Recommendation: The Secretary of Defense should direct the Director, Office of Cost Assessment and Program Evaluation to conduct an independent schedule assessment of the full program schedule for the Global Positioning System's next generation operational control system based on progress made through the end of calendar year 2019. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with our recommendation to conduct an independent assessment of the full OCX program schedule based on progress made through the end of calendar year 2019, citing an independent cost and schedule estimate conducted in September 2018 and other ongoing program assessment and monitoring efforts. GAO continues to affirm that the recommendation is necessary given that DOD has not conducted an assessment of the full schedule since June 2018, since which time program risks have evolved. Additionally, ongoing oversight efforts are limited in scope and do not include the developmental test period after product delivery. As of August 2020, the Air Force position remains a non-concur, based on the same rationale previously noted.

Recommendation: The Secretary of Defense should ensure that the Office of the Under Secretary of Defense for Policy (OUSD (Policy)), the Joint Staff, and the Office of the Director, Cost Assessment and Program Evaluation—in consultation with the services—determine the analytic products needed and the level of detail that is sufficient to serve as a common starting point but flexible to allow for variation of analysis to support senior leader decisions, and update these products to reflect current strategy and intelligence estimates, as well as the anticipated operational approaches needed to address future threats. (Recommendation 1)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation and, as of January 2020, has taken some steps to address it. Specifically, in May 2019, DOD sent a follow up letter to our final report that said that the Department's position on the report has not substantially changed and that the actions identified in the Department's initial response remain underway. DOD also noted that the FY 2021-2025 Defense Planning Guidance (DPG) signed in April 2019 directly addresses many of the report's recommendations and that the Joint Staff is leading an aggressive effort on joint force innovation and experimentation, with Tri-Chair oversight. In September 2019, we reviewed the DPG and found that it partially addressed our recommendation. In the DPG, DOD identified analytic products that would serve as the department's starting point for analysis in fiscal years 2021-2025. DOD has also begun developing some of these analytic products, including several defense planning scenarios that it developed in December 2018 to reflect some of the threats outlined in the National Defense Strategy. To fully implement this recommendation, DOD will need to develop the additional products it needs for the remaining key threats identified in the National Defense Strategy. Additionally, keeping these products updated will require sustained attention by the department, but the direction provided by DOD was limited to budget guidance for fiscal years 2021-2025. The direction would more closely adhere to the intent of our recommendation if it were provided in an enduring guidance or policy document. We will continue to monitor DOD actions in response to this recommendation.

Recommendation: The Secretary of Defense should ensure that OUSD (Policy) provide specific guidance requiring the services to explore a range of innovative force structure approaches relevant to the key threats identified in the National Defense Strategy, including identifying key assumptions on which the services must conduct sensitivity analyses. (Recommendation 2)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation and, as of January 2020, has taken some steps to address it. Specifically, in May 2019, DOD sent a follow up letter to our final report that said that the Department's position on the report has not substantially changed and that the actions identified in the Department's initial response remain underway. DOD also noted that the FY 2021-2025 Defense Planning Guidance (DPG) signed in April 2019 directly addresses many of the report's recommendations and that the Joint Staff is leading an aggressive effort on joint force innovation and experimentation, with Tri-Chair oversight. In September 2019, we reviewed the DPG and found that it directed some actions relevant to our recommendation regarding the need to explore a range of innovative force structure approaches. However, it did not directly address the need to require the services to conduct sensitivity analysis on key assumptions. The defense planning scenarios that DOD developed in December 2018 identify critical parameters for analytical exploration and encourage DOD components to conduct excursions and sensitivity analysis of assumptions, which we found has not been sufficient to spur this type of analysis in the past. To fully implement this recommendation, DOD needs to require the services to conduct this analysis. We will continue to monitor DOD actions in response to this recommendation.

Recommendation: The Secretary of Defense should establish an approach for comparing competing analyses and conducting joint analyses for force structure to support senior leaders as they seek to implement the National Defense Strategy. This could include establishing a separate body with these capabilities and/or specifying the organizational responsibilities and processes for conducting these comparisons and analyses. (Recommendation 3)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation and, as of January 2020, has taken some steps to address it. Specifically, in May 2019, DOD sent a follow up letter to our final report that said that the Department's position on the report has not substantially changed and that the actions identified in the Department's initial response remain underway. DOD also noted that the FY 2021-2025 Defense Planning Guidance (DPG) signed in April 2019 directly addresses many of the report's recommendations and that the Joint Staff is leading an aggressive effort on joint force innovation and experimentation, with Tri-Chair oversight. In September 2019, we reviewed the DPG and found that it included steps that could lay the groundwork for DOD to compare competing analyses and conduct joint force structure analyses. To fully implement this recommendation, DOD needs to establish an approach for doing so, which could include establishing a body or process for conducting comparisons or joint analyses. We will continue to monitor DOE actions in response to this recommendation.

Recommendation: Congress should consider designating an agency to regularly collect and maintain specified cost-related data from credit allocating agencies and periodically assess and report on LIHTC project development costs. (Matter for Congressional Consideration 1)

Agency: Congress
Status: Open

Comments: As of August 2020, Congress had not designated an agency to regularly collect and maintain data on LIHTC project development costs.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should require general contractor cost certifications for LIHTC projects to verify consistency with the developer cost certification. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that requiring general contractor cost certifications would help address a known fraud risk.

Recommendation: To help allocating agencies analyze development cost trends and drivers and make comparisons to other agencies, IRS's Commissioner of the Small Business/Self-Employed Division should encourage allocating agencies and other LIHTC stakeholders to collaborate on the development of more standardized cost data, considering information in this report about variation in data elements, definitions, and formats. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that greater standardization of LIHTC cost data would facilitate analysis of cost drivers and cost-management practices.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should communicate to credit allocating agencies how to collect information on and review LIHTC syndication expenses, including upper-tier partnership expenses. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that communicating expectations about the collection and review of syndication expenses would enhance program transparency and allocating agency financial assessments.

Recommendation: To better enable decision makers to evaluate the full long-term costs of posture initiatives under ERI, we recommend that the Secretary of Defense direct EUCOM and the military services to develop estimates for the sustainment costs of prepositioned equipment and other infrastructure projects under ERI and ensure that the services plan for these long-term costs in future budgets. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, stating that its components will continue to estimate the sustainment costs for prepositioned stocks and other infrastructure projects during DOD's annual program and budget review process, but adding that without additional topline base budget funding, some portion of the associated sustainment costs will need to be financed with OCO funds. We have since determined that the Department of the Army has estimated sustainment costs for prepositioned equipment and other infrastructure projects, and plans to incorporate those costs into the out-year cost projections in the next budget submission. As of August 2020 the Air Force had not taken steps to address this recommendation.

Recommendation: To improve insight into cost changes for individual ships in the Ford Class, the program office should prepare cost summary and funding summary sections for each individual ship in the class as part of the SAR for the overall Ford-Class program.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: In its comments on our draft report DOD disagreed with our recommendation, stating that it currently provides progress reports to Congress on costs for CVN 78 and CVN 79. In July 2020, Navy officials stated that the department continues to disagree with this recommendation. We continue to maintain that Selected Acquisition Reports represent the primary statutorily required means for DOD to report on program status. Grouping average unit costs for all Ford-class ships obscures individual ship cost growth and does not provide Congress with an adequate level of insight to monitor this over $55 billion program. Our recommendation would ensure that Congress receives insight into the costs of each existing and planned Ford-class ship. To fully implement this recommendation, the report should include cost information on individual ships.

Recommendation: To better enable DOD to provide congressional decision makers with complete and reliable information on the total anticipated costs for the JIAC consolidation efforts, the Office of the Assistant Secretary of Defense for Energy, Installations, and Environment's Basing Office--in coordination with the Office of the Assistant Secretary of the Air Force Installations, Environment and Energy-- should update future construction cost estimates for consolidating the JIAC at RAF Croughton using best practices for cost estimating as identified in the GAO Cost Estimating and Assessment Guide. Specifically, cost estimates for the JIAC consolidation should fully incorporate all four characteristics of a high-quality, reliable estimate.

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

Comments: In commenting on this report, DOD did not concur with our recommendation. DOD agreed that many components in the GAO Cost Estimating and Assessment Guide are broadly applicable in the decision process leading up to a military construction budget request. However, DOD further stated that once military construction funds are authorized and appropriated by Congress, the department transitions to a project management mode, and it would be a waste of resources to continue to generate cost estimates once they have transitioned to managing project execution using actual cost data. However, as we note in the report, DOD guidance for estimating construction costs, DOD's Unified Facilities Criteria 3-740-05, states that in the MILCON program, construction cost estimates are prepared throughout the planning, design, and construction phases of a construction project to account for the refinement of the project?s design and requirements. The final estimate should document the department?s assessment of the program's most probable cost and ensure that enough funds are available to execute it. As of October 2016, the military construction funds had not been authorized by Congress for the third phase of the JIAC construction project. According to DOD officials, construction is not scheduled to begin until fall of 2017, and the contract has not yet been awarded. Further, the GAO Cost Estimating and Assessment Guide states that regardless of whether changes to the program result from a major contract modification or an overtarget budget, the cost estimate should be regularly updated to reflect all changes. This is also a requirement outlined in OMB's Capital Programming Guide. The purpose of updating the cost estimate is to check its accuracy, defend the estimate over time, and archive cost and technical data for use in future estimates. After the internal agency and congressional budgets are prepared and submitted, it is imperative that cost estimators continue to monitor the program to determine whether the preliminary information and assumptions remain relevant and accurate. Keeping the estimate updated gives decision makers accurate information for assessing alternative decisions. Cost estimates must also be updated whenever requirements change, and the results should be reconciled and recorded against the old estimate baseline. Therefore, we continue to believe that DOD's implementation of our recommendation to update future JIAC cost estimates using the best practices identified in the GAO Cost Estimating and Assessment Guide would assist in ensuring that decision makers have complete and reliable information about costs associated with the JIAC consolidation and as the third phase of the JIAC project is authorized. Implementing our recommendation would also ensure that DOD develops a reliable historical record for the cost of the JIAC that can be used to estimate other similar projects in the future. As of June 2017, the agency had not taken any action to implement this recommendation. As of July 2018, a senior DOD official said that DOD is developing a new analysis of alternatives (AOA) for JIAC consolidation and will use, as appropriate, our AOA best practices. Those best practices include several focused on cost estimation. We have requested information on the extent to which the AOA team will use best practices for cost estimating to update the JIAC consolidation cost estimate. When we confirm what actions DOD has taken, we will provide updated information. As of September 2019, a senior DOD official said that DOD's prior non-concur with our recommendation is still valid for the reasons mentioned above.