oversight

Civilian Service Contract Inventories: Opportunities Exist to Improve Agency Reporting and Review Efforts

Published by the Government Accountability Office on 2012-09-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States Government Accountability Office

GAO              Report to Congressional Committees




September 2012
                 CIVILIAN SERVICE
                 CONTRACT
                 INVENTORIES

                 Opportunities Exist to
                 Improve Agency
                 Reporting and Review
                 Efforts




GAO-12-1007
                                           September 2012

                                           CIVILIAN SERVICE CONTRACT INVENTORIES
                                           Opportunities Exist to Improve Agency Reporting
                                           and Review Efforts
Highlights of GAO-12-1007, a report to
congressional committees




Why GAO Did This Study                     What GAO Found
In fiscal year 2011, civilian agencies     Civilian agencies did not fully comply with statutory requirements for compiling
reported $161 billion in contract          fiscal year 2011 service contract inventories. For example, because the
obligations, $126 billion (almost 80       information is not currently readily available, the Office of Management and
percent) of which were for services        Budget (OMB) directed the 49 agencies that were required to submit inventories
such as professional management and        to defer the collection of three statutorily required data elements for each
information technology support.            contract—the role the services played in achieving agency objectives, the total
Concerned about agencies’ reliance on      dollar amount invoiced for services under the contracts, and the number and
contractors, Congress included a           work locations of contractor and subcontractor personnel. Progress, however, is
requirement in the Consolidated
                                           being made to collect this information for future inventories. OMB directed
Appropriations Act of 2010 for civilian
                                           agencies to start collecting information on the role services play in achieving
agencies to compile and review an
annual inventory of service contracts to
                                           agency objectives for new contracts awarded on or after March 1, 2012. A
examine certain issues, such as            proposed Federal Acquisition Regulation rule was published in April 2011 to start
contractors performing inherently          collecting the remaining two data elements directly from contractors. We also
governmental functions or functions        found several instances where agencies significantly underreported obligations in
closely associated with inherently         their inventories, either because they misinterpreted or did not follow OMB
governmental functions, which would        guidance. For example, the General Services Administration underreported
require enhanced management                obligations by approximately $6.4 billion. Without complete and accurate service
oversight. It also required OMB to         contract inventories, OMB and Congress cannot meaningfully compare service
develop guidance to assist agencies in     contract obligations among agencies, or develop spending trends for agencies,
meeting the act’s requirements and for     thus limiting the overall utility of the inventories.
GAO to report on agency efforts.
                                           Nine of the 49 civilian agencies did not submit a report on their fiscal year 2010
GAO assessed agency efforts to             inventory review to OMB, as required. Of the 40 agencies that submitted reports
(1) compile their fiscal year 2011         on their inventory reviews, 5 agencies identified 3 contracts where contractors
inventories and (2) review and report      could be performing inherently governmental functions and 104 instances where
on their fiscal year 2010 inventories.     contractors were performing closely associated with inherently governmental
To meet these objectives, GAO              functions. It is unclear, however, based on the 40 agency reports, whether these
analyzed agencies’ fiscal year 2011        results were a real indication of the agencies’ effective and appropriate use of
service contract inventories and fiscal
                                           contractors or due to the different approaches agencies used to conduct the
year 2010 service contract inventory
                                           reviews. Agencies did not include important context in their reports, such as the
review reports and compared them to
legislative requirements, OMB
                                           number of contracts or the percentage of their inventories reviewed. As shown in
guidance, and federal procurement          the figure below, of the 25 agencies that reported the number of contracts they
data.                                      reviewed, most reviewed 50 or fewer contracts. OMB intends to have agencies
                                           share lessons learned, including the use of cross-functional teams, to help future
What GAO Recommends                        review efforts.
GAO recommends that OMB (1) work           Number of Contracts Agencies Reviewed
with agencies to improve how
compliance with the act and with OMB
guidance is monitored and (2) clarify
guidance to agencies for compiling and
reporting on their inventories. OMB
generally concurred with our
recommendations.


View GAO-12-1007. For more information,
contact John Hutton at (202) 512-4841 or
HuttonJ@gao.gov.

                                                                                   United States Government Accountability Office
Contents


Letter                                                                                                   1
                       Background                                                                        3
                       The Utility of Service Contract Inventories May Be Diminished by
                         Incomplete Data and Different Reporting Methodologies                          7
                       Inventory Review and Reporting Efforts Could Be Improved                        11
                       Conclusions                                                                     18
                       Recommendations for Executive Action                                            19
                       Agency Comments and Our Evaluation                                              19

Appendix I             Scope and Methodology                                                           22



Appendix II            Forty-Nine Agencies Required to Report on Service Contract
                       Inventories                                                                     24



Appendix III           GAO Contact and Staff Acknowledgments                                           26



Related GAO Products                                                                                   27



Tables
                       Table 1: Illustrative List of Special Interest Functions                          6
                       Table 2: Agencies Not Submitting Fiscal Year 2010 Inventory
                                Review Reports to OMB                                                  12
                       Table 3: Selected Agency Inventory Analysis Findings and
                                Resolutions                                                            15


Figures
                       Figure 1: Illustration of Variations in Service Contract Obligations
                                for Fiscal Year 2011 by Inventory Methodology (Using
                                GSA Obligations)                                                       10
                       Figure 2: Number of Contracts Agencies Reviewed                                 13




                       Page i                             GAO-12-1007 Civilian Service Contract Inventories
Abbreviations

ADP               Automated Data Processing
Commerce          Department of Commerce
DHS               Department of Homeland Security
DOT               Department of Transportation
FAIR Act          Federal Activities Inventory Reform Act of 1998
FAR               Federal Acquisition Regulation
FPDS-NG           Federal Procurement Data System-Next Generation
GSA               General Services Administration
HHS               Department of Health and Human Services
NASA              National Aeronautics and Space Administration
OFPP              Office of Federal Procurement Policy
OMB               Office of Management and Budget
State             Department of State


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Page ii                                   GAO-12-1007 Civilian Service Contract Inventories
United States Government Accountability Office
Washington, DC 20548




                                   September 27, 2012

                                   Congressional Committees

                                   Federal agencies rely on a multisector workforce of federal employees
                                   and contractor personnel to perform services needed to carry out their
                                   missions. These services include professional management support,
                                   information technology support, and medical support. In fiscal year 2011,
                                   federal civilian agencies reported $161 billion in total contract obligations,
                                   of which $126 billion, or almost 80 percent, were for services.
                                   Determining whether services should be performed by federal employees,
                                   contractor personnel, or a mixture of each is an important economic and
                                   strategic decision essential to the federal government’s effective and
                                   efficient use of taxpayers’ dollars. Certain functions that government
                                   agencies routinely perform, such as setting federal policy, issuing rules
                                   and regulations, or making best value determinations among contractors
                                   competing to provide needed goods or services are considered to be
                                   “inherently governmental” and must be performed by federal employees.
                                   In some cases, contractors may be performing services that are
                                   considered to be “closely associated with inherently governmental”
                                   functions, such as services to support policy makers or procurement
                                   officials. Agencies must give special management attention to these
                                   activities to guard against their expansion into inherently governmental
                                   functions. Other services, such as facilities maintenance or information
                                   technology support, may be obtained through a private contractor.

                                   In 2009, however, the President issued a memorandum on government
                                   contracting that expressed concerns about whether agencies have
                                   become overly reliant on contractors and if the government has
                                   outsourced services appropriately. 1 In particular, the President noted that
                                   the line between inherently governmental functions—those that must be
                                   performed by federal employees—and other services that may be
                                   contracted for has been blurred. In the memorandum, the President
                                   directed the Office of Management and Budget (OMB) to lead a series of
                                   contracting-related efforts including clarifying when outsourcing for
                                   services is appropriate.




                                   1
                                    The White House memorandum, Government Contracting (Mar. 4, 2009).




                                   Page 1                               GAO-12-1007 Civilian Service Contract Inventories
Congress has also expressed concern with agencies’ reliance on
contractors and has directed OMB and other federal agencies to examine
similar workforce issues, which include identifying functions that are not
appropriate for contractors to perform or require increased government
oversight. The Consolidated Appropriations Act of 2010 requires civilian
federal agencies to compile an annual inventory of their service contracts
and review their contracts and information in the inventories to determine,
among other things, whether contracts are being performed in
accordance with laws and regulations. 2 In addition, the act requires that
after reviewing the annual inventory, each agency must report to OMB on
the actions taken to consider and convert functions from contractor to
federal employee performance. Under the act, OMB is required to
develop guidance to assist agencies in meeting the law’s requirements
and to ensure that agencies compile their inventories in a consistent
manner. The act also requires GAO to report to Congress on OMB’s
guidance, and agency implementation of the service contract inventory
requirement for fiscal years 2010 and 2011.

In May 2011, we reported on OMB’s guidance and agency efforts to
compile their fiscal year 2010 inventories. 3 For this report, we assessed
civilian agencies’ efforts to (1) compile their fiscal year 2011 inventories
and (2) review and report on their fiscal year 2010 inventories.

To assess agencies’ efforts to compile their fiscal year 2011 inventories,
we reviewed the act, OMB guidance, and the proposed Federal
Acquisition Regulation (FAR) rule on service contract inventories. 4 In
addition, we obtained and reviewed available civilian agency inventories
to determine whether they contained data elements required by OMB
guidance. Further, we compared the obligations reported in their
inventories with the Federal Procurement Data System— Next
Generation (FPDS-NG) data. 5 While our prior work identified data


2
Pub. L. No. 111-117, § 743 (2009).
3
 GAO, OMB Service Contract Inventory Guidance and Implementation, GAO-11-538R
(Washington, D.C.: May 27, 2011).
4
 The Federal Acquisition Regulation is the regulation used by federal executive agencies
for acquisition of supplies and services with appropriated funds.
5
 FPDS-NG is the primary governmentwide contracting database, providing information on
government contracting actions, procurement trends, and achievement of socioeconomic
goals, such as small business participation.




Page 2                                   GAO-12-1007 Civilian Service Contract Inventories
             reliability issues with FPDS-NG, for the purposes of this report, we found
             FPDS-NG data to be sufficiently reliable to determine how agencies
             compiled their inventories. 6 To assess agencies’ efforts to review and
             report on their fiscal year 2010 inventories, we reviewed civilian agencies’
             reports of the fiscal year 2010 inventory reviews to determine the number
             of contracts reviewed, the methodologies used, and the workforce issues
             identified. In cases where agencies identified contracts that may involve
             inherently governmental, or closely associated with inherently
             governmental functions, we did not independently assess whether the
             functions were in fact inherently governmental or closely associated with
             inherently governmental functions. We also selected five civilian
             agencies—the Department of Health and Human Services (HHS), the
             Department of Homeland Security (DHS), the Department of
             Transportation (DOT), the General Services Administration (GSA), and
             the National Aeronautics and Space Administration (NASA)—for a more
             in-depth review as to how they compiled and reviewed their service
             contract inventories. We selected these agencies because they represent
             approximately 42 percent of civilian agency service contract obligations
             for fiscal year 2011. Appendix I provides a detailed description of our
             scope and methodology.

             We conducted this performance audit between April 2012 and September
             2012 in accordance with generally accepted government auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives.


             The Consolidated Appropriations Act of 2010 requires the heads of
Background   executive civilian agencies subject to the Federal Activities Inventory
             Reform (FAIR) Act of 1998 to annually submit to OMB an inventory of
             service contract actions by December 31 of each year, beginning with




             6
              For past reports on FPDS-NG see GAO, Contracting Strategies: Data and Oversight
             Problems Hamper Opportunities to Leverage Value of Interagency and Enterprisewide
             Contracts, GAO-10-367 (Washington, D.C.: Apr.29, 2010); and Federal Contracting:
             Observations on the Government’s Contracting Data Systems, GAO-09-1032T
             (Washington, D.C.: Sept. 29, 2009).




             Page 3                                 GAO-12-1007 Civilian Service Contract Inventories
fiscal year 2010 contracts. 7 The requirement, according to OMB, applies
to 49 executive agencies. Appendix II lists these agencies. The
inventories are to include 15 data elements for all contracts awarded or
extended in the preceding fiscal year, such as services purchased by the
agency, the role the services played in achieving agency objectives, the
total dollar amount obligated for services, and the number and work
location of contractor and subcontractor personnel compensated under
each contract. Agencies are required to make their inventories publicly
available no later than 30 days after they submit their inventory to OMB. 8

The act also directs agencies to review their inventories within 180 days
of the December 31 deadline to ensure that:

•   each personal service contract is being performed according to laws
    and regulations; 9
•   the agency is giving special management attention to functions that
    are closely associated with inherently governmental functions;
•   the agency is not using contractor personnel to perform inherently
    governmental functions;
•   the agency has specific safeguards and monitoring systems in place
    to ensure that work performed by contractors has not changed or
    expanded during performance to become an inherently governmental
    function;
•   the agency is not using contractor personnel to perform critical
    functions that could jeopardize the ability of the agency to maintain
    control of its mission and operations; and
•   there are sufficient internal agency resources to effectively manage
    and oversee contracts.



7
 Pub. L. No. 111-117, § 743 (2009). The Federal Activities Inventory Reform Act of 1998,
as amended (31 U.S.C. § 501 note), requires agencies to submit annual lists of activities
that are not inherently governmental functions. Executive agencies subject to the FAIR Act
include executive departments such as DHS, and independent establishments, such as
NASA.
8
Pub. L. No. 111-117, § 743(c).
9
 A personal services contract is characterized by the employer-employee relationship it
creates between the government and the contractor’s personnel. The government is
normally required to obtain its employees by direct hire under competitive appointment or
other procedures required by the civil service laws. Agencies are not permitted to award
personal services contracts unless specifically authorized by statute to do so. (FAR §
37.104.)




Page 4                                   GAO-12-1007 Civilian Service Contract Inventories
Agencies must also identify contracts that (1) have been poorly
performed, either because of excessive costs or inferior quality, and
(2) should be considered for conversion to performance by federal
employees, also known as insourcing, or an alternative acquisition
approach to enable the agency to efficiently utilize its resources and
achieve its public mission. The law requires that each agency include with
its current inventory a report on the actions taken as a result of reviewing
their prior year’s inventory and to make the report publicly available.

To aid agencies in establishing systems to collect the contract inventory
information and to ensure consistency across agencies, the act required
the Director of OMB to develop and disseminate guidance to agencies by
March 1, 2010. OMB issued the guidance in November 2010. We
previously reported on differences between the act and OMB guidance. 10
For example, although the act did not set a minimum dollar threshold for
the contracts included in the inventories, OMB directed agencies to report
only on contract actions over $25,000. Additionally, OMB directed
agencies to only report the data elements included in FPDS-NG. As a
result, agencies did not report three data elements required by the statute
in their fiscal year 2010 inventories—(1) the role the services played in
achieving agency objectives, (2) the total dollar amount invoiced for
services under the contract, and (3) the number and work location of
contractor and subcontractor personnel. In recent reviews of both DOD
and civilian agencies inventories, we also reported that FPDS-NG does
not allow agencies to:

•     identify and record more than one type of service purchased for each
      contracting action entered into the system;
•     capture any services performed under contracts that are
      predominantly for supplies; and
•     capture service contracts awarded on behalf of an agency by other
      agencies. 11




10
    GAO-11-538R.
11
  GAO, Defense Acquisitions: Further Actions Needed to Improve Accountability for
DOD’s Inventory of Contracted Services, GAO-12-357 (Washington, D.C.: Apr. 6, 2012),
GAO-11-538R; and Defense Acquisitions: Further Action Needed to Better Implement
Requirements for Conducting Inventory of Service Contract Activities, GAO-11-192
(Washington, D.C.: Jan. 14, 2011).




Page 5                                 GAO-12-1007 Civilian Service Contract Inventories
OMB also provided guidance to agencies on conducting and reporting
their fiscal year 2010 inventory reviews. The guidance states that the
reviews shall be informed through appropriate techniques, such as
sampling of contract files, interviewing program managers and contracting
officer technical representatives, and using other supplemental
information-gathering methods as needed. Under OMB’s guidance,
agencies should give heightened management consideration to certain
“special interest functions” that require increased management attention
due to heightened risk of workforce imbalance, such as agencies
becoming overreliant on contractor personnel. OMB anticipated that
professional and management services and information technology
support services posed an increased risk of agencies losing control of
their missions and operations. Table 1 provides an illustrative list of the
special interest functions identified by OMB.

Table 1: Illustrative List of Special Interest Functions

                          Professional and Management Services
                                   Cost Benefit Analyses
                            Policy Review/Development Services
                                Program Evaluation Services
                           Program Management/Support Services
                           Program Review/Development Services
                            Specifications Development Service
                   Management Services/Contract and Procurement Support
                                   Intelligence Services
                            Engineering and Technical Services
                               Systems Engineering Services
                                Personal Services Contracts
                         Information Technology Support Services
               Automated Data Processing (ADP) Systems Development Services
                          Automated Information Systems Services
                          ADP System Acquisition Support Services
                             ADP Backup and Security Services
Source: OMB.



The guidance also stated that as part of agencies’ reviews of professional
and management services, agencies should include acquisition support
and an appropriate sampling of policy and program management and
development services, and additional functions where the agency may be



Page 6                                    GAO-12-1007 Civilian Service Contract Inventories
                           at risk of overreliance on contractors or other challenges, such as
                           inadequate contract management support.


                           In our review of fiscal year 2011 service contract inventories, we found
The Utility of Service     that 48 of the 49 agencies compiled their inventories. However, agencies
Contract Inventories       are continuing to defer collection of three required data elements, per
                           OMB guidance. While most agencies followed OMB’s methodology for
May Be Diminished by       compiling inventories, some agencies used different methodologies. As a
Incomplete Data and        result, OMB and Congress cannot meaningfully use these service
                           contract inventories to compare service contract obligations among
Different Reporting        agencies or develop spending trends, and agencies did not have a
Methodologies              complete universe of service contracts to consider for review.


Agencies Are Not Fully     OMB directed agencies to prepare a fiscal year 2011 service contract
Complying with Inventory   inventory, submit the inventory to OMB, and make it publicly available by
Reporting Requirements     January 30, 2012. During the course of our review we sought to obtain
                           the inventories from each agency’s website and found that as of July
                           2012, 14 of the 49 agencies did not make their inventories publicly
                           available. We followed up with OMB and the agencies and eventually
                           obtained inventories from 13 of those 14 agencies. For the remaining
                           agency—the Court Services and Offender Supervision Agency for D.C.—
                           we could not find evidence that it compiled its service contract inventory
                           for fiscal year 2011, and nor did it do so for fiscal year 2010. OMB staff
                           indicated that they reminded the agency of its responsibility to prepare
                           and submit an inventory, but they did not devote resources to compelling
                           a response when the agency was not responsive. OMB staff explained
                           that the agency’s total spending is well under 1 percent of civilian agency
                           spending and attention on this initiative was more effectively devoted to
                           other agencies and issues. OMB continued to direct agencies to defer
                           collection of three statutorily required data elements—the role the
                           services played in achieving agency objectives, total dollar amount
                           invoiced for services under the contracts, and the number and work
                           locations of contractor and subcontractor personnel. The lack of this
                           required information diminished the utility of the inventory because
                           agencies do not have good visibility as to the number of contractor
                           personnel or their role in supporting agency activities.

                           Progress, however, is being made towards collecting this information. For
                           example, OMB directed agencies to start collecting information on the
                           role services play in achieving agency objectives for new contracts
                           awarded on or after March 1, 2012. The guidance states that agencies


                           Page 7                             GAO-12-1007 Civilian Service Contract Inventories
are to report, in the “description of requirement” field in FPDS-NG,
whether the services provided under the contract are predominantly for
functions closely associated with inherently governmental ones, critical
functions, or other functions. According to OMB guidance, by identifying
closely associated and critical functions at the time of award, agencies
can prioritize which contracts may require increased management
attention and oversight to ensure that mission creep does not result in
contractor personnel performing inherently governmental functions, and
ensure that the agency does not lose control of its mission and
operations. While this information may be helpful in identifying which
service contracts may require additional oversight or be appropriate
candidates for insourcing, it is not clear that this information will provide a
full description of the role contractors played in achieving agency
objectives. OMB staff indicated that they will review this issue, along with
others, as they consider revisions to the guidance based on initial agency
experience.

Information on the remaining two data elements—total dollar amount
invoiced for services under the contracts and the number and work
locations of contractor and subcontractor personnel—will continue to be
deferred pending the outcome of a proposed FAR rule on service contract
inventories. The proposed rule would create a new FAR subpart to
address responsibilities for collection, management, and reporting of the
inventory information. The rule would also create a new contract clause to
be used in contracts that meet certain dollar thresholds and would require
contractors to submit the following information for covered service
contracts (1) the contract number and, when applicable, order number;
(2) the total dollar amount invoiced for services performed during the
previous fiscal year under the contract; (3) the number of contractor direct
labor hours expended on the services during the previous fiscal year; and
(4) the number of direct-labor hours expended on services performed by
first-tier subcontractors. 12 The proposed FAR rule is being reviewed by
OMB and OMB staff anticipated that the rule would be finalized later this
fall. The proposed rule provides that collection of the information be
phased in over the next 4 years. Information will be collected directly from
contractors through a web portal and housed in the System for Award
Management. No additional hard copy reporting will be required.



12
  Federal Acquisition Regulation; Service Contract Reporting Requirements, 76 Fed. Reg.
22,070 (Apr. 20, 2011).




Page 8                                  GAO-12-1007 Civilian Service Contract Inventories
Most Agencies Followed   OMB provided guidance to civilian agencies for compiling their service
OMB Guidance When        contract inventories, including the structure and scope of the inventories.
Compiling Their          To standardize the structure of the service contract inventories, OMB
                         provided a template for agencies to organize contract activities by product
Inventories              and service code. 13 To establish the scope of the service contract
                         inventories, OMB directed agencies to include all service contract actions
                         over $25,000 that were awarded in fiscal year 2011. Agencies were to
                         include contract actions that they have funded, including contract actions
                         made on their behalf by other agencies, and exclude contract actions that
                         they have made on another agency’s behalf with the other agency’s
                         funding. We found the following based on our review of 48 available
                         civilian agency inventories:

                         •   Forty-five agencies reported on all the data elements in OMB’s
                             standard template. The other three agencies did not include certain
                             data elements, such as the extent to which the contract was
                             competed, the product and service code and description, and the date
                             signed. OMB staff was unaware that these agencies had not reported
                             on all data elements.

                         •   Forty-three agencies generally followed OMB’s guidance to report on
                             obligations on all contract actions over $25,000. Five agencies,
                             however, did not. One agency—DOT—reported information on fiscal
                             year 2010 obligations for its fiscal year 2011 inventory. DOT officials
                             were unaware of this error until our review. A DOT official told us DOT
                             sent a revised inventory with the correct fiscal year 2011 information
                             to OMB. Three agencies—the National Endowment for the
                             Humanities, the Selective Service System, and the U.S. Trade and
                             Development Agency—incorrectly interpreted OMB’s guidance as
                             limiting the scope of the inventory to just new awards for that fiscal
                             year. As a result, these agencies underreported their inventories.
                             OMB staff told us that they intended for civilian agencies to include all
                             changes in obligations over $25,000 occurring in fiscal year 2011,
                             regardless of when the contract award occurred. The fifth agency—
                             GSA—did not follow OMB’s guidance to include all contract actions
                             over $25,000 awarded in fiscal year 2011. Instead, GSA included in
                             its inventory only the obligations for contract actions related to the



                         13
                           Product and service codes describe the products, services, and research and
                         development purchased by the federal government. The codes indicate what was bought
                         for each contract action in FPDS-NG.




                         Page 9                                 GAO-12-1007 Civilian Service Contract Inventories
     special interest function product and service codes identified by OMB
     as priority areas for the inventory review. As a result, GSA excluded
     approximately $6.4 billion in service contracts from its inventory. In
     response to these findings, GSA officials noted that they are in the
     process of creating a new report with the correct information, which
     will be submitted to OMB. We used GSA as an example in figure 1 to
     illustrate the potential differences in obligations that would be reported
     based on the three different methodologies we identified. For
     instance, GSA’s obligations would be about $116 million if it only
     reported on special interest functions, $4.5 billion if it only reported on
     new awards, and $6.5 billion if it reported on all obligations for fiscal
     year 2011.


Figure 1: Illustration of Variations in Service Contract Obligations for Fiscal Year
2011 by Inventory Methodology (Using GSA Obligations)




Note: The information used for this analysis was based on data we obtained from FPDS-NG in
February 2012. While we recognize that the data may change slightly over time after the end of a
fiscal year, the analysis represents a snapshot of obligations for that time frame.


OMB staff were unaware that some agencies used different
methodologies to compile their inventories. OMB staff stated that
differences in agency methodologies were not readily apparent when they
initially reviewed the inventories because data is organized differently



Page 10                                       GAO-12-1007 Civilian Service Contract Inventories
                            than how it would otherwise appear in FPDS-NG. In the absence of a
                            consistent methodology, OMB and Congress cannot meaningfully
                            compare service contract obligations among agencies or develop
                            spending trends for agencies. Further, agency use of a different
                            methodology resulted in a smaller population of contracts to sample from
                            for their review. OMB staff acknowledged that the inconsistency in
                            reporting methods may limit the utility of the inventories.


                            Forty of the 49 agencies conducted a review of their fiscal year 2010
Inventory Review and        inventory and reported the results of their review. The other 9 agencies
Reporting Efforts           did not submit an inventory report to OMB or make their reports publicly
                            available. Most agencies that conducted a review followed OMB guidance
Could Be Improved           and reported on the number of product and service codes reviewed and
                            the obligations for these product and service codes. However, since OMB
                            did not require agencies to report the number of contracts reviewed or the
                            percentage of obligations associated with the contracts reviewed, it is
                            unclear how much of their inventories agencies actually reviewed. Based
                            on reports submitted to OMB, 5 of the 40 agencies identified workforce
                            issues such as functions that are not appropriate for contractors to
                            perform, require increased government oversight, or require agencies to
                            change the mix of contractor and government personnel performing a
                            function. Specifically, the 5 agencies identified a total of 3 contracts where
                            contractors could be performing inherently governmental functions and
                            104 instances of contractors performing closely associated with inherently
                            governmental functions. Agency officials identified several practices that
                            may be effective for future reviews and decision-making efforts.


Most Agencies Reviewed      OMB directed agencies to conduct a meaningful review of their fiscal year
Their Fiscal Year 2010      2010 inventory and identify at a minimum (1) the special interest functions
Inventory, but the Extent   studied by the agency, including the dollars obligated to those specific
                            product and service codes in fiscal year 2010; (2) the methodology used
of Review Is Unclear        to support their reviews; (3) their findings; and (4) the actions taken or
                            planned by the agency to address any identified weaknesses or
                            challenges. Agencies were also directed to submit an inventory review
                            report to OMB and make the report publicly available.

                            We collected the required reports for 40 of the 49 agencies, either from
                            their websites or OMB. OMB staff confirmed that the remaining
                            9 agencies, which accounted for less than 1 percent of civilian agency
                            service contract obligations for fiscal year 2010, did not submit the



                            Page 11                             GAO-12-1007 Civilian Service Contract Inventories
required information or made it publicly available. Table 2 lists these
agencies.

Table 2: Agencies Not Submitting Fiscal Year 2010 Inventory Review Reports to
OMB

                                         Broadcasting Board of Governors
                       Court Services and Offender Supervision Agency for D.C.
                                    Federal Energy Regulatory Commission
                                            Federal Maritime Commission
                                          Merit Systems Protection Board
                                National Archives and Records Administration
                                          National Endowment for the Arts
                                               Selective Service System
                                      U.S. Trade and Development Agency
Source: GAO analysis of reports collected through civilian agencies’ websites and OMB.




We followed up with these agencies to determine why they did not submit
the required information and received one response from the National
Endowment for the Arts as to why it had not conducted an inventory
review. An agency official told us the National Endowment for the Arts did
not conduct a fiscal year 2010 inventory review because it did not have
any service contracts for special interest functions as defined in OMB’s
guidance.

Based on the reports submitted to OMB by 40 agencies, we observed
that

•     Thirty-four agencies reported on the number of product and service
      codes reviewed and the associated obligations for these product and
      service codes. The number of product and service codes and
      obligations reviewed varied widely. For example, GSA reviewed 4
      product and service codes, while HHS reviewed 31 codes. OMB staff
      expected variance because agencies were directed to select service
      codes that warranted the agency’s increased management attention
      or posed an increased risk of workforce imbalances.

•     Twenty-five agencies reported on the number of contracts they
      reviewed; however, OMB did not require agencies to provide this
      information. The number of contracts reviewed ranged from one
      contract by the Federal Labor Relations Authority to more than



Page 12                                                      GAO-12-1007 Civilian Service Contract Inventories
                             2,000 contracts by the Department of the Interior. As shown in
                             figure 2, the majority of the agencies reviewed less than 50 contracts.


                         Figure 2: Number of Contracts Agencies Reviewed




                         More than a third of the 25 agencies, however, did not provide enough
                         context in their reports for us to determine the percentage of contracts
                         they reviewed, or the percentage of obligations that the selected contracts
                         represented. This information would provide an indication of the extent to
                         which agencies reviewed their inventories and context that would be
                         important for oversight purposes. For example, DOT reported
                         approximately $1.2 billion in contract obligations for the product and
                         service codes it reviewed. The agency reviewed 42 contracts, but did not
                         report how they selected these contracts or the percentage of obligations
                         the contracts covered. These 42 contracts could represent anywhere from
                         all of the contracts to a small fraction of the contracts in those product and
                         service codes. NASA was one of the agencies that reported on the
                         percentage of obligations covered under the contracts they reviewed.
                         NASA reported that the eight contracts it chose to review represented
                         more than 70 percent of the $3.2 billion in obligations for the two product
                         and service codes on which it focused its review.


Some Agencies Reported   The Consolidated Appropriations Act of 2010 required agencies to review
Workforce Issues         their fiscal year 2010 inventories and report on the findings and actions
                         taken as a result of the review. Of the 40 reports that were submitted to
                         OMB, 5 agencies—the Department of Commerce (Commerce), DHS,
                         GSA, HHS, and the Department of State (State)—identified a total of 3
                         contracts where contractors could potentially be performing inherently



                         Page 13                             GAO-12-1007 Civilian Service Contract Inventories
governmental functions and 104 instances of contractors performing
closely associated with inherently governmental functions.

•   State identified two of the contracts where contractors could
    potentially perform inherently governmental functions, but did not
    identify, in its report, how many contractor personnel were involved.
    State officials explained that no inherently governmental functions
    have been outsourced. In its report, State identified a contract where
    contractors could potentially perform inherently governmental
    functions. State officials told us that this contract was for private
    security contractors that perform security functions. Officials explained
    that while this contract was originally thought to potentially include
    inherently governmental functions, upon further analysis, they
    determined that strategies currently in place—including increased
    oversight, pre-mission briefs, video recording of movement, and
    recording of radio traffic—mitigated this risk. In its report, State
    explained that the departure from government control is only
    temporary, and government officials typically provide contingency
    direction to contractors in these instances.

•   DHS identified one contract as containing potentially inherently
    governmental functions. This contract was for watch officer support for
    the Transportation Security Administration Call Center. DHS officials
    stated that this contract included 5.5 full-time equivalent positions,
    which the component planned to insource, but has delayed action
    pending an organizational review to determine if the agency still
    needs the positions.

•   Each of the five agencies reported instances where contractors were
    identified as performing functions closely associated with inherently
    governmental functions. HHS was the only agency that reported that it
    insourced positions as a result of their findings. The other four
    agencies provided mixed responses as to whether their project
    managers or contracting officers’ representatives provided sufficient
    monitoring of activities and performance for these contracts. For
    example, State reported that while one contract received special
    management attention, a number of acquisition and program staff
    were unclear whether there was sufficient oversight for their contracts.

The act and OMB guidance also directed agencies to ensure that there
are sufficient internal resources to effectively manage and oversee
contracts. To do this, for example, DHS asked its components to report
the number of federal workers providing oversight and management of
service contracts. Similarly, NASA officials told us that they conducted


Page 14                            GAO-12-1007 Civilian Service Contract Inventories
                                           interviews with contracting officers and contracting officers’
                                           representatives to determine whether contractor personnel had
                                           appropriate oversight.

                                           Three of the five agencies we reviewed—DHS, HHS, and NASA—
                                           identified workforce issues and took steps to resolve them. Table 3
                                           summarizes these findings and the actions that these agencies have
                                           taken or planned to take to resolve their workforce issues. While the
                                           resolutions were outlined in the agencies’ reports, we followed up with the
                                           agencies to obtain the status of their resolutions.

Table 3: Selected Agency Inventory Analysis Findings and Resolutions

Agency Workforce issue                                         Proposed resolution                               Resolution status
DHS      One contract containing potentially inherently        Insource 5.5 full-time equivalents                Officials stated that this
         governmental functions                                                                                  resolution is pending
                                                                                                                 internal review
HHS      Two functions at risk of becoming inherently          Insource 22 full-time equivalents; redefine       Officials stated that this
         governmental functions                                contractor roles and responsibilities             resolution is complete
         Two functions that are closely associated with Insource 14 full-time equivalents; eliminate             HHS noted in its report
         inherently governmental functions              unnecessary contractor positions; reassign work          that this resolution was
                                                        to federal employees                                     complete
NASA     Federal full-time equivalents needed to               Insource 4 full-time equivalents                  Officials stated that this
         maintain control and oversight of mission                                                               resolution is complete
                                           Source: GAO analysis of civilian agency data.




                                           As shown in the table, some agencies reported their workforce issues as
                                           functions, while others reported them in terms of contracts. Agencies that
                                           report their issues in terms of contracts present a challenge because a
                                           service contract can include multiple functions. As a result, it is unclear
                                           whether the issue identified is pertinent to the entire contract or a specific
                                           function within a contract.

                                           Officials at two of the five agencies we visited stated more generally that if
                                           workforce issues were to be identified, the agencies may not be able to
                                           take immediate action due to resource limitations. For example, officials
                                           from DHS cited instances where components could not implement
                                           insourcing recommendations because they could not secure the full-time
                                           equivalent positions to do so. While OMB requires that agencies report, at
                                           a minimum, the actions taken or planned by the agency to address any
                                           identified weaknesses or challenges, OMB staff agreed with our
                                           observation that it would be helpful if agencies also reported on the
                                           resolution of any findings identified as part of their inventory review in



                                           Page 15                                         GAO-12-1007 Civilian Service Contract Inventories
                          future reports. We recently reported that DOD had not resolved workforce
                          issues identified during its fiscal year 2009 inventory review and in some
                          instances, contractors continued to perform functions identified as being
                          inherently governmental a year after they were originally identified. 14


Agencies Identified       According to OMB staff, some agencies struggled with their inventory
Practices That May Help   review efforts and OMB intends to have agencies share lessons learned
Future Efforts            to help facilitate future efforts. Officials at the five agencies we selected
                          for a more in-depth review identified several practices they found effective
                          in reviewing their fiscal year 2010 inventories, including using cross-
                          functional teams, leveraging existing related efforts, and obtaining
                          management support. Two of these agencies also used the inventories
                          for strategic sourcing purposes. 15

                          •     Using Cross-Functional Teams: Four of the five agencies we
                                reviewed employed cross-functional teams and some agency officials
                                noted that the team helped them to resolve workforce issues. For
                                example, the DHS cross-functional teams included representatives
                                from acquisition, budget and finance, general counsel, and human
                                resources at both the department and component levels. DHS officials
                                stated that the department-level team is equipped to resolve issues
                                involving costly or high-visibility contracts and has enabled DHS to
                                determine if workforce balance issues were widespread or only
                                affected certain components. HHS also used cross-functional teams,
                                which allowed the agency to identify and expeditiously resolve
                                workforce imbalance issues. For instance, HHS identified two
                                functions in the areas of acquisition assistance and human resource
                                classification specialists that the agency felt were more appropriately
                                suited for execution by federal employees. HHS took corrective action
                                by hiring 14 government employees, eliminating unnecessary
                                contractor support and reassigning work to federal employees as
                                necessary.

                          •     Leveraging Existing Efforts: Two agencies—NASA and DHS—
                                leveraged other ongoing efforts to conduct their reviews, thus


                          14
                              GAO-12-357.
                          15
                            Strategic sourcing is the collaborative and structured process of critically analyzing an
                          organization’s spending and using this information to make business decisions about
                          acquiring commodities and services more effectively and efficiently.




                          Page 16                                    GAO-12-1007 Civilian Service Contract Inventories
    reducing the amount of additional resources dedicated to the effort.
    For example, NASA incorporated the findings of an ongoing
    information technology program and a workforce pilot into their
    service contract inventory review. NASA reported it selected the
    workforce pilot because portions of the work being studied were
    perceived to be either critical or inherently governmental functions.
    Further, leveraging knowledge gained from the information technology
    program allowed NASA to include several high visibility information
    technology acquisitions in their reviews without having to
    independently review all the contracts associated with them.

    DHS relied on its existing Balanced Workforce Strategy to conduct the
    required inventory reviews and used its standardized Balanced
    Workforce Strategy Tool to review 212 service contracts. The tool is
    an automated decision support survey that enables components to
    categorize work as inherently governmental, personal services,
    closely associated with an inherently governmental function, or a
    critical function. The tool is also intended to facilitate an assessment
    of mission risk, level of contractor oversight needed, mitigation
    strategies, and cost analysis. Based on component responses, the
    tool is to provide a recommended sourcing decision on whether the
    work is appropriate for federal or contractor performance, or both.

•   Obtaining Management Support: Officials at four of the five
    agencies we reviewed had significant and visible management
    support and involvement, which helped facilitate inventory review
    efforts and department-level decision making. For example, the
    Assistant Secretary for Financial Resources at HHS, who also serves
    as the agency’s Chief Acquisition Officer, issued a memorandum to
    division heads outlining the requirements of the inventory review
    process. According to HHS’ senior procurement executive, this helped
    ensure participation from all divisions, and the agency was able to
    address redundancies and duplications from an enterprisewide
    perspective because of management involvement in the review. In
    contrast, GSA officials stated that management was kept up to date
    on, but did not actively participate in, the effort. Additionally, the GSA
    official responsible for overseeing the inventory review said that, to his
    knowledge, the inventory had not been used for any department-level
    decision making.

•   Strategic Sourcing: Some agencies reported that they used the
    inventories to identify redundancies and duplications, which led to
    strategic sourcing decisions. For example, HHS officials stated that
    the agency used its inventory to obtain visibility into redundant


Page 17                             GAO-12-1007 Civilian Service Contract Inventories
                  contracts across the department. As a result, it consolidated
                  15 service contracts into 4 contracts, resulting in an estimated savings
                  of $20 million. DOT reported that it concentrated its analysis efforts on
                  management support services contracts to identify ways to reduce
                  spending in these areas by 15 percent by the end of fiscal year 2012.

              The Consolidated Appropriations Act of 2010 required agencies to collect
Conclusions   information and compile an inventory of their service contracts and review
              the inventories to help agency officials determine, among other things,
              whether they have the right balance of contractor and in-house resources
              needed to accomplish their missions. If the service contract inventories
              are to be a valuable management tool, it is essential that civilian
              agencies’ inventories contain comprehensive, accurate, and actionable
              data. OMB plays an important role in ensuring that agencies are meeting
              statutory requirements and providing useful information. OMB efforts to
              date have been focused on issuing guidance to agencies on how to
              compile, review, and report on their service contract inventories.
              However, civilian agency efforts are in the early stages and agencies
              have not been able to meet all the requirements for compiling and
              reviewing the service contract inventories. In some cases this is due to
              the fact that some of the statutorily required data elements to be
              contained in the inventories are not available. Under the proposed FAR
              rule, if finalized, agencies would start collecting unavailable, but required
              data elements directly from contractors. In other cases, agencies
              misinterpreted or did not follow OMB’s guidance, which caused them to
              significantly underestimate the scope of their inventories.

              Although most agencies followed OMB guidance for reporting on their
              inventory reviews, it is unclear based on the information provided in their
              reports whether the results of the reviews were a real indication of the
              agencies’ effective and appropriate use of contractors or due to the
              different approaches used to conduct the inventory reviews. When
              workforce issues were identified, such as contractors performing
              potentially inherently governmental functions, agencies did not
              consistently report on the number of contractor personnel and functions
              involved. Further, three of the five agencies that we reviewed identified
              workforce issues and took corrective action. However, the agencies did
              not report if the issues had been fully resolved. Agencies were not
              required to report on either the number of contracts or the percentage of
              their inventories they reviewed. As a result, many of the reports did not
              have important context on the scope of the analyses performed. Without
              OMB’s continued guidance and agency commitment to improve the



              Page 18                            GAO-12-1007 Civilian Service Contract Inventories
                      compliance, consistency, and context for the inventory and inventory
                      reviews, the utility of the inventories for agency decision making and OMB
                      and congressional oversight will be limited.


                      To help improve civilian agency compliance for compiling, reviewing, and
Recommendations for   reporting on inventories, we recommend that the Administrator of OMB’s
Executive Action      Office of Federal Procurement Policy work with agencies to improve how
                      compliance with statutory and OMB requirements is monitored, which
                      might include agencies designating accountable officials to ensure
                      appropriate internal management attention and responsiveness.

                      To help ensure that the service contract inventories contain consistent
                      and reliable information and that the service contract inventory analysis
                      reports have sufficient information to provide greater context and value,
                      we recommend that the Administrator of OMB’s Office of Federal
                      Procurement Policy clarify guidance to:

                      •   Require agencies to fully describe in their inventory review reports the
                          scope of the inventory reviews, including information such as the
                          number of contracts and the percentage of contracts reviewed for
                          each product and service code selected and the total universe of
                          contracts;

                      •   Require agencies to consistently report on the number of contractor
                          personnel and functions that were involved with the workforce issues
                          identified during their inventory reviews; and

                      •   Require agencies to include, as part of their inventory review reports,
                          the status of agency efforts to resolve findings identified in previous
                          reviews until they are resolved.


                      We requested comments on a draft of this report from DHS, DOT, HHS,
Agency Comments       GSA, NASA, and OMB. HHS and NASA responded that they did not have
and Our Evaluation    comments. DHS, DOT, and GSA provided us with technical comments,
                      which we incorporated as appropriate. OMB provided comments via e-
                      mail, stating that it generally concurs with our recommendations. More
                      specifically, OMB stated that it believes a service contract inventory is a
                      useful management tool for assisting an agency in better understanding
                      how contracted services are being used to support mission and
                      operations and where opportunities may exist for improvement. Moving
                      forward, OMB commented that the Office of Federal Procurement Policy



                      Page 19                            GAO-12-1007 Civilian Service Contract Inventories
(OFPP) intends to work with agencies to strengthen their use of this tool
by sharing lessons learned and best practices derived from the initial
inventories, such as the promising practices highlighted in the report.

OMB also commented on our first recommendation and asked that we
modify it to shift primary responsibility for monitoring inventory compliance
from OMB to the civilian agencies. OMB stated that OFPP is a policy-
making organization, not an enforcement agency, and greater progress
can be achieved if OFPP works collaboratively with agencies by
continually refining the guidance to make it a more useful management
tool and ensuring agencies are doing effective self-governance, such as
with the help of an accountable official that can liaison with OFPP to
ensure appropriate management attention is being given to this initiative.
In recognition that conducting and reviewing the service contract
inventory is an agency responsibility, and to ensure that civilian agencies
are held accountable for complying with statutory and OMB requirements,
we agreed to modify the recommendation.


We are sending copies of this report to the Director of the Office of
Management and Budget; Secretaries of the Department of Health and
Human Services, the Department of Homeland Security, and the
Department of Transportation; the Administrators of the General Services
Administration and the National Aeronautics and Space Administration;
and interested congressional committees. In addition, the report is
available at no charge on the GAO website at http://www.gao.gov.

If you have any questions about this report or need additional information,
please contact me at (202) 512-4841 or huttonj@gao.gov. Contact points
for our Office of Congressional Relations and Public Affairs may be found
on the last page of this report. Key contributors to this report are listed in
appendix IV.




John P. Hutton
Director
Acquisition and Sourcing Management




Page 20                             GAO-12-1007 Civilian Service Contract Inventories
List of Committees

The Honorable Joseph I. Lieberman
Chairman
The Honorable Susan M. Collins
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Richard J. Durbin
Chairman
The Honorable Jerry Moran
Ranking Member
Subcommittee on Financial Services and General Government
Committee on Appropriations
United States Senate

The Honorable Darrell E. Issa
Chairman
The Honorable Elijah Cummings
Ranking Member
Committee on Oversight and Government Reform
House of Representatives

The Honorable Jo Ann Emerson
Chairwoman
The Honorable José E. Serrano
Ranking Member
Subcommittee on Financial Services and General Government
Committee on Appropriations
House of Representatives




Page 21                        GAO-12-1007 Civilian Service Contract Inventories
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             Section 743 of the 2010 Consolidated Appropriations Act directed GAO to
             report on the second annual service contract inventory that civilian
             agencies were required to submit to the Office of Management and
             Budget (OMB) by December 31, 2011. To satisfy the mandate, we
             assessed civilian agencies’ efforts to (1) compile their fiscal year 2011
             inventories and (2) review and report on their fiscal year 2010 inventories.

             To assess civilian agencies’ efforts to compile their fiscal year 2011
             inventories, we reviewed the act and OMB guidance to determine what
             data elements were required to be included in the service contract
             inventories. In addition, we obtained and reviewed available civilian
             agency inventories to determine whether they contained data elements
             required by OMB guidance. We also reviewed the proposed Federal
             Acquisition Regulation (FAR) rule on service contract inventories and
             interviewed staff from OMB to determine the status of efforts to collect all
             required inventory data elements. In addition, we used OMB guidance
             and conducted a logic check for five selected agencies—the Department
             of Health and Human Services, the Department of Homeland Security,
             the Department of Transportation, the General Services Administration,
             and the National Aeronautics and Space Administration—to ensure that
             the obligations reported by these agencies were close to our own analysis
             of the Federal Procurement Data System—Next Generation (FPDS-NG)
             data. These agencies were selected because they represent
             approximately 42 percent of total fiscal year 2011 service contract
             obligations for civilian agencies. In addition, they are also among the
             agencies with the largest obligations for the special interest functions
             identified by OMB for heightened management consideration because
             they present an increased risk of losing control of mission and operations.

             During our logic check, we identified differences between obligations the
             agencies reported in their inventories and what we obtained by applying
             OMB guidance. To determine if these differences were more widespread,
             we expanded our logic check to all available agency inventories. To
             determine possible reasons for these differences, we pulled data from
             FPDS-NG by funding agency using eight different methodologies for fiscal
             year 2011—all obligations for service contract actions; obligations for
             service contract actions over $25,000; obligations for new awards;
             obligations for new awards over $25,000; all obligations for special
             interest product and service code contract actions; obligations for special
             interest product and service code contract actions over $25,000;
             obligations for new awards on special interest product and service code
             contract actions; and all obligations for new awards on special interest
             product and service code contract actions over $25,000. After our initial


             Page 22                             GAO-12-1007 Civilian Service Contract Inventories
Appendix I: Scope and Methodology




comparison, we determined that the difference between the obligations in
all categories and those above $25,000 was small. In addition, we
determined that only one agency had reported its inventory using the
special interest function methodology. Therefore, we reported only three
main methodologies—all obligations, new awards, and special interest
functions. While our prior work identified data reliability issues with FPDS-
NG, for the purposes of this report, we found FPDS-NG data to be
sufficiently reliable for determining how agencies compiled their
inventories. We also identified agencies with missing elements to
determine what data elements were missing from their inventories.

To assess the result of agencies’ efforts to review and report on their
fiscal year 2010 inventories, we reviewed civilian agencies’ reports on the
fiscal year 2010 inventory review submitted to OMB to determine the
number of contracts that were analyzed, the methodologies used, and the
workforce issues identified. While we reported the workforce issues
identified, we did not independently assess whether the functions the
civilian agencies identified were in fact inherently governmental or closely
associated with inherently governmental functions. In addition, for the five
selected agencies, we interviewed officials to identify the resources used
and methodologies they applied to conduct the reviews, as well as
challenges they encountered, lessons learned, and practices they
identified that can be applied to future reviews. We also met with agency
officials to determine the extent to which agencies have used their
reviews for decision making, including workforce planning and strategic
sourcing efforts, and to determine how agencies identified instances in
which contractors were performing inherently governmental functions or
functions closely associated with inherently governmental functions.

We conducted this performance audit between April 2012 and September
2012 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 23                             GAO-12-1007 Civilian Service Contract Inventories
Appendix II: Forty-Nine Agencies Required to
              Appendix II: Forty-Nine Agencies Required to
              Report on Service Contract Inventories



Report on Service Contract Inventories

              Agency for International Development
              Broadcasting Board of Governors
              Commodity Futures Trading Commission
              Consumer Product Safety Commission
              Court Services and Offender Supervision Agency for D.C.
              Defense Nuclear Facilities Safety Board
              Department of Agriculture
              Department of Commerce
              Department of Education
              Department of Energy
              Department of Health and Human Services
              Department of Homeland Security
              Department of Housing and Urban Development
              Department of Justice
              Department of Labor
              Department of State
              Department of the Interior
              Department of Transportation
              Department of the Treasury
              Department of Veterans Affairs
              Environmental Protection Agency
              Equal Employment Opportunity Commission
              Federal Communications Commission
              Federal Election Commission
              Federal Energy Regulatory Commission
              Federal Labor Relations Authority
              Federal Maritime Commission
              Federal Trade Commission
              General Services Administration
              International Trade Commission
              Merit Systems Protection Board
              National Aeronautics and Space Administration
              National Archives and Records Administration
              National Endowment for the Arts
              National Endowment for the Humanities
              National Labor Relations Board
              National Science Foundation
              National Transportation Safety Board
              Nuclear Regulatory Commission
              Office of Management and Budget
              Office of Personnel Management
              Office of Special Counsel
              Peace Corps



              Page 24                                   GAO-12-1007 Civilian Service Contract Inventories
Appendix II: Forty-Nine Agencies Required to
Report on Service Contract Inventories




Railroad Retirement Board
Securities and Exchange Commission
Selective Service System
Small Business Administration
Social Security Administration
U.S. Trade and Development Agency




Page 25                                   GAO-12-1007 Civilian Service Contract Inventories
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  John P. Hutton, (202) 512-4841 or huttonj@gao.gov
GAO Contact
                  Key contributors to this report were Cheryl Andrew, Assistant Director;
Staff             Richard Burkard; Danielle Greene; Laura Jezewski; Julia Kennon; Bryan
Acknowledgments   Miller; and Guisseli Reyes-Turnell.




                  Page 26                               GAO-12-1007 Civilian Service Contract Inventories
Related GAO Products
             Related GAO Products




             Defense Acquisitions: Further Actions Needed to Improve Accountability
             for DOD’s Inventory of Contracted Services. GAO-12-357. Washington,
             D.C.: April 6, 2012.

             Government Operations: OMB Service Contracts Inventory Guidance and
             Implementation. GAO-11-538R. Washington, D.C.: May 27, 2011.

             Defense Acquisitions: Further Action Needed to Better Implement
             Requirements for Conducting Inventory of Service Contract Activities.
             GAO-11-192. Washington, D.C.: January 14, 2011.




(121062)
             Page 27                          GAO-12-1007 Civilian Service Contract Inventories
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