We want to express our appreciation to the Office of Inspector General (OIG) for the time and energy it has invested in this very important subject. The OIG has done an admirable job reviewing a program that has been in a constant state of growth and evolution. Since you began your audit 18 months ago, the Office of Intelligence has grown from a staff of approximately 50 people to a Directorate of over 6,000 personnel with operational responsibility for all FBI intelligence activities. We appreciate your willingness to work with us to understand these changes, and your attempt to reflect them in your report.
As we discussed, many of the recommendations you have made could not have been implemented prior to the December 8, 2004, creation of the Directorate and the intelligence budget decision unit by Congress. We are now able to move forward on the key recommendations you have developed as a result of the audit and have already acted on many of them. We appreciate your recognition of our progress and value your recommendations to ensure continued progress.
We remain concerned about some elements in the report. We have previously conveyed these concerns to you in letter dated February 28, 2005. While the final report responds to some of our concerns, there are several issues we feel obligated to address here. We have also responded to each of the OIG’s recommendations.
- The use of anecdotal evidence.
In several instances, the report relies on anecdotal evidence to support its conclusions. Two instances cause us the greatest concern:
First, in the section on Analyst training, the report quotes a single guest instructor at the FBI’s College of Analytical Studies who “believes that the FBI has grossly underestimated” the investment in staff necessary to make the program work (p. 61). This single opinion forms the basis for an indictment that “the FBI has not invested sufficient resources” in its Analyst training program (p. 61). We note there appears to have been no attempt to include available information on the FBI resource investment in Analyst training in the report.
Second, in the section on the utilization of FBI Analysts, the report relies on several anecdotes to support the observation that Analysts complained about being assigned “much administrative work” and that “[m]any analysts told us that most intelligence analysts do very little analysis.” (p. 86) We are concerned with the apparent discrepancy between these anecdotal findings and the actual data generated by the OIG survey, which notes that:
- “The vast majority, 84 percent, of the analysts in our survey are satisfied with the work assignments they receive.” (p. 69)
- Only 10 percent of FBI Analysts spend more than 30 percent of their time in an average month working on administrative duties not related to their job responsibilities. (p. 131)
- “Seventy-three percent of the respondents to our survey rated their contribution to the FBI mission as ‘high’ or ‘very high’...[while] only four percent of the respondents rated their contribution as ‘below average’ or ‘low’.” (p. 65)
Finally, we would note that the lack of administrative support is not unique to the FBI, but is a problem that pervades the Intelligence Community. The recent report of The Commission on the Intelligence Capabilities of the United States Regarding Weapons of Mass Destruction found that “analysts across the board face declining administrative support.” (WMD report, p.424)
- The use of the number of intelligence products produced by Analysts as a performance metric.
We remain concerned with the OIG emphasis on intelligence report dissemination as an indicator of Analyst productivity. (p. 81) While the OIG report acknowledges that “the analyst position involves work other than disseminated intelligence products,” it places undue emphasis on them and betrays a fundamental lack of understanding of the range of work performed by Intelligence Analysts (IAs).
The production of reports is just one part of the intelligence cycle, and, therefore, just one measure of Intelligence Analyst performance. Analytical work also drives collection, source development, and supports investigations. As a result, we examine intelligence performance in four categories: analysis, sources, products, and Field intelligence operations. The number of intelligence products produced by each Analyst is just one of 27 different measures that we use to evaluate FBI intelligence operations.
- The suggestion that Analysts hired from within the FBI are less qualified than external hires.
On page 29, the report states that “new analysts who transferred from other positions within the FBI are less than half as likely to have an advanced degree and were less likely to have the desired military intelligence experience, intelligence community experience, be a Presidential Management Fellow, lived outside the United States, or have foreign language skills.” Two things about this statement cause us concern:
First, the FBI does not “transfer” personnel to the IA career field. All of the Analysts hired from other positions in the FBI go through the same application process as those hired from outside the Bureau. Even FBI Intelligence Analysts who want to transfer from Headquarters to the Field or from one Field Office to another must reapply to the Bureau and compete with outside applicants for these positions.
Second, there is an assertion that FBI employees hired into the IA position are less qualified that not further substantiated. The report says that “the analysts hired in the last three years have -- as a group -- superior qualifications. We believe the FBI should select the best qualified personnel available such as these recently hired external candidates.” (p. 29) The superior group that the OIG refers to includes Analysts who were selected from within the FBI. We have analyzed the educational attainment of external versus internal Analyst hires and found no evidence that internal “transfers” were less educated than the IA population as a whole.
The FBI applies the same hiring standards for all applicants to Analyst positions, regardless of whether they are currently FBI employees. FBI employees who have applied for and been hired into Analyst positions bring with them extensive knowledge and experience of FBI investigations, policies, procedures, and the FBI’s dual role as an intelligence and law enforcement agency. We believe that experience is of significant value.
- The assertion that the EAD-I is “pleased” with the Analyst turnover rate.
We ask only that this statement he put in context. On page xii of the executive summary, the report says ‘the FAD for Intelligence told us she was pleased with the 8 percent turnover rate in FY04 because she believes this rate compares favorably with the rest of the intelligence community.’ What EAD-I Baginski said is that she is pleased that the turnover rate has gone down from higher levels and appears to have stabilized at 8%. We believe it is important to continue our efforts to improve out retention of Analysts (as detailed in our response to the OlG’s recommendations). We also believe our current turnover rate compares favorably with other intelligence agencies.
- The lack of clarity on the fact that the single greatest cause of Analyst attrition is retirement.
We remain concerned that this point is insufficiently highlighted in the report. We believe it is important to note that fully 20% of the respondents to the OIG’s survey cited retirement as the reason they would leave the FBI (p. 102) - twice as many as the 10% who cited their work assignments, and more than twice as many as the 8% who cited a lack of respect or challenge in their jobs as a reason for leaving.
- The statement that enrollment in Analyst training is voluntary.
On page ix, the report states that “While all analysts are required to attend the basic course, actual enrollment is voluntary.” As stated in an 11/03/04 Electronic Communication (enclosed), attendance and enrollment in either the Analytic Cadre Education Strategy (ACES)
1.0 or ACES 1.5 course is mandatory for all Intelligence Analysts. ACES 1.0 is a 7-week mandatory in-residence course designed to satisfy core competency-based learning objectives for new Intelligence Analysts. ACES 1.5 is a 2-week mandatory basic course for more experienced FBI Analysts also focused on those same competency-based learning objectives.
- The conclusion that less than half of the FBI’s Intelligence Analysts were assigned to the Field Offices.
The balance of Analysts in the Field Offices to Analysts at Headquarters has shifted since the OIG began its audit. Now more than half of our Analysts are located in the Field, where, as the OIG noted, EAD-I Baginski believes “the intelligence is.” (p. 32)
In March 2004, there were equal numbers of Analysts in the Field Offices (620) and at Headquarters (620). As of March 24, 2005, there were 966 Analysts in the Field and 924 at Headquarters.
One reason for this shift is a concerted management effort to put our Analysts “where the intelligence is.” Another is that in March 2004, we lifted the GS-12 grade ceiling previously placed on IAs in the Field.
The FBI generally agrees with the OIG recommendations and we appreciate the OIG’s insights into how we might further improve Intelligence Analyst hiring, training, and retention. We are pleased to say that in many cases, we have ongoing initiatives that respond to the recommendations.
- Establish hiring goals for intelligence analysts based on: a) the forecasted need for intelligence analysts; b) projected attrition in the analyst corps; and e) the FBI’s ability to hire, train, and utilize intelligence analysts.
The FBI must base its hiring goals on the appropriated funds granted by Congress - we cannot determine how many Analysts we can hire without knowing our appropriations level. We agree, however, that our budget request to Congress for Analyst Funded Staffing Levels (FSLs) should be based on the forecasted need for Intelligence Analysts, projected attrition, and our ability to hire, train, and use Intelligence Analysts. We are working on a threat-based methodology for determining the number of IAs required (see recommendation 3 below) and are obtaining automated tools from the Office of Personnel Management (OPM) to better forecast needs based on attrition and other factors. Continued refinement of our hiring capability through our online automated hiring management system, QuickHire; automated forecasting; and better projection of resource requirements based on threat assessments will allow us to establish accurate hiring goals. However, it is Congress that ultimately decides the actual funded level, and that will determine how many Analysts we can hire.
- Assign applicants a point of contact at the FBI to answer questions during the application and background investigation process.
We agree and have addressed this recommendation in the following manner: Applicants are provided a point of contact only after they have received a conditional offer of employment. Because of the sheer volume of applications received, we believe it is impractical to do so prior to that point in the process. We rely instead on our online automated hiring management system, QuickHire, to notify applicants of the status of their applications before they receive a conditional offer of employment. Applicants are notified once when their application is received and again when it is referred to a specific division. We will examine adding a step to the process that informs applicants that their applications have been reviewed and no job offer will be made. Applicants can also use the online QuickHire system to check on the status of their application.
- Develop and implement a threat-based or risk-based methodology for determining the number of intelligence analysts required.
This is underway. We arc developing a multi-pronged approach to determine the “ideal” baseline of Intelligence Analysts based on the FBI Threat Assessment, Field Threat Assessments and other threat and/or risk data. The Future Threat Forecast is the first step in developing future operational requirements for all 181 programs, including the FBI Intelligence Program. We will also include intelligence sources and intelligence production against Director of Central Intelligence (DCI) priorities as factors in determining the Intelligence Analyst needs.
This new methodology will allow IAs to be migrated to an ideal baseline during FY05 and FY06. This baseline will serve as the foundation of a more robust methodology to determine future intelligence needs and will be reviewed and updated regularly. We note that this process could not have been established prior to the December 8 2004, enactment of the FY05 Omnibus Appropriations Act, which created an Intelligence budget decision unit under which all IAs are now funded.
- Develop and implement a threat-based or risk-based methodology for allocating intelligence analyst positions across the FBI’s headquarters divisions and field offices.
We agree and this is under way. As discussed above, the DI is developing a new Intelligence Analyst Allocation Process for allocating Analysts to Headquarters divisions and Field Offices based on maximizing the productivity and value of the Analysts to FBI operations. The Future Threat Forecast is the first step in developing future operational requirements for all FBI programs, including the FBI Intelligence Program. We will also include sources, both human and technical, and productivity (HQ and Field) as criteria or metrics to determine the number of IAs required as part of the Intelligence Analyst Allocation Process.
This methodology maximizes the overall value of the Headquarters division or Field Office contribution (in terms of productivity) to FBI operations by allocating the optimum number of IAs to each organizational unit, subject to the Funded Staffing level and other constraints.
- Link the methodology for allocating intelligence analyst positions to the Human Talent Requirements forecast.
We agree with the recommendation. In October 2004, in cooperation with industry human resources experts, we began the process of building “competency models” for the Intelligence Career Service, including selection and hiring, training and development, career development, retention, and Intelligence Officer Certification. These competency models were based on a survey of the entire Intelligence Analyst population at the FBI designed to identify IA competencies, capabilities, and needs. A competency is a cluster of related knowledge, skills and abilities needed to perform a specific job. These competencies correlate with job performance, can be measured against standards, and can be improved via training and development. Competency models allow for maximum reuse of human resources tools (testing, training courses, etc.) to assess and develop common requisite skills. Competency models also allow for the development of unique tools to assess and develop specialized skills.
The Intelligence Human Talent Requirements Forecast is an assessment of the characteristics of human talent required to support tile future FBI Intelligence Program. It will be based upon our competency models, the Future Threat Forecast, and the Operational Impact Assessment and will be produced annually. The Directorate of Intelligence will use the Operational Impact Assessment as the primary input for developing the Intelligence Human Talent Requirements Forecast and the Intelligence Information Technology Requirements Forecast.
Productivity measurement links the methodology for allocating IA positions to the Human Talent Requirements Forecast. The output of intelligence products can be increased by improving the skills of existing IAs or adding new IA positions. Obtaining the desired level of productivity (or IA value) requires determining the optimal mix of skills and number of IA positions, based on considerations such as cost, FSL and FBI intelligence priorities. The combined skill set and size of the IA cadre must he sufficient to meet the FBI’s information needs. The Human Talent Requirements Forecast enables the FBI to improve the critical skills and size of the cadre through education, training and recruitment.
- List the current FSL for intelligence analysts and any requested additions to this FSL in all budget documentation.
This has already been done. Since September 23, 2004, we have separately tracked the FSL of our intelligence Analysts. We will continue to ensure that all budget requests specifically identify Intelligence Analyst positions.
- Ensure that all ACES-1 courses are full.
We agree. This has already been done. An 11/03/04 Electronic Communication (EC) made attendance at Analytical Cadre Educational Strategy (ACES) classes mandatory for all Intelligence Analysts. We currently have more requests to attend ACES 1.0 classes that we can accommodate. ACES 1.0 classes are being attended at the maximum levels allowed by our classroom space - 48 students per class. Our goal is to train more than 1,000 IAs by the end of the calendar year 2005. By the end of April, 2005, more than 500 Analysts will have graduated from or be enrolled in ACES 1.0 or 1.5 training.
- Develop a more rigorous training evaluation system that includes the effectiveness and relevance of each instructional block; asks analysts what other topics need to be covered; obtains the views of analysts after returning to work when they can evaluate the effectiveness of the training in improving their job skills; and obtains evaluations of training effectiveness from analysts’ supervisors.
We agree. This is under way. The initial ACES classes offered in November and December 2004 were part of a rigorous pilot project that provided critiques and comments from students and instructors that led to rapid changes and improvements in the classes that followed.
Now, Analysts fill out evaluation forms after each ACES session rating the content of the class as well as the instructor. Senior DI executives also hold “feedback forums” with each class to hear, first-hand, student evaluations of the course. That feedback is provided to the Training modules. We will also conduct six-month follow-up surveys with Analysts after they return to work to evaluate the effectiveness of their training in improving their job skills - this is a standard process that the FBI’s Training and Development Division already follows with other courses. In addition, we will work with TDD to ensure more rigorous evaluations are put in place to provide objective perspectives on the effectiveness and relevance of ACES training from both Analysts and their supervisors.
- Develop a methodology to determine the number of staff needed to teach ACES-1 and a plan to staff ACES-1 with FBI personnel, including experienced FBI intelligence analysts.
We agree with the recommendation. Our Training and Development Division is in the process of developing a plan for staffing the Center for Intelligence Training, which includes ACES instruction. The staff will be a mixture of contractors, subject matter experts, and full-time FBI instructors. In addition, 33 FBI Intelligence Analysts are available to serve as adjunct faculty members. The plan is scheduled for completion by July 2005.
In addition, we are working with OPM to exercise Congressionally granted authority to designate critical intelligence positions at senior levels. We have reserved three of these positions for the Center for Intelligence Training.
- Integrate testing into the ACES-1 curriculum.
We agree with the recommendation. We will incorporate testing into the ACES 1.0 and 1.5 curriculum in FY06.
- Require all special agents to attend some mandatory training on the role and capabilities of intelligence analysts.
We agree. This is already under way. New Agent Training has been extended from 17 to 18 weeks, in part to incorporate more intelligence training into the curriculum. We developed 7 core learning objectives for training all new Agents in the intelligence discipline:
- FBI intelligence Mandates and Authorities
- Overview of the Intelligence cycle
- Introduction to the US Intelligence Community
- Intelligence Reporting and Dissemination
- FBI intelligence Requirements and Collection Management Process
- Role of Intelligence Analysts
- Validating Human Sources
We incorporated two of these objectives into the New Agents Training curriculum. Those competency-based learning objectives center on source development and the writing of raw intelligence reports. We are also holding special seminars to be attended jointly by both ACES 1.0 students and New Agent Trainees while at the FBI Academy. In addition, we are developing a joint practical training exercise in which new Agents and Intelligence Career Service personnel will work together to solve a case.
At the other end of the spectrum, mid-management level Agents and Analysts are participating together in a seminar designed by the Kellogg School of Management on Navigating Strategic Change. The two-and-a-half day seminar is focused on integrating the intelligence process into Bureau operations and brings mid-level Agent supervisors and mid-level Intelligence Center Service personnel together to work a series of case studies.
- Assess the work done by intelligence analysts arid determine what work is analytical in nature and what work is in general support of investigations that can more effectively be performed by other support or administrative personnel.
We agree. This is already under way. In March 2004, EAD-I Baginski established an Operations Specialist Working Group (OSWG) to assess the work performed by Intelligence Analysts in the Operation Specialist (OS) work role and establish a clear vision for that work. Through focus groups, work diaries, and interviews, the OSWG developed a comprehensive list of tasks and duties that are regularly assigned to OSs. Using OPM and FBI Administrative Services Division (ASD) guidelines, each task was reviewed and grouped by functional area: Intelligence/Analytic, non-Intelligence/Analytic, Administrative Support, and Intelligence Support. As a result, the OSWG recommended the following:
- Reassign program and case management work duties to Headquarters Supervisory Special Agents.
- Staff Operational and Sections as FBIHQ with Management and Program Analysts, GS-343 series (MAPA). MAPAs act as staff analysts, evaluators, and advisors to management on the effectiveness and efficiency of programs and functions. The primary function of the MAPA is to provide managers with objective information for making decisions on the administrative and programmatic aspects of operations and management.
- Staff Operational Units and Sections at FBIHQ with Program Assistants, GS-344 series (PAs). PAs perform clerical and technical work in support of management analysis and/or program analysis. PAs apply clerical and technical procedures, methods, and techniques to support management analysis functions and processes. PAs perform routine, procedural, or standard assignments.
- Focus Intelligence Assistant resources and efforts on intelligence-related duties. Intelligence Assistants perform support and clerical work in the field of intelligence. They apply their knowledge of administrative or clerical procedures peculiar to the collection, production, or dissemination of intelligence information.
- Increase FSL and lending to support the implementation of these recommendations.
- Continue these efforts across all IA work roles at both the Headquarters and Field Office level.
These recommendations are being implemented. In March 2005, EAD-I Baginski expanded the OSWG to incorporate IAs from all work roles - All Source, Reports officer, and Operations Specialists from all work roles All Source, Reports Officer, and Operations Specialists - to expand this work to all Intelligence Analyst work roles.
- Develop a strategic workforce plan for intelligence support personnel, and include in that plan a gap analysis of current investigate support personnel (by position) and the number (by position) the FBI needs to meet current and forecasted threats.
We agree with the recommendation and had a support workforce analysis completed by an outside consultant in 2004. That analysis documented the need for more administrative personnel across the FBI and was the basis for the FBI’s FY 2005 budget request for additional support personnel. In 2004 the FBI also developed a strategic Human Capital Plan using GAO’s four cornerstone model framework.
- Develop retention and succession plans and strategies for its intelligence analysts, including measurable goals.
We agree. This is under way. In the past, the FBI had difficulty retaining intelligence professionals for a variety of reasons, some cultural, and some a result of personnel policies that limited their career growth and compensation potential. Efforts made in recent years to evaluate the stature of FBI intelligence professionals have ameliorated that trend. We stabilized our attrition rate at approximately 8%, and FY05 statistics to date look promising. Our largest single cause of personnel loss is retirement.
The improvements are due in part to our efforts to provide intelligence professionals a forum to voice their concerns. In 2003, we created an Intelligence Analyst Advisory Board. leveraging the strong FBI culture of creating advisory groups to provide advocacy for specific career fields. Based on feedback received from this group we took actions such as establishing a mentoring program, establishing an annual Director’s Award tar Excellence in Intelligence Analysis and revamping our basic intelligence training program. At the same time Congress granted pay flexibilities that allow FBI intelligence professionals to be compensated at a rate equal to that of their peers in the Intelligence Community.
In October 2004, we conducted an IA Career Development Survey of over 1,200 Intelligence Analysts using scripted questions. We designed the survey to move from anecdotes about the qualifications and concerns of our intelligence professionals to hard data based on which plans of action should be developed. We completed the survey and analyzed its results. We have presented the results of the survey to our intelligence career service and are working with them develop action plans to address those concerns
In addition to the plans that result from the survey results, this year we will implement two key pay flexibilities authorized by Congress:
- Relief from Certain Pay and Position Classification Restrictions. This requires that we define grade and pay structures for the Intelligence Career Service. We will submit our plan to OMB and then to Congress and begin a phased implementation of the exemption this summer.
- Critical Pay Authorization will be implemented using a pilot of twenty positions: ten requiring critical subject matter expertise and ten executing critical intelligence enabling functions such as training, policy, legal analysis and information technology. Recruiting for these positions will begin this summer.
In addition, we will strengthen and enhance our Analyst mentoring program and create a web-based “Community of Interest” to provide a forum for collaboration and knowledge sharing among FBI intelligence professionals.
We are also implementing an Intelligence Officer Certification Program that will allow FBI intelligence professional to be eligible for certification by the DCI as Intelligence Community Officers. Intelligence Officer Certification is a credential that recognizes achievement in and long-term commitment to the intelligence profession as demonstrated through experience, education, and training. A certified FBI Intelligence Officer will be a recognized authority who has demonstrated in-depth knowledge and understanding of the national and international threat environment and the role of intelligence in informing tactical and strategic decisions on those threats. All Special Agents, Intelligence Analysts, Language Analysts and Surveillance Specialists are eligible for certification. Not all personnel occupying these positions are required to obtain certification, however, for certain management positions certification will be required including Directorate of Intelligence Executive Management, all ASACs, and all Section Chiefs serving in an operational or intelligence capacity.
We completed the Intelligence Officer Certification Program plan in December 2004. In 2005, our efforts will focus on executing the certification plan. Our goal is to name our first FBI Intelligence Officers in December 2005.
- Conduct exit interviews of intelligence analysts who leave the FBI entirely or transfer to other positions within the FBI.
We agree. This is under way. Currently, informal exit interviews are being conducted with immediate supervisors. The DI also plans to implement more rigorous exit interviews that will provide stronger data to attack the underlying causes of Analyst attrition.
Corporately, the FBI’s Administrative Services Division (ASD) is in the concept phase of developing an annual or biennial attitude survey that will cover all employees, including Intelligence Analysts. This will also include exit surveys timed to within 120 days following
departure, conducted by neutral third parties. The new surveys are scheduled to be implemented by the end of FY05.
