Tuesday, July 31, 2012

The Cost of an ICR

On Sunday I responded to a Reader comment about the abbreviated CFATS hearing before the House Appropriations Committee (it was billed as a Committee hearing, but only the Chair and Ranking Member of the Homeland Security Committee were present). I mistakenly ignored the Reader’s comment about the ire of Rep. Price (D,NC) about the cost of the ICR. I reasoned that the actual cost of preparing the ICR, even the crafting of the personnel surety program that the ICR supported, just could not be that high. After all, we are already paying for the salaries of the people who worked on writing the two documents. And they were obviously not doing anything else in any case.

Then I had a conversation with a long time Reader with connections to ISCD. That Reader informed me that ISCD had made payments to TSA in two fiscal years (I forgot to ask, but I assume FY 2010 and FY 2011) for services in support of the personnel surety program; payments probably in excess of $4 million. Cognoscenti will realize that TSA, who operates the Terrorist Screening Data Base (TSDB) is required to recoup the cost of TSDB checks by charging the requesting agency or individual for those checks.

What is interesting here is not that the money was misspent (while $4 million is a lot of money to most people, it really is small change to congressional spenders), but that it was misspent twice. When ISCD published their original detailed ICR notice describing how they intended to operate the program, industry responded with a firestorm of negative comments. At this point ISCD should have realized that there were problems with their proposed personnel surety program and started doing some revising. And they should have not made any pre-payments for TSA services until the program was closer to actual operation.

A year later (which should have been time to revise the program significantly) when the second notice was published, some revisions in details were made, but the main sticking points for both industry and labor remained the same. Like a spoiled child, ISCD essentially said, we want what we want and we are going to get it. The published responses to that were even less positive than the first batch. Who knows how bad the back-channel complaints to OMB were? Actually we can guess pretty well; they were severe enough and numerous enough for OMB not to take any action on the ICR.

Hopefully, when ISCD goes back to the drawing board on this program, they will start from scratch and develop a clean program that provides a mechanism for checking employees, contractors and unaccompanied visitors against the TSDB and allows for the recognition other programs (TWIC and HME for instance) that vet individuals against that database.

Then, when the ICR is approved, ISCD can make the appropriate payment to TSA. And perhaps the Secretary might want to give them at least partial credit for the unused checks that have already been paid for.

BTW: The Appropriations Committee has yet to re-schedule their hearing on the CFATS program.

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