oversight

Chief Acquisition Officers: Appointments Generally Conform to Legislative Requirements, but Agencies Need to Clearly Define Roles and Responsibilities

Published by the Government Accountability Office on 2012-07-26.

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

             United States Government Accountability Office

GAO          Report to the Committee on Homeland
             Security and Governmental Affairs,
             U.S. Senate


July 2012
             CHIEF ACQUISITION
             OFFICERS
             Appointments
             Generally Conform to
             Legislative
             Requirements, but
             Agencies Need to
             Clearly Define Roles
             and Responsibilities




GAO-12-792
                                               July 2012

                                               CHIEF ACQUISITION OFFICERS
                                               Appointments Generally Conform to Legislative
                                               Requirements, but Agencies Need to Clearly Define
                                               Roles and Responsibilities
Highlights of GAO-12-792, a report to the
Committee on Homeland Security and
Governmental Affairs, U.S. Senate




Why GAO Did This Study                         What GAO Found
Federal agencies spent more than half          Most agencies have appointed Chief Acquisition Officers (CAO) in accordance
a trillion dollars in fiscal year 2011         with two of the three key requirements in the Services Acquisition Reform Act of
through contracts to acquire goods and         2003 (SARA): that the CAOs be political appointees and have agency Senior
services in support of their missions,         Procurement Executives report directly to them. However, few CAOs have
but have historically faced significant        acquisition management as their primary duty; other areas of responsibility
acquisition management challenges              included financial, information, and human capital management.
preventing them from getting the best
return on their investments. The SARA          CAO Characteristics
legislation requires 16 federal civilian
agencies to appoint a Chief Acquisition
Officer to advise and assist agency
leadership to help ensure that the
agency’s mission is achieved through
the management of its acquisition
activities. GAO was asked to examine:
(1) how agencies have filled the CAO
position; (2) the extent to which CAOs
are involved in performing the
acquisition management functions set
forth in the SARA legislation and Office
of Management and Budget (OMB)
guidance; and (3) what challenges, if          Several CAOs noted that their additional responsibilities were not a detriment.
any, agency CAOs report in fulfilling          Rather, they believe that performing multiple roles helps them positively influence
their responsibilities. GAO                    acquisition management across their agencies. For example, the CAO at the
administered a questionnaire to 16             Department of Commerce stated that his additional responsibilities gave him the
CAOs, reviewed documentation on
                                               ability to integrate planning, budgeting, risk management, human resources, and
CAOs’ roles and responsibilities,
                                               acquisition to achieve the agency’s mission.
organizational placement, and
backgrounds, and interviewed a                 CAOs reported varying levels of involvement in the acquisition management
number of CAOs and other acquisition           functions for which they are responsible. Generally, CAOs see their role as
officials.                                     providing high-level oversight of the acquisition function as opposed to day-to-
                                               day management, which they typically delegated to the Senior Procurement
What GAO Recommends
                                               Executive or other officials as permitted by the legislation. Many CAOs said that
GAO recommends that the                        the amount of their involvement is related to several factors, such as the nature
Administrator of OMB’s Office of               of goods and services that the agency buys and whether the agency has a
Federal Procurement Policy work with           centralized or decentralized acquisition function.
the CAO Council to issue guidance
directing agencies to more clearly             Having clearly defined roles and responsibilities of stakeholders in the acquisition
define CAOs’ roles and responsibilities.       process is a key element of an effective acquisition function. Yet at many
The Administrator agreed with the              agencies, the statutory roles and responsibilities of the CAO position are not
recommendation.                                described in detail in acquisition regulations, policies, or other documentation.
                                               These agencies may be missing an opportunity to fully institutionalize the CAO
                                               position within their senior leadership structures.
                                               CAOs at the 16 agencies generally did not report facing significant challenges
                                               related to the CAO position, such as the level of influence they have in their
                                               agency’s acquisition process, amount of control over acquisition budget
View GAO-12-792. For more information,         resources, and access to agency leadership. Consistent with our prior work on
contact William T.Woods at (202) 512-4841 or
WoodsW@gao.gov.
                                               the acquisition workforce, however, most CAOs reported that not having enough
                                               staff to manage acquisitions was moderately to extremely challenging.
                                                                                        United States Government Accountability Office
Contents


Letter                                                                                         1
               Background                                                                      3
               Agencies Have Established CAOs as a Focal Point for Acquisition,
                 but Most Have Other Management Responsibilities and Short
                 Tenures                                                                      6
               CAO Involvement in Acquisition Management Functions Varies                    14
               CAOs Reported Few Significant Challenges and Generally Did Not
                 Identify Changes Needed to Improve Their Effectiveness                      21
               Conclusions                                                                   23
               Recommendation for Executive Action                                           24
               Agency Comments and Our Evaluation                                            24

Appendix I     Objectives, Scope, and Methodology                                            26



Appendix II    Key Responsibilities of CAOs                                                  29



Appendix III   Comments from the Department of Health and Human Services                     30



Appendix IV    GAO Contact and Staff Acknowledgments                                         32



Tables
               Table 1: CAO Agencies’ Contract Spending and Acquisition
                        Management Challenges                                                  5
               Table 2: Official Titles and Management Responsibilities of Chief
                        Acquisition Officers                                                   8
               Table 3: Summary of Observations on CAO Position in Agency
                        Acquisition Regulations and Policies                                 20


Figures
               Figure 1: CAO Characteristics                                                  7
               Figure 2: Organizational Placement of CAOs                                    11




               Page i                                       GAO-12-792 Chief Acquisition Officers
Figure 3: CAO Turnover and Proportion of Time CAO Position
         Filled by a Permanent Official (from SARA Enactment
         through April 2012)                                                              13
Figure 4: Level of CAO Involvement in the Eight Acquisition
         Functions Outlined in SARA Legislation and OMB
         Guidance                                                                         15
Figure 5: Delegation of Responsibilities Reported by CAOs across
         the Eight Acquisition Management Functions Outlined in
         SARA Legislation and OMB Guidance                                                17
Figure 6: Extent of Challenge Reported by CAOs in Fulfilling Their
         Acquisition Management Responsibilities                                          22


Abbreviations

CAO              Chief Acquisition Officer
CFO              Chief Financial Officer
CHCO             Chief Human Capital Officer
CIO              Chief Information Officer
DHS              Department of Homeland Security
EPA              Environmental Protection Agency
FAR              Federal Acquisition Regulation
GSA              General Services Administration
HHS              Department of Health and Human Services
HUD              Department of Housing and Urban Development
IG               Inspector General
IT               information technology
NASA             National Aeronautics and Space Administration
OFPP             Office of Federal Procurement Policy
OMB              Office of Management and Budget
SARA             Services Acquisition Reform Act of 2003
SPE              Senior Procurement Executive
VA               Department of Veterans Affairs




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Page ii                                              GAO-12-792 Chief Acquisition Officers
United States Government Accountability Office
Washington, DC 20548




                                   July 26, 2012

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

                                   In fiscal year 2011, federal agencies collectively spent more than half a
                                   trillion dollars through contracts to acquire goods and services in support
                                   of their missions. With the United States facing increasing fiscal
                                   pressures, there is a need to ensure that federal agencies make the most
                                   efficient and effective use of their resources. However, agencies have
                                   historically faced significant acquisition management challenges that have
                                   prevented them from getting the best return on their investments in goods
                                   and services. To address these challenges, agencies must establish a
                                   strong foundation for an effective, efficient and accountable acquisition
                                   process, which includes proper organizational alignment and committed
                                   agency leadership. To this end, the Services Acquisition Reform Act of
                                   2003 (SARA) 1 requires 16 federal civilian agencies to establish the
                                   position of a Chief Acquisition Officer (CAO) to advise and assist agency
                                   leadership to help ensure that the agency’s mission is achieved through
                                   the management of its acquisition activities.

                                   You asked that we review the implementation of the CAO position at
                                   federal agencies. In response, we examined: (1) how agencies have filled
                                   the CAO position; (2) the extent to which CAOs are involved in performing
                                   the acquisition management functions set forth in the SARA legislation
                                   and Office of Management and Budget (OMB) guidance, and (3) what
                                   challenges, if any, agency CAOs report in fulfilling their responsibilities.
                                   To address these objectives, we analyzed the SARA legislation and
                                   directives from OMB’s Office of Federal Procurement Policy (OFPP) to
                                   identify the key roles and responsibilities of the CAO position. We then




                                   1
                                       Pub. L. No. 108-136, § 1421, 117 Stat. 1663 (codified as amended at 41 U.S.C. § 1702).




                                   Page 1                                                GAO-12-792 Chief Acquisition Officers
administered a questionnaire by e-mail to the 16 civilian agencies 2 within
the scope of our review. 3 The questionnaire requested information on,
among other things, the CAOs’ organizational reporting relationships,
tenure, involvement in acquisition management functions within the
agency, and challenges experienced in fulfilling their CAO responsibilities.
We received responses from all 16 agencies, though not all agencies
provided responses to each question. We also collected and reviewed
agency organizational charts, acquisition regulations and guidance,
applicable policies and delegation orders, as well as biographical
information, to identify the organizational placement, roles and
responsibilities, and professional background of the CAO position within
the agency. Finally, we conducted follow-up interviews to discuss the
CAO’s roles and responsibilities with CAOs and acquisition officials at
seven agencies: Energy, the General Services Administration (GSA),
Commerce, Department of Health and Human Services (HHS), Interior,
Department of Homeland Security (DHS), and the National Aeronautics
and Space Administration (NASA). We selected a nongeneralizable
sample of agencies for follow-up interviews based upon the following
criteria: review of the questionnaire responses, the agency’s procurement
obligations in fiscal year 2010, and whether the agency’s Inspector
General had identified acquisition-related issues as a major management
challenge. Our review did not assess the effectiveness of individual CAOs
or individual agencies’ acquisition functions. A more complete description
of our objectives, scope, and methodology is provided in appendix I.

We conducted this performance audit from October 2011 to July 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


2
  We sent the questionnaire to the Departments of Agriculture, Commerce, Education,
Energy, Health and Human Services, Homeland Security, Housing and Urban
Development, the Interior, Labor, State, Transportation, the Treasury, Veterans Affairs,
the Environmental Protection Agency, the National Aeronautics and Space Administration,
and the General Services Administration (GSA).
3
  The SARA legislation exempts the Department of Defense (DOD) from the CAO
requirement. Legislation enacted prior to SARA required DOD to have an Under
Secretary of Defense (Acquisition, Technology & Logistics) who has responsibilities
similar to those of a CAO. Justice is not required to appoint a CAO under the SARA
legislation, but has designated the Assistant Attorney General for Administration as the
CAO.




Page 2                                               GAO-12-792 Chief Acquisition Officers
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             Chief Acquisition Officers provide a focal point for acquisition in agency
Background   operations. The SARA legislation requires that CAOs:

             •   be noncareer employees; 4
             •   have acquisition management as their primary duty; and
             •   have the agency’s Senior Procurement Executive (SPE) report
                 directly to them without intervening authority, or serve as both CAO
                 and SPE. 5
             The SARA legislation outlined seven acquisition management functions
             CAOs are expected to perform within their agencies. Subsequent to the
             enactment of SARA, governmentwide directives and guidance have
             assigned CAOs responsibility for additional functions, such as internal
             control reviews of the acquisition function under OMB Circular A-123 and
             ensuring the quality of federal procurement data. The key functions of the
             CAO we reviewed are listed below; additional information on these
             functions is also available in appendix II:

             •   monitoring and evaluating agency acquisition activities;
             •   increasing the use of full and open competition;
             •   increasing performance-based contracting;
             •   making acquisition decisions;
             •   managing agency acquisition policy;
             •   acquisition career management;
             •   acquisition resources planning; and
             •   conducting acquisition assessments under OMB Circular A-123.
             The SARA legislation also established a Chief Acquisition Officers
             Council that is chaired by OMB’s Deputy Director for Management, and


             4
               For purposes of this report, we refer to noncareer employees as political appointees. For
             additional information, see GAO, Personnel Practices: Conversions of Employees from
             Political to Career Positions May 2005-May 2009, GAO-10-688 (Washington, D.C.: June
             28, 2010).
             5
               The Senior Procurement Executive position was established in 1983 prior to the creation
             of the CAO position (see Pub. L. No. 98-191, § 7). The Senior Procurement Executive is
             typically a career employee who is responsible for management direction of an agency’s
             procurement system, including implementation of the agency’s unique procurement
             policies, regulations, and standards.




             Page 3                                               GAO-12-792 Chief Acquisition Officers
whose activities are led by the OFPP Administrator. 6 The council is the
principal interagency forum for monitoring and improving the federal
acquisition system. Its activities include developing recommendations for
the Director of OMB on acquisition policies and requirements; sharing
best practices; and helping to address the hiring, training, and
professional development needs of the acquisition workforce.

Our prior work has emphasized the need for strong, effective leadership
and the appropriate placement of the acquisition function within agencies
among many key factors needed in order to facilitate efficient, effective,
and accountable acquisition processes. Clear, strong, and ethical
executive leadership, including a CAO, is key to obtaining and
maintaining organizational support for executing the acquisition function. 7
Most of the agencies required to appoint a CAO spend a substantial
amount of funding each year through contracts to acquire goods and
services in support of their missions, as shown below in table 1. Yet,
acquisition management challenges persist among many of these
agencies. Among the 16 agencies, 11 had acquisition-related issues
identified as a major management challenge by their respective Inspector
General (IG) in its most recent report on agency management challenges.
Additionally, our high-risk list includes a number of areas related to
acquisition management. 8




6
    Pub. L. No. 108-136, § 1422, 117 Stat. 1663, 1668 (2003).
7
  GAO, Framework for Assessing the Acquisition Function at Federal Agencies,
GAO-05-218G (Washington, D.C.: Sept. 2005).
8
    GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).




Page 4                                                GAO-12-792 Chief Acquisition Officers
Table 1: CAO Agencies’ Contract Spending and Acquisition Management Challenges

                                                             Contract obligations as
                             Fiscal year 2011 funded percentage of agency fiscal year         Acquisition-related issues
                                 contract obligations      2011 discretionary budget identified as a major management
Agency                                    (in billions)                     authority            challenge by agency IG
Energy                                             $21.3                                               82.9%                                         X
HHS                                                $19.9                                               25.8%                                         X
Veterans Affairs                                   $17.8                                               31.5%                                         X
DHS                                                $14.8                                               35.1%                                         X
NASA                                               $14.7                                               79.7%                                         X
State                                               $9.2                                               35.2%                                         X
GSA                                                 $7.1                                    Not applicable                                           X
Treasury                                            $7.0                                               52.0%
Agriculture                                         $5.4                                               23.3%
Transportation                                      $4.9                                               28.9%                                         X
Commerce                                            $3.2                                               56.8%                                         X
Interior                                            $3.0                                               25.7%
Labor                                               $2.5                                               20.1%                                         X
Environmental Protection
Agency                                              $2.1                                               24.2%
Education                                           $1.9                                                 2.8%                                        X
Housing and Urban
Development                                         $1.8                                                 4.8%
                                      Source: GAO analysis of federal procurement data, OMB historical budget data, and Inspector General reports.

                                      Note: GSA primarily funds its operations through fee revenue generated by its activities, as opposed
                                      to the use of appropriated funds.


                                      Since the creation of the CAO position, other reviews have made
                                      recommendations related to its implementation at specific agencies:

                                      •     The Department of Labor IG has frequently reported on concerns that
                                            the agency has not been in compliance with the SARA requirement
                                            for the CAO to have acquisition management as the primary duty.
                                      •     A 2011 Department of Transportation IG report also found that the
                                            department’s acquisition organizational structure does not effectively
                                            support the department’s acquisition function, and noted that the CAO
                                            does not have acquisition management as the primary duty.




                                      Page 5                                                                       GAO-12-792 Chief Acquisition Officers
                           The agencies within the scope of our review generally have established
Agencies Have              CAOs in a way that satisfies two of three key aspects of the legislation.
Established CAOs as a      The CAOs in place at these agencies are generally political appointees
                           situated at top levels in their organization, and at most agencies, the
Focal Point for            Senior Procurement Executive reports directly to the CAO. However, very
Acquisition, but Most      few agency CAOs have acquisition management as their primary duty,
Have Other                 the third key requirement of the SARA legislation. Most of these CAOs
                           have other significant management responsibilities within their agencies,
Management                 such as serving as the Chief Financial Officer (CFO). Additionally, some
Responsibilities and       CAOs and acquisition officials said it was a challenge in determining how
                           to fill the position within their agency, because the SARA legislation did
Short Tenures              not provide an additional leadership slot specifically for the CAO position.
                           Tenure in the CAO position also has been relatively short, as the average
                           CAO tenure was about 2 years, and several agencies have had frequent
                           turnover in CAOs.


CAOs Generally Appointed   As shown below in figure 1, most agency CAOs are political appointees
in Accordance with         and have the Senior Procurement Executives report directly to them, but
Requirements, but Few      few have acquisition management as their primary duty.
Have Acquisition
Management as Their
Primary Duty




                           Page 6                                      GAO-12-792 Chief Acquisition Officers
Figure 1: CAO Characteristics




•    Twelve of the 16 agencies had a permanent CAO in place at the time
     we administered our questionnaire. 9 Three agencies (Education,
     Department of Veterans Affairs (VA) and Department of Housing and
     Urban Development (HUD)) had an acting CAO, and the position was
     vacant at Energy, which is currently relying on the Senior
     Procurement Executive as its lead acquisition official. 10 All 12
     permanent CAOs were political appointees, and 1 of the 3 acting
     CAOs was a political appointee.
•    At 13 agencies, the Senior Procurement Executive reports directly to
     the Chief Acquisition Officer without intervening authority. The Senior
     Procurement Executive does not report directly to the CAO at 2
     agencies—HHS and NASA. Officials at these agencies told us there is
     an informal reporting relationship between the two positions. HHS
     also noted that despite the indirect organizational relationship
     between the two positions, the CAO and Senior Procurement
     Executive communicate frequently on the department’s acquisition
     policies, priorities, and programs.
•    Only 3 of the CAOs in place during our review (DHS, GSA, and VA)
     reported that acquisition management was their primary duty, another
     requirement of the SARA legislation. When asked to estimate the
     amount of time spent on their CAO duties relative to their other



9
  Following the administration of our CAO questionnaire, 3 agencies reported changes in
the CAO position. The GSA CAO left the agency in April 2012. GSA appointed an acting
CAO in June 2012 who also serves as Senior Advisor to the Acting Administrator. The
Treasury CAO also left the agency in April 2012 and the position is held by an acting
official who is a political appointee. HUD, which had an acting CAO at the time we
administered our questionnaire, now has a permanent CAO who is a political appointee.
10
  In the past, Energy’s CAO has been a political appointee to whom the SPE directly
reported, and has had acquisition management as the primary duty.




Page 7                                              GAO-12-792 Chief Acquisition Officers
                                                  responsibilities, the average among the 14 agencies that provided a
                                                  response was about 27 percent. Furthermore, only 3 of the 12
                                                  permanent CAOs in place during our review had prior experience in
                                                  acquisition or procurement prior to serving as CAO. Although SARA
                                                  does not require the CAO to have a background in acquisition, this is
                                                  one of many factors that could affect the CAO’s success in the
                                                  position.
                                              •   As shown below in table 2, almost all of the CAOs in our review had
                                                  additional management responsibilities and few had an official title of
                                                  Chief Acquisition Officer. For example, at the Departments of State,
                                                  Agriculture, and Commerce, the Assistant Secretary for Administration
                                                  serves as the CAO. These officials’ additional areas of responsibility,
                                                  among other things, include financial management, information
                                                  management, equal employment opportunity, and emergency
                                                  preparedness.


Table 2: Official Titles and Management Responsibilities of Chief Acquisition Officers

                                                                     Number of       Chief Acquisition Officer also serves as the
                                                                additional positions                       Chief
                                                                held within agency                                      Chief
                                                                                                         Human
                  Official title of the Chief Acquisition        (excluding official Chief Financial     Capital     Information
Agency            Officer                                               title)           Officer         Officer        Officer
Agriculture       Assistant Secretary for Administration                 0
Commerce          Chief Financial Officer/Assistant Secretary            5                   X                 X
                  for Administration
DHS               Under Secretary for Management                         0
Education         Chief Financial Officer                                1                   X
Energy            Chief Acquisition Officer (vacant)                     0
EPA               Assistant Administrator                                4                                     X
GSA               Chief Acquisition Officer                              0
HHS               Assistant Secretary for Financial                      5                   X
                  Resources
HUD               Deputy Secretary                                       3
Interior          Assistant Secretary, Policy, Management                7                   X                 X
                  and Budget
Labor             Assistant Secretary for Administration and             2                                     X             X
                  Management
NASA              Chief Financial Officer                                2                   X
State             Assistant Secretary for Administration                 4
Transportation    Deputy Secretary                                       1




                                              Page 8                                             GAO-12-792 Chief Acquisition Officers
                                                                    Number of       Chief Acquisition Officer also serves as the
                                                               additional positions                       Chief
                                                               held within agency                                      Chief
                                                                                                        Human
                                                                (excluding official
           Official title of the Chief Acquisition                                  Chief Financial     Capital     Information
Agency     Officer                                                     title)           Officer         Officer        Officer
Treasury   Assistant Secretary for Management,                               2              X
           Chief Financial Officer and Chief
           Performance Officer
VA         Principal Executive Director, Office of                           0
           Acquisition, Logistics and Construction
                                    Source: GAO analysis of agency information


                                    Although acquisition management is supposed to be a CAO’s primary
                                    duty, several CAOs we met with told us that having responsibility for
                                    additional management functions was not a detriment and often helped
                                    them positively influence acquisition management across their agency:

                                    •     At half of the 16 agencies, the Chief Acquisition Officer also serves in
                                          at least one additional “Chief” officer position. Similar to the SARA
                                          legislation, the legislation that created the Chief Human Capital Officer
                                          (CHCO) and Chief Information Officer (CIO) positions required that
                                          those respective functions be the primary duty of each position. 11 We
                                          have raised concerns in prior work about those positions having
                                          additional significant responsibilities and whether an individual serving
                                          in these positions can deal effectively with an agency’s management
                                          challenges. 12 Although this could be a concern with respect to CAOs
                                          who do not have acquisition management as their primary duty, the
                                          Office of Federal Procurement Policy noted that an agency’s Senior
                                          Procurement Executive provides high-level attention to the
                                          management of the acquisition function.
                                    •     Some CAOs and acquisition officials also pointed out that the SARA
                                          legislation did not provide agencies an additional position specifically
                                          for the CAO, which created a challenge for agencies to determine how
                                          to fill the CAO position. For example, the NASA CAO noted in her



                                    11
                                      Chief Human Capital Officers Act of 2002, Pub .L. No. 107-296, § 1302, 116 Stat. 2287,
                                    2288; Information Technology Management Reform Act of 1996, Pub. L. No. 104-106, §
                                    5125, 110 Stat. 679, 684.
                                    12
                                       GAO, Human Capital: Observations on Agencies’ Implementation of the Chief Human
                                    Capital Officers Act, GAO-04-800T (Washington, D.C.: May 18, 2004); and Chief
                                    Information Officers: Ensuring Strong Leadership and an Effective Council,
                                    GAO/T-AIMD-98-22 (Washington, D.C.: Oct. 27, 1997).




                                    Page 9                                                      GAO-12-792 Chief Acquisition Officers
                          questionnaire response that the agency has a low allocation of
                          politically appointed positions. As a result, NASA gave the CAO duties
                          to the CFO. NASA’s CAO stated that because the agency spends
                          such a large amount of its budget through obligations on contracts,
                          her role as the CFO is closely connected with her additional role as
                          the CAO to effectively conduct acquisition management at NASA.
                          Furthermore, the NASA CAO thought that having these two functions
                          integrated was a positive aspect of her current position and helped
                          her be an effective CAO, as opposed to having acquisition operate in
                          a separate stovepipe.
                      •   The CAO at Commerce emphasized the positive aspects of the
                          agency’s organizational structure and approach to implementation of
                          the CAO position. At Commerce, one individual serves in a number of
                          roles that includes the CFO, CHCO, and Chief Performance Officer as
                          well as the CAO. The CAO noted that this structure gave him the
                          ability to integrate planning, budgeting, risk management, human
                          resources, as well as acquisition to achieve the agency’s mission. As
                          the individual who ties these functional areas together, he indicated
                          he has the authority to get other groups within Commerce to work
                          together. The Commerce CAO also stated that while he oversees the
                          department’s budget as the CFO, he uses his CAO role to look at
                          whether components have demonstrated a sound acquisition
                          management approach in evaluating their budget requests. He also
                          stated that if he were only the agency CAO he would not have as
                          much authority in other functional areas to effectively manage the
                          agency’s acquisition function.
                      •   Likewise, the CAO at DHS said that he has oversight of many
                          different management functions such as finance, budgeting, human
                          resources, as well as acquisition. While this arrangement may appear
                          to be in conflict with the statutory requirement that acquisition
                          management be the CAO’s primary duty, he stated that having a
                          larger area of responsibility gives him a fuller view of the entire
                          acquisition cycle from requirements development and contract funding
                          to service delivery. As a result, he reports that he spends a majority of
                          his time on acquisition management issues because integrating the
                          different management functions has a positive impact on the CAO’s
                          ability to effectively manage acquisitions across DHS.

Almost All CAOs Are   While the SARA legislation does not specify where CAOs should be
Positioned at Top     located within their agency’s organization, as shown below in figure 2, we
Management Levels     found that almost all of the 16 CAOs were positioned at their agency’s top
                      management levels, reporting to either to the agency head or to an official
                      one level removed from the agency head. The CAO at Energy reports to



                      Page 10                                      GAO-12-792 Chief Acquisition Officers
the Director of the Office of Management, who is more than one level
removed from the agency head.

Figure 2: Organizational Placement of CAOs




The location of CAOs at high levels within their agencies may be by virtue
of their official titles described above in table 2 rather than being
specifically related to the CAO position. Nevertheless, several CAOs and
acquisition officials we met with stressed the value of the CAO position in
having access to agency leadership and other peers in ensuring that
acquisition issues are being considered at top levels within the agency.

•   Fourteen CAOs reported that they had at least sufficient access to
    their agency head, and that the CAO position was appropriately
    located for ensuring proper authority over their agency’s acquisition
    activities.
•   Acquisition officials at the Department of Energy, where the CAO
    position has been vacant for several years, and whose questionnaire
    response noted that the CAO had neither sufficient nor insufficient
    access to the agency head, said that it would have been helpful to
    have a political appointee in the CAO role who could have high level
    interactions with agency leadership, better communicate acquisition
    related issues, and build effective working relationships with the CFO,
    CIO, and other senior agency officials.
•   Additionally, acquisition officials with the Department of the Interior
    noted that as a political appointee, the CAO can work closely with
    other assistant secretaries in the department as well as with peers at


Page 11                                      GAO-12-792 Chief Acquisition Officers
                                 other agencies and OMB. They added that with the CAO placed at the
                                 assistant secretary level, the position can be more focused on
                                 strategic decisions, and can make final decisions on how resources
                                 will be deployed to achieve goals.
                             •   Similarly, the HHS CAO said that by virtue of her position, she is able
                                 to interact as a peer with the leaders of the agency’s operating
                                 divisions and communicate the acquisition priorities of the agency and
                                 administration. She added that being CAO affords her a “seat at the
                                 table” to discuss acquisition issues when the agency is making
                                 mission decisions.

CAO Position Usually         Twelve of the agencies have had a CAO serving in a permanent capacity
Filled by Permanent          more than two-thirds of the time since enactment of SARA, as shown
Official, but Tenures Have   below in figure 3. Education and VA have had a CAO serving in a
                             permanent capacity less than 50 percent of the time. 13 The remaining
Been Short
                             time the CAO position has been vacant or held by an official in an acting
                             capacity.




                             13
                                While VA’s current CAO is a career official serving in an acting capacity, VA has sought
                             to establish an Assistant Secretary for Acquisition, Logistics, and Construction who would
                             serve as CAO in accordance with the SARA legislation requirements.




                             Page 12                                              GAO-12-792 Chief Acquisition Officers
Figure 3: CAO Turnover and Proportion of Time CAO Position Filled by a
Permanent Official (from SARA Enactment through April 2012)




•   Despite most agencies’ ability to fill the position with a permanent
    CAO, turnover in the CAO position varied among agencies, as
    evidenced by the number of acting and permanent CAOs in place
    since SARA’s enactment. Half of the agencies have had four or fewer
    CAOs in place, while other agencies have had higher turnover in the
    CAO position. For example, GSA and Treasury have each had nine
    CAOs in place since creation of the CAO requirement. The high
    turnover at GSA and Treasury equate to an average tenure for each
    CAO of about 10 months at GSA and about 11 months at Treasury
    since late 2003. In contrast, Commerce and HHS have had only two
    CAOs over the same timeframe, with an average CAO tenure at each
    agency of more than 3.5 years.



Page 13                                        GAO-12-792 Chief Acquisition Officers
                     •    Since enactment of SARA, the average tenure of permanent CAOs
                          has been 2.1 years. This is fairly consistent with a recent GAO review
                          that found an average tenure of about 2.6 years for CIOs at 30 federal
                          departments and agencies. 14
                     While short tenures in the CAO position may be expected given the
                     political nature of the position, this may work against an individual CAO’s
                     ability to effectively implement needed changes in the acquisition function
                     or new acquisition initiatives:

                     •    Our prior work has noted that it can take 5 to 7 years to fully
                          implement major change initiatives in large public and private sector
                          organizations and to transform cultures in a sustainable manner, yet
                          frequent turnover of political leadership in the federal government can
                          make it difficult to obtain sustained attention to make needed
                          changes. 15
                     •    Among the 76 permanent and acting CAOs that have been in place
                          since the enactment of SARA, only 3 served in the position for 5 years
                          or more.

                     CAOs reported they have differing levels of involvement in the
CAO Involvement in   management of their agency’s acquisition activities. For example, most
Acquisition          CAOs indicated they were extremely or very involved in managing
                     acquisition policy, but only somewhat or not at all involved in making
Management           acquisition decisions or conducting acquisition assessments. Generally,
Functions Varies     CAOs saw their role as providing high-level oversight of the acquisition
                     function as opposed to day-to-day management, for which they typically
                     relied on the Senior Procurement Executive and other senior procurement
                     officials. Many CAOs told us that the amount of their involvement is
                     related to several factors, such as the nature of goods and services that
                     the agency buys and the extent the agency has a centralized or
                     decentralized acquisition function. For example, in some agencies, CAOs
                     are less involved because agency units and bureaus operate more
                     autonomously with respect to acquisition management. Our review of


                     14
                        GAO, Federal Chief Information Officers: Opportunities Exist to Improve Role in
                     Information Technology Management, GAO-11-634 (Washington, D.C.: Sept. 15, 2011).
                     15
                       GAO, Major Management Challenges and Program Risks: A Governmentwide
                     Perspective, GAO-03-95 (Washington, D.C.: Jan. 2003); and Results-Oriented Cultures:
                     Implementation Steps to Assist Mergers and Organizational Transformations,
                     GAO-03-669 (Washington, D.C.: July 2, 2003).




                     Page 14                                           GAO-12-792 Chief Acquisition Officers
                                        acquisition regulations and policies found that the roles and
                                        responsibilities of the CAO position are not described in detail across all
                                        the 16 agencies within the scope of our review. Without clearly defined
                                        roles and responsibilities within each federal agency, it will be challenging
                                        for these agencies to more permanently institutionalize the CAO position
                                        within their organizational structure and realize the benefits from the
                                        added attention it brings to acquisition management.


CAO Involvement in SARA                 The SARA legislation broadly outlined acquisition management functions
Acquisition Management                  for CAOs and left it up to each agency how to implement them. Overall,
Functions Varied with                   CAOs reported varying levels of involvement in the various acquisition
                                        management functions we reviewed, as shown below in figure 4:
Most CAOs Focused on
High-Level Acquisition
Oversight and Policy
Management

Figure 4: Level of CAO Involvement in the Eight Acquisition Functions Outlined in SARA Legislation and OMB Guidance




                                        •   CAOs reported being most involved in managing the direction of
                                            acquisition policy and least involved in two activities—making
                                            acquisition decisions and conducting assessments of the acquisition
                                            function under OMB Circular A-123.
                                        •   Only three CAOs (Agriculture, Labor, and DHS) reported being
                                            extremely or very involved in all eight acquisition management
                                            functions.




                                        Page 15                                        GAO-12-792 Chief Acquisition Officers
•   In contrast, officials at four agencies (Education, Energy, HUD, and
    State) who were either serving as the acting CAO, recently appointed
    as the new permanent CAO, or serving as the senior procurement
    official while the CAO position was vacant, reported being somewhat
    or not at all involved in seven or more of the acquisition management
    functions.

Many CAOs see their role as providing high-level acquisition oversight
rather than the day-to-day acquisition management that is more typically
provided by other career procurement officials such as the Senior
Procurement Executive and heads of contracting activities. As shown
below in figure 5, a majority of CAOs reported that they delegate day-to-
day responsibility for all eight CAO acquisition management functions to
the Senior Procurement Executive and/or other senior procurement
officials such as heads of contracting activities and competition
advocates. The SARA legislation does not preclude CAOs from
delegating these functions, and it is not surprising that there is a high
degree of delegation given that CAOs have other significant management
responsibilities and few had extensive prior experience in acquisition
management.




Page 16                                    GAO-12-792 Chief Acquisition Officers
Figure 5: Delegation of Responsibilities Reported by CAOs across the Eight Acquisition Management Functions Outlined in
SARA Legislation and OMB Guidance




                                        Several CAOs we met with stated that they delegated acquisition
                                        management functions to others to ensure that these duties are
                                        performed by highly experienced procurement officials. Additionally, they
                                        could focus on other acquisition issues such as program management
                                        and rely on the agencies’ acquisition professionals to manage the
                                        agency’s contract award process and acquisition workforce.

                                        •   For example, the DHS CAO reported delegating seven of the eight
                                            CAO acquisition management functions to the Senior Procurement
                                            Executive and others, and said that he must take a larger view of the
                                            acquisition function that includes program management while the
                                            Senior Procurement Executive is more focused on the contract award
                                            process and management of contracting officers and contracting
                                            specialists.

                                        CAOs’ delegation of their responsibilities may also be expected given the
                                        roles of other agency officials in acquisition management.

                                        •   The Senior Procurement Executive position had been in place at
                                            federal agencies for many years before the CAO position was
                                            established. This position is typically filled by a career employee who
                                            is responsible for the management direction of the agency’s




                                        Page 17                                         GAO-12-792 Chief Acquisition Officers
                                  procurement system, including implementation of agency unique
                                  procurement policies, regulations, and standards. 16
                            •     In addition, while increasing the use of full and open competition is
                                  one of the CAO responsibilities outlined in SARA, each executive
                                  agency is also required to designate a competition advocate who is
                                  responsible for promoting full and open competition, among other
                                  things. 17
                            •     Similarly, CAOs are responsible for acquisition career management,
                                  but the Office of Federal Procurement Policy also requires civilian
                                  executive agencies to designate an acquisition career manager who is
                                  responsible for, among other things, managing the development and
                                  identification of the acquisition workforce and providing input
                                  regarding short term and long term human capital strategic planning
                                  for the acquisition workforce. 18


CAO Involvement in          CAOs we spoke with stated there is no “one-size fits all” solution for how
Acquisition Management      best to structure the CAO position and integrate the acquisition
May Vary Due to Agency      management responsibilities outlined by SARA. Many CAOs emphasized
                            that the level of acquisition management oversight they provide is based
Characteristics and Other   upon several factors, which include the nature of the goods and services
Attributes                  that the agency buys and the amount of decentralization in the agency’s
                            acquisition function.

                            •     For example, the CAO at HHS said that she is very involved in
                                  acquisition policy issues but the oversight of day-to-day acquisition
                                  management issues is handled by other officials because much of
                                  what HHS buys through contracts is done to support their operating
                                  divisions rather than acquisitions of major systems.
                            •     The CAOs at both HHS and Interior reported that their agencies have
                                  a decentralized acquisition management structure where heads of
                                  operating divisions and bureaus execute most acquisition authority
                                  within their two agencies. HHS also stated that although the CAO
                                  does not approve acquisition decisions, acquisition management is
                                  achieved through the CAO’s roles in financial management,



                            16
                                 41 U.S.C. § 1702(c).
                            17
                                 41 U.S.C. § 1705 and Federal Acquisition Regulation §§ 6.501and 6.502.
                            18
                             Office of Federal Procurement Policy, Developing and Managing the Acquisition
                            Workforce (Washington, D.C.: Apr. 15, 2005).




                            Page 18                                              GAO-12-792 Chief Acquisition Officers
                                performance measurement, and acquisition and grants policy and
                                accountability.
                          In comparison, several CAOs at other agencies play a greater role in the
                          acquisition process. These agencies also tended to have major
                          acquisition programs and projects.

                          •     The CAO at DHS reported having approval authority for individual
                                acquisitions and since assuming the position in 2010 has revised the
                                acquisition oversight structure. The CAO stated that these changes in
                                the oversight structure at DHS are intended to decrease acquisition
                                program risk and provide better insight into budget, schedule and
                                performance information for approximately 135 major acquisition
                                programs for which the CAO serves as the Acquisition Decision
                                Authority.
                          •     CAOs at other agencies who said they are more involved in
                                acquisition management also reported having some form of decision
                                authority over certain acquisitions. For example, the CAO at
                                Commerce serves as co-chair of the agency’s Investment Reviews,
                                which provide oversight, review, and advice to the Secretary and
                                Deputy Secretary on both information technology (IT) and non-IT
                                investments that meet certain criteria. This advice includes
                                recommendations for approval or disapproval of funding for new
                                systems and investments, or major modifications to existing systems
                                or investments.
                          •     Similarly, at the Department of Labor, a Procurement Review Board
                                recommends to the CAO approval or disapproval of various
                                acquisition decisions that meet certain thresholds or conditions and
                                serves as a senior-level clearinghouse to review proposed
                                noncompetitive acquisitions.

CAO Roles and             At many agencies, the CAO position was not clearly defined in
Responsibilities Not      documents that would form the basis for more permanently
Clearly Defined at Many   institutionalizing the CAO within their organizational leadership structure.
                          Clearly defined roles and responsibilities for each stakeholder in the
Agencies                  acquisition process is a key element of an effective acquisition function,
                          as outlined in GAO’s framework for assessing the acquisition function
                          within federal agencies. 19 We found that the amount of detail on a CAO’s
                          agency-specific authorities and responsibilities varies greatly based on


                          19
                               GAO-05-218G.




                          Page 19                                      GAO-12-792 Chief Acquisition Officers
the agency’s Federal Acquisition Regulation (FAR) supplement and other
policy documentation we collected. As shown in table 3, at some
agencies, the CAO position is described in detail while for others the only
information about the CAO’s authorities and acquisition management
responsibilities under SARA is a passing reference to the legislation that
established the position.

Table 3: Summary of Observations on CAO Position in Agency Acquisition
Regulations and Policies

                            Defined in agency               Some or all statutory Neither defined nor
                            FAR supplements                  responsibilities are        statutory
                             or acquisition                    listed in policy   responsibilities listed
 Agency                          manual                        documentation       in policy documents
 Agriculture                                                                                        X
 Commerce                                X
 DHS                                                                        X
 Education                               X                                  X
 Energy                                                                                             X
 EPA                                                                        X
 GSA                                                                        X
 HHS                                                                                                X
 HUD                                                                                                X
 Interior                                X
 Labor                                   X                                  X
 NASA                                                                                               X
 State                                                                                              X
 Transportation                          X
 Treasury                                                                                           X
 VA                                      X                                  X
 Totals                                  6                                  6                        7
Source: GAO analysis of agency acquisition regulations and other policy documentation.



•     For example, the CAO position is defined or designated in FAR
      supplements or acquisition manuals by just 6 of the agencies.
•     Detail on the CAO’s specific acquisition management responsibilities
      was listed in other policy documentation for only 6 of the agencies.
•     At 7 agencies, the CAO position is not defined in their FAR
      Supplement or acquisition manual, nor are the acquisition
      management responsibilities listed in other policy documentation.




Page 20                                                                      GAO-12-792 Chief Acquisition Officers
                             Additionally, we found that agencies varied in how their acquisition policy
                             guidance delegates authority for procurement matters with respect to the
                             CAO. At half of the agencies, authority for procurement matters is
                             delegated from the agency head through the CAO position to other
                             agency officials. In contrast, at the other 8 agencies, this authority is
                             delegated from the agency head directly to other agency officials such as
                             the Senior Procurement Executive and/or bureau heads, bypassing the
                             CAO. This may be due to agencies neglecting to update their acquisition
                             policies and regulations since creation of the CAO position or to reflect a
                             more recent organizational change.

                             •   For example, the GSA Organizational Manual still refers to an Office
                                 of the CAO that reports to the Administrator, which, according to the
                                 CAO in place during our review, did not reflect the organizational
                                 reporting structure in the agency.

                             This lack of fully defined CAO roles and responsibilities, and at some
                             agencies, outdated policies, may be an obstacle to ensuring that the CAO
                             position is more permanently institutionalized within the agencies’
                             acquisition management and senior leadership structures.


                             CAOs at the 16 agencies generally did not report facing significant
CAOs Reported Few            challenges related to the CAO position, such as the level of influence they
Significant Challenges       have in their agency’s acquisition process, amount of control over
                             acquisition budget resources, and access to agency leadership. However,
and Generally Did Not        most CAOs reported that not having enough staff to manage acquisitions
Identify Changes             was moderately to extremely challenging. As GAO and others have
Needed to Improve            reported in recent years, the capacity and capability of the federal
                             government’s acquisition workforce to oversee and manage contracts has
Their Effectiveness          been a challenge. Most CAOs did not believe any changes were needed
                             to improve their effectiveness and also felt that they had the appropriate
                             degree of authority to effectively fulfill their acquisition management
                             functions.


Aside from the Sufficiency   We asked agency CAOs to indicate how much six management and
of Acquisition Staff, CAOs   resource issues that we identified challenged them in carrying out their
Reported Few Significant     responsibilities. As shown below in figure 6, CAOs generally answered
                             that most areas we identified were not challenges for them.
Challenges




                             Page 21                                     GAO-12-792 Chief Acquisition Officers
Figure 6: Extent of Challenge Reported by CAOs in Fulfilling Their Acquisition Management Responsibilities




                                         Note: Responses in some challenge areas do not sum to 16 because “Not Applicable” or “Don’t
                                         Know” responses are not included.
                                         •   No CAOs reported being very or extremely challenged by their
                                             employment status (career official versus political appointee) in
                                             fulfilling their acquisition management functions or in having sufficient
                                             access to agency leadership.
                                         •   The CAOs at DHS, HHS, and State reported five of these areas as
                                             being not at all challenging. In contrast, the CAO at GSA and the
                                             career acquisition official at Energy reported being moderately to
                                             extremely challenged in most of the areas.

                                         Despite the lack of challenges reported by CAOs related to most areas,
                                         11 CAOs reported the sufficiency of staff to manage acquisitions as a
                                         moderate to extreme challenge. These responses echo concerns from
                                         our prior work that the capacity and the capability of the federal
                                         government’s acquisition workforce to oversee and manage contracts
                                         have not kept pace with increased spending for increasingly complex
                                         purchases. Additionally, 6 of the 16 agencies’ IGs have identified the
                                         acquisition workforce as a source of serious management challenge in
                                         their most recent management challenge reports issued during 2011.
                                         However, none of the CAOs at these 6 agencies reported the sufficiency
                                         of acquisition staff as extremely or very challenging.


Majority of CAOs Said No                 When asked if any other changes were needed to improve their
Additional Changes                       effectiveness, 10 out of 16 CAOs reported that no changes were needed.
Needed to Improve Their                  Six CAOs did provide some suggestions. For example, Energy’s
                                         response to our questionnaire stated that the CAO position needs
Effectiveness


                                         Page 22                                                  GAO-12-792 Chief Acquisition Officers
              improved resource support and full engagement with the agency’s senior
              leadership team. At EPA, the CAO responded that it would be helpful if
              there were a better understanding of the contracting process by agency
              management. The GSA CAO, who left the position during our review,
              believed that returning the CAO position to a direct report to the GSA
              Administrator would improve the position’s effectiveness at her agency.
              Following the completion of our CAO questionnaire, GSA appointed an
              Acting CAO who reports to the Acting GSA Administrator. CAOs at
              Transportation, Interior, and HUD reported that more budgetary resources
              and acquisition workforce staff are needed to improve their effectiveness.
              Despite these responses and other issues raised in our report, almost all
              the CAOs believed that they had the appropriate authority to fulfill their
              acquisition management responsibilities.


              More than 8 years after the enactment of the SARA legislation, there is
Conclusions   wide variation in how agencies have implemented the CAO position. On
              one hand, agencies have generally filled the CAO position with political
              appointees who sit at relatively high levels within their agencies in a
              position to ensure that acquisition is receiving attention from agency
              leadership. Many CAOs and acquisition officials we met with cited this as
              a key benefit of the CAO position. On the other hand, there are
              inconsistencies in the implementation of the law across agencies, with
              very few CAOs having acquisition management as their primary
              responsibility, although many CAOs cited the benefits to integrating
              acquisition management with their additional responsibilities. The CAO
              position is only one factor of many in an efficient, effective, and
              accountable acquisition function in agencies. Having an experienced
              Senior Procurement Executive is another. There is no one-size-fits-all
              approach to how to organize an effective acquisition function, and a
              CAO’s role should be suited to the nature and volume of an agency’s
              acquisition activities. Yet, agencies should ensure that they are
              maximizing their chances for success by having CAOs that are in a
              position to influence agency leadership and serve as a strong advocate
              for acquisition management, which includes having clearly defined roles
              and responsibilities for the CAO. Not all agencies have these, however,
              and may be missing an opportunity to ensure that the CAO position is
              fully institutionalized within agencies’ acquisition management and senior
              leadership structures. Given CAOs’ short tenures, a lack of defined roles
              and responsibilities could hinder a CAO’s ability to maximize time in the
              position and serve as an effective advocate for acquisition management.




              Page 23                                     GAO-12-792 Chief Acquisition Officers
                     To strengthen the functions of CAOs in acquisition management, we
Recommendation for   recommend that the Administrator of the Office of Federal Procurement
Executive Action     Policy, working with the CAO Council, issue guidance to agencies
                     directing them to ensure that CAO roles and responsibilities are more
                     clearly defined in accordance with law and regulations, tailored to suit the
                     agency’s acquisition activities, and documented as appropriate.


                     We sent copies of a draft of this report to OMB and the 16 agencies within
Agency Comments      the scope of our review. OMB’s Office of Federal Procurement Policy
and Our Evaluation   provided comments via e-mail, in which it concurred with our
                     recommendation. The office also suggested that the report further
                     highlight the role of the Senior Procurement Executive in providing day-to-
                     day leadership of an agency’s acquisition function. We considered this
                     suggestion and made changes to the report as appropriate.

                     We received communications from each of the 16 agencies, with 15
                     providing no substantive comments. HHS provided additional information
                     on the roles and responsibilities of the CAO, which we incorporated into
                     the draft. HHS’s written comments are reproduced in appendix III.


                     We are sending copies of this report to other interested congressional
                     committees, the Director of the Office of Management and Budget, and
                     the Secretaries of Agriculture, Commerce, Education, Energy, Health and
                     Human Services, Homeland Security, Housing and Urban Development,
                     the Interior, Labor, State, Transportation, the Treasury, and Veterans
                     Affairs; the administrators of the Environmental Protection Agency and
                     the National Aeronautics and Space Administration, and the Acting
                     Administrator of General Services. In addition, this report will be available
                     at no charge on the GAO website at http://www.gao.gov.




                     Page 24                                      GAO-12-792 Chief Acquisition Officers
If you or your staff have any questions concerning this report, please
contact me at (202) 512-4841 or by e-mail at woodsw@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs are on
the last page of this report. Key contributors to this report are listed in
appendix IV.




William T. Woods
Director, Acquisition and Sourcing Management




Page 25                                     GAO-12-792 Chief Acquisition Officers
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to assess: (1) how agencies have filled the Chief
              Acquisition Officer (CAO) position; (2) the extent to which CAOs are
              involved in performing the acquisition management functions set forth in
              the Services Acquisition Reform Act of 2003 (SARA) legislation and
              Office of Management and Budget (OMB) guidance, and (3) what
              challenges, if any, agency CAOs report in fulfilling their responsibilities for
              acquisition management. Our review did not assess the effectiveness of
              individual CAOs or individual agencies’ acquisition functions.

              To address our objectives, we reviewed the SARA legislation and
              directives from OMB’s Office of Federal Procurement Policy to identify the
              key roles and responsibilities of the CAO position. We also reviewed
              previous GAO work on assessing the acquisition function and the
              implementation of other chief officer positions in the federal government.
              To learn more about CAOs’ characteristics, as well as CAOs’ involvement
              in acquisition management functions and challenges faced in fulfilling
              their responsibilities, we developed and administered a questionnaire by
              e-mail in an attached Microsoft Word form to the 16 civilian agencies 1
              within the scope of our review. 2 We pretested the questionnaire to ensure
              that the questions were relevant, clearly stated, and easy to understand.
              We also solicited comments on the draft questionnaire from members of
              the Chief Acquisition Officers Council. The questionnaire requested
              information on, among other things, the CAOs’ reporting relationships,
              involvement in acquisition management functions within the agency, the


              1
                We sent the questionnaire to the Departments of Agriculture, Commerce, Education,
              Energy, Health and Human Services, Homeland Security, Housing and Urban
              Development, the Interior, Labor, State, Transportation, the Treasury, Veterans Affairs,
              the Environmental Protection Agency, the National Aeronautics and Space Administration,
              and the General Services Administration (GSA).
              2
                SARA required executive agencies described in certain sections of the Chief Financial
              Officers Act of 1990, Pub. L. No. 101-576 (see, 31 U.S.C. §§ 901(b)(1) and 901(b)(2)(C)
              (CFO Act)), to appoint a CAO. When SARA was enacted in 2003, the U.S. Code listed
              GSA under 31 U.S.C. § 901(b)(2)(C). In 2004, the Department of Homeland Security
              Financial Accountability Act, Pub. L. No. 108-330, § 3, amended the CFO Act to make a
              number of changes, including adding the Department of Homeland Security to the list of
              agencies required to have a CFO and changing GSA’s position on the CFO list. For the
              purposes of this report, we included GSA in our review, as it was listed in section
              901(b)(2)(C) of title 31 of the U.S. Code when SARA was enacted. The SARA legislation
              exempts the Department of Defense (DOD) from the CAO requirement. Legislation
              enacted prior to SARA required DOD to have an Under Secretary of Defense (Acquisition,
              Technology & Logistics) who has responsibilities similar to those of a CAO. Justice is not
              required to appoint a CAO under the SARA legislation, but has designated the Assistant
              Attorney General for Administration as the CAO.




              Page 26                                              GAO-12-792 Chief Acquisition Officers
Appendix I: Objectives, Scope, and
Methodology




extent to which the CAO had delegated their acquisition management
responsibilities to other officials, and challenges identified by GAO that
CAOs may have experienced in fulfilling their responsibilities. We sent the
questionnaire to agencies in November 2011. All questionnaires were
returned by March 2012. We received responses from all 16 agencies,
though not all agencies provided responses to each question.

To provide additional information on CAOs’ characteristics, involvement in
acquisition management functions and challenges faced, as well as to
corroborate information provided in the questionnaire responses, we
collected and reviewed agencies’ organizational charts that showed the
CAO’s position relative to the head of the agency and other senior
officials; letters of delegation or other documents that formally designate
the appointment of the CAO, the CAO’s resume or curriculum vitae
describing their qualifications and experience related to the CAO position;
applicable policies, guidance, position descriptions or functional
statements for both the CAO and Senior Procurement Executive
positions; applicable policies or orders that delegate the CAO’s
responsibilities to other acquisition officials; agency acquisition function
assessments performed under OMB Circular A-123; Acquisition Human
Capital Plans or similar documents; agency strategic plans and
performance reports; agency-specific acquisition regulations and
acquisition manuals; and descriptions of acquisition metrics or
performance measures the agency tracks. We also asked each agency to
supply the name, time in office, and circumstances (whether they were in
an acting or permanent position and whether they were a career
employee or political appointee) of each of the individuals who had
served as agency CAO and Senior Procurement Executive since
enactment of the SARA legislation in November 2003.

To complement information gathered through the questionnaire and
agency documentation, we conducted follow-up interviews to discuss the
CAO’s roles and responsibilities with CAOs and acquisition officials at
seven agencies: Commerce, Department of Homeland Security (DHS),
Department of Health and Human Services (HHS), Interior, Energy, GSA,
and the National Aeronautics and Space Administration (NASA). We used
a nongeneralizable sample of agencies based upon the following criteria:
review of the questionnaire responses, the amount of procurement
spending as a portion of the agency’s fiscal year 2010 budget, and
whether the agency’s Inspector General had identified acquisition-related
issues as a major management challenge. We also met with officials from
OMB’s Office of Federal Procurement Policy to discuss the roles and
responsibilities of agency CAOs.


Page 27                                     GAO-12-792 Chief Acquisition Officers
Appendix I: Objectives, Scope, and
Methodology




We conducted this performance audit from October 2011 to July 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 28                                   GAO-12-792 Chief Acquisition Officers
Appendix II: Key Responsibilities of CAOs
                                             Appendix II: Key Responsibilities of CAOs




CAO responsibility           Source                             Description
Monitoring and evaluating SARA legislation                      Monitoring the performance of acquisition activities and acquisition
agency acquisition                                              programs of the executive agency, evaluating the performance of those
activities                                                      programs on the basis of applicable performance measurements, and
                                                                advising the head of the executive agency regarding the appropriate
                                                                business strategy to achieve the mission of the executive agency
Increasing the use of full   SARA legislation                   Increasing the use of full and open competition in the acquisition of
and open competition                                            property and services by the executive agency by establishing policies,
                                                                procedures, and practices that ensure that the executive agency receives a
                                                                sufficient number of sealed bids or competitive proposals from responsible
                                                                sources to fulfill the Government’s requirements at the lowest cost or best
                                                                value considering the nature of the property or service procured.
Increasing performance-      SARA legislation                   Increasing appropriate use of performance-based contracting and
based contracting                                               performance specifications
Making acquisition           SARA legislation                   Making acquisition decisions consistent with all applicable laws and
decisions                                                       establishing clear lines of authority, accountability, and responsibility for
                                                                acquisition decision-making within the executive agency
Managing agency              SARA legislation                   Managing the direction of acquisition policy for the executive agency,
acquisition policy                                              including implementation of the unique acquisition policies, regulations,
                                                                and standards of the executive agency
Acquisition career           SARA legislation                   Developing and maintaining an acquisition career management program in
management                                                      the executive agency to ensure that there is an adequate professional
                                                                workforce
Acquisition resources        SARA legislation                   As part of the strategic planning and performance evaluation process,
planning                                                        assessing the requirements established for agency personnel regarding
                                                                knowledge and skill in acquisition resources management and the
                                                                adequacy of such requirements for facilitating the achievement of the
                                                                performance goals established for acquisition management; developing
                                                                strategies and specific plans for hiring, training and professional
                                                                development to rectify any deficiency in meeting such requirements; and
                                                                reporting to the head of the executive agency on the progress made in
                                                                improving acquisition management capability.
Conducting acquisition       OMB Memorandum for Chief Conducting entity-level internal control reviews of the acquisition function
assessments under OMB        Acquisition Officers, May 21, under OMB Circular A-123
A-123                        2008, Conducting Acquisition
                             Assessments under OMB
                             Circular A-123, Guidelines
                             for Assessing the Acquisition
                             Function
                                             Source: GAO analysis of SARA legislation and OMB memorandum.




                                             Page 29                                                        GAO-12-792 Chief Acquisition Officers
Appendix III: Comments from the
             Appendix III: Comments from the Department
             of Health and Human Services



Department of Health and Human Services




             Page 30                                      GAO-12-792 Chief Acquisition Officers
Appendix III: Comments from the Department
of Health and Human Services




Page 31                                      GAO-12-792 Chief Acquisition Officers
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  William T. Woods, (202) 512-4841 or woodsw@gao.gov
GAO Contact
                  In addition to the contact named above, John Oppenheim (Assistant
Staff             Director); Matthew Drerup; Kristine Hassinger; Lauren Heft; Jean
Acknowledgments   McSween; Roxanna Sun; and Robert Swierczek made key contributions
                  to this report.




(121013)
                  Page 32                                GAO-12-792 Chief Acquisition Officers
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