Defense Acquisition: DOD Should Clarify Requirements for Assessing and Documenting Technical-Data Needs

In May 2011, GAO reported that a sample of acquisition programs partially addressed four technical-data-documentation requirements. We also reported that DOD had issued guides--that are voluntary for program managers to use--to improve technical-data decision making. Despite these voluntary guides, DOD technical-data policies remained unclear. As a result, program managers had not always documented required information on technical data in acquisition strategies. We therefore recommended that DOD clarify requirements for documenting long-term technical-data requirements in program acquisition strategies and acquisition plans. In December 2011, DOD issued the "Open Systems Architecture Contract Guidebook for Program Managers." This guidebook provides direction that program managers may voluntarily choose to follow as they develop their technical-data strategies and it is therefore a positive step. However, as was the case for guidebooks in place at the time of our 2011 report, program managers are not required to follow this guidebook. In November 2013, DOD issued an interim acquisition policy that modified technical data requirements, however the new policy does not clarify the information that program managers are required to document in acquisition strategies.

In May 2011, GAO reported that a sample of acquisition programs partially addressed four technical-data-documentation requirements. We also reported that DOD added a requirement that program managers conduct a business-case analysis for systems' long-term technical-data needs. However, DOD had not issued policy or other internal controls that described how to conduct this analysis. In 2008, we reported that the military services inconsistently completed similar business-case analyses because DOD had not issued instructions in policy on how to conduct them. Because OSD has not issued policy instructing program managers on how to conduct and document the analyses, program managers may conduct incomplete or inconsistent analyses and report inconsistently on important elements of the analyses and findings. Similar to the situations we described in our 2008 report, program managers may not include key required elements of business-case analyses, such as assumptions, feasible alternatives, and costs and benefits that support their technical-data decisions. We therefore recommended that DOD issue instructions for program managers to use when conducting business-case analyses that are part of the process for determining the levels and types of technical data and technical-data rights needed to sustain DOD's systems. In August 2011, DOD issued the "Open Systems Architecture /Data Rights Business Case Analysis Guide & Templates," which is a positive step that is consistent with GAO's recommendation. However, this guidebook did not include required instructions for program managers to use when conducting business-case analyses for determining the technical data needed to sustain DOD's systems. In November 2013, DOD issued an interim acquisition policy, however the new policy does not include required instructions for program managers to use when conducting business-case analyses for determining the technical data needs.