DHS OIG, OIG-10-54, CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network (2010)

Department of Homeland Security Office of Inspector General CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network OIG-10-54 February 2010 Office of Inspector General U.S. Department of Homeland Security Washington, DC 25028 February 3, 2010 Preface The Department of Homeland Security (DHS) Office of Inspector General (OIG) was established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector General Act of 1978. This is one of a series of audit, inspection, and special reports prepared as part of our oversight responsibilities to promote economy, efficiency, and effectiveness within the department. The attached report presents the results of our review to determine whether U.S. Customs and Border Protection’s Secure Border Initiative Network contracting strategies will provide access to small business for the term of the contract. It is based on interviews with CBP employees, direct observations, and a review of applicable documents.

The recommendations herein have been developed to the best knowledge available to our office, and have been discussed in draft with those responsible for implementation. We trust this report will result in more effective, efficient, and economical operations. We express our appreciation to all who contributed to the preparation of this report. Richard L. Skinner Inspector General Table of Contents/Abbreviations Executive Summary .............................................................................................................1 Background ..........................................................................................................................2 Results of Audit ...................................................................................................................3 Recommendation ...........................................................................................................4 Management Comments and OIG Analysis ..................................................................4 Appendixes Appendix A: Purpose, Scope, and Methodology..........................................................6 Appendix B: Management Comments to the Draft Report ..........................................7 Appendix C: History of SBInet Performance in Meeting Small Business Goals…...12 Appendix D: Major Contributors to this Report .........................................................13 Appendix E: Report Distribution ................................................................................14 Abbreviations CBP DHS FAR SBI SBInet U.S. Customs and Border Protection Department of Homeland Security Federal Acquisition Regulation Secure Border Initiative Secure Border Initiative Network CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network OIG Department of Homeland Security Office of Inspector General Executive Summary We conducted this audit to determine whether Secure Border Initiative Network contracting strategies will provide access to small business for the term of the contract.

Federal Acquisition Regulation 19.702 requires agencies to provide maximum practicable opportunity in their contracts to small business, veteran-owned small business, service- disabled veteran-owned small business, small disadvantaged business, women-owned small business, and small businesses located in designated historically underdeveloped “HUBZone” areas. Customs and Border Protection faces challenges in meeting small business subcontracting goals for the remainder of the Secure Border Initiative Network indefinite delivery, indefinite quantity contract. A change in Customs and Border Protection’s acquisition strategy from acquiring technology to acquiring steel for border fence construction reduced opportunities for small business to participate in awards under the Secure Border Initiative Network indefinite delivery, indefinite quantity contract. In response, the prime contractor Boeing, has implemented initiatives to improve small business participation in Secure Border Initiative Network subcontracts to achieve its subcontracting goals.

Despite these initiatives, the contractor has not achieved the established goals for small business participation since the reporting period ended September 2007. We recommended that Customs and Border Protection continue monitoring Boeing’s efforts to identify and recruit small business in order to achieve established small business goals in the Secure Border Initiative Network indefinite delivery, indefinite quantity contract. Customs and Border Protection non-concurred with the recommendation. CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Background The Secure Border Initiative (SBI) program is a comprehensive, DHS-wide effort to secure the Nation’s borders.

A component of the overall effort is the Secure Border Initiative Network (SBInet), a major acquisition program initiated to gain operational control of the borders through improved use of technology, infrastructure, and personnel. To implement technology to monitor the border, the department awarded the SBInet systems integration contract in September 2006 to the Boeing Company (Boeing). The base period of the indefinite delivery, indefinite quantity (IDIQ) contract was three years. The Federal Acquisition Regulation (FAR) requires companies who bid on contracts valued over $550,000 to submit subcontracting plans with bid proposals.1 The subcontracting plans are required to establish small business goals in each applicable small business category and identify mechanisms to recruit small business.

Incorporated in the SBInet IDIQ contract with Boeing are small business participation goals. Strategies for achieving these goals are outlined in the Boeing Subcontracting Plan. Boeing has established an overall small business goal of 40% of the SBInet IDIQ contract. Within this overall goal are five small business subcategories with goals ranging from 1% to 5% for small business participation.

The Boeing Subcontracting Plan identified a Mentor-Protégé component, an outreach component, and a web-based registry component as means of encouraging small business participation in the project. The contractor is required to provide small business participation data twice annually at the end of the six month periods ending March 31 and September 30. 1 FAR 19.702. Statutory Requirements.

CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Results of Audit CBP faces challenges in meeting its small business participation goals for the remainder of the SBInet IDIQ contract. A change in CBP’s acquisition strategy from acquiring technology to acquiring steel for fence construction along 670 miles of the southern border significantly reduced opportunities for small business to participate in awards under the SBInet contract. This shift in border security strategy occurred in response to the Secure Fence Act of 2006. To meet the material needs of the fencing effort, CBP awarded the Supply and Supply Chain Management task order to Boeing.

Generally, since steel companies are inherently large businesses, this strategy shift to fence construction reduced opportunities for small business participation. CBP has taken steps to increase focus on small business participation in awards under the SBInet IDIQ contract to meet the challenge posed by the change in acquisition strategy. Specifically, the SBInet systems task order awarded in April 2008 more clearly focused on meeting small business goals in award fee calculations. CBP recruited knowledgeable contract specialists to monitor awards to small business.

To develop opportunities for subcontracting to small business given the reduced emphasis on system deployment, CBP also encouraged Boeing to identify small businesses that could provide steel mesh for fence construction. Despite these actions, awards to small business have not achieved the 40% goal since the reporting period ended September 2007. The trend for the last three reporting periods has been generally positive, showing a slight increase in small business participation. In March 2008, small business accounted for approximately 31% of subcontract awards.

As of the reporting period ended September 2009, awards to small business remained at approximately 34% of subcontracts, with awards to HUBZone and veteran-owned small business exceeding the subcontract goal. Nonetheless, overall small business participation has not met established goals. Appendix C provides a summary of small business participation in awards under the SBInet IDIQ contract since project initiation. CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Recommendation We recommend that the Commissioner, U.S. Customs and Border Protection continue monitoring Boeing’s efforts to identify and recruit small business in order to achieve established small business goals in the SBInet IDIQ contract.

Management Comments and OIG Analysis CBP’s Comments on Recommendation: CBP did not concur with the recommendation stating that it was unnecessary because it closely monitors small business subcontracting performance under the SBInet IDIQ contract as a matter of routine and robust contract administration. CBP’s response included examples which it claimed demonstrated that its subcontracting oversight program for the contract was adequate and exceeded requirements of federal acquisition regulations and routine contract administration guidelines. A copy of CBP’s written response is included in Appendix B. OIG Comments: The FAR requires the administrative contracting officer to assist in the evaluation of the subcontracting plan, and to monitor, evaluate, and document contract performance.2 CBP’s assertion that its oversight of Boeing’s subcontracting performance was adequate, and exceeded the requirements of federal acquisition regulations and routine contract administration guidelines is not evident in the agency’s achievement of its small business goals. Many of the examples provided are exercises that do not provide in-depth oversight of the small business contract monitoring and evaluation requirement, and do not document performance.

For instance, CBP’s response that reviews were conducted semi-annually to assess small business participation and recommend actions when appropriate often do not result in increased participation as evidenced by the approximately 38% decline in small business participation from September 2007 to March 2008. 2 FAR 19.706 Responsibility of the cognizant administrative contracting officer CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Other examples provided represent external assessments of subcontracting monitoring activity which also do not address actual subcontracting performance. CBP Comments: CBP also expressed concerns regarding our assessment of its achievement of its small business goals and our portrayal of Boeing’s small business goals and CBP agency wide goals in our recommendation. CBP stated that the OIG incorrectly reported small business achievements.

CBP stated that Boeing had exceeded small business subcontracting goals in October 2007. OIG Analysis: The reported data is correct. The timing, form, and mechanism for reporting awards to small business are prescribed in FAR 52.219.9 and section H.28 of the SBInet IDIQ contract. Awards to small business are reported at 6-month intervals ending March 31st and September 30th.

To clarify the reporting period, the Results of Audit section was revised to “Despite these actions, awards to small business have not achieved the 40% goal since the reporting period ended September 2007.” CBP Comments: CBP also commented that (1) the report recommendation mistakenly addresses the Boeing Subcontracting Plan small business goals and the agency’s small business goals; and (2) small business goals specified in the Boeing Subcontracting Plan are dictated by federal and department regulations which limits CBP’s authority beyond the implementation of mechanisms identified in the Boeing Subcontracting Plan. OIG Analysis: The SBInet IDIQ contract and the Boeing Subcontracting Plan were the focus of our audit. To clarify this issue, we revised references to “SBInet contracts” to “SBInet IDIQ contract”. We agree that the SBInet IDIQ is not the only procurement tool used to execute SBI.

CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix A Purpose, Scope, and Methodology The objective of our review was to determine whether Secure Border Initiative Network (SBInet) contracting strategies will provide access to small business for the term of the SBInet indefinite delivery, indefinite quantity (IDIQ) contract HSBP1006D01353. We interviewed government officials and reviewed information gathered at Department of Homeland Security (DHS), Office of Chief Procurement Officer and U.S. Customs and Border Protection (CBP) headquarters in Washington, DC, and at CBP’s National Finance Center in Indianapolis, IN. We developed an understanding of internal controls to provide access to small business in awards under the SBInet IDIQ contract by reviewing requirements of the Federal Acquisition Regulation and the Boeing Subcontracting Plan by interviewing small business and contract specialists at DHS and CBP. The understanding gained was used to plan the audit and determine the nature, timing, and extent of tests to be performed.

We conducted this performance audit between September 2007 and April 2008 under the authority of the Inspector General Act of 1978, as amended, and according to generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We updated information for the report to present small business participation in the SBInet IDIQ contract through September 2009 and to present recent improvement initiatives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix B Management Comments to the Draft Report U.S.I)~JW'UT1enl ofHomrluld Security w...hlngton. DC 20129 ~ ~ u.s. Customs and Border Protection MEMORANDUM FOR RICHARD L. SKINNER INSPECTOR GENERAL DEPARTMENTOrHOMELANDSECU~TY FROM: SUBJECT: f Executive D i t e e to r ( ) /Y ~, Office of Policy and Planmng U.S. Customs and Bordcr Protection Response to the Office of Inspector General's Revised Draft Letter Report Entitled, "CBP Faces Challenges in Achieving Its Goals for Small Business Participation in SBlnel" Thank you for providing us with a copy of the revised draft letter report entitled, "CBP Faces Chailenges in Acb.icving Its Goals for Small Business Panicipation in SBIner," and the opportunity to discuss the issues included therein. The report summarizes the results of the Office of Inspector General's (OlG) audit of smail business subcontracting achievements under the Secure Border Initiative's SBlner prime contract with the Boeing Company, and provides a recommendation for continued monitoring of Boeing's efforts 10 identify and recruit small business in order to achieve established small business goals in SBlner contracts. Summary CBP does not concur with the report's recommendation and does not agree with the report's conclusions and content.

Despite extensive and collaborative pre-draft coordination with the OIG on the results of the audit, the draft report continues to contain misstatement offacl and inaccuracies that are misleading regarding small business participation in the SBlnel prime contraet and Boeing's role rciated to small busincss participation in the SBI program as a whole. Of note, CBP has the following concerns: • The rccommendation, as wriUen, interchangeably uses subcontracting goals of the SBlnet indclinitc-delivery indefinite-quantity (IDIQ) contract and small business prime contmct goals of the agency as a whole. Small business subcontmcting and prime contrdcling gools, and regulations governing them, tire It/uf/llllly exclush'e. ACC(lrdingly, CBP cannot implement a portion oflhe recommendation as il extends beyond the SBlnel contracl awarded to the Boeing Company. • Moreover, small business goals, and how small business sel-asides are detennined and approved are dictated by federal and departmental regulations. CBP is required to follow CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix B Management Comments to the Draft Report 2 these regulations and cannot "contrace for Boeing to achieve the agency's or the S81 Program's small business goals. • The report's recommendation regarding continued oversight and monitoring by esp's Commissioner ofBocing's su!x:ontrdcting achievements is unnecessary.

CBP closely monitors small business subcontracting perfonnance under the SBlnellD1Q contract as a mallcr of routine and robust contract administration, • For these reasons. the reports findings do not logically support the reIXm's recommendation. esP's rntionale in support of its position follows below. Small Business I)articipation in the SBlne' Prime Contract Awards to small business have nollll:hieved the 40% goal required in the OIG Finding: SBlne/ systems integration contract since OClObcr 2007, The trend for the last three reponing periods have been genemlly positive, showing a slight increase in small busincss participation. In March 2008, small business accounted for approximately 31% of subcontract awards. A year later, awards to small business were approximatel)· 34% of subcontracts, with awards to veteran­ owned small business exceeding the subcontract goal.

Nonetheless, Boeing still needs to do more to achieve its small business panicipation goals. In October 2007 Boeing. in fact, exceeded its [t was in late December 2007 that small business CBP Response: The DIG correctly identifies several challenges the prime contractor faced in achieving its planned small business subcontracting goals on the SBlnel1D1Q contract. However, the DIG's data as reported is incorrect. small business subcontracting goals. subcontracting achievements under the COntract with the Boeing Company were impacted by a stmtcgic acquisition decision to purchase structural steel and inventory management services. This purchase providcd for structural steel, wire mesh panels, inventory management, storage and distribution of these materials to construction contractors completing 670 miles of fence along our nation's Southwest border.

I The decision to use the contract for this purchase was three fold: (1) the contract was pre-competed and allowed for this type of support; (2) it was the most cost effective and efficient means for acquiring and distributing these materials; and (3) it fuJly supported the agency in meeting the timeframe and mandate of the Secure Fence Act to expeditiously construct tactical infrasiructure in areas determined by the Border Patrol to be high areas of illegal cross border activi ty2. Moreover. as part of Boeing's suocontraeting efforts for the supply and supply chain management task order (SSCM) a good faith effort was made by the contractor to locate small businesses capable of supplying steel materials. Two small businesses were identified to provide steel mesh panels, and no smal1 businesses were available to supply the other structural steel components. This '".as due to both the nature of the market place and financial capabilities 1 Referred to herein and in contraci relat~d documents as the "Supply and Suppty Chain Management'" task order. 'The agency', determination ,uPIX'"ing the ex.,edilCd a....ard oflhe Supply and Supply Chain Management task a....ard is dlX:umented in the .ontral:l file.

CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix B Management Comments to the Draft Report 3 required to complete the work. The value of the small business subcontracts were -S28 million and the large business subconlnK:t -$237 million. Subsequent to the award oftbc SSCM task order in December 2007, small business subcontracting achievements have notably bun jmproving. Reference Table J ~SmQlI Business Goals and Awards as a Percenrage ojSB/nel SubconIrOCIS.

1 Task Ordef Awarded .J Supply & Supply Chaon - "OM.. ~ ....1% TIblf.l. Small Bulillf'SS Gub aid AlI"trdt III rffttO!ltf orSB~ Cattgol'- Onrall SmaU BUllrom SflKlfd S.bc.l!'lorif'S: Small Disarh-ama w_"""'" HURl.. VelefalKl~lICd Senlce-dis&bIed Go.l Mar 2007 "" S% S% 1% 3.5% J% 42% Jj% l% 3.5% 0.9% 0.1% Arla1l Mpt 2007 MJr 2008 ,,9% 68,6% un Stp12008 Mlr 2009 34.2% 34.7% 2.1% l.N '.9% 1% OJ% urI 1.4% 0.4% 13% 0.6% 13% 1.S% OJ% 3.2% 1% 1."/, 1.5% OJ'" 3.9% ,,% ~ = .~ w. ,.. When subcontrneling achievements IlU analyzed by both excluding and including the SSCM task order we find: 1. Exdusivc of SSCM: Boeing is in fact e:>.:ceeding the overall small business subconlracting goals by 1J.91%.

2. Inclusive or SSCM: Boeing is within 5,8% points of meeting the contract's overall small business subcontra<:ting goals ollly one )ltar aflu award oftlte SSCM tMk order, These results demonstrate both Boeing's commitment to attaining the ori~inally established goals, and the government's commitment to overseeing their altainment. Redirecting Work to Ensure Subcontracting Goals are Attained Given uncertain fimding and potential future changes in SBInet acquisition OIG Finding: strategy, CBP may also need to redire<:! its approach to increasing small business panieipation in SBlner contract. Pursuing alternative contract strategies, such as focusing efforts on deployment technology solutions on the nonhero border and subcontracting fence maintelUlJlce 10 small businesses on the southern border, should strengthen CBP's ability to increase small business access to and participation in SSlnel.

CBP Response: Although the SBlnel lDIQ contract is an important procun,:ment tool utilized by CBP, it is not the exclusive contract vehicle used by the agency 10 execute its Border Security CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix B Management Comments to the Draft Report 4 Fencing and Te\:hnology (BSFI1) funded initiatives. When using lhis contract CBP must weigh the benefits of competition and prime contract small business opportunities againsl1he skill sets. resources. and Icelmology that can be provided through the SBlne/ IDIQ contract. This fiscal year CBP has chosen to compete its fence maintenance contracts and to set-aside approximately half of that effort to both I [V8Z0NE and 8(a) construction contractors. CDP will benefit from the competitive environment. leverage the resources of contractors who have a construction and road maintenance skill SCI. and the procurement will benefit small business by providing opportunities al the prime contract level.

Similarly, eBP has chosen to compete and partially set-aside: a series of pilots thai may bring new commercialle\:hnologies to the border security community: its newest Northern Border demonstration project: and, its requiremcnt for mobile surveillance systems, The SBlnetlDlQ contract will be used to: complete planned integratcd technology deployments: t<,.'Chnology logistic and maintenance support services: tower-based technology deploymcnts along the northern border; and, continued SSCM ~rvices, Continued Oversight by CDP's Commissioner OIG Finding: Continucd oversight is needed to ensurc that the improvement initiatives and actions prescribed in the subcontracting plan will be sufficient to increase small business access 10 and participation in SBlllet for the remainder of the contract, CBP Response: As shared with the OIG team previously. thc following examples and documentation support our dctermination that thc subcontracting oversight program for thc contract is adcquate, and exceeds the requirements of federal acquisition regulations and routine contract administration guidelines: • • • eBP's Small Business Specialist and DHS's Office of Small and Disadvantaged Business Utilization (OSDBU) statc; "Since our im'oll'emem early-on with the SRlllel lDlQ comract, we hal'e found Ihe SRI Acqllisilio/l Office's ol'l!rsighl o1/the SBlllet lDIQ 10 be adequate, Further, we find 1/0 el'idence 10 show thm the prime con/ractor is nor making a goodfai/h ejJori/o meeling the subcolI/rlIcting phm requirements_ " Thc Defense Contract Managemem Agency (DCMA) provides CBP with independent oversight and reviews of Boeing's compliance and subcontracting efforts. DCMA has validatcd, consistently. the contractor's clC(:tronic Subcontracting Reporting System (eSRS) reports, and found that "Ihe contraclor has demons/rated a goodjaith effort 10 meet all ofih" goals and fulfills the reqlliremems ofits sllbcomracting plan and the regulations.··J CBP hosts semi-annual subcontracting reviews. To date DHS and CBP have panicipated in 5 semi·annual small business subcontracting revicw roundtables (2 during the review period). Participants in each meeting include the SI3l Acquisition Office.

CBP Small Business Specialist. and DHS OSDBU among others. During these revil;ws progress toward goal achievement arc discussed, assessed, and recommendations made toward J DCMA report dated Novembc:r 10, 2008. CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix B Management Comments to the Draft Report s improving small business subcontracting opportunities - .... here appropriate and necessary. • • • • • All semi-annual eSRS Subcontract Reports have been submitted, reviewed, and accepted in a timely manner by the Contracting Officer. Advarn;e and pre-award approval of all subcontract awards are conducted by the Contracting Oflker.

Of note, this approval process is flot required by the Federal Acquisition Regulation. or by known best practices. as the Boeing Company's purchasing system has been audited and approved by the Defense Contract Management Agency (DCMA). Although not required, CBP instituted this comrol to better manage and have insight into the conlractor's subcontracting activities. Review and assessment of Boeing's perfonnance againsllhc subcontracting plan is conducted semi.annually as pan of the award fee monitoring and evaluation of the Systems rask Urder (previously the Program Management task order). Boeing conducts quanerly diversity reviews with its existing subcontraclOr and supplier base to review performance against goals and identify opponunities to improve performance.

Additionally, Boeing conducts and panicipates in numerous outreach conferences and established a small business outreach program specifically for !he SBlllet program. This activity funher demonstrates the contractor's e!fons to engage small businesses in executing its contract requirements. These activities, controls, and independent assessments have been in place or have reviewed subcontracting activities since inception of the contrac!. Finally. the O[G has an imbedded team located in the program office that is afforded every opponunity to panicipate in any of the aforementioned activities to monitor - in real time Boeing's subcontracting performance should they have concerns not addressed by the current uv",r:.ight l>yl>t"'lll.

Given the rubu:.l mtlute ami em.:elln:nel>S ufCBP'l> uversight aelivitiel>. quancrly reponing by the Commissioner 10 the DIG on these activities is unnecessary and unproductive. ••••• In regard to the classification of the draft repon, COP did not identify any sensitive information that would require a "For Official Usc Only" designation or warrant protection under the Freedom of Information Act. If you have any questions regarding this response, please contact me or have a member of your statT contact Ms. Patricia Quintana. Program Analyst. Office of Policy and Planning. al (202) 344·1038.

CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix C History of SBInet Performance in Meeting Small Business Goals The SBInet systems integration contract was awarded in September 2006 to the Boeing Company (Boeing). The base period of the indefinite delivery, indefinite quantity contract was 3 years with three 1-year options. Boeing’s bid proposal contained a Subcontracting Plan that established small business participation goals as a percentage of overall subcontract awards. The Subcontracting Plan prescribed mechanisms Boeing would implement to ensure access to small business in SBInet contracts.

The following table reflects Boeing’s efforts over the past 3 years to achieve its small business participation through its Subcontracting Plan. Table 1. Small Business Goals and Awards as a Percentage of SBInet Subcontracts Category Overall Small Business Selected Subcategories: Small Disadvantaged Women-Owned HUBZone Veteran-Owned Service-Disabled Goal 40% 5% 5% 1% 3.5% 3% Actual Performance Mar 2007 Sept 2007 Mar 2008 Sept 2008 Mar 2009 Sept 2009 42% 68.6% 30.9% 34.7% 34.2% 34.3 3.5% 2% 3.5% 0.9% 0.7% 2.1% 2.3% 0.9% 1% 0.5% 1.3% 1.4% 0.4% 1.3% 0.6% 1.3% 1.5% 0.3% 3.2% 1% 1.4% 1.5% 0.5% 3.9% 1.2% 3.5 1.6 2.1 3.6 1.1 CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix D Major Contributors to this Report Alexander Best, Director, Border Security Division Inez Jordan, Desk Officer, Border Security Division Mark Ferguson, Project Lead Patricia Alcaniz, Auditor Yeseira Diaz, Auditor Raul Quintero, Analyst James Best, Independent Referencer CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network Appendix E Report Distribution Department of Homeland Security Secretary Deputy Secretary Chief of Staff for Operations Chief of Staff for Policy Acting General Counsel Executive Secretariat Director, GAO/OIG Liaison Office Assistant Secretary for Office of Policy Assistant Secretary for Office of Public Affairs Assistant Secretary for Office of Legislative Affairs Under Secretary for Management Chief Procurement Officer DHS Audit Liaison Acting Commissioner, Customs and Border Protection Executive Director, SBI Program Office Executive Director, SBI Acquisition Office OIG Liaison, CBP Office of Management and Budget Chief, Homeland Security Branch DHS OIG Budget Examiner Congress Congressional Oversight and Appropriations Committees, as appropriate CBP Faces Challenges in Achieving Its Goals for Small Business Participation in Secure Border Initiative Network ADDITIONAL INFORMATION AND COPIES To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig.

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