring COTS-based systems[Footnote 31] in these five 
functions. In conducting our review, we interviewed SASS project 
officials and other FLETC staff involved in the acquisition, including 
staff from the information systems division, the procurement division, 
legal counsel, and the training analysis and coordination division. We 
also interviewed potential SASS users from two FLETC training 
divisions.

To determine whether FLETC was performing these acquisition management 
functions, we compared the center's actions to those defined by SEI as 
key in establishing at least basic acquisition management controls for 
the five functions. In addition, we compared the center's actions to 
those SEI has redefined as being key to effectively leveraging the 
COTS-based systems. To document FLETC's actions, in addition to 
interviewing staff, we reviewed documentation including SASS program 
documentation such as contractor reports; the SASS solicitation 
package, including the SASS software and database requirements; 
training model schedule templates; the 2002 master class schedule; 
information technology modernization 2004 capital asset plan; National 
Institute of Standards and Technology security publications; and fiscal 
year 2000 congressional reports.

Governance and Oversight Structure and Guidance:

To determine FLETC's oversight and governance structures and the extent 
to which these structures are providing guidance to FLETC as it 
addresses its capacity and planning challenges during a period of 
transformational change, we reviewed FLETC's 1970 MOU establishing, 
among other things, its Board of Directors, and governance and 
management and internal control best practices--these were the Business 
Roundtable's 2002 Principles of Corporate Governance and a 2003 report 
by the Conference Board's Commission on Public Trust and Private 
Enterprise titled Findings and Recommendations; and GAO's 1999 
Standards for Internal Control in the Federal Government and OMB's 1995 
Circular No. A-123, Management Accountability and Control. We drew from 
our August 2002 report on the governance of the U.S. Capitol Police, 
"Information on Capitol Police Board Roles and Responsibilities, 
Operations, and Alternative Structures." We discussed governance issues 
in general and the Board in particular, including its mission, roles 
and responsibilities, current and past practices, and its status with 
cognizant FLETC and DHS officials. We compared the governance and 
management and internal control best practices with those of the Board 
to determine the extent to which they were consistent.

[End of section]

Appendix II: FLETC's 75 Partner Organizations:

Following is a listing of the current (as of June 2003) Federal Law 
Enforcement Training Center (FLETC) partner organizations (PO).

Agriculture:

Forest Service Office of Inspector General:

Amtrak:

Northeast Corridor Police:

Central Intelligence Agency:

Office of Inspector General Office of Security:

Commerce:

National Institute of Standards and Technology National Marine 
Fisheries Service Bureau of Industry and Security Office of Inspector 
General Office of Security:

Defense:

Pentagon Force Protection Agency Naval Criminal Investigative Service 
National Security Agency Defense Criminal Investigative Service Office 
of Inspector General Air Force Office of Special Investigations:

Education:

Office of Inspector General:

Energy:

Office of Inspector General:

Environmental Protection Agency:

Office of Criminal Investigations:

Federal Deposit Insurance Corporation:

Office of Inspector General:

General Services Administration:

Office of Inspector General:

Health and Human Services:

Food and Drug Administration National Institutes of Health Office of 
Inspector General:

Homeland Security:

Customs and Border Protection (includes Customs, INS, and Agriculture's 
Animal and Plant Health Quarantine inspectors, and the Border Patrol, a 
division of CBP) 

Federal Emergency Management Agency 

Immigration and Customs Enforcement (includes Federal Protective 
Service) 

Transportation Security Administration 

U.S. Coast Guard 

U.S. Secret Service 

Office of Inspector General:

Housing and Urban Development:

Office of Inspector General:

Interior:

Bureau of Indian Affairs; Bureau of Land Management; Bureau of 
Reclamation; National Park Service; U.S. Park Police; Office of 
Inspector General; Office of Surface Mining, Reclamation and 
Enforcement; U.S. Fish and Wildlife Service:

Justice:

Bureau of Alcohol, Tobacco, Firearms and Explosives; Bureau of Prisons; 
Drug Enforcement Administration; Office of Inspector General; U.S. 
Marshals Service:

Labor:

Office of Inspector General:

National Aeronautics and Space Administration:

Office of Inspector General:

Nuclear Regulatory Commission:

Office of Inspector General:

Office of Personnel Management:

Office of Inspector General:

Railroad Retirement Board:

Office of Inspector General:

Small Business Administration:

Office of Inspector General:

Smithsonian:

National Zoological Park Office of Protection Services:

Social Security Administration:

Office of Inspector General:

State:

Agency for International Development - Office of Inspector General; 
Bureau of Diplomatic Security; Department of State--Office of Inspector 
General:

Supreme Court:

Supreme Court Police:

Tennessee Valley Authority:

TVA Police Office of Inspector General:

Transportation:

Office of Inspector General:

Treasury:

Bureau of Engraving and Printing; Financial Crimes Enforcement Network; 
Internal Revenue Service; Office of Inspector General; Treasury 
Inspector General for Tax Administration; U.S. Mint:

U.S. Congress:

Government Printing Office--Office of Security; Library of Congress 
Police; Government Printing Office--Office of Inspector General; U.S. 
Capitol Police:

U.S. Postal Service:

Office of Inspector General Postal Inspection Service--Postal Police:

Veterans Affairs:

Office of Inspector General:

[End of section]

Appendix III: Training Programs and Seminars Provided by FLETC:

FLETC offers eight variations of training programs and seminars. A 
priority system is employed to fund, schedule, and deliver these 
training programs. FLETC basic training programs are delivered in two 
formats: Center Basic followed by an Agency-Specific Basic either on or 
off site, or a single Center Integrated Basic program that combines the 
Center Basic and Agency-Specific Basic concepts into one program. A 
Center Integrated Basic program is granted for those agencies that have 
such a unique mission that their training requirements cannot be met in 
a Center Basic program. The categories of training, in priority order, 
are:

1. Center Basic--law enforcement entry-level recruit training designed 
to meet the training needs for multiple agencies. The job tasks and 
course content are identified and validated by the participating 
agencies and 100 percent of the training is managed and delivered 
through FLETC staffing resources. These staffing resources are 
comprised of approximately 50 percent of FLETC's permanent staff and 50 
percent of Partner Organization staff. The three Center Basic programs 
offered by FLETC are the Criminal Investigator Training Program, the 
Mixed Basic Police Training Program, and the Natural Resource Police 
Training Program.

2. Center Integrated Basic---law enforcement entry-level training 
designed to meet the mission-specific or unique requirements of a 
single agency. The job tasks and course content are identified and 
validated by the user agency and the training is managed and delivered 
through the combined efforts of the agency and FLETC staffing 
resources. Like the Center Basic and Agency-Specific Basic, the Center 
Integrated Basic provides both the foundational knowledge, skills, and 
abilities and the specific mission requirements for that agency. FLETC 
is responsible for teaching the common basic recruit training and the 
agency is responsible for teaching the mission-specific courses. FLETC 
can and does provide instructional resources when the agency does not 
have sufficient staffing. FLETC currently offers 10 Center Integrated 
Basic programs. Some examples are the United States Border Patrol 
Integrated, the United States Park Police Integrated, and the United 
States Marshal Service Integrated.

3. Agency-Specific Basic--law enforcement entry-level training that 
supplements and follows Center Basic training programs for individual 
agencies. The job tasks and course content are identified by the user 
agency and the training is managed and delivered by agency staffing 
resources. However, FLETC does provide staffing resources as requested. 
The program builds on the foundational knowledge, skills, and abilities 
that were developed in the Center Basic program and focuses on the 
specific mission requirements of that law enforcement agency.

4. Center Advanced--center advanced training is developed, managed, and 
delivered through FLETC staffing resources by the individual training 
divisions to meet a specific or specialized need for instructor or 
mission-specific training. These programs address the specialized and 
instructor needs of the various Partner Organizations. Some examples of 
Center Advanced training include the Firearms Instructor Training 
Program, the Technical Investigative Equipment Training Program, and 
the Weapons of Mass Destruction Training Program.

5. Agency Advanced--agency advanced training is developed, managed, and 
delivered by the user agency and addresses the specialized training 
requirements for that agency. These training courses are generally 
conducted for mid-and senior-level law enforcement personnel.

6. State, local, and international training--state, local, and 
international training is primarily delivered on an off-site basis. 
FLETC collaborates with these entities to deliver a variety of training 
programs and in support of various law enforcement initiatives.

7. Agencies without Partner Organization status participate in training 
in a space available basis. Training programs are developed and 
delivered as appropriate.

8. Conferences, seminars, and non law enforcement training are also 
provided.

[End of section]

Appendix IV: Comments from the Department of Homeland Security:

U.S. Department of Homeland Security:

July 18, 2003:

Mr. Richard M. Stana:

Director, Homeland Security Justice Issues US Government Accounting 
Office Washington, DC 20548:

Dear Mr. Stana:

Thank you for the opportunity to review the draft Government Accounting 
Office (GAO) report 03-736, dated July 3, 2003, about capacity issues 
and related matters at the Federal Law Enforcement Training Center 
(FLETC) before it is issued in final form.

It is important to point out the U. S. Department of Homeland Security 
(DHS) and, particularly, the Border Transportation and Security 
Directorate (BTS), view FLETC as having a "flagship" role in the 
training being provided to all law enforcement personnel of the 
Department, and indeed, to other FLETC customer agencies of government. 
Their role already has been a stabilizing force in marshalling the 
entire law enforcement training efforts of the Department during a 
highly active transition period and formation of a new training 
approach to homeland security's daunting mission. To their credit, 
FLETC has continued to provide training services to its interagency 
customers during an extraordinary period of explosive growth and 
dynamic change for federal law enforcement in the post September 11, 
2001 period. The flexibility shown by FLETC in partnering with the 
Transportation Security Administration (TSA) to quickly complete the 
training of thousands of Federal Air Marshals to meet time sensitive 
deadlines is but one demonstration of the positive impact FLETC has on 
law enforcement training.

There are, to be certain, many issues to be addressed by this 
Department in its stewardship of consolidated law enforcement training 
under FLETC's auspices. The major questions of capacity, scheduling, 
and governance of training raised in this GAO report are appropriate 
and justified. Some of these issues already were being considered and 
all areas discussed will be given our full attention.

While there is room for improvement, it is very satisfying to note that 
the respected reputation of FLETC for providing quality training for 
such a diverse federal law enforcement community is not disputed nor 
seriously impaired by the issues mentioned in the report.

Enclosed are the specific comments to this report that have been 
compiled by FLETC. The Department endorses these comments and pledges 
to work with FLEW in carrying out the recommendations and responses 
presented.

Sincerely,

Asa Hutchinson 
Undersecretary for Border and Transportation:

Signed by Asa Hutchinson: 

Enclosure:

THE FEDERAL LAW ENFORCEMENT TRAINING CENTER COMMENTS TO THE GOVERNMENT 
ACCOUNTING OFFICE REPORT 03-736:

Listed below are the comments by the Federal Law Enforcement Training 
Center (FLETC) regarding the draft Government Accounting Office (GAO) 
report (03-736), dated July 3, 2003, and entitled "Capacity Planning 
and Management Oversight Need Improvement." The FLETC's response is 
divided into three sections: General Comments, Responses to 
Recommendations for Executive Action, and Errata (specific suggested 
content changes to accurately reflect descriptive portions of the 
report from FLETC's standpoint). We appreciate the opportunity to 
comment on the proposed report and extend our acknowledgement to the 
GAO staff for their courteous efforts.

I. General Comments: FLETC does not disagree materially with the GAO 
recommendations for executive action contained in the draft report. The 
report and its findings are valued and will be afforded full 
consideration and implementation as indicated in our comments.

- FLETC strongly disagrees with the styling of the report by GAO 
entitled "Capacity Planning and Management Oversight Need Improvement." 
This title implies a much broader based concern than is actually the 
case or is supported in the report itself.

- FLETC believes the report fails to point out that the current 
constraint to the flow of new federal law enforcement officers and 
agents is not the training system. The constraint is recruitment. In a 
typical fiscal year, the FLETC's Partner Organizations (PO) are able to 
supply only about 75% of the trainees they project as requiring 
training. Since its inception over 30 years ago, the FLETC has 
successfully accommodated 100% of the actual basic law enforcement 
training requirement presented by its partners-even in today's 
challenging "surge" workload conditions.

- FLETC believes the study fails to adequately recognize the 
extraordinary success of the FLETC and its partners in dealing with a 
national exigency and meeting critical law enforcement training 
requirements. From our perspective, the key measure is the number of 
qualified officers and agents produced, and the timeliness of their 
deployment.

- The FLETC has graduated over 100,000 officers and agents since 
September 11, 2001; and the accelerated pace of training achieved via 
the 6-day training week and other capacity enhancements have resulted 
in the on-the-job presence of several thousand additional qualified law 
enforcement personnel for America on a reliable, but quickened pace.

- FLETC is perplexed that laudatory information in earlier drafts of the 
report (pertaining to law enforcement training accreditation activities 
and counter-terrorism:

training, for example) has been excised from the final draft. These are 
impressive leadership areas that reflect positively upon FLETC and its 
partners.

- During the period that GAO studied FLETC, the organization and the 
needs of its partners evolved continuously. Major changes in management 
structure and leadership were made, the organization was transferred to 
the U.S. Department of Homeland Security (DHS), and constant 
adjustments in key processes (e.g. scheduling) were made to better meet 
the partners' needs. Specific to scheduling and capacity utilization, 
the processes described in the report have changed and the responsible 
organization has been reconfigured. Projected workloads are so dynamic 
that the information cited in the report in some instances will already 
be obsolete when published. FLETC therefore urges caution to all 
readers in relying on the specific numbers or process descriptions in 
the report.

- This report implies FLETC is accountable for variables which are 
beyond its control, such as timely recruitment, operational needs, 
class cancellations, shifts in training strategies, and funding 
considerations, all of which seriously impact capacity planning.

II. Responses to Recommendations for Executive Action:

Capacity Constraints and Planning:

- 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.

Concur. A contingency planning team is currently working to develop a 
formal contingency plan.

- Consider alternative approaches to estimating future facility 
construction needs (in the Master Plan), including (a) specification of 
a range of training workload scenarios, and, (b) after consultation 
with experts, application of risk analysis techniques.

FLETC will consider alternative approaches and will examine the 
application of risk analysis techniques. Consultation with experts will 
be conducted as needs and resources dictate/permit.

- Develop plans for the use of alternative or additional law enforcement 
training campuses should circumstances limit or prohibit the use of 
available facilities.

Concur. FLETC's Director is presently chairing a DHS/BTS working group 
that is addressing this issue, as well as broader training facility 
optimization issues. The contingency plan will also address the use of 
alternative or additional law enforcement campuses. FLETC already 
comprises a significant majority of the total federal facilities 
capacity.

Student Administration and Scheduling System (SASS):

[NOTE: The Information Technology Modernization Plan (of which the SASS 
is a component) has not yet been funded. Therefore, FLETC activities to 
date in this context have been necessarily limited. The comments below 
are offered with this reality in mind.]

* Identify and document risks.

* Categorize risk severity based on probability of occurrence and 
potential impact.

* Develop and implement risk management strategies.

* Develop [reporting mechanism] on risk status, including progress in 
implementing mitigation strategies.

* Treat known risks in acquiring COTS-based systems 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.

The FLETC developed a Project Risk Assessment Plan for the SASS in May 
2003. This plan is a "living" document and will be modified as needed.

* Ensure that security is made a clear, explicit, and visible component 
of system requirements in the SASS solicitation package.

The FLETC is in the process of addressing the security concerns with 
the SASS. FLETC is using the National Institute of Standards and 
Technology Guidelines to ensure that adequate security is provided in 
the SASS. FLETC has hired a Security Manager to address this area of 
concern and who will be working with the project manager to ensure we 
comply with all security requirements.

* 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 commercially available system 
products and components.

The FLETC followed the best practices in the software acquisition 
process as defined by the Software Acquisition Capability Maturity 
Model (SA-CMM). This process was not documented but will be in the 
future.

Monitor and Reduce Risk-FLETC Facilities and Infrastructure:

- 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.

FLETC conducts periodic facility assessments and tracks maintenance and 
repair progress. However, in light of this recommendation, FLETC will 
examine these processes/programs to identify required enhancements.

- Adopt a performance measurement, such as FCI, to monitor the trend of 
FLEW facilities conditions and to also offer a benchmark indicator for 
comparison to industry standards.

Concur. The Facilities Condition Index (FCI) will be examined as an 
additional tool to monitor the condition of FLETC facilities.

Retain the FLEW Board of Directors.

Concur. A move is already underway to reconstitute the Board and a 
meeting is projected for August 2003.

- Review the Board's mission, roles and responsibilities, and function 
and practices to better align them with prevailing standards of 
governance and management control. Concur. FLETC already has under 
development an overview of prospective duties and responsibilities of a 
reconstituted Board of Directors. This will include 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 on its roles, responsibilities and membership.

[See PDF for image]

[End of figure]

Cheltenham Comments: 

Pages(s) Highlights:

4, 10, etc.: Generally, all comments regarding the Cheltenham campus 
being upgraded and not fully operational are correct. However, what is 
not correct is the reference on page 4 "(the US Capitol Police is 
conducting limited classroom training" when, in fact, the US Capitol 
Police are using the Cheltenham facility for vehicle traffic stop 
training, patrol practical exercises and physical training on several 
Cheltenham campus venues.

A second GAO error was found on page 10; paragraph I, which states 
"Currently, the US Capitol Police is the only PO using the campus." In 
fact, there are over 12 federal, state and local law enforcement 
agencies utilizing Cheltenham classroom space, the tactical village and 
road system for agency specific training. As early as February 2002, 
the renovation of several Cheltenham buildings enabled the FLETC to 
provide an early return on the government's investment by making 
available to area federal, state and local law enforcement agencies 
classroom space and tactical areas concurrent with on-going master plan 
construction.

Since then, Cheltenham has averaged 1,500 to 2,000 law enforcement 
officers attending training at the Cheltenham site per month. During 
FY02, Cheltenham provided training venues for over I2 law enforcement 
agencies, which represented 1,193 student weeks. Thus far in FY 03, as 
of June 30, 2003, Cheltenham has hosted I7,013 federal, state and local 
law enforcement officers for a total of 547.2 student weeks of 
training.

On page 26 of the report, footnote I7 is inaccurate. Although the US 
Capitol Police conducts their agency specific and advanced training in 
FLETC assigned buildings at the Cheltenham site, they have agreed in a 
Memorandum of Agreement with the FLETC to report their daily student 
throughput to the FLETC Cheltenham Scheduling Office, as well as 
schedule use of the FLETC Cheltenham buildings and grounds.

19: Text cites Cheltenham infrastructure problems as evidence of the 
effects of deferred maintenance driven by law enforcement training 
workload. Not a valid example-FLETC inherited the Navy facilities in 
200I, has not yet substantially trained there, and is developing the 
site.

12: Text suggests that Cheltenham's contribution to FLETC's throughput 
capacity is limited, while it is being developed. This is misleading. 
Current Congressional restrictions on the use of that facility will 
limit its predominate use to requalification activities.

That fact is salient in the context because the GAO report (and all of 
the capacity figures contained within it) address only basic and 
advanced training-not requalification activities.

Workload Projections: 

13: Text asserts TSA projected 49,000 student Projections weeks of 
flight deck officer training. Incorrect. The projections (and 
subsequent cancellations) were predominantly for airport security 
officer training:

13,16: The chart used to depict projected workload is misleading. It 
needs to be balanced with actual workload data (with the exception of 
a large amount of unprojected training conducted in 2002, actual 
training conducted in a fiscal year typically amounts to 
approximately 75% of the projection). The chart is also obsolete, using 
inflated workload projections for FY's 2003 and 2004.

Consolidated Training Economics:

2: Text suggests that most "economies of scale" savings accruing 
from FLEW operation are related to student per diem costs. Not true. 
Per Office of Management and Budget, consolidated training drives 
significant cost avoidance by negating the need for duplicative and 
redundant training facilities and shared staff and expertise.

Training Quality; 2,12: 

Text cites quotations and concerns about "relevance, quality, and 
timeliness" of FLETC training in the current "surge" environment. All 
available evidence (e.g. graduation rates and test scores) demonstrates 
that there are no significant differences.

Deferral of Advanced; 4,18: 

Text suggests that the FLETC cancelled 
PO's advanced training to meet basic training needs. Substantially 
untrue. A few (5%) advanced classes were rescheduled within the FY.

Use of Alternative Training Assets: 5, 12:

Text asserts that FLETC does not routinely employ alternative 
training assets. Not true. The FLETC routinely conducts advanced 
and state and local training at export sites around the country; and is 
responsible for the development and provision of distributed learning 
alternatives when appropriate.

Inefficient Scheduling Process: 5: 

Text asserts that FLETC's current (partially manual) scheduling 
process does not make efficient use of training facilities. Not true. 
The process is laborious, time-consuming, and requires modernization. 
However, it is injudicious to suggest that automation of the 
process in itself will result in a significant increase in throughput 
capacity.

27: Text asserts that three classes must sit idle while a fourth class 
trains on the driving range. This is manifestly untrue. Neither the 
FLETC nor its partners would tolerate this occurring on a regular 
basis.

Contingency Planning: 

12: Text implies that FLETC is unable to react to 
mission exigencies because it lacks a formal contingency plan. While 
the FLETC has not yet published a plan to cover all possible mission 
contingencies, it must be observed that current (and successfully) 
FLETC operations are being conducted to meet all PO requirements in a 
highly dynamic environment.

Charleston: 

15: Text appears to suggest (as an illustration of the effect 
of choke points?) that the resurfacing of the Charleston emergency 
response range negatively impacted FY 2003 USBP training throughput. 
Not true. USBP training throughput (I00% of actual demand) would have 
been the same whether or not the range was resurfaced.

Basic Training Needs: 

18: Text (and the title of the section) says that 
FLETC has "generally" met PO basic training needs. FLETC has meet I00% 
of actual basic training needs since its inception, even throughout the 
"surge" workload periods following the events of 9/11. No projected 
basic training has been deferred or cancelled by FLETC.

18,19: Text asserts that a former Treasury PO was obliged to defer 
basic training for 168 agents due to FLETC capacity constraints. The 
actual last-minute (unprojected) agency request was for 240 students. 
Some were accommodated immediately, and the remaining students were 
provided training slots in the following fiscal quarter. This 
performance is really a demonstration of 
flexibility and responsiveness. The FLETC scheduled all of these I1 
week programs (2,640 unprojected student weeks) to commence within 60 
days of the unexpected request.

Advanced: 

18: Text quotes a May 2002 internal Justice Department Training 
Needs report that an agency was obliged to "cancel" all of its advanced 
training due to lack of space at FLETC. Substantially untrue. The 
agency was asked to shift its advanced training within the fiscal year, 
which it declined to do. Adjustments for training requests are a matter 
of routine business. In most instances, FLETC and the impacted partner 
agency work collaboratively and satisfactorily to make adjustments.

SASS:

27,35: Text refers consistently to a 
Statement of Work (SOW). FLETC is using a Statement of Objectives in 
the acquisition of the Student Administration and Scheduling System 
(SASS) not a SOW. As such we are asking industry to tell us what the 
best system is and what technology to use.

Text asserts that FLETC has not evaluated the Academy Class Management 
System (ACMS). FLETC examined the ACMS two years ago and again 
evaluated for the present purpose in June 2003. This system is not 
complete. The scheduling component is still in the development state. 
An operating version of the system is not yet available. We are 
requesting that USBP provide us copies of the project plan, risk 
assessment, implementation plan, security plan and cost figures to 
date. Once this information is furnished and the module is completed 
and tested we can further evaluate this product. This product is a 
proprietary system and may be costly and difficult to replace in the 
future. The system:

will also be viewed in terms of whether it will accomplish other 
desired deliverables specific to FLETC. It is far too early to suggest 
what, if any, significant cost savings can be realized by using the 
ACMS. However, FLETC will remain vigilant to determine if any other 
automation approach is warranted consideration.

[End of section]

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Richard M. Stana (202) 512-8777 Seto J. Bagdoyan (202) 512-8658:

Staff Acknowledgments:

In addition to those named above, the following teams and individuals 
contributed to this report: Wendy C. Simkalo, Jared Hermalin, Nettie 
Richards, Elizabeth Lessmann, Grace A. Coleman, Brenda Rabinowitz, R. 
Rochelle Burns, Kim Hutchens, Homeland Security and Justice; Terrell 
Dorn, Physical Infrastructure; Carl L. Higginbotham, Dave Hinchman, 
Information Technology; Susan Ragland, K. Scott Derrick, Trina Lewis, 
Strategic Issues; Kenneth Bombara, Leo Barbour, Donna L. Miller, Evan 
Gilman, Applied Research & Methodology; Jan B. Montgomery, Geoffrey 
Hamilton, General Counsel; Susan Conlon, Shirley A. Perry, Product 
Assistance Group.



FOOTNOTES

[1] FLETC transferred to DHS on March 1, 2003, pursuant to the Homeland 
Security Act of 2002 (P.L. 107-296, 116 Stat. 2135). Previously, FLETC 
was part of the Enforcement Division of the Department of the Treasury.

[2] It should be noted that not all federal law enforcement agencies 
receive their training at FLETC. For example, the Federal Bureau of 
Investigation and the Drug Enforcement Administration have their own 
training facilities in Quantico, Va.

[3] For this report, capacity is defined as the resources required, 
such as instructors, facilities, and equipment, to achieve the optimum 
level of training. Its measurement depends upon the following factors: 
type of operation schedule (e.g., 5-day/8-hour schedule), the campus 
(e.g., Glynco), the time frame (e.g., a given fiscal year), and special 
considerations (e.g., changes in training priority, mission, or 
policy).

[4] On March 1, 2003, the border protection functions of the Border 
Patrol, and the border protection responsibilities of certain other 
agencies, such as the U.S. Customs Service and INS, were transferred to 
the Bureau of Customs and Border Protection within DHS. Since they each 
have their own training programs and academies at FLETC campuses, we 
use the terms Border Patrol, Customs, and INS to identify these 
agencies throughout this report.

[5] The firm, Clark Nexsen, Architecture and Engineering, was retained 
to develop an updated Master Plan and assist in establishing a strategy 
to analyze existing facilities and programs and handle future growth.

[6] The POs who expressed their opinions to us about the impact of the 
capacity constraints on their personnel were, at the time of our 
meetings, still part of the Department of Justice. On March 1, 2003, 
most of these POs moved to DHS.

[7] Managing project risk means proactively identifying facts and 
circumstances that increase the probability of failing to meet project 
commitments and taking steps to prevent this from occurring.

[8] However, according to our review of Board minutes, the Board did 
not meet for a period of 5 years (from November 1997 to November 2002).

[9] "Student week" is the statistical measure of capacity for training; 
FLETC has defined a student week as 5 days of training for one student. 
For example, if 100 students receive training during a fiscal year, of 
which 25 receive 3 weeks of training, 40 receive 6 weeks of training, 
and the remaining 35 receive 8 weeks of training, the campus would be 
providing 595 student weeks of training during that fiscal year [(25 X 
3) + (40 X 6) + (35 X 8) = 595].

[10] FLETC also has oversight responsibility on behalf of DHS for the 
International Law Enforcement Academy at Gabarone, Botswana.

[11] Department of Defense Appropriations Act, 2003 (P.L 107-248, 116 
Stat. 1519 (2002)).

[12] Consolidated Appropriations Resolution, 2003 (P.L. 108-7, 117 
Stat. (2003)).

[13] FLETC uses PO projections of demand for training as part of its 
capacity planning. In March/April of each year, POs submit to FLETC 
their projections for training. These projections are generally a 
function of the need for personnel and expected funding levels. In June 
of each year, FLETC, in consultation with POs, adjusts the projections, 
in recent years by less than 5 percent. In addition to the projections 
they submit, throughout the year, POs may submit requests to add, 
defer, or cancel classes.

[14] National Research Council, "Stewardship of Federal Facilities--A 
Proactive Strategy for Managing the Nation's Public Assets," 
(Washington, D.C.: National Academy Press, 1998).

[15] Ibid.

[16] There were, in the past, some congressional committee expectations 
that the temporary training facility at Charleston would close. In 
1998, for example, a House Appropriations Committee report, citing a 
commitment to the principle of consolidated federal law enforcement 
training through FLETC, expressed an expectation that the 
administration would strive to close the temporary training facility at 
Charleston. H.R. Rep. No. 105-592 (1998). In March 2000, the then 
Director of FLETC testified before the Senate Committee on 
Appropriations, Treasury and General Government Subcommittee, that 
plans, at that time, called for Charleston to be closed by the fiscal 
year 2004 time frame, once the training requirements for the new Border 
Patrol hires were completed and/or new facilities became available to 
accommodate the training at FLETC's permanent locations. S.Hrg. 106-712 
at 152 (March 30, 2000). 

[17] At FLETC's fourth campus, in Cheltenham, Maryland, the Capitol 
Police reports its daily student throughput to FLETC's Cheltenham 
Scheduling Office and schedules use of buildings and grounds.

[18] See U.S. General Accounting Office, Internal Control Standards: 
Internal Control Management and Evaluation Tool, GAO-01-1008G 
(Washington, D.C.: Aug. 2001).

[19] Software Engineering Institute, Software Acquisition Capability 
Maturity Model® Version 1.03, CMU/SEI-2002-TR-010 (Pittsburgh, PA: 
March 2002).

[20] FLETC issued a SASS RFP in 2002. However, because of vendor 
complaints about the potential costs involved in preparing their 
respective proposals, FLETC withdrew the request and is now revising 
it.

[21] U.S. General Accounting Office, High Risk Series: Protecting 
Information Systems Supporting the Federal Government and the Nation's 
Critical Infrastructures, GAO-03-121 (Washington, D.C.: Jan. 2003). 

[22] The Computer Security Act of 1987, as amended, (P.L.100-235, 101 
Stat. 1724 (1988) requires federal agencies with computer systems that 
process sensitive information to identify and develop security plans 
for the systems and to provide periodic computer security training to 
personnel managing, using, and operating these systems. The Act defines 
sensitive information as any information that if lost, misused, or 
accessed or modified without proper authorization could adversely 
affect either the national interest or conduct of federal programs, or 
the privacy to which individuals are entitled under the Privacy Act of 
1974 (P.L. 93-579). 

[23] See, for example, National Institute of Standards and Technology, 
Guidelines to Federal Organizations on Security Assurance and 
Acquisition/Use of Tested/Evaluated Products: Recommendations of the 
National Institute of Standards and Technology, NIST SP 800-23 (Aug. 
2000) and Guide For Developing Security Plans for Information 
Technology Systems, NIST SP 800-18 (Dec. 1998). 

[24] Software Engineering Institute, Evolutionary Process for 
Integrating COTS-Based Systems (EPIC): An Overview, CMU/SEI-2002-TR-
009 (Pittsburgh, PA: July 2002). 

[25] FLETC's solicitation utilizes a performance-based statement of 
objectives methodology that provides high-level business needs and 
describes the objectives that prospective offerors will be expected to 
achieve. FLETC officials said that this is intended to allow offerors 
to prepare their own statements of work and to propose innovative and 
cost-effective approaches.

[26] According to a FLETC official, ACMS's scheduling component does 
not have two elements that SASS would provide; he also said that the 
absence of these functions could either be overcome or were acceptable 
to FLETC. The first element is a "conflict resolution" capability to 
help resolve the sequencing of classes. According to the FLETC 
official, this could be resolved by using ACMS's "priority" capability, 
under which schedulers would be able to schedule classes and facilities 
by placing them in priority order. For example, legal classroom 
training would have a higher priority than the subsequent mock 
courtroom training and, accordingly, would be scheduled before the 
courtroom training. The second element is speed--ACMS is not as fast as 
SASS would be. The FLETC official said that ACMS's slower speed was 
acceptable because it was still faster than the current paper-intensive 
process.

[27] To identify the relevant prevailing best practices, we relied 
primarily on the May 2002 Principles of Corporate Governance by the 
Business Roundtable, an association of chief executive officers of 
leading U.S. corporations; GAO's 2001 Internal Control Standards: 
Internal Control Management and Evaluation Tool, (GAO-01-1008G, 
Washington, D.C.: Aug. 2001); and OMB's 1995 Circular No. A-123, 
Management Accountability and Control. We also drew from our August 
2002 report (unnumbered correspondence), on the governance of the U.S. 
Capitol Police, titled Information on Capitol Police Board Roles and 
Responsibilities, Operations, and Alternative Structures. 

[28] See, for example, a report by The Conference Board Commission on 
Public Trust and Private Enterprise titled Findings and 
Recommendations, New York, New York, January 2003. The Conference Board 
is a leading business network that creates and disseminates knowledge 
about management and the marketplace. According to its report, the 
Conference Board created the Commission to help address the causes of 
declining public and investor trust in companies, their leaders, and 
capital markets. The 12-member commission included a former Comptroller 
General of the United States and the current Secretary of the Treasury. 


[29] FLETC officials said that at the conclusion of the Board's 
November 2002 meeting, a follow-up meeting was planned for January 
2003. However, by early December 2002, the decision had been made to 
transfer FLETC to the newly created DHS. They said that taskings 
resulting from the transition delayed decisions regarding the Board. 
FLETC officials, however, said they would review the duties and purview 
of the Board.

[30] Software Engineering Institute, Software Acquisition Capability 
Maturity Model ® Version 1.03, CMU/SEI-2002-TR-010 (Pittsburgh, PA: 
March 2002).

[31] Software Engineering Institute, Evolutionary Process for 
Integrating COTS-Based Systems (EPIC): An Overview, CMU/SEI-2002-TR-
009 (Pittsburgh, PA: July 2002).

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