Recommendation: The Director of BOP should update its program evaluation plan to set a new timeline for conducting an evaluation of FPI. (Recommendation 1)

Agency: Department of Justice: Bureau of Prisons
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: In order to help promote a meaningful program assessment, the Director of BOP should develop a goal for FPI related to recidivism reduction and measure progress toward meeting that goal.(Recommendation 2)

Agency: Department of Justice: Bureau of Prisons
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of DLA should include a step for the opportunity for PCR review of the proposed contract and subcontracting plan in agency procedures and memorandums, and develop a mechanism for documenting whether the opportunity for PCR review was provided. (Recommendation 1)

Agency: Department of Defense: Defense Logistics Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Navy should include a step for the opportunity for PCR review of the proposed contract and subcontracting plan in agency procedures and memorandums, and develop a mechanism for documenting whether the opportunity for PCR review was provided. (Recommendation 2)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of DLA should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 3)

Agency: Department of Defense: Defense Logistics Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The NASA Administrator should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 4)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Navy should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 5)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of DLA should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 6)

Agency: Department of Defense: Defense Logistics Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of the GSA should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 7)

Agency: General Services Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The NASA Administrator should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 8)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Navy should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 9)

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The SBA Administrator should ensure Commercial Market Representatives clearly and consistently document compliance reviews and maintain these records. (Recommendation 10)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to, in coordination with the Office of Program Accountability and Risk Management, develop a risk-based approach for reviewing service requirements—through the Procurement Strategy Roadmap or other means—to ensure proposed service requirements are clearly defined and reviewed before planning how they are to be procured. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: DHS disagreed with our recommendation, preferring to maintain the status quo in its policy and procedures. However, by doing so, DHS is missing important opportunities to prevent negative acquisition outcomes and the potential for wasted resources. In its response, DHS noted its processes for major acquisitions, however, DHS service programs and contracts did not rise to the level of being classified a major service acquisition.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to document the factors the Office of the Chief Procurement Officer considers when waiving procurement actions from its Procurement Strategy Roadmap to ensure it is consistently considering potential acquisition risks in its planning—including those specific to services. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation, maintaining that the factors considered when waiving a Procurement Strategy Roadmap are not static. We believe, however, that documenting the factors considered will help ensure that the decisions to waive the Procurement Strategy Roadmaps are made consistently, transparently, and help maintain institutional knowledge.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to require the identification of special interest functions. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will update the Inherently Governmental and Critical Functions Analysis job aid to require the identification of a special interest function when applicable.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to provide guidance for analyzing, documenting, and updating the federal workforce needed to perform or oversee service contracts requiring heightened management attention. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation maintaining that the components are certifying that they have sufficient internal capacity or federal employees available for oversight within the Inherently Governmental and Critical Functions Analysis. We continue to believe, however, that without guidance, each component is making its own determination about which factors to consider, and DHS does not know how or whether the components are considering the federal workforce available to oversee service contracts in need of heightened management attention, or what steps, if any, the components are taking to mitigate risks if there are not enough federal personnel available to oversee the contracts after award.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to develop guidance identifying oversight tasks or safeguards personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental functions, special interest functions, or critical functions. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will develop guidance that identifies oversight tasks or safeguards that personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental, special interest, or critical functions.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Financial Officer to work with Congress to identify information to include in its annual congressional budget justifications to provide greater transparency into requested and actual service requirement costs, particularly for those services requiring heightened management attention. (Recommendation 6)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation stating that its annual Congressional Budget Justification already contains substantial service contract information. We maintain, however, that the service contract information currently included limits visibility for both DHS and Congress into requested and actual service requirements costs.

Recommendation: The Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should ensure that the TRANSCOM Commander, in coordination with the military services and the Coast Guard, develop a process for tracking data during the first 3 years of the Global Household Goods Contract to inform its planned manpower study during the third year of the contract to more precisely determine DP3 manpower needs and associated costs. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should ensure that the TRANSCOM Commander develop performance metrics for those DP3 activities that will not be a part of the Global Household Goods Contract, such as servicemember counseling and claims resolution that will, at least in part, continue to be performed by the military services. (Recommendation 2)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should ensure that the TRANSCOM Commander articulate the linkage, where appropriate, between DP3 performance metrics, including Global Household Goods Contract performance indicators, and overarching program goals. (Recommendation 3)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to take steps to ensure that the details of the pilot program's data protections are incorporated into the existing agreements. (Recommendation 1)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will require the Primary Sponsor for each applicable federally funded research and development center (FFRDC) to provide documentation that shows that the details of the pilot program's data protections have been incorporated into existing sponsoring agreements and contracts, and estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to take steps to ensure that the FFRDCs and sponsors are implementing the pilot program's protections for sensitive data. (Recommendation 2)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will task the Primary Sponsor for each applicable federally funded research and development center (FFRDC) to provide a report detailing the FFRDC's plan for implementing the pilot program's protections for sensitive data and confirming that the FFRDC is adhering to that plan. OUSD(R&E)/L&PO estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to establish a monitoring and oversight mechanism to ensure that primary sponsors submit complete information on pilot projects, as required by DOD's guidance for the pilot program. (Recommendation 3)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a monitoring and oversight plan, and estimated it would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan that outlines the methodology by which DOD will assess the pilot and how and when information collected will be analyzed to evaluate the pilot program. (Recommendation 4)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop and coordinate a plan that outlines the methodology by which DOD will assess the pilot as well as the methodology for collecting and analyzing information to evaluate the pilot program. OUSD(R&E)/L&PO estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan to identify and evaluate lessons learned from the pilot program. (Recommendation 5)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a plan to identify and evaluate lessons learned from the pilot program, and estimated the plan would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan for obtaining input from stakeholders on the pilot program. (Recommendation 6)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a plan to obtain stakeholder inputs for use in evaluating the pilot program, and estimated the plan would be completed in early Fall 2020.

Recommendation: The Secretary of Agriculture should direct Departmental Administration to work with the mission areas to develop department-level outcome-oriented performance goals and related measures for the business centers, and use them to assess the effectiveness and impact of the business center reforms. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

Comments: In January 2020, USDA officials agreed with our recommendation and stated that the department is evaluating options for the development of performance metrics and inclusion of these metrics and related information as part of the regular and recurring reviews by the department's Deputy Secretary who is identified as the Chief Operating Officer.

Recommendation: The Administrator of GSA should direct the Office of Government-wide Policy (1) to incorporate into its guidance approaches or practices that agencies could use to assess utilization of and the ongoing need for property—approaches such as recommendations for periodic justifications, data analytics, and utilization reviews—and (2) to develop a plan and timelines for communicating the guidance to agencies government-wide. (Recommendation 1)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of April 2020, GSA indicated in its 180-day letter that it had published on its website draft guidance in response to the Federal Personal Property Management Act of 2018. In addition, GSA identified several actions it planned to take in the coming months, such as publishing a comprehensive plan and timelines to address GAO's recommendation, publishing a request for information in the Federal Register to seek comments and suggestions, and engaging additional subject matter experts and related associations and standards group to improve upon the draft guidance. GAO will continue to monitor GSA's efforts to implement this recommendation.

Recommendation: The NASA Administrator should ensure that the NASA Associate Administrator for Human Exploration and Operations directs the Advanced Exploration Systems division to define and determine a schedule for synchronization reviews, including the role of the proposed Lunar Exploration Control Board, to help ensure that requirements between mission and program levels are reconciled. (Recommendation 1)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation and stated that the Advanced Exploration Systems division will review program life-cycle review plans to ensure enterprise and program requirements are reconciled across the mission. NASA is in the process of determining the organizational structure of the Human Exploration and Operations Mission Directorate. Following this completion, NASA officials stated that the appropriate control board and division structures for review and program direction will become active.

Recommendation: The NASA Administrator should ensure that the NASA Associate Administrator for Human Exploration and Operations directs the Gateway program to conduct a joint cost and schedule confidence level at the program level for the Artemis III mission. (Recommendation 2)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation and stated it would conduct a joint cost and schedule confidence level analysis or equivalent. The Gateway program is planning to conduct a series of project- and program-level reviews and assessments aligned with key decision point reviews. This includes conducting a joint cost and schedule confidence level analysis or equivalent of the Gateway initial configuration to support a program key decision point planned for fall 2021. NASA has not yet taken action on this recommendation.

Recommendation: The NASA Administrator should ensure that the NASA Associate Administrator for Human Exploration and Operations directs the Gateway program to update its overall schedule for 2024 to add a KDP II to occur before system integration. (Recommendation 3)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation, but has not yet taken action on it. NASA stated that it would provide a schedule for future reviews, including whether there will be a Key Decision Point (KDP) II, at the KDP-I review currently scheduled for fall 2021.

Recommendation: The NASA Administrator should ensure that the NASA Associate Administrator for Human Exploration and Operations creates a life-cycle cost estimate for the Artemis III mission. (Recommendation 4)

Agency: National Aeronautics and Space Administration
Status: Open
Priority recommendation

Comments: NASA agreed with the recommendation and stated that the agency will provide a preliminary cost estimate for the Artemis III mission by the end of 2020. Further, NASA stated that it will provide an updated cost estimate for the Artemis III mission after it establishes cost and schedule commitments for some of the projects that compose the lunar mission, currently planned for the Spring of 2021. To fully implement this recommendation, NASA will need to provide a cost estimate.

Recommendation: The NASA Administrator should ensure that the NASA Associate Administrator for Human Exploration and Operations directs the Advanced Exploration Systems division to commit to a completion date and finalize a cohesive document outlining the rationale for selecting its current lunar architecture and lunar programs. (Recommendation 5)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation and stated that it is developing a document that will summarize the trades and architectural studies, but the document is not yet complete.

Recommendation: The NASA Administrator should ensure that the Office of the Chief Engineer determines under what conditions it is appropriate to complete an analysis of alternatives, particularly when there are multiple pathways—including architectures or programs—that NASA could pursue in the future, and document the justification for not completing an analysis. (Recommendation 6)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation, but has not yet taken any action on it. NASA stated that it will provide additional clarifying guidance for conducting analyses of alternatives for new programs in the next update to NASA Procedural Requirements 7120.5E, "NASA Space Flight Program and Project Management Requirements." NASA plans to complete the update of the procedural requirement in September 2021.

Recommendation: The Associate Administrator for Acquisition and Project Management should report information on all professional SSCs to which funds were obligated during the fiscal year in its annual congressional budget justification materials. (Recommendation 1)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: NNSA concurred with our recommendation and agreed to update its methodology for the fiscal year 2021 budget justification materials in an effort to ensure that contracts are counted accurately. Based on our review of the contracts listed in the budget justification materials, NNSA inappropriately excluded six contracts from its fiscal year 2021 congressional budget justification reporting. GAO is following up with NNSA officials to determine why these contracts were excluded.

Recommendation: The Associate Administrator for Acquisition and Project Management should collect and report all required data regarding the number of FTE contractor personnel employed under an SSC for more than 2 years. (Recommendation 2)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: NNSA concurred in principle with the recommendation and planned to meet with congressional staff to discuss ways to further enhance the reported data before the 2021 budget materials were prepared. NNSA provided additional information in its fiscal year 2021 budget justification explaining that it did not have access to the information needed to report information to report required data regarding the number of FTE contractor personnel employed under an support service contract for more than 2 years. We will continue to follow-up on NNSA's progress in collecting and reporting the required data.

Recommendation: The Associate Administrator for Acquisition and Project Management should report in NNSA's annual congressional budget justification materials the program appropriations account—Weapons Activities or Defense Nuclear Nonproliferation—used to fund each SSC and total the amounts obligated by appropriations account. (Recommendation 4)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: NNSA concurred with the recommendation and included in the fiscal year 2021 budget justification materials additional information on the fund value and description in the table of support service contracts. However, NNSA did not total the amounts for each appropriation account. As a result, information on the total amounts of each appropriation account is not as transparent as it could be to assist Congress for planning purposes. GAO is following up with agency officials to identify any additional actions planned to close the recommendation.

Recommendation: The Associate Administrator for Acquisition and Project Management should take steps to ensure that contracting officers document—in the required determination form or elsewhere in the contract file—information on the steps that the contracting officers plan to take to oversee SSCs that NNSA has determined to be at high risk of including inherently governmental functions. (Recommendation 5)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: In its comments on a draft of this report, NNSA stated that it considers the recommendation closed based on processes already in place, as well as the complementary activities discussed in response to our sixth recommendation. We continue to believe that documenting planned oversight activities in the contract files is important to ensure that planned oversight is consistent throughout the duration of the contract. We will continue to monitor NNSA's implementation of this recommendation.

Recommendation: The Associate Administrator for Acquisition and Project Management should develop a process to verify that contracting officers are carrying out the steps identified to oversee contracts at risk of including inherently governmental functions throughout the term of the contract. (Recommendation 6)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open
Priority recommendation

Comments: NNSA generally agreed with the recommendation. NNSA stated that, among other things, it will review and revise, as necessary, the designation letters for contractor officers' representatives to ensure they clearly address the expectations for daily operational awareness and monitoring for risks associated with high-risk contracts, including those involving activities closely associated with inherently governmental functions. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of EM to develop cost estimates for the IWTU reengineering project and the SBW treatment operations that meet best practices for being comprehensive (e.g., account for all costs). (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In an update provided in April 2020, DOE said that it had taken steps to ensure the cost estimates will meet best practices for being comprehensive (e.g., account for all costs) as part of contract negotiations for the cleanup project. GAO has requested additional information from DOE and will update the status of this recommendation after it has received and analyzed this information.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of EM to develop schedule estimates for the IWTU reengineering project and the SBW treatment operations that meet best practices for being well-constructed. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: In an update provided by DOE in April 2020, DOE said that in negotiating the Idaho Cleanup Project contract it had taken steps to ensure the schedule estimates for the IWTU reengineering project and the SBW treatment operations will meet best practices for being well constructed. Further, DOE stated that the remaining baseline scope and schedule estimate received an external review by its contractor's parent corporation and DOE's Office of Environmental Management to ensure that the schedule meets best practices for being well-constructed. GAO has requested additional information from DOE and will update the status of this recommendation after it has received and analyzed this information.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of EM to follow best practices for ensuring the reliability for the IWTU reengineering project's earned value management system. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: In an update provided by DOE in April 2020, DOE said that cost and performance data for the IWTU is being tracked against the cost and schedule baselines incorporated in the core contract for the Idaho Cleanup Project, and that the data meets best practices for reliability. GAO has requested additional information from DOE and will update the status of this recommendation after it has received and analyzed this information.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of EM to develop a strategy, including a timeline, for implementing the actions required to achieve its preferred disposal pathway, or an alternative, for the SBW. (Recommendation 4)

Agency: Department of Energy
Status: Open

Comments: In an update provided by DOE in April 2020, DOE said that EM will assess the range of potential strategies and pathways for disposal of the treated SBW. Once this effort is completed, GAO will review EM's strategy and timeline for achieving its preferred disposal pathway, or an alternative, and update the status of this recommendation accordingly.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of EM to develop a strategy, including a timeline, to identify and develop a treatment approach for the disposal of the calcine waste to ensure that EM meets the milestone for completing the treatment of this waste by the target date of December 31, 2035. (Recommendation 5)

Agency: Department of Energy
Status: Open

Comments: In an update provided by DOE in April 2020, DOE said that DOE's Idaho Operations Office is in the process of chartering a team of subject matter experts to update an analysis of alternatives for calcine treatment and disposal. DOE said that this evaluation will be completed by September 30, 2020. GAO will request additional information from DOE on this analysis once completed and will update the status of this recommendation after it has received and analyzed this information.

Recommendation: The Assistant Secretary of ETA should develop, document, and implement a comprehensive strategy that (1) accounts for Job Corps' projected workload requirements and (2) considers its acquisition workforce needs—including the number of staff, skills, and other supports necessary to plan, award, and monitor Job Corps center contracts—to enable it to effectively plan for and competitively award future Job Corps center contracts. (Recommendation 1)

Agency: Department of Labor: Employment and Training Administration
Status: Open

Comments: DOL stated that it will develop, document, and implement a comprehensive strategy that accounts for Job Corps' projected workload requirements and considers its acquisition workforce needs. DOL noted that it has released a new procurement plan which reflects its decision to re-procure 28 Job Corps centers prior to the final option year of their contract. DOL said that this action would result in each region having no more than five procurements each year, which it considers a manageable procurement workload for its current staffing level. We will consider closing the recommendation when such a comprehensive strategy is implemented.

Recommendation: The Under Secretary of Health should require that all failures to meet quality standards are cited as deficiencies on SVH inspections. (Recommendation 2)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred with this recommendation and, as of July 2020, had taken some initial steps to address the recommendation such as modifying the SVH contractor's contract to stop the practice of using 'recommendations' for low-level deficiencies and beginning the process of revising a VA policy to address this practice.

Recommendation: The Under Secretary of Health should develop guidance for Veterans Affairs Medical Center staff conducting optional onsite CNH reviews. (Recommendation 3)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle with this recommendation and indicated in January 2020 that it had begun taking actions to address this recommendation such as developing a memo of clarification and planning the release of additional guidance for staff.

Recommendation: The Under Secretary of Health should provide information on the quality of all SVHs that is comparable to the information provided on the other nursing home settings on its Access to Care website. (Recommendation 4)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle and, as of July 2020, had begun taking some steps to address this recommendation such as exploring options for presenting SVH quality measure data.

Recommendation: We recommend that the Acting Secretary of Defense direct the Under Secretary for Acquisition and Sustainment to ensure it conducts a comprehensive assessment of the effect that its contract financing and profit policies have on the defense industry and update that assessment on a recurring basis. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with the recommendation. The Department stated that it would seek fiscal year 2020 funds to contract a study on DOD contract financing policies and their effect on the defense industry. In September 2020, DOD stated that this action would be completed by December 31, 2021. The first phase of the report is estimated to be completed September 30, 2021. The department secured funds to complete the study and a contract was awarded on April 23, 2020.

Recommendation: We recommend the NASA Administrator ensure that the NASA Associate Administrator for Human Exploration and Operations direct the SLS program to calculate its development cost growth using a baseline that is appropriately adjusted for scope and costs NASA has determined are not associated with the first flight, and determine if the development cost growth has increased by 30 percent or more. (Recommendation 1)

Agency: National Aeronautics and Space Administration
Status: Open
Priority recommendation

Comments: NASA agreed with this recommendation. As of February 2020, NASA stated that it is conducting a rebaseline of the cost and schedule commitments for the SLS program and will document final decisions in an Agency Baseline Commitment decision memorandum. NASA officials anticipate they will complete this effort in Spring 2020. To fully implement this recommendation, NASA will need to measure cost growth using a baseline that reflects the scope of work currently planned for the first mission.

Recommendation: We recommend the NASA Administrator ensure that the NASA Associate Administrator for Human Exploration and Operations direct the Orion program to update its cost estimate to reflect its committed EM-2 baseline date of April 2023. (Recommendation 2)

Agency: National Aeronautics and Space Administration
Status: Open
Priority recommendation

Comments: NASA partially agreed with this recommendation, stating that providing the estimate to the forecasted launch date rather than to the committed baseline date of April 2023 is the most appropriate approach. In November 2019, program officials told us that they will consider this recommendation as part of updating the joint confidence level analysis for the program's Key Decision Point D review. This review occurs before the program enters the system assembly, integration and test, and launch phase, and is not scheduled to occur until December 2020. To fully implement this recommendation, NASA needs to provide an updated cost estimate through April 2023.

Recommendation: We recommend the NASA Administrator ensure that the NASA Associate Administrator for Human Exploration and Operations direct the EGS program to demonstrate design maturity by completing 3D product modeling of the basic and functional design of the second Mobile Launcher prior to construction start. (Recommendation 3)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with this recommendation and stated that the acquisition strategy for the second mobile launcher requires the use of 3D product modeling and that it will be the source for all engineering activities including integrated design reviews to demonstrate design maturity. It is too soon to assess the design maturity prior to construction start and we will provide updated information on actions NASA has taken at that time.

Recommendation: We recommend the NASA Administrator ensure that the NASA Associate Administrator for Human Exploration and Operations direct the SLS and Orion programs to reevaluate their strategies for incentivizing contractors and determine whether they could more effectively incentivize contractors to achieve the outcomes intended as part of ongoing and planned contract negotiations. (Recommendation 4)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with the intent of this recommendation and stated that the SLS and Orion program offices reevaluate their strategies for incentivizing contract performance as part of normal contracting activities including contract restructures, contract baseline adjustments, and new contract actions. The Orion program has awarded a long term contract for production of the Orion spacecraft that incorporates new strategies intended to reduce contract costs. The SLS program is in the process of negotiating long term production contracts for required hardware.

Recommendation: The Director of the DOE Office of Acquisition Management should clearly define—in guidance or other documents—which subcontracts should be audited, how an audit is defined, and how to meet subcontract audit requirements if Defense Contract Audit Agency is unable to conduct the audit.(Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In its comments on a draft of the report, DOE partially concurred with the recommendation, but stated that there is no government-wide requirement that defines an audit or prescribes the auditing of subcontracts. According to officials, DOE reviewed existing regulations, guidance, and contract provisions on audit requirements and determined that a need exists for additional guidance or contract provisions on audits for major contracts. As of June 2020, DOE was working with the Civilian Agency Acquisition Council to recommend a government-wide requirement to define audit and prescribe when to obtain audits of subcontracts. Additionally, DOE included in its Acquisition Guide information on audit options when the Defense Contract Audit Agency is unable to conduct an audit.

Recommendation: The Director of the DOE Office of Acquisition Management should require local officials to independently review subcontractor ownership information as part of DOE consent reviews and assess potential conflicts of interest to ensure contractors are mitigating them. (Recommendation 4)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE did not concur with our recommendation; instead, they plan to issue guidance emphasizing the importance of contracting officers reviewing contractors' disclosing and dealing with issues created by close working relationships, conflicts of interest, or ownership affiliations between prime and subcontractor. We have identified complex relationships among DOE contractors and subcontractors that were not documented by DOE, as well as incidents involving subcontractors related to conflicts of interest that were not disclosed to DOE. We noted that DOE officials--including those in local offices--have access to several databases and other sources of information that would allow them to independently verify ownership information that could allow the local offices to identify potential conflicts of interest that were not disclosed. In July 2020, DOE issued guidance summarizing and reiterating existing regulations, policy and procedures that require DOE contracting officers to perform independent analyses when reviewing subcontract consent packages, contractor purchasing systems, and potential organizational conflicts of interest. However, this is the same as previous guidance and it does not include direction to review subcontractor ownership information.

Recommendation: The Director of the DOE Office of Acquisition Management should require contracting officers to include assessments of the contractors' management of subcontractors as part of annual Performance Evaluation and Measurement Plans, as appropriate. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with the recommendation and agreed to review existing guidance and determine if additional guidance is needed to conduct an assessment of the contractors' management of subcontractors in annual Performance Evaluation and Measurement Plans. As of June 2020, DOE officials said they have reviewed existing federal and departmental policies, procedures, and available tools and determined sufficient guidance exists for contracting officers to make informed decisions on whether to include contractor management of subcontractors in annual Performance Evaluation and Measurement Plans based on the characteristics, circumstances, and requirements of a specific contract. DOE's Performance Evaluation and Measurement Plan template provides a subcontractor management evaluation factor for use by contracting officers who have determined it is appropriate for their contracts. Although we recognize the value in deferring to contracting officers to determine whether the factor is appropriate based on the characteristics, circumstances, and requirements of the contract, we continue to believe that DOE should place additional emphasis on the contractors' oversight of subcontracts by assessing the contractors on this factor.

Recommendation: The Administrator for the National Nuclear Security Administration should develop and document clear procedures for implementing NAP-4C, specifying the process for collecting contractor performance information and describing how officials are to ensure this information can be traced to rating determinations. (Recommendation 1)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: The National Nuclear Security Administration (NNSA) concurred with the recommendation. In February 2020, NNSA issued its fiscal year 2020 Corporate Performance Evaluation Process Annual Implementation Guidance. This guidance included a new section specifying the process for collecting contractor performance information and further details regarding the preparation of interim feedback reports and final performance evaluation reports. However, the guidance is unclear regarding how this information can be traced to rating determinations. In order to provide more transparency and ensure this traceability, NNSA guidance and the Performance Evaluation Reports themselves should more clearly link how collected performance information tracks to rating determinations.

Recommendation: The Assistant Secretary for the Office of Energy Efficiency and Renewable Energy should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 2)

Agency: Department of Energy: Office of Energy Efficiency and Renewable Energy
Status: Open

Comments: The Office of Energy Efficiency and Renewable Energy (EERE) partially concurred with the recommendation. As of April 2020, EERE officials stated that cost performance feedback was included in the 2019 final performance evaluation for the EERE Management and Operating contractor. EERE officials also stated that they had incorporated cost performance evaluation criteria into the fiscal year 2020 Performance Evaluation Measurement Plan (PEMP) for NREL. EERE officials noted that these actions ensure cost performance will be included as part of the ongoing contractor evaluation process. We have requested documentation of the new PEMP and performance evaluation report and, in order to ensure cost performance evaluation criteria are included in the future, EERE should update its policy to require quality information on cost performance going forward.

Recommendation: The Assistant Secretary for the Office of Environmental Management should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 3)

Agency: Department of Energy: Office of Environmental Management
Status: Open

Comments: The Office of Environmental Management (EM) concurred with the recommendation. As of April 2020, EM officials stated that they will include the requirement for quality information on cost performance in EM's Cleanup Project Management Policy. According to officials, EM is working on this policy, along with an additional Cleanup Program Management Policy that they expect to complete by the end of fiscal year 2020.

Recommendation: The Assistant Secretary for the Office of Fossil Energy should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 4)

Agency: Department of Energy: Office of Fossil Energy
Status: Open

Comments: The Office of Fossil Energy (FE) concurred with the recommendation. As of April 2020, FE officials stated that they had revised and executed the Performance Evaluation and Measurements Plan (PEMP), for the current Management and Operating contract to add a new PEMP measure that addresses monitoring cost growth, additional activities in internal audit, and data quality that addresses our recommendation. We have requested documentation of the PEMP showing the new measures and an updated policy requiring inclusion of quality information on cost performance in Performance Evaulation Reports. Upon receiving those, we will review to determine if it addresses our recommendation.

Recommendation: The Administrator for the National Nuclear Security Administration should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 5)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: The National Nuclear Security Administration (NNSA) concurred with the recommendation. In February 2020, NNSA issued its fiscal year 2020 Corporate Performance Evaluation Process Annual Implementation Guidance. This guidance provides instructions regarding the evaluation of cost performance, including examples of the types of cost information that should be collected and how cost data should be analyzed and described. However, the guidance's template for Performance Evaluation and Measurement Plans does not include any explicit cost performance Objectives or Key Outcomes and it is unclear how the cost performance information discussed in the guidance would enable an overall assessment of Management and Operating contractor cost performance. In order to provide quality cost information that does enable such an overall assessment, NNSA should clarify its guidance regarding cost performance information and how this information links to overall Management and Operating contractor performance.

Recommendation: The Assistant Secretary for the Office of Nuclear Energy should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 6)

Agency: Department of Energy: Office of Nuclear Energy
Status: Open

Comments: The Office of Nuclear Energy (NE) partially concurred with the recommendation. As of May 2020, NE officials stated that they will include criteria for "day-to-day" cost performance in the annual Performance Evaluation Measurement Plan (PEMP) for fiscal year 2020. NE's evaluation of the contractor's performance against those criteria will be included in the year-end performance reports of its Management and Operating contractor beginning in fiscal year 2020. NE officials stated that modifying the fiscal year 2020 PEMP with added cost criteria, usually done in April, has been delayed due to COVID-19 and that they expect to complete the modification by the end of May 2020. Once the cost criteria are included and evaluated in the Performance Evaluation Report, we will review to determine if it addresses our recommendation. In addition to changes to the fiscal year 2020 report, NE should update its policy to require such criteria for evaluating contractor cost performance going forward.

Recommendation: The Director of the Office of Science should update its policy to require that Performance Evaluation Reports include quality information on cost performance to enable an overall assessment of Management and Operating contractor cost performance. (Recommendation 7)

Agency: Department of Energy: Office of Science
Status: Open

Comments: The Office of Science (SC) partially concurred with the recommendation. In commenting on our report in August 2019, DOE stated that by focusing on the annual Performance Evaluation Reports (PER), our report does not capture the cost performance reviews conducted in day-to-day contract oversight, the annual laboratory planning process, and contract extend/compete decisions. In its comments, DOE stated that since SC conducts cost performance reviews in normal operations and at the year-end annual evaluation process, adequate information is available to assess whether the contractor cost performance is acceptable to the department. As of April 2020, SC had not updated these comments. In the report, we note that SC conducts some cost performance evaluation activities outside of the annual performance evaluation process, although we did not assess these efforts. While there may be adequate information available, SC does not commonly document this information or assessments from such activities in the PERs. We continue to believe that the PERs are important sources of information for contract management--particularly for acquisition decisions and oversight of spending on cost-reimbursement contracts--and that action is needed to improve these formal records of contractor performance. By not including quality information on overall cost performance and assessments in PERs, SC is missing a valuable opportunity to better document contractors' cost performance, improve acquisition decision-making, and strengthen oversight of billions of dollars in contracting. We continue to believe that it is important for SC to implement the recommendation and that by doing so, the office would have better assurance that Management and Operating contractor performance evaluations fully address required elements.

Recommendation: The Secretary of Energy should direct the Director of the Office of Project Management and the Assistant Secretary of the Office of Environmental Management to work together to establish requirements for classifying cleanup work as capital asset projects or operations activities. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE developed a draft Cleanup Project Management Policy to clarify the expectations for EM's management of discrete work, such as operations activities that could be considered projects. In February 2020, EM officials stated that they are addressing this recommendation in two steps. First, EM is working with DOE's Office of Project Management to draft a Cleanup Project Management Policy (expected to be completed in spring 2020) to address the Decommissioning and Deactivation (D&D) phase of cleanup. This policy will become an appendix in DOE's Order 413.3B. EM officials further stated that EM plans to develop an additional Cleanup Program Management Policy that would classify the remaining types of activities not covered by the Cleanup Project Management Policy, including what EM currently classifies as operations activities. EM plans to implement this policy by the end of fiscal year 2020.

Recommendation: The Secretary of Energy should direct the Director of the Office of Project Management and the Assistant Secretary of the Office of Environmental Management to work together to asses EM's ongoing operations activities to determine if they should be reclassified as capital asset projects based on the newly established requirements. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE developed a draft Cleanup Project Management Policy to clarify the expectations for EM's management of discrete work, such as operations activities that could be considered projects. In February 2020, EM officials stated that they are addressing this recommendation in two steps. First, EM is working with DOE's Office of Project Management to draft a Cleanup Project Management Policy (expected to be completed in spring 2020) to address the Decommissioning and Deactivation (D&D) phase of cleanup. This policy will become an appendix in DOE's Order 413.3B. EM officials further stated that EM plans to develop an additional Cleanup Program Management Policy that would classify the remaining types of activities not covered by the Cleanup Project Management Policy, including what EM currently classifies as operations activities. EM plans to implement this policy by the end of fiscal year 2020.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to review and revise EM's 2017 cleanup policy to include program management leading practices related to scope, cost, schedule performance, and independent reviews. (Recommendation 3)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate leading practices related to scope, cost, and schedule, and independent reviews, as appropriate. In February 2020, EM officials stated that EM is working on a Cleanup Project Management Policy (expected to be completed in spring 2020) that will cover the Decommissioning and Deactivation (D&D) phase of cleanup. EM plans to develop an additional Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020), which will supersede EM's current cleanup policy and include leading program management practices-and possibly also project management practices-related to scope, cost, schedule performance, and independent reviews.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to review and revise EM's 2017 cleanup policy to include project management leading practices related to scope, cost, schedule performance, and independent reviews. (Recommendation 4)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate leading practices related to scope, cost, and schedule, and independent reviews, as appropriate. In February 2020, EM officials stated that EM is working on a Cleanup Project Management Policy (expected to be completed in spring 2020) that will cover the Decommissioning and Deactivation (D&D) phase of cleanup. EM plans to develop an additional Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020), which will supersede EM's current cleanup policy and include leading program management practices-and possibly also project management practices-related to scope, cost, schedule performance, and independent reviews.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to update its cleanup policy to require that earned value management (EVM) systems be maintained and used in a way that follows EVM best practices. (Recommendation 5)

Agency: Department of Energy
Status: Open

Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to replace its current EM Cleanup Policy with two separate project and program management policies that will incorporate earned value management best practices, as appropriate. In February 2020, EM officials stated that EM's forthcoming Cleanup Project Management Policy (expected to be completed in spring 2020) will require capital asset projects covered under the policy to use earned value management (EVM) systems that have been independently certified, which is an EVM best practice. However, EM officials told us that this policy will not require operations activities to follow EVM best practices. EM officials stated that EM is also considering including this requirement in its forthcoming Cleanup Program Management Policy (expected to be completed by the end of fiscal year 2020). In addition, EM officials told is that EM plans to require future end-state contracts to use EVM systems that have either been certified by the DOE Office of Project Management or been subject to a "compliance review" conducted by EM itself, depending on the dollar value of the contract.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to develop a policy to ensure that work is categorized as level of effort only in appropriate, specified circumstances, such as when work is not measurable or when measurement is impractical. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that EM intends to include requirements related to the categorization of level of effort work in the project and program management policies EM is developing.

Recommendation: The Secretary of Energy should direct the Assistant Secretary of the Office of Environmental Management to integrate EVM data into EM's performance metrics for operations activities. (Recommendation 7)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with this recommendation. In August 2019, in a letter to GAO on how EM will address our recommendation, the Senior Advisor for Environmental Management to the Under Secretary for Science stated that DOE is in the process of developing a Cleanup Program Management Policy that will, among other things, incorporate changes relative to the integration of EVM data into performance metrics as appropriate. As of February 2020, EM officials told us that the new policy is expected to be completed by the end of fiscal year 2020. In February 2020, EM officials stated that EM plans to begin a new performance review process for operations activities that will include EVM-based performance metrics as part of annual reporting to the Assistant Secretary. The new process is expected to begin in October 2020, but EM officials have not determined whether this will be a requirement included in EM's forthcoming Cleanup Program Management Policy.

Recommendation: The Under Secretary for Benefits should develop and implement a plan for how VBA will use data from the new exam management system to oversee contractors, including how it will capture accurate data on the status of exams and use it to (1) assess contractor timeliness, (2) monitor time spent correcting inadequate and insufficient exams, and (3) verify proper exam invoicing. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and outlined improvements in the information collected through VBA's new exam management system. VBA is testing a mechanism to validate exam invoices submitted by contractors. It will be important for VBA to take the next step of developing and implementing a plan for how it will use information from the new system to ensure both accurate timeliness data and proper exam invoicing.

Recommendation: The Under Secretary for Benefits should regularly monitor and assess aggregate performance data and trends over time to identify higher-level trends and program-wide challenges. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA will use improved data in the new exam management system to regularly monitor and assess aggregate performance data, identify error trends, and monitor contractor performance and program-wide challenges.

Recommendation: The Under Secretary for Benefits should document and implement a plan and processes to verify that contracted examiners have completed required training. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Under Secretary for Benefits should collect information from contractors or examiners on training and use this information to assess training and make improvements as needed. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Under Secretary for Management should require the Office of Program Accountability and Risk Management to assess the results of major acquisition programs' post-implementation reviews and identify opportunities to improve performance across the acquisition portfolio. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report, DHS concurred with our recommendation and stated that it planned to update its policy to require more formal reporting requirements and execution criteria for post-implementation reviews. PARM also plans to initiate a study focused on assessing lessons learned and developing a tool to share them across components to improve performance of the acquisition portfolio. In February 2020, PARM approved guidance intended to standardize analysis elements for post-implementation reviews. As of July 2020, PARM was still in the process of developing a tool to share results across components, but in the interim, results from some post-implementation reviews have been shared during meetings with Component Acquisition Executives. GAO will review post-implementation reviews conducted under the new guidance and will monitor DHS's implementation of the tool to ensure the department's actions meet the intent of this recommendation.

Recommendation: The Secretary of the Navy should take steps to ensure that the Marine Corps not enter full-rate production until the Marine Corps has determined that the contractor has achieved an MRL of at least 9 for all risk areas. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, stating that it agreed that manufacturing readiness levels (MRL) for the Amphibious Combat Vehicle 1.1 should be assessed prior to the decision to award the option for the second lot of low-rate production, but disagreed that an MRL assessment of any individual risk area, in itself, should delay the contract award. We maintained that achieving an overall MRL-9 by the by the start of full-rate production represents best practice to minimize production risk. According the Marine Corp, the most recent MRL Assessment as of August 2020 assessed the program at an overall MRL-8. The Marine Corps indicated that another MRL assessment is estimated to be completed in November 2020 to support the decision to enter full-rate production, which is planned for December 2020.

Recommendation: The Chief Executive Officer should direct the Chief Information Officer to take steps needed to ensure that system requirements are defined to align with the business needs of CNCS's future risk-based grants monitoring process (Recommendation 1).

Agency: Corporation for National and Community Service
Status: Open

Comments: In November 2018, CNCS officials stated that the agency made the decision to terminate the development of the Grants and Member Management (GMM) system. They subsequently awarded a contract to assess the state of development for the GMM system and to provide recommendations on the actions CNCS needed to take in order to implement a commercial off-the-shelf (COTS) application for core grants management functions. According to CNCS officials, based on the findings from that assessment, further investments in developing customized applications (even an implementation of a COTS application) were not likely to be successful. As of September 2019, CNCS officials stated that they were pursuing the option of a federal shared service as a solution to grants management. As of November 2019, according to CNCS officials, the agency had not yet defined requirements for the grant monitoring system project because the decision to pursue the federal shared services as a solution for grants management is very recent. CNCS officials agreed to provide GAO with an update as further progress is made on this recommendation.

Recommendation: The Chief Executive Officer should direct the Chief Information Officer to ensure that the system development project schedule identifies in the baseline both planned and actual dates for completing all project-level activities, and can be used to monitor and measure progress of the grant monitoring system project (Recommendation 2).

Agency: Corporation for National and Community Service
Status: Open

Comments: In November 2018, CNCS officials stated that the agency made the decision to terminate the development of the GMM system. They subsequently awarded a contract to assess the state of development for the GMM system and to provide recommendations on the actions CNCS needed to take in order to implement a COTS application for core grants management functions. According to CNCS officials, based on the findings from that assessment, further investments in developing customized applications (even an implementation of a COTS application) were not likely to be successful. As of September 2019, CNCS officials stated that they were pursuing the option of a federal shared service as a solution to grants management. As of November 2019, according to CNCS officials, the agency had not yet established a project schedule for completing the grant monitoring system project because the decision to pursue the federal shared services as a solution for grants management is very recent. CNCS officials agreed to provide GAO with an update as further progress is made on this recommendation.

Recommendation: The Chief Executive Officer should direct the Chief Information Officer to ensure that test plans are defined and implemented to include the second version of the grant monitoring system in all stages of testing during development, and results of initial stages are approved before conducting subsequent test stages (Recommendation 3).

Agency: Corporation for National and Community Service
Status: Open

Comments: In November 2018, CNCS officials stated that the agency made the decision to terminate the development of the GMM system. They subsequently awarded a contract to assess the state of development for the GMM system and to provide recommendations on the actions CNCS needed to take in order to implement a COTS application for core grants management functions. According to CNCS officials, based on the findings from that assessment, further investments in developing customized applications (even an implementation of a COTS application) were not likely to be successful. As of September 2019, CNCS officials stated that they were pursuing the option of a federal shared service as a solution to grants management. As of November 2019, according to CNCS officials, the agency had not yet established a timeframe to define test plans for the selected solution for the grant monitoring system project because the decision to pursue the federal shared services as a solution for grants management is very recent. CNCS officials agreed to provide GAO with an update as further progress is made on this recommendation.

Recommendation: The Under Secretary of Defense for Acquisition, Technology and Logistics should identify the specific types of information that would best meet the department's needs and, based on that determination, collect and analyze relevant data after contract performance is sufficiently complete to determine the extent to which contracts with incentives achieved their desired outcomes.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: DOD concurred with our recommendation and has taken steps to address it. For example, in April 2018, the department developed a template for the military departments to use to identify specific types of information to collect. Since then, each of the military departments has initiated or planned to initiate efforts to collect and analyze information about outcomes of incentive contracts. In addition, in July 2020 DOD provided examples of selected DOD, Army, and Navy incentive contracts documented in the template previously noted. The department did not provide additional information about the Air Force's efforts, or about how DOD is analyzing the information to determine whether incentives can achieve desired outcomes. GAO has ongoing work to review DOD's use of fixed-price type contracts--including fixed-price incentive contracts--for major DOD systems, which may provide additional insights related to this recommendation.

Recommendation: To ensure that the HVBP program accomplishes its goal to balance quality and efficiency and to ensure that it minimizes the payment of bonuses to hospitals with lower quality scores, the Administrator of CMS should revise the formula for the calculation of hospitals' total performance score or take other actions so that the efficiency score does not have a disproportionate effect on the total performance score.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS indicated that it would examine the formula used for calculating hospitals' total performance scores and consider revisions, which would be subject to notice and comment rulemaking. In September 2018, HHS indicated that it had been examining alternatives and considering revising the formula for the calculation of hospitals' total performance scores (TPS) consistent with relevant statutory guidance, and in a way to reduce the effect of the efficiency domain on the TPS. In the Fiscal Year 2019 Inpatient Prospective Payment System proposed rule, CMS proposed to remove the safety domain weighted at 25 percent of the TPS and, in connection, increase the weight of the clinical care domain from 25 percent to 50 percent, which was estimated to reduce the effect of the efficiency domain on the TPS. According to CMS, stakeholders were concerned about the safety domain removal and adverse impacts to rural and smaller hospitals due to increasing outcome measure relative weights. CMS indicated that it analyzed current data in the fall of 2018 and found a similar trend, where rural and small hospitals' payment would be adversely impacted from increasing outcome measure weights. CMS decided to keep measure weights to avoid adversely impacting rural and small hospitals. However, CMS did not take actions so that the efficiency score would not have a disproportionate effect on the total performance score and bonus payments to hospitals with lower quality scores. As of January 2020, the recommendation remains open.

Recommendation: To ensure that the HVBP program accomplishes its goal to balance quality and efficiency and to ensure that it minimizes the payment of bonuses to hospitals with lower quality scores, the Administrator of CMS should revise the practice of proportional redistribution used to correct for missing domain scores so that it no longer facilitates the awarding of bonuses to hospitals with lower quality scores.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS indicated that it would explore alternatives to the practice of proportional redistribution, and any changes to the distribution of weights for missing domains would be evaluated for potential negative impacts and would be subject to notice and comment rulemaking. In September 2018, HHS indicated that it was exploring alternatives and considering revising the practice of proportional redistribution used to correct for missing domain scores while also being mindful of any potential unintended consequences. In the Fiscal Year 2019 Inpatient Prospective Payment System proposed rule, CMS proposed to remove the safety domain and, in connection, to require scores for the remaining three domains in order to calculate the total performance score, but CMS did not finalize the weighting revision. CMS reported that stakeholders were concerned about the safety domain removal and any adverse impact to rural and smaller hospitals due to increasing outcome measure relative weights. CMS reported that it analyzed data and found that rural and small hospitals' payment would be adversely impacted from changing proportional redistribution to assign greater relative weight to outcomes. As a result, CMS decided to keep proportional redistribution. However, CMS's actions did not revise the practice of proportional redistribution, and, as a result, the practice may continue to facilitate the awarding of bonuses to hospitals with lower quality scores. As of January 2020, the recommendation remains open.

Recommendation: To help ensure the Navy thoroughly considers the relative benefits of using FPI contracts for shipbuilding versus other contract types, the Secretary of Defense should direct the Secretary of the Navy to conduct a portfolio-wide assessment of the Navy's use of additional incentives on FPI contracts across its shipbuilding programs. This assessment should include a mechanism to share proven incentive strategies for achieving intended cost, schedule, and quality outcomes among contracting and program office officials.

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: In providing comments on this report, the agency concurred with this recommendation. As of July 2020, the Navy had commissioned a study of its use of additional incentives on fixed-price incentive contracts across its shipbuilding programs. The Navy plans to socialize this report with the shipbuilding program executive offices so that they can share lessons learned across the shipbuilding enterprise. The estimated completion date for this effort is the fourth quarter of fiscal year 2020. Following completion of that effort, in the first quarter of fiscal year 2021, the Navy plans to provide recommendations regarding the use of additional incentives on fixed-price incentive contracts across its shipbuilding programs.

Recommendation: To improve the internal control environment for oversight using information from CAS and develop a consistent approach to the use of information from CAS in M&O contractor oversight and performance evaluation across the nuclear security enterprise, the Administrator of NNSA should establish comprehensive NNSA policies and guidance, beyond a general framework as included in NAP-21, for using information from CAS to conduct oversight of M&O contractors, clarifying whether CAS is to cover mission-related activities, and describing how to conduct assessments of risk, CAS maturity, and the level of the contractor's past performance.

Agency: Department of Energy: National Nuclear Security Administration
Status: Open
Priority recommendation

Comments: We recommended that NNSA establish comprehensive policies and guidance, beyond a general framework, for using information from contractor assurance systems (CAS) to conduct oversight of management and operating (M&O) contractors, clarifying whether CAS is to cover mission-related activities and describing how to conduct assessments of risk, CAS maturity, and the level of the contractor's past performance. NNSA agreed with the recommendation and has taken an important step to revise its policy. However, NNSA needs to take additional action. Specifically, NNSA approved a revised corporate site governance policy in August 2016, and NNSA further revised its policy in October 2019. The revised policy improves on the agency's prior policy by clarifying one element in our recommendation that CAS is to cover mission-related activities. However the policy is still a general framework and NNSA has not established associated implementing guidance. Specifically, NNSA needs to develop guidance for NNSA headquarters' and field offices' procedures to use information from CAS and appropriately balance use of information from CAS with other more direct activities to oversee M&O contractors. As of April 2020, this recommendation remains open.

Recommendation: To improve the effectiveness of the MSP program and process for NGHPs, and to improve the agency's communication regarding the MSP process for situations involving NGHPs, the Acting Administrator of CMS should develop guidance regarding liability and no-fault set-aside arrangements.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: As of March 2019, CMS officials reported that the agency was still in the process of implementing this recommendation about developing guidance regarding liability and no-fault set-aside arrangements. Since April 2012, the month the recommendation was made, CMS officials have reported at various times that the agency was planning to issue either regulatory or sub-regulatory guidance on this topic. In March 2019, officials said that the agency now planned to issue regulatory guidance, and that a Notice of Proposed Rulemaking was expected to be posted in October 2019. We will continue to update the status of this recommendation as new information is available.