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entitled 'Defense Management: More Transparency Needed over the
Financial and Human Capital Operations of the Joint Improvised
Explosive Device Defeat Organization' which was released on February 6,
2008.
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
March 2008:
Defense Management:
More Transparency Needed over the Financial and Human Capital
Operations of the Joint Improvised Explosive Device Defeat
Organization:
Defense Management:
GAO-08-342:
GAO Highlights:
Highlights of GAO-08-342, a report to congressional committees.
Why GAO Did This Study:
Improvised explosive devices (IED) have been and continue to be a
significant threat to U.S. forces. The Department of Defense (DOD)
expanded efforts to defeat IEDs with the establishment of the Joint
Improvised Explosive Device Defeat Organization (JIEDDO) in January
2006. GAO was asked to review JIEDDO’s management and operations. For
this second report in its series, GAO determined (1) the extent to
which JIEDDO’s management processes provide adequate assurances that
its financial information is accurate and provides transparency over
its operations and (2) the extent to which JIEDDO identifies, records,
tracks, and reports numbers of all personnel, including contractors.
GAO analyzed data for the first half of fiscal year 2007, which
included 47 funding transactions totaling $1.34 billion for 24
initiatives to address these objectives.
What GAO Found:
JIEDDO’s financial management processes do not provide adequate
assurances that its financial information is accurate, and as a result,
JIEDDO is unable to provide full transparency over the cost of its
operations. While JIEDDO has improved its financial management
processes, it has not yet reached a point where those processes contain
an effective system of internal control. According to federal
standards, internal control comprises the plans, methods, and
procedures used to meet missions, goals, and objectives of an
organization and help it to achieve desired results through effective
stewardship of its resources. GAO identified four internal control
weaknesses that affect JIEDDO’s financial management processes. First,
JIEDDO has not comprehensively documented its administrative policies
and operating manuals, which affects the consistency of how its
financial management personnel perform their duties. Second, JIEDDO
does not have adequate funds authorization controls to ensure that
transactions are properly authorized before funds are committed. In
reviewing funding transactions totaling $795 million, 18 of 24
initiatives were not properly authorized in accordance with internal
control standards. As a result, funds may be used without proper
scrutiny and without a mechanism to detect, correct, or address this
control failure. Third, JIEDDO does not have controls to ensure that
transactions are properly categorized. For example, of the $1.34
billion in fiscal year 2007 commitments reviewed, JIEDDO inaccurately
categorized at least 83 percent of these dollars under one category
that should have been applied to others. This could distort information
used in assessing trends and prioritizing funds. Fourth, JIEDDO does
not have an adequate internal process to monitor and review the
efficacy of its internal controls. In the absence of an adequate system
of internal control, the agency may not achieve all of its objectives
and its use of resources may not be consistent with DOD priorities.
Furthermore, decision makers may be basing their decisions on
inaccurate financial data and reports. At the end of this review,
JIEDDO managers said that they had corrected these weaknesses; however,
because these actions occurred after audit completion, GAO could not
determine their effectiveness.
JIEDDO does not fully identify, track, and report all government and
contractor personnel as provided for in DOD Directive 1100.4.
Identifying all government and contractor personnel is important to
JIEDDO’s management and oversight responsibilities and contributes to
its ability to effectively plan for its future workforce needs. While
JIEDDO has a system in place for routinely tracking and reporting
numbers of personnel JIEDDO regards as staff, this system is limited
because it does not track all government and contractor personnel
performing work for JIEDDO. However, since its creation in February
2006, JIEDDO has relied heavily on contractor support to accomplish its
mission, which is not fully reflected in JIEDDO’s system. When the
Senate Appropriations Committee directed that JIEDDO provide a
comprehensive accounting of all of its personnel, including
contractors, by May 2007, JIEDDO had to rely on an ad hoc process to
develop the report, which resulted in several inaccuracies and
inconsistencies.
What GAO Recommends:
To help ensure that JIEDDO provides adequate transparency over its
resource use and addresses specific internal control weaknesses, GAO
recommends that JIEDDO develop an effective internal control system and
establish a means to identify, track, and report all personnel,
including its contractor support. DOD agreed with the thrust of all of
the GAO recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-342]. For more information, contact
William M. Solis at (202) 512-8365 or solisw@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
JIEDDO Has Taken Steps to Improve Financial Management Processes but
Lacks Effective Internal Controls to Provide Assurances That Its
Financial Data Are Accurate and Provide Transparency over Its
Operations:
JIEDDO Does Not Comprehensively Identify, Track, and Report All
Government and Contractor Personnel as Described by DOD:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Defense:
Appendix III: GAO Contact and Staff Acknowledgments:
Table:
Table 1: JIEDDO Descriptions of How to Calculate Initiative Value:
Abbreviations:
COIC: Counter-IED Operations Integration Center:
DFARS: Defense Federal Acquisition Regulation Supplement:
DOD: Department of Defense:
FMFIA: Federal Managers' Financial Integrity Act of 1982:
IED: improvised explosive device:
JCAAMP: Joint Improvised Explosive Device Defeat Capability Approval
and Acquisition Management Process:
JIEDDO: Joint Improvised Explosive Device Defeat Organization:
MIPR: Military Interdepartmental Purchase Request:
OMB: Office of Management and Budget:
PGI: Procedures, Guidance, and Information:
United States Government Accountability Office:
Washington, DC 20548:
March 6, 2008:
Congressional Committees:
When major combat operations for Operation Iraqi Freedom ceased in May
2003, U.S. and coalition forces transitioned to stabilization
operations. Since that time, U.S. forces have come under frequent and
deadly attacks from insurgents using such weapons as improvised
explosive devices (IED), mortars, and rocket launchers. IEDs also have
been a significant threat to U.S. forces operating in Afghanistan. The
Congressional Research Service recently reported that IEDs have caused
60 percent of all American combat casualties both killed and wounded in
Iraq and 50 percent of casualties in Afghanistan.[Footnote 1] The
Department of Defense (DOD) has described IEDs as the number one weapon
of strategic influence in the Iraq war and consequently has dedicated a
high level of resources toward countering the impact of IEDs and their
use by enemy forces.
In response to the threat posed by IEDs, DOD and Congress have provided
resources to fund efforts to defeat IEDs. From fiscal year 2004 through
the end of fiscal year 2007, $11.25 billion has been provided to
various DOD organizations to address the IED threat. For example, in
June 2005, the Deputy Secretary of Defense established the Joint IED
Task Force to lead DOD's efforts in fighting the IED threat with the
intent to establish a holistic approach to defeating IEDs, streamline
the processes for supporting the warfighter's efforts to counter IEDs,
and build a dedicated staff with an IED-defeat knowledge base. In
January 2006, the Deputy Secretary of Defense established the Joint
Improvised Explosive Device Defeat Organization (JIEDDO) to expand the
task force's scope by establishing a permanent organizational structure
to execute the IED defeat mission. In fiscal year 2007, Congress
appropriated about $4.35 billion for JIEDDO, and JIEDDO expects to
continue to receive additional funding through subsequent supplemental
appropriations to complete its fiscal year projects and begin new
projects.
Insurgents have adapted to U.S. countermeasures thus requiring JIEDDO
to continue to evaluate and analyze efforts to defeat them. Given long-
term fiscal challenges, congressional committees have expressed
concerns regarding JIEDDO's rapid growth in structure, scope, and
funding, and the extent to which DOD manages its resources to
efficiently and effectively defeat IEDs. In a series of reviews in
response to direction in Senate Report 109-292,[Footnote 2] we first
reported in March 2007 on several issues related to JIEDDO's management
and operations, including JIEDDO's lack of a strategic plan and the
resulting effects on the development of its financial and human capital
management programs.[Footnote 3] We made several recommendations to the
Secretary of Defense to improve the management of JIEDDO operations,
stressing the development of JIEDDO's detailed strategic plan. In this
second review, we determined to what extent (1) JIEDDO's financial
management processes provide adequate assurances that its financial
information is accurate and provides transparency over its operations
and (2) JIEDDO identifies, records, tracks, and reports numbers of all
personnel, including contractors. We are also conducting a third review
that examines JIEDDO's processes for coordinating counter-IED
intelligence support across DOD, which we will report on separately.
To address our objectives, we met with JIEDDO officials to gain a
general understanding of JIEDDO's management of financial resources and
personnel. To assess JIEDDO's financial management processes, controls,
and data, we analyzed 47 funding actions totaling $1.34 billion for 24
of the 301 initiatives JIEDDO had approved at the time we collected our
data. Nineteen of the 24 initiatives were those with the highest fund
commitments in JIEDDO's defeat-the-device and attack-the-network
initiatives based on the financial transaction data we collected. The 5
additional initiatives were those receiving Deputy Secretary of Defense
approval after our initial data collection date. We also identified
required approval controls over use of funds, reviewed these selected
transactions for adherence to these controls, and assessed whether the
data recorded in the accounting and managerial systems accurately
reflected JIEDDO's activities. However, we did not perform a
comprehensive assessment of all of JIEDDO's internal controls. To
assess JIEDDO's efforts to identify, record, track, and report numbers
of all personnel, including contractors, we collected and reviewed
JIEDDO staff reports and selectively compared the associated data with
corroborating sources to determine whether the reported figures were
comprehensive and accurate. We conducted this performance audit from
April 2007 to December 2007 in accordance with 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 believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Appendix I provides additional details on our scope and methodology.
Results in Brief:
JIEDDO's financial management processes do not provide adequate
assurances that its financial information is accurate, and as a result,
JIEDDO is unable to provide full transparency over the cost of its
operations. While JIEDDO has made progress in improving its financial
management processes, it has not yet reached a point where those
processes contain an effective system of internal control. Such a
system is required by federal laws and regulations and enables
organizations to provide accurate financial information for both
internal and external decision makers. According to federal standards,
internal control comprises the plans, methods, and procedures used to
meet missions, goals, and objectives of an organization and help it to
achieve desired results through effective stewardship of public
resources. We found that JIEDDO has four internal control weaknesses.
First, JIEDDO has not comprehensively documented its administrative
policies and operating manuals, which affects the consistency of how
its financial management personnel perform their duties. As a result,
we found inconsistent financial management control processes among
staff and managers. Second, JIEDDO does not have adequate funds
authorization controls to ensure that transactions are properly
authorized before funds are committed. Thus, JIEDDO made funding
commitments prior to obtaining required approvals, which underscores
the possibility that funds are used without the proper scrutiny of
authorizing agents and without a mechanism in place to detect, correct,
or address this control failure. For example, funding transactions--
totaling $795 million--for 18 of 24 initiatives we reviewed were not
properly authorized in accordance with internal control standards.
Third, JIEDDO does not have controls to ensure that transactions are
properly categorized. For example, of the $1.34 billion in fiscal year
2007 commitments we reviewed, JIEDDO inaccurately categorized at least
83 percent of these dollars under one category that should have been
applied to others. This could distort information provided in JIEDDO's
financial reports and affects its ability to accurately determine
trends in the use of funds in conjunction with its priorities. Fourth,
JIEDDO does not have an adequate internal process to monitor and review
the efficacy of its internal controls. For example, JIEDDO's process
used to assess its internal controls for its May 2007 annual statement
of assurance, submitted to DOD as required by the Federal Managers'
Financial Integrity Act of 1982 (FMFIA), resulted in several inaccurate
statements that were used as the basis for an unqualified statement
that JIEDDO's internal control system met federal standards. In the
absence of an adequate system of internal control, the agency may not
achieve all of its objectives, and its use of resources may not be
consistent with DOD priorities. Furthermore, decision makers may be
basing their decisions on inaccurate financial data and reports. JIEDDO
officials stated that their efforts to develop an effective financial
management program have been significantly challenged by turnover in
key financial positions and difficulties hiring adequate numbers of
qualified staff. They also said that JIEDDO has recently taken several
actions to address and correct these weaknesses. However, because these
changes have recently occurred and have not yet been fully implemented,
we have not been able to evaluate their effectiveness in improving
JIEDDO's internal control system. Therefore, we are recommending that
JIEDDO develop and document a comprehensive system of internal control
for its financial management processes that fully complies with federal
internal control standards, and routinely monitor its effectiveness
using internal audit staff. We are also recommending that JIEDDO report
to Congress on the status of its efforts to implement a comprehensive
system of internal control.
JIEDDO does not fully identify, track, and report all personnel,
including contractors, as described by DOD Directive 1100.4. This
directive provides that each DOD organization shall designate an
individual with the authority to maintain a manpower data system that
accounts for all manpower resources--including military, civilian, and
contractor.[Footnote 4] Furthermore, such an accounting helps internal
and external decision makers conduct effective oversight of personnel.
While JIEDDO has a system in place for tracking and reporting numbers
of personnel, this system does not track all government and contractor
personnel performing work for JIEDDO. For example, JIEDDO does not
track field service representatives, who are contractors providing
support for deployed counter-IED systems. From this limited system,
JIEDDO routinely accounted for personnel filling about 418 authorized
positions. In Senate Report 110-37, the Senate Appropriations Committee
directed JIEDDO to provide a comprehensive report of all of its
personnel, including all contractors, by May 2007.[Footnote 5] Because
JIEDDO does not have a comprehensive process to track all personnel, it
relied on an ad hoc process to develop the report. The results
identified a total of 1,466 personnel working for JIEDDO. However, we
were not assured of the accuracy of those figures in the congressional
report given the lack of guidance or evidence of a process that would
help to ensure reasonable accuracy in identifying and reporting all
categories of government and contractor personnel. When we reviewed the
report, we discovered inaccuracies in the data that led us to conclude
that at about 114 personnel had been omitted from the report. In
addition, we also noted that as it collected data for the report,
JIEDDO applied inconsistent criteria. For example, JIEDDO reported some
field service representatives as individuals and others as full-time
equivalents, which could account for more than one individual. Although
JIEDDO officials said that they do not consider all contractors as
staff, since its creation in February 2006, JIEDDO has relied heavily
on contractor support to accomplish its mission. For example, JIEDDO
has employed contractors to perform such tasks as evaluating initiative
proposals from outside contractors and operating unmanned aerial
vehicles. DOD Directive 1100.4 states that it is DOD policy that
manpower requirements be established at the minimum levels necessary to
accomplish mission and performance objectives. It follows that a
manpower data system that accurately accounts for all personnel,
including contractors, enables manpower management that promotes
efficient and effective use of manpower resources. Furthermore, such
accounting helps congressional decision makers and JIEDDO management
conduct effective oversight of personnel. Therefore, we are
recommending that JIEDDO establish a method or system to
comprehensively identify, track, and report on a routine basis all
personnel, including all levels of contractor support.
In written comments on a draft of this report, DOD concurred with our
findings and the thrust of our six recommendations. With respect to our
fifth recommendation as originally stated in our draft report, which
was to report on JIEDDO's efforts to implement internal control
improvements as part of JIEDDO's recurring quarterly congressional
reports, DOD instead proposed a report that provides this information
to the Armed Services and Appropriations Committees 1 year after the
issuance of our report, which satisfies the intent of our
recommendation. Consequently, we modified our original recommendation
to reflect this change. DOD also provided additional information on
several activities it has undertaken to date. DOD's written comments
are reprinted in appendix II.
Background:
JIEDDO was created by the Deputy Secretary of Defense in January 2006
and is responsible for leading, advocating, and coordinating all DOD
efforts to defeat IEDs. Prior DOD efforts to defeat IEDs included
various process teams and task forces. For example, DOD established the
Joint IED Defeat Task Force in June 2005 for which the Army provided
primary administrative support. This task force replaced the Army IED
Task Force, the Joint IED Task Force, and the Under Secretary of
Defense, Force Protection Working Group. To focus all of DOD's efforts
and minimize duplication, DOD published new IED policy in February 2006
through DOD Directive 2000.19E, which changed the name of the Joint IED
Defeat Task Force to JIEDDO and established it as a joint entity and
jointly manned organization within DOD, reporting to the Deputy
Secretary of Defense. The directive states that JIEDDO shall "focus
(lead, advocate, and coordinate) all Department of Defense actions in
support of the Combatant Commanders' and their respective Joint Task
Forces' efforts to defeat Improvised Explosive Devices as weapons of
strategic influence." The organization is directed to identify, assess,
and fund initiatives that provide specific counter-IED solutions, and
is granted the authority to approve joint IED defeat initiatives valued
up to $25 million and make recommendations to the Deputy Secretary of
Defense for initiatives valued over $25 million. Under the directive,
the Army remains the organization's executive agent and is responsible
for providing primary administrative support to JIEDDO.
JIEDDO's primary role is to provide funding to the military services
and DOD agencies to rapidly develop and field counter-IED solutions.
Prior to fiscal year 2007, JIEDDO did this by working with the DOD
Comptroller to transfer its appropriated funds into a standard DOD
appropriation account, such as one for procurement or one for research,
development, testing, and evaluation. JIEDDO would then send these
transferred funds to the military service that is designated to sponsor
the initiatives using a Military Interdepartmental Purchase Request
(MIPR).[Footnote 6] Beginning in fiscal year 2007, Congress provided
JIEDDO with its own separate direct appropriation, but it still must
transfer funds to the military services using a duly authorized and
signed MIPR, which the Defense Federal Acquisition Regulation
Supplement (DFARS) Subpart 208.7004 (Procedures, Guidance, and
Information (PGI) 208.7004) states is the acquiring department's
authority for acquiring the goods or services on the requiring
department's behalf.[Footnote 7] DFARS PGI 208.7004 also states that
the acquiring department, or military service, is then authorized to
create obligations against the funding without further referral to the
requiring department--JIEDDO--and that the military service has no
responsibility to determine the validity of an approved MIPR.
Therefore, after JIEDDO provides funding authority to the military
service and the designated program manager for a specific initiative,
the service program manager, not JIEDDO, is responsible for managing
the initiatives for which JIEDDO has provided funds.
JIEDDO's efforts to counter the use of IEDs and subsequent funding for
those efforts are organized according to three primary lines of
operation: (1) attack the network that enables the use of IEDs, (2)
defeat the IED itself once emplaced, and (3) train the military forces
in counter-IED techniques. JIEDDO assigns all funds used to one of
these lines of operation--or to a fourth line of operation called staff
and infrastructure for miscellaneous expenditures not directly related
to the three lines of operation. When JIEDDO undertakes any effort
requiring funds, it assigns the funds for the effort to one of the
lines of operations. JIEDDO further breaks down its expenditures into
more detailed subsets, which it designates as initiatives, assigning a
name and a unique number to track expenditures related to each
initiative. JIEDDO manages and reports on all funds expended by line of
operation and by initiative.
Office of Management and Budget (OMB) Circular A-123 specifies that
federal agencies have a fundamental responsibility to develop and
maintain effective internal control that ensures the prevention or
detection of significant weaknesses--that is, weaknesses that could
adversely affect the agency's ability to meet its objectives.[Footnote
8] According to OMB, the importance of management controls is addressed
in many statutes and executive documents. A memorandum from the OMB
Director to the heads of the executive departments accompanying OMB
Circular A-123 as an attachment requires agencies and individual
federal managers to take systematic and proactive measures to develop
and implement appropriate, cost-effective internal controls for results-
oriented management. FMFIA establishes the overall requirements with
regard to internal control. Accordingly, an agency head must establish
controls that reasonably ensure that (1) obligations and costs are in
compliance with applicable law; (2) funds, property, and other assets
are safeguarded against waste, loss, unauthorized use, or
misappropriation; and (3) revenues and expenditures applicable to
agency operations are properly recorded and accounted for to permit the
preparation of accounts and reliable financial and statistical reports
and to maintain accountability over the assets.[Footnote 9] Specific
internal control standards underlying the internal controls concept in
the federal government are promulgated by GAO and are referred to as
the Green Book.[Footnote 10]
In March 2007, the Senate Appropriations Committee directed JIEDDO to
identify and track all civilian, military, and contractor personnel in
the organization.[Footnote 11] In addition, DOD Directive 1100.4,
"Guidance for Manpower Management," provides that DOD components shall
designate an individual with the authority to establish and maintain a
manpower data system that accounts for all manpower resources, to
include active military, DOD civilian, reserve component, contract, and
host-nation support.[Footnote 12] The Senate Appropriations Committee,
in its report on emergency supplemental appropriations, expressed
concern over JIEDDO's exponential personnel growth and ability to track
this growth.[Footnote 13] The report stated that the committee has
limited visibility into current staffing and future staffing
requirements and is concerned that JIEDDO is not accounting for certain
contractor support properly. As a result of these concerns, the
committee directed JIEDDO to provide a report to the congressional
defense committees on current staffing levels and future staffing
requirements, broken down by function, contractor, civilian, military,
and detailed from other agencies, and should include all contractor
support that is provided through various contracts. The committee
further directed JIEDDO to update this report whenever JIEDDO personnel
authorizations change. In response to the committee's direction, JIEDDO
officials developed the JIEDDO Manning Description in May 2007
identifying and accounting for civilian, military, and contractor
personnel working for JIEDDO.
JIEDDO Has Taken Steps to Improve Financial Management Processes but
Lacks Effective Internal Controls to Provide Assurances That Its
Financial Data Are Accurate and Provide Transparency over Its
Operations:
JIEDDO has made progress in improving its financial management
processes but has not yet reached a point where its processes contain a
system of internal control that ensures the accuracy of its financial
data related to resources it has used in its operations. According to
federal standards, internal control comprises the plans, methods, and
procedures used to meet missions, goals, and objectives of an
organization and help it to achieve desired results through effective
stewardship of public resources.[Footnote 14] In addition, our prior
work has stated the importance of organizations addressing internal
control weaknesses.[Footnote 15] Otherwise, organizations may not
achieve their objectives or may not use their resources to best
advantage in achieving their objectives. Before beginning fiscal year
2007 operations, JIEDDO took several steps to improve its processes for
managing and controlling its financial resources, and JIEDDO has been
proactive in responding to financial management issues we raised during
this audit by pursuing additional financial management process
improvements. Nonetheless, JIEDDO is lacking an effective system of
internal control that will provide adequate assurances of financial
data accuracy and operations transparency. Although JIEDDO added
changes toward the end of our review that are expected to address
internal control weaknesses, their implementation occurred too late for
us to determine their effectiveness. Nonetheless, in the absence of an
adequate system of internal controls, inaccurate financial data and
reports may negatively affect the internal and external decision-making
process.
JIEDDO Has Taken Steps to Improve Its Financial Management Processes:
JIEDDO has taken several steps to improve its financial management
processes. JIEDDO's actions are divided into (1) those taken in
preparation for the beginning of fiscal year 2007 operations and (2)
those taken to develop and continually improve on its operations.
JIEDDO's approach for fiscal year 2007 included three changes aimed at
streamlining and reducing data processing and analysis. The first of
these changes was that JIEDDO took direct control of accounting
functions previously performed by Army activities in support of JIEDDO.
This allowed JIEDDO to directly execute and oversee funds budgeted and
made available to JIEDDO. Second, JIEDDO requested and received a
separate appropriation exclusively for its efforts, without having to
obtain approval for funds through other DOD funding streams. Third,
JIEDDO developed a procedure for assigning distinct numbers to specific
initiatives because some initiatives were referred to by more than one
name. The assignment of numbers eliminated confusion over the name of
the initiative and facilitated the automated transfer of data, which
was not possible using only a descriptive name.
JIEDDO's more recent actions were taken as part of its efforts to fully
establish its organizational framework as the organization evolves and
to continually improve its processes. These actions include issuing an
internal written instruction describing the roles and responsibilities
of JIEDDO subdivisions in greater detail; developing internal controls
imbedded in a new automated document management and storage system; and
establishing a new internal control audit function to be staffed by
three persons, reporting directly to the JIEDDO Director. While these
actions could address JIEDDO's internal control weaknesses, they have
not yet been fully implemented and occurred too late for us to
determine their effectiveness.
JIEDDO Lacks Effective Internal Controls to Provide Assurances That Its
Financial Data Are Accurate, and JIEDDO Is Unable to Provide
Transparency over Its Operations:
JIEDDO does not have an effective internal control system in place to
ensure that its financial data are accurate, and without such
assurances, JIEDDO is unable to provide adequate transparency over the
cost of its operations. The ability of JIEDDO to provide accurate
financial information for internal and external decision makers depends
on management accountability and an effective system of internal
control. Consistent with federal standards, JIEDDO would need to
adequately document its financial management processes and procedures,
including related internal controls, and the internal control system
would contain basic elements providing assurance that proper
authorization is obtained before using funds and that once a
transaction occurs it is accurately and promptly recorded. Furthermore,
developing adequate oversight mechanisms within JIEDDO is a key factor
in developing the conscientious control environment required by federal
standards. However, although our review was not designed to identify
all significant deficiencies in internal control, we identified four
weak control areas at JIEDDO, which individually and collectively
precluded adequate assurances of accuracy and usefulness of financial
data produced by JIEDDO's financial management operations. JIEDDO does
not have (1) comprehensive documentation of its internal controls, (2)
adequate funds authorization controls, (3) sufficient controls to
ensure accurate categorization of transactions, and (4) an adequate
process to monitor and review its internal control program.
First, JIEDDO's internal control processes related to its financial
management are not adequately documented as required by government
internal control standards.[Footnote 16] Specifically, JIEDDO has not
developed management directives, administrative policies, or operating
manuals that comprehensively describe how JIEDDO financial management
personnel should perform their duties and the internal control
activities designed to assure management that those duties are timely
and accurately performed. As a result, we found inconsistent financial
management control processes among JIEDDO staff and managers. For
example, while DOD's JIEDDO directive divides approval authority for
JIEDDO initiatives between the Deputy Secretary of Defense--initiatives
valued at greater than $25 million--and JIEDDO itself--initiatives
valued up to $25 million, DOD did not adequately define in its
directive the terms initiative or value with respect to which
initiatives measure over or below $25 million. Not defining terms would
affect interpretation for both those with approval authority and those
making processing and authorization control decisions. As a result,
when determining whether an initiative should be forwarded to the
Deputy Secretary of Defense for approval--a key external authorization
control--or whether the authority rests within JIEDDO itself because
the value does not exceed $25 million, various JIEDDO officials and
contractors provided us with varying descriptions for value
determination (see table 1 for a listing of varying descriptions).
However, any of these approaches could significantly change an
initiative's value calculations and consequently affect JIEDDO's
approval control decision process. In November 2007, JIEDDO issued an
instruction that included further guidance on how to determine what
constitutes an initiative for the purposes of requiring approval by the
Deputy Secretary of Defense.[Footnote 17] However, this instruction has
not yet been incorporated into financial management operating
procedures to ensure that staff understand the definition and apply it
consistently when processing transactions. According to JIEDDO
officials, the instruction, while better documenting the initiative
determination and approval processes, does not provide adequate detail
to constitute sufficient standard operating procedures for the
components of JIEDDO. JIEDDO officials added that they have planned to
form internal teams in the upcoming months to develop the more detailed
operating procedures JIEDDO components need to implement this
instruction.
Table 1: JIEDDO Descriptions of How to Calculate Initiative Value:
* Only costs[A] included on individual purchase request to a military
service.
* Only costs associated with an individual activity or program office.
* Only costs to be incurred by JIEDDO within 1 fiscal year.
* Only costs to be incurred within the fisca1 year, regardless of which
organization funds the initiative.
* All costs to be incurred by JIEDDO over the life of the initiative,
until termination or management transfer to one of the military
services.
* All costs incurred over multiple years, regardless of which
organization funds the initiative.
Source: GAO analysis of JIEDDO descriptions.
[A] Costs include goods and services to develop, purchase, field,
maintain, and sustain the initiative.
[End of table]
Second, JIEDDO's internal control system does not have adequate funds
authorization controls to ensure that transactions are properly
authorized before committing funds, which is a fundamental control
activity required by government internal control standards.[Footnote
18] We reviewed 24 initiatives of which 18 had funding transactions
totaling $795 million that were not authorized in accordance with the
process that JIEDDO officials said should take place in advance of the
commitment of funds on initiatives valued at greater than $25 million.
JIEDDO officials stated that approval of the Deputy Secretary of
Defense had to be obtained before funds could be committed on
initiatives valued at greater than $25 million. Fourteen of the 18
initiatives received the required Deputy Secretary of Defense
authorization after JIEDDO financial management personnel committed
funds by approving the MIPR to transfer funds from JIEDDO to the
external program manager for the initiative. For example, JIEDDO spent
about $8 million in the first quarter of fiscal year 2007 for an
initiative that it expected would, overall, require $57 million for
that fiscal year. Since that overall amount exceeded the $25 million
value determination that requires the approval of the Deputy Secretary
of Defense, JIEDDO acted before obtaining required authorization.
JIEDDO did obtain Deputy Secretary of Defense approval for this
initiative, but it was approximately 3 months after JIEDDO had
committed funds for this initiative. In another case, the financial
management division initially refused to commit funds for one
initiative exceeding $25 million until JIEDDO management obtained
approval from the Deputy Secretary of Defense. However, JIEDDO
management's response was to request funds for only one quarter's
expenses, thus reducing the amount to under $25 million. According to
documentation in the file, the financial management division then
agreed to fund the amount and commit the funds, even though it was
aware that total program costs exceeded $25 million for the fiscal
year. Subsequently, JIEDDO's legal advisor determined that the project
was not an initiative because it was considered part of JIEDDO's
infrastructure costs and thus did not require approval by the Deputy
Secretary of Defense. Nevertheless, although JIEDDO eventually decided
approval was not required, the process for approving funds for this
project demonstrates a breakdown in the internal control structure
necessary to ensure proper authorization before funds are spent, since
JIEDDO officials avoided obtaining approval even though they thought
prior approval was required. Additionally, it is not clear whether 4 of
the 18 initiatives were authorized prior to commitment of funds because
authorization letters were not dated, making the time of authorization
unverifiable. It is clear, however, that inconsistent with JIEDDO
processes, officials within JIEDDO made several funding commitments
prior to obtaining the approvals required by JIEDDO processes. This
underscores that JIEDDO's system of internal control allowed funds to
be committed without the scrutiny of authorizing agents. Furthermore,
the system did not detect, correct, or address this control failure.
Third, JIEDDO internal controls do not ensure that its transactions are
properly categorized, in spite of federal internal control standards
requiring that accurate transaction recording be ensured by an entity's
internal control system.[Footnote 19] For example, JIEDDO used about
$216 million on an initiative titled "CREW --USMC - Program Management
Support (Contractor Salaries, Travel & Infrastructure)," recording the
expenditure as management and professional support services. However,
the $216 million actually funded the purchase of tangible equipment--
IED jammers--and therefore should have been recorded as procurement of
equipment instead. Overall, of the $1.34 billion in fiscal year 2007
commitments we reviewed, JIEDDO inaccurately recorded at least 83
percent of the dollars committed--involving 15 of the 24 initiatives we
reviewed--as management and professional support services, when other
categorizations should have been applied by JIEDDO financial managers.
JIEDDO's system of internal control also does not ensure that all
transactions are accurately recorded in the proper JIEDDO lines of
operation, and this could distort reported expenditures on these lines
of operation. A key part of JIEDDO's overall strategy to manage
operations is to code various initiatives to reflect one of four JIEDDO
lines of operation to track success in achieving the overall goal of
increased effort to attack the IED network. According to officials,
JIEDDO policy is to assign a single line-of-operation code to each
initiative even when operations overlap, which may result in the
reported funding for a given line of operation being inaccurate. For
example, JIEDDO's initiative involving the testing of counter-IED
devices (constituting $92 million in fiscal year 2007 funds) was coded
as an attack-the-network effort, when our analysis indicates that the
initiative more accurately represents JIEDDO's defeat-the-device line
of operation. When originally established, JIEDDO coded its testing
efforts as staff and infrastructure, which reflects general overhead
incurred by JIEDDO, and reported the initiative as such in its second
quarter congressional report. However, subsequently JIEDDO recoded the
initiative and reported it as an attack-the-network initiative in its
third quarter congressional report. We found four other instances of
JIEDDO recoding initiatives in the attack-the-network line of
operations that also affected the third quarter report. JIEDDO
officials explained that the recoding was based on a JIEDDO decision to
code or recode any nondirect overhead staff and infrastructure
initiatives as attack-the-network initiatives. They did not have
supporting documentation reflecting JIEDDO's decision to recode.
Documented directions would serve to track the rationale for how this
line of operation was coded and recoded. The blanket assignment of
direct overhead costs to the attack-the-network line of operation,
along with reassigning lines of operation after initial recording
affects JIEDDO's ability to accurately determine trends in the use of
funds in conjunction with its attack the network objective. Further, in
the case of the testing operations, funding for attack the network is
overstated because, according to JIEDDO officials, the majority of
testing operations can be attributed to other lines of operation.
Fourth, JIEDDO's internal process to monitor and review the efficacy of
its internal controls is inadequate. The first federal government
internal control standard, relating to an entity's control environment,
includes having oversight mechanisms present within the agency as a key
factor in accomplishing a conscientious control environment.[Footnote
20] However, JIEDDO appeared to lack adequate mechanisms to monitor and
review its internal control program during the period of our audit. In
a May 2007 internal control report that JIEDDO prepared for the annual
DOD internal controls assurance statement, JIEDDO described its process
for assessing its controls and, based on that assessment, stated that
it was able to provide an unqualified statement of reasonable assurance
that its system of internal controls met federal internal control
objectives.[Footnote 21] However, we found several inaccurate
statements in the report that were used as the basis for this
conclusion, raising questions about the adequacy of JIEDDO's process
for assessing its internal control system and determining reasonable
assurance. For example, the financial management section of the report
cited four final audit reports from the Air Force Audit Agency, DOD
Program Analysis and Evaluation, the DOD Inspector General, and GAO.
According to JIEDDO, these reports said the organizations reviewed
JIEDDO financial management for activity beginning in fiscal year 2004
and did not have findings or recommendations. However, two of the
reports cited do not exist (those for the Air Force Audit Agency and
DOD Program Analysis and Evaluation), and the DOD Inspector General
report focused on assessing controls over the Army's purchases from
other government activities, not on JIEDDO's internal control system.
Further, that report concluded that the Army did not have adequate
internal controls over purchases from governmental sources, which
included one JIEDDO fiscal year 2006 expenditure, because the Army did
not ensure that expenditures were properly initiated, prepared,
executed, and monitored.[Footnote 22] Lastly, the GAO report cited is
the predecessor to this review, and it concluded that JIEDDO's lack of
a strategic plan limits JIEDDO's ability to properly align its resource
use and management to achieve JIEDDO-wide goals.[Footnote 23] The
report, however, did not provide any assessment of JIEDDO's internal
control system.
Another question about the adequacy of JIEDDO's internal control
assessment process and related assurance report concerns JIEDDO's
statement that training of its staff has improved internal controls.
However, some of the individuals who actually prepared feeder sections
of the report had not received any training on internal controls or how
to assess them. Further, some of these individuals are not familiar
with the internal control standards and the structured internal control
risk assessment. We did not assess JIEDDO's stated basis for reasonable
assurance of its internal control standards in its entirety because of
the inaccuracies found relating to resource management and training
sections of the report and because JIEDDO's report did not identify the
significant control weaknesses we found, such as JIEDDO's noncompliance
with authorization controls and inaccurate classification of
expenditures.
As evidenced by these four weaknesses, in the absence of an adequate
system of internal control the objectives of the agency may not be
fully achieved and its use of resources may not be fully consistent
with DOD priorities. Furthermore, decision makers may be basing their
decisions on inaccurate financial data and reports. JIEDDO officials
stated that their efforts to develop an effective financial management
program have been significantly challenged by turnover in key financial
positions and difficulties hiring adequate numbers of staff. In
discussing these internal control findings at the end of our fieldwork,
JIEDDO managers said that they have taken several actions to address
and correct these weaknesses, which we noted previously. JIEDDO
believes that these actions have already improved the internal control
weaknesses found; however, the changes are still in the early
implementation stages, and as such, we have not been able to evaluate
their effectiveness in improving JIEDDO's internal control system.
JIEDDO Does Not Comprehensively Identify, Track, and Report All
Government and Contractor Personnel as Described by DOD:
JIEDDO does not fully identify, track, and report all government and
contractor personnel as provided for in DOD Directive 1100.4.
Identifying all government and contractor personnel is important to
JIEDDO's management and oversight responsibilities and contributes to
its ability to effectively plan for its future workforce needs. DOD
Directive 1100.4 states that it is DOD policy that manpower
requirements be established at the minimum levels necessary to
accomplish mission and performance objectives. It follows that a
manpower data system that accurately accounts for all personnel, to
include contractors, enables manpower management that promotes
efficient and effective use of manpower resources. While JIEDDO employs
various DOD policies to manage civilian and military personnel, these
policies do not include accurately accounting for all of its personnel,
as described in DOD Directive 1100.4. According to JIEDDO personnel
officials, JIEDDO applies existing DOD policies to address
administrative issues, such as performance, pay, and leave. JIEDDO also
refers to the Federal Acquisition Regulation that includes personnel
policy and procedures that are specific to the acquisition and
management of services by contract. Additionally, JIEDDO issues policy
letters as needed to clarify personnel management issues. For example,
JIEDDO issued policy letter #16A that directed the division chiefs to
be aware of the number of hours all employees, including contractor
personnel, were working, and directed all employees to report all hours
worked and obtain approval for their schedules from their supervisors.
Nonetheless, these approaches do not identify, track, and report all
military, civilian, and contractor personnel.
JIEDDO officials track civilian, military, and some contractor
personnel on a daily basis to identify personnel currently staffed and
determine positions remaining to be filled; however, this effort does
not track all personnel performing work for JIEDDO. For example, JIEDDO
does not include some or all of personnel in the following categories:
* contractors working as field service representatives,[Footnote 24]
* contractors engaged as interagency liaisons,
* contractors providing law enforcement training,
* contractors involved in JIEDDO's interagency partnership team,
* civilians and contractors from JIEDDO's Joint Test Board,[Footnote
25] and:
* contractors maintaining infrastructure at the Counter-IED Operations
Integration Center (COIC) facilities.
Personnel officials said that these data are collected to identify
changes in JIEDDO's on-hand strength as personnel leave or are newly
assigned and are not intended to be a comprehensive data collection. We
reviewed JIEDDO's daily report from October 9, 2007, which shows that
JIEDDO had 321, including civilian, military, and some contractor
personnel, out of 418 authorized positions.
The Senate Appropriations Committee directed JIEDDO to provide a
comprehensive report of all of its personnel by May 2007, and because
JIEDDO does not have a comprehensive process to track all personnel, it
relied on an ad hoc process to develop the report. The results
identified a total of 1,466 personnel working for JIEDDO, as compared
to the 321 personnel filling 418 positions routinely tracked by the
organization in its daily snapshots. The figures in the report to
Congress tripled the number of personnel overall and showed a ratio
between contractor and government personnel of nearly 5 to 1 when
compared with the figures in the daily snapshots.
We were not assured of the accuracy of those figures in the
congressional report given the lack of guidance or evidence of a
process that would indicate reasonable accuracy in identifying and
reporting all categories of government and contractor personnel. JIEDDO
officials also said that the organization lacked procedures for
identifying and tracking all of its personnel. When we reviewed the
report, we discovered inaccuracies and inconsistencies in the data that
led us to conclude that about 114 personnel had been omitted from the
report:
* 25 civilian positions and about 30 contractor personnel with the
Joint Test Board, all funded by JIEDDO since JIEDDO funds all of the
board's operations costs, including these positions, and:
* 59 contractor personnel working as field service representatives who
were not included for one initiative but were reported in JIEDDO's
funding documentation.
In addition, we also found 67 personnel who were not reported in the
body of the report but were reported in JIEDDO's summary schedule of
personnel, and 9 additional authorized intern positions that were
included in the report but were not included in JIEDDO's daily
snapshots.
When accounting for personnel, different divisions may have applied
inconsistent criteria as they collected data for the May 2007
congressional report because JIEDDO officials did not provide formal
guidance to the divisions on how to report some personnel. For example,
JIEDDO officials said that they could not tell whether the 474 field
service representatives reported reflected actual individuals or full-
time equivalents, which could represent more than one individual. At
the conclusion of our review, JIEDDO officials were still unable to
clarify this issue. In addition to the fact that the figure could be
higher or lower, JIEDDO officials further explained that the reported
field service figure of 474 was inaccurate because JIEDDO subsequently
determined that the number for one initiative included in the data
contained a significant error.
JIEDDO had no means to track and verify the accuracy of its figures
presented in the May 2007 report because officials did not maintain
adequate supporting documentation representing how they arrived at
their figures. For example, when JIEDDO accounted for field service
representatives, we asked JIEDDO officials for clarification on how
they arrived at the number of contractors they reported. However, they
could not explain adequately because they did not document the process
and their recollections were admittedly incomplete. Without adequate
supporting documentation, JIEDDO cannot provide assurance that the data
it reports are accurate. Furthermore, with change of personnel, which
is typical within JIEDDO, new personnel would have difficulty
determining the accuracy of figures as well as what process to follow
to prepare subsequent reports.
Although JIEDDO has not routinely tracked all of its contractors, it
has relied heavily on contractor support to accomplish its mission
since its creation in February 2006. According to JIEDDO officials,
this reliance on contractors was attributed to the lengthy and complex
civilian hiring process, the inability of the military services to fill
all of the services' authorized positions, and the urgency of the
organization's mission. Contractors have performed a broad range of
labor and services for JIEDDO. Examples of functions contractors have
performed include:
* evaluating initiative proposals from outside contractors,
* piloting unmanned aerial vehicles,
* managing a division's efforts to develop useful metrics,
* conducting virtually all of the day-to-day management of the various
functions at the COIC, and:
* providing equipment maintenance and logistics support in theater for
new initiatives.
In addition to playing significant roles in accomplishing JIEDDO's
mission, contractors have also held critical positions within JIEDDO
management and might have had a significant influence on its decision
making. In the recent past, JIEDDO employed contractor personnel for
positions the organization designated as inherently governmental. OMB
defines an inherently governmental function as one involving the
exercise of substantial discretion in applying government authority,
making decisions for the government, or both.[Footnote 26] JIEDDO
personnel documentation showed that the organization had staffed
contract personnel in positions of key governmental responsibility, and
officials stated that the organization is in the process of resolving
this practice. In July 2007, JIEDDO officials began transitioning
government personnel--primarily temporary military staff--into these
positions that until recently were held by contractors. According to
JIEDDO officials, the organization is moving toward filling these
positions with permanent government personnel.
JIEDDO officials said that they did not believe tracking all contractor
personnel was necessary because they are not considered JIEDDO staff,
and consequently, JIEDDO has not developed a comprehensive process to
identify, track, and report all personnel in accordance with DOD
policy. However, without a comprehensive process, JIEDDO is not in a
position to readily provide accurate and reliable information to
internal and external decision makers on its staffing levels. For
example, when the Senate Appropriations Committee directed JIEDDO to
identify and report on staffing levels of civilian, military, and
contractor staff, JIEDDO officials used ad hoc data requests to
divisions they receive information from in their daily reports and to
activities that are not being captured by the current process in order
to collect information on contractor personnel. Despite responding to
the committee's direction for a May 2007 report and its direction to
update this report to reflect future personnel changes, JIEDDO
officials have not developed a policy requiring the collection of data
accounting for all categories of personnel or provided guidance for
doing this accurately.
Additionally, without a comprehensive process to track all government
and contractor personnel, JIEDDO cannot be in a position to effectively
plan for its future workforce needs. For example, according to a JIEDDO
official, in the case of one initiative JIEDDO needed to compare
unmanned aerial vehicle piloting alternatives, contracted versus in-
house, and it was critical for JIEDDO to know the quantity of and
functions of contractor staff employed under the existing contract.
However, because JIEDDO's manpower management system does not routinely
capture contractor staff information, it would have been difficult for
JIEDDO to determine whether to continue the contract without finding an
alternative source for this information. For this initiative, JIEDDO
was able to obtain the information needed through detailed contract
information that happened to be available. However, according to the
JIEDDO official, these details are not always routinely available,
depending on the type and terms of the contract.
Our prior work also highlights the importance of accounting for and
providing effective oversight of contractors. A recent report
concerning the management and oversight of contractor support for
deployed forces addresses the issue of limited visibility over the
number of contractors deployed with U.S. forces and potential problems
with planning for security and logistics needs if the numbers of
contractors are not known to military commanders in theater.[Footnote
27] JIEDDO deploys contractor personnel in the theater to assist with
counter-IED solutions. JIEDDO does not track the number of contractors
it employs, and yet its May 2007 report indicates that the number can
significantly affect how JIEDDO uses its resources and plans for future
needs.
Conclusions:
As IEDs continue to pose a significant threat to U.S. forces in Iraq
and Afghanistan, defeating the threat continues to be a high defense
priority. This likely will require a continued significant investment
in resources, both financial and human capital. The volume of resources
required, coupled with the scale and span of JIEDDO's mission to focus
all DOD counter-IED efforts, creates a challenge to achieving efficient
and best use of funding made available to JIEDDO. However, DOD and
JIEDDO cannot adequately manage JIEDDO's financial and human capital
resources if it does not have an effective system of internal control
to provide reliable data and insight into how these resources are
invested, and external parties cannot be assured that the information
JIEDDO reports is reasonably accurate, complete, and transparent.
Consequently, because of the absence of adequate internal controls and
of a comprehensive efficient method for identifying, tracking, and
reporting JIEDDO's human capital resources, JIEDDO's systems currently
cannot efficiently provide the data and insight needed for internal
management. Further, Congress is limited in its oversight of JIEDDO's
current and future requirements, the organization's substantial use of
contractors, and the organization's use of resources to support its
mission because of the unreliable information JIEDDO has reported.
JIEDDO officials are not fully aware of how their personnel resources
are being spent, and cannot fully plan for future workforce needs if
their baseline information on current funds use and workforce
composition is inaccurate. Although JIEDDO has taken several actions to
improve its internal control system, as we noted in this report, these
actions have not yet been fully implemented. As such, it is important
that JIEDDO evaluate its recent actions to ensure that they will
address the control weaknesses we identified and provide for a system
of internal control that fully meets federal standards. Improving
JIEDDO's internal controls and the quality of its financial and
personnel data is critical to assuring Congress and the public that
JIEDDO is focusing all of its resources and using them wisely to
address the threat of IEDs to U.S. forces.
Recommendations for Executive Action:
To comply with federal internal control standards as well as improve
the quality of JIEDDO's financial management and the reliability of
resulting financial data and reports, we are recommending that the
Secretary of Defense direct the Director of JIEDDO to develop and
document a comprehensive system of internal control for its financial
management processes. Actions to develop and implement JIEDDO's system
of internal control to address specific control weaknesses we
identified should, at a minimum, include the following:
* Fully documenting all internal control processes and procedures
related to its financial management through the development of
management directives, administrative policies, standard operating
procedures, or other documentation that describe how JIEDDO personnel
should perform their duties.
* Establishing effective controls to ensure that transactions are
properly authorized before funding is executed, related documentation
supporting transactions is accurately dated, and exceptions are
properly approved and documented.
* Establishing effective controls to ensure that all transactions are
properly classified by lines of operation and other expenditure
categories used by JIEDDO, and to promptly and properly correct
misclassifications when identified.
* Developing an internal process, to include involvement of its
internal audit staff, to routinely monitor and review the efficacy of
JIEDDO's system of internal control and promptly correct any weaknesses
identified.
We are also recommending that the Secretary of Defense direct the
Director of JIEDDO to report to Congress on the status of its efforts
to implement its comprehensive system of internal control 1 year from
the date of this report.
To improve JIEDDO personnel or manpower management and provide Congress
with the information it needs to perform its oversight duties
effectively, we are recommending that the Secretary of Defense direct
the Director of JIEDDO to establish and document a method or system to
comprehensively identify, track, and report on a routine basis all
government and contractor personnel.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD concurred with our
findings and the thrust of our six recommendations. However, DOD did
not concur with our fifth recommendation as originally stated in our
draft report, which was to report on JIEDDO's efforts to implement
internal control improvements as part of JIEDDO's recurring quarterly
congressional reports. In its response, DOD proposed an alternative
means for providing this information to the Armed Services and
Appropriations Committees. DOD said that the focus of its quarterly
report to Congress is to describe the IED threat and associated counter-
IED efforts, and that adding the additional information we recommended
would blur the focus of the report. DOD stated that instead, JIEDDO can
produce and provide a report to the oversight committees 1 year after
the issuance of our report as to the steps JIEDDO has taken to address
and correct the weaknesses we identified. We believe that this approach
satisfies the intent of our original recommendation and consequently we
modified our recommendation to reflect this change.
In commenting on our four recommendations dealing with internal control
and financial management, JIEDDO provided several details of the
actions it plans or said it has already taken to address the
recommendations. While we acknowledge that JIEDDO management recognizes
the importance of addressing the weaknesses we identified in our
report, we maintain that more needs to be done before the weaknesses
are fully corrected. For example, regarding our recommendation to
develop documented internal control processes and procedures that
describe how JIEDDO personnel should perform their duties, JIEDDO
responded that it has established and fully implemented an internal
control system, identifying four specific efforts for illustration.
However, the specific efforts listed do not fully support JIEDDO's
statement that needed controls and operating procedures are fully
developed. One of the efforts cited was JIEDDO's November 2007
Capability Approval and Acquisition Management Plan instruction. While
we agree and reported that this instruction is an important step in
developing documented processes, it does not contain operating
procedures developed to the level we recommended because JIEDDO
divisions had not developed and documented roles, responsibilities, and
specific procedures for implementing the JIEDDO Capability Approval and
Acquisition Management Plan. As of February 2008, JIEDDO was still
developing and documenting these roles, responsibilities, and specific
procedures for implementing the JIEDDO Capability Approval and
Acquisition Management Plan. Consequently, the degree to which JIEDDO
has implemented this recommendation is unclear and additional action on
JIEDDO's part may be needed.
In commenting on our sixth recommendation regarding establishing and
documenting a method to comprehensively identify, track, and report
government and contractor personnel, JIEDDO included extensive
background information on its existing personnel processes and
improvement efforts it is undertaking. However, more remains to be done
in order to fully implement our recommendation. For example, while
JIEDDO stated that it is in the process of accounting for contractors
maintaining COIC facilities, JIEDDO did not identify any additional
efforts to account for the remainder of contractor personnel cited in
our report or any specific steps it plans to take to establish and
document a method or system to comprehensively identify and track all
personnel. Instead, JIEDDO explained that it does not track certain
classes of personnel working in direct support of JIEDDO because these
persons are already accounted for by other organizations in DOD.
Consequently, JIEDDO's insight into its human capital is limited
because it excludes tracking certain manpower funded by the JIEDDO
appropriation, such as personnel directly working for the Joint IED
Defeat Test Board, whose workload is performed exclusively in support
of testing JIEDDO initiatives. We recognize JIEDDO's comments regarding
the responsibility of the military, DOD, and other government agencies
in providing oversight and reporting of their staff who may be assigned
to work in support of the JIEDDO mission. However, we believe that as
an organization, JIEDDO has an interest and a responsibility to
identify, track, and report all civilian, military, and contractor
personnel working in support of JIEDDO as a matter of good resource
stewardship and sound human capital management. Any overlapping
manpower management interests or responsibilities between JIEDDO and
other organizations could still be recognized and reported with the
appropriate caveats to users of the information. In its comments
related to this recommendation, DOD also cited ongoing efforts that do
not directly address our recommendation as well as several new efforts
that were not established at the time of our review, and therefore we
could not validate or consider them for purposes of this audit. DOD's
comments and our specific responses to them are provided in appendix
II.
We are sending copies of this report to the appropriate congressional
committees and the Secretary of Defense. We will also make copies
available to others upon request. If you or your staff have any
questions about this report, please contact me at (202) 512-8365 or
solisw@gao.gov. Contact points for our Offices of Congressional
Relations and Public:
Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix III.
Signed by:
William M. Solis:
Director, Defense Capabilities and Management:
List of Committees:
The Honorable Daniel K. Inouye:
Chairman:
The Honorable Ted Stevens:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable John P. Murtha:
Chairman:
The Honorable C. W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives:
The Honorable Ike Skelton:
Chairman:
The Honorable Duncan L. Hunter:
Ranking Member:
Committee on Armed Services:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To assess the Joint Improvised Explosive Device Defeat Organization's
(JIEDDO) financial management processes, controls, and data, we
collected data on the $1.9 billion in funds available to JIEDDO for the
first half of fiscal year 2007 and analyzed associated financial
management and counter-improvised explosive device (IED) initiative
data available for management and external reporting of JIEDDO's
activities. We selected the initial fiscal year 2007 funding provided
to JIEDDO because it was received after JIEDDO made significant changes
in its resource management processes and therefore should reflect
impacts and improvements resulting from those changes. We also
identified required approval controls over use of funds, reviewed
selected transactions for compliance with these controls, and assessed
whether the data recorded in the accounting and managerial systems
accurately reflected JIEDDO's activities. However, we did not perform a
comprehensive assessment of all of JIEDDO's internal controls. We drew
high-dollar initiatives during the scoping phase of the review to more
efficiently assess the largest portion of JIEDDO's funds use in the
relatively limited phase. Because the items initially selected included
little in the way of attack the network initiatives, we added items
from this line of operations to do control testing. We also reviewed
large-dollar initiatives approved by the Deputy Secretary of Defense
that had no recorded commitments at the time our initial data were
collected for the first half of fiscal year 2007. Because we identified
weaknesses in the completeness and accuracy of JIEDDO's documentation
and controls, we did not review the full range of initiatives we had
originally planned because it would have added no further value for
purposes of addressing the objectives of this review. Our analysis
included 47 funding actions totaling $1.34 billion for 24 of the 301
initiatives JIEDDO had approved at the time we collected our data. We
selected initiatives to review that reflected the JIEDDO defeat the
device and attack the network activities as well as some approved most
recently by the Deputy Secretary of Defense. The 24 initiatives we
selected were divided into three subsets: 10 counter-IED initiatives
JIEDDO identified as defeat the device initiatives with the highest
fund commitments recorded as of the time we collected financial data, 9
of the 10[Footnote 28] counter-IED initiatives JIEDDO identified as
attack the network initiatives with the highest fund commitments
recorded as of the time we collected financial data, and 5 additional
initiatives that received Deputy Secretary of Defense approval after
the date we collected our comprehensive funding data to determine
whether conditions had changed. We also met with officials from
JIEDDO's Counter-IED Operational Integration Center, the Joint Center
of Excellence, the Navy Center of Excellence, the Air Force Center of
Excellence, the Technology and Requirements Integration Division, and
the Joint IED Defeat Test Board to gather information corroborating and
explaining the financial activity and documentation related to JIEDDO
initiatives we tested.
To assess JIEDDO's efforts to identify, record, track, and report
numbers of all personnel, including contractors, we met with officials
from JIEDDO's Secretariat Division who are responsible for the
organization's personnel management to discuss and obtain information
on the numbers of JIEDDO personnel, the composition of personnel, and
JIEDDO's processes for capturing this information. We collected
information on the numbers of JIEDDO personnel from several personnel
documents and reports from the Secretariat Division. We reviewed the
information and selectively compared it with corroborating sources,
such as interviews with JIEDDO officials and JIEDDO's financial
documentation, to determine whether the reported figures were
comprehensive and accurate. We also met with officials from JIEDDO's
Counter-IED Operational Integration Center, the Joint Center of
Excellence, the Navy Center of Excellence, the Air Force Center of
Excellence, the Technology and Requirements Integration Division, and
the Joint IED Defeat Test Board to gather information regarding the
numbers of and composition of JIEDDO's personnel. In addition, we met
with officials in the Office of the Secretary of Defense's Directorate
for Organizational and Management Planning to discuss the origins of
DOD Directive 2000.19E.
We assessed the reliability of JIEDDO's financial data we reviewed by
(1) corroborating the data with supporting information and
documentation from physical file records at JIEDDO headquarters and
from initiative program offices to verify the accuracy of the data, (2)
reviewing existing information about the data and the system that
produced them, and (3) interviewing agency officials knowledgeable
about the data. We found problems with the reliability of the data,
which we discuss in the report and in part form the basis for our
recommendations.
We conducted this performance audit from April 2007 to December 2007 in
accordance with 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 believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: Comments from the Department of Defense:
Joint Ied Defeat Organization:
5000 Army Pentagon:
Washington DC 20310-5000:
February 14, 2008:
Mr. William M. Solis:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Solis:
This is the Department of Defense (DoD) response to the GAO draft
report, "Defense Management: More Transparency Needed Over the
Financial and Human Capital Operations of the Joint Improvised
Explosive Device Defeat Organization," dated 21 December 2007 (GAO Code
351017).
JIEDDO would like to thank GAO for its due diligence and thoughtfulness
in the preparation of this report. Overall, this report provides an
accurate description of the weaknesses identified during the audit time
frame with regard to JIEDDO's compliance with internal control
standards.
JIEDDO has instituted several processes to strengthen our internal
control standards and to ensure that financial transactions are
properly approved and documented. Many of these processes were
implemented during the audit time frame. Our response provides detailed
descriptions of current processes and other planned improvements that
will occur over the next several months. Projected completion dates are
included in the response.
My point of contact for this matter is Ms. Lin Malec, Internal Review,
703-602-4807.
Signed by:
THOMAS F. METZ:
LTG, U.S. Army:
Director, JIEDDO:
Branch IOC: 01 MAR 08:
Branch FOC: 01 MAY 08:
GAO Draft Report - dated December 21, 2008 GAO Code 351017 – GAO-08-342
"Defense Management: More Transparency Needed Over the Financial and
Human Capital Operations of the Joint Improvised Explosive Device
Defeat Organization"
Department Of Defense Comments To The Recommendations:
Recommendation l. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to develop and document a comprehensive
system of internal control for its financial management processes by
fully documenting all internal control processes and procedures related
to its financial management through the development of management
directives, administrative policies, standard operating procedures, or
other documentation that describe how personnel should perform their
duties.
DOD Response: Concur.
Before the initiation of the subject audit, JIEDDO had been and
continues to work diligently to formalize and document processes to
ensure that internal controls are emplaced within our organization.
During the audit timeframe, many of these processes were finalized, but
due to GAO reporting time constraints, they were unable to validate
these processes. Following are samples of the procedures and processes
we have finalized, documented and implemented:
(See comment 1.):
1) Formation of the Acquisition Oversight Division (AOD)
The Acquisition Oversight Division was established to support the
JIEDDO mission to defeat Improvised Explosive Devices (IEDs). AOD
provides executive program management oversight of Counter-lED (C-IED)
initiatives; develops and implements acquisition life-cycle management
policies; and ensures effective transition and transfer of initiatives
to the Services for sustainment and further integration.
(See comment 2.):
The need for an oversight division that applied scrutiny to processes
and analysis of JIEDDO process methodology for all JIEDDO divisions
became apparent as JIEDDO began breaking new ground in field of rapid
acquisition. The AOD systematically reviews programs that have been
funded by JIEDDO in an established process called (JIEDD) (Joint lED
Defeat) System Reviews (JSRs). The AOD improves JIEDDO processes by
offering objective analysis and review from a division reporting
directly to the Director, JIEDDO. The monitoring of established policy
and oversight by AOD enhances JIEDDO's overall capability to find
Counter-IED Solutions and get those solutions quickly assessed and to
the Warfighter. It assists in the control of documents while seeking to
match technology gaps. The outcome is improved controls in accounting
for the prudent spending of funds while assessing metrics and control
measures throughout the process.
The JIEDDO AOD maintains overall proponency for the JIEDD Capability
Approval and Acquisition Management Process (JCAAMP); provides
executive program management oversight and independent assessment of
initiatives approved by the Director and Deputy Director; develops and
publishes policies for the development, procurement, testing,
deployment and initial sustainment of C-IED initiatives; conducts
JIEDDO System Reviews (JSRs); chairs the JIEDDO Transition Team (JTT)
and Transition Working Group (TWG); coordinates the transition,
transfer, or termination of initiatives with the Military Services or
agencies and oversees the completion of all Transition Packets (TPKs);
produces JIEDDO future budget programmatic requirements; maintains an
audit trail for all initiative funding; provides members to serve on
all JIEDDO IPTs; serves on the Chief of Staff's JCAAMP Council;
provides oversight for all test and evaluation activities; provides
oversight of the JIEDD Test Board (JTB); produces all initiative
funding decision memoranda; provides members to the JIEDDO Joint Urgent
Operational Needs (JUONS) Review Board (J2RB); and the JIEDDO Special
Access Program and Additional Compensatory Measures Review Board
(JSARB). The AOD oversees staff actions related to initiative
performance, interoperability, and compatibility test activities;
provides members to the JIEDDO Initiative Evaluation Team (JET);
establishes policies for testing in support of Initiative Evaluation
Plans (IEPs) and coordinates test issues related to IEPs with the JTB.
AOD coordinates with Program Managers and Service test organizations
for testing support during initiative evaluations and coordinates the
inclusion of subject matter experts to serve on JIETs. The AOD ensures
an evolutionary improvement of JIEDDO processes and plans; coordinates
and provides administrative and logistical support to the JIEDD
Requirements, Resources and Acquisition Board (JR2AB) and JIEDD
Integrated Process Team (JIPT); and proposes the evaluation Tier
development for each initiative. These actions are performed in
coordination with the ORSA Division Chief.
Several documents are enclosed to provide more detail describing the
Acquisition Oversight Process:
* Acquisition Oversight Division & The Joint LED Defeat Capability
Approval and Acquisition Management Process;
* Memorandum for JIEDDO Personnel, Subject: Joint lED Defeat
Requirements, Resources and Acquisition Board and Joint IED Defeat
Integrated Process Team Scheduling;
* JR2AB Scheduling Request Memorandum Example;
* JR2AB Scheduling Request Memorandum Instructions;
* Transition Packet Instructions (JR2AB);
* JR2AB and JIPT Briefing Slides Template;
* JIEDDO Assessment Readiness Levels;
2) Published and Implemented JCAAMP Instruction – Joint Improvised
Explosive Device Defeat Capability and Acquisition Management Process
(JIEDDOI 5000.1, dated 9 November 2007):
(See comment 3.):
JCAAMP is JIEDDO's process to respond to urgent warfighter needs; to
identify C-IED operational capability gaps; aggressively to seek,
acquire, and assess potential materiel and nonmaterial solutions to
these gaps through extensive finding networks; and to place approved C-
lED initiatives in the hands or warfighters for operational assessment
and deployment. JCAAMP enables a smooth transition or transfer of C-lED
initiatives to one or more Services or agencies and provides guidance
on the disposition of those initiatives recommended for termination.
The JCAAMP instruction defines JCAAMP's roles, responsibilities, and
oversight requirements as applicable to all JIEDDO components.
Functional responsibilities described below are not inclusive. JIEDDOI
5000.01 is enclosed and contains a thorough description of the
initiative process and associated responsibilities.
JCAAMP is conducted in three phases – VET, Equip, and Sustain. Each of
these phases incorporates transition points (TP) representing critical
activities and decisions that define the path forward through each of
the three phases.
JCAAMP's goal is to approve, develop, and acquire initiatives quickly,
normally within 4 to 12 months. JCAAMP also enables initiative delivery
for employment by warfighters while conducting operational assessments,
normally within 6 to 24 months. After an initiative receives a
successful operational assessment (OA) and a decision on transition,
transfer, or termination (T3) to a Service or agency has been made,
JCAAMP manages the remainder of the fiscal year and one additional
fiscal year of sustainment prior to T3 execution.
C-IED Urgent Needs and Operational Capability gaps are obtained from
various sources – principally warfighter JUONs, after action reviews
(AAR), reports, lessons learned, special access programs, and theater
visits by senior leaders. Operational analyses, intelligence trends,
tactical and strategic gaming, the special technical operations
community, and JIEDDO's finding networks also inform the development of
needs and, ultimately, may result in the identification all approval of
C-IED operational capability gaps. JUONs forwarded to JIEDDO by the
Joint Staff (JS), J-8, are processed for acceptance through the JIEDD
JUONs Review Board (J2RB) for review by the JIEDDO Chief of Staff's
JCAAMP Council and acceptance by the JIEDDO Deputy Director. The
Director, JIEDDO, reviews and approves all C-IED operational capability
gaps semi-annually. Time critical JUONs may be forwarded directly by
the J2RB to the Deputy Director with subsequent notification to the
Chief of Staff's JCAAMP Council.
JIEDDO leverages aggressive finding networks comprised of industry,
academia, laboratories, special technical operations, and other
government agencies to develop potential solutions to urgent and
operational capability gaps. Most proposed technology solutions enter
JCAAMP through the Broad Agency Announcement (BAA) Information Delivery
System (BIDS) and are processed by one of the six Integrated Process
Teams (IPTs) aligned with JIEDDO's three Lines of Operations (LOO):
Attack the Network (Atn); Defeat the Device (DtD), and Train the Force
(TtF). Proposals that do not enter JCAAMP through BIDS, such as
Commercial Off the Shelf (COTS) and some non-material solutions, are
submitted by the LOO IPT Leads to the Chief of Staff's JCAAMP Council
for disposition to the appropriate IPT for further development and
evaluation.
Figure:
[See PDF for image]
[End of figure]
TP 1 — Complete assessment of technology merit against capability gaps
and IPT Leads gain approval as a proposal from the Deputy Director or
Chief of Staff's JCAAMP Council;
TP 2 — LOO Chair approval to proceed to JR2AB;
TP 3 — JR2AB recommendation to proceed to JIEDD Integrated Process Team
(JIPT);
TP 4 – JIPT endorsement and Initiative Decision Memoranda signed;
TP 5 – Decision to deploy for operational assessment by Director;
TP 6 – Authorize full rate production based on OA report. Decision to
transition, transfer, or terminate (T3) initiatives, as appropriate;
TP 7 — Complete transition or transfer of initiatives to Services or
Agencies; or Terminate.
JCAAMP Characteristics:
* Support for flexible points of entry depending on maturity;
* Effective test and evaluation requirements;
* Initiative assessment continues after initial delivery to warfighters
* Continuous risk reduction enforced;
* Formal acquisition oversight during every phase;
* The JCAAMP Governance is perhaps the most important part of the
process to ensure that all initiatives pass though various approval
levels before a decision is made to commit funding. Every initiative
must be vetted through the JCAAMP process as follows:
* JIEDDO Senior Resource Steering Group (SRSG)
The SRSG is an advisory body to the Deputy Secretary of Defense
(DEPSECDEF), established to review JIPT-recommended C-IED initiatives
that are valued greater than $25 million, and to make recommendations
to the DEPSECDEF for disposition.
SRSG membership consists of the Principal Deputies of the Under
Secretaries of Defense, the DOT&E; the Principal Deputy ASD(NII); the
Principal Deputy General Counsel of the Department of Defense; the
Deputy PA&E; the Vice Chief of Staff of the Army, the Vice Chief of
Naval Operations, the Vice Chief of Staff of the Air Force; the
Assistant Commandant of the Marine Corps; the Vice Chairman and the
Joint Chiefs of Staff; the Assistant to the Chairman of the Joint
Chiefs of Staff, the Director, JRAC; and other members as the DEPSECDEF
may determine.
* JIEDD IPT (JIPT);
The JIPT is an advisory body to the Director, JIEDDO, established to
consider C-IED proposals after review by the JIEDD Requirements,
Resources, and Acquisition Board (JR2AB).
Membership consists of representatives at the Flag or General
Officer/SES level from the Offices of the Under Secretaries of Defense;
the ASD (NII)/DoD CIO; the DOT&E; the Director, PA&E, the Military
Services; the Chairman of the Joint Chiefs of Staff and such other
representatives as the Director, JIEDDO, may determine.
The JIPT is chaired by the Deputy director and meets weekly to
recommend further development and funding of a proposal as a C-IED
initiative; provide comments on transition, transfer, or terminate (T3)
actions of mature initiatives; ensure synchronization of JIPT member C-
IED efforts and those of other agencies; validate JIEDD efforts
requiring rapid implementation, acceleration, or development and
recommend appropriate funding levels to the Director; review potential
C-IED solutions provided by industry, interagency, and international
sources when considering appropriate funding levels to the Director;
review actions of the JR2AB and make recommendations to the Director,
as appropriate.
* JIEDD Requirements, Resources, Acquisition Board (JR2AB);
The JR2AB meets weekly to assess all C-IED proposals forwarded by the
LOO chairs prior to making any funding recommendations to the JIPT.
Proposals are evaluated using the following criteria: extent of systems
integration; military utility and effectiveness; programmatic and
resource limitations; potential to satisfy and operational capability
gap; ability to be developed and deployed in JACAAMP-designated
timeframe; and the degree of risk. Additionally, JR2AB develops
strategies for integration into the Joint Capabilities Integration and
Development System (JCIDS); advises the Director, JIEDDO, regarding
resource and acquisition management matters; reviews the current status
of program execution and operational fielding of approved JIEDD
initiatives; monitors coordination between JIEDDO and the appropriate
Service or agency for the transition of approved C-IED initiatives that
are deemed only required for the duration of a given conflict or
theater of operations; and reviews resource requirements and
appropriate planning documents for establishment of current and future
funding needs, including out-year funding requirements.
Membership consists of representatives at the O-6/GS-15/PB3 level from
the Offices of the Secretaries of Defense; the Director, PA&E; the
Military Services; the Chairman of the Joint Chiefs of Staff, and the
ASD(NII)/DoD CIO. The Director, JIEDDO, may select additional members
to serve on the JR2AB and may modify JR2AB requirements with respect to
JIEDD initiatives, as necessary.
* Chief of Staff's JCAAMP Council.
The JIEDDO Chief of Staff, assisted by the Division Chief's and select
special staff officers, provides oversight of JCAAMP to ensure the
Director's guidance and priorities are met.
The Council meets weekly to review JIEDDO's metrics; identify resource
imbalances, coordinate required management actions to resolve
outstanding issues and make recommendations for actions by the
Executive Committee. Additionally, the Council reviews all actionable,
pending and approved JUONs; reviews operational capability gaps and
science and technology gaps and recommends changes to JIEDDO
leadership; reviews BIDS key performance indicators, including the
processing rate, BAAs in development, and the number of proposals
received, accepted and rejected that week; reviews that week's JR2AB
results and forecasted agenda; reviews that week's JIPT results and
forecasted agenda; reviews the corporate budget and balance; identifies
tradeoffs between changing budget requirements; reviews all JIEDDO
initiatives assessed as "Red;" and reviews the transition, transfer,
terminate actions monthly and review staffing issues.
* JIEDDO JUONs Review Board (J2RB);
The J2RB meets weekly to review emergent JUONs and recommends their
acceptance, rejection or limited acceptance to the Deputy Director via
the Chief of Staff's JCAAMP Council. The J2RB reviews all JUONs to
determine the tactical, technical, training, and acquisition readiness
levels of a proposed solution and develops a recommendation for the
Chief of Staff's JCAAMP Council and a drafts a decision memo for the
Deputy Director.
J2RB membership consists of representatives from JIEDDO's TRID, AOD,
the JRAC, JCS (J-8) and the supported COCOM. Service Liaison Officers
and additional subject matter experts relevant to the topic(s) under
discussion are also included in the meetings to ensure unilateral
representation resulting in informed, educated decision-making.
3) Establishment of the Records Management Division;
(See comment 4.):
As noted by GAO, internal controls necessitate the completion,
maintenance and availability of documentation to support decisions and
transactions accomplished by JIEDDO leadership. The Records Management
Division was tasked to ensure that JIEDDO personnel are educated on the
importance of maintaining supporting documentation.
The JIEDDO Records Management Program provides oversight and assists
JIEDDO components in the establishment and maintenance of a system for
maintaining and protecting records in all media. Adhering to statute
(44 U.S.C. Chapter 31), JIEDDO's Records Management Program has
accomplished the following:
* Issued a Records Management Directive and/or Instruction;
* Instituted training on policies, responsibilities, and recordkeeping
requirements and ensuring employees understand the distinction between
records and non-records;
* Developed and implemented records disposition schedules; preserving
permanent records and promptly destroying temporary records when their
retention period expires;
* Established a Vital Records Program for safeguarding and recovering
JIEDDO records.
* At the request of JIEDDO leadership and through coordination with
Washington Headquarters Services, McNeil Technologies was requested to
conduct an assessment of JIEDDO's records management policies,
practices, and procedures. The objective was to establish a baseline
status. The review occurred during JAN/FEB 2007. The report findings
are enclosed.
* The Chief of Staff (CoS) formally designated a JIEDDO Records Manager
with responsibility for carrying out a Records Management Program. The
designation letter is enclosed.
* The Director signed the Directive establishing responsibility for the
Records Management Program under the Chief of Staff, establishing
policy and responsibilities for life-cycle management (creation,
maintenance and use, and disposition) of information as records in all
media (including electronic), and establishing and authorizing the
publication of procedural guidance on the management of records within
JIEDDO. Directive 1015.1A, JIEDDO Records Management Program, is
enclosed.
* Records administrative staff, action officers, executive assistants,
file clerks, and others with regular records duties receive training in
records maintenance and filing procedures and records disposition.
Module 1 training (basic course) occurs bi-weekly and is a requirement
for all employees. Module 2 training (topics: hard copy and electronic
recordkeeping, AI 15, Naming Convention, shared drives, emails,
labeling, File Plan, etc.) was conducted on 4 January 2008. It is also
being executed as a desk-side training session for Division
administrators. Training slides are enclosed. Module 3 training began
in January 2008. This course focuses on Action Officer responsibilities
in handling records.
* A rigorous Program Plan of Action for Headquarters Records Management
implementation was developed. The initial operational capability (IOC)
date for Division administrator central file systems is projected to be
31 January 2008; for Branch administrator central file areas, the IOC
date is projected to be 01 March 2008.
* An electronic file structure was established to capture official,
final version documents. The output of this process is an electronic
File Disposition Schedule on JIEDDO's internal J: drive. As of January
2008, 5,469 files were identified as official records and have been
placed within this File Disposition Schedule.
* The Chief of Staff issued a Standardized Naming Convention memo,
providing direction on the importance of naming electronic files
properly, along with rules for developing file names and versions.
Electrons of the memo are enclosed.
* File Plans were drafted and Division employees are in the process of
validating the content.
* The Records Program's Final Operational Capability (FOC) date is
projected to include an assessment process to ensure employees are
operating under the guidelines of the program being established. The
FOC assessment will confirm whether administrators are maintaining
electronic and hard copy file systems. The assessment will determine
whether further training/practice is required.
* Self-evaluation checklists and internal reviews are included in the
Draft JIEDDO Records Management Handbook. The Draft Handbook provides
guidance on how the Records Manager, with the assistance of the Records
Team and Division/Branch records Administrative Staff, will
periodically evaluate records management practices. Reference: NARA's
publication Records Management Self-Evaluation Guide, 2001 edition,
available at [hyperlink, http://www.archives.gov/records-
mgmt/publications/records-management-self-evaluation-guide.html
].
* A draft Management Control Checklist for Records Management is
underway. The initial draft is enclosed.
* JIEDDO is in the implementation phase of its Records Management
Program. Fostering Records Management practices in the JIEDDO culture
will be a paramount focus.
* With the support of JIEDDO's senior leadership we are eliciting
support and adherence from JIEDDO's middle-management and Action
Officers. There adherence to the new Records Management Program is a
critical factor in establishing a culture inclusive of Records
Management processes.
* The Records Program strategy is in two phases: (1) Division Level;
(2) Branch Level. The Initial Operational Capability (IOC) and Final
Operational Capability (FOC) dates are schedule as:
Division IOC: 31 Jan 08;
Division FOC: 15 Feb 08;
Branch IOC: 01 Mar 08;
Branch IOC: 01 May 08;
4) Implementation of Comprehensive Cost and Requirement System (CCaRs).
(See comment 5.):
In 2007 JIEDDO began implementation of the Comprehensive Cost and
Requirement System (CCaR) used by Air Force, Army, Navy and Defense
Threat Reduction Agency (DTRA) to manage billions in funding.
JIEDDO CCaR objectives include:
* Maintains budget requirement packages/initiatives;
* Coordinate workflow electronically for MIPRs;
* Track budgets and associated fiscal years, as well as all
commitments, obligations, and expenditures providing internal financial
controls;
* Ensure STANFINS data (official Defense Finance and Accounting System
(DFAS) data) is downloaded daily for reconciliation against JIEDDO data
for validation of accuracy;
* Provides reporting capability to quickly assess JIEDDO financial
position by overall budget (macro) or single initiative (micro)
perspective providing internal financial controls.
Currently, there is on-going training of Program Integrators in CCaR
and one-on-one training as necessary. CCaR was installed for the
Resource Management Budget Execution team enabling the electronic
preparation of Military Interdepartmental Purchase Requests (MIPRs).
Full implementation of CCaRs is expected by March 2008.
JIEDDO CCaR process improvements include:
* The system will serve as a repository for all new MIPRs;
* The system eliminates the need to maintain a JIEDDO MIPR log;
* CCaRs allows Program Integrators/Office Primary Responsibilities
(OPRs) visibility of their assigned initiatives by Lines of Operation;
* Requirements gathering for interface with current financial system is
underway
* CCaRs ensures that backup Resource Management (RM) staff can execute
transactions when primary RM staff is unavailable.
The CCaR is an enterprise program and financial management system that
will deliver real-time program information to decision makers. At the
core of the CCaR system are the automated reports and analysis tools
which allow the program and financial managers to define program
requirements, formulate program budgets, forecast program execution and
track the execution of program funds.
Recommendation 2. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to develop and document a comprehensive
system of internal control for its financial management processes by
establishing effective controls to ensure transactions are properly
authorized before funding is executed, related documentation supporting
transactions is accurately dated, and exceptions are properly approved
and documented.
DOD Response: Concur.
Funding documents are only released after proper authorization is
received and documented; i.e. funding memorandums (for less than $25M)
or Deputy Secretary of Defense approval (for in excess of $25M). In the
past, there has been some confusion regarding the actual definition of
the $25M. JCAAMP (described above) clearly defines that the $25M is
total program costs. There have been instances when the projected total
costs were under $25M, but it was subsequently determined that the
actual initiative costs would exceed the threshold. The current process
requires that as soon as it is determined that an initiative will
exceed the $25M threshold, an SRSG package is developed and SECDEF
approval is obtained addressing the increase.
(See comment 6.):
In another effort to ensure adequate internal control standards are
included in JIEDDO processes, RM developed mandatory minimal
transaction documentation that must be completed and kept on file. For
example, the JIEDDO RM Funding Request Flow and Required Documents
package, and the JIEDDO RM Checklist were developed and enclosed for
your review. The JIEDDO Projects/Initiatives Pending Prioritized
Listing and MIPRs Listing is updated and published daily. The JIEDDO
Corporate Report (reporting of expenditures from our "official"
financial system by each initiative), the Monthly Execution Report
(compares execution to monthly spend plan by each initiative), and
Status of Funds is also included in internal daily reporting.
Because of its charter JIEDDO must respond quickly to requests from the
field. Supplemental funding is a contributing factor of JIEDDO's
flexibility. These funds are not "programmed" in a traditional DOD
fashion but fluid and available where needed to meet approved lED
Defeat initiatives. For example, JIEDDO's Corporate Report has
successfully tracked these funds and pointed out errors when funds have
been improperly executed allowing for detection and correction.
Recommendation 3. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to develop and document a comprehensive
system of internal control for its financial management processes by
establishing effective controls to ensure all transactions are properly
classified by lines of operation and other expenditure categories used
by JIEDDO, and to promptly and properly correct misclassifications when
identified.
DOD Response: Concur.
Early in fiscal year 2007, JIEDDO Resource Management (RM) identified
and corrected inconsistencies with the assignment of Lines of
Operations (LOOs) to ensure that information being reported in its
financial reports was correct. JIEDDO currently has the ability to
accurately determine trends in the use of funds in conjunction with its
priorities. In an effort to prevent future erroneous postings of LOOs,
all funding documentation must include the LOO. RM then validates
against spending plan data to ensure accuracy prior to committing any
funds in the accounting system. In addition, JIEDDO continues to review
LOO assignments for individual requirements during each budget review
and corrections are made as required.
(See comment 7.):
As JIEDDO is growing, so is the understanding of operational functions
and mission. Initiatives recorded in first quarter of 2007 that were
recorded and reported in one Line of Operation (LOO) and subsequently
moved and reported in another LOO in later quarters demonstrates
JIEDDO's informal non-documented continual review of initiatives and
the reporting thereof. Perspective on what LOO an initiative falls into
is relative to the familiarity of the initiative/program. JIEDDO
efforts to accurately report and record transactions are represented by
our continual improvement. In addition, JIEDDO continues to review LOO
assignments for individual requirements during each budget review and
corrections are made as required.
RM is developing guidance for accounting and budget personnel to ensure
that correct Elements of Resource (EORs) are used in the recording of
accounting data. It is important to note that as requirements mature
their nature may change. In a fluid operating environment technologies
may cross EOR and LOO definitions and require adjustments in accounting
information on an individual basis when identified. JIEDDO continues to
review LOO assignments for individual requirements during each budget
review and corrections are made as required. The goal is to accurately
process all financial documentation and when exceptions occur we will
continue to promptly and properly correct misclassifications and
document corrective action in official records.
RM is also in the process of fully staffing the Resource Management
(RM) Division. The additional essential personnel will allow us to take
immediate action in correcting the weakness identified in the audit. We
are currently studying the feasibility of establishing a Policy and
Quality Assurance Section within RM that will be dedicated to fully
documenting all internal control processes and procedures related to
our financial management through the development of management
directives, administrative policies, standard operating procedures, and
other documentation that describe specific organizational
responsibilities. Following is our planned actions:
Action Item: Establish Desk Guides for each Position within RM (Job
Title; Job Description; General Description of Daily Duties; General
Description of Weekly Duties; General Description of Monthly Duties;
General Description of Unscheduled or Annual Duties);
Planned Completion Date: 28 February 2008.
Action Item: Timeline Chart for all RM Requirements/Submissions (I.e.
for Budget Formulation, Budget Execution, and Accounting);
Planned Completion Date: 31 January 2008.
Action Item: Reference Guide to identify Useful Financial Web Sites
Standard Operating Procedures Documenting the Financial Management
Process to Resolve Aged Commitments and Unliquidated Obligations
(ULOs);
Planned Completion Date: 28 February 2008.
Action Item: Standard Operation Procedures for the Processing of MIPRs;
Planned Completion Date: 15 March 2008.
Action Item: Standard Operating Procedures for the Corporate Report
process;
Planned Completion Date: 29 February 2008.
Action Item: Budget Formulation Guidance;
Planned Completion Date: 29 February 2008.
Action Item: Consolidated Funding Package Handbook (i.e. JIEDDO Funds;
Funding Policy; Funding Package Process; Required Documentation; Travel
Policy; Accounting Process, etc.);
Planned Completion Date: 31 March 2008.
Recommendation 4. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to develop and document a comprehensive
system of internal control for its financial management processes by
developing an internal process, to include involvement of its internal
audit staff, to routinely monitor and review the efficacy of JIEDDO's
system of internal control and promptly correct any weaknesses
identified.
DOD Response: Concur.
JIEDDO agrees that an adequate internal process to monitor and review
the efficacy of its internal controls is required. Funds allocated to
JIEDDO are for the IED Defeat mission within DOD. JIEDDO's primary
mission is to provide funding to the Military Services and DOD agencies
to rapidly develop and field counter-lED solutions and is successfully
accomplishing its mission. Mission accomplishment in this area is not
the only part of the process. GAO accurately identified weaknesses in
JIEDDO's internal control process. It is very important to JIEDDO that
any agency looking at JIEDDO's execution of funds can understand
funding decisions from the inception of researching an initial idea or
initiative through documentation of a decision and each stop of the
approval process. Recognizing our weaknesses, especially in the area of
maintaining adequate documentation to ensure an accurate transaction
audit trail, JIEDDO hired an Internal Review Evaluator to have
continuous oversight over internal controls and recommend improvements
to correct any identified weakness. The auditor actually came on board
during the audit timeframe. The auditor reports directly to the JIEDDO
Director to avoid any conflicts of interest and to maintain
independence within the organization. The auditor also serves as
JIEDDO's Management control Administrator. Specific details will be
addressed later in our comments.
(See comment 8.):
Internal Review has incorporated Management Control Training during our
Block Training sessions for new employees. The importance of the
training is centered on ensuring that personnel understand the
importance of internal control standards. A basic overview is provided
on the Management Control Program so that awareness is instituted at
all levels of the organization.
Internal Review has also provided elementary training to all key JIEDDO
leadership. A training package developed by OAA was provided to
leadership and successful review of the package was certified. An
example is enclosed.
A draft Five-Year Management Control Plan was developed and will be
provided to JIEDDO leadership for comment and modification. Target date
for development is 8 February 2008.
Additional training and instructions will be provided to all JIEDDO
personnel. Key checklists were developed and are integral piece of the
Management Control Program. Management Control Administrators and
Assessable Unit Managers will be identified and targeted training will
be provided to ensure that checklists are not just completed – but
actual testing of key controls will be accomplished. Target date for
completion is 15 March 2008.
Recommendation 5. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to report to congress on the status of
its efforts to implement its comprehensive system of internal control
as part of its quarterly congressional reports. DOD RESPONSE:
Nonconcur.
OSD Policy comments best explain the basis for this nonconcurrence.
JIEDDO's progress in implementing its internal control measures should
not be reported in the Quarterly Reports to Congress. This report is
specifically focused on describing the lED threat and JIEDDO's efforts
to counter that threat. Including JIEDDO's internal "administrative
efforts" within the report is not in keeping with the intent of the
report and serves to weaken the report's focus. OSD Policy recommends
that the Deputy Secretary of Defense direct JIEDDO to provide Ranking
and Minority leaders of the Armed Services and Appropriations Committee
with a report within one year from the date of the GAO final report as
to steps JIEDDO has taken to address and correct the weaknesses
identified by GAO.
(See comment 9.):
As noted throughout JIEDDO comments, many actions have already been
taken to address these weaknesses. It is our firm commitment to ensure
that constant improvements are made to strengthen our internal
controls.
Recommendation 6. The GAO recommends that the Secretary of Defense
direct the Director of JIEDDO to establish and document a method or
system to comprehensively identify, track, and report on a routine
basis all government and contractor personnel.
DOD Response: Concur.
The Joint Improvised Explosive Device Defeat Organization (JIEDDO) was
established as a temporary, non-institutionalized jointly-manned entity
by directive of the Deputy Secretary of Defense effective January 18,
2006. As a temporary entity, the JIEDDO manpower requirement is
identified and documented on a Joint Manning Document (JMD). Following
a decision to institutionalize JIEDDO, the JMD identified positions
will be validated and formally approved on a Joint Table of
Distribution (JTD). The JTD is a permanent funded authorization
document that articulates the approved manpower for the organization.
The JMD is an unfunded temporary document that identifies the specific
positions required to support a non-institutionalized organization.
Since JIEDDO is a jointly-manned activity the manpower to support the
organization's requirements, come directly from the Services and are
maintained on the Service documents. The JMD replicates the positions
identified on the Service documents.
(See comment 10.):
JIEDDO, though a non-institutionalized jointly-manned entity, does
comply with the provisions of Department of Defense Directive 1100.4,
Guidance for Manpower Management. The organization has implemented and
continues to refine the implementation of the provisions outlined in
this Directive to include requirements determination, resource
allocations, manpower authorizations, and manpower planning.
When JIEDDO was formed, the Army Task Force from which JIEDDO was
constructed was staffed from temporary personnel resources, primarily
military and contractor personnel, by the Army. Historical data
indicates that at the time of transition the Army Task Force consisted
of 174 billets, of which 99 were contractors, 1 was a SES, and 74 were
military personnel, including four coalition officers. When JIEDDO was
formed many of these individuals chose to remain with their parent
organizations. Most contracted personnel did transfer to JIEDDO.
At the direction of the DEPSECDEF, JIEDDO set up and conducted a
Service Manpower Validation Board to review, validate, and authorize
the manpower to support the JIEDDO requirements. The Board validated
383 billets. The structure and manpower allocation recommended by the
Board was approved by DEPSECDEF on 27 Jan 06 as reported to the
military services in his Memorandum, dated February 14, 2006. The
Service Manpower Validation Board authorized 129 US military billets,
39 government civilian billets, five (5) coalition officer billets, and
190 Contract Manpower Equivalent (CME) billets. Since the establishment
of JIEDDO the leadership has received approval from the Army for an
additional 54 government civilian billets (approved May 3, 2007) and
has pending a request (November 30, 2007) for an additional 39
government civilian employees. Additionally, the Army approved three
military billets. Two were approved on May 3, 2007 and the third on
July 19, 2007. The Navy approved one military billet. Two of those
billets, the Deputy Director of the COIC and the Chief of the Resource
Management Division, possess primarily inherently government
supervisory responsibility over resource management and fiduciary
oversight of JIEDDO assets.
(See comment 11.):
The success of JIEDDO as an organization depends on its ability to
leverage the capabilities of each person employed within the
organization. Our strategic human capital plan (encl) is a key step in
providing our workforce with the means to reach its full potential. A
copy of the final draft is attached. This plan is comprised of three
overarching goals with objectives and action steps that can be taken to
achieve outcomes and initiatives. These three goals are the essential
first steps that must be in place in order to address the significant
challenges that we are facing.
* Goal 1: Build a well-balanced, world-class workforce with the
knowledge, expertise, and abilities necessary to accomplish JIEDDO's
mission;
* Goal 2: Institute a framework of human resource policies and
processes that model JIEDDO's business approach of rapid, responsive,
and effective solutions;
* Goal 3: Construct a physical and technological infrastructure that
supports JIEDDO's world-class workforce;
The Secretariat is developing a plan for achieving these goals and
expects to achieve these goals by 2010.
JIEDDO from its inception on 18 January 2006 has focused on creating
the organizational structure best suited for the expanding and ever
changing mission. The organization recognizes and has taken the
necessary steps to increase government oversight and fiduciary control
over all JIEDDO controlled and directed programs. The control and
oversight of programs, projects, or initiatives controlled and directed
by the military services and other Department of Defense and government
departments, including those funded wholly or in part by JIEDDO, remain
the responsibility of the service or organization overseeing and/or
operating the program, project, or initiative. The manpower and
resources applied to these programs are reported by the individual
services and are not included in the JIEDDO reported manpower and
resource components. The Service documented manpower is provided in the
quarterly report to the Congress.
(See comment 12.):
JIEDDO is currently undergoing an annual JMD review and validation
process and expects to validate requirements for an additional 18
military and 27 government civilian billets to provide enhanced
government oversight and fiduciary control over the organization's
resources. This chart identifies the manpower growth by JMD category
over the two year history of JIEDDO and known projections for the
future.
Figure: EVOLUTION OF JIEDDO STAFFING LEVELS:
This figure is a combination line chart showing the evolution of JIEDDO
staffing levels.
[See PDF for image]
Sources: FY04 data obtained from approval briefing from JIEDDOTF
manning requirements dated 2 Nov 05. FY05 data obtained from a JIEDDO
Billet Staffing Summary dated 30 January 2006. FY06 data based on
authorized JMD positions dated 14 February 2006. FY07 Data based on
authorized JMD positions dated 3 May 2007.
[End of figure]
As noted in the above chart, JIEDDO in its short two-year existence has
focused on increasing the number of military and civilian billets
required to ensure proper resource and fiduciary oversight. In the
first year (FY06), JIEDDO requested and received Army support for an
additional 54 government civilian billets and three (3) Army military
billets to perform inherently governmental functions. The US Navy
provided one (1) senior military billet to oversee our Resource
Management Division. This represents an increase of 135 percent in
manpower billets associated with government oversight of JIEDDO
resources. In the second year, JIEDDO requested an additional 39
government civilian billets (encl). This request is still pending at
the Army. JIEDDO has also initiated a JMD review to determine areas
where additional government oversight would be warranted. The review is
still on-going but the organization has identified 57 additional
government positions that if supported by the Army will further enhance
the performance of inherently governmental responsibilities. It is
expected that after a detailed review by the JIEDDO senior leadership,
the requests for additional manpower will be submitted to the
respective military services for consideration. The civilian billets
will be requested from the Army as it is the executive agent for
civilian personnel support. The formal submission is expected to be
released in late March 2008.
JIEDDO's official JMD authorizes 192 contractors (Contract Manpower
Equivalent) s. The Service Validation Board in Jan 2006 approved 190.
Two additional CMEs were requested in February 2007 and supported in
May 2007 by the Army. The CME program was established by the Department
of Defense to compensate for the lack of sufficient government civilian
billets. In the current annual JMD review, the JIEDDO staffs have
identified an additional eight CME billets to enhance operational
oversight of JIEDDO programs and initiatives. In addition to the CMEs
authorized in the Joint Manning Document, JIEDDO employs other
contractor personnel under various contract instruments. These
additional contractor billets are necessary to support JIEDDO
initiatives, programs, projects, and provide administrative support and
are categorized as Below-The —Line (BTL) and constrained by funding
limitations. At the request of the GAO and in an effort to provide
further clarification, the BTL category was further broken out into
IAPT, LOEs, and BMS. The following definitions previewed with the GAO
are consistently applied in accounting for manpower and ensures a
commonality in reporting: Joint Improvised Explosive Devise Defeat
Organization (JIEDDO) Manpower Definitions:
1. Joint Manning Document (JMD)
* JIEDDO Manning;
- Military, government civilians, and Contractor Man-year Equivalent
(CME) personnel reflected in the approved JIEDDO JMD (3 May 2007);
- Serve as the baseline around which appropriate structures are built
to address critical integration missions;
- Standard Joint Task Force Headquarters (SJTFHQ) — Counter-IED
Operations Integration Center (COIC);
- Core element of military, government civilian, or CME personnel
assigned to the COIC;
2. Basic Mission Staff (BMS) and Below the Line (BTL) Contractors;
- Augment the JMD approved counter IED mission staff, providing
additional capability in support of the JIEDDO mission;
- Approved by the JIEDDO senior leadership based on available funding
3. Partners;
* Liaison Personnel (LNO)
- Representatives of external agencies that provide interagency
assistance in support of the JIEDDO mission;
- Individuals are normally military, government civilian employees, or
contractors;
- Support is funded by the parent agency. JIEDDO may reimburse salary
and travel related expenses;
* COIC-Interagency partnership Team (IAPT);
- Individuals that represent agencies involved in the integration of
external capabilities in support of the counter-lED mission;
- Individuals may be military, government civilians, or contractors
with the appropriate experience and access;
- JIEDDO may fund salary and/or travel expenses as agreed jointly by
the represented agency;
* Interns;
- Students or recent university graduates participating in a supervised
program, attached to JIEDDO, to gain knowledge and insight in the
JIEDDO concept of operation and JIEDDO sponsored programs;
4. Level of Effort (LOE) (Interim Mission-based Capability);
- Individuals that are retained to provide mission essential support on
an interim or limited term basis to support the execution of specific
elements of the mission;
- Individuals provide support through an approved government services
contract vehicle providing level of effort support for requirements for
various programs for a defined duration in support of the warfighter.
5. Field Service Representatives;
- Individuals retained as part of a services contract to install,
maintain, and service procured or contracted equipment and software
programs.
- Services are provided on an as needed basis.
These definitions were approved by the JIEDDO senior leadership and
have been frequently disseminated to the JIEDDO staff. It is
understandable that one might find individuals who are not directly
involved in the manpower management process that may not fully
understand the meaning of these definitions. JIEDDO will make every
effort to ensure wider dissemination of these definitions.
A report to the Congress on the manpower authorized on the JMD to
support the JIEDDO mission is submitted on a quarterly basis in
response to language in the annual Department of Defense Authorization
and the Department of Defense Appropriations bills. These reports, at
the direction of the Department, are also used to report the manpower
applied, funded, and controlled by the military services in support of
the Department of Defense counter-IED mission. The service manpower
contributions are applied by the services to support their internal
counter- lED programs and are not part of the manpower used to support
JIEDDO counter-lED programs, projects, and initiatives. Therefore, the
service internal counter-lED manpower component is not accounted or
documented on the JIEDDO JMD or manning document. In some cases, JIEDDO
funding supports initiatives under the management and direction of the
Services. In these instances, the Services normally account for and
report the manpower contributions.
JIEDDO also responds regularly to manpower data requests from the
Congress and other Departmental and government agencies. As an example,
the Report to the Congress in May 2007 requested in the FY 2007 Senate
Appropriations bill asked JIEDDO to report all assigned civilian,
military, and those individuals detailed from other agencies. The
report also asked for an accounting of "all contractor support that is
provided through various contracts." In the report, JIEDDO provided
full accountability for all manpower billets and personnel.
The Report suggests that JIEDDO does not include field service
representatives, interagency liaisons, law enforcement training
personnel, interagency partnership team members and infrastructure
contractors working at the Counter-lED Operational Integration Center.
The charts below from the Senate Report were provided to the GAO in
response to a request for this data. It covers interagency liaisons,
law enforcement training personnel, and interagency partnership team
members.
(See comment 13.):
Table:
[See PDF for image]
[End of table]
In an effort to provide complete transparency, JIEDDO solicited and
obtained from firms under contract to provide services for JIEDDO
supported programs and initiatives the number of Full Time Equivalent
(FTE) manpower required to accomplish the contracted support. The firms
translated the FTEs into manpower equivalents for the May 2007 report
to the Congress. Normally under Part 37 "Service Contracting" of the
Federal Acquisition Regulation (FAR) the effort expended in support of
such contracts are reported as the number of FTEs. For the May 2007
report to the Congress the FTEs represented the equivalent of 474
manpower equivalents.
Table:
[See PDF for image]
[End of table]
Section 37.102 of the FAR indicates that performance-based acquisition
(see subpart 37.6) is the preferred method for acquiring services
(Public Law 106-398, section 821). JIEDDO's contracted support falls
within this definition. In order to fill approved Contractor billets,
JIEDDO works hand in hand with various DoD Contracting Agencies in
order to ensure that those contracts that are let are done so in
accordance with the guidelines detailed with FAR 37.1 and 37.2.
Furthermore, surveillance plans are utilized to provide a guide to
systematically and effectively monitor the contractor's performance to
ensure compliance with the terms and conditions of the contract. The
Contracting Officer's Representative (COR) documents the contract file
with sufficient information to support decisions to exercise option
years and outline corrective procedures to be taken against the
contractor for deficient performance and determine if and when the
government should intercede or terminate the contract."
JIEDDO also applies the definitions outlined in the FAR in categorizing
the contracted manpower that is applied to directed, funded, and
supported programs and initiatives. The JIEDDO definition cited above
are consistent with the intent of the FAR. These definitions were
previewed with the GAO team prior to being implemented.
The chart below was provided to the GAO in October. Subsequent updates
were also provided.
The manpower management process is overseen by the Chief of the
Secretariat supported by a staff of manpower and personnel subject
matter experts within the Secretariat and within the supported
divisions and the two agencies. All requirements are reviewed,
assessed, validated, and justified prior to submission through the
Joint Improvised Explosive Device Defeat (JIEDD) Capability Approval
and Acquisition Management Process (JCAAMP) process to the senior
leadership for consideration. To refine the processes and to help
validate the requirements, JIEDDO employs an outside agency to work
with the requesting organizational entities. Each manpower proposal is
reviewed to ensure that the tasks are properly identified and
categorized and the manpower requirement properly articulates the
capabilities required to perform the task. Following the review and
assessment by the Secretariat staff and the outside agency, the
requirement is entered into the JCAAMP process.
Through the JCAAMP process, all manpower requirements identified by the
organizational entities and validated by the Secretariat are reviewed
by the COS Council and presented to the Executive Committee for
consideration and approval. The COS Council consists of representatives
of each of the JIEDDO Divisions, the Joint Center of Excellence (JCOE),
and the Counter-IED Operational Integration Center (COIC). The
Executive Committee includes the Director, the Deputy Director, the
Deputy Director for Operations and the Deputy Director for
Intelligence. The JCAAMP process ensures that manpower and other
resource requirements are appropriate and adequate and comply with the
intent of the provisions of DoD 1100.4 and all other issuances of the
Department of Defense associated with the management of departmental
manpower and resources.
JIEDDO manpower requirements are generally related to new programs,
initiatives, and projects developed in response to the ever-changing
improvised explosive device threat. JIEDDO manpower requirements are
driven by workload required to perform specific tasks as defined by the
program, project or initiative approved by the JIEDDO senior
leadership. Such proposals, projects and initiatives go through a
series of detailed review and analysis prior to approval by the senior
leadership. These include the JCAAMP, the JROC, JR2AB, JIPT, the SRSG
and various internal and external Departmental oversight committees
prior to approval. For programs and initiatives, in excess of 25
million dollars additional approval processes exist that require
approval at the Secretary level. Manpower requirements associated with
staff and infrastructure requirements are reviewed through the JCAAMP
process, which includes review by the COS Council, the Executive
Committee, and final approval by the Director. All manpower
requirements are proposed and sustained at the lowest level possible to
ensure the accomplishment of the mission. Additionally, JIEDDO manpower
is revalidated annually as part of the Annual JMD Review process. The
2007 JMD Review assessed approximately 100 new manpower requirements
but only approved 29 additional permanent civilian billets, 25
temporary civilian billets and 4 military billets for submission to the
Services for consideration. Because of the revalidation of
requirements, several of the new requirements were met by the
redistribution of existing manpower assets. A similar review is
currently on-going for 2008.
As an example of the level of effort taken to validate new manpower
requirements, the Counter- IED Operational Integration Center (COIC)
recently contracted for a Personnel Management Review that sought to
validate the organization's missions, functions statements, and
manpower requirements. The organization applied the workload standards
accepted by the Officer of the Secretary of Defense Policy and
Requirements, the Office of the Secretary of Defense Program Analysis
and Evaluation, and the Joint Staff in determining manpower
authorizations. The analysis captured total workload performed by
existing personnel and developed appropriate Full time Equivalent (FTE)
requirements for each task. The standards were applied to each of the
organizational elements producing an accurate assessment of the
manpower needed to achieve the missions assigned. This detailed
analysis was used to support the organization's manpower request
submitted for consideration in the current JMD Review.
The Report notes a preference on the part of the JIEDDO leadership to
employ contractor personnel rather than government civilians and
military personnel. JIEDDO has been aggressively taking the necessary
steps to increase the number of military and civilian billets required
to provide effective government oversight. However, the time required
to obtain the additional billets has forced JIEDDO to rely on
contractor personnel to fill temporarily requested government civilian
requirements. JIEDDO since its establishment has requested 54
additional government civilian billets, has pending with the Army a
request for 39 additional government civilian billets and is currently
reviewing a potential request for 27 additional government civilian
billets. The timelines for establishing, classifying, and hiring
government civilians does not lend itself to expeditious filling of
critical manpower billets. The timeline for obtaining approval of
additional billets normally exceeds 165 days. Following the approval of
a billet, the average processing time to fill such valid vacancies,
from initiation of position classification to selection, was an
additional 171 days. As an example, in the May 2007 time period 56 of
the 93 JIEDDO billets were vacant. Today, JIEDDO has 46 vacant
government civilian billets. The hiring process was further exacerbated
by the quality of the applicants and unattractiveness of the 25 Term
billets with limited appointments. Further challenging the process is
the need for highly specialized scientific and professional skills
required by JIEDDO's unique mission. Such time lags in the recruitment
processes have placed a significant strain on the organization's
ability to meet its government oversight and fiduciary
responsibilities.
(See comment 14.):
JIEDDO has solicited the help of senior Army and Defense officials in
an effort to shorten the hiring process timelines and to ensure that
the best qualified individuals are recruited and hired. With the
assistance of the Deputy Under Secretary of Defense for Civilian
Personnel Policy, the Army appointed a "Strategic Advisor" to assist
JIEDDO in addressing civilian personnel management issues. The Chief of
the Secretariat has initiated a weekly reporting process providing the
Civilian Personnel Advisory Center (CPAC) the status of pending
civilian personnel actions that: (1) require CPAC classification, (2)
require job announcements, (3) are awaiting release of a referral list,
(4) awaiting the extension of a Tentative Job Offer (TJO) following
selection, (5) awaiting a Firm Job Offer (FJO) after the TJO has been
accepted, and (6) the positions where FJOs have been accepted but a
report date has not been established. This is intended to ensure that
both the CPAC and JIEDDO have a firm accountability of pending hiring
actions.
While these actions have provided some relief to the hiring process,
the timelines for hire have not improved substantially. Pending the
approval of the current request under consideration by the Army JIEDDO
will have 85 vacant government civilian billets that will require
expeditious recruitment and hire.
The GAO report cites several examples of individuals not accounted for
on the JIEDDO JMD and manning document. The report cites the staff of
the Joint Testing Board as one example. This agency is an element of
the Army and is accounted for on their Table of Distributions and
Authorizations (TDA). While it is recognized that JIEDDO provides some
funding for this organization, its primary mission is in support of the
Army. The report also cites the use of contractors to pilot unmanned
aerial vehicles. The program that these individuals are involved with
is managed by the Army as well. As noted earlier, Service manpower
contributions that are applied by the Services to support their
internal counter-lED programs are accounted for and reported by the
Services. Since the Joint Test Board is an Army entity it is not
accounted or documented on the JIEDDO JMD or manning document.
(See comment 15.):
As noted earlier field service representatives based on the contract
vehicle that solicits the service being provided are tracked as Full
Time Equivalent (FTE) effort applied to perform the contracted tasks.
The report to the Senate included the FTE's converted to actual
manpower applied to these functions on 1 May 2007. JIEDDO recognizes
that the tasks contracted for drives the level of manpower contribution
required to achieve the contracted service and that the level of FTE
will or may fluctuate on a daily basis. The report to the Senate was an
attempt to provide visibility on this category of support and was not
intended to reflect a continuous manpower commitment associated with
the specific service contracts. JIEDDO does track the FTEs associated
with the effort of field service representatives and complies with the
guidance outlined in the Secretary of the Army direction on accounting
for contract services as outlined in the Secretary's guidance of 7
January 2005. JIEDDO also complies with the manpower accountability
requirements outlined in the Federal Acquisition Regulation.
Since the Army is the executive agent for support of JIEDDO, the
command recognizes the responsibility to apply the Army guidance on
contracting and has systematically taken the necessary steps to
transition all contracts under the Army contracting system. JIEDDO has
been working diligently to implement the provision of the Secretary of
the Army Memorandum of 7 January 2005 that outlines the procedures for
accounting for contract services. As these programs are transitioned to
the Services, the provisions of the Army guidance are applied
consistent with the policies for contracting of services outlined in
the Federal Acquisition Regulation. Additionally as programs are
transferred to the Services, the control, funding and accountability
are also transferred. As an example, this fiscal year, the Law
Enforcement Program will be transferred to the Army. Once the transfer
is completed, the manpower and funding associated with this program
will be reported by the Army and not JIEDDO.
The Report notes that the contractors maintaining the infrastructure at
the Counter-IED Operational Integration Center (COIC) are not being
accounted for on the JIEDDO JMD and manning documents. The facility
occupied by the COIC is contracted for by the Office of the Secretary
of Defense (OSD). The facility houses other government agencies. The
manpower associated with support of this facility also services the
other agencies. JIEDDO recognizes and has begun to track the manpower
specifically associated with the JIEDDO occupied portion of the
facility. The actual number of individuals involved in this process
attributed to JIEDDO support is under negotiation between JIEDDO and
the OSD. Once this number is validated manpower that specifically can
be attributed to the support of JIEDDO will be tracked on the JIEDDO
manning document.
JIEDDO has continuously and systematically applied additional controls
to the management of the manpower associated with the command's
program, projects, and initiatives. As an example, in November 2007
JIEDDO migrated all civilian billets under the National Security
Personnel System (NSPS). The NSPS strengthens our ability to accomplish
the mission in an ever-changing national security environment and
accelerates the Department's efforts to create a Total Force (military,
civilian personnel, Reserve, Guard, and contractors), operating as one
cohesive unit, with each performing the work most suitable to their
skills. NSPS provides a human resources system that appropriately
recognizes and rewards our employees' performance and the contributions
to the JIEDDO mission.
JIEDDO has also instituted the Manpower Staffing Request System within
the JCAMMP program to formalize the management of new manpower
requirements. The purpose of the JIEDDO MSRF is to provide an
efficient, centralized, and automated method for requesting additional
manpower and personnel. JIEDDO has formulated and published common
manpower definitions cited earlier to provide consistency in the
application of manpower resources.
(See comment 16.):
JIEDDO has also issued various policy statements that refine the
manpower management process. As an example, Policy Memorandum 25
provides guidance on the selection and hiring of GS/GG 14 and 15s
setting standards for the selection processes and mandating Deputy
Director review prior to final selection. Policy Memorandum 24 set
policy for the reimbursement of PCS expenses as a recruitment tool. The
entitlements provided in each case will be in accordance with the
policies published by the Department of the Army as executive agent for
our civilian component.
Policy Memorandum 20 establishes management controls, rules, methods,
procedures, and devices to be used to ensure that business is conducted
ethically. These controls assure the JIEDDO leadership that resources-
military and civilian personnel, property, and funds are employed and
accounted for properly. The JIEDDO management control process ensures
the periodic evaluation of the organization's most critical controls.
The management control process also provides a means for disclosing any
shortcomings detected. The process involves assessing safety
operations, safeguarding resources, complying with laws and policy, and
using resources efficiently and effectively. The process also helps
identify vulnerabilities and minimize risks. Management controls are a
leadership responsibility and an essential part of being prudent
stewards of the organizations limited resources.
Policy Memorandum 13 provides guidance on duty hours, overtime,
compensatory time and other administrative policy applicable to the
staff. Memorandum 16A speaks directly to the control of personnel
requiring that all civilian employees and contractor report the hours
worked in support of JIEDDO initiatives. The effort was initiated to
obtain a clear understand of the workload required to support the
JIEDDO missions.
Policy Memorandum 28 requires that all JIEDDO activities that seek to
propose organizational changes to include; internal organizational
structures, manpower increases, and/or recategorizations or
reallocations of manpower or personnel must submit through the
Secretariat a formal proposal for review by the COS Council and
approval for the Director. The underlying guidance recognizes that with
the unique challenges brought on by the counter-lED fight, there is a
need to reflect on the organizational structure, manning, and processes
that have supported our efforts. There is a realization that the
organization must evolve in response to the ever-changing threat but
such an evolution must be structurally sound. The policy also
recognizes that such evolution should not disrupt the synergy that has
been the underpinning of our successes. Finally, the policy recognizes
that any structural changes be responsive to the mission and to the
needs of the individuals who are dedicated to the resolution of the IED
problem.
Another action initiated by JIEDDO was to institute a formal records
management program (mentioned earlier in our response). JIEDDO
Directive 1015.1A outlines the responsibilities for life-cycle
management (creation, maintenance and use, and disposition) of
information as records in all media, including electronic. This
includes the documentation supporting the management of manpower. While
in the infancy, the program will help to ensure that all manpower
requirements are appropriately documented and reinforce JIEDDO's effort
to enhance accountability of the organization's manpower.
JIEDDO is also in the process of developing and instituting matrices to
enable an assessment of the organizational functions, missions, goals
and processes. These matrices will reinforce the manpower and personnel
management processes insuring that manpower resources are allocated to
the most needed requirements and to provide increasingly granular
alignment of resources against missions. The data will also support the
development of manpower requirements. This will support the development
of a synergy in the application of manpower and personnel. It is
expected that a fully developed matrices system will be in place by the
end of 2009.
These initiatives have had a positive affect on the ability of the
organization to effectively manage and oversee the manpower and
personnel programs. JIEDDO had and will continue to work systematically
to enhance its oversight and accountability of all categories of
personnel and to refine policies, procedures, and processes to manage
the command manpower and personnel resources.
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
The following are our comments on the Department of Defense's (DOD)
letter dated February 14, 2008.
GAO Comments:
1. DOD states that before our audit commenced, JIEDDO had worked
diligently to formalize and document its processes to ensure that
internal controls were in place. Further, DOD asserts that "many of
these processes were finalized during the audit timeframe," and then
lists details on four specific "samples" where JIEDDO has "finalized,
documented and implemented processes and procedures." While we
recognize that JIEDDO has undertaken efforts to improve its operations
and resource management, the specific efforts described in DOD's
comments overstate the status and degree of implementation regarding
these four "samples." Specifically, responses 2 through 5 summarize our
conclusions regarding the status and potential effectiveness of JIEDDO
"samples" contained in DOD's comments.
2. Before our review began in May 2007, JIEDDO planned to spin off part
of an existing division to form a new acquisition oversight division.
JIEDDO did not identify the planned division as relevant to our audit
objectives, and while we were aware of the plans for the new division,
we did not see documented objectives, plans, or policies describing the
division's role or purpose. The first policy document JIEDDO issued
outlining the oversight division's responsibilities was a broad
instruction issued in November 2007, which was too late for us to
review in the conduct of our audit. Further, as of mid-February 2008,
JIEDDO was still drafting a roles and procedures manual to implement
the instruction's requirements for the new division, and none of the
five civil service positions planned for the division had been
filled.[Footnote 29] Consequently, this particular "sample" cited in
the DOD comments does not by itself support the statement that JIEDDO
has "finalized, documented and implemented processes and procedures."
3. JIEDDO issued this instruction to define and implement JIEDDO's
"rapid acquisition management responsibilities" established in its
charter documents and presented to us when we met to close out our
fieldwork.[Footnote 30] To follow up on the comprehensiveness of the
instruction related to the internal control weaknesses we identified
during our review, we had brief follow-up conversations with JIEDDO
personnel involved in the development of the instruction. At that time,
we determined that specific steps regarding addressing the control
weaknesses identified were not fully developed because JIEDDO divisions
had not yet documented or developed the specific roles,
responsibilities, processes, and procedures at the division level.
Further, JIEDDO had not yet identified the persons who would
participate in developing and drafting proposed division-level
instructions for coordination and approval. One official stated that to
have done so before issuing the instruction would have delayed issuance
by 1 to 2 months. As with the prior item cited in DOD's comments on our
recommendation, this instruction does not by itself support the
statement that JIEDDO has "finalized, documented and implemented
processes and procedures."
4. While JIEDDO has established the Records Management Division in
recognition of the importance of good documentation, it is still an
effort in development and not fully implemented. The comments provided
state that some elements of JIEDDO's records management processes and
procedures are still in draft and are not scheduled to be initially
operational until March 2008 or fully operational until May 2008. Based
on DOD's comments, we again conclude that establishment efforts for
this division do not support the summary statement that JIEDDO has
"finalized, documented and implemented processes and procedures."
5. JIEDDO is in the process of adopting a new financial management
system, adapted from an existing system, and is expecting full
implementation of the new system by March 2008. While JIEDDO has
identified the objectives of the new system and lists expected
improvements for the organization, the comments clearly indicate that
all requirements for the new system have not yet been gathered, which
makes full implementation by March 2008 uncertain. Further, given the
tasks yet to be accomplished for full implementation, JIEDDO's new
system status does not support the summary statement that JIEDDO has
"finalized, documented and implemented processes and procedures."
6. DOD states emphatically that funding authorizations are always made
and documented according to the criteria in JIEDDO's charter directive.
As we reported, this was not the case for the items we selected in our
review. DOD identified a new resource management checklist in its
comments, and while it constitutes a new control measure that is a
positive step, we were not able to test compliance with the new control
or assess its effectiveness.
7. JIEDDO's reasons for initial assignment and change in its lines of
operations accounting do not address the specific inconsistency and
potential impact on the reliability of its financial reports that we
reported when JIEDDO moved Joint IED Defeat Test Board expenses to its
attack the network line of operation. Further, changes in controls over
recording of fund use into expenditure categories or lines of operation
are either still in development or were not sufficiently developed for
us to evaluate their effectiveness in meeting our recommendation's
intent.
8. DOD's statements acknowledge JIEDDO's internal control weaknesses.
The actions proposed and those already taken, if fully implemented,
would substantially address the intent of our recommendation.
9. Expressing full agreement with the findings in our report, DOD
proposed an alternative approach for communicating the status of its
efforts to Congress. We agree that DOD's approach for reporting its
progress in implementing internal control measures satisfies the
overall intent of our recommendation. Consequently, we modified our
original recommendation to reflect this change.
10. JIEDDO outlines steps that it is taking toward identifying and
tracking civilian, military, and contractor personnel and to improve
its personnel management practices that we highlighted in our report.
While a positive first step, other efforts are needed to
comprehensively account for all personnel, as noted in comments 11
through 16.
11. JIEDDO introduces processes that do not directly address our
recommendation. We were aware of the development of JIEDDO strategic
human capital plan, and based on our review of JIEDDO's working
documents, we concluded that the strategic human capital plan would not
directly address the extent to which JIEDDO would identify and track
all of its personnel. Also, JIEDDO had not instituted prior to the
conclusion of our audit its Manpower Staffing Request System within the
JCAAMP program to formalize the management of new manpower
requirements. While these steps may assist JIEDDO in improving its
personnel management, they do not directly address our recommendation.
12. We recognize and understand DOD's comments regarding accounting for
JIEDDO personnel who staff programs under the control and direction of
the military services and other DOD and government departments,
including those funded wholly or in part by JIEDDO. However, we believe
that as an organization, JIEDDO has an interest in accounting for all
civilian, military, and contractor personnel working in any capacity
for JIEDDO, as a matter of sound personnel management. This information
can be collected and reported with caveats stating that the personnel
are, in whole or part, funded by JIEDDO.
13. DOD noted that our report suggested that JIEDDO does not account
for categories of contractor personnel, such as field service
representatives, interagency liaisons, law enforcement training
personnel, interagency partnership team members, and infrastructure
contractors, and stated that the information was included in the Senate
report. During our audit and as stated in our report, we recognized
that this information with the associated charts was included in the
Senate report, but we found that it was not included in any of JIEDDO's
personnel documentation or daily staffing reports prior to the
development of the Senate report. As a result, we questioned why JIEDDO
did not account for these categories of personnel in its daily staffing
reports or in other personnel documentation.
14. DOD explained JIEDDO's challenges in hiring staff and the steps it
is taking to increase the number of military and civilian billets and
to facilitate the hiring of civilian employees by working with the Army
and the Office of the Secretary of Defense. While these steps appear to
address our recommendation and other areas of concern, we cannot
validate the information because these steps occurred after we
completed our audit.
15. We disagree with DOD's statement that JIEDDO provides some funding
for the staff of the Joint Test Board. According to financial
documentation we obtained and corroborated with interviews, the Joint
Test Board's primary mission is to provide support to JIEDDO as stated
in JIEDDO's charter, DOD Directive 2000.19E.
16. See comment 11.
[End of section]
Appendix III GAO Contact and Staff Acknowledgments:
GAO Contact:
William M. Solis, (202) 512-8365 or solisw@gao.gov:
Acknowledgments:
In addition to the contact named above, the following individuals made
contributions to this report: Cary Russell, Assistant Director; Grace
Coleman; Eric Essig; Paul Kinney; Ronald La Due Lake; Stephen Lipscomb;
Lonnie McAllister; Paulina Reaves; James Reynolds; Brian Shiels; Glenn
Slocum; Yong Song; and John Strong.
[End of section]
Footnotes:
[1] Congressional Research Service, Improvised Explosive Devices (IEDs)
in Iraq and Afghanistan: Effects and Countermeasures (Washington, D.C.:
Aug. 28, 2007).
[2] S. Rep. No. 109-292 at 239-40 (2006).
[3] GAO, Defense Management: A Strategic Plan Is Needed to Guide the
Joint Improvised Explosive Device Organization's Efforts to Effectively
Accomplish Its Mission, GAO-07-377C (Washington D.C.: Mar. 28, 2007).
[4] DOD Directive 1100.4, "Guidance for Manpower Management," para.
4.4.10 (Feb. 12, 2005).
[5] S. Rep. No. 110-37 at 26-27 (2007).
[6] DOD uses MIPRs as the primary documents to order goods or services
from other DOD components. MIPRs are prepared on DD Form 448, "Military
Interdepartmental Purchase Request," and include a description of the
supplies or services requested, unit price, total price, period of
performance, and fund citation.
[7] In this case, the acquiring department would be one of the military
services and the requiring department would be JIEDDO.
[8] OMB Circular A-123, Management's Responsibility for Internal
Control, Section I (2004).
[9] 31 U.S.C. § 3512 (2007).
[10] GAO, Internal Control: Standards for Internal Control in the
Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November
1999).
[11] S. Rep. No. 110-37 at 26-27 (2007).
[12] DOD Directive 1100.4, "Guidance for Manpower Management," para.
4.4.10.1 (Feb. 12, 2005).
[13] S. Rep. No. 110-37 at 26-27 (2007).
[14] GAO/AIMD-00-21.3.1.
[15] We have issued many reports that highlight the importance of
addressing internal control weaknesses. For example, see GAO, Premium
Class Travel: Internal Control Weaknesses Governmentwide Led to
Improper and Abusive Use of Premium Class Travel, GAO-07-1268
(Washington, D.C.: Sept. 28, 2007); Financial Audit: Significant
Internal Control Weaknesses Remain in the Preparation of the
Consolidated Financial Statements of the U.S. Government, GAO-07-805
(Washington, D.C.: July 23, 2007); and Veterans Affairs: Lack of
Accountability and Control Weaknesses over IT Equipment at Selected VA
Locations, GAO-07-1100T (Washington, D.C.: July 24, 2007).
[16] GAO/AIMD-00-21.3.1.
[17] JIEDDO issued JIEDDO Instruction 5000.01 on November 9, 2007, to
define and implement the rapid acquisition management responsibilities
for counter-IED efforts contained in DOD Directive 2000.19E.
[18] GAO/AIMD-00-21.3.1.
[19] GAO/AIMD-00-21.3.1.
[20] GAO/AIMD-00-21.3.1.
[21] The statement is required by FMFIA to disclose material weaknesses
identified through an evaluation to determine the effectiveness of an
entity's internal controls for its overall program, administrative, and
operational activities and describe the plans and schedules to correct
identified weaknesses.
[22] Department of Defense Office of the Inspector General, Department
of the Army Purchases from Government sources, Report No. D-2007-075
(Arlington, Va.: Mar. 22, 2007).
[23] GAO-07-377C.
[24] Field service representatives are contractors who are responsible
for providing a range of support (goods and services) needed while an
equipment item or system is in use in the field versus in production or
manufacture.
[25] The Joint Test Board is an organization within the Army and funded
by JIEDDO that the Deputy Secretary of Defense directed be established.
Its mission is to synchronize testing of communications and counter-IED
and other systems, to ensure that they can operate and are compatible
with other JIEDDO initiatives currently fielded in Iraq and
Afghanistan. The board has been in operation since fiscal year 2006
with current fiscal year 2007 funding commitments of $92 million.
[26] OMB Circular A-76 (Revised), Performance of Commercial Activities,
Attachment A, sec. B.1.a (2003).
[27] GAO, Military Operations: High-Level DOD Action Needed to Address
Long-standing Problems with Management and Oversight of Contractors
Supporting Deployed Forces, GAO-07-145 (Washington, D.C.: Dec. 18,
2006).
[28] We excluded 1 of the top 10 attack the network initiatives because
its sensitive nature and remote location made obtaining documentation
difficult.
[29] There are approximately 20 positions identified in the new
division. Two military staff currently manage the contract staff
filling the other positions in the division.
[30] Joint IED Defeat Organization Instruction 5000.01, Joint
Improvised Explosive Device Defeat Capability Approval and Acquisition
Management Process (JCAAMP), (Nov. 9, 2007).
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