PALMS

DHS’ funding and payments for PALMS violated Federal appropriations law.  Specifically, DHS violated the bona fide needs rule in using fiscal year (FY) 2011 component funds in FYs 2012 and 2013 for e-Training services and PALMS implementation respectively, when the funds were not legally available for those needs.  As a result of the bona fide needs rule and purpose statute violations, DHS may also have violated the Antideficiency Act in FYs 2013 – 2015 when the Department augmented appropriations for the Human Resources Information Technology program with component funds. We made nine recommendations to address violations of Federal appropriations law and to improve controls to prevent such potential violations in the future.

We determined that DHS’ Performance and Learning Management System (PALMS) does not address the Department’s critical need for an integrated department-wide system.  As of October 2016, PALMS has not met DHS operational requirements for effective administration of employee learning and performance management activities.  In addition, the PALMS program office did not effectively implement the acquisition methodology selected for PALMS and did not monitor contractor performance.  Finally, between August 2013 and November 2016, the Department spent more than $5.7 million for unused and partially used subscriptions; incurred more than $11 million to extend contracts of existing learning management systems; and more than $813,000 for increased program management costs.  The Department also did not identify $72,902 in financial credits stemming from the contractor not meeting performance requirements.  The Government Accountability Office (GAO) also reported in its February 2016 report, GAO-16-253, that the Department experienced programmatic and technical challenges that led to years-long schedule delays.  We made seven recommendations to address the challenges with the PALMS acquisition and to improve future acquisitions.  The Department concurred with all seven of our recommendations.