DHS’s Acquisition Needs-Assessment Process Needs Improvement

The Department of Homeland Security (DHS) spends tens of billions of dollars in contracted goods and services each year. All of that flows through the department’s acquisition processes, organizations and support systems, so the effectiveness of those elements is crucial to both mission success and fiscal stewardship.

DHS’s Office of Inspector General (OIG) recently audited the department’s acquisition processes to determine the extent to which DHS and its components have the necessary controls in place to identify capability needs prior to acquiring goods and services, something DHS has struggled to do in the past.

To decide whether to proceed with a proposed acquisition DHS uses an acquisition lifecycle framework that consists of four phases: 1) Need, 2) Analyze/Select, 3) Obtain, and 4) Produce/Deploy/Support/Dispose. Each phase culminates with a review board that decides whether the acquisition has met the requirements to move forward.

The Need phase is led by DHS’s Joint Requirements Council (JRC) in coordination with the individual DHS component pursuing the acquisition. The JRC established and uses a Joint Requirements Integration and Management System (JRIMS) process that guides components in how to identify required capabilities, gaps and opportunities for joint efforts which are captured in capability documents. The JRC validates and signs-off on the component’s required joint development of capability documents, which identify required capabilities, gaps, and opportunities and support the need for the acquisition.  

Inconsistencies Produce Inefficiencies and Delays

The OIG found that while DHS has processes in place for needs assessment, a lack of standardized procedures leads to inconsistency in the review and decision-making process. As a result, the department validates noncompliant capability needs documents, does not hold components accountable for failing to follow guidance and has not provided adequate direction on how to implement the guidance. These inconsistencies can lead to additional work, unaddressed issues, delayed acquisitions and ultimately bad acquisitions decisions.

Recommendations

The OIG recommends that the DHS Deputy Secretary (or the Senior Official performing those duties) require the Joint Requirements Council to perform the following:

• Follow through on the responsibilities outlined in its charter, including following the operating procedures provided in management directives and detailed instruction manuals. (Since its creation in 2003, the JRC’s history has been on-again-off-again and was reestablished in 2014.)
• Update the JRIMS manual to include all criteria the JRC intends to hold components responsible for meeting and to remove unnecessary criteria.
• Develop and implement internal standard operating procedures for analysts to follow when reviewing a component’s capability documents.
• Document the decision-making process for the capability document review, including comment resolution and validation justification.

DHS responded to the OIG’s four recommendations and described actions they have taken to address them. However, the OIG was unsatisfied with the department’s response to the first recommendation and considers it still open and unresolved.

Implications

The issues raised by the OIG about the DHS acquisition process – and specifically around the assessment and validation of the needs and requirements that drive an acquisition – echo frequent and common themes across all federal acquisitions. Program managers and agency end-users grapple with effectively identifying, validating and documenting what it is exactly that the requiring entity wants and needs.

Inconsistent policies and procedures muddy the waters and often lead to vague specifications, unaddressed requirements, rework and even poor decisions. Each issue can delay and elongate the acquisition timeline and even lead to the procurement of obsolete products. Contractors providing acquisition and/or program support often find themselves in the middle of the process or on the post-award, receiving-end of sub-optimal requirements.

Over the last decade or more, agencies across the federal landscape have been working to improve their processes and we have seen numerous government-wide policies and initiatives to address acquisition challenges. Yet, this latest DHS example highlights that establishing and adhering to core operating processes goes a long way to achieving the improvements and effectiveness that agencies need.