SSP and RBPS Update – 04-27-09

After I posted the news Saturday that OMB has approved the RBPS Guidance document I had a chance to talk with some people that I know in the ‘industry’. Based on those discussions I thought I would take some time today to discuss what we can expect to see in the coming weeks. Publishing Documents First, I expect that DHS will put the final version of the RBPS on their web site this week. I understand that DHS will notify registered CFATS users when it is posted. As soon as I see it on the site, I’ll post that information on this blog. Needless to say I will also start doing my typical reviews of the new documents. At this point it is not clear if OMB made any changes to the document. If there had been large changes, I am sure that we would have heard about them by now. But there is a possibility that there were small changes made. Even small changes could delay the roll-out of the SSP Tool on CSAT; even something as small as changes in metric numbering could require SSP revisions. In any case the SSP tool will soon go online. At the same time as that is made available I would expect DHS to publish two manuals to accompany the SSP Tool. First there should be a copy of the questions asked in the SSP. Second there would be the ‘users manual’ for the SSP Tool. If the draft SSP Template that I have seen is any indication these two documents will be much larger than those seen for the Top Screen or SVA tools. Changes to the RBPS Guidance will be potentially even more of a problem for these documents. Tiering Notifications DHS has not yet notified facilities of the results of the evaluations of SVA’s that were submitted last year. This was because the receipt of the notification letters would start the clock on SSP completion. Since the SSP tool has not yet been made available the decision was made to hold those letters until the SSP did become available. DHS had intended to send the letters out in a risk-based staggered schedule. Tier 1 facilities would receive the letters first then the other tiers would receive their’s over the next few months. I expect that the same thing will still happen, but the original schedule will certainly change (the original schedule called for Tier 1 and Tier 2 letters to have already been sent by now). If I were DHS (what a thought) I would send out Tier 1 letters next week, Tier 2 the first week of June, Tier 3 the first week of August, and Tier 4 the first week of October. As soon as DHS announces their schedule, I’ll discuss it’s implication in more detail. Stay Tuned for Further Information