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(ARB) if AIT could not meet any of TSA's five key performance
parameters or if TSA changed a key performance parameter during
qualification testing. 12 Senior TSA officials acknowledged that TSA did not
comply with the directive's requirements, but stated that TSA still reached
a "good decision" in procuring AIT and that the ARB was fully informed of
the program's changes to its key performance parameters. Further, TSA
officials stated that the program was not bound by AD 102 because it was
a new acquisition process and they believed that the ARB was not fully
functioning at the time. 13 DHS officials stated that the ARB discussed the
changed key performance parameter but did not see the documents
related to the change and determined that TSA must update the
program's key acquisition document, the Acquisition Program Baseline,
before TSA could deploy AIT systems. However, we concluded that,
according to a February 2010 acquisition decision memorandum from
DHS, the ARB gave approval to TSA for full-scale production without
reviewing the changed key performance parameter. DHS officials stated
that the ARB should have formally reviewed changes made to the key
performance parameter to ensure that TSA did not change it arbitrarily.
According to TSA, it should have submitted its revised requirements for
approval, but it did not because there was confusion as to whether DHS
should be informed of all changes. Acquisition best practices state that
programs procuring new technologies with fluctuating requirements pose
challenges to agencies ensuring that the acquisition fully meets program
12AD 102 (effective November 7, 2008) and its associated instruction manual establish the
department's policies and processes for managing major acquisition programs. DHS
generally defines major programs as those expected to cost at least $300 million over
their respective life cycles, and many are expected to cost more than $1 billion. The ARB,
now called the Investment Review Board, is the cross-component board within DHS that
determines whether a proposed acquisition has met the requirements of key phases in the
acquisition life cycle framework and is able to proceed to the next phase and eventual full
production and deployment. Key performance parameters (KPP) are system
characteristics that are considered critical or essential. Failure to meet a KPP could be the
basis to reject a system solution.
13DHS's Undersecretary for Management issued a memorandum on November 7, 2008,
requiring compliance with the directive at the program's next formal decision point, but no
later than 6 months from the date of the directive (by May 2009). DHS acquisition officials
stated that enforcing compliance with the new policy took almost 1 year, but that it worked
with TSA to make the directive's requirements known. However, DHS's previous
directive-Management Directive 1400, which AD 102 superseded -also required
component agencies to follow a similar process whereby programs were reviewed by
DHS's Investment Review Board. Accordingly, the Investment Review Board began
reviewing TSA's AIT program (at that time called the Whole Body Imager) as early as
2008.GAO-13-469T
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United States. Government Accountability Office. Homeland Security: DHS and TSA Continue to Face Challenges Developing and Acquiring Screening Technologies, text, May 8, 2013; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc302906/m1/8/: accessed July 17, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.