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entitled 'NOAA: Next Steps to Strengthen Its Acquisition Function' 
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Report to the Chairman, Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 

GAO: 

June 2006: 

NOAA: 

Next Steps to Strengthen Its Acquisition Function: 

NOAA Acquisition Function: 

GAO-06-594: 

GAO Highlights: 

Highlights of GAO-06-594, a report to the Chairman, Committee on 
Finance, U.S. Senate 

Why GAO Did This Study: 

The National Oceanic and Atmospheric Administration (NOAA) accounts for 
about half of the Department of Commerce’s (Commerce) acquisition 
spending, over $851 million in fiscal year 2005 alone. In recent years 
however, NOAA has experienced instances of poor contract management. 

GAO was asked to determine if NOAA is positioned to effectively carry 
out its acquisition function. Specifically, GAO assessed the extent to 
which NOAA has structured an acquisition organization that provides 
appropriate oversight; established policies and processes that promote, 
among other things, a knowledge-based acquisition process for 
development and production of complex systems; and planned and managed 
its contracting workforce to address future retirement challenges. 

What GAO Found: 

NOAA has yet to structure all of its field acquisition activities under 
the direct oversight of its acquisition organization, increasing the 
risk that taxpayers are not getting the best value for their dollars. 
To improve oversight of its acquisition function, NOAA reorganized in 
2005 by having all acquisition divisions report to the NOAA Director of 
Acquisition and Grants. However, NOAA’s acquisition director still 
lacks direct line authority to oversee a National Weather Service field 
office that is responsible for one of the agency’s contracts worth up 
to half a billion dollars. Also, without appropriate oversight from the 
acquisition organization, collateral duty field staff who are not 
career contracting officers have bought millions of dollars in goods 
and services. Our work has shown that a well-functioning acquisition 
organization has direct lines of oversight between the head of 
acquisition and various components to help enforce policies that enable 
efficient and effective contract spending. 

Although NOAA has established clear and consistent policies for some 
key areas, such as advance acquisition planning, the agency lacks a 
knowledge-based process for developing and producing complex systems—a 
situation that can increase the risk of cost increases and schedule 
delays. NOAA is missing key elements that promote successful outcomes 
for complex developmental systems because it must adhere to Commerce’s 
acquisition policies that do not support a knowledge-based approach. 
Without such an approach, the multibillion-dollar satellite investment 
that NOAA is in the early stages of acquiring is at a higher risk of 
not meeting program requirements. 

NOAA has yet to focus on succession planning and management for its 
contracting workforce, although the agency is pursuing hiring 
flexibilities to recruit new contracting employees in anticipation of 
an impending wave of retirements. NOAA is facing a human capital 
challenge because of its aging contracting workforce and has reported 
that about 43 percent of contracting employees are now eligible to 
retire or will be eligible to retire by 2009. While senior acquisition 
managers are concerned with the loss of a high percentage of their 
contracting staff to retirement and other attrition, NOAA has not 
specifically addressed such contracting workforce challenges in its 
strategic human capital plan. Also, it is unclear whether human capital 
planning under way by Commerce will determine the gaps in numbers and 
skills in the contracting workforce. Unless the future retirement and 
workforce capacity challenges are strategically addressed, NOAA could 
soon lose a significant portion of its contracting knowledge base. 

What GAO Recommends: 

GAO recommends establishment of policies for using a knowledge-based 
approach for complex developmental acquisitions and other actions to 
strengthen oversight of NOAA contracting activities and build capacity 
of NOAA’s contracting workforce to address the agency’s retirement 
challenges. After reviewing a draft of this report, Commerce concurred 
with our findings and recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-594]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Lisa Shames, 202-512-
4841, shamesl@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

NOAA Lacks Oversight of Some Field Acquisition Activities: 

Advances in Day-to-Day Acquisition Policies Not Matched in Policies for 
Complex Developmental Systems: 

NOAA Has Taken Limited Actions to Address Contracting Workforce 
Retirement Challenges: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Knowledge-Based Acquisition Framework for Complex 
Developmental Systems: 

Appendix III: Comments from the Department of Commerce: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: NOAA's Acquisition Divisions and Locations: 

Figures: 

Figure 1: Organizational Placement of NOAA Acquisition Function: 

Figure 2: Demographics of the NOAA Contracting Specialists and 
Procurement Analysts as of September 2005: 

Figure 3: Knowledge-Based Acquisition Framework: 

Abbreviations: 

CPDF: Central Personnel Data File: 

GOES-R: Geostationary Operational Environmental Satellite: 

GS: general series: 

NOAA: National Oceanic and Atmospheric Administration: 

OPM: Office of Personnel Management: 

United States Government Accountability Office: 
Washington, DC 20548: 

June 7, 2006: 

The Honorable Charles E. Grassley: 
Chairman: 
Committee on Finance: 
United States Senate: 

Dear Mr. Chairman: 

The National Oceanic and Atmospheric Administration (NOAA) is one of 
the largest agencies within the Department of Commerce (Commerce) and 
accounts for 45 percent of the department's dollars spent on 
acquisition. In fiscal year 2005 alone, NOAA's acquisition organization 
contracted for over $851 million in goods and services in support of 
the agency's mission. NOAA's mission is to understand and predict 
changes in the Earth's environment and conserve and manage coastal and 
marine resources to meet the nation's economic, social, and 
environmental needs. To accomplish this mission, NOAA acquires goods 
including ships, satellites, aircraft, and high-performance computers 
as well as services such as hydrographic surveys, fisheries analyses, 
and buoy maintenance. For the first time, NOAA is managing an expected 
$6.2 billion acquisition investment for developing a complex 
geostationary environmental satellite. 

NOAA relies more and more on contractor support to conduct its mission- 
critical work. However, in recent years, NOAA has experienced instances 
of poor contract management that prompted the Commerce Inspector 
General to designate management of Commerce's acquisition processes as 
one of the top 10 departmental management challenges. The Commerce 
Inspector General identified a lack of effective oversight and 
management controls over acquisition processes as a contributing factor 
to the poor contract management. 

In response to your request, we examined whether NOAA is positioned to 
effectively carry out its acquisition function. Specifically, we 
assessed the extent to which NOAA has (1) structured an acquisition 
organization that provides appropriate oversight; (2) established clear 
and consistent acquisition policies and processes that promote, among 
other things, a knowledge-based acquisition process for development and 
production of complex systems; and (3) planned and managed its 
contracting workforce to address future retirement challenges. See 
appendix I for additional details on scope and methodology. 

To conduct this work, we assessed information from NOAA headquarters 
and acquisition divisions and compared this information against what 
our previous work has shown to be best acquisition practices. We 
reviewed agency directives, memorandums, and other documentation; 
interviewed agency officials; and analyzed agency systems and 
processes. We conducted our review from August 2005 to April 2006 in 
accordance with generally accepted government auditing standards. 

Results in Brief: 

NOAA has yet to structure all of its field acquisition activities under 
the direct oversight of its acquisition organization, increasing the 
risk that taxpayers are not getting the best value for their dollars. 
To improve oversight over its acquisition function, NOAA reorganized 
its acquisition divisions nationwide under the single authority of a 
headquarters office, headed by the Director of Acquisition and Grants. 
Yet NOAA's acquisition director still lacks direct line authority to 
oversee the National Data Buoy Center, which is responsible for one of 
the agency's largest contracts--worth up to half a billion dollars. In 
addition, field staff who are not contracting officers but whose 
collateral responsibility is to acquire millions of dollars in goods 
and services annually manage contract actions without appropriate 
oversight from the acquisition organization. Our best practices work 
has shown that a well-functioning acquisition organization has direct 
lines of authority and oversight between the head of acquisition and 
various components of the organization in order to enforce acquisition 
policies effectively. 

Although NOAA has established clear and consistent acquisition policies 
and processes in some key areas such as advance acquisition planning, 
the agency still lacks a knowledge-based acquisition process for 
development and production of complex systems. NOAA acquires a number 
of high-cost systems and is in the early acquisition stages of 
developing a new multibillion-dollar geostationary environmental 
satellite. However, it must adhere to Commerce's policies for 
development and production of major systems and does not support a 
knowledge-based approach to acquiring such complex developmental 
systems. Senior Commerce and NOAA officials believe that NOAA program 
managers remain uncertain about the information they must provide to 
senior leaders for each key decision point. We have found that a 
knowledge-based approach enables program managers to be reasonably 
certain, at critical junctures, or "knowledge points," in the 
acquisition life cycle, that complex developmental systems are likely 
to meet established cost, schedule, and performance targets, and 
therefore they will be able to provide senior leaders with information 
needed to make sound investment decisions. 

NOAA has yet to focus on succession planning and management for its 
contracting workforce, although recognition of an impending wave of 
retirements prompted the agency to obtain approval to use more flexible 
direct hire authority to recruit new contracting employees. NOAA is 
facing a human capital challenge because of its aging contracting 
workforce and could soon lose a significant portion of its contracting 
knowledge base. For example, almost 52 percent of its contracting 
specialists are more than 49 years old, and 66 percent have served at 
least 20 years with the agency. Senior NOAA acquisition managers 
expressed concern about the looming retirements and other attrition of 
a high percentage of the contracting workforce. However, while NOAA 
completed a strategic human capital plan to help ensure it has the 
expertise necessary to achieve its mission, the plan does not address 
potential gaps in the agency's contracting workforce. Also, while 
Commerce's acquisition management office is developing a human capital 
plan to address challenges facing the contracting workforce, it is too 
early to determine if it will address the gaps in numbers and skills. 

We are making a recommendation to the Secretary of Commerce to 
incorporate a knowledge-based approach for complex developmental 
systems in revising the department's acquisition policies and 
processes. We are also recommending that the Under Secretary of 
Commerce for Oceans and Atmosphere (1) take the necessary steps to 
provide oversight authority for NOAA's acquisition director over field 
acquisition activities and (2) conduct an assessment of the contracting 
workforce needed to help achieve NOAA's mission-critical work. After 
reviewing a draft of this report, Commerce concurred with our findings 
and recommendations. The full text of Commerce's comments may be found 
in appendix III. 

Background: 

The NOAA acquisition function is carried out by the headquarters 
acquisition office, headed by the Director of Acquisition and Grants, 
as well as 10 divisions, of which 6 are located at NOAA headquarters in 
Silver Spring, Maryland, and 4 in regions throughout the country (see 
table 1). In 2005, NOAA employed 123 contracting and acquisition 
support staff in its acquisition function across headquarters and 
regional locations. 

Table 1: NOAA's Acquisition Divisions and Locations: 

Acquisition division: National Environmental Satellite, Data, and 
Information Service; 
Location: Silver Spring, Md. 

Acquisition division: National Ocean Service/National Marine Fisheries 
Service/Oceanic and Atmospheric Research; 
Location: Silver Spring, Md. 

Acquisition division: National Weather Service; 
Location: Silver Spring, Md. 

Acquisition division: Staff Offices and External Clients; 
Location: Silver Spring, Md. 

Acquisition division: High Performance Computing; 
Location: Silver Spring, Md. 

Acquisition division: Satellite Program; 
Location: Silver Spring, Md. 

Acquisition division: Eastern Region; 
Location: Norfolk, Va. 

Acquisition division: Central Region; 
Location: Kansas City, Mo. 

Acquisition division: Mountain Region; 
Location: Boulder, Colo. 

Acquisition division: Western Region; 
Location: Seattle, Wash. 

Source: NOAA. 

[End of table] 

NOAA's acquisition function also provides procurement services to 
several other Commerce components, including the International Trade 
Administration, the Bureau of Economic Analysis, and the Economic 
Development Administration. In fiscal year 2005, NOAA administered over 
15,000 contract actions with total awards over $851 million. 

In recent years, NOAA has experienced problems in acquiring goods and 
services. For example, NOAA's inadequate negotiations and oversight, 
and lack of proper review, led the National Weather Service to pay for 
defective equipment and execute a contract modification without 
adequate negotiation for the transition power source for a high- 
resolution Doppler weather radar system jointly designed, acquired, and 
operated by Commerce, the Department of Defense, and the Department of 
Transportation.[Footnote 1] As a result, contract costs increased by 
approximately $4.5 million. Similarly, the Commerce Inspector General 
reported that NOAA had insufficient management controls to ensure 
adequate oversight of the procurement of over $65 million in new 
fisheries research vessels.[Footnote 2] For example, NOAA did not have 
the information required to effectively monitor the schedule and cost 
of the vessels and failed to implement an effective award fee plan on a 
timely basis to encourage superior performance by the contractor. 

NOAA Lacks Oversight of Some Field Acquisition Activities: 

Although NOAA has taken some actions, the agency has yet to structure 
all of its field acquisition activities under the appropriate oversight 
of its acquisition organization, increasing the risk that taxpayers are 
not getting best value for their dollars. After the Commerce Inspector 
General criticized the lack of effective oversight and management 
controls over acquisition processes, NOAA changed the structure of its 
acquisition organization in 2005 to have acquisition divisions report 
to the Director of Acquisition and Grants. Yet the acquisition director 
lacks direct line authority over a field acquisition office in 
Mississippi. In addition, some NOAA field operations rely on staff who 
are not career contracting officers but whose collateral 
responsibilities are to procure goods and services without appropriate 
oversight from the acquisition organization. Our work has shown that a 
well-functioning acquisition organization has direct lines of oversight 
between the head of acquisition and various components of the 
organization to help enforce acquisition policies that enable the 
agency to get the best value on goods and services.[Footnote 3] 

Acquisition Office Reorganization Was Not Comprehensive: 

In some respects, NOAA's reorganization has fallen short in providing 
comprehensive authority to the NOAA acquisition director to provide 
appropriate oversight to field acquisition activities. After the 
Commerce Inspector General faulted NOAA's contracting oversight, in an 
effort to better ensure oversight and management of acquisition across 
the agency, NOAA established an Acquisition and Grants Office in 
headquarters in 2005. The reorganization elevated the office, formerly 
part of the NOAA Office of Finance and Administration, as a new staff 
office reporting directly to the Deputy Under Secretary for Oceans and 
Atmosphere. Also, the NOAA regional acquisition divisions--which 
previously were separate entities reporting to the directors of the 
regional service centers in which they were located--all now report 
directly to the Director of the Acquisition and Grants Office as part 
of the reorganization. By elevating its acquisition office to a level 
that reports directly to an Under Secretary and having the divisions as 
direct reports to the acquisition director, NOAA has positioned itself 
to appropriately oversee agencywide acquisition activities and enforce 
acquisition policies. 

However, the reorganization was not comprehensive because it did not 
include the National Weather Service's National Data Buoy Center 
acquisition office at the Stennis Space Center, Mississippi. 
Specifically, the Buoy Center does not report to the NOAA acquisition 
director (see fig. 1), even though this acquisition office is 
responsible for administering multiple contracts, including one of 
NOAA's largest contracts, worth up to $500 million.[Footnote 4] While 
contracting officers in the Buoy Center acquisition office derive their 
contracting authority from headquarters, they report through the Buoy 
Center chain of command, not to NOAA's acquisition director. 

This reporting relationship was first established more than 20 years 
ago in a Commerce appropriation act,[Footnote 5] which created the Buoy 
Center acquisition office, and was stipulated in each subsequent 
appropriations act through 1988, but not since. During the recent 
reorganization, NOAA officials believed these laws prohibited NOAA from 
changing the reporting relationship to one where the Buoy Center 
acquisition office would report directly to the NOAA Acquisition and 
Grants Office. However, an analysis by our general counsel found no law 
requiring the Buoy Center acquisition office to report to the Director 
of the Buoy Center or prohibiting NOAA from making this change. 
Commerce's General Counsel agreed with our assessment. Although we did 
not identify any inefficiencies resulting from this current reporting 
relationship, we believe NOAA runs the risk of poor outcomes of 
contracts. 

Figure 1: Organizational Placement of NOAA Acquisition Function: 

[See PDF for image] 

Source: NOAA. 

[End of figure] 

NOAA Relies on Staff Who Have Collateral Contracting Responsibilities: 

Certain NOAA field offices rely on "collateral duty" contracting 
officers who perform contracting duties in addition to their mission- 
related responsibilities but who are not career contracting officers. 
In these locations, collateral duty contracting officers have authority 
to make individual purchases of up to $25,000 for such day-to-day needs 
as provisions for ships. While NOAA relies on collateral duty 
contracting staff for a relatively small share of total agency 
procurement spending, these staff administered about 6,400 contract 
actions worth over $36 million alone in fiscal year 2005. 

NOAA's acquisition director as well as senior field division 
contracting officers expressed concern about how well they can monitor 
the actions by staff with collateral duty contracting responsibilities 
to ensure that they follow NOAA acquisition policies. For example, 
unlike with their own contracting staff, some NOAA regional acquisition 
divisions provide only sporadic oversight over collateral duty 
contracting officers through occasional audits, either performed in 
person or through contract file samples sent by these staff for review. 
One regional acquisition division is only able to audit work by staff 
with collateral contracting responsibilities once every 2 to 3 years. 
NOAA acquisition managers attributed their inability to provide regular 
oversight to limited time and resources, given other responsibilities. 

Our review of contracting weaknesses at a Department of Homeland 
Security agency found challenges similar to NOAA's with regard to 
providing appropriate oversight to collateral duty contracting 
officers.[Footnote 6] In view of such situations, we have found that an 
agency needs to explore ways of making collateral duty contracting 
officers in field locations accountable through the acquisition 
function for the contracting work. 

Advances in Day-to-Day Acquisition Policies Not Matched in Policies for 
Complex Developmental Systems: 

Although NOAA has established clear and consistent acquisition policies 
and processes for day-to-day acquisitions of goods and services, the 
agency lacks a knowledge-based acquisition process for development and 
production of complex systems. For example, NOAA has implemented 
planning processes intended to improve opportunities to achieve savings 
and reduce administrative burden in acquiring goods and services. 
However, NOAA has experienced difficulties in acquiring more complex 
developmental systems such as lacking sufficient management controls 
when it acquired its new fisheries research vessels. NOAA is missing 
key elements that promote successful outcomes because it must adhere to 
Commerce's acquisition policies that do not promote a knowledge-based 
approach to acquiring complex developmental systems. Our work has shown 
that a knowledge-based approach would enable decision makers to be 
reasonably certain, at critical investment decision junctures in the 
acquisition life cycle, that the system is likely to meet cost, 
schedule, and performance targets. 

New NOAA Policies and Processes Intended to Improve Acquisition 
Outcomes: 

To facilitate effective planning, award, and administration of 
contracts that help to ensure the best value on goods and services, 
NOAA recently implemented new policies and processes to guide the 
agency's acquisition activities. For example, to ensure consistency of 
the NOAA acquisition process, a new acquisition handbook establishes 
standard operating procedures, which the agency previously lacked, such 
as required reviews and approvals, and quality assurance of acquisition 
activities within the agency. To ensure that contracting employees are 
adhering to proper procedures, NOAA instituted periodic acquisition 
management reviews. Under these reviews NOAA's acquisition director (or 
a senior contracting officer appointed by the director) personally 
inspects a sample of completed contract files from an acquisition 
division in order to identify and remedy any systemic problem areas and 
identify best practices to share with other divisions. In the last few 
years, reviews in several divisions found a lack of proper contract 
file management, as required in part 4.8 of the Federal Acquisition 
Regulation. The acquisition director consequently instructed the 
division heads to take steps with their staff to correct this problem. 

Recognizing that NOAA lacked effective acquisition planning and that 
this lack was hindering effective workload management, the Acquisition 
and Grants Office in fiscal year 2005 implemented new advance 
acquisition planning requirements. For example, all staff offices and 
programs must develop annual acquisition plans that include 
acquisitions that are over $100,000 or expected to result in new 
contracts. To support these new planning requirements and provide real- 
time data, the acquisition office deployed an online strategic 
acquisition management tool in fall 2005, in which NOAA staff offices 
and programs enter their annual acquisition plans for the upcoming 
fiscal year. Although the tool is new and still requires occasional 
modifications, NOAA officials generally agreed that it provides 
considerable benefits for the acquisition process to better plan the 
agency's use of resources and reduce the administrative burden 
previously experienced with managing unscheduled contracting 
requirements. 

NOAA's Acquisition Process for Development of Complex Systems Lacks a 
Knowledge-Based Approach: 

Because of the high dollar value and risk associated with acquiring 
complex developmental systems, Commerce requires that its subordinate 
organizations, including NOAA, adhere to departmentwide policy and 
processes regarding such acquisitions. However, Commerce policies and 
processes do not promote a knowledge-based approach for acquiring these 
systems, increasing the risk that Commerce will make decisions to 
commit the government to major investments without knowing that NOAA's 
systems can be developed at estimated costs, according to planned 
schedules, and with expected performance. Commerce officials 
acknowledged that their acquisition policy for developing major systems 
is outdated and said they are revising it.[Footnote 7] While the 
current policy identifies key decision points that a program must 
complete while acquiring a complex developmental system, it still lacks 
key features of a knowledge-based acquisition framework--specific 
criteria and metrics--that can be used to measure whether a program is 
ready to move through each key decision point. 

Our work has shown that leading developers in industry and government 
organizations use a knowledge-based approach to deliver high-quality 
products on time and within budget. An acquisition policy that requires 
such a framework for complex developmental systems enables program 
managers to be reasonably certain, at critical junctures, or knowledge 
points, in the project's acquisition life cycle, that their products 
will meet established cost, schedule, and performance targets. Such an 
acquisition policy also enables program managers to provide senior 
leaders with the information necessary to make sound project investment 
decisions for their agencies. Highlights of an acquisition policy that 
incorporates best practices for the development of complex systems 
include the equivalent of: 

* Knowledge point 1: Resources and needs match. This point occurs when 
a match is made between the customer's requirements and the product 
developer's available resources in terms of knowledge, time, money, and 
capacity. 

* Knowledge point 2: Product design is stable. This point occurs when a 
program determines that a product's design will meet customer 
requirements, as well as cost, schedule, and reliability targets. 

* Knowledge point 3: Production processes are mature and the design is 
reliable. This is demonstrated when the product can be manufactured 
within cost, schedule, and quality targets. 

(See app. II for additional information on the knowledge-based 
acquisition framework for complex developmental systems.) 

Having a knowledge-based framework to guide acquisitions of complex 
developmental systems is especially critical given that NOAA is in the 
early acquisition stages of developing a geostationary environmental 
satellite at a projected investment cost of about $6.2 
billion.[Footnote 8] According to a Commerce official, in the past NOAA 
relied on agencies outside of Commerce to acquire such systems, but 
experienced cost and schedule problems.[Footnote 9] To maintain 
management control over contractor performance, NOAA chose to manage 
the acquisition of its new satellite--the Geostationary Operational 
Environmental Satellite (GOES-R), which the agency plans to launch in 
2012. 

Amplifying the need for clear guidance, NOAA officials told us the 
agency is "feeling its way" through the GOES-R acquisition by relying 
on existing Commerce and NOAA policies, but also learning from lessons 
drawn from previous satellite acquisitions at other agencies. According 
to senior officials directly involved, NOAA was forced to prepare for 
the most recent key decision point in 2005--authorizing program 
definition and risk reduction activities in the GOES-R acquisition-- 
with vague guidance from Commerce over what specific criteria and 
metrics were required for the program to pass through the key decision 
point. 

In order to be ready for the next key decision point, NOAA officials 
said that clearer guidance from Commerce is needed on the information 
required. The next key decision point is scheduled for fiscal year 2007 
and will commit the agency to development and production of the GOES-R 
series. Commerce acquisition management officials told us they are 
briefing NOAA officials and developing a plan for necessary 
documentation on the requirements for the project's next key decision 
point. It remains to be seen whether these steps will provide 
sufficient clarity not only for what NOAA is expected to do to prepare 
for the remaining key decision points but also sufficient knowledge to 
make a well-informed decision on proceeding with the GOES-R 
acquisition. 

NOAA Has Taken Limited Actions to Address Contracting Workforce 
Retirement Challenges: 

NOAA is facing a human capital challenge because of its aging 
contracting workforce, and senior acquisition managers are concerned 
about the loss of a high percentage of their contracting staff to 
retirement and other attrition. However, NOAA has yet to focus on 
succession planning and management for its contracting workforce, even 
though the agency has approval to use flexible direct hire authority in 
anticipation of an impending wave of retirements. 

NOAA relies on contract specialists and procurement analysts to carry 
out its acquisition function.[Footnote 10] However, NOAA's acquisition 
director is worried about the near-term retirements of experienced 
contracting employees. Our analysis of Office of Personnel Management's 
(OPM) personnel data for NOAA confirms there is cause for this sense of 
urgency, given that almost 52 percent of the agency's contract 
specialists and procurement analysts are more than 49 years old and 
that 66 percent had at least 20 years of service (see fig. 2). 
Moreover, NOAA reported in January 2006 that about 43 percent of its 
contracting employees are already eligible to retire or will become 
eligible to retire between now and fiscal year 2009. Given that NOAA 
has historically found that 50 percent of employees who are eligible to 
retire do so within 3 years, it could lose a significant portion of its 
contracting workforce within the next few years. 

In addition to being concerned about retirements, senior acquisition 
managers are very concerned about the significant acceleration in 
contracting staff turnover as well as what they view as "fierce" 
competition for federal contract specialists that prompts many to 
accept jobs outside of NOAA. For example, NOAA reported in January 2006 
that over 12 percent of headquarters contracting positions are vacant. 
Moreover, NOAA's acquisition organization is concerned that the risk of 
continuing losses is high, given that governmentwide, Commerce had the 
highest reported agency attrition rate of 19 percent for contracting 
employees as recently as fiscal year 2004. Our analysis of OPM's fiscal 
year 2005 personnel data affirms their concern, since about half of the 
contracting specialists and procurement analysts that separated that 
year from NOAA transferred to jobs in other agencies (6 of the 13 
employee separations). 

Figure 2: Demographics of the NOAA Contracting Specialists and 
Procurement Analysts as of September 2005: 

[See PDF for image] 

Source: OPM. 

Notes: GAO analysis of data from OPM's Central Personnel Data File. 
Percentage may not add to 100 because of rounding. 

[End of figure] 

In 2006 NOAA's workforce management office completed a strategic human 
capital management plan intended to respond to recognized challenges 
and to help ensure the agency has the scientific, technical, and 
administrative expertise necessary to accomplish NOAA's mission. 
However, the plan does not specifically address the potential gaps in 
NOAA's contracting workforce even though NOAA is responsible for 
executing up to 25 percent of the Department of Commerce's budget on 
acquiring goods and services. Furthermore, because contracting 
expertise was not recognized as mission-critical, the acquisition 
director said she was not asked and did not provide input about the 
challenges to the workforce management office. Involving senior 
management, employees, and other stakeholders in strategic human 
capital planning is an important step toward its successful 
implementation. 

In addition, Commerce has taken some initial steps to address this 
retirement challenge in its contracting workforce. The Secretary of 
Commerce's Office of Acquisition Management and Financial Assistance 
hired a contractor to develop a human capital plan for the department's 
contracting workforce. However, it is too early to determine if this 
Commerce-wide plan will determine the gaps in numbers and skills in the 
contracting workforce to achieve mission-critical work and develop 
strategies to address these gaps. Until this assessment of the 
contracting workforce is completed at the departmental level, NOAA will 
be hard pressed to make its own assessment. Also recognizing a critical 
staffing shortage, in January 2006, Commerce approved NOAA's use of 
flexible direct hire authority to recruit qualified 
individuals.[Footnote 11] Civilian agency heads are authorized to 
determine if a shortage exists in certain federal acquisition positions 
so that persons with high qualifications can be recruited and directly 
hired. Direct hire authority allows an agency the flexibility to 
appoint individuals to positions without adherence to certain 
competitive examination requirements. According to a NOAA official, to 
date, NOAA has not implemented this authority. 

The prospect of many retirements in experienced staff make NOAA's need 
for contracting workforce planning more significant, and NOAA stands to 
benefit greatly by planning strategically for its contracting 
workforce. Our work has shown that to recruit, develop, and retain the 
right number of people with the right skills to support mission needs, 
leading organizations go beyond a succession planning approach that 
focuses on simply replacing individuals and engage in broad, integrated 
succession planning and management efforts that focus on strengthening 
both current and future organizational capacity.[Footnote 12] A key 
part of succession planning and management is to identify the talent 
required to achieve organizational goals. To that end, effective human 
capital planning involves (1) identifying the gaps in skills and 
competencies that need to be filled to achieve current and future 
mission-critical work, (2) developing strategies that are tailored to 
address these gaps, and (3) monitoring and evaluating the progress 
toward closing the gaps, and adjusting strategies accordingly. Unless 
the future retirement and workforce capacity challenges are 
strategically addressed, NOAA could soon lose a significant portion of 
its contracting knowledge base. 

Conclusions: 

Effectively and efficiently acquiring goods and services will continue 
to play a major role in enabling NOAA to accomplish its mission. 
Therefore, NOAA's success depends greatly on how well it manages its 
acquisition function. While NOAA has taken initial steps intended to 
put in place an efficient, effective, and accountable acquisition 
function, more can be done. NOAA can improve oversight of its field 
acquisition operations by requiring direct reporting of all of its 
acquisition offices and developing an oversight process for collateral 
duty contracting officers; adopting a knowledge-based acquisition 
process to help ensure that complex developmental systems meet cost, 
schedule, and performance targets; and addressing the imminent 
retirements of its contracting workforce to ensure it has a solid 
knowledge base to carry out its acquisition function. These next steps 
can facilitate achieving successful acquisition outcomes and enable 
NOAA to responsibly and prudently manage its investments to help meet 
the nation's economic, social, and environmental needs. 

Recommendations for Executive Action: 

To close the gaps between NOAA's current acquisition process and best 
practices for the development of complex systems, we recommend that the 
Secretary of Commerce take the following actions: 

* Incorporate a knowledge-based framework in the revision of Commerce's 
policy for acquiring complex developmental systems. This framework 
should identify requirements for major system projects to attain 
specific product knowledge at significant stages in the acquisition 
life cycle. Demonstration of this knowledge should be used as a basis 
for decision making by departmental leadership at the following key 
points: 

* Before projects are approved to move from concept and technology 
development to start the acquisition program, the policy should require 
that customer requirements and product developers' resources match, as 
indicated by achieving a high level of technology maturity. 

* Before projects are approved to move from integration to 
demonstration, the policy should require that the product design is 
stable and performs as expected. 

* Before projects are approved to move from demonstration into 
production, the policy should require that its design is reliable and 
can be manufactured within cost, schedule, and quality targets. 

To provide appropriate oversight of NOAA's field acquisition 
operations, we recommend that the Under Secretary of Commerce for 
Oceans and Atmosphere take the following two actions: 

* take steps to ensure that NOAA's Director of Acquisition and Grants 
has direct authority over all acquisition entities within the agency by 
realigning the National Data Buoy Center's Acquisition Office to report 
directly to NOAA's acquisition director and: 

* provide for regular monitoring of collateral duty contracting 
officers in field offices to help ensure they are accountable to senior 
acquisition officials for their contracting work. 

To address the future retirement challenges of NOAA's contracting 
workforce, we recommend that the Under Secretary of Commerce for Oceans 
and Atmosphere take the following action: 

* conduct a data-driven assessment of NOAA's contracting workforce to 
(1) identify skill gaps, develop strategies to address these gaps, 
evaluate progress toward closing these gaps, and adjust strategies 
accordingly and (2) involve relevant stakeholders in the development of 
this assessment. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report signed by the Deputy 
Secretary of Commerce, the department agreed with our findings and 
recommendations. Commerce stated that the report presented an accurate 
assessment of the major issues NOAA faces and described current or 
planned actions to address the recommendations. The department's 
comments are reprinted in appendix III. 

As we agreed with your office, unless you publicly announce the 
contents of this report earlier, we plan no further distribution of it 
until 30 days from the date of this letter. We will then send copies to 
other interested congressional committees, the Secretary of Commerce, 
and the Under Secretary for Oceans and Atmosphere. We will make copies 
available to others on request. In addition, the report will be 
available at no charge on GAO's Web site at [Hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-4841 or shamesl@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 IV. 

Sincerely yours, 

Signed by: 

Lisa Shames: 
Acting Director, Acquisition and Sourcing Management: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine if the National Oceanic and Atmospheric Administration 
(NOAA) has structured an acquisition organization that provides 
adequate oversight, we interviewed NOAA's Director of Acquisition and 
Grants, the acquisition division heads, and Commerce acquisition 
management executives regarding NOAA's acquisition function. We 
reviewed pertinent NOAA and Commerce organizational, management, and 
policy documents pertaining to the oversight of its acquisition 
activities. We also performed a legislative analysis of the 
establishment of the National Data Buoy Center in Mississippi to 
determine if there was a legal basis for not having its acquisition 
office report directly to NOAA's Director of Acquisition and Grants. In 
addition, we reviewed reports from Commerce's Office of the Inspector 
General to obtain an understanding of relevant Commerce and NOAA 
acquisition management challenges. 

To determine if NOAA has established clear and consistent acquisition 
policies and processes that promote, among other things, a knowledge- 
based acquisition approach for development and production of complex 
systems, we reviewed acquisition policies, processes, and guidelines. 
We interviewed NOAA's acquisition and grants director and acquisition 
division heads and reviewed information regarding new acquisition 
policies, handbook guidance, quality assurance, and planning processes. 
To determine if NOAA has established policies and processes that 
promote a knowledge-based review process for complex developmental 
systems acquisitions, we compared and discussed with NOAA and Commerce 
acquisition officials their policies for major acquisitions to our 
knowledge-based acquisition approach. Specifically, we compared and 
contrasted Commerce and NOAA's major system acquisition review process 
with criteria contained in GAO best practices work on systems 
acquisition and space system acquisitions. 

Finally, to determine the extent to which NOAA has planned and managed 
its contracting workforce to address future retirement challenges, we 
interviewed NOAA and Commerce officials responsible for contracting 
workforce and strategic human capital planning. We also analyzed and 
compared NOAA's contracting workforce and strategic human capital 
planning efforts with principles of effective human capital management. 
In addition to obtaining Commerce and NOAA officials' views and 
concerns regarding future human capital challenges, we analyzed data 
from Office of Personnel Management's (OPM) Central Personnel Data File 
(CPDF), which is its database of federal civilian employees. 
Specifically, to assess the potential for retirements in the next few 
years in NOAA's contracting workforce, the CPDF data we used reflected 
information on NOAA employees--as of September 30, 2005--working in the 
general series (GS) 1102 contracting series of contract specialists and 
procurement analysts. We limited our analysis to focus on contract 
specialists and procurement analysts because NOAA's Acquisition and 
Grants Office workforce mainly consists of this occupational category. 
We analyzed CPDF's separations and demographic data (on the ages and 
years of service) and NOAA information for contract specialists and 
procurement analysts in order to identify the extent to which NOAA's 
experienced contracting workforce is eligible for and thus has the 
potential for retiring in the near future. We did not independently 
verify the CPDF data on NOAA's contracting series employees for the 
year we reviewed. However, we previously reported that data from the 
CPDF for key variables in another study--occupation, agency/subagency, 
birth date, and service computation date--were 99 percent 
accurate.[Footnote 13] 

We conducted our review from August 2005 through April 2006 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix II: Knowledge-Based Acquisition Framework for Complex 
Developmental Systems: 

The federal government spends billions annually to research, develop, 
and produce large custom projects, such as satellites, space projects, 
weapon systems, air traffic control systems, and information technology 
systems. However, undesirable acquisition outcomes often occur because 
agency officials proceed further into development or production without 
obtaining sufficient knowledge that the product will be able to meet 
established cost, schedule, performance, and quality targets. 

The risk of undesirable acquisition outcomes can be significantly 
reduced. All product development acquisition projects, whether for a 
ship, airplane, missile, or satellite, go through a complex process of 
building knowledge. Ultimately, across the acquisition life cycle, this 
process brings together and integrates the technology, components, and 
subsystems needed for the product to work and be reliably manufactured. 
Over the past decade, we have undertaken a body of best practices work 
that draws upon lessons learned from product development practices of 
leading commercial firms, which expect their program managers to 
deliver high-quality products on time and within budget. 

Our work has identified three discrete points in the process for 
complex developmental systems at which obtaining certain levels of 
knowledge promote successful project outcomes. These knowledge points, 
depicted in figure 3, are defined in the following manner. 

Figure 3: Knowledge-Based Acquisition Framework: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

* Knowledge point 1: Resources and needs match. This point occurs when 
a sound business case is made for the system--that is, a match is made 
between customer requirements and the product developer's available 
resources in terms of knowledge, time, money, and capacity. Achieving a 
high level of technology maturity at the start of system development 
acquisition is an important indicator of whether this match has been 
made such that the technologies needed to meet essential product 
requirements have been demonstrated to work in their intended 
environment. 

* Knowledge point 2: Product design is stable. This point occurs when a 
program determines that a product's design will meet customer 
requirements and cost, schedule, and reliability targets. A best 
practice is to achieve design stability at the system-level critical 
design review usually held midway through development. Completion of at 
least 90 percent of engineering drawings at the system design review 
provides tangible evidence that the design is stable. 

* Knowledge point 3: Production processes are mature and the design is 
reliable. This is demonstrated when a product can be manufactured 
within cost, schedule, and quality targets. A best practice is to 
ensure that all key manufacturing processes are in statistical control-
-they are repeatable, sustainable, and capable of consistently 
producing parts within the product's quality tolerances and standards-
-at the start of production. 

The attainment of each successive knowledge point builds on the 
preceding one. While the knowledge itself builds continuously without 
clear lines of demarcation, the attainment of knowledge points is 
sequential. In other words, production maturity cannot be attained if 
the critical technologies are not mature. 

This knowledge-based approach is not just applicable to improving how 
the Department of Defense manages the acquisition of weapon systems. As 
we have recently reported, utilizing a knowledge-based approach to 
manage complex developmental system acquisitions can likewise help 
civilian agencies reduce risk by ensuring high levels of knowledge are 
attained on individual acquisitions at key decision points, thereby 
enabling senior leaders to make informed investment decisions.[Footnote 
14] A knowledge-based approach can also provide inexperienced program 
managers the necessary guidance to implement good management practices 
and ensure that the correct data are on hand for decision makers. 
Further, the methodology used by successful program managers to acquire 
complex developmental systems does not differ based upon each 
individual system being acquired. Notwithstanding the type of system 
being acquired, these managers follow a regimented process that uses 
common and consistent criteria for decision making. 

[End of section] 

Appendix III: Comments from the Department of Commerce: 

The Deputy Secretary Of Commerce: 
Washington, D.C. 20230: 

June 5, 2006: 

Ms. Lisa Shames: 
Acting Director, Acquisition and Sourcing Management: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Ms. Shames: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office's draft report entitled NOAA: Next Steps to 
Strengthen Its Acquisition Function (GAO-06-594). I enclose the 
Department of Commerce's comments on this draft report. 

Sincerely, 

Signed by: 

David A. Sampson: 

Enclosure: 

Department of Commerce Comments on the Draft GAO Report Entitled "NOAA: 
Next Steps to Strengthen Its Acquisition Function" (GAO-06-594/June 
2006): 

General Comments: 

The report on the acquisition function in NOAA presents an accurate 
assessment of the major issues facing NOAA, and many other agencies, as 
they impact the agency's ability to execute its mission. 

Response to GAO Recommendations: 

The draft GAO report states, "To close the gaps between NOAA's current 
acquisition process and best practices for the development of complex 
systems, we recommend that the Secretary of Commerce take the following 
actions: 

Recommendation 1: "Incorporate a knowledge-based framework in the 
revision of Commerce's policy for acquiring complex developmental 
systems. This framework should identify requirements for major system 
projects to attain specific product knowledge at significant stages in 
the acquisition life cycle. Demonstration of this knowledge should be 
used as a basis for decision making by departmental leadership at the 
following key points: 

* Before projects are approved to move from concept and technology 
development to start the acquisition program, the policy should require 
that customer requirements and product developers' resources match, as 
indicated by achieving a high level of technology maturity. 

* Before projects are approved to move from integration to 
demonstration, the policy should require that the product design is 
stable and performs as expected. 

* Before projects are approved to move from demonstration into 
production, the policy should require that its design is reliable and 
can be manufactured within cost, schedule, and quality targets." 

Response: The Department of Commerce (DOC) concurs with this 
recommendation and NOAA will continue to work with the DOC Senior 
Procurement Executive to develop and implement policy and process for 
effectively managing major systems acquisitions. 

The draft GAO report provides three recommendations for the 
Undersecretary of Commerce for Oceans and Atmosphere to (1) "provide 
appropriate oversight of NOAA's field acquisition operations" 
(Recommendations 2 and 3 below) and (2) "to address the future 
retirement challenges of NOAA's contracting workforce" (Recommendation 
4 below): 

Recommendation 2: "Take steps to ensure that NOAA's Director of 
Acquisition and Grants has direct authority over all acquisition 
entities within the agency by realigning the National Data Buoy 
Center's Acquisition Office to report directly to NOAA's acquisition 
director." 

Response: NOAA agrees with this recommendation and will undertake the 
steps necessary to move the organizational placement of the three 
acquisition professionals from the National Weather Service to NOAA's 
Acquisition and Grants Office (AGO), including transfer of the FTEs and 
associated funding. NOAA AGO will continue to physically locate the 
three acquisition specialists at the National Data Buoy Center to 
provide the acquisition support necessary to effectively implement and 
execute their mission. 

Recommendation 3: "Provide for regular monitoring of collateral duty 
contracting officers in field offices to help ensure they are 
accountable to senior acquisition officials for their contracting 
work." 

Response: NOAA agrees with this recommendation and will develop and 
implement a formal delegated procurement authority oversight process 
and program recognizing the resource limitations (both dollars and 
personnel) that exist within the organization. NOAA AGO will work with 
NOAA program offices which have delegated procurement authority to 
establish that process and to identify means to share the financial 
burden for this oversight program. 

Recommendation 4: "Conduct a data-driven assessment of NOAA's 
contracting workforce to (1) identify skill gaps, develop strategies to 
address these gaps, evaluate progress toward closing these gaps, and 
adjust strategies accordingly and (2) involve relevant stakeholders in 
the development of this assessment." 

Response: NOAA agrees with this recommendation and will work with the 
DOC Office of Acquisition Management and Financial Assistance to 
develop and conduct the workforce assessment. Recognizing the 
limitations on resources (people and dollars), NOAA AGO will utilize, 
to the extent possible, free training available from the Defense 
Acquisition University, eLearning tools, and on-the-job training, 
reserving limited training funds for those training requirements that 
cannot be obtained through other sources. NOAH is exploring the 
feasibility of instituting an outreach program to colleges and 
universities designed to encourage applications for entry-level 1102 
positions. NOAA AGO will utilize the recently approved Direct Hire 
Authority to expedite the hiring of qualified acquisition 
professionals. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-4841 or shamesl@gao.gov. 

Staff Acknowledgments: 

In addition to the individual named above, Carolyn Kirby, Assistant 
Director; Ian Jefferies; Jose Ramos; Sylvia Schatz; Bob Swierczek; and 
Greg Wilmoth made key contributions to this report. 

FOOTNOTES 

[1] Department of Commerce Inspector General, National Oceanic and 
Atmospheric Administration: Acquisition of NEXRAD Transition Power 
Source Marred by Management, Technical, and Contractual Problems, Final 
Inspection Report OSE-15676 (Washington, D.C.: September 2003). 

[2] Department of Commerce Inspector General, National Oceanic and 
Atmospheric Administration: Program for Acquiring Fisheries Research 
Vessels Needs Stronger Management Controls, Final Inspection Report STD-
14428-2-0001 (Washington, D.C.: June 2002). 

[3] GAO, Homeland Security: Successes and Challenges in DHS's Efforts 
to Create an Effective Acquisition Organization, GAO-05-179 
(Washington, D.C.: Mar. 29, 2005), and Transportation Security 
Administration: High-Level Attention Needed to Strengthen Acquisition 
Function, GAO-04-544 (Washington, D.C.: May 28, 2004). 

[4] In 2005, the National Data Buoy Center awarded a 10-year (5-year 
base with 5 option years) technical services contract to provide life 
cycle support for NOAA's Marine Observation Network; other buoy 
programs, including the network of Deep Ocean Assessment and Reporting 
of Tsunami stations; and its Data Assembly Center. 

[5] Department of Commerce and Related Agencies Appropriation Act, 
1984, Pub. L. No. 98-166, November 28, 1983. 

[6] GAO, Contract Management: INS Contracting Weaknesses Need Attention 
from the Department of Homeland Security, GAO-03-799 (Washington, D.C.: 
July 25, 2003). 

[7] U.S. Department of Commerce, Major Systems Acquisitions for the 
Department of Commerce, Department Administrative Order 208-3 
(Washington, D.C.: Dec. 9, 1997). 

[8] NOAA's geostationary satellites analyze data to detect and track 
severe weather conditions such as tornadoes, flash floods, hailstorms, 
and hurricanes. They orbit the earth at a speed matching the earth's 
rotation, allowing them to hover over one position on the surface. 

[9] GAO, Polar Orbiting Operational Environmental Satellites: Technical 
Problems, Cost Increases, and Schedule Delays Trigger Need for 
Difficult Trade-off Decisions, GAO-06-249T (Washington, D.C.: Nov. 16, 
2005); Space Acquisitions: Stronger Development Practices and 
Investment Planning Needed to Address Continuing Problems, GAO-05-891T 
(Washington, D.C.: July 12, 2005); Polar Orbiting Environmental 
Satellites: Information on Program Costs and Schedule Changes, GAO-04-
1054 (Washington, D.C.: Sept. 30, 2004); and Military Space Operations: 
Common Problems and Their Effects on Satellite and Related 
Acquisitions, GAO-03-825R (Washington, D.C.: June 2, 2003). 

[10] Under the Office of Personnel Management's general series (GS) of 
federal occupations, GS-1102 (contracting series) employees are 
contract specialists and procurement analysts. 

[11] Section 1413 of the Services Acquisition Reform Act of 2003 
(Public Law 108-136). 

[12] GAO, Human Capital: Selected Agencies Have Opportunities to 
Enhance Existing Succession Planning and Management Efforts, GAO-05-585 
(Washington, D.C.: June 30, 2005), and Human Capital: Key Principles 
for Effective Strategic Workforce Planning, GAO-04-39 (Washington, 
D.C.: Dec. 11, 2003). 

[13] See GAO, OPM's Central Personnel Data File: Data Appear 
Sufficiently Reliable to Meet Most Customer Needs, GAO/GGD-98-199 
(Washington, D.C.: Sept. 30, 1998). 

[14] GAO, NASA: Implementing a Knowledge-Based Acquisition Framework 
Could Lead to Better Investment Decisions and Project Outcomes, GAO-06-
218 (Washington, D.C.: Dec. 21, 2005), and Homeland Security: Successes 
and Challenges in DHS's Efforts to Create an Effective Acquisition 
Organization, GAO-05-179 (Washington, D.C.: Mar. 29, 2005). See also 
GAO, Defense Acquisitions: Assessments of Selected Major Weapon 
Programs, GAO-06-391 (Washington, D.C.: Mar. 31, 2006) and Defense 
Acquisitions: Major Weapon Systems Continue to Experience Cost and 
Schedule Problems under DOD's Revised Policy, GAO-06-368 (Washington, 
D.C.: Apr. 13, 2006). 

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