Detailed Information on the
Federal Emergency Management Agency: Targeted Infrastructure Protection Grants Assessment

Establish in FY07 the baselines and targets for its newly-created long-term, annual and efficiency measures. When possible, measures will be reported in FY07.

Grants and Training will develop a compliance policy that addresses award withholding and funding draw-downs for grantees delinquent in their reporting and monitoring requirements.

Grants and Training should begin collecting grantee performance information, develop analytical processes and report it regularly in a publicly-accessible forum for decision-making purposes.

Measure: Percent reduction in risk for grantees

Explanation:- The measure currently is specific to the grantee/facility level and may need revision to capture regional focus as program requirements change (e.g., shift from individual facility risk buy-down to port-wide risk buy-down) - Intended methodology is an aggregate percentage and un-weighted; however, weighting options warrant further consideration (particularly to the extent other component programs may be drawn under this measure)

Measure: Percent progress toward implementation of applicable strategies for IPP component programs

Explanation:- This measure currently applies only to the Transit Security Grant Program (TSGP), and is only applicable from FY2005 onward - Monitoring protocols will serve as the basis for verification and validation pending final review of monitoring protocols - The measure is contingent on newly developed methodologies

Measure: Vehicle/vessel security enhancement projects completed

Explanation:Infrastructure Protection Program's (IPP) component programs report on output measures only as they are applicable and allowable under the grant guidance. These measures reflect a core set of outputs common to most IPP component programs.

Measure: Facility/perimeter security enhancement projects completed

Explanation:Infrastructure Protection Program's (IPP) component programs report on output measures only as they are applicable and allowable under the grant guidance. These measures reflect a core set of outputs common to most IPP component programs.

Measure: Passenger security enhancement projects completed

Explanation:Infrastructure Protection Program's (IPP) component programs report on output measures only as they are applicable and allowable under the grant guidance. These measures reflect a core set of outputs common to most IPP component programs.

Measure: Training projects completed

Explanation:Infrastructure Protection Program's (IPP) component programs report on output measures only as they are applicable and allowable under the grant guidance. These measures reflect a core set of outputs common to most IPP component programs.

Measure: Average number of days from enactment to award grants after application approval from G&T

Explanation:This measure is subject to reconsideration and revision based on recent discussions.

Measure: Percent of projects per award period that address the risk-based national priorities identified in the applicable grant guidance

Explanation:Percent of projects per award period that address the risk-based national priorities identified in the applicable grant guidance. The Port Security Grant Program (PSGP), Transit Security Grant Program (TSGP), and the Intercity Bus Security Grant Program (IBSGP) are the current IPP component programs with the applicable grant guidance. Collect and analyze documentation of a given award period to determine whether applicable component program's projects address risk-based national priorities. Divide the number of projects determined to address these priorities by the total number of projects to yield the percent of projects that address the risk-based national priorities for inter-city bus security identified in the annual grant guidance.

Measure: Average number of days from transit sector grant application submission to funding allocation determination announcement. (New measure, added February 2008)

Explanation:Improving the timeliness of grant processing is an important component to GPD's effort to maintain their customer-focused and remain results-oriented. The timely processing of grants allows the grantees to spend the funds necessary to improve infrastructure and security programs for the benefiting state and local populations. Minimizing the amount of time it takes to process grants demonstrates the programs are employing strong grant management procedures.

Is the program purpose clear?

Explanation: Infrastructure Protection Program (IPP) component programs overall mission is to act as an "agent for the prevention and deterrence of threats, protection of assets, and response to terrorist incidents impacting security of the Nation's critical infrastructure through grants and other assistance." With this mission, the Infrastructure Protection Program aims to develop a standardized approach for the risk-based distribution, administration, and performance-oriented monitoring for infrastructure protection. Most components support the creation of locally-sustainable programs for the protection of key assets, employees, and residents from terrorism, especially explosives and non-conventional threats that would cause major disruption to commerce and significant loss of life. However, some components not requested by DHS are inconsistent with this purpose, directing funds to national organizations regardless of threat or need.

Evidence: - FY2006 Guidelines and Application Kit for TSGP, PSGP, TSP, and IBSGP - TISD Presentation at SE Regional Conference in Birmingham, Alabama - March 28, 2006.

Does the program address a specific and existing problem, interest, or need?

Explanation: the Infrastructure Protection Program (IPP) reflects the Department's understanding of the vast scope of infrastructure assets and security needs across the Nation, and the need to prioritize funding to protect assets based on threat, vulnerability, and consequence. Protection of transportation and buffer zone infrastructure assets, thus, has been a particular focal point for infrastructure protection grant funding. IPP components share a common objective of securing the Nation's critical infrastructure against terrorism and other security threats. A number of statutes and national policy directives call for sustained efforts to protect critical infrastructure. From these, a series of Homeland Security Presidential Directives (HSPDs) further outline the role of the Department of Homeland Security (DHS) in providing grants for critical infrastructure protection activities. The IPP program has made progress in integrating appropriate guidelines within current statutes and policy; however, the program has not resolved disparate visions for how Federal funding should leverage such improvements. The various statutes and policies have not delineated consistent principles to guide Federal infrastructure protection grant funding. As a result, some program components focus on infrastructure owners, both public or private; others focus on the role of surrounding local jurisdictions; and some supplement the resources of commercial entities. This remains a challenge for the program to address in ensuing years.

Evidence: - 2002 Homeland Security Act -Maritime Transportation Security Act (MTSA) - HSPD-7 Critical Infrastructure Identification, Prioritization, and Protection - HSPD-8 National Preparedness - HSPD-13 Maritime Security Policy - National Strategy for Homeland Security - National Strategy for Maritime Security - National Strategy for Transportation Security - National Infrastructure Protection Plan - National Preparedness Goal

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: The Infrastructure Protection Program (IPP) is the principal Federal program charged with providing grant funds to increase the security of critical infrastructure. Grant funds provided through IPP component programs are designed to support priority security enhancements??enhancements that state, local, or private sector stakeholders might not prioritize without targeted grant funds. IPP employs a variety of mechanisms to eliminate or prevent redundancy. All FY2005 and FY2006 IPP grant funds carry a non-supplanting condition, meaning they cannot replace or serve as a substitution for existing state or local funding. The Transit Security Grant Program Guidance specifically requires coordination of the Regional Transit Security Strategy with existing State and Urban Areas Security Initiative strategies to prevent funding overlaps. IPP also collaborates closely with other Federal stakeholders within the Department of Homeland Security (DHS) and the Department of Transportation (DOT) in developing the annual Program Guidance, thus ensuring that authorized grant expenditures for program components are not duplicative but leveraged across programs. Subject-matter experts from DHS and DOT partners are represented on the national review panels making grant award recommendations to program leadership. State Administrative Agencies and Homeland Security Advisors also coordinate during the review and approval process, assuring that IPP grants funding is not duplicative of other projects. The Buffer Zone Protection Program directs grantees to coordinate funding efforts with these grants, and other G&T funding.

Evidence: - FY 2005 Program Guidelines and Application Kit for TSGP, PSGP, TSP, and IBSGP - FY 2006 Program Guidelines and Application Kit for TSGP, PSGP, TSP, and IBSGP

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Despite the Department of Homeland Security's (DHS) FY2006 budget request, the Infrastructure Protection Program (IPP) is not currently appropriated as one integrated grant program, but rather as a collection of component, sector-specific programs (Transit Security Grant Program (TSGP), the Port Security Grant Program (PSGP), the Trucking Security Program (TSP), the Intercity Bus Security Grant Program (IBSGP); and the Buffer Zone Protection Program. The funding levels for each program are not based on an analysis of risk and need among sectors. DHS has requested that IPP be funded as one integrated program, called the Targeted Infrastructure Protection Program (TIPP), to allow the Department more flexibility in targeting and prioritizing grant activities. However, Congressional reluctance to fund an integrated program may partially be explained by the lack of a clearly delineated risk management framework that could guide funding decisions. DHS has made progress on a "risk analysis" framework, but only recently has it been robust enough to compare threat and consequence data across different types of infrastructure assets.

Evidence: - Congressional Research Service (CRS), CRS Report for Congress: FY2007 Appropriations for State and Local Homeland Security, February 17, 2006 - Congressional Research Service (CRS), CRS Report for Congress: FY2006 Appropriations for State and Local Homeland Security, June 16, 2005 - Office of Management and Budget (OMB), Budget of the United States Government Fiscal Year 2007

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: While the program funding structure is not optimal for the effective targeting of resources among infrastructure sectors, most of the componeent programs are effectively targeted towards specific beneficiaries in order to address the program's purpose and align with the National Priorities. For each component grant program, the DHS Office of Grants and Training (G&T) releases a detailed Program Guidance document that both outlines eligible beneficiaries and funding priorities. For FY2005 and FY2006, the Transit Security Grant Program (TSGP), Port Security Grant Program (PSGP), and Inter-City Bus Security Grant Program (IBSGP) use risk-based criteria to target grant funds to the owners and operators of critical transportation infrastructure. For example, the FY2005 PSGP used a risk formula to identify 66 port areas eligible for grant funding. In FY2006, the PSGP expanded its eligibility to the 100 most critical port areas as assessed through the U.S. Coast Guard's new Port Criticality List. Similarly, TSGP employs a risk formula to target funds toward critical rail transit, intra-city bus transit, and ferry transit systems. IBSGP targets grant funds to fixed route and charter bus systems servicing high-risk urban areas. PSGP, TSGP, IBSGP, and TSP all outline specific authorized expenditures which align to their respective priorities and ensure that awarded grants address each program's purpose. However, the intercity rail program and trucking security program are constrained by congresssional guidance to fund activity that supplant the responsibility of AMTRAK and the American Trucking Association.

Evidence: -FY2005 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP -FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The Infrastructure Protection Program (IPP) tracks two primary outcome-based performance measures: 1) Percent reduction in risk 2) Percent progress toward implementation of applicable strategies for IPP component programs These measures reflect goals of preventing and deterring threats, protection of assets, and response to terrorist incidents impacting security of the Nation's critical infrastructure. The first outcome measure captures the extent to which grant-funded activity have a measureable impact on an infrastructure assets vulnerability to attack and/or the associated consequences for local community. However, there are significant concerns whether current or planned DHS asset risk assessments would account for impact of grant-funded activity into account. The second outcome measure currently demonstrates the ability of grantees to implement goals and objectives identified in their strategies and grant agreements. Because these goals and objectives are aligned with national risk-based priorities, this measure may ultimately reflect the achievement of program objectives.

Evidence: As of yet, DHS has not provided any evidence that it collects such data consistently across the majority of IP programs, nor whether its risk assessment system can accurately measure the impact of gran-funded projects.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Because the Infrastructure Protection Program's (IPP) outcome measures were recently developed, the program is currently in the process of reexamining its initial targets and timeframes. For both measures, the IPP program is collecting and analyzing baseline data to inform the establishment of targets. Targets and timeframes will be reported in future PART submissions.

Evidence:

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The Infrastructure Protection Program (IPP) has established four annual performance measures that reflect progress toward the long-term goals of the program: Percent of vessel/vehicle security enhancement projects completed Percent of facility/perimeter security enhancement projects completed Percent passenger security enhancement projects completed Percent training projects completed Percent of projects per award period that address the risk-based national priorities identified in the applicable grant guidance These measures address the program's ability to align component programs' projects with regional and national risk-based priorities. While these lack consistency in their approach to managing risk, they contribute establishing a baseline of goals and objectives, and the extent to which they are addressed by grant funding.

Evidence:

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The Infrastructure Protection Program's (IPP) annual measures were established at the outset of FY 2006, at which point the program also established targets and timeframes for FY06-08 measures. The IPP program is collecting and analyzing baseline data to inform the establishment of future year targets and their integration into a broader risk-based structure.

Evidence: FY 2006 FYHSP

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The DHS Infrastructure Protection Program's (IPP) principal partners include state, local, and private sector grantees and sub-grantees and Federal interagency transportation infrastructure stakeholders. All IPP components' Program Guidance materials articulate the goals of the program, how program goals support broader Departmental goals (e.g. the Interim National Preparedness Goal), and how grant activities should contribute to and align with program and Departmental goals. In addition, Program Guidance materials lay out clear reporting requirements for grantees, including periodic monitoring "to ensure that project goals, objectives, timelines, budgets and other related program criteria are being met." In FY2006, the Office of Grants and Training has strengthened its monitoring protocols for IPP to collect more performance-related information to further ensure that grantees are supporting program goals. Following a reallocation of program oversight responsibilities in 2006, TSA and the US Coast Guard were assigned greater responsibility in setting goals and oversight for surface transportation and ports respectively. In addition, the Buffer Zone Protection Program is largely overseen by the Infrastructure Protection office. This dispersed program authority will require further consultation between DHS components and grantees on how IPP grant funding should be allocated and targeted. Some assset operators oppose an integrated grant program and risk management framework, strongly prefering 'stove-piped' allocations for each sector. Other stakeholders, such as the Coast Guard and port operators, believe Federal grants should fund private sector compliance with regulatory requirements, an approach not used for most other infrastructure sectors.

Evidence: - FY2005 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP - FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Major components of the Infrastructure Protection Program (IPP) have undergone, or are undergoing, comprehensive, independent evaluations. The Port Security Grant Program (PSGP), for instance, was the focus of a January 2005 Department of Homeland Security (DHS) Office of the Inspector General (OIG) report, a February 2006 OIG follow-up evaluation, and a December 2005 Government Accountability Office (GAO) report. The two OIG evaluations were broadly focused, examining the design and goals of the program, potential duplication of other programs, the roles and responsibilities of participating agencies, and the grant evaluation and selection process. GAO's report had a narrower scope than the OIG evaluations but still focused on PSGP's risk management strategy. The Trucking Security Program (TSP) is currently undergoing an OIG evaluation that is expected to be broad in focus and to be completed in late calendar 2006. Finally, the Office of Grants & Training has a multi-year program evaluation contract in place designed to provide comprehensive evaluations of all G&T programs, including the IPP. G&T anticipates initiating a comprehensive evaluation of all IPP components during FY 2007.

Evidence: - Government Accountability Office (GAO), Risk Management: Further Refinements Needed to Assess Risks and Prioritize Protective Measures at Ports and Other Critical Infrastructure, September 2005 - DHS Office of the Inspector General, Review of the Port Security Grant Program (OIG-05-10), January 2005 - DHS Office of the Inspector General, Follow Up Review of the Port Security Grant Program (OIG-06-24), February 2006

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The long-term and annual goals delineated in Sections 2.1 and 2.3 are newly established, and FY 2006 will be the first year they are used as performance measures. Consequently, no past budget request was explicitly tied to their accomplishment. Beginning in FY 2006 or FY 2007, conclusions on program performance, based on the DHS Infrastructure Protection Program's current efforts to collect and analyze data on accomplishment of the annual and long-term goals, will inform subsequent budget requests. Specifically, requests for funding will tie in goals of improving critical infrastructure protection, in accordance with sections 2.1 and 2.3 above.

Evidence: - FY 2006 Program Guidelines and Application Kit for TSGP, PSGP, TSP, and IBSGP

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Infrastructure Protection Program (IPP) is a component of the Nation's broader efforts to address emerging threats to critical infrastructure. IPP has taken steps to address deficiencies identified internally and by outside evaluations. Most significantly, IPP has reshaped the strategic purpose and structure of its transportation infrastructure security grants, improving risk-based formulas to target and prioritize grant funding. For instance, the division within G&T administering IPP has updated its mission description to align more clearly with national goals, directives and plans. Additionally national mode specific security priorities have been incorporated into program planning. Further, the program has worked to develop and refine long-term and annual performance goals and measures that align to risk-based priorities. The Department of Homeland Security's (DHS) Office of Inspector General (OIG) highlighted the positive impact of these strategic planning improvements on the Port Security Grant Program (PSGP). An OIG report noted that PSGP had implemented a series of twelve OIG strategic planning recommendations, concluding that, "DHS reshaped the program to make it more strategic, and risk-based."

Evidence: - TISD Presentation at SE Regional Conference in Birmingham, Alabama - March 28, 2006 - Department of Homeland Security Office of Inspector General OIG-06-24 Follow Up Review of the Port Security Grant Program - FY2005 Program Guidance for PSGP, TSGP, IBSGP, and TSP

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The Infrastructure Protection Program (IPP) collects a variety of information from its grantees and sub-grantees, though such information is focused on the execution of grant funding and projects, and is not well-linked to broader program measures and long-term goals. Sample information that IPP collects regularly includes: - Transit Security Grant Program (TSGP): TSGP grantees are required to develop a Regional Transit Security Strategy (RTSS) and then submit Biannual Strategy Implementation Reports (BSIR) which tie grant funds to implementation of RTSS goals and objectives. - Port Security Grant Program (PSPG), Intercity Bus Security Grant Program (IBSGP), and Trucking Security Program (TSP): PSGP, IBSGP, and TSP grantees are all required to submit biannual Categorical Assistance Progress Reports (CAPRs) that identify outputs purchased with grant funding. IPP also monitors legacy grant programs, previously administered by the Transportation Security Administration (TSA), to ensure compliance with TSA Office of Acquisition guidelines, G&T grant guidelines, and grant award special conditions. Programs subject to this monitoring include PSGP, IBSGP, and TSP grants awarded in FY04 and prior years. Programmatic monitoring activities for legacy grant programs include office-based and on-site reviews requiring grantees to substantiate adherence to program guidelines. IPP is able to use performance-based data to manage and improve the program in a variety of ways. IPP personnel also closely review RTSSs and performance reports as part of their management responsibilities. For example, IPP required several TSGP grantees to revise and resubmit RTSSs to ensure that these critical strategy documents met program standards.

Evidence: - FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP (Sec. VI.A) -G&T has not provided any reports to document that performance information is systematically consolidated and analyzed

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: The Infrastructure Protection Program (IPP) holds Federal managers and most program partners accountable for cost, schedule, and performance results. The Preparedness Directorate recently conducted a Performance Management Implementation course (MAX HR) for individual program managers and IPP program staff within the Preparedness Directorate now have organizational and individual performance goals aligned with the National Preparedness Goal and its associated National Priorities and program efficiency (e.g., award processing). Grant monitoring and reporting requirements are intended to hold grantees and sub-grantees accountable for performance results. All IPP component programs have clear grant reporting and monitoring requirements for all grantees and sub-grantees. G&T can withhold future awards and fund draw downs if grantees and sub-grantees are delinquent in their reporting and monitoring requirements, but has not provided specific documenation regarding grantees under this program. Further standardization of compliance oversight processes is an area for improvement. Additionally, past grant performance plays a role in future funding eligibility for the Port Security Grant Program, the IPP component with the highest number of funding cycles to date. Past grant performance is an area for strong consideration for other IPP component programs as they mature. Grant monitoring and reporting requirements serve to hold grantees and sub-grantees accountable for performance results. All IPP component programs have clear grant reporting and monitoring requirements for all grantees and sub-grantees. While IPP can withhold future awards and fund draw downs if grantees and sub-grantees are delinquent in their reporting and monitoring requirements, it has only a minimal systematic process for tracking compliance, and has not documented any specific actions taken to hold grantees accountable. Past grant perfomance does not play a consistent role in future funding eligibility throughout IPP's component programs.

Evidence: - FY 2005 and FY 2006 Program Guidance documents (required "project plan" file attachments) - Grant Monitoring Protocols for Legacy Transportation Grants, July 2005 - Department of Homeland Security (DHS), Preparedness Directorate: MAXHR Performance Management for Headquarters Employees March 17, 2006.

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: The Infrastructure Protection Program (IPP) has encountered difficulty in obligating grant awards on a timely basis. The process of drafting guidance for multiple grant programs and securing stakeholder input has taken up to 9 months. Grants are typically awarded in the 4th quarter. In FY 2005, Transit Security Grant Programs (TSGP) awards were obligated in July, and the Intercity Bus Security Grant Program (IBSGP) and Port Security Grant Program (PSGP) were obligated in September. Similar delays have occured in FY 2006. Once IPP obligates grant funding, grant Guidance and Application Kits direct allocation to local grantees. TSGP, for example, requires that the State Administrative Agency (SAA) allocate 97% of funding within 60 days of the receipt of funds. However, sub-grantees require additional time to commit grant funds to projects, over which G&T has little or no visibility. Grant application reviews and monitoring protocols seek to ensure that IPP funding reaches the intended target and is spent for the intended purpose. While national review panels examine grant applications to assess whether proposed projects align with key goals and priorities, this alone does not ensure appropriate use of grant funding. Grant monitoring and subsequent grant close-out procedures are intended to ensure that grantees spend funds appropriately, but program and finanical reporting are not integrated. The program can track the rate of funding draw-down, but cannot document more detailed financial compliance or project performance measures.

Evidence: -FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP -Monitoring Plan for Transportation Infrastructure Security Grants -FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP; -Grant Monitoring Protocols and Monitoring Plans -Initial BSIR report for TSGP and sample closeout report for PSGP (additions to initial PART submission)

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The Infrastructure Protection Program (IPP) provides grant funding to stakeholders in order to improve the Nation's preparedness to prevent, protect against, respond to, and recover from acts of terrorism and other disasters. Given this goal, the program faces a challenge in measuring and controlling efficient unit costs in preparedness. However, the IPP program has implemented a series of IT solutions and budget management processes that contribute to efficiencies and cost effectiveness in program execution. IPP demonstrates program efficiency through the deployment of a common information technology solution and administrative changes aimed at improving program cost effectiveness in program execution. For example, IPP component programs funded prior to FY 2005 were initially administered through a paper application and award process or through a single program-specific electronic grants system. However, beginning in FY 2005 all IPP components are now administered through a single electronic grants management system, thereby standardizing internal processes and improving administrative efficiency. Additionally, with the transfer of all grants administration functions for IPP component programs to the Office of Grants and Training (G&T) in late FY 2004, programmatic and financial responsibilities for grants administration are no longer handled by separate agencies within the Department. Further, G&T ensures that cost effectiveness is a key factor in resource allocation for projects undertaken through funding from IPP component programs. For instance, under the Port Security Grant Program (PSGP) and Intercity Bus Security Grant Program (IBSGP), all applicants are required submit a detailed budget that demonstrates cost-effectiveness in relation to each proposed project. Once these budgets are submitted, interagency National Review Panels composed of members from stakeholder programs are responsible for reviewing them to ensure they meet all cost requirements. The PSGP application process further includes field reviews conducted in coordination with the United States Coast Guard, Maritime Administration (MARAD) Regional Director, and associated State Administrative Agencies (SAAs) to determine whether projects are providing high potential for risk reduction at minimal cost. Likewise, the Transit Security Grant Program (TSGP) requires requires that the applicant address cost effectiveness as an evaluation factor for each individual proposed project to ensure that the project addresses a strategic regional transit security goal and that execution is conceived in a cost effective manner. Moreover, the Program Guidance for all IPP programs outlines allowable costs and expenditures and places a highly restrictive cap on grantee management and administration costs under the grant, ensuring that grant funds are used in a cost effective manner to meet direct, operational security enhancement needs.

Evidence: - FY2006 Program Guidance for PSGP, TSGP, IBSGP, and TSP - FY2005 Program Guidance for PSGP, TSGP, IBSGP, and TSP

Does the program collaborate and coordinate effectively with related programs?

Explanation: The Infrastructure Protection Program (IPP) has taken a number of steps to collaborate with key infrastructure protection stakeholders, however, these coordination efforts have not been effective in integrating program priorities or developing a consistent approach to reducing infrastructure risk. IPP component programs consult with related programs and critical infrastructure stakeholders during the formulation of grant Program Guidance. Interagency National Review Panels responsible for reviewing grant applications include individuals from stakeholder programs. However, senior officials with stakeholder agencies have expressed concern about a lack of consultation in finalizing this program guidance. Delays in achieving consensus have held up the release of program guidance. The Transit Security Grant Program (TSGP) also works collaboratively with other agencies and programs. The TSGP worked closely with the DOT's Federal Transit Administration to leverage FTS risk assessments into the program's risk management framework. However, other agencies have not conccurred with the effort to use Regional Transit Security Working Groups to help administer transit security enhancements. The Intercity Bus Security Grant Program (IBSGP) has also collaborated with Interagency partners from TSA and the Federal Motor Carriers Safety Administration (FMCSA) to develop its Program Guidance. These same program stakeholders are included in IBSGP's National Review Panel, which reviews grant applications and makes recommendations for awards.

Evidence: -FY 2005 and FY 2006 Concept Papers (and Concurrences) -FY 2005 and FY 2006 Program Guidance documents (concurrence messages, references to related programs operated by partners) and Fact Sheets -FY 2005 and FY 2006 Field Review Results (for PSGP) and documented National Panel results for other programs - FY 2006 Communications Strategies (addition to initial PART submission)

Does the program use strong financial management practices?

Explanation: Infrastructure Protection Program (IPP) grant management is provided by the Office of Grant Operations (OGO) in the Office of Grants and Training (G&T). For FY 2005 and prior years, the Office of the Comptroller (OC) in the Office of Justice Programs (OJP), Department of Justice (DOJ), had responsibility for financial management practices. The DOJ Inspector General has repeatedly identifed DOJ's grant management system as one of the Department's top ten management challenges, and, although OJP received an unqualified opinion for FY 2005, has been the subject of qualified financial statements. All IPP components' Program Guidance materials lay out clear financial management and reporting requirements for all grantees and sub-grantees. These financial management practices are in accordance Office of Management and Budget (OMB) and Government Accountability Office (GAO) circulars and guidance. However, the program does not have a consistent system for monitoring compliance. Furthermore, grant recipients that are subject to OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations and that expend $500,000 or more of federal funds during their fiscal year are required to submit an organization-wide financial and compliance audit report performed in accordance with OMB and GAO standards.

Evidence: - FY2006 Guidelines and Application Kit for TSGP, PSGP, TSP, and IBSGP -Office of Grant Operations (OGO) Financial Management Guide -Office of Justice Programs (OJP) Financial Guide - OJP FY 2005 Audit Results

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The Infrastructure Protection Program (IPP) has generally sound management practices and it assesses opportunities for improvement. As part of the Preparedness Directorate, IPP is participating in the Performance Management Implementation (MAX HR) process, seeking to better link the performance and goals of individual managers with broader programmatic performance and goals and outcomes. The consolidation of IPP components within the Transportation Infrastructure Division (TISD) in the Office of Grants and Training (G&T) is also a significant management improvement. All IPP components are now coordinated under one management structure with clear lines of responsibility, improving the overall administration of the program and enhancing collaboration among IPP components. IPP is also in the process of updating and revising its grant monitoring protocols in an effort to further improve the management and oversight of its grant funds. IPP has a series of mechanisms to ensure that program management issues are identified and addressed. IPP managers meet regularly with program personnel and participate in off-site management meetings, allowing management issues to be identified and addressed quickly.

Evidence: -Department of Homeland Security (DHS), Preparedness Directorate: MAXHR Performance Management for Headquarters Employees March 17, 2006. -FY2006 Program Guidelines and Application Kit for PSGP, TSGP, IBSGP, and TSP

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: Most IPP program components now combine a risk-based allocation with competition based on merit. The following programs are awarded based on an assessment of risk with a competitive element: Port Security Grant Program (PSGP): PSGP employs a risk-based formula to identify port areas eligible for grant funding. In FY 2005 and FY 2006, PSGP evaluated and ranked candidate projects according to their risk-reduction potential. While a risk-based formula was initially introduced in FY 2005, award of PSGP funds has been based on a competitive process from the inception of the program. Transit Security Grant Program (TSGP): TSGP identifies eligible transit systems and funding allocations using a risk-based formula, followed by a competitive process within risk-tiers. Designated individual transit systems within high-risk Tier I regions must compete for funding within the region. Further, Tier II regions must compete against each other for the funds allocated for Tier II. Intercity Bus Security Grant Program (IBSGP): IBSGP identifies eligible intercity and charter bus system operators based primarily on the provision of service to Urban Areas Security Initiative (UASI) jurisdictions. In FY 2005 and FY 2006, TSGP used a scoring process, outlined in the Guidelines and Application Kit, that evaluated candidate projects against a set of competitive, merit-based criteria. The following programs do not incorporate both risk and a competitive element: Buffer Zone Protection Program (BZPP): BZPP grant allocations are made to states based on an asset risk assessment and buffer zone protection plans. While states are required to follow DHS guidance in making sub-allocations, this did not require a competitive process. The Trucking Security Program (TSP) and Intercity Passenger Rail Security Program (IPRSGP) grantees were selected on a discretionary basis, and the selection process did not address risk or competitive merit.

Evidence: - FY 2005 and FY 2006 Grant Guidance

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: G&T has established a number of systems to monitor grantee activities, including regular grant performance and financial monitoring that provide sufficent knowlege of individual grantee actvities, but many challenges remain. IPP grantees and sub-grantees must regularly provide reports on both program performance (Bi-Annual Strategy Implementation Report (BSIR) or Categorical Assistance Progress Report (CAPR)) and financial performance (Financial Status Reports (FSRs)). However financial information and program information are tracked through different systems and not easily synchronized or reconciled. Program information is not well-linked to annual or long-term measures. IPP program staff conduct a limited number of office-based and onsite monitoring of its grantees. For FY 2006, IPP will conduct at least one office-based monitoring review for each grant award during the award's 30-month project period. IPP staff also conduct on-site monitoring as specified in an annual monitoring plan or as identified on an as-needed basis with approval from G&T management. Financial monitoring is conducted by a program manager using a checklist in the Office-based Monitoring Memorandum and is used to review the grantee's budget, payment requests, and reports in the context of the approved grant-funded activity. The program has made progress in integrating and standardizing reporting and monitoring processes, but challenges remain in linking project-level reporting to the specific capabilities in the interim National Preparedness Goal and Target Capability List, or to other infrastructure protection objectives. GAO and other reviewers have found that the current system does not track the extent to which grant-funded projects reduce asset risk.

Evidence: -Grant Monitoring Protocols for Legacy Transportation Grants, July 2005 -In Progress - revised grant monitoring protocols, with enhanced emphasis on tracking performance as well as implementation/project schedule -Samples of Desk Reviews and On-site Monitoring Reports

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: G&T currently does not make performance information available to the general public. While security-related concerns are a factor, the primary culprit is a lack of consistent, reliable data on the performance and impact of grant-funded projects. While available on a case-by-case basis, it is not systematically analyzed for internal reporting. The absence of any public information limits the ability of key stakeholders -- including government officials and asset owners -- to determine the effectiveness of the program.

Evidence:

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The Infrastructure Protection Program (IPP) is analyzing data to evaluate program performance through the program's agreed-upon outcome measures. These outcome measures were newly developed and reflect a strategic redesign of funded IPP components funded prior to FY 2005 and roll-out of additional program components beginning in FY 2005. In addition, G&T will be aggregating FY 2006 data for annual performance measures later this year for comparison to corresponding data from FY 2005 to gauge improvement. The results of these analyses will be provided in future PART responses.

Evidence:

Does the program (including program partners) achieve its annual performance goals?

Explanation: Because the Infrastructure Protection Program (IPP)'s performance measures were recently established (at the outset of FY 2006), the program is currently in the process of analyzing data to provide performance results. Preliminary analysis indicates that initial annual targets for FY06 are being met. Achieving targets in future years is contingent upon continued support from program partners that have been assigned oversight responsibility, particularly TSA and the US Coast Guard.

Evidence:

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: Increased use of risk analysis and competitive procedures has increased the relative cost of implementing the program and lengthened the awards process. In addition, the Infrastructure Protection Program (IPP)'s efficiency measures were recently developed. G&T is currently in the process of analyzing data on the current measures to determine the appropriate baseline for FY 06 and future years. The Administration has proposed integrating the disparate programs under a more integrated grant process, but stakeholder agencies have opposed this change and it has not been enacted.

Evidence:

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: There have been no evaluations comparing the Infrastructure Protection Program to other grant programs. However, G&T has made numerous enhancements to grant procedures inherited from other agencies, such as utilization of a web-based process and more consistent evaluation criteria. GAO has compared this program's risk assessment efforts to similar efforts in DHS, finding it less advanced that the US Coast Guard's, but more advanced than that of the Office of Infrastructure Protection. While a range of Federal programs support infrastructure protection, such as information sharing and regulatory efforts, their effectivness has not been compared to grants.

Evidence: - United States Government Accountability Office GAO-06-91 Risk Management Further Refinements Needed to Assess Risks and Prioritize Protective Measures at Ports and Other Critical Infrastructure December 2005

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The Government Accountability Office (GAO) and Department of Homeland Security's (DHS) Office of Inspector General (OIG) have conducted independent evaluations of the Port Security Grant Program (PSGP) within the Infrastructure Protection Program (IPP). These evaluations identified a number of significant issues, particularly in the Port Security Program, but indicated that G&T is making progress in improving the program's performance. The January 2005 OIG report made twelve recommendations based on concerns about program management, and strongly urged that PSGP implement five critical recommendations before proceeding with the next round of port security grants. The OIG concluded in a follow-up report of February 2006 that, "DHS implemented recommendations in time to improve the administration and effectiveness of the fifth and most recent round of port security grants." However, the IG report issued six other findings related to program management, and made no specific conclusions on the results of past grants. A December 2005 GAO report on risk management focused on the risk-based methodology utilized by the PSGP and compared it to risk management frameworks of the U.S. Coast Guard and Information Analysis and Infrastructure Protection (IAIP) within DHS. While the report noted areas for improvement, it also highlighted that PSGP had a "robust methodology for assessing risks at ports." The report noted that PSGP had made significant progress in conducting port-based risk assessments and improved its process for risk-based grant awards. The report also highlighted PSGP's improvements in identifying risk-based goals and objectives, but noted that much work remains in quantifying performance, synchronizing risk management, and refining basic policies and procedures.

Evidence: - Department of Homeland Security Office of Inspector General OIG-05-10 Review of the Port Security Grant Program January 2005 - Department of Homeland Security Office of Inspector General OIG-06-24 Follow Up Review of the Port Security Grant Program February 2006 - United States Government Accountability Office GAO-06-91 Risk Management Further Refinements Needed to Assess Risks and Prioritize Protective Measures at Ports and Other Critical Infrastructure December 2005