Depot Maintenance: Actions Needed to Provide More Consistent
Funding Allocation Data to Congress (30-NOV-06, GAO-07-126).
Under 10 U.S.C. 2466, the military departments and defense
agencies may use no more than 50 percent of annual depot
maintenance funding for work performed by private-sector
contractors. The Department of Defense (DOD) must submit a report
to Congress annually on the allocation of depot maintenance
funding between the public and private sectors for the preceding
fiscal year and projected distribution for the current and
ensuing fiscal years for each of the armed forces and defense
agencies. As required by Section 2466, GAO reviewed the report
submitted in April 2006 and is, with this report, submitting its
view to Congress on whether (1) the military departments and
defense agencies complied with the 50-50 requirement for fiscal
2005 and (2) the projections for fiscal years 2006 and 2007
represent reasonable estimates. GAO obtained data used to develop
the April 2006 report, conducted site visits, and reviewed
supporting documentation.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-126
ACCNO: A63769
TITLE: Depot Maintenance: Actions Needed to Provide More
Consistent Funding Allocation Data to Congress
DATE: 11/30/2006
SUBJECT: Allocation (Government accounting)
Costing errors
Data integrity
Defense audits
Defense cost control
Defense procurement
Department of Defense contractors
Financial management systems
Internal controls
Maintenance costs
Military appropriations
Projections
Reporting requirements
Defense budgets
Cost estimates
DOD Enterprise Transition Plan
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GAO-07-126
* [1]Results in Brief
* [2]Background
* [3]DOD's Compliance with the 50-50 Requirement for Fiscal Year
* [4]DOD Reported Compliance with the 50-50 Requirement in Fiscal
* [5]DOD's 50-50 Report Included Both Expenditures and Obligation
* [6]Depot Maintenance Allocations Involving Some Interservice an
* [7]Other Identified Errors
* [8]DOD Took Actions to Improve 50-50 Reporting, but Deficiencie
* [9]Fiscal Year 2006 and 2007 Projections Are Not Reasonable Due
* [10]Conclusions
* [11]Recommendations for Executive Action
* [12]Agency Comments and Our Evaluation
* [13]Appendix I: Scope and Methodology
* [14]Appendix II: GAO Adjustments to Army Fiscal Year 2005 Report
* [15]Appendix III: Comments from the Department of Defense
* [16]Appendix IV: GAO Contacts and Staff Acknowledgments
* [17]GAO Contact
* [18]Acknowledgments
* [19]Related GAO Products
* [20]Order by Mail or Phone
Report to Congressional Committees
United States Government Accountability Office
GAO
November 2006
DEPOT MAINTENANCE
Actions Needed to Provide More Consistent Funding Allocation Data to
Congress
GAO-07-126
Contents
Letter 1
Results in Brief 3
Background 5
DOD's Compliance with the 50-50 Requirement for Fiscal Year 2005 Could Not
Be Validated 7
Fiscal Year 2006 and 2007 Projections Are Not Reasonable Due to Data
Inaccuracies 14
Conclusions 15
Recommendations for Executive Action 16
Agency Comments and Our Evaluation 16
Appendix I Scope and Methodology 18
Appendix II GAO Adjustments to Army Fiscal Year 2005 Reported Data 20
Appendix III Comments from the Department of Defense 21
Appendix IV GAO Contacts and Staff Acknowledgments 23
Related GAO Products 24
Tables
Table 1: DOD's Reported Depot Maintenance Funding Allocations for Fiscal
Year 2005 8
Table 2: DOD's Projected Allocations of Depot Maintenance Funds for Fiscal
Years (FY) 2006 and 2007 14
Table 3: Adjustments to Army Fiscal Year 2005 Reported Data 20
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separately.
United States Government Accountability Office
Washington, DC 20548
November 30, 2006
The Honorable John Warner Chairman The Honorable Carl Levin Ranking
Minority Member Committee on Armed Services United States Senate
The Honorable Duncan L. Hunter Chairman The Honorable Ike Skelton Ranking
Minority Member Committee on Armed Services House of Representatives
Each year the Department of Defense (DOD) spends billions of dollars for
depot maintenance of its ships, aircraft, tanks, and other weapons
systems.^1 DOD reported total depot maintenance funding of more than $26
billion for fiscal year 2005. This maintenance is accomplished by both
federal government workers in the public sector and contractor personnel
in the private sector. Under 10 U.S.C. S 2466(a), not more than 50 percent
of funds made available in a fiscal year to a military department or
defense agency for depot-level maintenance and repair may be used to
contract for the performance by nonfederal government personnel of such
workload for the military departments and defense agencies.^2 Section
2466(b) states that the Secretary of Defense may waive the 50 percent
limitation if he determines the waiver is necessary for national security
and submits to Congress a notice of the waiver and the reasons for the
waiver. Section 2466(d)(1) directs the Secretary of Defense to submit an
annual report to Congress identifying, for each of the armed forces and
defense agencies, the percentage of the funds referred to in Section
2466(a) that was expended during the preceding fiscal year, and are
projected to be expended during the current fiscal year and the ensuing
fiscal year, for performance of depot-level maintenance and repair
workloads by the public and private sectors. In its most recent annual
report, dated April 6, 2006, DOD reported that depot maintenance
allocations by the Departments of the Army, Navy,^3 and Air Force were
below the 50 percent threshold in fiscal year 2005, and all the
departments except for the Air Force projected that they will remain below
the threshold for fiscal years 2006 and 2007. According to DOD's report,
the Air Force projected that it would exceed the 50 percent limit in
fiscal year 2007.
^1 Depot maintenance is the highest level of maintenance within DOD and
generally refers to major maintenance and repair actions such as the
overhauling, upgrading, or rebuilding of parts, assemblies, or
subassemblies.
^2 This limitation is sometimes referred to as the "50-50" requirement,
although the limitation applies only to the allocation of funds for work
that may be performed by nonfederal government personnel.
Section 2466(d)(2) also requires us to submit to Congress our views on
whether DOD complied with Section 2466(a) during the preceding fiscal year
and whether the expenditure projections for the current and ensuing fiscal
years are reasonable. This is the ninth year that we have evaluated and
reported on DOD's annual 50-50 report to Congress.^4 Specifically, our
objectives were to determine whether (1) the military departments complied
with the 50-50 requirement for fiscal year 2005 and (2) the projections
for fiscal years 2006 and 2007 represent reasonable estimates.
To accomplish these objectives, we reviewed guidance for reporting 50-50
workload funding data and analyzed the military services' procedures and
internal controls for collecting data and ensuring the accuracy and
completeness of data included in the report. To determine whether the
military departments complied with the 50-50 requirement, we obtained
service data used to develop DOD's April 2006 report, conducted site
visits at reporting commands and depots, interviewed officials involved in
the 50-50 process, and reviewed documentation supporting reported funding
data. Our work covered all four military services, but we placed greater
emphasis on reviewing Army data because that service was close to the 50
percent threshold for fiscal year 2005. We reviewed a total of $2.7
billion of reported depot maintenance funding. We based our sample on
previously identified areas of concern, varying program amounts, and
selected locations for our site visits. Because we selected a
nonprobability sample of data for our review, our results cannot be
projected. To determine the reasonableness of fiscal year 2006 and 2007
projections, we discussed with service officials how they developed their
projections and whether historical funding information and known increases
in funding were included in their projections. As discussed below, we have
found that reported depot maintenance funding allocation data are not
reliable because of weaknesses in DOD's financial systems^5 and 50-50 data
gathering and reporting processes. For the past several years, we have
reported that DOD's report on the use of these funds cannot be relied upon
as an accurate reflection of the distribution of these funds. We conducted
our review from March 2006 to September 2006 in accordance with generally
accepted government auditing standards. See appendix I for a more detailed
discussion of our scope and methodology.
^3 The Marine Corps is part of the Department of the Navy.
^4 A list of related GAO products is provided at the end of this report.
Results in Brief
Although DOD reported to Congress that it complied with the 50-50
requirement for fiscal year 2005, we could not validate compliance due to
weaknesses in DOD's financial management systems and the processes used to
collect and report 50-50 data. On the basis of our evaluation of selected
50-50 data, DOD's April 2006 report provides an approximation of the depot
maintenance funding allocation between the public and private sectors for
fiscal year 2005. However, we identified errors in the reported data
which, if adjusted, would increase the Army's private-sector funding
allocation percentage from 49.4 percent to 50 percent. During our current
review, we determined that 50-50 funding allocation data were not being
consistently reported because some maintenance depots were reporting
expenditures rather than following Office of the Secretary of Defense
(OSD) guidance on reporting obligations. Combining obligations and
expenditures produces an inaccurate accounting of 50-50 funding
allocations, including accounting for workload that is carried over from
one fiscal year to the next. For example, an Army depot official estimated
that almost $1.5 million was expended in fiscal year 2006 on a fiscal year
2005 contract obligation. The official stated that this obligation would
not be reported in fiscal year 2005 because it was not yet expended, and
it would not be reported in fiscal year 2006 because it was expended on a
fiscal year 2005 obligation. Until reporting organizations consistently
identify and report depot maintenance funding obligations, rather than a
combination of expenditures and obligations, inaccurate allocation of
depot maintenance funding between the public and private sectors will
continue to be reported. We also found that amounts associated with
interservice depot maintenance work may not accurately reflect the actual
allocation of private- and public-sector funds because visibility over the
allocation of these funds is limited. For example, we found instances
where a military service awarded public depot maintenance work to another
military service, which then contracted out a portion of that workload to
the private sector. The military service awarding the work inaccurately
reported this as public workload because it had not inquired whether all
the awarded work was performed at the public depot. OSD guidance requires
that the military departments establish measures to ensure correct
accounting of interservice workloads, but the services have not
established sufficient measures for complying with this guidance. Until
the military services accurately account for and report their distribution
of depot maintenance workload performed under interservice agreements, the
50-50 data reported by DOD will continue to be inaccurate. We also found
several other errors that resulted in inaccuracies in reported 50-50 data
for the Navy and Army. In prior years' reports on DOD's compliance with
the 50-50 requirement, we have discussed deficiencies that have limited
data accuracy and recommended specific corrective actions. While we found
that DOD has taken some additional actions to improve the quality of
reported data for fiscal year 2005, it has not fully addressed the
persistent deficiencies that have limited 50-50 data accuracy.
^5 DOD has had long-standing weaknesses in its financial management that
affect its ability to produce auditable financial information as well as
provide accurate and timely information for management and Congress to use
in making informed decisions. We have previously reported on these
problems and have identified DOD financial management as one of the
federal government's high-risk programs. See GAO, High-Risk Series: An
Update, [21]GAO-05-207 (Washington, D.C.: January 2005).
Reported projections do not represent reasonable estimates of public- and
private-sector depot maintenance funding allocations for fiscal years 2006
and 2007 due to data inaccuracies. In the April 2006 report, the Army and
Navy projected that they would remain below the 50-50 threshold in fiscal
years 2006 and 2007; while the Air Force projected that it would be below
the threshold in fiscal year 2006 but would exceed the threshold in fiscal
year 2007. However, data errors similar to those we identified for fiscal
year 2005 could affect these projections. For example, some errors in
DOD's fiscal year 2005 data are carried into the projected years. If the
adjustments we made to the Army's fiscal year 2005 data--increasing the
private-sector percentage by about 0.6 percentage points--are carried
forward, it could move the Army's projection to within 2 percent of the 50
percent limitation for fiscal year 2007. Under OSD guidance, the 2 percent
threshold triggers certain planning requirements to avoid breaching the 50
percent limitation. In addition, we found $1.6 million in errors in the
Army's 2006 projections, and the projected numbers do not include
supplemental funds, which can change the allocation percentages. These
errors and omissions affect the reasonableness and accuracy of the
reported projections. To avoid breaching the 50 percent threshold in
future years, the Air Force is implementing its plan to ensure compliance
with the 50-50 requirement through fiscal year 2010. The plan involves
moving some maintenance workload, including the F-100 engine, from the
private sector to the public sector.
To improve the consistency and accuracy of depot maintenance funding
allocation data submitted to Congress, we are recommending that the
components report obligations rather than expenditures, and establish
measures to properly account for the allocation of interservice workloads.
In commenting on the draft of this report, DOD concurred with our
recommendations and cited actions it planned to take to implement them.
Background
In addition to the 50-50 requirement in 10 U.S.C. S 2466, the following
provisions directly affect the reporting of workload funding allocations
to the public and private sectors:
o Section 2460(a) of Title 10 defines "depot-level maintenance and
repair" as material maintenance or repair requiring the overhaul,
upgrading, or rebuilding of parts, assemblies, or subassemblies
and the testing and reclamation of equipment as necessary,
regardless of the source of funds for the maintenance or repair,
or the location at which the maintenance or repair is performed.
This term also includes: (1) all aspects of software maintenance
classified by DOD as of July 1, 1995 as depot-level maintenance
and repair; and (2) interim contractor support or contractor
logistics support (or any similar contractor support) to the
extent that such support is for the performance of services
described in the preceding sentence. Section 2460(b)(1) excludes
from the definition of depot maintenance the nuclear refueling of
an aircraft carrier, and the procurement of major modifications or
upgrades of weapon systems that are designed to improve program
performance, although a major upgrade program covered by this
exception could continue to be performed by private- or
public-sector entities. Section 2460(b)(2) also excludes from the
definition of depot-level maintenance the procurement of parts for
safety modifications, although the term does include the
installation of parts for safety modifications.
o Depot maintenance funding involving certain public-private
partnerships is exempt from the 50 percent limitation. Section
2474(f) of Title 10 provides that amounts expended for the
performance of depot-level maintenance and repair by nonfederal
government personnel at Centers of Industrial and Technical
Excellence^6 under any contract entered into during fiscal years
2003 through 2009 shall not be counted when applying the 50
percent limitation in Section 2466(a) if the personnel are
provided by entities outside DOD pursuant to a public-private
partnership. In its annual 50-50 report to Congress, DOD
identifies this funding as a separate category called "exempt."
o Section 2466(b) allows the Secretary of Defense to waive the 50
percent limitation if he determines the waiver is necessary for
national security, and he submits the notification of waiver
together with the reasons for the waiver to Congress. Waivers were
previously submitted for the Air Force for fiscal years 2000 and
2001.
OSD issues guidance to the military departments for reporting
public-private workload funding allocations. The guidance's
definition of "depot level maintenance and repair" is consistent
with the definition of "depot-level maintenance and repair" in 10
U.S.C. S 2460. The military services have also issued internal
instructions to manage the data collection and reporting process,
tailored to their individual organizations and operating
environments.
DOD�s Compliance with the 50-50 Requirement for Fiscal Year 2005
Could Not Be Validated
Although DOD reported that the military departments complied with
the 50-50 requirement for fiscal year 2005, we could not validate
compliance because of systemic weaknesses in DOD's financial
management systems^7 and persistent deficiencies in the processes
used to collect and report 50-50 data. DOD's report provides an
approximation of the depot maintenance funding allocation between
the public and private sectors but contains some inaccuracies. Our
current review showed that 50-50 funding data were not being
consistently reported because some maintenance depots were
reporting expenditures rather than obligations as directed by OSD
guidance. We also found that amounts associated with interservice
depot maintenance work and certain contract agreements between
depots and private contractors may not accurately reflect the
distribution reported for private- and public-sector funds because
visibility over the allocation of these funds is limited. In
addition, we found several other errors that resulted in
inaccuracies in reported 50-50 data for the Navy and Army. DOD
took some actions this year to improve 50-50 reporting. However,
our work over the last several years has identified a number of
persistent deficiencies, such as inadequate management attention
and review, which have affected the quality of reported 50-50
data. While DOD took actions to improve 50-50 reporting this year,
DOD has not implemented recommendations we made last year to
address these deficiencies.
DOD Reported Compliance with the 50-50 Requirement in Fiscal Year
2005, but Reported Data Contained Inaccuracie
In DOD's April 2006 report to Congress on funding allocations for
depot maintenance, all three military departments reported that
their private-sector depot maintenance allocation was below the 50
percent limitation for fiscal year 2005. However, we found that
the reported data contained inaccuracies. Table 1 shows the
reported allocation between the public and private sectors and the
exempted workload funding.
Table 1: DOD's Reported Depot Maintenance Funding Allocations for
Fiscal Year 2005
Dollars in millions
Category Army Navy Air Force Total
Private 2,861 4,709 4,592 12,162
(49.4%) (43.2%) (47.3%) (46.1%)
Public 2,908 5,936 5,106 13,950
(50.2%) (54.5%) (52.6%) (52.9%)
Exempt 28 245 8 281
(0.5%) (2.3%) (0.1%) (1.0%)
Total 5,796 10,890 9,706 26,393
(100%) (100%) (100%) (100%)
Sources: GAO analysis of DOD data.
Notes: Based on data and analysis of DOD's April 6, 2006, reported
50-50 data. The numbers in the table may not add due to rounding.
The Department of the Navy includes the Marine Corps.
On the basis of our evaluation of selected 50-50 data, DOD's April
2006 report provides an approximation of depot maintenance funding
allocations between the public and private sectors for fiscal year
2005. However, we identified errors in reported workload funding
data. The net effects of correcting the data inaccuracies we
identified would increase the Army's private-sector funding
allocation from 49.4 percent to 50 percent. Identified errors in
the Army's data resulted in a total decrease in public-sector
funding of $5.9 million and a total increase in private-sector
funding of $68.1 million. Appendix II provides additional
information on these adjustments. We could not quantify the errors
that we identified for the Air Force regarding direct sales
agreements. We continue to identify areas that continue to be
excluded from the Navy's 50-50 reporting. While we found an error
in the Marine Corps data, correcting this inaccuracy would not
result in changes to the Department of the Navy's funding
allocation percentages. We did not conduct a review of all
reported 50-50 data; therefore, there may be additional errors,
omissions, and inconsistencies that were not identified.
DOD�s 50-50 Report Included Both Expenditures and Obligations
Depot maintenance funding data for fiscal year 2005 were not being
consistently reported because some maintenance depots were
reporting expenditures, rather than obligations as directed by OSD
guidance. The reporting of expenditures instead of obligations by
some depots presents an inaccurate picture of depot maintenance
allocations since the amounts may differ. For the most part, the
allocation percentages for public funds represent obligation
amounts obtained from the military department's financial
accounting systems. However, in reporting the amount of depot
maintenance funds allocated to the private sector, some reporting
organizations used expenditures rather than obligations as
required by OSD guidance.^8 For example, three depots we visited
reported their subcontracted depot-level maintenance work as
expenditures rather than obligations. Reasons given by depot
officials for reporting expenditures rather than obligations
include the following: (1) the workload against obligated funds
may not have been fully performed during the fiscal year, and
therefore they believed reporting expenditures was a better
reflection of the actual workload; (2) they did not know that
obligations were to be reported instead of expenditures; and (3)
many work orders can be associated with a multiyear contract, so
they believed that reporting expenditures would be a better
representation of the costs associated with multiyear contracts
for the fiscal year in question.
Accurately reporting carryover work is a problem when the
services' data contain both expenditures and obligations.
Carryover is work that a depot may "carry over" from one fiscal
year to another to ensure a smooth flow of work during the
transition between fiscal years. This means that while the funds
are obligated in one fiscal year, a certain portion may not be
expended until the next fiscal year. When expenditures rather than
obligations are reported, we found that the carryover work that is
performed in the following year may not be included in either
year's 50-50 report. For example, an Army depot official provided
us with an estimate of almost $1.5 million that was expended in
fiscal year 2006 on a fiscal year 2005 contract obligation. The
official stated that this portion of the obligation was not
reported in fiscal year 2005 because it was not yet expended, and
it would not be reported in fiscal year 2006 because it was
expended on a fiscal year 2005 obligation. As a result, the
private portion of the service's depot maintenance funds was
underreported in the year of the obligation, while the public
portion was overreported. Until depot maintenance funding
obligations are consistently reported, rather than a combination
of expenditures and obligations, inaccurate reporting of the
allocation of depot maintenance funding between the public and
private sectors will continue.
Depot Maintenance Allocations Involving Some Interservice and
Direct Sales Agreements May Not Be Properly Reported
Because DOD has limited visibility over the allocation of private-
and public-sector funds in some interservice agreements and direct
sales agreements, inaccurate reporting of the depot maintenance
workload allocation may result. Interservice workload agreements
refer to work that is performed by one component for another. OSD
guidance requires that the military departments establish measures
to ensure correct accounting of interservice workloads; however
the allocation of these funds may not always be accurately
reported. We found instances where a military service awarded
public depot maintenance work to another military service, which
then contracted out a portion of that workload to the private
sector. The military service awarding the work, as principal owner
of the funds, inaccurately reported this as public workload
because it had not inquired whether all the awarded work was
performed at the public depot. For example, we identified
approximately $172,000 of private-sector work that may have been
inaccurately reported as public-sector work because the principal
owner of the funds did not follow up to determine whether all of
the work was performed by the public depot. While we were unable
to fully evaluate the extent of inaccurate reporting associated
with interservice agreements, until the military departments
establish sufficient measures to accurately account for and report
their distribution of depot maintenance workload, the 50-50 data
reported by DOD may continue to be inaccurate.
The limited visibility over direct sales agreements is another
reason why the depot maintenance workload allocation may be
inaccurately reported to Congress. A direct sales agreement
involves private vendors contracting back to a DOD maintenance
facility for labor to be performed by DOD employees. OSD guidance
requires that sales of articles and services by DOD maintenance
depots to entities outside of DOD, when work is accomplished by
DOD employees, shall be reported as public-sector work. However,
we found that the reporting of the distribution of private- and
public-sector workload for direct sales agreements may not be
accurate. With a direct sales agreement, there is no requirement
for the private vendor to identify and break out the contract
costs, such as materials and other factors of production, and
allocate them to expenses performed by the private vendor or the
public depot. We found the use of direct sales agreements by the
Air Force may have resulted in an overstatement of private-sector
funds, with a corresponding understatement of public-sector funds.
In addition, we found similar instances in the Army where work
performed by the public sector under a direct sales agreement with
a private vendor may have been misreported as being performed by
the private sector. Although we were unable to fully evaluate the
extent to which costs associated with these types of contract
agreements were misreported, until private vendors break out
direct sales agreement costs by the private and public sectors,
DOD's reporting of 50-50 funding allocation may remain inaccurate.
Other Identified Errors
We identified several other errors that resulted in inaccurate
reported 50-50 data for the Navy and Army. As we reported in
previous years,^9 we identified two areas that continue to be
excluded from the Navy's 50-50 reporting. First, the Navy did not
report any depot maintenance work on aircraft carriers performed
while nuclear refueling. Navy officials cited the exclusion of
nuclear refueling in 10 U.S.C. S 2460(b)(1) and guidance from the
General Counsel's office in the Department of the Navy as reasons
for not including $115 million in depot maintenance work performed
on aircraft carriers while nuclear refueling. However, we continue
to believe that depot repairs not directly associated with the
task of nuclear refueling should be reported. Second, the Navy, as
in prior years, continues to inconsistently report
ship-inactivation activities related to the servicing and
preservation of systems and equipment before ships are placed in
storage or in an inactive status. The Navy did not report $14.4
million of private-sector allocations for inactivation work on
nonnuclear ships, even though it reported inactivation activities
on nuclear ships. The Navy contends that the work for nuclear ship
inactivation is complex while the work for nonnuclear ships is
not. We continue to maintain that all such depot-level work should
be reported, since the statute and implementing guidance do not
make a distinction based on complexity. In addition, our review of
the Marine Corps data found that it underreported the
private-sector total and overreported the public-sector total by
about $1.5 million. This amount was for depot-level maintenance
that was performed in a public depot by contractor personnel,
which was misreported as public sector rather than private sector.
We also identified several data inaccuracies in the Army's 50-50
data. For example, one Army depot failed to include approximately
$31 million of private contract work it had outsourced for depot
maintenance in its 50-50 report. An Army official said that they
had not known that this type of contract work should be included
in 50-50 reporting, but they now plan to include it in future
submissions. Our review also determined that several Army
omissions, totaling approximately $53 million, were due to
misinterpretation of the guidance regarding modifications and
remanufacturing. The OSD guidance provides information about what
to include and not to include in reporting depot maintenance with
regard to upgrades, modifications, and remanufacturing. An Army
official acknowledged that there has been confusion over what to
report for 50-50 depot maintenance and stated the Army is in the
draft stages of updating the Army's Depot Maintenance Workload
Distribution Reporting Procedures. In addition, the Army's 50-50
data contained errors totaling approximately $4 million due to
changes in program costs. Finally, our review of the Army's data
found miscellaneous errors, including one instance of double
counting and the transposition of numbers in some entries.
DOD Took Actions to Improve 50-50 Reporting, but Deficiencies
Affecting Data Accuracy Have Persisted
During our review we noted actions taken by OSD and the military
services that, while not fully implemented, provided some
improvement in the 50-50 reporting process. For example, OSD, in
its 50-50 guidance, added a new requirement that the military
services include variance analyses in their submissions of 50-50
data. The services performed variance analyses; however, these
were at a very high level and provided little detail on how the
fiscal year 2005 allocations differed from the prior year's data.
OSD guidance also included a new requirement that the services
maintain records and reports for 50-50 data for at least 2 years,
although we did find two instances where reporting locations could
not provide backup documentation for their 50-50 data. In
addition, as in previous years, OSD instructed the services to use
a third-party reviewer, such as a service audit agency, to
validate their data prior to submission. However, due to time
constraints, each service audit agency performed only a limited
review of the service's data. For example, the Air Force directed
its audit service to perform a limited review that focused on two
issues. Additionally, each service headquarters continued to
provide some form of training for its 50-50 reporting activities,
although no service required attendance by all individuals
involved in 50-50 data gathering and reporting. Guidance issued by
OSD emphasized, but did not require, training for individuals
involved in the 50-50 process. In one instance, an official who
was responsible for querying the 50-50 information from the
service's data systems was unaware that any training was ever
offered for 50-50 reporting.
Our work over the last several years has identified a number of
persistent deficiencies, such as inadequate management attention
and review, which have affected the quality of reported 50-50
data. DOD has not implemented recommendations we made last year to
address these deficiencies. In prior years' reports, we have
identified problems in 50-50 data accuracy attributable to
deficiencies in management attention, controls, and oversight;
documentation of procedures and retention of records; independent
validation of data; training for staff involved in the 50-50
process; and guidance. DOD has taken steps over the years to
improve 50-50 reporting in response to our recommendations, but we
have found that some deficiencies have persisted, including
inadequate management attention and review, limited review and
validation of data by independent third parties, and inadequate
staff training. In our November 2005 report, we concluded that the
recurring nature of deficiencies in 50-50 reporting indicates a
management control weakness that DOD should disclose in its annual
performance and accountability report to Congress.^10 By doing so,
DOD would increase the level of management attention and help
focus improvement efforts so that the data provided to Congress
are accurate and complete. DOD partially concurred with this
recommendation, stating that systemic changes to the 50-50
reporting process had already been made in response to previous
recommendations. DOD did not disclose 50-50 reporting as a
management control weakness in its most recent performance and
accountability report. An OSD official responsible for developing
the annual 50-50 report to Congress noted that completion of the
department's Enterprise Transition Plan^11 would result in more
accurate 50-50 reporting.
As we have previously reported, DOD's April 2006 report satisfies
the annual mandate as required by 10 U.S.C. S 2466(d). In our
November 2005 report, we stated that DOD could enhance the
usefulness of its report for congressional oversight by providing
additional information. For example, we recommended that DOD add
information such as variance analyses that identify significant
changes from the prior year's report and the reasons for these
variances, longer term trend analyses, an explanation of
methodologies used to estimate workload allocation projections for
the current and ensuing fiscal years, and plans to ensure
continued compliance with the 50-50 requirement, including
decisions on new weapon systems maintenance workload sourcing that
could be made to support remaining within the 50 percent
threshold. DOD partially concurred with this recommendation and
stated that producing the types of information we suggested would
require a massive undertaking and may be of limited value. We
disagreed and, on the basis of DOD's response, added a matter for
congressional consideration suggesting that Congress require the
Secretary of Defense to enhance the department's annual 50-50
report as stated in our recommendations. In the April 2006 report,
DOD did not make changes consistent with our recommendations, nor
has Congress acted.
Fiscal Year 2006 and 2007 Projections Are Not Reasonable Due to
Data Inaccuracies
DOD's reported projections for fiscal years 2006 through 2007 do
not represent reasonable estimates of public- and private-sector
depot maintenance funding allocations, in part because some errors
in DOD's fiscal year 2005 data are carried into the projected
years. As shown in table 2, the Army and the Navy projected that
their private-sector depot maintenance allocations will remain
below the 50 percent limitation for fiscal years 2006 and 2007.
The Air Force projected that it will remain below the limitation
for fiscal year 2006, but will exceed the limitation for fiscal
year 2007.
^6 Section 2474(a) states that the Secretary concerned (or the Secretary
of Defense in the case of a defense agency) shall designate depot-level
activities of the military departments and defense agencies (other than
facilities approved for closure or major realignment under the Defense
Base Closure and Realignment Act of 1990) as Centers of Industrial and
Technical Excellence in their recognized core competencies. The Secretary
of Defense was also directed to establish a policy to encourage the
secretary of each military department and the head of each defense agency
to reengineer industrial processes and adopt best business practices at
the Centers of Industrial and Technical Excellence in connection with
their core competency requirements so as to serve as recognized leaders in
their core competencies.
^7 For a recent discussion of weaknesses in DOD financial management, see
GAO, Department of Defense: Sustained Leadership Is Critical to Effective
Financial and Business Management Transformation, [22]GAO-06-1006T
(Washington, D.C.: Aug. 3, 2006).
^8 Although 10 U.S.C. S 2466(d) specifies that the Secretary of Defense
report the percentage of funds referred to in S 2466(a) that were expended
in the preceding fiscal year and projected to be expended in the current
and ensuing fiscal years, DOD's past and current 50-50 reports are
generally based on obligation data. A DOD official explained that
obligation data are considered to be more appropriate because of the
statutory requirement to report funds made available in a given fiscal
year and because expenditure data may not be completely recognized in the
accounting records for a year or more following the funds' obligation.
^9 For the two most recent reports, see GAO, Depot Maintenance: Persistent
Deficiencies Limit Accuracy and Usefulness of DOD's Funding Allocation
Data Reported to Congress, [23]GAO-06-88 (Washington, D.C.: Nov. 18,
2005), and Depot Maintenance: DOD Needs Plan to Ensure Compliance with
Public- and Private-Sector Funding Allocation, [24]GAO-04-871 (Washington,
D.C.: Sept. 29, 2004).
^10 For a discussion of this issue, see GAO, Depot Maintenance: Persistent
Deficiencies Limit Accuracy and Usefulness of DOD's Funding Allocation
Data Reported to Congress, [25]GAO-06-88 (Washington, D.C.: Nov. 18,
2005).
^11 In September 2005, DOD issued the Enterprise Transition Plan as part
of its program to modernize business systems.
Table 2: DOD's Projected Allocations of Depot Maintenance Funds for Fiscal
Years (FY) 2006 and 2007
Private sector Public sector Exempt
FY 2006 FY 2007 FY 2006 FY 2007 FY 2006 FY 2007
Army 40.3% 47.5% 59.4% 52.2% 0.3% 0.4%
Navy 45.1% 41.2% 53.1% 58.8% 1.8% 0.0%
Air Force 48.4% 50.2% 51.6% 49.6% 0.1% 0.2%
Source: DOD.
Notes: Based on data from DOD's April 6, 2006, reported 50-50 data. The
Department of the Navy includes the Marine Corps.
Errors similar to those we identified in fiscal year 2005 reported data
could affect these projections, as the Air Force is moving closer to the
threshold for private-sector funding in fiscal year 2006 (48.4 percent)
and beyond the threshold in fiscal year 2007 (50.2 percent). If the
adjustments we made to the Army's fiscal year 2005 data--increasing the
private-sector percentage by about 0.6 percentage points--are carried
forward into fiscal year 2007 projections, it could cause the Army to come
within 2 percent of the 50 percent limitation on contracting for
depot-level maintenance and repair. When spending projections reflect data
within 2 percent of the 50 percent limitation in a fiscal year, OSD
guidance directs the components to submit a plan that identifies actions
to be taken to ensure continued compliance. This plan shall include
identification of decisions on candidate maintenance workload sourcing
that could be made to support remaining within compliance with the 50
percent limitation. In addition, we found an error of approximately $1.6
million in the Army's fiscal year 2006 projections, which further limits
the accuracy of reported projections. Furthermore, DOD's projected fiscal
year 2006 and fiscal year 2007 allocations are based on the President's
budget numbers and often did not include supplemental funds, which can
change the percentage allocations. However, in the case of some Air Force
depot projections, supplemental funds are included in the projections if
the amounts are already known. These limitations affect the reasonableness
of the data reported as projections of future funding allocations.
While the Army and Navy project compliance with the 50-50 requirement
through fiscal year 2007, the Air Force's fiscal year 2006 projections are
within 2 percent of the 50 percent limitation and its fiscal year 2007
projections exceed the 50 percent limitation by 0.2 percent. To avoid
breaching the 50 percent threshold, the Air Force is implementing a plan
to ensure compliance in fiscal years 2007 through 2010. Under this plan,
the Air Force is identifying and evaluating candidate weapon system
programs for shifting maintenance workload from the private sector to the
public sector. The Air Force has committed resources and approved shifting
some maintenance associated with the F-100 engine beginning in fiscal year
2006. The Air Force plan shows that a total workload of $68 million
associated with the F-100 engine could be shifted to the public sector,
enabling the Air Force to achieve compliance with the 50-50 requirement in
fiscal year 2007. The Air Force is also evaluating workload associated
with the KC-135 aircraft, the C-17 aircraft, the B-2 aircraft, the F-119
engine, and the F-117 engine that may be shifted to the public sector.
Conclusions
The errors we identified in DOD's April 2006 50-50 report--while not
extensive--are indicative of the long-standing problems DOD has
encountered in providing accurate depot maintenance funding allocation
data to Congress. We have previously observed that the usefulness of the
annual 50-50 report to Congress is limited because of data reliability
concerns. Our prior reports identified data inaccuracies and recommended
corrective actions aimed at addressing deficiencies that limited the
accuracy of 50-50 reporting. In addition, we have recommended actions that
Congress could take to improve the reliability and usefulness of DOD's
annual report. Our current review shows that while DOD has taken some
additional actions to improve the quality of reported data for fiscal year
2005, it has not fully addressed the persistent deficiencies that have
limited 50-50 data accuracy in the past. DOD's report presented an
inaccurate measure of the balance of funding between the public and
private sectors due to inconsistencies in reporting expenditures rather
than obligations, and inaccurate distribution of reporting of allocations
from interservice and direct sales agreements. Without consistent
reporting of depot maintenance funding obligations, rather than a
combination of expenditures and obligations, inaccurate reporting of the
funding allocation between the public and private sectors will continue.
Moreover, without accurate reporting of the allocation of depot
maintenance workload performed by the private and public sectors under
interservice and direct sales agreements, the 50-50 data reported by DOD
will continue to be inaccurate.
Recommendations for Executive Action
To improve the consistency and accuracy of depot maintenance funding
allocation data in DOD's annual 50-50 report to Congress, we recommend
that the Secretary of Defense take the following two actions:
o Direct the Secretaries of the Army, Navy, and Air Force and the
Commandant of the Marine Corps to follow OSD guidance and report
funding obligations rather than expenditures.
o Direct the Under Secretary of Defense for Acquisition,
Technology, and Logistics, in conjunction with the Secretaries of
the Army, Navy, and Air Force, and the Commandant of the Marine
Corps, to establish measures to ensure proper accounting of the
allocation of interservice workloads between the public and
private sectors.
Agency Comments and Our Evaluation
In commenting on a draft of this report, DOD concurred with our
recommendations. Regarding our recommendation that the military
services follow guidance and report funding obligations rather
than expenditures, DOD stated that it will be specific in its
guidance on 50-50 reporting and require organizations to report
obligations rather than expenditures. Also, DOD stated that Army
guidance and training will address our findings. Consistent with
our recommendation, we believe that the Air Force, Navy, and
Marine Corps also should take appropriate steps to ensure that
obligations are reported. Regarding our recommendation that
measures be established to ensure proper accounting of the
allocation of interservice workloads, DOD said that its guidance
will require component audit agencies to specifically validate
interservice data prior to submitting the 50-50 report to the
department. Validation of interservice data would meet the intent
of our recommendation.
DOD also stated that it did not agree with our adjustments to the
work accomplished during the nuclear refueling of aircraft
carriers and for inactivation work on nonnuclear ships. DOD stated
that all costs during nuclear aircraft carrier refueling are
properly excluded and conventional ship inactivation workload is
not considered depot-level maintenance. We have had a
long-standing disagreement with DOD on including funding for these
two areas in its 50-50 report. For the past several years we have
maintained that DOD should include these funds, while DOD has
disagreed. Our reasons for including these adjustments are
discussed in this report.
DOD's written comments are reprinted in appendix III. DOD also
provided technical comments which we have incorporated as
appropriate.
We are sending copies of this report to appropriate congressional
committees; the Secretary of Defense; the Secretaries of the Army,
Navy, and Air Force; the Commandant of the Marine Corps; and the
Director, Office of Management and Budget. We will make copies
available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at
http://www.gao.gov . If you or your staffs have any questions
on the matters discussed in this report, please contact me at
(202) 512-8365 or [email protected] . Contact points for our
Offices 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.
William M. Solis
Director, Defense Capabilities and Management
Appendix I: Scope and Methodology
To determine whether the military departments provided accurate
data in reporting depot maintenance funding allocations and
whether they met the 50-50 requirement for fiscal year 2005, we
reviewed military services' procedures and internal management
controls for collecting and reporting their depot maintenance
allocations. We discussed with key officials the process used to
identify and report depot maintenance workload allocation between
the public and private sectors. We selected a nonprobability
sample of reported 50-50 obligations totaling $2.7 billion of the
reported $26.4 billion reported in the Department of Defense's
(DOD) report to Congress on depot maintenance funding allocation.
We based our sample on previously identified areas of concern,
varying program amounts, and selected locations for our site
visits. We also contacted service audit agencies and third-party
officials at service headquarters to discuss their verification
review of the fiscal year 2005 50-50 obligation data. We did not
conduct a review of all reported 50-50 data; therefore, there may
be additional errors, omissions, and inconsistencies that were not
identified. Because we used a nonprobability sample, our results
cannot be projected.
We visited departmental headquarters, major commands, and selected
maintenance activities. We interviewed service officials
responsible for data collection, and we reviewed the reported data
for accuracy and completeness. We compared reported amounts to
funding documents, contracts, and accounting reports for selected
programs for all the military services, but we placed greater
emphasis on the Army data because the Army was close to the 50
percent threshold for fiscal year 2005.
To determine the actions taken by the Office of the Secretary of
Defense (OSD) and military departments to improve the quality of
the reported 50-50 data and implementation of GAO's prior year's
recommendations, we reviewed the results of studies conducted by
the service audit agencies and reconciled areas of concern
identified during prior years' audits. We also reviewed prior
years' recommendations to find out whether known problem areas
were being addressed and resolved. We discussed with officials
actions they took to improve 50-50 data gathering and reporting
processes.
To determine the reasonableness of fiscal year 2006 and 2007
projections, we discussed with service officials how they
developed their projections and whether historical funding
information and known increases in funding were included in their
projections. Our analysis of the data for fiscal years 2006 and
2007 was limited because our current and past work on this issue
has shown that DOD's 50-50 data cannot be relied upon as a precise
measure of allocation of depot maintenance funds between the
public and private sectors. We discussed with Air Force officials
reasons for the increase in their fiscal year 2007 projection and
their plans to avoid breaching the 50 percent limitation.
In accomplishing our objectives, we interviewed officials,
examined documents, and obtained data at the Office of the
Secretary of Defense, Army, Navy, Marine Corps, and Air Force
headquarters in the Washington, D.C., area; Anniston Army Depot in
Anniston, Ala.; Red River Army Depot in Texarkana, Tex.; Army
Material Command in Alexandria, Va.; Tank-automotive and Armaments
Command (TACOM) Life Cycle Management Command in Warren, Mi.;
Naval Air Systems Command in Patuxent River, Md.; U.S. Fleet
Forces Command in Norfolk, Va.; Air Force Materiel Command in
Wright-Patterson Air Force Base, Oh.; Marine Corps Logistics
Command in Albany, Ga.; and Army, Navy, and Air Force Audit
Services. We conducted our work from March 2006 to September 2006
in accordance with generally accepted government auditing
standards.
Appendix II: GAO Adjustments to Army Fiscal Year 2005 Reported Data
Our review of the Army's data supporting the Department of
Defense's (DOD) fiscal year 2005 50-50 report identified the
following adjustments.
Table 3: Adjustments to Army Fiscal Year 2005 Reported Data
Public Private adjustment
Site adjustment (+/-) (+/-) Description
Anniston
Army Depot
$35,779.00 -$35,779.00 Contract
amount
overreported
$33,212.93 -$33,212.93 Contract
amount
overreported
Red River
Army Depot
-$1,482,178.10 $1,482,178.10 Private
carryover
work
misreported
-$30,823,990.55 $30,823,990.55 Outsourced
contract work
misreported
$245,011.00 -$245,011.00 Miscellaneous
math errors
in report
U.S. Army Tank-automotive and Armaments Command (TACOM) Life
Cycle Management Command
$742,490.00 Reset work underreported due to
changes in program costs
-$5,156,575.00 Reset work
overreported due to
double counting
$11,170,845.00 M9 Armored Combat Earthmover
(M9 ACE) work unreported due to
not reporting all applicable
amounts
$39,445,735.53 Heavy Expanded
Mobility Tactical
Truck (HEMTT) work
unreported due to
guidance
misinterpretation
-$127,738.97 High Mobility Multipurpose
Wheeled Vehicle (HMMWV) work
overreported due to changes in
program costs
$1,848,952.51 High Mobility
Multipurpose Wheeled
Vehicle (HMMWV) work
underreported due to
changes in program
costs
$13,953,000.00 Bradley work unreported due to
guidance misinterpretation
-$500,580.00 Abrams work overreported due to
changes in program costs
$504,278.50 Bradley work underreported due
to changes in program costs
$302,546.90 Bradley work underreported due
to changes in program costs
Total Army -$5,947,324.19 $68,130,278.66
adjustments
Source: GAO analysis of DOD data.
Appendix III: Comments from the Department of Defense
Appendix IV: GAO Contacts and Staff Acknowledgments
GAO Contact
William M. Solis (202) 512-8365
Acknowledgments
Key contributors to this report include Thomas Gosling, Assistant
Director; Connie W. Sawyer, Jr.; Janine Cantin; Clara Mejstrik; Stephanie
Moriarty; and Renee Brown.
Related GAO Products
Depot Maintenance: Persistent Deficiencies Limit Accuracy and Usefulness
of DOD's Funding Allocation Data Reported to Congress. [28]GAO-06-88 .
Washington, D.C.: November 18, 2005.
Depot Maintenance: DOD Needs Plan to Ensure Compliance with Public- and
Private-Sector Funding Allocation. [29]GAO-04-871 . Washington, D.C.:
September 29, 2004.
Depot Maintenance: Army Needs Plan to Implement Depot Maintenance Report's
Recommendations. [30]GAO-04-220 . Washington, D.C.: January 8, 2004.
Depot Maintenance: DOD's 50-50 Reporting Should Be Streamlined.
[31]GAO-03-1023 . Washington, D.C.: September 15, 2003.
Department of Defense: Status of Financial Management Weaknesses and
Progress Toward Reform. [32]GAO-03-931T . Washington, D.C.: June 25, 2003.
Depot Maintenance: Change in Reporting Practices and Requirements Could
Enhance Congressional Oversight. [33]GAO-03-16 . Washington D.C.: October
18, 2002.
Depot Maintenance: Management Attention Needed to Further Improve Workload
Allocation Data. [34]GAO-02-95 . Washington, D.C.: November 9, 2001.
Depot Maintenance: Action Needed to Avoid Exceeding Threshold on Contract
Workloads. [35]GAO/NSIAD-00-193 . Washington, D.C.: August 24, 2000.
Depot Maintenance: Air Force Faces Challenges in Managing to 50-50
Threshold. [36]GAO/T-NSIAD-00-112 . Washington, D.C.: March 3, 2000.
Depot Maintenance: Future Year Estimates of Public and Private Workloads
Are Likely to Change. [37]GAO/NSIAD-00-69 . Washington, D.C.: March 1,
2000.
Depot Maintenance: Workload Allocation Reporting Improved, but Lingering
Problems Remain. [38]GAO/NSIAD-99-154 . Washington, D.C.: July 13, 1999.
Defense Depot Maintenance: Public and Private Sector Workload Distribution
Reporting Can Be Further Improved. [39]GAO/NSIAD-98-175 . Washington,
D.C.: July 23, 1998.
Defense Depot Maintenance: Information on Public and Private Sector
Workload Allocations. [40]GAO/NSIAD-98-41 . Washington, D.C.: January 20,
1998.
Defense Depot Maintenance: More Comprehensive and Consistent Workload Data
Needed for Decisionmakers. [41]GAO/NSIAD-96-166 . Washington, D.C.: May
21, 1996.
(350818)
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and methodology, click on the link above.
For more information, contact William M. Solis (202) 512-8365 or
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Highlights of [49]GAO-07-126 , a report to congressional committees
November 2006
DEPOT MAINTENANCE
Actions Needed to Provide More Consistent Funding Allocation Data to
Congress
Under 10 U.S.C. S 2466, the military departments and defense agencies may
use no more than 50 percent of annual depot maintenance funding for work
performed by private-sector contractors. The Department of Defense (DOD)
must submit a report to Congress annually on the allocation of depot
maintenance funding between the public and private sectors for the
preceding fiscal year and projected distribution for the current and
ensuing fiscal years for each of the armed forces and defense agencies. As
required by Section 2466, GAO reviewed the report submitted in April 2006
and is, with this report, submitting its view to Congress on whether (1)
the military departments and defense agencies complied with the 50-50
requirement for fiscal 2005 and (2) the projections for fiscal years 2006
and 2007 represent reasonable estimates. GAO obtained data used to develop
the April 2006 report, conducted site visits, and reviewed supporting
documentation.
[50]What GAO Recommends
GAO recommends that DOD improve the consistency and accuracy of depot
maintenance workload allocation funding data in its 50-50 report to
Congress. DOD should ensure that obligations rather than expenditures are
reported, and that measures are established to ensure proper accounting of
interservice workloads between the public and private sectors. DOD
concurred with the recommendations.
Although DOD reported to Congress that it complied with the 50-50
requirement for fiscal year 2005, GAO could not validate compliance due to
weaknesses in DOD's financial management systems and the processes used to
collect and report 50-50 data. DOD's April 2006 report provides an
approximation of the depot maintenance funding allocation between the
public and private sectors for fiscal year 2005. GAO identified errors in
the reported data which, if adjusted, would increase the Army's
private-sector funding allocation percentage from 49.4 percent to 50
percent. GAO found that 50-50 funding allocation data were not being
consistently reported because some maintenance depots were reporting
expenditures rather than following Office of the Secretary of Defense
(OSD) guidance and reporting obligations. Combining obligations and
expenditures produces an inaccurate accounting of 50-50 funding
allocations. GAO also found amounts associated with interservice depot
maintenance work may not accurately reflect the actual allocation of
private- and public-sector funds because visibility over the allocation of
these funds is limited. OSD guidance requires that the military
departments establish measures to ensure correct accounting of
interservice workloads. In prior years' reports on DOD's compliance with
the 50-50 requirement, GAO discussed deficiencies limiting data accuracy
and recommended specific corrective actions. While DOD has taken some
additional actions to improve the quality of reported data for fiscal year
2005, it has not fully addressed the persistent deficiencies that have
limited 50-50 data accuracy.
Reported projections do not represent reasonable estimates of public- and
private-sector depot maintenance funding allocations for fiscal years 2006
and 2007 due to data inaccuracies. Errors GAO identified for fiscal year
2005 could affect these projections. If the adjustments GAO made to the
Army's fiscal year 2005 data--increasing the private-sector percentage by
about 0.6 percentage points--are carried forward, it could move the Army's
projection to within 2 percent of the 50 percent limitation for fiscal
year 2007. GAO also found that the projected numbers often did not include
supplemental funds, which could change the allocation percentages. These
errors and omissions affect the reasonableness and accuracy of the
reported projections. To avoid breaching the 50 percent threshold in
future years, the Air Force is implementing its plan to ensure compliance
with the 50-50 requirement until fiscal year 2010. The plan involves
moving some maintenance workload, including the F-100 engine, from the
private sector to the public sector.
References
Visible links
21. http://www.gao.gov/cgi-bin/getrpt?GAO-05-207
22. http://www.gao.gov/cgi-bin/getrpt?GAO-06-1006T
23. http://www.gao.gov/cgi-bin/getrpt?GAO-06-88
24. http://www.gao.gov/cgi-bin/getrpt?GAO-04-871
25. http://www.gao.gov/cgi-bin/getrpt?GAO-06-88
28. http://www.gao.gov/cgi-bin/getrpt?GAO-06-88
29. http://www.gao.gov/cgi-bin/getrpt?GAO-04-871
30. http://www.gao.gov/cgi-bin/getrpt?GAO-04-220
31. http://www.gao.gov/cgi-bin/getrpt?GAO-03-1023
32. http://www.gao.gov/cgi-bin/getrpt?GAO-03-931T
33. http://www.gao.gov/cgi-bin/getrpt?GAO-03-16
34. http://www.gao.gov/cgi-bin/getrpt?GAO-02-95
35. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-00-193
36. http://www.gao.gov/cgi-bin/getrpt?GAO/T-NSIAD-00-112
37. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-00-69
38. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-99-154
39. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-98-175
40. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-98-41
41. http://www.gao.gov/cgi-bin/getrpt?GAO/NSIAD-96-166
49. http://www.gao.gov/cgi-bin/getrpt?GAO-07-126
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