Defense Management:

More Transparency Needed over the Financial and Human Capital Operations of the Joint Improvised Explosive Device Defeat Organization

GAO-08-342: Published: Mar 6, 2008. Publicly Released: Mar 6, 2008.

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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.

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.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Secretary of Defense should 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.

    Agency Affected: Department of Defense

    Status: Closed - Not Implemented

    Comments: DOD did not concur with this recommendation, stating that JIEDDO's Quarterly Reports to Congress were specifically focused on describing the IED threat and JIEDDO's efforts to counter that threat and that including JIEDDO's internal "administrative efforts" within the report was not in keeping with the intent of the report and would serve to weaken the report's focus. Instead, DOD planned to implement an OSD policy recommendation for the Deputy Secretary of Defense to direct JIEDDO to provide ranking and minority leaders of the Armed Services and Appropriations Committees with a report within one year from the date of the GAO final report regarding steps JIEDDO has taken to address and correct the weaknesses identified by GAO. If accomplished, we believe this alternative action would have satisfied the intent of our recommendation. However, according to JIEDDO officials, as of July 2012, the Deputy Secretary of Defense had not directed JIEDDO to produce any such report to the defense committees and no such report has been produced by JIEDDO. Accordingly, we are closing this recommendation as not implemented.

    Recommendation: 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, the Secretary of Defense should 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 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.

    Agency Affected: Department of Defense

    Status: Closed - Implemented

    Comments: DOD concurred with this recommendation and stated that JIEDDO has developed a Five-Year management Control Plan. JIEDDO provided additional training and instructions to all of its personnel and developed key checklists, which are an integral piece of the Management Control Program. JIEDDO also identified Management Control Administrators and Assessable Unit Managers and provided targeted training to ensure that checklists are not just completed, but that actual testing of key controls was accomplished. JIEDDO has taken several other actions to improve its Management Internal Control program. For example: (1) in August 2010 JIEDDO hired and experienced Management Control Administrator to build a strong internal control program and in September 2010, published an Internal Assessments Plan Standard Operating Procedure which defines roles and responsibilities for senior leadership, Assessable Unit Managers, and the Management Control Administrator for the Management Internal Control program; (2) in February 2011 JIEDDO published a desk-side guide for Management Control Administrators and Assessable Unit Managers; (3) in February 2011 JIEDDO implemented Management Internal Control program training at various levels and points in JIEDDO; and (4) in June 2011 updated an organization-wide risk assessment. In addition, JIEDDO has taken several steps to identify and correct its weaknesses. In its July 2009 Statement of Assurance for management controls to DOD, JIEDDO identified and reported its funds control process as a material weakness. JIEDDO's self-disclosure of a material weakness demonstrates a willingness to acknowledge its serious shortfalls to external parties and address remediation transparently. Further, in 2011, the steps JIEDDO has taken to remedy weaknesses in its Managers' Internal Control Program were corroborated and validated by the Office of the Secretary of Defense's Office of Financial Improvement Audit Readiness, concluding in June 2012 that JIEDDO's Managers' Internal Control Program material weaknesses previously reported in its Statement of Assurance had been successfully remedied. Accordingly, we are closing this recommendation as implemented.

    Recommendation: 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, the Secretary of Defense should 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 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.

    Agency Affected: Department of Defense

    Status: Closed - Implemented

    Comments: DOD concurred with this recommendation and has undertaken actions to: (1) develop guidance for accounting and budget personnel to ensure that correct cost categories are used in the recording of accounting data; (2) fully staffed the division responsible for financial management and; (3) develop management directives, administrative policies, standard operating procedures, and other documentation that describe specific organizational responsibilities. JIEDDO has improved its financial management system--the Comprehensive Costs and Requirements System--by implementing and strengthening embedded transaction control and improved proper classification of transactions through its quality assurance program and staff training. JIEDDO has also developed and implemented a processing checklist to ensure that all transactions are properly coded for accounting classifications before executing funding transaction and has continued to revise controls as needed. For example, JIEDDO's Financial Management division revised its standard operating procedure to include a process for classifying expenditures and to correct misclassification's when identified. This included comprehensive review by appropriate budget analysts prior to the dispersal of funds. Moreover, JIEDDO's Financial Management division redesigned templates within its Comprehensive Costs and Requirements System workflow in an effort to capture obligation entries for supervisor review and supporting documentation. The revision and implementation of the JIEDDO Financial Management division's standard operating procedure is necessary to ensure that JIEDDO transactions are properly classified by lines of operation and other expenditure categories used by JIEDDO, and to promptly and properly correct misclassifications when identified. Accordingly, we are closing this recommendation as implemented.

    Recommendation: 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, the Secretary of Defense should 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 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.

    Agency Affected: Department of Defense

    Status: Closed - Implemented

    Comments: DOD concurred with this recommendation, responding that as of 6/5/2008 it had completed its planned action and that JIEDDO now releases funding documents only after proper authorization is received and documented by either a JIEDDO funding memorandum (for initiatives less than $25M) or after Deputy Secretary of Defense approval (for initiatives in excess of $25M). JIEDDO acknowledged that in the past, there has been some confusion regarding the actual definition of the $25M. The new process requires that as soon as it is determined that an initiative will exceed the $25M threshold, DEPSECDEF approval is obtained. In another effort to ensure adequate internal controls are included in its processes, JIEDDO developed mandatory minimal transaction documentation that is required to be completed and kept on file. In GAO's subsequent work at JIEDDO, our objectives included assessing the efficacy of actions JIEDDO has taken to address our original findings and recommendations. We have noted a marked increased in JIEDDO's attention and efforts to improve its resource management to address this recommendation. For example, in December 2010, JIEDDO revised its Approval and Acquisition Management Process by creating a new mechanism for review and management of requests for funding. Specifically, JIEDDO created a new requirements assessment board that is independent of its technology acquisition directorate, thereby segregating key funding decisions from the entity that nominates/proposes JIEDDO counter-IED initiatives--the technology acquisition directorate. The board reviews and scrutinizes requests for funding and must validate all requirements before funding actions are executed. Accordingly, we are closing this recommendation as implemented.

    Recommendation: 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, the Secretary of Defense should 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 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.

    Agency Affected: Department of Defense

    Status: Closed - Implemented

    Comments: DOD concurred with this recommendation, responding as of 6/5/2008 that it had completed its planned action. DOD stated that JIEDDO had worked to formalize and document its processes to emplace internal controls in JIEDDO. Subsequent JIEDDO actions demonstrated an improved understanding of internal controls and evidenced compliance with DOD criteria for identification and disclosure of weaknesses. Specifically, JIEDDO (1) developed a Financial Management Standard Operating Procedure; (2) implemented controls to correct its material weaknesses, and; (3) published Program Budget Advisory Council instructions that outline the use of appropriated funds against a master spending plan. JIEDDO accomplished this with the help of an experienced, independent public accounting firm. According to JIEDDO officials, the engagement of an experienced accounting firm, and the initial steps taken thus far, directly resulted from GAO's work, findings, and recommendations. As a result, use of funds is better scrutinized by JIEDDO based on associated risks to the organization and accordingly we are closing this recommendation as being implemented.

    Recommendation: To improve JIEDDO personnel or manpower management and provide Congress with the information it needs to perform its oversight duties effectively, the Secretary of Defense should 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 Affected: Department of Defense

    Status: Closed - Implemented

    Comments: DOD concurred with this recommendation and JIEDDO has instituted an improved process for routinely identifying, categorizing, and reporting government and contractor personnel employed in the work of JIEDDO. This system, the Personnel Statistics (PERSTAT) and Manpower Accountability Report system, accounts for and reports the status of all personnel and positions assigned on a daily basis, including all contractors employed by JIEDDO on counter-IED initiatives. JIEDDO completed the last phase of its PERSTAT system in its October 26, 2010 issuance of a written detailed operating procedure documenting JIEDDO staff's responsibilities under the system. By adopting and implementing the use of PERSTAT, JIEDDO is in a better position to readily provide accurate and reliable information to internal and external decision makers on its staffing levels, as well as to effectively plan for its future workforce needs. Accordingly, we are closing this recommendation as implemented.

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