Homeland Security: Clearer Roles and Responsibilities for the Office of Strategy, Policy, and Plans and Workforce Planning Would Enhance Its Effectiveness

GAO has designated DHS management as high risk because of challenges in building a cohesive department. PLCY supports cohesiveness by, among other things, coordinating departmentwide policy and strategy. In the past, however, questions have been raised about PLCY's efficacy. In December 2016, the NDAA codified PLCY's organizational structure, roles, and responsibilities.

GAO was asked to evaluate PLCY's effectiveness. This report addresses the extent to which (1) DHS established an organizational structure and processes and procedures that position PLCY to be effective, (2) DHS and PLCY have ensured alignment of workforce with priorities, and (3) PLCY has engaged relevant component staff to help identify and respond to emerging needs. GAO analyzed the NDAA, documents describing specific responsibilities, and departmentwide policies and strategies. GAO also interviewed officials in PLCY and all eight operational components.

According to our analysis and interviews with operational components, the Department of Homeland Security's (DHS) Office of Strategy, Policy, and Plans' (PLCY) organizational structure and efforts to lead and coordinate departmentwide and crosscutting strategies—a key organizational objective–have been effective. For example, PLCY's coordination efforts for a strategy and policy executive steering committee have been successful, particularly for strategies. However, PLCY has encountered challenges leading and coordinating efforts to develop, update, or harmonize policies that affect multiple DHS components. In large part, these challenges are because DHS does not have clearly-defined roles and responsibilities with accompanying processes and procedures to help PLCY lead and coordinate policy in a predictable, repeatable, and accountable manner. Until PLCY's roles and responsibilities for policy are more clearly defined and corresponding processes and procedures are in place, situations where the lack of clarity hampers PLCY's effectiveness in driving policy are likely to continue. Development of a delegation of authority, which involves reaching agreement about PLCY's roles and responsibilities and clearly documenting them, had been underway. However, it stalled due to changes in department leadership. As of May 2018, the effort had been revived, but it is not clear whether and when DHS will finalize it.

PLCY does some workforce planning as part of its annual budgeting process, but does not systematically apply key principles of the DHS Workforce Planning Guide to help ensure that PLCY's workforce aligns with its and DHS's priorities and goals. According to PLCY officials, the nature of its mission requires a flexible staffing approach. As such, a portion of the staff functions as generalists who can be assigned to meet the needs of different situations, including unexpected changing priorities due to an emerging need. However, shifting short-term priorities requires tradeoffs, which may divert attention and resources from longer-term priorities. As of June 5, 2018, PLCY also had a number of vacancies in key leadership positions, which further limited attention to certain priorities. According to PLCY officials, PLCY recently began a review to identify the office's authorities in the National Defense Authorization Act for Fiscal Year 2017 (NDAA) and other statutes, compare these authorities to the current organization and operations, and address any workforce capacity gaps. Employing workforce planning principles—in particular, systematic identification of workforce demand, capacity gaps, and strategies to address them—consistent with the DHS Workforce Planning Guide could better position PLCY to use its workforce as effectively as possible under uncertain conditions and to communicate effectively with DHS leadership about tradeoffs.

Officials from PLCY and DHS operational components praised existing mechanisms to coordinate and communicate at the senior level, especially about strategy, but component officials identified opportunities to better connect PLCY and component staff to improve communication flow about emerging policy and strategy needs. Among the ideas offered by component officials to enhance communication and collaboration were holding routine small-group meetings, creating forums for periodic knowledge sharing, and maintaining accurate and up-to-date contact information for all staff-level stakeholders.

GAO is making four recommendations. DHS concurred with three recommendations, including that DHS finalize a delegation of authority defining PLCY's roles and responsibilities and develop corresponding processes and procedures. DHS did not concur with a recommendation to apply the DHS Workforce Planning Guide to identify and communicate workforce needs. GAO believes this recommendation is valid as discussed in the report.

The Department of Homeland Security (DHS) was established by the  Homeland Security Act of 2002 and began operations in 2003. That  year, we designated implementing and transforming DHS as high risk  because DHS had to transform 22 agencies—several with major  management challenges—into one department. Further, failure to  effectively address DHS’s management and mission risks could have  serious consequences for U.S. national and economic security. Given the  significant effort required to build and integrate a department as large and  complex as DHS, our initial high-risk designation addressed the  department’s implementation and transformation efforts to include  associated management and programmatic challenges. We reported that  the creation of DHS was an enormous undertaking and successfully  transforming large organizations, even those undertaking less strenuous  reorganizations, could take years to implement. Over the past 15 years,  the focus of this high-risk area has evolved in tandem with DHS’s  maturation and evolution. The overriding tenet has consistently remained  DHS’s ability to build a single, cohesive, and effective department that is  greater than the sum of its parts—a goal that requires effective  collaboration and integration of its various components and management  functions.

DHS’s Office of Strategy, Policy, and Plans (PLCY) is responsible for  some of these management functions, including developing and  coordinating departmentwide policies and strategies, conducting analyses for senior leadership, and supporting the Secretary’s initiatives. For  example, PLCY develops and disseminates departmentwide policies in  the form of directives and instructions, strategy documents required by  statute, operational plans, and reports for Congress. The National  Defense Authorization Act for Fiscal Year 2017 (NDAA), enacted in  December 2016, established PLCY in statute. Although largely  consistent with the roles and responsibilities of DHS’s Office of Policy, as  PLCY was named before enactment of the NDAA, implementation of the  act required organizational changes designed to respond to certain  challenges the office had identified as barriers to its ability to perform  effectively.

For a number of years, questions have been raised about the office’s  efficacy and engagement with key stakeholders, like the DHS operational  components. For example, we have reported on challenges related to  obtaining stakeholder feedback under the office’s leadership of the 2010  and 2014 Quadrennial Homeland Security Reviews (QHSR). We have  also reported on opportunities for select components of the office—the  Screening Coordination Office and the Office of International Affairs—to  implement better management controls to help enhance monitoring and  accountability for their respective missions. DHS agreed with all of our  recommendations in those prior reports.

In light of past concerns about efficacy and the recent statutory changes,  you asked us to review how PLCY is contributing to efforts to build a  single, cohesive department by driving departmentwide and crosscutting  strategy and policy. This report addresses the extent to which (1) DHS  has established an organizational structure and processes and  procedures that position PLCY to achieve its organizational objectives, (2)  DHS and PLCY have ensured that PLCY’s workforce is aligned with  PLCY’s and DHS’s priorities and goals, and (3) PLCY has effectively  engaged across the operational components to identify and respond to  emerging policy and strategy needs.

To address all three objectives, we analyzed key documents and  interviewed officials from PLCY and other DHS offices, including officials  responsible for policy, strategy, and plan development and  implementation at all eight of DHS’s operational components. Specifically,  to better understand the roles and responsibilities of PLCY, DHS’s eight  operational components, and other offices at DHS, we reviewed the  NDAA and analyzed documents, such as departmental directives that  describe what is required and expected of each office. In addition, we  interviewed officials from PLCY to understand its roles and  responsibilities, workforce planning practices, and collaboration with DHS  operational components.

Furthermore, we interviewed officials from DHS’s Office of the Under  Secretary for Management to understand the differences between  PLCY’s roles and responsibilities and those of the Office of the Under  Secretary for Management, who oversees all internal management  operations and oversight of management functions for components at  DHS headquarters. To further understand PLCY’s engagement with DHS  operational components as well as their perspectives on PLCY’s roles  and responsibilities, we conducted both unstructured and structured  interviews with each of DHS’s eight operational components. For the  structured interviews, we developed a questionnaire that we tested  internally before administering it to DHS officials. At the structured  interviews, we asked officials at each operational component the same  questions in the same order to ensure we collected information  consistently and reliably across the different respondents. We compared  our findings to Standards for Internal Control in the Federal Government,  leading collaboration practices identified in our prior work, and the DHS  Workforce Planning Guide to determine the extent to which PLCY is able  to achieve its goals given its organizational structure, workforce planning,  and communication and collaboration with operational components.

We conducted this performance audit from July 2017 to September 2018  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

PLCY Organizational Structure and Vacancies

With the passage of the NDAA in December 2016, PLCY is to be led by  an Under Secretary for Strategy, Policy, and Plans, who is appointed by  the President with advice and consent of the Senate. The Under  Secretary is to report directly to the Secretary of Homeland Security. Prior  to the NDAA, the office was headed by an assistant secretary. Since the  passage of the act, the undersecretary position has been vacant, and as  of June 5, 2018, the President had not nominated an individual to fill the position. According to PLCY officials, elevating the head of the office to  an undersecretary was important because it equalizes PLCY with other  DHS management offices and DHS headquarters components. The  NDAA further authorizes, but does not require, the Secretary to establish  a position of deputy undersecretary within PLCY. If the position is  established, the NDAA provides that the Secretary may appoint a career  employee to the position (i.e., not a political appointee). In March 2018,  the Secretary named a Deputy Under Secretary, who has been  performing the duties of the Deputy Under Secretary and the Under  Secretary since then. As shown in figure 1, PLCY is divided into five sub- offices, each with a different focus area.

As of June 5, 2018, the top position in these sub-offices was an assistant  secretary and two of the five positions were vacant. As of June 5, 2018, 6  of PLCY’s 12 deputy assistant secretary positions were vacant or filled by  acting staff temporarily performing the duties in the absence of permanent  staff placement.

PLCY’s Policy and Strategy Responsibilities, and Strategic Priorities

The NDAA codified many of the functions and responsibilities that PLCY  had been carrying out prior to the act’s enactment and, with a few  exceptions as discussed later in this report, were largely consistent with  the duties the office was already pursuing. According to the act and PLCY  officials, one of the office’s fundamental responsibilities is to lead,  conduct, and coordinate departmentwide policy development and  implementation, and strategic planning. According to PLCY officials, there  are four categories of policy and strategy efforts that PLCY leads,  conducts, or coordinates:

Statutory responsibilities: among others, the Homeland Security  Act, as amended by the NDAA, includes such responsibilities as  establishing standards of validity and reliability for statistical data  collected by the department, conducting or overseeing analysis and  reporting of such data, and maintaining all immigration statistical  information of U.S. Customs and Border Protection, U.S. Immigration  and Customs Enforcement, and U.S. Citizenship and Immigration  Services; the Immigration and Nationality Act includes such  responsibilities as providing for a system for collection and  dissemination to Congress and the public of information useful in  evaluating the social, economic, environmental, and demographic  impact of immigration laws, and reporting annually on trends in lawful  immigration flows, naturalizations, and enforcement actions,

Representing DHS in interagency efforts: coordinating or  representing departmental policy and strategy positions for larger  interagency efforts (e.g., interagency policy committees convened by  the White House),

Secretary’s priorities: leading or coordinating efforts that correspond  to the Secretary of Homeland Security’s priorities (e.g., certain  immigration or law-enforcement related issues), and

Self-initiated activities: opportunities to better harmonize policy and  strategy or create additional efficiencies given PLCY’s ability to see  across the department. For example, PLCY officials said that DHS  observed an increase in e-commerce and small businesses shipping  items via carriers other than the U.S. Postal Service, thus exploiting a  gap in DHS monitoring, which covers the U.S. Postal Service and  other traditional shipping entities. PLCY officials noted that DHS’s  interest in addressing e-commerce issues occurred just before opioids  and other controlled substances were being mailed through small  businesses and the U.S. Postal Service. As a result, PLCY developed  an e-commerce strategy for, among other things, the shipping of  illegal items and how to provide information to U.S. Customs and  Border Protection before parcels are shipped to the United States  from abroad.

In accordance with the NDAA, as PLCY leads, conducts, and coordinates  policy and strategy, it is to do so in a manner that promotes and ensures  quality, consistency, and integration across DHS and applies risk-based  analysis and planning to departmentwide strategic planning efforts. The  NDAA further provides that all component heads are to coordinate with  PLCY when establishing or modifying policies or strategic planning  guidance to ensure consistency with DHS’s policy priorities. In addition to  the roles PLCY plays that are directly related to leading, conducting, and  coordinating policy and strategy, the office is responsible for select  operational functions. For example, PLCY is charged with operating the  REAL ID and Visa Waiver Programs.

The NDAA also conferred responsibilities to PLCY that had not been  responsibilities of the DHS Office of Policy prior to the NDAA’s  enactment. Among other things, the NDAA charged PLCY with  responsibility for establishing standards of reliability and validity for  statistical data collected and analyzed by the department, and ensuring  the accuracy of metrics and statistical data provided to Congress. In  conferring this responsibility, the act also transferred to PLCY the  maintenance of all immigration statistical information of the U.S. Customs  and Border Protection, U.S. Immigration and Customs Enforcement, and  U.S. Citizenship and Immigration Services.

PLCY has established five performance goals: build departmental policy-making capacity, coordination, and foster  the Unity of Effort, mature the office as a mission-oriented, component-focused  organization that is responsive to DHS leadership, effectively engage and leverage stakeholders, enhance productivity and effectiveness of policy personnel through  appropriate alignment of knowledge, skills, and abilities, and accountability, transparency, and leadership.

PLCY officials stated that the office established the performance goals in  fiscal year 2015 and they were still in effect as of fiscal year 2018.

Homeland Security Crosscutting Missions and Functions

As previously discussed, DHS has eight operational components. DHS  also has six support components. Although each one has a distinct role  to play in helping to secure the homeland, there are operational and  support functions that cut across mission areas. For example, nearly  every operational component has, as part of its security operations, a  need for screening, vetting, and credentialing procedures and risk- targeting mechanisms. Likewise, nearly all operational components have  some form of international engagement, deploying staff abroad to help  secure the homeland before threats reach U.S. borders. Finally, as shown  in figure 2, different aspects of broad mission areas fall under the purview  of more than one DHS operational component.

Key Departmentwide and Crosscutting Strategic Efforts

PLCY is responsible for coordinating three key DHS strategic efforts: the  QHSR, the DHS Strategic Plan, and the Resource Planning Guidance.

The QHSR is a comprehensive examination of the homeland security strategy of the nation that is to occur every 4 years and include recommendations regarding the long-term strategy and priorities for homeland security of the nation and guidance on the programs, assets, capabilities, budget, policies, and authorities of DHS. The QHSR is to be conducted in consultation with the heads of other federal agencies, key DHS officials (including the Under Secretary, PLCY), and key officials from other relevant governmental and nongovernmental entities.

The DHS Strategic Plan describes how DHS can accomplish the missions it identifies in the QHSR report, identifies high-priority mission areas within DHS, and lays the foundation for DHS to accomplish its Unity of Effort Initiative as well as various cross-agency priority goals in the strategic plan, such as cybersecurity.

The Resource Planning Guidance describes DHS’s annual resource allocation process in order to execute the missions and goals of the QHSR and DHS Strategic Plan. The Resource Planning Guidance contains guidance over a 5-year period and informs several forward- looking reports to Congress, including the annual fiscal year Congressional Budget Justification as well as the Future Years Homeland Security Program Report.

PLCY Has Effectively Coordinated Intradepartmental Strategy Efforts, but Ambiguous Roles and Responsibilities Have Limited PLCY’s Effectiveness in Coordinating Policy

Although PLCY has effectively carried out key coordination functions at  the senior level related to strategy, PLCY’s ability to lead and coordinate  policy have been limited due to ambiguous roles and responsibilities and  a lack of predictable, accountable, and repeatable procedures.

PLCY Has Effectively Conducted Key Coordination Functions at the Senior Level

According to our analysis and interviews with operational components,  PLCY’s efforts to lead and coordinate departmentwide and crosscutting  strategies—a key organizational objective—have been effective in  providing opportunities for all relevant stakeholders to learn about and  contribute to departmentwide or crosscutting strategy development. In  this role, PLCY routinely serves as the executive agent for the Deputies  Management Action Group and the Senior Leaders Council, which  involve analytical and coordination support. PLCY also provides support  for deputy- and principal-level decision making. For example, the Strategy  and Policy Executive Steering Committee (S&P ESC) meetings have  been used to discuss components’ implementation plans for crosscutting  strategies, PLCY’s requests for information from components for an  upcoming strategy, and updates on departmentwide strategic planning  initiatives. According to PLCY and operational component officials, PLCY  also provides leadership for the Resource Planning Guidance and Winter  Studies, both of which help inform departmentwide resource decision- making. For example, officials from one operational component stated  that PLCY’s leadership of the Resource Planning Guidance is a helpful  practice for coordination and collaboration on departmentwide or  crosscutting strategies. The officials stated that PLCY reaches out to  ensure that the component is covering the Secretary’s priorities and this  helps the component to ensure that its budget includes them.  Furthermore, PLCY develops and coordinates policy options and opinions  for the Secretary to present at the National Security Council and other  White House-level meetings. For example, PLCY officials told us that, in  light of allegations of Russian involvement in using poisonous nerve  agents on two civilians in Great Britain, PLCY coordinated the collection  of information to develop a policy recommendation for the Secretary to  present at a National Security Council meeting.

Ambiguity in Roles and Responsibilities and a Lack of Predictable, Repeatable, and Accountable Procedures Have Limited PLCY’s Ability to Lead and Coordinate Policy

PLCY has encountered challenges leading and coordinating efforts to  develop, update, or harmonize policy—also a key organizational  objective—because it does not have clearly-defined roles, responsibilities,  and mechanisms to implement these responsibilities in a predictable,  repeatable, and accountable way. Standards for Internal Control in the  Federal Government states that management should establish an  organizational structure, assign responsibility, and delegate authority to  achieve the entity’s objectives. As such, an organization’s management  should develop an organizational structure with an understanding of the  overall responsibilities and assign these responsibilities to discrete units  to enable the organization to operate in an efficient and effective  manner. An organization’s management should also implement control  activities through policies. It is important that an organization’s  management document and define policies and communicate those  policies and procedures to personnel, so they can implement control  activities for their assigned responsibilities. In addition, leading  collaboration practices we have identified in our prior work include  defining and articulating a common outcome, clarifying roles and  responsibilities, and establishing mutually-reinforcing or joint strategies to  enhance and sustain collaboration, such as the work that PLCY and the  components need to do together to ensure that departmentwide and  crosscutting policy is effective for all relevant parties.

According to PLCY officials, in general, PLCY is responsible for leading  the development of a policy when it crosses multiple components or if  there is a national implication, including White House interest in the  policy. However, PLCY officials acknowledged that this practice does not  always make them the lead and there are no established criteria that  define the circumstances under which PLCY (or another organizational  unit) should lead development of policies that cut across organizational  boundaries. PLCY officials said the lead entity for a policy is often  announced in an email from the Secretary’s office, on a case-by-case  basis. According to PLCY officials, once components have been assigned responsibility for a policy, they have generally tended to retain it, and  PLCY may not have oversight for crosscutting policies that are  maintained by operational components. Therefore, there is no  established, coordinated system of oversight to periodically monitor the  need for policy harmonization, revision, or rescission.

In the absence of clear roles and responsibilities, and processes and  procedures to support them, PLCY and officials in 5 of the 8 components  have encountered challenges in coordinating with each other. Although  PLCY and most component officials we interviewed described overall  positive experiences in coordinating with each other, we identified  multiple instances of (1) confusion about which parties should lead and  engage in policy efforts, (2) not engaging components at the right times,  (3) incompatible expectations around timelines, and (4) uncertainty about  PLCY’s role and the extent to which it can and should identify and drive  policy in support of a more cohesive DHS.

Confusion about who should lead and engage. Officials from one  operational component told us that they were tasked with leading a  departmentwide policy development effort they believed was outside their  area of responsibility and expertise. Officials in another operational  component stated that components sometimes end up coordinating  among themselves, but that policy development could be more effective  and efficient if PLCY took the role of convener and facilitator to ensure the  departmentwide perspective is present and all relevant stakeholders  participate. Officials from a third component stated that they spent  significant time and resources to develop a policy directly related to their  component’s mission. As the component got ready to implement the  policy, PLCY became aware of it and asked the component to stop  working on the policy, so PLCY could develop a departmentwide policy.  According to component officials, while they were supportive of a  departmentwide policy, PLCY’s timing delayed implementation of the  policy the component had developed and wasted the resources it had  invested. Moreover, officials from four operational components told us  that sometimes counselors from outside PLCY, such as the Secretary’s  office, have led policy efforts that seem like they should be PLCY’s  responsibility, which created more confusion about what PLCY’s ongoing  role should be. PLCY officials agreed that, at times, it has been challenging to define PLCY’s role relative to counselors for the Secretary,  and acknowledged that clear guidance to define who is leading which  types of policy development and coordination would be helpful.

Not engaging components at the right times. Officials from 5 of 8  operational components told us that they had not always been engaged  at the right times by PLCY in departmentwide or crosscutting policies that  affected their missions. For example, officials from an operational  component described a crosscutting policy that had significant  implications for some of its key operational resources, but the component  was not made aware of the policy until it was about to be presented at the  White House. Officials from another component stated that they learned  of a new policy after it was in place and had to find significant training and  software resources to implement it even though they viewed the policy as  unnecessary for their mission. PLCY officials stated that, while they  intend to identify all components that should be involved in a policy, there  are times when PLCY is unaware a component is developing a policy that  affects other components. PLCY officials said they will involve other  components when PLCY becomes aware that a component is developing  such a policy. PLCY officials stated that it would be helpful to have a  process and procedures for cross-component coordination on policies to  help guide engagement regardless of who is developing the policy.

Incompatible expectations around timelines. Officials at 4 of 8  operational components stated that short timelines from PLCY to provide  input and feedback can prevent PLCY from obtaining thoughtful and  complete information from components. For example, officials from one  component stated that PLCY asked them to perform an analysis that  would inform major, departmental decision-making and quickly provide  the analysis. Component officials told us that they did not understand why  PLCY needed the analysis on such an accelerated timeline, which  seemed inappropriate given the level of importance and purpose of the  analysis. Officials from another component told us that PLCY had not  always provided enough time to provide thoughtful feedback; therefore,  component officials were not sure if PLCY really wanted their feedback.  Officials from a third component stated that sometimes PLCY did not  provide sufficient time for thoughtful input or feedback that had cleared  the component’s legal review, so component officials elected to miss  PLCY’s deadline and provide late feedback. PLCY officials told us that,  frequently, timelines are not within their control, a situation that some  component officials also noted during our interviews with them. However,  PLCY officials agreed that a documented, predictable, and repeatable  process and procedures for policies may help ensure PLCY provides  sufficient comment time when in its control and may provide a basis to  help negotiate timelines with DHS leadership in other situations. PLCY  officials stated that, even with a documented process and procedures,  there would still be circumstances when short timelines are unavoidable.

Uncertainty about PLCY’s role in driving policy harmonization. Policy  officials at 6 of 8 operational components told us that they were unsure or  not aware of PLCY’s role in harmonizing policy across the department,  and stated a desire for PLCY to be more involved in harmonizing or  enhancing departmentwide and crosscutting policy or for greater clarity  about PLCY’s responsibility to play this role. As previously discussed,  PLCY’s policy and strategy efforts fall into four categories—statutory  responsibilities, interagency efforts, Secretary’s priorities, and self- initiated activities; these activities include efforts to better harmonize  policies and strategies. According to PLCY officials, the category with the  lowest priority is self-initiated activities. PLCY officials stated that PLCY  makes tradeoffs and rarely chooses to work on self-initiated projects over  its other three categories of effort. According to the officials, PLCY’s work  on the other three higher-priority categories is sufficient to ensure that the  office is effectively leading, conducting, and coordinating strategy and  policy across the department. Given its organizational position and  strategic priorities, PLCY is uniquely situated to identify opportunities to  better harmonize or enhance departmentwide and crosscutting policy, a  role that is in line with its strategic priority to build departmental  policymaking capacity and foster Unity of Effort. In the absence of clear  articulation of the department’s expectations for PLCY in this role, it is  difficult for PLCY and DHS leadership to make completely informed and  deliberate decisions about the tradeoffs they make across any available  resources.

Past Efforts to Define and Codify PLCY’s Roles and Responsibilities in a Delegation of Authority Remain Incomplete

In addition to statutory authority that PLCY received in the NDAA, PLCY  officials stated that a separate, clear delegation of authority—a  mechanism by which the Secretary delegates responsibilities to other  organizational units within DHS—is needed to help confront the  ambiguous roles it has experienced in the past. PLCY officials stated that  past efforts to finalize a delegation of authority have stalled during  leadership changes and that the initiative has been a lower priority, in  part, due to where PLCY is in its maturation process and DHS is in its  evolution into a more cohesive department under the Unity of Effort. As of  May 2018, the effort had been revived, but it is not clear whether and  when DHS will finalize it.

According to a senior official in the Office of the Under Secretary for  Management, a delegation of authority is important for PLCY. He  described the creation of a delegation of authority as a process that does  more than simply delegate the Secretary’s authority. He noted that  defining PLCY’s roles and responsibilities in relation to other  organizational units presents an opportunity to engage all relevant  components and agree on appropriate roles. He said that, earlier in the  organizational life of the Office of the Under Secretary for Management, it  went through a process like this, which has been vital in it being able to  carry out its mission. He said now that PLCY has a deputy undersecretary  in place, this is a good time to restart the process to develop the  delegation of authority. Until the delegation or a similar process clearly  and fully articulates PLCY’s roles and responsibilities, PLCY and the  operational components are likely to continue to experience limitations in  collaboration on crosscutting and departmentwide policy.

PLCY Identifies Workforce Needs during the Annual Budget Cycle, but Could Apply DHS Workforce Planning Guidance to Better Identify and Communicate Resource Needs

PLCY determines its workforce needs through the annual budget  process, but systematic identification of workforce demand, capacity  gaps, and strategies to address them could help ensure that PLCY’s  workforce aligns with its and DHS’s priorities and goals.

PLCY Uses the Annual Budget Cycle to Determine Workforce Needs and Requires Flexibility in Staffing

To determine its workforce needs each year, PLCY officials told us that,  as part of the annual budget cycle, they work with PLCY staff and  operational components to determine the scope of activities required for  each PLCY area of responsibility and the associated staffing needs.  PLCY officials said there are three skill sets needed to carry out the  office’s responsibilities: policy analysis, social science analysis, and  regional affairs analysis. PLCY officials explained that the office’s  priorities can change rapidly as events occur and the Secretary’s and  administration’s priorities shift. Therefore, according to PLCY officials,  their staffing model must be flexible. They said that, rather than a defined  system of full-time equivalents with set position types and levels, PLCY  officials start with their budget allotment and consider current and  potential emerging needs to set position types and levels, which may  fluctuate significantly from year to year. In addition, PLCY officials stated  that PLCY staff are primarily generalists and, given the versatility in skill  sets of their workforce, PLCY has a lot of flexibility to move staff around if  there is an emerging need. For example, if there is an emerging law  enforcement issue that affects all law enforcement agencies, PLCY may  be tasked with developing a policy to ensure the issue is addressed  quickly and that the resulting policy is harmonized across the department  and with other law enforcement agencies, such as the Department of  Justice.

PLCY Has Not Used DHS’s Workforce Planning Guide to Analyze Workforce Gaps or Communicate Tradeoffs to DHS Management to Ensure Alignment with DHS Priorities

While PLCY completes some workforce planning activities as part of its  annual budgeting process, PLCY does not systematically address several  aspects of the DHS Workforce Planning Guide that may create more  efficient operations and greater alignment with DHS priorities. According  to the DHS Workforce Planning Guide, workforce planning is a process  that ensures the right number of people with the right skills are in the right  jobs at the right time for DHS to achieve the mission. This process  provides a framework to: align workforce planning to the department’s mission and goals, predict, then assess how evolving missions, new processes, or  environmental conditions may impact the way that work will be  performed at DHS in the future,  identify gaps in capacity, develop and implement strategies and action plans to address  capacity and capability gaps, and  continuously monitor the effectiveness of action plans and modify, as  necessary.

The DHS Workforce Planning Guide stipulates that an organization’s  management should not only lead and show support during the workforce  planning process, but ensure alignment with the strategic direction of the  agency. Moreover, Standards for Internal Control in the Federal  Government states that management should use quality information to  achieve the entity’s objectives. For example, management uses an  entity’s operational processes to make informed decisions and evaluate  the entity’s performance in achieving key agency objectives.

According to PLCY officials, the current staffing paradigm involves shifting  the office’s staff when new and urgent issues arise from the Secretary or  White House, and adding these unexpected tasks to staff’s existing  responsibilities. However, this means that tradeoffs are made, resulting in  some priority items taking longer to address or not getting attention at all.  PLCY officials stated that they have been caught off-guard at times by  changes in demands placed on PLCY and had to scramble to address the  new needs.

Additionally, PLCY officials said they have a number of vacancies, which  hamper the office’s ability to meet certain aspects of its mission. For  example, PLCY’s Office of Cyber, Infrastructure, and Resilience was  created in 2015. According to PLCY officials, PLCY has had some  resources to address cyber issues, however, there has not been funding  to staff this office and an assistant secretary has not been appointed to  lead it. Therefore, PLCY officials stated that PLCY has not been able to  address its responsibilities for infrastructure resilience.

Similarly, PLCY has limited capacity for risk analysis. A provision of the  NDAA provides that PLCY is to:  develop and coordinate strategic plans and long-term goals of the  department with risk-based analysis and planning to improve operational  mission effectiveness, including consultation with the Secretary regarding  the quadrennial homeland security review under section 707 [6 U.S.C. §  347].

However, PLCY officials acknowledged that their focus on identifying  needs for risk analyses and conducting them has been limited, in part,  because DHS disbanded the risk management office.

Officials from one component told us that they contribute to a report that  PLCY coordinates, called Homeland Security National Risk  Characteristics, which is prepared as a precursor to the DHS Strategic  Plan. PLCY officials stated that, outside of these foundational documents  and some risk-based analyses completed as part of specific policy  development efforts, PLCY does not have the capacity to complete any  additional risk analysis activities.

Although PLCY officials said they conduct some analysis of potential  demands as a starting point for how to allocate PLCY’s annual staffing  budget, these efforts are largely informal and internal and have not  resulted in a systematic analysis that provides PLCY and DHS  management with the information they need to understand the effects of  resource tradeoffs. Also, PLCY officials said they track accomplishments  toward PLCY’s strategic priorities as part of a weekly meeting and report,  however, officials acknowledged they do not analyze what role workforce  decisions have played in achieving or not achieving strategic priorities.  Moreover, although PLCY officials stated that they have intermittent, in- person, informal communication about resource use, they have not used  the principles outlined in the DHS Workforce Planning Guide to  systematically identify and communicate workforce demands, capacity  gaps, and strategies to address workforce issues. According to PLCY  officials, they have not conducted such analysis, in part, because the  Secretary’s office has not requested it of them or the other DHS offices  that are funded in the same part of the DHS budget. Regardless of  whether the Secretary expects workforce analysis as part of the  budgeting process, the DHS Workforce Planning Guide could be used  within and outside of the budgeting process to help inform resource  decision making throughout the year.

PLCY officials stated that at the PLCY Deputy Under Secretary’s  initiative, they recently began a review of all relevant statutory authorities,  which they will map against the current organizational structure and day- to-day operations. The Deputy Under Secretary plans to use the results of  the review to enhance PLCY’s efficiency and effectiveness, and the  results could serve as a foundation for a more holistic and systematic  analysis of workforce demand, any capacity gaps, and strategies to  address them. Employing workforce planning principles—in particular,  systematic identification of workforce demand, capacity gaps, and  strategies to address them—consistent with the DHS Workforce Planning  Guide could better position PLCY to use its workforce as effectively as  possible under uncertain conditions. Moreover, using the DHS guide  would help PLCY to systematically communicate information about any  workforce gaps to DHS leadership, so there is transparency about how  workforce tradeoffs affect PLCY’s ability to support DHS goals.

Additional External Communication Practices Could Enhance PLCY’s Collaboration with DHS Stakeholders

As discussed earlier, officials from PLCY and DHS operational  components praised existing mechanisms to coordinate and  communicate at the senior level, especially about strategy. However,  component officials identified opportunities for PLCY to better connect at  the staff level to identify and respond to emerging policy and strategy  needs. Leading practices for collaboration that we have identified in our  prior work state that it is important to ensure that all relevant participants  have been included in a collaborative effort, and positive working  relationships among participants from different agencies or offices can  bridge organizational cultures. These relationships build trust and foster  communication, which facilitate collaboration.

Also, as previously stated, PLCY has mechanisms like the S&P ESC to  communicate and coordinate with operational components and other  DHS stakeholders at the senior level (e.g., Senior Executive Service  officials). However, PLCY does not have a mechanism to effectively  engage in routine communication and collaboration at the staff level (e.g.,  program and policy specialists working at operational components to  oversee or implement policy and strategy functions). Specifically, officials  with responsibility for policy and strategy at 6 of 8 operational  components told us that they did not have regular contact with or know  who to contact at PLCY for questions about policies or strategies, or that  the reason they knew who to contact was because of existing working  relationships, not because of efforts PLCY had undertaken to facilitate  such contacts. In addition, some component officials noted that, when  they tried to use the PLCY website to coordinate, they found it to be out of  date and lacking sufficient information. PLCY officials acknowledged that  the website needs improvement. They stated that the office has  developed improved content for the website, but does not have the  necessary staff to update the website. According to the officials, the  needed staff should be hired soon and improved content should be on the  website by the end of summer 2018.

Although officials at 5 of the 8 operational components we interviewed  stated that the quality of PLCY’s coordination and collaboration has  improved in the past 2 years or so, component officials offered several  suggestions to enhance PLCY’s coordination and collaboration,  especially at the staff level. Among these were:  conduct routine information sharing meetings with staff-level officials  who have policy and strategy responsibilities at each operational  component,  clearly articulate points of contact, their contact information, and their  portfolios at PLCY as well as at other policy and strategy  stakeholders, ensure the PLCY website is up-to-date with contact information for  PLCY and components that work in strategy and policy areas, and  with relevant information about crosscutting strategy and policy  initiatives underway, host a forum—such as an annual conference—to bring together policy  and strategy officials from PLCY and DHS components to share ideas  and make contacts, and prepare a standard briefing for component officials with strategy and  policy responsibilities to help ensure that staff at all levels understand  what PLCY does, how it works, and opportunities for engagement on  emerging policy and strategy needs or identified harmonization  opportunities.

For example, officials from one component told us that they would like  PLCY officials to have in-person meetings with component staff to  discuss what PLCY does, who to contact in PLCY, where to find  information about policies and strategies, and other relevant information  to ensure a smooth working relationship between the component and  PLCY.

According to PLCY officials, the office recognizes the value of creating  mechanisms to connect staff, who work on policy and strategy at all levels  in DHS. PLCY officials said they have historically done a better job in  coordinating at the senior level, but are interested in expanding  opportunities to connect other staff with policy and strategy  responsibilities. PLCY officials stated that they are considering creating a  working group structure that mirrors existing organizational mechanisms  to coordinate at the senior level, but have not taken steps to do so.

Routine collaboration among PLCY, operational components, and other  DHS offices at the staff level is important to ensure that PLCY is able to  carry out its functions under the NDAA, including the effective  coordination of policies and strategies. A positive working relationship  among these stakeholders can build trust, foster communication, and  facilitate collaboration. Such enhanced communication and collaboration  across PLCY and among component officials with policy and strategy  responsibility could help the department more quickly and completely  identify emerging, crosscutting strategy and policy needs and  opportunities to enhance policy harmonization.

PLCY’s efforts to lead, conduct, and coordinate departmentwide and  crosscutting policies have sometimes been hampered by the lack of  clearly-defined roles and responsibilities. In addition, PLCY does not have  a consistent process and procedures for its strategy development and  policymaking efforts. Without a delegation of authority or similar  documentation from DHS leadership clearly articulating PLCY’s missions,  roles, and responsibilities—along with defined processes and procedures  to carry them out in a predictable and repeatable manner—there is  continuing risk that confusion and uncertainty about PLCY’s authority,  missions, roles, and responsibilities will limit its effectiveness.

PLCY employs some workforce planning, but does not systematically  apply key principles of the DHS Workforce Planning Guide to help predict  workforce demand, and identify any workforce gaps and design strategies  to address them. Without this analysis, PLCY faces limitations in ensuring  that its workforce is aligned with its and DHS’s priorities and goals.  Moreover, the results of this analysis would better position PLCY to  communicate to DHS leadership any potential tradeoffs in workforce  allocation that would affect PLCY’s ability to meet priorities and goals.

PLCY could enhance its use of mechanisms for collaboration and  communication with DHS stakeholders at the staff level. Implementation  of additional mechanisms at the staff level for regular communication and  coordination, including providing up-to-date information to stakeholders  about the office, could help PLCY and operational components to better  connect in order to identify and address emerging policy and strategy  needs.

We are making the following four recommendations to DHS:  The Secretary of Homeland Security should finalize a delegation of  authority or similar document that clearly defines PLCY’s mission, roles,  and responsibilities relative to DHS’s operational and support  components. (Recommendation 1)

The Secretary of Homeland Security should create corresponding  processes and procedures to help implement the mission, roles, and  responsibilities defined in the delegation of authority or similar document  to help ensure predictability, repeatability, and accountability in  departmentwide and crosscutting strategy and policy efforts.  (Recommendation 2)

The Under Secretary for Strategy, Policy, and Plans should use the DHS  Workforce Planning Guide to help identify and analyze any gaps in  PLCY’s workforce, design strategies to address any gaps, and  communicate this information to DHS leadership. (Recommendation 3)

The Under Secretary for Strategy, Policy, and Plans should enhance the  use of collaboration and communication mechanisms to connect with staff  in the components with responsibilities for policy and strategy to better  identify and address emerging needs. (Recommendation 4)

We provided a draft of this report for review and comment to DHS. DHS  provided written comments, which are reproduced in appendix I. DHS  also provided technical comments, which we incorporated, as  appropriate. DHS concurred with three of our recommendations and  described actions planned to address them. DHS did not concur with one  recommendation.

Specifically, DHS did not concur with our recommendation that PLCY  should use the DHS Workforce Planning Guide to help identify and  analyze any gaps in PLCY’s workforce, design strategies to address any  gaps, and communicate this information to DHS leadership. The letter  described a number of actions, including actions that are also described  in the report, which PLCY takes to help ensure alignment of its staff with  organizational needs. In the letter, PLCY officials pointed to the workforce  activities PLCY undertakes as part of the annual budgeting cycle. We  acknowledge that the actions described to predict upcoming priorities and  resource needs as part of the annual budgeting cycle are in line with the  DHS workforce planning principles. However, as we noted, there are  opportunities to apply the workforce planning principles outside the  annual budgeting cycle to provide greater visibility and awareness of  resource tradeoffs to management inside PLCY and in the Secretary’s  office.

In the letter, PLCY officials made note of the dynamic and changing  nature of its operational environment, stating that it often required them to  shift resources and priorities on a more frequent or ad hoc basis than  many organizations. We acknowledged in the report that PLCY’s  operating environment requires it to maintain flexibility in its staffing  approach. However, PLCY has a number of important duties, including  helping foster Unity of Effort throughout the department and helping to  ensure the availability of risk information for departmental decision  making, that require longer-term, sustained attention and strategic  management. During interviews, PLCY officials acknowledged that  striking a balance between these needs has been difficult and at times  they have faced significant struggles. The report describes some areas  where, during the time we were conducting our work, it was clear that  some tasks and functions, such as risk analyses, lacked the resources or  focus necessary to ensure they received sustained institutional attention.  It is because of PLCY’s dynamic operating environment, coupled with the  need for sustained institutional attention to other key responsibilities, that  we recommended PLCY undertake workforce planning activities that  would help generate better information for PLCY and DHS management  to have full visibility and awareness of gaps and resource tradeoffs.

Finally, the letter stated that because PLCY is a very small and flat  organization, it is able to identify capacity gaps and develop action plans  without obtaining all of the data collected through each recommended  element, worksheet, form, and template of the model proposed in the  DHS Workforce Planning Guide. We acknowledge that it would be  counterproductive for PLCY to engage in data collection and analysis that  are significantly more elaborate than its planning needs. Nevertheless, we  continue to believe that PLCY could use the principles more robustly,  outside the annual budgeting process, to help ensure that it identifies and  communicates the effect that resource tradeoffs have on its ability to  accomplish its multifaceted mission.

We are sending copies of this report to the appropriate congressional  committees and the Secretary of Homeland Security. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov. If you or your staff have any questions concerning  this report, please contact me at (404) 679-1875 or CurrieC@gao.gov.  Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this report. GAO staff who made  significant contributions to this report are listed in Appendix II.

Appendix I: Comments from the Department of Homeland Security

Appendix II: GAO Contact and Staff Acknowledgements

In addition to the contact named above, Kathryn Godfrey (Assistant  Director), Joseph E. Dewechter (Analyst-in-Charge), Michelle Loutoo  Wilson, Ricki Gaber, Dominick Dale, Thomas Lombardi, Ned Malone,  David Alexander, Sarah Veale, and Michael Hansen made key  contributions to this report.

Twenty-two agencies—several with major management challenges—combined to form the Department of Homeland Security in 2003. Since then, DHS has often struggled to build a cohesive, effective department, and its management has remained on our High Risk list.

Its Office of Strategy, Policy, and Plans helps shape DHS by, for example, developing and coordinating departmentwide strategies and policies. The office has been effective with strategies, but a lack of clearly defined roles and responsibilities in DHS has hampered its efforts to develop and align policies.

We recommended, among other things, that DHS more clearly define the office's role.