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Department of Energy Contracting: NNSA Has Taken Steps to Improve Its Work Authorization Process, but Challenges Remain

GAO-22-103948 Published: Oct 27, 2021. Publicly Released: Oct 27, 2021.
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Fast Facts

The National Nuclear Security Administration in the Department of Energy is responsible for the U.S. nuclear weapons stockpile. NNSA relies on 7 contractors to manage and operate its 8 lab and production sites.

To direct the work of its contractors, NNSA issues work authorizations, which task each contractor with activities for the fiscal year. NNSA has taken steps to improve its process for developing and issuing these authorizations, but continues to face challenges issuing them by the start of the fiscal year, as required.

Our recommendations include that NNSA establish a required schedule to issue these authorizations in a timely manner.

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Highlights

What GAO Found

The National Nuclear Security Administration (NNSA) has taken steps to improve its process for developing, reviewing, and issuing work authorizations (WA) for its management and operating (M&O) contractors. Such authorizations specify the activities to be conducted in a given fiscal year by the contractors that operate NNSA's sites (see figure). However, NNSA continues to face challenges issuing WAs before the start of the fiscal year, as generally required by NNSA's directive on WAs.

As part of its efforts to improve the agency's WA process, NNSA convened an internal working group in 2017 and 2018 to review the process. In October 2018, the working group recommended that NNSA's program offices submit draft WAs for review by August 15 each year. This recommendation was intended to ensure that field-based contracting officers and M&O contractor representatives finalized and issued WAs by the start of each fiscal year. However, NNSA continued to experience delays in issuing WAs by the start of fiscal year 2020, in part because NNSA does not have a schedule with required deadlines for review and revisions of draft WAs. Contractors that begin work without a WA in place by the start of the fiscal year risk incurring unallowable costs. Further, delays in issuing WAs may require duplicative efforts, such as the need to create interim “stopgap” WAs.

NNSA Work Authorization Development and Approval Process

NNSA Work Authorization Development and Approval Process

According to NNSA officials and M&O contractor representatives, WAs are an input for setting contractor performance expectations against which to monitor. However, when GAO reviewed performance evaluation reports for each contractor for fiscal years 2019 and 2020, GAO found that the reports did not clearly reference the performance expectations contained in WAs. NNSA officials confirmed that performance expectations contained in WAs cannot generally be traced to contractor's performance evaluation reports. This lack of traceability occurred in part because NNSA does not have clearly documented procedures specifying how officials should collect and use performance information, including from WAs, for evaluating contractor performance. This issue is similar to one on which GAO previously reported in February 2019 and made a recommendation for NNSA to develop such documented procedures. NNSA concurred with the recommendation but has not fully implemented it. GAO continues to believe that improving the ability to trace performance expectations to performance ratings would enable NNSA to more consistently evaluate contractor performance.

Why GAO Did This Study

NNSA relies on seven M&O contractors to manage and operate its eight laboratory and production sites. NNSA uses documents called WAs to direct the work of its contractors. NNSA's program offices collectively issued on average 94 WAs per fiscal year from 2018 to 2020. In 1990, GAO designated the Department of Energy's (DOE) contract management as a high-risk area and continues to identify ongoing challenges with NNSA's management of its contractors.

As part of an effort to understand the status of NNSA's actions to address contract management challenges, GAO was asked to review NNSA's work authorization process and documentation. This report examines NNSA's (1) efforts to improve its work authorization process, and (2) use of WAs in its contractor performance evaluation process.

GAO reviewed relevant laws and DOE and NNSA policy and guidance on WAs; analyzed a nongeneralizable sample of WAs for fiscal years 2019 and 2020; analyzed survey responses from all relevant NNSA program and field offices and contractor sites; reviewed contractor performance documentation; and interviewed agency officials.

Recommendations

GAO is making two recommendations, including that NNSA establish a required WA schedule to ensure finalization by the start of the fiscal year. NNSA concurred in principle with the recommendations and stated that they have been addressed. GAO believes that NNSA needs to take additional actions to fully address them, as discussed in the report.

Recommendations for Executive Action

Agency Affected Recommendation Status Sort descending
National Nuclear Security Administration The Associate Administrator for Acquisition and Project Management should establish a required schedule for NNSA's offices and contractor sites to review, revise, and finalize draft WAs by the start of each fiscal year. Such a schedule should include specific dates by which NNSA's program offices must transmit draft WAs to the M&O contractors for review, specific dates by which the program offices and M&O contractor finalize any needed revisions to the draft WAs, and specific dates by which the NNSA field offices will receive the draft WAs for final review and issuance before the start of the fiscal year. (Recommendation 1)
Open
NNSA concurred in principle with this recommendation. In September 2023, NNSA issued an integrated project team charter on the WA process. In this charter, NNSA stated that it planned to analyze the WA process to identify and implement efficiencies and streamline the process if necessary. In addition, it stated that it would determine if a schedule is necessary to ensure that WAs are completed by the beginning of the fiscal year. We will continue to monitor NNSA's actions to address this recommendation.
National Nuclear Security Administration The Associate Administrator for Acquisition and Project Management should assess the cause of technical challenges with STRIPES that hinder its usage by program and field offices and contractor sites. As part of its assessment, NA-APM should determine whether a different document management system is needed to facilitate the drafting and sharing of WAs between NNSA program and field offices and contractor sites. (Recommendation 2)
Open
NNSA concurred in principle with this recommendation. In September 2023, NNSA issued an integrated project team charter on the WA process. In this charter, NNSA stated that it planned to analyze the use of STRIPES or an alternative system as a repository of documents related to the WA process. We will continue to monitor NNSA's actions to address this recommendation.

Full Report

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Topics

Agency evaluationsContracting officersContractor performanceFederal acquisition regulationsGovernment contractsNuclear securityPerformance measurementProcurement recordsPerformance appraisalProject management