Defense Management: More Transparency Needed over the Financial  
and Human Capital Operations of the Joint Improvised Explosive	 
Device Defeat Organization (06-MAR-08, GAO-08-342).		 
                                                                 
Improvised explosive devices (IED) have been and continue to be a
significant threat to U.S. forces. The Department of Defense	 
(DOD) expanded efforts to defeat IEDs with the establishment of  
the Joint Improvised Explosive Device Defeat Organization	 
(JIEDDO) in January 2006. GAO was asked to review JIEDDO's	 
management and operations. For this second report in its series, 
GAO determined (1) the extent to which JIEDDO's management	 
processes provide adequate assurances that its financial	 
information is accurate and provides transparency over its	 
operations and (2) the extent to which JIEDDO identifies,	 
records, tracks, and reports numbers of all personnel, including 
contractors. GAO analyzed data for the first half of fiscal year 
2007, which included 47 funding transactions totaling $1.34	 
billion for 24 initiatives to address these objectives. 	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-342 					        
    ACCNO:   A81216						        
  TITLE:     Defense Management: More Transparency Needed over the    
Financial and Human Capital Operations of the Joint Improvised	 
Explosive Device Defeat Organization				 
     DATE:   03/06/2008 
  SUBJECT:   Agency evaluation					 
	     Agency missions					 
	     Contractors					 
	     Data integrity					 
	     Defense capabilities				 
	     Defense cost control				 
	     Explosives 					 
	     Financial management				 
	     Financial statement audits 			 
	     Financial statements				 
	     Funds management					 
	     Internal controls					 
	     Monitoring 					 
	     Policy evaluation					 
	     Program evaluation 				 
	     Reporting requirements				 
	     Standards						 
	     Strategic planning 				 
	     Program goals or objectives			 
	     Transparency					 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-08-342

   

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

March 2008: 

Defense Management: 

More Transparency Needed over the Financial and Human Capital 
Operations of the Joint Improvised Explosive Device Defeat 
Organization: 

Defense Management: 

GAO-08-342: 

GAO Highlights: 

Highlights of GAO-08-342, a report to congressional committees. 

Why GAO Did This Study: 

Improvised explosive devices (IED) have been and continue to be a 
significant threat to U.S. forces. The Department of Defense (DOD) 
expanded efforts to defeat IEDs with the establishment of the Joint 
Improvised Explosive Device Defeat Organization (JIEDDO) in January 
2006. GAO was asked to review JIEDDOâs management and operations. For 
this second report in its series, GAO determined (1) the extent to 
which JIEDDOâs management processes provide adequate assurances that 
its financial information is accurate and provides transparency over 
its operations and (2) the extent to which JIEDDO identifies, records, 
tracks, and reports numbers of all personnel, including contractors. 

GAO analyzed data for the first half of fiscal year 2007, which 
included 47 funding transactions totaling $1.34 billion for 24 
initiatives to address these objectives. 

What GAO Found: 

JIEDDOâs financial management processes do not provide adequate 
assurances that its financial information is accurate, and as a result, 
JIEDDO is unable to provide full transparency over the cost of its 
operations. While JIEDDO has improved its financial management 
processes, it has not yet reached a point where those processes contain 
an effective system of internal control. According to federal 
standards, internal control comprises the plans, methods, and 
procedures used to meet missions, goals, and objectives of an 
organization and help it to achieve desired results through effective 
stewardship of its resources. GAO identified four internal control 
weaknesses that affect JIEDDOâs financial management processes. First, 
JIEDDO has not comprehensively documented its administrative policies 
and operating manuals, which affects the consistency of how its 
financial management personnel perform their duties. Second, JIEDDO 
does not have adequate funds authorization controls to ensure that 
transactions are properly authorized before funds are committed. In 
reviewing funding transactions totaling $795 million, 18 of 24 
initiatives were not properly authorized in accordance with internal 
control standards. As a result, funds may be used without proper 
scrutiny and without a mechanism to detect, correct, or address this 
control failure. Third, JIEDDO does not have controls to ensure that 
transactions are properly categorized. For example, of the $1.34 
billion in fiscal year 2007 commitments reviewed, JIEDDO inaccurately 
categorized at least 83 percent of these dollars under one category 
that should have been applied to others. This could distort information 
used in assessing trends and prioritizing funds. Fourth, JIEDDO does 
not have an adequate internal process to monitor and review the 
efficacy of its internal controls. In the absence of an adequate system 
of internal control, the agency may not achieve all of its objectives 
and its use of resources may not be consistent with DOD priorities. 
Furthermore, decision makers may be basing their decisions on 
inaccurate financial data and reports. At the end of this review, 
JIEDDO managers said that they had corrected these weaknesses; however, 
because these actions occurred after audit completion, GAO could not 
determine their effectiveness. 

JIEDDO does not fully identify, track, and report all government and 
contractor personnel as provided for in DOD Directive 1100.4. 
Identifying all government and contractor personnel is important to 
JIEDDOâs management and oversight responsibilities and contributes to 
its ability to effectively plan for its future workforce needs. While 
JIEDDO has a system in place for routinely tracking and reporting 
numbers of personnel JIEDDO regards as staff, this system is limited 
because it does not track all government and contractor personnel 
performing work for JIEDDO. However, since its creation in February 
2006, JIEDDO has relied heavily on contractor support to accomplish its 
mission, which is not fully reflected in JIEDDOâs system. When the 
Senate Appropriations Committee directed that JIEDDO provide a 
comprehensive accounting of all of its personnel, including 
contractors, by May 2007, JIEDDO had to rely on an ad hoc process to 
develop the report, which resulted in several inaccuracies and 
inconsistencies. 

What GAO Recommends: 

To help ensure that JIEDDO provides adequate transparency over its 
resource use and addresses specific internal control weaknesses, GAO 
recommends that JIEDDO develop an effective internal control system and 
establish a means to identify, track, and report all personnel, 
including its contractor support. DOD agreed with the thrust of all of 
the GAO recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-342]. For more information, contact 
William M. Solis at (202) 512-8365 or [email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

JIEDDO Has Taken Steps to Improve Financial Management Processes but 
Lacks Effective Internal Controls to Provide Assurances That Its 
Financial Data Are Accurate and Provide Transparency over Its 
Operations: 

JIEDDO Does Not Comprehensively Identify, Track, and Report All 
Government and Contractor Personnel as Described by DOD: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Defense: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: JIEDDO Descriptions of How to Calculate Initiative Value: 

Abbreviations: 

COIC: Counter-IED Operations Integration Center: 

DFARS: Defense Federal Acquisition Regulation Supplement: 

DOD: Department of Defense: 

FMFIA: Federal Managers' Financial Integrity Act of 1982: 

IED: improvised explosive device: 

JCAAMP: Joint Improvised Explosive Device Defeat Capability Approval 
and Acquisition Management Process: 

JIEDDO: Joint Improvised Explosive Device Defeat Organization: 

MIPR: Military Interdepartmental Purchase Request: 

OMB: Office of Management and Budget: 

PGI: Procedures, Guidance, and Information: 

United States Government Accountability Office: 

Washington, DC 20548: 

March 6, 2008: 

Congressional Committees: 

When major combat operations for Operation Iraqi Freedom ceased in May 
2003, U.S. and coalition forces transitioned to stabilization 
operations. Since that time, U.S. forces have come under frequent and 
deadly attacks from insurgents using such weapons as improvised 
explosive devices (IED), mortars, and rocket launchers. IEDs also have 
been a significant threat to U.S. forces operating in Afghanistan. The 
Congressional Research Service recently reported that IEDs have caused 
60 percent of all American combat casualties both killed and wounded in 
Iraq and 50 percent of casualties in Afghanistan.[Footnote 1] The 
Department of Defense (DOD) has described IEDs as the number one weapon 
of strategic influence in the Iraq war and consequently has dedicated a 
high level of resources toward countering the impact of IEDs and their 
use by enemy forces. 

In response to the threat posed by IEDs, DOD and Congress have provided 
resources to fund efforts to defeat IEDs. From fiscal year 2004 through 
the end of fiscal year 2007, $11.25 billion has been provided to 
various DOD organizations to address the IED threat. For example, in 
June 2005, the Deputy Secretary of Defense established the Joint IED 
Task Force to lead DOD's efforts in fighting the IED threat with the 
intent to establish a holistic approach to defeating IEDs, streamline 
the processes for supporting the warfighter's efforts to counter IEDs, 
and build a dedicated staff with an IED-defeat knowledge base. In 
January 2006, the Deputy Secretary of Defense established the Joint 
Improvised Explosive Device Defeat Organization (JIEDDO) to expand the 
task force's scope by establishing a permanent organizational structure 
to execute the IED defeat mission. In fiscal year 2007, Congress 
appropriated about $4.35 billion for JIEDDO, and JIEDDO expects to 
continue to receive additional funding through subsequent supplemental 
appropriations to complete its fiscal year projects and begin new 
projects. 

Insurgents have adapted to U.S. countermeasures thus requiring JIEDDO 
to continue to evaluate and analyze efforts to defeat them. Given long- 
term fiscal challenges, congressional committees have expressed 
concerns regarding JIEDDO's rapid growth in structure, scope, and 
funding, and the extent to which DOD manages its resources to 
efficiently and effectively defeat IEDs. In a series of reviews in 
response to direction in Senate Report 109-292,[Footnote 2] we first 
reported in March 2007 on several issues related to JIEDDO's management 
and operations, including JIEDDO's lack of a strategic plan and the 
resulting effects on the development of its financial and human capital 
management programs.[Footnote 3] We made several recommendations to the 
Secretary of Defense to improve the management of JIEDDO operations, 
stressing the development of JIEDDO's detailed strategic plan. In this 
second review, we determined to what extent (1) JIEDDO's financial 
management processes provide adequate assurances that its financial 
information is accurate and provides transparency over its operations 
and (2) JIEDDO identifies, records, tracks, and reports numbers of all 
personnel, including contractors. We are also conducting a third review 
that examines JIEDDO's processes for coordinating counter-IED 
intelligence support across DOD, which we will report on separately. 

To address our objectives, we met with JIEDDO officials to gain a 
general understanding of JIEDDO's management of financial resources and 
personnel. To assess JIEDDO's financial management processes, controls, 
and data, we analyzed 47 funding actions totaling $1.34 billion for 24 
of the 301 initiatives JIEDDO had approved at the time we collected our 
data. Nineteen of the 24 initiatives were those with the highest fund 
commitments in JIEDDO's defeat-the-device and attack-the-network 
initiatives based on the financial transaction data we collected. The 5 
additional initiatives were those receiving Deputy Secretary of Defense 
approval after our initial data collection date. We also identified 
required approval controls over use of funds, reviewed these selected 
transactions for adherence to these controls, and assessed whether the 
data recorded in the accounting and managerial systems accurately 
reflected JIEDDO's activities. However, we did not perform a 
comprehensive assessment of all of JIEDDO's internal controls. To 
assess JIEDDO's efforts to identify, record, track, and report numbers 
of all personnel, including contractors, we collected and reviewed 
JIEDDO staff reports and selectively compared the associated data with 
corroborating sources to determine whether the reported figures were 
comprehensive and accurate. We conducted this performance audit from 
April 2007 to December 2007 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. 
Appendix I provides additional details on our scope and methodology. 

Results in Brief: 

JIEDDO's financial management processes do not provide adequate 
assurances that its financial information is accurate, and as a result, 
JIEDDO is unable to provide full transparency over the cost of its 
operations. While JIEDDO has made progress in improving its financial 
management processes, it has not yet reached a point where those 
processes contain an effective system of internal control. Such a 
system is required by federal laws and regulations and enables 
organizations to provide accurate financial information for both 
internal and external decision makers. According to federal standards, 
internal control comprises the plans, methods, and procedures used to 
meet missions, goals, and objectives of an organization and help it to 
achieve desired results through effective stewardship of public 
resources. We found that JIEDDO has four internal control weaknesses. 
First, JIEDDO has not comprehensively documented its administrative 
policies and operating manuals, which affects the consistency of how 
its financial management personnel perform their duties. As a result, 
we found inconsistent financial management control processes among 
staff and managers. Second, JIEDDO does not have adequate funds 
authorization controls to ensure that transactions are properly 
authorized before funds are committed. Thus, JIEDDO made funding 
commitments prior to obtaining required approvals, which underscores 
the possibility that funds are used without the proper scrutiny of 
authorizing agents and without a mechanism in place to detect, correct, 
or address this control failure. For example, funding transactions-- 
totaling $795 million--for 18 of 24 initiatives we reviewed were not 
properly authorized in accordance with internal control standards. 
Third, JIEDDO does not have controls to ensure that transactions are 
properly categorized. For example, of the $1.34 billion in fiscal year 
2007 commitments we reviewed, JIEDDO inaccurately categorized at least 
83 percent of these dollars under one category that should have been 
applied to others. This could distort information provided in JIEDDO's 
financial reports and affects its ability to accurately determine 
trends in the use of funds in conjunction with its priorities. Fourth, 
JIEDDO does not have an adequate internal process to monitor and review 
the efficacy of its internal controls. For example, JIEDDO's process 
used to assess its internal controls for its May 2007 annual statement 
of assurance, submitted to DOD as required by the Federal Managers' 
Financial Integrity Act of 1982 (FMFIA), resulted in several inaccurate 
statements that were used as the basis for an unqualified statement 
that JIEDDO's internal control system met federal standards. In the 
absence of an adequate system of internal control, the agency may not 
achieve all of its objectives, and its use of resources may not be 
consistent with DOD priorities. Furthermore, decision makers may be 
basing their decisions on inaccurate financial data and reports. JIEDDO 
officials stated that their efforts to develop an effective financial 
management program have been significantly challenged by turnover in 
key financial positions and difficulties hiring adequate numbers of 
qualified staff. They also said that JIEDDO has recently taken several 
actions to address and correct these weaknesses. However, because these 
changes have recently occurred and have not yet been fully implemented, 
we have not been able to evaluate their effectiveness in improving 
JIEDDO's internal control system. Therefore, we are recommending that 
JIEDDO develop and document a comprehensive system of internal control 
for its financial management processes that fully complies with federal 
internal control standards, and routinely monitor its effectiveness 
using internal audit staff. We are also recommending that JIEDDO report 
to Congress on the status of its efforts to implement a comprehensive 
system of internal control. 

JIEDDO does not fully identify, track, and report all personnel, 
including contractors, as described by DOD Directive 1100.4. This 
directive provides that each DOD organization shall designate an 
individual with the authority to maintain a manpower data system that 
accounts for all manpower resources--including military, civilian, and 
contractor.[Footnote 4] Furthermore, such an accounting helps internal 
and external decision makers conduct effective oversight of personnel. 
While JIEDDO has a system in place for tracking and reporting numbers 
of personnel, this system does not track all government and contractor 
personnel performing work for JIEDDO. For example, JIEDDO does not 
track field service representatives, who are contractors providing 
support for deployed counter-IED systems. From this limited system, 
JIEDDO routinely accounted for personnel filling about 418 authorized 
positions. In Senate Report 110-37, the Senate Appropriations Committee 
directed JIEDDO to provide a comprehensive report of all of its 
personnel, including all contractors, by May 2007.[Footnote 5] Because 
JIEDDO does not have a comprehensive process to track all personnel, it 
relied on an ad hoc process to develop the report. The results 
identified a total of 1,466 personnel working for JIEDDO. However, we 
were not assured of the accuracy of those figures in the congressional 
report given the lack of guidance or evidence of a process that would 
help to ensure reasonable accuracy in identifying and reporting all 
categories of government and contractor personnel. When we reviewed the 
report, we discovered inaccuracies in the data that led us to conclude 
that at about 114 personnel had been omitted from the report. In 
addition, we also noted that as it collected data for the report, 
JIEDDO applied inconsistent criteria. For example, JIEDDO reported some 
field service representatives as individuals and others as full-time 
equivalents, which could account for more than one individual. Although 
JIEDDO officials said that they do not consider all contractors as 
staff, since its creation in February 2006, JIEDDO has relied heavily 
on contractor support to accomplish its mission. For example, JIEDDO 
has employed contractors to perform such tasks as evaluating initiative 
proposals from outside contractors and operating unmanned aerial 
vehicles. DOD Directive 1100.4 states that it is DOD policy that 
manpower requirements be established at the minimum levels necessary to 
accomplish mission and performance objectives. It follows that a 
manpower data system that accurately accounts for all personnel, 
including contractors, enables manpower management that promotes 
efficient and effective use of manpower resources. Furthermore, such 
accounting helps congressional decision makers and JIEDDO management 
conduct effective oversight of personnel. Therefore, we are 
recommending that JIEDDO establish a method or system to 
comprehensively identify, track, and report on a routine basis all 
personnel, including all levels of contractor support. 

In written comments on a draft of this report, DOD concurred with our 
findings and the thrust of our six recommendations. With respect to our 
fifth recommendation as originally stated in our draft report, which 
was to report on JIEDDO's efforts to implement internal control 
improvements as part of JIEDDO's recurring quarterly congressional 
reports, DOD instead proposed a report that provides this information 
to the Armed Services and Appropriations Committees 1 year after the 
issuance of our report, which satisfies the intent of our 
recommendation. Consequently, we modified our original recommendation 
to reflect this change. DOD also provided additional information on 
several activities it has undertaken to date. DOD's written comments 
are reprinted in appendix II. 

Background: 

JIEDDO was created by the Deputy Secretary of Defense in January 2006 
and is responsible for leading, advocating, and coordinating all DOD 
efforts to defeat IEDs. Prior DOD efforts to defeat IEDs included 
various process teams and task forces. For example, DOD established the 
Joint IED Defeat Task Force in June 2005 for which the Army provided 
primary administrative support. This task force replaced the Army IED 
Task Force, the Joint IED Task Force, and the Under Secretary of 
Defense, Force Protection Working Group. To focus all of DOD's efforts 
and minimize duplication, DOD published new IED policy in February 2006 
through DOD Directive 2000.19E, which changed the name of the Joint IED 
Defeat Task Force to JIEDDO and established it as a joint entity and 
jointly manned organization within DOD, reporting to the Deputy 
Secretary of Defense. The directive states that JIEDDO shall "focus 
(lead, advocate, and coordinate) all Department of Defense actions in 
support of the Combatant Commanders' and their respective Joint Task 
Forces' efforts to defeat Improvised Explosive Devices as weapons of 
strategic influence." The organization is directed to identify, assess, 
and fund initiatives that provide specific counter-IED solutions, and 
is granted the authority to approve joint IED defeat initiatives valued 
up to $25 million and make recommendations to the Deputy Secretary of 
Defense for initiatives valued over $25 million. Under the directive, 
the Army remains the organization's executive agent and is responsible 
for providing primary administrative support to JIEDDO. 

JIEDDO's primary role is to provide funding to the military services 
and DOD agencies to rapidly develop and field counter-IED solutions. 
Prior to fiscal year 2007, JIEDDO did this by working with the DOD 
Comptroller to transfer its appropriated funds into a standard DOD 
appropriation account, such as one for procurement or one for research, 
development, testing, and evaluation. JIEDDO would then send these 
transferred funds to the military service that is designated to sponsor 
the initiatives using a Military Interdepartmental Purchase Request 
(MIPR).[Footnote 6] Beginning in fiscal year 2007, Congress provided 
JIEDDO with its own separate direct appropriation, but it still must 
transfer funds to the military services using a duly authorized and 
signed MIPR, which the Defense Federal Acquisition Regulation 
Supplement (DFARS) Subpart 208.7004 (Procedures, Guidance, and 
Information (PGI) 208.7004) states is the acquiring department's 
authority for acquiring the goods or services on the requiring 
department's behalf.[Footnote 7] DFARS PGI 208.7004 also states that 
the acquiring department, or military service, is then authorized to 
create obligations against the funding without further referral to the 
requiring department--JIEDDO--and that the military service has no 
responsibility to determine the validity of an approved MIPR. 
Therefore, after JIEDDO provides funding authority to the military 
service and the designated program manager for a specific initiative, 
the service program manager, not JIEDDO, is responsible for managing 
the initiatives for which JIEDDO has provided funds. 

JIEDDO's efforts to counter the use of IEDs and subsequent funding for 
those efforts are organized according to three primary lines of 
operation: (1) attack the network that enables the use of IEDs, (2) 
defeat the IED itself once emplaced, and (3) train the military forces 
in counter-IED techniques. JIEDDO assigns all funds used to one of 
these lines of operation--or to a fourth line of operation called staff 
and infrastructure for miscellaneous expenditures not directly related 
to the three lines of operation. When JIEDDO undertakes any effort 
requiring funds, it assigns the funds for the effort to one of the 
lines of operations. JIEDDO further breaks down its expenditures into 
more detailed subsets, which it designates as initiatives, assigning a 
name and a unique number to track expenditures related to each 
initiative. JIEDDO manages and reports on all funds expended by line of 
operation and by initiative. 

Office of Management and Budget (OMB) Circular A-123 specifies that 
federal agencies have a fundamental responsibility to develop and 
maintain effective internal control that ensures the prevention or 
detection of significant weaknesses--that is, weaknesses that could 
adversely affect the agency's ability to meet its objectives.[Footnote 
8] According to OMB, the importance of management controls is addressed 
in many statutes and executive documents. A memorandum from the OMB 
Director to the heads of the executive departments accompanying OMB 
Circular A-123 as an attachment requires agencies and individual 
federal managers to take systematic and proactive measures to develop 
and implement appropriate, cost-effective internal controls for results-
oriented management. FMFIA establishes the overall requirements with 
regard to internal control. Accordingly, an agency head must establish 
controls that reasonably ensure that (1) obligations and costs are in 
compliance with applicable law; (2) funds, property, and other assets 
are safeguarded against waste, loss, unauthorized use, or 
misappropriation; and (3) revenues and expenditures applicable to 
agency operations are properly recorded and accounted for to permit the 
preparation of accounts and reliable financial and statistical reports 
and to maintain accountability over the assets.[Footnote 9] Specific 
internal control standards underlying the internal controls concept in 
the federal government are promulgated by GAO and are referred to as 
the Green Book.[Footnote 10] 

In March 2007, the Senate Appropriations Committee directed JIEDDO to 
identify and track all civilian, military, and contractor personnel in 
the organization.[Footnote 11] In addition, DOD Directive 1100.4, 
"Guidance for Manpower Management," provides that DOD components shall 
designate an individual with the authority to establish and maintain a 
manpower data system that accounts for all manpower resources, to 
include active military, DOD civilian, reserve component, contract, and 
host-nation support.[Footnote 12] The Senate Appropriations Committee, 
in its report on emergency supplemental appropriations, expressed 
concern over JIEDDO's exponential personnel growth and ability to track 
this growth.[Footnote 13] The report stated that the committee has 
limited visibility into current staffing and future staffing 
requirements and is concerned that JIEDDO is not accounting for certain 
contractor support properly. As a result of these concerns, the 
committee directed JIEDDO to provide a report to the congressional 
defense committees on current staffing levels and future staffing 
requirements, broken down by function, contractor, civilian, military, 
and detailed from other agencies, and should include all contractor 
support that is provided through various contracts. The committee 
further directed JIEDDO to update this report whenever JIEDDO personnel 
authorizations change. In response to the committee's direction, JIEDDO 
officials developed the JIEDDO Manning Description in May 2007 
identifying and accounting for civilian, military, and contractor 
personnel working for JIEDDO. 

JIEDDO Has Taken Steps to Improve Financial Management Processes but 
Lacks Effective Internal Controls to Provide Assurances That Its 
Financial Data Are Accurate and Provide Transparency over Its 
Operations: 

JIEDDO has made progress in improving its financial management 
processes but has not yet reached a point where its processes contain a 
system of internal control that ensures the accuracy of its financial 
data related to resources it has used in its operations. According to 
federal standards, internal control comprises the plans, methods, and 
procedures used to meet missions, goals, and objectives of an 
organization and help it to achieve desired results through effective 
stewardship of public resources.[Footnote 14] In addition, our prior 
work has stated the importance of organizations addressing internal 
control weaknesses.[Footnote 15] Otherwise, organizations may not 
achieve their objectives or may not use their resources to best 
advantage in achieving their objectives. Before beginning fiscal year 
2007 operations, JIEDDO took several steps to improve its processes for 
managing and controlling its financial resources, and JIEDDO has been 
proactive in responding to financial management issues we raised during 
this audit by pursuing additional financial management process 
improvements. Nonetheless, JIEDDO is lacking an effective system of 
internal control that will provide adequate assurances of financial 
data accuracy and operations transparency. Although JIEDDO added 
changes toward the end of our review that are expected to address 
internal control weaknesses, their implementation occurred too late for 
us to determine their effectiveness. Nonetheless, in the absence of an 
adequate system of internal controls, inaccurate financial data and 
reports may negatively affect the internal and external decision-making 
process. 

JIEDDO Has Taken Steps to Improve Its Financial Management Processes: 

JIEDDO has taken several steps to improve its financial management 
processes. JIEDDO's actions are divided into (1) those taken in 
preparation for the beginning of fiscal year 2007 operations and (2) 
those taken to develop and continually improve on its operations. 

JIEDDO's approach for fiscal year 2007 included three changes aimed at 
streamlining and reducing data processing and analysis. The first of 
these changes was that JIEDDO took direct control of accounting 
functions previously performed by Army activities in support of JIEDDO. 
This allowed JIEDDO to directly execute and oversee funds budgeted and 
made available to JIEDDO. Second, JIEDDO requested and received a 
separate appropriation exclusively for its efforts, without having to 
obtain approval for funds through other DOD funding streams. Third, 
JIEDDO developed a procedure for assigning distinct numbers to specific 
initiatives because some initiatives were referred to by more than one 
name. The assignment of numbers eliminated confusion over the name of 
the initiative and facilitated the automated transfer of data, which 
was not possible using only a descriptive name. 

JIEDDO's more recent actions were taken as part of its efforts to fully 
establish its organizational framework as the organization evolves and 
to continually improve its processes. These actions include issuing an 
internal written instruction describing the roles and responsibilities 
of JIEDDO subdivisions in greater detail; developing internal controls 
imbedded in a new automated document management and storage system; and 
establishing a new internal control audit function to be staffed by 
three persons, reporting directly to the JIEDDO Director. While these 
actions could address JIEDDO's internal control weaknesses, they have 
not yet been fully implemented and occurred too late for us to 
determine their effectiveness. 

JIEDDO Lacks Effective Internal Controls to Provide Assurances That Its 
Financial Data Are Accurate, and JIEDDO Is Unable to Provide 
Transparency over Its Operations: 

JIEDDO does not have an effective internal control system in place to 
ensure that its financial data are accurate, and without such 
assurances, JIEDDO is unable to provide adequate transparency over the 
cost of its operations. The ability of JIEDDO to provide accurate 
financial information for internal and external decision makers depends 
on management accountability and an effective system of internal 
control. Consistent with federal standards, JIEDDO would need to 
adequately document its financial management processes and procedures, 
including related internal controls, and the internal control system 
would contain basic elements providing assurance that proper 
authorization is obtained before using funds and that once a 
transaction occurs it is accurately and promptly recorded. Furthermore, 
developing adequate oversight mechanisms within JIEDDO is a key factor 
in developing the conscientious control environment required by federal 
standards. However, although our review was not designed to identify 
all significant deficiencies in internal control, we identified four 
weak control areas at JIEDDO, which individually and collectively 
precluded adequate assurances of accuracy and usefulness of financial 
data produced by JIEDDO's financial management operations. JIEDDO does 
not have (1) comprehensive documentation of its internal controls, (2) 
adequate funds authorization controls, (3) sufficient controls to 
ensure accurate categorization of transactions, and (4) an adequate 
process to monitor and review its internal control program. 

First, JIEDDO's internal control processes related to its financial 
management are not adequately documented as required by government 
internal control standards.[Footnote 16] Specifically, JIEDDO has not 
developed management directives, administrative policies, or operating 
manuals that comprehensively describe how JIEDDO financial management 
personnel should perform their duties and the internal control 
activities designed to assure management that those duties are timely 
and accurately performed. As a result, we found inconsistent financial 
management control processes among JIEDDO staff and managers. For 
example, while DOD's JIEDDO directive divides approval authority for 
JIEDDO initiatives between the Deputy Secretary of Defense--initiatives 
valued at greater than $25 million--and JIEDDO itself--initiatives 
valued up to $25 million, DOD did not adequately define in its 
directive the terms initiative or value with respect to which 
initiatives measure over or below $25 million. Not defining terms would 
affect interpretation for both those with approval authority and those 
making processing and authorization control decisions. As a result, 
when determining whether an initiative should be forwarded to the 
Deputy Secretary of Defense for approval--a key external authorization 
control--or whether the authority rests within JIEDDO itself because 
the value does not exceed $25 million, various JIEDDO officials and 
contractors provided us with varying descriptions for value 
determination (see table 1 for a listing of varying descriptions). 
However, any of these approaches could significantly change an 
initiative's value calculations and consequently affect JIEDDO's 
approval control decision process. In November 2007, JIEDDO issued an 
instruction that included further guidance on how to determine what 
constitutes an initiative for the purposes of requiring approval by the 
Deputy Secretary of Defense.[Footnote 17] However, this instruction has 
not yet been incorporated into financial management operating 
procedures to ensure that staff understand the definition and apply it 
consistently when processing transactions. According to JIEDDO 
officials, the instruction, while better documenting the initiative 
determination and approval processes, does not provide adequate detail 
to constitute sufficient standard operating procedures for the 
components of JIEDDO. JIEDDO officials added that they have planned to 
form internal teams in the upcoming months to develop the more detailed 
operating procedures JIEDDO components need to implement this 
instruction. 

Table 1: JIEDDO Descriptions of How to Calculate Initiative Value: 

* Only costs[A] included on individual purchase request to a military 
service. 

* Only costs associated with an individual activity or program office. 

* Only costs to be incurred by JIEDDO within 1 fiscal year. 

* Only costs to be incurred within the fisca1 year, regardless of which 
organization funds the initiative. 

* All costs to be incurred by JIEDDO over the life of the initiative, 
until termination or management transfer to one of the military 
services. 

* All costs incurred over multiple years, regardless of which 
organization funds the initiative. 

Source: GAO analysis of JIEDDO descriptions. 

[A] Costs include goods and services to develop, purchase, field, 
maintain, and sustain the initiative. 

[End of table] 

Second, JIEDDO's internal control system does not have adequate funds 
authorization controls to ensure that transactions are properly 
authorized before committing funds, which is a fundamental control 
activity required by government internal control standards.[Footnote 
18] We reviewed 24 initiatives of which 18 had funding transactions 
totaling $795 million that were not authorized in accordance with the 
process that JIEDDO officials said should take place in advance of the 
commitment of funds on initiatives valued at greater than $25 million. 
JIEDDO officials stated that approval of the Deputy Secretary of 
Defense had to be obtained before funds could be committed on 
initiatives valued at greater than $25 million. Fourteen of the 18 
initiatives received the required Deputy Secretary of Defense 
authorization after JIEDDO financial management personnel committed 
funds by approving the MIPR to transfer funds from JIEDDO to the 
external program manager for the initiative. For example, JIEDDO spent 
about $8 million in the first quarter of fiscal year 2007 for an 
initiative that it expected would, overall, require $57 million for 
that fiscal year. Since that overall amount exceeded the $25 million 
value determination that requires the approval of the Deputy Secretary 
of Defense, JIEDDO acted before obtaining required authorization. 
JIEDDO did obtain Deputy Secretary of Defense approval for this 
initiative, but it was approximately 3 months after JIEDDO had 
committed funds for this initiative. In another case, the financial 
management division initially refused to commit funds for one 
initiative exceeding $25 million until JIEDDO management obtained 
approval from the Deputy Secretary of Defense. However, JIEDDO 
management's response was to request funds for only one quarter's 
expenses, thus reducing the amount to under $25 million. According to 
documentation in the file, the financial management division then 
agreed to fund the amount and commit the funds, even though it was 
aware that total program costs exceeded $25 million for the fiscal 
year. Subsequently, JIEDDO's legal advisor determined that the project 
was not an initiative because it was considered part of JIEDDO's 
infrastructure costs and thus did not require approval by the Deputy 
Secretary of Defense. Nevertheless, although JIEDDO eventually decided 
approval was not required, the process for approving funds for this 
project demonstrates a breakdown in the internal control structure 
necessary to ensure proper authorization before funds are spent, since 
JIEDDO officials avoided obtaining approval even though they thought 
prior approval was required. Additionally, it is not clear whether 4 of 
the 18 initiatives were authorized prior to commitment of funds because 
authorization letters were not dated, making the time of authorization 
unverifiable. It is clear, however, that inconsistent with JIEDDO 
processes, officials within JIEDDO made several funding commitments 
prior to obtaining the approvals required by JIEDDO processes. This 
underscores that JIEDDO's system of internal control allowed funds to 
be committed without the scrutiny of authorizing agents. Furthermore, 
the system did not detect, correct, or address this control failure. 

Third, JIEDDO internal controls do not ensure that its transactions are 
properly categorized, in spite of federal internal control standards 
requiring that accurate transaction recording be ensured by an entity's 
internal control system.[Footnote 19] For example, JIEDDO used about 
$216 million on an initiative titled "CREW --USMC - Program Management 
Support (Contractor Salaries, Travel & Infrastructure)," recording the 
expenditure as management and professional support services. However, 
the $216 million actually funded the purchase of tangible equipment-- 
IED jammers--and therefore should have been recorded as procurement of 
equipment instead. Overall, of the $1.34 billion in fiscal year 2007 
commitments we reviewed, JIEDDO inaccurately recorded at least 83 
percent of the dollars committed--involving 15 of the 24 initiatives we 
reviewed--as management and professional support services, when other 
categorizations should have been applied by JIEDDO financial managers. 

JIEDDO's system of internal control also does not ensure that all 
transactions are accurately recorded in the proper JIEDDO lines of 
operation, and this could distort reported expenditures on these lines 
of operation. A key part of JIEDDO's overall strategy to manage 
operations is to code various initiatives to reflect one of four JIEDDO 
lines of operation to track success in achieving the overall goal of 
increased effort to attack the IED network. According to officials, 
JIEDDO policy is to assign a single line-of-operation code to each 
initiative even when operations overlap, which may result in the 
reported funding for a given line of operation being inaccurate. For 
example, JIEDDO's initiative involving the testing of counter-IED 
devices (constituting $92 million in fiscal year 2007 funds) was coded 
as an attack-the-network effort, when our analysis indicates that the 
initiative more accurately represents JIEDDO's defeat-the-device line 
of operation. When originally established, JIEDDO coded its testing 
efforts as staff and infrastructure, which reflects general overhead 
incurred by JIEDDO, and reported the initiative as such in its second 
quarter congressional report. However, subsequently JIEDDO recoded the 
initiative and reported it as an attack-the-network initiative in its 
third quarter congressional report. We found four other instances of 
JIEDDO recoding initiatives in the attack-the-network line of 
operations that also affected the third quarter report. JIEDDO 
officials explained that the recoding was based on a JIEDDO decision to 
code or recode any nondirect overhead staff and infrastructure 
initiatives as attack-the-network initiatives. They did not have 
supporting documentation reflecting JIEDDO's decision to recode. 
Documented directions would serve to track the rationale for how this 
line of operation was coded and recoded. The blanket assignment of 
direct overhead costs to the attack-the-network line of operation, 
along with reassigning lines of operation after initial recording 
affects JIEDDO's ability to accurately determine trends in the use of 
funds in conjunction with its attack the network objective. Further, in 
the case of the testing operations, funding for attack the network is 
overstated because, according to JIEDDO officials, the majority of 
testing operations can be attributed to other lines of operation. 

Fourth, JIEDDO's internal process to monitor and review the efficacy of 
its internal controls is inadequate. The first federal government 
internal control standard, relating to an entity's control environment, 
includes having oversight mechanisms present within the agency as a key 
factor in accomplishing a conscientious control environment.[Footnote 
20] However, JIEDDO appeared to lack adequate mechanisms to monitor and 
review its internal control program during the period of our audit. In 
a May 2007 internal control report that JIEDDO prepared for the annual 
DOD internal controls assurance statement, JIEDDO described its process 
for assessing its controls and, based on that assessment, stated that 
it was able to provide an unqualified statement of reasonable assurance 
that its system of internal controls met federal internal control 
objectives.[Footnote 21] However, we found several inaccurate 
statements in the report that were used as the basis for this 
conclusion, raising questions about the adequacy of JIEDDO's process 
for assessing its internal control system and determining reasonable 
assurance. For example, the financial management section of the report 
cited four final audit reports from the Air Force Audit Agency, DOD 
Program Analysis and Evaluation, the DOD Inspector General, and GAO. 
According to JIEDDO, these reports said the organizations reviewed 
JIEDDO financial management for activity beginning in fiscal year 2004 
and did not have findings or recommendations. However, two of the 
reports cited do not exist (those for the Air Force Audit Agency and 
DOD Program Analysis and Evaluation), and the DOD Inspector General 
report focused on assessing controls over the Army's purchases from 
other government activities, not on JIEDDO's internal control system. 
Further, that report concluded that the Army did not have adequate 
internal controls over purchases from governmental sources, which 
included one JIEDDO fiscal year 2006 expenditure, because the Army did 
not ensure that expenditures were properly initiated, prepared, 
executed, and monitored.[Footnote 22] Lastly, the GAO report cited is 
the predecessor to this review, and it concluded that JIEDDO's lack of 
a strategic plan limits JIEDDO's ability to properly align its resource 
use and management to achieve JIEDDO-wide goals.[Footnote 23] The 
report, however, did not provide any assessment of JIEDDO's internal 
control system. 

Another question about the adequacy of JIEDDO's internal control 
assessment process and related assurance report concerns JIEDDO's 
statement that training of its staff has improved internal controls. 
However, some of the individuals who actually prepared feeder sections 
of the report had not received any training on internal controls or how 
to assess them. Further, some of these individuals are not familiar 
with the internal control standards and the structured internal control 
risk assessment. We did not assess JIEDDO's stated basis for reasonable 
assurance of its internal control standards in its entirety because of 
the inaccuracies found relating to resource management and training 
sections of the report and because JIEDDO's report did not identify the 
significant control weaknesses we found, such as JIEDDO's noncompliance 
with authorization controls and inaccurate classification of 
expenditures. 

As evidenced by these four weaknesses, in the absence of an adequate 
system of internal control the objectives of the agency may not be 
fully achieved and its use of resources may not be fully consistent 
with DOD priorities. Furthermore, decision makers may be basing their 
decisions on inaccurate financial data and reports. JIEDDO officials 
stated that their efforts to develop an effective financial management 
program have been significantly challenged by turnover in key financial 
positions and difficulties hiring adequate numbers of staff. In 
discussing these internal control findings at the end of our fieldwork, 
JIEDDO managers said that they have taken several actions to address 
and correct these weaknesses, which we noted previously. JIEDDO 
believes that these actions have already improved the internal control 
weaknesses found; however, the changes are still in the early 
implementation stages, and as such, we have not been able to evaluate 
their effectiveness in improving JIEDDO's internal control system. 

JIEDDO Does Not Comprehensively Identify, Track, and Report All 
Government and Contractor Personnel as Described by DOD: 

JIEDDO does not fully identify, track, and report all government and 
contractor personnel as provided for in DOD Directive 1100.4. 
Identifying all government and contractor personnel is important to 
JIEDDO's management and oversight responsibilities and contributes to 
its ability to effectively plan for its future workforce needs. DOD 
Directive 1100.4 states that it is DOD policy that manpower 
requirements be established at the minimum levels necessary to 
accomplish mission and performance objectives. It follows that a 
manpower data system that accurately accounts for all personnel, to 
include contractors, enables manpower management that promotes 
efficient and effective use of manpower resources. While JIEDDO employs 
various DOD policies to manage civilian and military personnel, these 
policies do not include accurately accounting for all of its personnel, 
as described in DOD Directive 1100.4. According to JIEDDO personnel 
officials, JIEDDO applies existing DOD policies to address 
administrative issues, such as performance, pay, and leave. JIEDDO also 
refers to the Federal Acquisition Regulation that includes personnel 
policy and procedures that are specific to the acquisition and 
management of services by contract. Additionally, JIEDDO issues policy 
letters as needed to clarify personnel management issues. For example, 
JIEDDO issued policy letter #16A that directed the division chiefs to 
be aware of the number of hours all employees, including contractor 
personnel, were working, and directed all employees to report all hours 
worked and obtain approval for their schedules from their supervisors. 
Nonetheless, these approaches do not identify, track, and report all 
military, civilian, and contractor personnel. 

JIEDDO officials track civilian, military, and some contractor 
personnel on a daily basis to identify personnel currently staffed and 
determine positions remaining to be filled; however, this effort does 
not track all personnel performing work for JIEDDO. For example, JIEDDO 
does not include some or all of personnel in the following categories: 

* contractors working as field service representatives,[Footnote 24] 

* contractors engaged as interagency liaisons, 

* contractors providing law enforcement training, 

* contractors involved in JIEDDO's interagency partnership team, 

* civilians and contractors from JIEDDO's Joint Test Board,[Footnote 
25] and: 

* contractors maintaining infrastructure at the Counter-IED Operations 
Integration Center (COIC) facilities. 

Personnel officials said that these data are collected to identify 
changes in JIEDDO's on-hand strength as personnel leave or are newly 
assigned and are not intended to be a comprehensive data collection. We 
reviewed JIEDDO's daily report from October 9, 2007, which shows that 
JIEDDO had 321, including civilian, military, and some contractor 
personnel, out of 418 authorized positions. 

The Senate Appropriations Committee directed JIEDDO to provide a 
comprehensive report of all of its personnel by May 2007, and because 
JIEDDO does not have a comprehensive process to track all personnel, it 
relied on an ad hoc process to develop the report. The results 
identified a total of 1,466 personnel working for JIEDDO, as compared 
to the 321 personnel filling 418 positions routinely tracked by the 
organization in its daily snapshots. The figures in the report to 
Congress tripled the number of personnel overall and showed a ratio 
between contractor and government personnel of nearly 5 to 1 when 
compared with the figures in the daily snapshots. 

We were not assured of the accuracy of those figures in the 
congressional report given the lack of guidance or evidence of a 
process that would indicate reasonable accuracy in identifying and 
reporting all categories of government and contractor personnel. JIEDDO 
officials also said that the organization lacked procedures for 
identifying and tracking all of its personnel. When we reviewed the 
report, we discovered inaccuracies and inconsistencies in the data that 
led us to conclude that about 114 personnel had been omitted from the 
report: 

* 25 civilian positions and about 30 contractor personnel with the 
Joint Test Board, all funded by JIEDDO since JIEDDO funds all of the 
board's operations costs, including these positions, and: 

* 59 contractor personnel working as field service representatives who 
were not included for one initiative but were reported in JIEDDO's 
funding documentation. 

In addition, we also found 67 personnel who were not reported in the 
body of the report but were reported in JIEDDO's summary schedule of 
personnel, and 9 additional authorized intern positions that were 
included in the report but were not included in JIEDDO's daily 
snapshots. 

When accounting for personnel, different divisions may have applied 
inconsistent criteria as they collected data for the May 2007 
congressional report because JIEDDO officials did not provide formal 
guidance to the divisions on how to report some personnel. For example, 
JIEDDO officials said that they could not tell whether the 474 field 
service representatives reported reflected actual individuals or full- 
time equivalents, which could represent more than one individual. At 
the conclusion of our review, JIEDDO officials were still unable to 
clarify this issue. In addition to the fact that the figure could be 
higher or lower, JIEDDO officials further explained that the reported 
field service figure of 474 was inaccurate because JIEDDO subsequently 
determined that the number for one initiative included in the data 
contained a significant error. 

JIEDDO had no means to track and verify the accuracy of its figures 
presented in the May 2007 report because officials did not maintain 
adequate supporting documentation representing how they arrived at 
their figures. For example, when JIEDDO accounted for field service 
representatives, we asked JIEDDO officials for clarification on how 
they arrived at the number of contractors they reported. However, they 
could not explain adequately because they did not document the process 
and their recollections were admittedly incomplete. Without adequate 
supporting documentation, JIEDDO cannot provide assurance that the data 
it reports are accurate. Furthermore, with change of personnel, which 
is typical within JIEDDO, new personnel would have difficulty 
determining the accuracy of figures as well as what process to follow 
to prepare subsequent reports. 

Although JIEDDO has not routinely tracked all of its contractors, it 
has relied heavily on contractor support to accomplish its mission 
since its creation in February 2006. According to JIEDDO officials, 
this reliance on contractors was attributed to the lengthy and complex 
civilian hiring process, the inability of the military services to fill 
all of the services' authorized positions, and the urgency of the 
organization's mission. Contractors have performed a broad range of 
labor and services for JIEDDO. Examples of functions contractors have 
performed include: 

* evaluating initiative proposals from outside contractors, 

* piloting unmanned aerial vehicles, 

* managing a division's efforts to develop useful metrics, 

* conducting virtually all of the day-to-day management of the various 
functions at the COIC, and: 

* providing equipment maintenance and logistics support in theater for 
new initiatives. 

In addition to playing significant roles in accomplishing JIEDDO's 
mission, contractors have also held critical positions within JIEDDO 
management and might have had a significant influence on its decision 
making. In the recent past, JIEDDO employed contractor personnel for 
positions the organization designated as inherently governmental. OMB 
defines an inherently governmental function as one involving the 
exercise of substantial discretion in applying government authority, 
making decisions for the government, or both.[Footnote 26] JIEDDO 
personnel documentation showed that the organization had staffed 
contract personnel in positions of key governmental responsibility, and 
officials stated that the organization is in the process of resolving 
this practice. In July 2007, JIEDDO officials began transitioning 
government personnel--primarily temporary military staff--into these 
positions that until recently were held by contractors. According to 
JIEDDO officials, the organization is moving toward filling these 
positions with permanent government personnel. 

JIEDDO officials said that they did not believe tracking all contractor 
personnel was necessary because they are not considered JIEDDO staff, 
and consequently, JIEDDO has not developed a comprehensive process to 
identify, track, and report all personnel in accordance with DOD 
policy. However, without a comprehensive process, JIEDDO is not in a 
position to readily provide accurate and reliable information to 
internal and external decision makers on its staffing levels. For 
example, when the Senate Appropriations Committee directed JIEDDO to 
identify and report on staffing levels of civilian, military, and 
contractor staff, JIEDDO officials used ad hoc data requests to 
divisions they receive information from in their daily reports and to 
activities that are not being captured by the current process in order 
to collect information on contractor personnel. Despite responding to 
the committee's direction for a May 2007 report and its direction to 
update this report to reflect future personnel changes, JIEDDO 
officials have not developed a policy requiring the collection of data 
accounting for all categories of personnel or provided guidance for 
doing this accurately. 

Additionally, without a comprehensive process to track all government 
and contractor personnel, JIEDDO cannot be in a position to effectively 
plan for its future workforce needs. For example, according to a JIEDDO 
official, in the case of one initiative JIEDDO needed to compare 
unmanned aerial vehicle piloting alternatives, contracted versus in- 
house, and it was critical for JIEDDO to know the quantity of and 
functions of contractor staff employed under the existing contract. 
However, because JIEDDO's manpower management system does not routinely 
capture contractor staff information, it would have been difficult for 
JIEDDO to determine whether to continue the contract without finding an 
alternative source for this information. For this initiative, JIEDDO 
was able to obtain the information needed through detailed contract 
information that happened to be available. However, according to the 
JIEDDO official, these details are not always routinely available, 
depending on the type and terms of the contract. 

Our prior work also highlights the importance of accounting for and 
providing effective oversight of contractors. A recent report 
concerning the management and oversight of contractor support for 
deployed forces addresses the issue of limited visibility over the 
number of contractors deployed with U.S. forces and potential problems 
with planning for security and logistics needs if the numbers of 
contractors are not known to military commanders in theater.[Footnote 
27] JIEDDO deploys contractor personnel in the theater to assist with 
counter-IED solutions. JIEDDO does not track the number of contractors 
it employs, and yet its May 2007 report indicates that the number can 
significantly affect how JIEDDO uses its resources and plans for future 
needs. 

Conclusions: 

As IEDs continue to pose a significant threat to U.S. forces in Iraq 
and Afghanistan, defeating the threat continues to be a high defense 
priority. This likely will require a continued significant investment 
in resources, both financial and human capital. The volume of resources 
required, coupled with the scale and span of JIEDDO's mission to focus 
all DOD counter-IED efforts, creates a challenge to achieving efficient 
and best use of funding made available to JIEDDO. However, DOD and 
JIEDDO cannot adequately manage JIEDDO's financial and human capital 
resources if it does not have an effective system of internal control 
to provide reliable data and insight into how these resources are 
invested, and external parties cannot be assured that the information 
JIEDDO reports is reasonably accurate, complete, and transparent. 
Consequently, because of the absence of adequate internal controls and 
of a comprehensive efficient method for identifying, tracking, and 
reporting JIEDDO's human capital resources, JIEDDO's systems currently 
cannot efficiently provide the data and insight needed for internal 
management. Further, Congress is limited in its oversight of JIEDDO's 
current and future requirements, the organization's substantial use of 
contractors, and the organization's use of resources to support its 
mission because of the unreliable information JIEDDO has reported. 
JIEDDO officials are not fully aware of how their personnel resources 
are being spent, and cannot fully plan for future workforce needs if 
their baseline information on current funds use and workforce 
composition is inaccurate. Although JIEDDO has taken several actions to 
improve its internal control system, as we noted in this report, these 
actions have not yet been fully implemented. As such, it is important 
that JIEDDO evaluate its recent actions to ensure that they will 
address the control weaknesses we identified and provide for a system 
of internal control that fully meets federal standards. Improving 
JIEDDO's internal controls and the quality of its financial and 
personnel data is critical to assuring Congress and the public that 
JIEDDO is focusing all of its resources and using them wisely to 
address the threat of IEDs to U.S. forces. 

Recommendations for Executive Action: 

To comply with federal internal control standards as well as improve 
the quality of JIEDDO's financial management and the reliability of 
resulting financial data and reports, we are recommending that the 
Secretary of Defense direct the Director of JIEDDO to develop and 
document a comprehensive system of internal control for its financial 
management processes. Actions to develop and implement JIEDDO's system 
of internal control to address specific control weaknesses we 
identified should, at a minimum, include the following: 

* Fully documenting all internal control processes and procedures 
related to its financial management through the development of 
management directives, administrative policies, standard operating 
procedures, or other documentation that describe how JIEDDO personnel 
should perform their duties. 

* Establishing effective controls to ensure that transactions are 
properly authorized before funding is executed, related documentation 
supporting transactions is accurately dated, and exceptions are 
properly approved and documented. 

* Establishing effective controls to ensure that all transactions are 
properly classified by lines of operation and other expenditure 
categories used by JIEDDO, and to promptly and properly correct 
misclassifications when identified. 

* Developing an internal process, to include involvement of its 
internal audit staff, to routinely monitor and review the efficacy of 
JIEDDO's system of internal control and promptly correct any weaknesses 
identified. 

We are also recommending that the Secretary of Defense direct the 
Director of JIEDDO to report to Congress on the status of its efforts 
to implement its comprehensive system of internal control 1 year from 
the date of this report. 

To improve JIEDDO personnel or manpower management and provide Congress 
with the information it needs to perform its oversight duties 
effectively, we are recommending that the Secretary of Defense direct 
the Director of JIEDDO to establish and document a method or system to 
comprehensively identify, track, and report on a routine basis all 
government and contractor personnel. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, DOD concurred with our 
findings and the thrust of our six recommendations. However, DOD did 
not concur with our fifth recommendation as originally stated in our 
draft report, which was to report on JIEDDO's efforts to implement 
internal control improvements as part of JIEDDO's recurring quarterly 
congressional reports. In its response, DOD proposed an alternative 
means for providing this information to the Armed Services and 
Appropriations Committees. DOD said that the focus of its quarterly 
report to Congress is to describe the IED threat and associated counter-
IED efforts, and that adding the additional information we recommended 
would blur the focus of the report. DOD stated that instead, JIEDDO can 
produce and provide a report to the oversight committees 1 year after 
the issuance of our report as to the steps JIEDDO has taken to address 
and correct the weaknesses we identified. We believe that this approach 
satisfies the intent of our original recommendation and consequently we 
modified our recommendation to reflect this change. 

In commenting on our four recommendations dealing with internal control 
and financial management, JIEDDO provided several details of the 
actions it plans or said it has already taken to address the 
recommendations. While we acknowledge that JIEDDO management recognizes 
the importance of addressing the weaknesses we identified in our 
report, we maintain that more needs to be done before the weaknesses 
are fully corrected. For example, regarding our recommendation to 
develop documented internal control processes and procedures that 
describe how JIEDDO personnel should perform their duties, JIEDDO 
responded that it has established and fully implemented an internal 
control system, identifying four specific efforts for illustration. 
However, the specific efforts listed do not fully support JIEDDO's 
statement that needed controls and operating procedures are fully 
developed. One of the efforts cited was JIEDDO's November 2007 
Capability Approval and Acquisition Management Plan instruction. While 
we agree and reported that this instruction is an important step in 
developing documented processes, it does not contain operating 
procedures developed to the level we recommended because JIEDDO 
divisions had not developed and documented roles, responsibilities, and 
specific procedures for implementing the JIEDDO Capability Approval and 
Acquisition Management Plan. As of February 2008, JIEDDO was still 
developing and documenting these roles, responsibilities, and specific 
procedures for implementing the JIEDDO Capability Approval and 
Acquisition Management Plan. Consequently, the degree to which JIEDDO 
has implemented this recommendation is unclear and additional action on 
JIEDDO's part may be needed. 

In commenting on our sixth recommendation regarding establishing and 
documenting a method to comprehensively identify, track, and report 
government and contractor personnel, JIEDDO included extensive 
background information on its existing personnel processes and 
improvement efforts it is undertaking. However, more remains to be done 
in order to fully implement our recommendation. For example, while 
JIEDDO stated that it is in the process of accounting for contractors 
maintaining COIC facilities, JIEDDO did not identify any additional 
efforts to account for the remainder of contractor personnel cited in 
our report or any specific steps it plans to take to establish and 
document a method or system to comprehensively identify and track all 
personnel. Instead, JIEDDO explained that it does not track certain 
classes of personnel working in direct support of JIEDDO because these 
persons are already accounted for by other organizations in DOD. 
Consequently, JIEDDO's insight into its human capital is limited 
because it excludes tracking certain manpower funded by the JIEDDO 
appropriation, such as personnel directly working for the Joint IED 
Defeat Test Board, whose workload is performed exclusively in support 
of testing JIEDDO initiatives. We recognize JIEDDO's comments regarding 
the responsibility of the military, DOD, and other government agencies 
in providing oversight and reporting of their staff who may be assigned 
to work in support of the JIEDDO mission. However, we believe that as 
an organization, JIEDDO has an interest and a responsibility to 
identify, track, and report all civilian, military, and contractor 
personnel working in support of JIEDDO as a matter of good resource 
stewardship and sound human capital management. Any overlapping 
manpower management interests or responsibilities between JIEDDO and 
other organizations could still be recognized and reported with the 
appropriate caveats to users of the information. In its comments 
related to this recommendation, DOD also cited ongoing efforts that do 
not directly address our recommendation as well as several new efforts 
that were not established at the time of our review, and therefore we 
could not validate or consider them for purposes of this audit. DOD's 
comments and our specific responses to them are provided in appendix 
II. 

We are sending copies of this report to the appropriate congressional 
committees and the Secretary of Defense. We will also make copies 
available to others upon request. If you or your staff have any 
questions about 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. GAO staff who 
made major contributions to this report are listed in appendix III. 

Signed by: 

William M. Solis: 

Director, Defense Capabilities and Management: 

List of Committees: 

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Ted Stevens: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
United States Senate: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable John P. Murtha: 
Chairman: 
The Honorable C. W. Bill Young: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
House of Representatives: 

The Honorable Ike Skelton: 
Chairman: 
The Honorable Duncan L. Hunter: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

To assess the Joint Improvised Explosive Device Defeat Organization's 
(JIEDDO) financial management processes, controls, and data, we 
collected data on the $1.9 billion in funds available to JIEDDO for the 
first half of fiscal year 2007 and analyzed associated financial 
management and counter-improvised explosive device (IED) initiative 
data available for management and external reporting of JIEDDO's 
activities. We selected the initial fiscal year 2007 funding provided 
to JIEDDO because it was received after JIEDDO made significant changes 
in its resource management processes and therefore should reflect 
impacts and improvements resulting from those changes. We also 
identified required approval controls over use of funds, reviewed 
selected transactions for compliance with these controls, and assessed 
whether the data recorded in the accounting and managerial systems 
accurately reflected JIEDDO's activities. However, we did not perform a 
comprehensive assessment of all of JIEDDO's internal controls. We drew 
high-dollar initiatives during the scoping phase of the review to more 
efficiently assess the largest portion of JIEDDO's funds use in the 
relatively limited phase. Because the items initially selected included 
little in the way of attack the network initiatives, we added items 
from this line of operations to do control testing. We also reviewed 
large-dollar initiatives approved by the Deputy Secretary of Defense 
that had no recorded commitments at the time our initial data were 
collected for the first half of fiscal year 2007. Because we identified 
weaknesses in the completeness and accuracy of JIEDDO's documentation 
and controls, we did not review the full range of initiatives we had 
originally planned because it would have added no further value for 
purposes of addressing the objectives of this review. Our analysis 
included 47 funding actions totaling $1.34 billion for 24 of the 301 
initiatives JIEDDO had approved at the time we collected our data. We 
selected initiatives to review that reflected the JIEDDO defeat the 
device and attack the network activities as well as some approved most 
recently by the Deputy Secretary of Defense. The 24 initiatives we 
selected were divided into three subsets: 10 counter-IED initiatives 
JIEDDO identified as defeat the device initiatives with the highest 
fund commitments recorded as of the time we collected financial data, 9 
of the 10[Footnote 28] counter-IED initiatives JIEDDO identified as 
attack the network initiatives with the highest fund commitments 
recorded as of the time we collected financial data, and 5 additional 
initiatives that received Deputy Secretary of Defense approval after 
the date we collected our comprehensive funding data to determine 
whether conditions had changed. We also met with officials from 
JIEDDO's Counter-IED Operational Integration Center, the Joint Center 
of Excellence, the Navy Center of Excellence, the Air Force Center of 
Excellence, the Technology and Requirements Integration Division, and 
the Joint IED Defeat Test Board to gather information corroborating and 
explaining the financial activity and documentation related to JIEDDO 
initiatives we tested. 

To assess JIEDDO's efforts to identify, record, track, and report 
numbers of all personnel, including contractors, we met with officials 
from JIEDDO's Secretariat Division who are responsible for the 
organization's personnel management to discuss and obtain information 
on the numbers of JIEDDO personnel, the composition of personnel, and 
JIEDDO's processes for capturing this information. We collected 
information on the numbers of JIEDDO personnel from several personnel 
documents and reports from the Secretariat Division. We reviewed the 
information and selectively compared it with corroborating sources, 
such as interviews with JIEDDO officials and JIEDDO's financial 
documentation, to determine whether the reported figures were 
comprehensive and accurate. We also met with officials from JIEDDO's 
Counter-IED Operational Integration Center, the Joint Center of 
Excellence, the Navy Center of Excellence, the Air Force Center of 
Excellence, the Technology and Requirements Integration Division, and 
the Joint IED Defeat Test Board to gather information regarding the 
numbers of and composition of JIEDDO's personnel. In addition, we met 
with officials in the Office of the Secretary of Defense's Directorate 
for Organizational and Management Planning to discuss the origins of 
DOD Directive 2000.19E. 

We assessed the reliability of JIEDDO's financial data we reviewed by 
(1) corroborating the data with supporting information and 
documentation from physical file records at JIEDDO headquarters and 
from initiative program offices to verify the accuracy of the data, (2) 
reviewing existing information about the data and the system that 
produced them, and (3) interviewing agency officials knowledgeable 
about the data. We found problems with the reliability of the data, 
which we discuss in the report and in part form the basis for our 
recommendations. 

We conducted this performance audit from April 2007 to December 2007 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. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Joint Ied Defeat Organization: 
5000 Army Pentagon: 
Washington DC 20310-5000: 

February 14, 2008: 

Mr. William M. Solis: 
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Solis: 

This is the Department of Defense (DoD) response to the GAO draft 
report, "Defense Management: More Transparency Needed Over the 
Financial and Human Capital Operations of the Joint Improvised 
Explosive Device Defeat Organization," dated 21 December 2007 (GAO Code 
351017). 

JIEDDO would like to thank GAO for its due diligence and thoughtfulness 
in the preparation of this report. Overall, this report provides an 
accurate description of the weaknesses identified during the audit time 
frame with regard to JIEDDO's compliance with internal control 
standards. 

JIEDDO has instituted several processes to strengthen our internal 
control standards and to ensure that financial transactions are 
properly approved and documented. Many of these processes were 
implemented during the audit time frame. Our response provides detailed 
descriptions of current processes and other planned improvements that 
will occur over the next several months. Projected completion dates are 
included in the response. 

My point of contact for this matter is Ms. Lin Malec, Internal Review, 
703-602-4807. 

Signed by: 

THOMAS F. METZ: 
LTG, U.S. Army: 
Director, JIEDDO: 

Branch IOC: 01 MAR 08: 
Branch FOC: 01 MAY 08: 

GAO Draft Report - dated December 21, 2008 GAO Code 351017 â GAO-08-342 

"Defense Management: More Transparency Needed Over the Financial and 
Human Capital Operations of the Joint Improvised Explosive Device 
Defeat Organization" 

Department Of Defense Comments To The Recommendations:  

Recommendation l. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to develop and document a comprehensive 
system of internal control for its financial management processes by 
fully documenting all internal control processes and procedures related 
to its financial management through the development of management 
directives, administrative policies, standard operating procedures, or 
other documentation that describe how personnel should perform their 
duties. 

DOD Response: Concur. 

Before the initiation of the subject audit, JIEDDO had been and 
continues to work diligently to formalize and document processes to 
ensure that internal controls are emplaced within our organization. 
During the audit timeframe, many of these processes were finalized, but 
due to GAO reporting time constraints, they were unable to validate 
these processes. Following are samples of the procedures and processes 
we have finalized, documented and implemented: 

(See comment 1.): 

1) Formation of the Acquisition Oversight Division (AOD) 

The Acquisition Oversight Division was established to support the 
JIEDDO mission to defeat Improvised Explosive Devices (IEDs). AOD 
provides executive program management oversight of Counter-lED (C-IED) 
initiatives; develops and implements acquisition life-cycle management 
policies; and ensures effective transition and transfer of initiatives 
to the Services for sustainment and further integration. 

(See comment 2.): 

The need for an oversight division that applied scrutiny to processes 
and analysis of JIEDDO process methodology for all JIEDDO divisions 
became apparent as JIEDDO began breaking new ground in field of rapid 
acquisition. The AOD systematically reviews programs that have been 
funded by JIEDDO in an established process called (JIEDD) (Joint lED 
Defeat) System Reviews (JSRs). The AOD improves JIEDDO processes by 
offering objective analysis and review from a division reporting 
directly to the Director, JIEDDO. The monitoring of established policy 
and oversight by AOD enhances JIEDDO's overall capability to find 
Counter-IED Solutions and get those solutions quickly assessed and to 
the Warfighter. It assists in the control of documents while seeking to 
match technology gaps. The outcome is improved controls in accounting 
for the prudent spending of funds while assessing metrics and control 
measures throughout the process.

The JIEDDO AOD maintains overall proponency for the JIEDD Capability 
Approval and Acquisition Management Process (JCAAMP); provides 
executive program management oversight and independent assessment of 
initiatives approved by the Director and Deputy Director; develops and 
publishes policies for the development, procurement, testing, 
deployment and initial sustainment of C-IED initiatives; conducts 
JIEDDO System Reviews (JSRs); chairs the JIEDDO Transition Team (JTT) 
and Transition Working Group (TWG); coordinates the transition, 
transfer, or termination of initiatives with the Military Services or 
agencies and oversees the completion of all Transition Packets (TPKs); 
produces JIEDDO future budget programmatic requirements; maintains an 
audit trail for all initiative funding; provides members to serve on 
all JIEDDO IPTs; serves on the Chief of Staff's JCAAMP Council; 
provides oversight for all test and evaluation activities; provides 
oversight of the JIEDD Test Board (JTB); produces all initiative 
funding decision memoranda; provides members to the JIEDDO Joint Urgent 
Operational Needs (JUONS) Review Board (J2RB); and the JIEDDO Special 
Access Program and Additional Compensatory Measures Review Board 
(JSARB). The AOD oversees staff actions related to initiative 
performance, interoperability, and compatibility test activities; 
provides members to the JIEDDO Initiative Evaluation Team (JET); 
establishes policies for testing in support of Initiative Evaluation 
Plans (IEPs) and coordinates test issues related to IEPs with the JTB. 
AOD coordinates with Program Managers and Service test organizations 
for testing support during initiative evaluations and coordinates the 
inclusion of subject matter experts to serve on JIETs. The AOD ensures 
an evolutionary improvement of JIEDDO processes and plans; coordinates 
and provides administrative and logistical support to the JIEDD 
Requirements, Resources and Acquisition Board (JR2AB) and JIEDD 
Integrated Process Team (JIPT); and proposes the evaluation Tier 
development for each initiative. These actions are performed in 
coordination with the ORSA Division Chief. 

Several documents are enclosed to provide more detail describing the 
Acquisition Oversight Process: 

* Acquisition Oversight Division & The Joint LED Defeat Capability 
Approval and Acquisition Management Process;  

* Memorandum for JIEDDO Personnel, Subject: Joint lED Defeat 
Requirements, Resources and Acquisition Board and Joint IED Defeat 
Integrated Process Team Scheduling;  

* JR2AB Scheduling Request Memorandum Example; 

* JR2AB Scheduling Request Memorandum Instructions; 

* Transition Packet Instructions (JR2AB); 

* JR2AB and JIPT Briefing Slides Template; 

* JIEDDO Assessment Readiness Levels; 

2) Published and Implemented JCAAMP Instruction â Joint Improvised 
Explosive Device Defeat Capability and Acquisition Management Process 
(JIEDDOI 5000.1, dated 9 November 2007): 

(See comment 3.): 

JCAAMP is JIEDDO's process to respond to urgent warfighter needs; to 
identify C-IED operational capability gaps; aggressively to seek, 
acquire, and assess potential materiel and nonmaterial solutions to 
these gaps through extensive finding networks; and to place approved C-
lED initiatives in the hands or warfighters for operational assessment 
and deployment. JCAAMP enables a smooth transition or transfer of C-lED 
initiatives to one or more Services or agencies and provides guidance 
on the disposition of those initiatives recommended for termination. 

The JCAAMP instruction defines JCAAMP's roles, responsibilities, and 
oversight requirements as applicable to all JIEDDO components. 
Functional responsibilities described below are not inclusive. JIEDDOI 
5000.01 is enclosed and contains a thorough description of the 
initiative process and associated responsibilities. 

JCAAMP is conducted in three phases â VET, Equip, and Sustain. Each of 
these phases incorporates transition points (TP) representing critical 
activities and decisions that define the path forward through each of 
the three phases. 

JCAAMP's goal is to approve, develop, and acquire initiatives quickly, 
normally within 4 to 12 months. JCAAMP also enables initiative delivery 
for employment by warfighters while conducting operational assessments, 
normally within 6 to 24 months. After an initiative receives a 
successful operational assessment (OA) and a decision on transition, 
transfer, or termination (T3) to a Service or agency has been made, 
JCAAMP manages the remainder of the fiscal year and one additional 
fiscal year of sustainment prior to T3 execution. 

C-IED Urgent Needs and Operational Capability gaps are obtained from 
various sources â principally warfighter JUONs, after action reviews 
(AAR), reports, lessons learned, special access programs, and theater 
visits by senior leaders. Operational analyses, intelligence trends, 
tactical and strategic gaming, the special technical operations 
community, and JIEDDO's finding networks also inform the development of 
needs and, ultimately, may result in the identification all approval of 
C-IED operational capability gaps. JUONs forwarded to JIEDDO by the 
Joint Staff (JS), J-8, are processed for acceptance through the JIEDD 
JUONs Review Board (J2RB) for review by the JIEDDO Chief of Staff's 
JCAAMP Council and acceptance by the JIEDDO Deputy Director. The 
Director, JIEDDO, reviews and approves all C-IED operational capability 
gaps semi-annually. Time critical JUONs may be forwarded directly by 
the J2RB to the Deputy Director with subsequent notification to the 
Chief of Staff's JCAAMP Council. 

JIEDDO leverages aggressive finding networks comprised of industry, 
academia, laboratories, special technical operations, and other 
government agencies to develop potential solutions to urgent and 
operational capability gaps. Most proposed technology solutions enter 
JCAAMP through the Broad Agency Announcement (BAA) Information Delivery 
System (BIDS) and are processed by one of the six Integrated Process 
Teams (IPTs) aligned with JIEDDO's three Lines of Operations (LOO): 
Attack the Network (Atn); Defeat the Device (DtD), and Train the Force 
(TtF). Proposals that do not enter JCAAMP through BIDS, such as 
Commercial Off the Shelf (COTS) and some non-material solutions, are 
submitted by the LOO IPT Leads to the Chief of Staff's JCAAMP Council 
for disposition to the appropriate IPT for further development and 
evaluation. 

Figure: 

[See PDF for image] 

[End of figure] 

TP 1 â Complete assessment of technology merit against capability gaps 
and IPT Leads gain approval as a proposal from the Deputy Director or 
Chief of Staff's JCAAMP Council; 

TP 2 â LOO Chair approval to proceed to JR2AB; 

TP 3 â JR2AB recommendation to proceed to JIEDD Integrated Process Team 
(JIPT); 

TP 4 â JIPT endorsement and Initiative Decision Memoranda signed; 

TP 5 â Decision to deploy for operational assessment by Director; 

TP 6 â Authorize full rate production based on OA report. Decision to 
transition, transfer, or terminate (T3) initiatives, as appropriate; 

TP 7 â Complete transition or transfer of initiatives to Services or 
Agencies; or Terminate. 

JCAAMP Characteristics: 

* Support for flexible points of entry depending on maturity; 

* Effective test and evaluation requirements; 

* Initiative assessment continues after initial delivery to warfighters 

* Continuous risk reduction enforced; 

* Formal acquisition oversight during every phase; 

* The JCAAMP Governance is perhaps the most important part of the 
process to ensure that all initiatives pass though various approval 
levels before a decision is made to commit funding. Every initiative 
must be vetted through the JCAAMP process as follows: 

* JIEDDO Senior Resource Steering Group (SRSG) 

The SRSG is an advisory body to the Deputy Secretary of Defense 
(DEPSECDEF), established to review JIPT-recommended C-IED initiatives 
that are valued greater than $25 million, and to make recommendations 
to the DEPSECDEF for disposition. 

SRSG membership consists of the Principal Deputies of the Under 
Secretaries of Defense, the DOT&E the Principal Deputy ASD(NII); the 
Principal Deputy General Counsel of the Department of Defense; the 
Deputy PA&E the Vice Chief of Staff of the Army, the Vice Chief of 
Naval Operations, the Vice Chief of Staff of the Air Force; the 
Assistant Commandant of the Marine Corps; the Vice Chairman and the 
Joint Chiefs of Staff; the Assistant to the Chairman of the Joint 
Chiefs of Staff, the Director, JRAC; and other members as the DEPSECDEF 
may determine. 

* JIEDD IPT (JIPT); 

The JIPT is an advisory body to the Director, JIEDDO, established to 
consider C-IED proposals after review by the JIEDD Requirements, 
Resources, and Acquisition Board (JR2AB). 

Membership consists of representatives at the Flag or General 
Officer/SES level from the Offices of the Under Secretaries of Defense; 
the ASD (NII)/DoD CIO; the DOT&E the Director, PA&E, the Military 
Services; the Chairman of the Joint Chiefs of Staff and such other 
representatives as the Director, JIEDDO, may determine. 

The JIPT is chaired by the Deputy director and meets weekly to 
recommend further development and funding of a proposal as a C-IED 
initiative; provide comments on transition, transfer, or terminate (T3) 
actions of mature initiatives; ensure synchronization of JIPT member C-
IED efforts and those of other agencies; validate JIEDD efforts 
requiring rapid implementation, acceleration, or development and 
recommend appropriate funding levels to the Director; review potential 
C-IED solutions provided by industry, interagency, and international 
sources when considering appropriate funding levels to the Director; 
review actions of the JR2AB and make recommendations to the Director, 
as appropriate. 

* JIEDD Requirements, Resources, Acquisition Board (JR2AB); 

The JR2AB meets weekly to assess all C-IED proposals forwarded by the 
LOO chairs prior to making any funding recommendations to the JIPT. 
Proposals are evaluated using the following criteria: extent of systems 
integration; military utility and effectiveness; programmatic and 
resource limitations; potential to satisfy and operational capability 
gap; ability to be developed and deployed in JACAAMP-designated 
timeframe; and the degree of risk. Additionally, JR2AB develops 
strategies for integration into the Joint Capabilities Integration and 
Development System (JCIDS); advises the Director, JIEDDO, regarding 
resource and acquisition management matters; reviews the current status 
of program execution and operational fielding of approved JIEDD 
initiatives; monitors coordination between JIEDDO and the appropriate 
Service or agency for the transition of approved C-IED initiatives that 
are deemed only required for the duration of a given conflict or 
theater of operations; and reviews resource requirements and 
appropriate planning documents for establishment of current and future 
funding needs, including out-year funding requirements. 

Membership consists of representatives at the O-6/GS-15/PB3 level from 
the Offices of the Secretaries of Defense; the Director, PA&E the 
Military Services; the Chairman of the Joint Chiefs of Staff, and the 
ASD(NII)/DoD CIO. The Director, JIEDDO, may select additional members 
to serve on the JR2AB and may modify JR2AB requirements with respect to 
JIEDD initiatives, as necessary. 

* Chief of Staff's JCAAMP Council. 

The JIEDDO Chief of Staff, assisted by the Division Chief's and select 
special staff officers, provides oversight of JCAAMP to ensure the 
Director's guidance and priorities are met. 

The Council meets weekly to review JIEDDO's metrics; identify resource 
imbalances, coordinate required management actions to resolve 
outstanding issues and make recommendations for actions by the 
Executive Committee. Additionally, the Council reviews all actionable, 
pending and approved JUONs; reviews operational capability gaps and 
science and technology gaps and recommends changes to JIEDDO 
leadership; reviews BIDS key performance indicators, including the 
processing rate, BAAs in development, and the number of proposals 
received, accepted and rejected that week; reviews that week's JR2AB 
results and forecasted agenda; reviews that week's JIPT results and 
forecasted agenda; reviews the corporate budget and balance; identifies 
tradeoffs between changing budget requirements; reviews all JIEDDO 
initiatives assessed as "Red;" and reviews the transition, transfer, 
terminate actions monthly and review staffing issues. 

* JIEDDO JUONs Review Board (J2RB); 

The J2RB meets weekly to review emergent JUONs and recommends their 
acceptance, rejection or limited acceptance to the Deputy Director via 
the Chief of Staff's JCAAMP Council. The J2RB reviews all JUONs to 
determine the tactical, technical, training, and acquisition readiness 
levels of a proposed solution and develops a recommendation for the 
Chief of Staff's JCAAMP Council and a drafts a decision memo for the 
Deputy Director. 

J2RB membership consists of representatives from JIEDDO's TRID, AOD, 
the JRAC, JCS (J-8) and the supported COCOM. Service Liaison Officers 
and additional subject matter experts relevant to the topic(s) under 
discussion are also included in the meetings to ensure unilateral 
representation resulting in informed, educated decision-making. 

3) Establishment of the Records Management Division; 

(See comment 4.): 

As noted by GAO, internal controls necessitate the completion, 
maintenance and availability of documentation to support decisions and 
transactions accomplished by JIEDDO leadership. The Records Management 
Division was tasked to ensure that JIEDDO personnel are educated on the 
importance of maintaining supporting documentation. 

The JIEDDO Records Management Program provides oversight and assists 
JIEDDO components in the establishment and maintenance of a system for 
maintaining and protecting records in all media. Adhering to statute 
(44 U.S.C. Chapter 31), JIEDDO's Records Management Program has 
accomplished the following: 

* Issued a Records Management Directive and/or Instruction; 

* Instituted training on policies, responsibilities, and recordkeeping 
requirements and ensuring employees understand the distinction between 
records and non-records; 

* Developed and implemented records disposition schedules; preserving 
permanent records and promptly destroying temporary records when their 
retention period expires; 

* Established a Vital Records Program for safeguarding and recovering 
JIEDDO records. 

* At the request of JIEDDO leadership and through coordination with 
Washington Headquarters Services, McNeil Technologies was requested to 
conduct an assessment of JIEDDO's records management policies, 
practices, and procedures. The objective was to establish a baseline 
status. The review occurred during JAN/FEB 2007. The report findings 
are enclosed. 

* The Chief of Staff (CoS) formally designated a JIEDDO Records Manager 
with responsibility for carrying out a Records Management Program. The 
designation letter is enclosed. 

* The Director signed the Directive establishing responsibility for the 
Records Management Program under the Chief of Staff, establishing 
policy and responsibilities for life-cycle management (creation, 
maintenance and use, and disposition) of information as records in all 
media (including electronic), and establishing and authorizing the 
publication of procedural guidance on the management of records within 
JIEDDO. Directive 1015.1A, JIEDDO Records Management Program, is 
enclosed. 

* Records administrative staff, action officers, executive assistants, 
file clerks, and others with regular records duties receive training in 
records maintenance and filing procedures and records disposition. 
Module 1 training (basic course) occurs bi-weekly and is a requirement 
for all employees. Module 2 training (topics: hard copy and electronic 
recordkeeping, AI 15, Naming Convention, shared drives, emails, 
labeling, File Plan, etc.) was conducted on 4 January 2008. It is also 
being executed as a desk-side training session for Division 
administrators. Training slides are enclosed. Module 3 training began 
in January 2008. This course focuses on Action Officer responsibilities 
in handling records. 

* A rigorous Program Plan of Action for Headquarters Records Management 
implementation was developed. The initial operational capability (IOC) 
date for Division administrator central file systems is projected to be 
31 January 2008; for Branch administrator central file areas, the IOC 
date is projected to be 01 March 2008. 

* An electronic file structure was established to capture official, 
final version documents. The output of this process is an electronic 
File Disposition Schedule on JIEDDO's internal J: drive. As of January 
2008, 5,469 files were identified as official records and have been 
placed within this File Disposition Schedule. 

* The Chief of Staff issued a Standardized Naming Convention memo, 
providing direction on the importance of naming electronic files 
properly, along with rules for developing file names and versions. 
Electrons of the memo are enclosed. 

* File Plans were drafted and Division employees are in the process of 
validating the content. 

* The Records Program's Final Operational Capability (FOC) date is 
projected to include an assessment process to ensure employees are 
operating under the guidelines of the program being established. The 
FOC assessment will confirm whether administrators are maintaining 
electronic and hard copy file systems. The assessment will determine 
whether further training/practice is required. 

* Self-evaluation checklists and internal reviews are included in the 
Draft JIEDDO Records Management Handbook. The Draft Handbook provides 
guidance on how the Records Manager, with the assistance of the Records 
Team and Division/Branch records Administrative Staff, will 
periodically evaluate records management practices. Reference: NARA's 
publication Records Management Self-Evaluation Guide, 2001 edition, 
available at [hyperlink, http://www.archives.gov/records-
mgmt/publications/records-management-self-evaluation-guide.html 
]. 

* A draft Management Control Checklist for Records Management is 
underway. The initial draft is enclosed. 

* JIEDDO is in the implementation phase of its Records Management 
Program. Fostering Records Management practices in the JIEDDO culture 
will be a paramount focus. 

* With the support of JIEDDO's senior leadership we are eliciting 
support and adherence from JIEDDO's middle-management and Action 
Officers. There adherence to the new Records Management Program is a 
critical factor in establishing a culture inclusive of Records 
Management processes. 

* The Records Program strategy is in two phases: (1) Division Level; 
(2) Branch Level. The Initial Operational Capability (IOC) and Final 
Operational Capability (FOC) dates are schedule as:

Division IOC: 31 Jan 08; 

Division FOC: 15 Feb 08; 

Branch IOC: 01 Mar 08; 

Branch IOC: 01 May 08; 

4) Implementation of Comprehensive Cost and Requirement System (CCaRs). 

(See comment 5.): 

In 2007 JIEDDO began implementation of the Comprehensive Cost and 
Requirement System (CCaR) used by Air Force, Army, Navy and Defense 
Threat Reduction Agency (DTRA) to manage billions in funding. 

JIEDDO CCaR objectives include: 

* Maintains budget requirement packages/initiatives; 

* Coordinate workflow electronically for MIPRs; 

* Track budgets and associated fiscal years, as well as all 
commitments, obligations, and expenditures providing internal financial 
controls; 

* Ensure STANFINS data (official Defense Finance and Accounting System 
(DFAS) data) is downloaded daily for reconciliation against JIEDDO data 
for validation of accuracy; 

* Provides reporting capability to quickly assess JIEDDO financial 
position by overall budget (macro) or single initiative (micro) 
perspective providing internal financial controls. 

Currently, there is on-going training of Program Integrators in CCaR 
and one-on-one training as necessary. CCaR was installed for the 
Resource Management Budget Execution team enabling the electronic 
preparation of Military Interdepartmental Purchase Requests (MIPRs). 
Full implementation of CCaRs is expected by March 2008. 

JIEDDO CCaR process improvements include: 

* The system will serve as a repository for all new MIPRs; 

* The system eliminates the need to maintain a JIEDDO MIPR log; 

* CCaRs allows Program Integrators/Office Primary Responsibilities 
(OPRs) visibility of their assigned initiatives by Lines of Operation;  

* Requirements gathering for interface with current financial system is 
underway 

* CCaRs ensures that backup Resource Management (RM) staff can execute 
transactions when primary RM staff is unavailable. 

The CCaR is an enterprise program and financial management system that 
will deliver real-time program information to decision makers. At the 
core of the CCaR system are the automated reports and analysis tools 
which allow the program and financial managers to define program 
requirements, formulate program budgets, forecast program execution and 
track the execution of program funds. 

Recommendation 2. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to develop and document a comprehensive 
system of internal control for its financial management processes by 
establishing effective controls to ensure transactions are properly 
authorized before funding is executed, related documentation supporting 
transactions is accurately dated, and exceptions are properly approved 
and documented. 

DOD Response: Concur. 

Funding documents are only released after proper authorization is 
received and documented; i.e. funding memorandums (for less than $25M) 
or Deputy Secretary of Defense approval (for in excess of $25M). In the 
past, there has been some confusion regarding the actual definition of 
the $25M. JCAAMP (described above) clearly defines that the $25M is 
total program costs. There have been instances when the projected total 
costs were under $25M, but it was subsequently determined that the 
actual initiative costs would exceed the threshold. The current process 
requires that as soon as it is determined that an initiative will 
exceed the $25M threshold, an SRSG package is developed and SECDEF 
approval is obtained addressing the increase. 

(See comment 6.): 

In another effort to ensure adequate internal control standards are 
included in JIEDDO processes, RM developed mandatory minimal 
transaction documentation that must be completed and kept on file. For 
example, the JIEDDO RM Funding Request Flow and Required Documents 
package, and the JIEDDO RM Checklist were developed and enclosed for 
your review. The JIEDDO Projects/Initiatives Pending Prioritized 
Listing and MIPRs Listing is updated and published daily. The JIEDDO 
Corporate Report (reporting of expenditures from our "official" 
financial system by each initiative), the Monthly Execution Report 
(compares execution to monthly spend plan by each initiative), and 
Status of Funds is also included in internal daily reporting. 

Because of its charter JIEDDO must respond quickly to requests from the 
field. Supplemental funding is a contributing factor of JIEDDO's 
flexibility. These funds are not "programmed" in a traditional DOD 
fashion but fluid and available where needed to meet approved lED 
Defeat initiatives. For example, JIEDDO's Corporate Report has 
successfully tracked these funds and pointed out errors when funds have 
been improperly executed allowing for detection and correction. 

Recommendation 3. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to develop and document a comprehensive 
system of internal control for its financial management processes by 
establishing effective controls to ensure all transactions are properly 
classified by lines of operation and other expenditure categories used 
by JIEDDO, and to promptly and properly correct misclassifications when 
identified. 

DOD Response: Concur. 

Early in fiscal year 2007, JIEDDO Resource Management (RM) identified 
and corrected inconsistencies with the assignment of Lines of 
Operations (LOOs) to ensure that information being reported in its 
financial reports was correct. JIEDDO currently has the ability to 
accurately determine trends in the use of funds in conjunction with its 
priorities. In an effort to prevent future erroneous postings of LOOs, 
all funding documentation must include the LOO. RM then validates 
against spending plan data to ensure accuracy prior to committing any 
funds in the accounting system. In addition, JIEDDO continues to review 
LOO assignments for individual requirements during each budget review 
and corrections are made as required. 

(See comment 7.): 

As JIEDDO is growing, so is the understanding of operational functions 
and mission. Initiatives recorded in first quarter of 2007 that were 
recorded and reported in one Line of Operation (LOO) and subsequently 
moved and reported in another LOO in later quarters demonstrates 
JIEDDO's informal non-documented continual review of initiatives and 
the reporting thereof. Perspective on what LOO an initiative falls into 
is relative to the familiarity of the initiative/program. JIEDDO 
efforts to accurately report and record transactions are represented by 
our continual improvement. In addition, JIEDDO continues to review LOO 
assignments for individual requirements during each budget review and 
corrections are made as required. 

RM is developing guidance for accounting and budget personnel to ensure 
that correct Elements of Resource (EORs) are used in the recording of 
accounting data. It is important to note that as requirements mature 
their nature may change. In a fluid operating environment technologies 
may cross EOR and LOO definitions and require adjustments in accounting 
information on an individual basis when identified. JIEDDO continues to 
review LOO assignments for individual requirements during each budget 
review and corrections are made as required. The goal is to accurately 
process all financial documentation and when exceptions occur we will 
continue to promptly and properly correct misclassifications and 
document corrective action in official records. 

RM is also in the process of fully staffing the Resource Management 
(RM) Division. The additional essential personnel will allow us to take 
immediate action in correcting the weakness identified in the audit. We 
are currently studying the feasibility of establishing a Policy and 
Quality Assurance Section within RM that will be dedicated to fully 
documenting all internal control processes and procedures related to 
our financial management through the development of management 
directives, administrative policies, standard operating procedures, and 
other documentation that describe specific organizational 
responsibilities. Following is our planned actions: 

Action Item: Establish Desk Guides for each Position within RM (Job 
Title; Job Description; General Description of Daily Duties; General 
Description of Weekly Duties; General Description of Monthly Duties; 
General Description of Unscheduled or Annual Duties); 
Planned Completion Date: 28 February 2008. 

Action Item: Timeline Chart for all RM Requirements/Submissions (I.e. 
for Budget Formulation, Budget Execution, and Accounting);  
Planned Completion Date: 31 January 2008. 

Action Item: Reference Guide to identify Useful Financial Web Sites 
Standard Operating Procedures Documenting the Financial Management 
Process to Resolve Aged Commitments and Unliquidated Obligations 
(ULOs); 
Planned Completion Date: 28 February 2008. 

Action Item: Standard Operation Procedures for the Processing of MIPRs; 
Planned Completion Date: 15 March 2008. 

Action Item: Standard Operating Procedures for the Corporate Report 
process; 
Planned Completion Date: 29 February 2008. 

Action Item: Budget Formulation Guidance; 
Planned Completion Date: 29 February 2008. 

Action Item: Consolidated Funding Package Handbook (i.e. JIEDDO Funds; 
Funding Policy; Funding Package Process; Required Documentation; Travel 
Policy; Accounting Process, etc.); 
Planned Completion Date: 31 March 2008. 

Recommendation 4. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to develop and document a comprehensive 
system of internal control for its financial management processes by 
developing an internal process, to include involvement of its internal 
audit staff, to routinely monitor and review the efficacy of JIEDDO's 
system of internal control and promptly correct any weaknesses 
identified. 

DOD Response: Concur. 

JIEDDO agrees that an adequate internal process to monitor and review 
the efficacy of its internal controls is required. Funds allocated to 
JIEDDO are for the IED Defeat mission within DOD. JIEDDO's primary 
mission is to provide funding to the Military Services and DOD agencies 
to rapidly develop and field counter-lED solutions and is successfully 
accomplishing its mission. Mission accomplishment in this area is not 
the only part of the process. GAO accurately identified weaknesses in 
JIEDDO's internal control process. It is very important to JIEDDO that 
any agency looking at JIEDDO's execution of funds can understand 
funding decisions from the inception of researching an initial idea or 
initiative through documentation of a decision and each stop of the 
approval process. Recognizing our weaknesses, especially in the area of 
maintaining adequate documentation to ensure an accurate transaction 
audit trail, JIEDDO hired an Internal Review Evaluator to have 
continuous oversight over internal controls and recommend improvements 
to correct any identified weakness. The auditor actually came on board 
during the audit timeframe. The auditor reports directly to the JIEDDO 
Director to avoid any conflicts of interest and to maintain 
independence within the organization. The auditor also serves as 
JIEDDO's Management control Administrator. Specific details will be 
addressed later in our comments. 

(See comment 8.): 

Internal Review has incorporated Management Control Training during our 
Block Training sessions for new employees. The importance of the 
training is centered on ensuring that personnel understand the 
importance of internal control standards. A basic overview is provided 
on the Management Control Program so that awareness is instituted at 
all levels of the organization. 

Internal Review has also provided elementary training to all key JIEDDO 
leadership. A training package developed by OAA was provided to 
leadership and successful review of the package was certified. An 
example is enclosed. 

A draft Five-Year Management Control Plan was developed and will be 
provided to JIEDDO leadership for comment and modification. Target date 
for development is 8 February 2008. 

Additional training and instructions will be provided to all JIEDDO 
personnel. Key checklists were developed and are integral piece of the 
Management Control Program. Management Control Administrators and 
Assessable Unit Managers will be identified and targeted training will 
be provided to ensure that checklists are not just completed â but 
actual testing of key controls will be accomplished. Target date for 
completion is 15 March 2008. 

Recommendation 5. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to report to congress on the status of 
its efforts to implement its comprehensive system of internal control 
as part of its quarterly congressional reports. DOD RESPONSE: 
Nonconcur. 

OSD Policy comments best explain the basis for this nonconcurrence. 
JIEDDO's progress in implementing its internal control measures should 
not be reported in the Quarterly Reports to Congress. This report is 
specifically focused on describing the lED threat and JIEDDO's efforts 
to counter that threat. Including JIEDDO's internal "administrative 
efforts" within the report is not in keeping with the intent of the 
report and serves to weaken the report's focus. OSD Policy recommends 
that the Deputy Secretary of Defense direct JIEDDO to provide Ranking 
and Minority leaders of the Armed Services and Appropriations Committee 
with a report within one year from the date of the GAO final report as 
to steps JIEDDO has taken to address and correct the weaknesses 
identified by GAO. 

(See comment 9.): 

As noted throughout JIEDDO comments, many actions have already been 
taken to address these weaknesses. It is our firm commitment to ensure 
that constant improvements are made to strengthen our internal 
controls. 

Recommendation 6. The GAO recommends that the Secretary of Defense 
direct the Director of JIEDDO to establish and document a method or 
system to comprehensively identify, track, and report on a routine 
basis all government and contractor personnel. 

DOD Response: Concur. 

The Joint Improvised Explosive Device Defeat Organization (JIEDDO) was 
established as a temporary, non-institutionalized jointly-manned entity 
by directive of the Deputy Secretary of Defense effective January 18, 
2006. As a temporary entity, the JIEDDO manpower requirement is 
identified and documented on a Joint Manning Document (JMD). Following 
a decision to institutionalize JIEDDO, the JMD identified positions 
will be validated and formally approved on a Joint Table of 
Distribution (JTD). The JTD is a permanent funded authorization 
document that articulates the approved manpower for the organization. 
The JMD is an unfunded temporary document that identifies the specific 
positions required to support a non-institutionalized organization. 
Since JIEDDO is a jointly-manned activity the manpower to support the 
organization's requirements, come directly from the Services and are 
maintained on the Service documents. The JMD replicates the positions 
identified on the Service documents. 

(See comment 10.): 

JIEDDO, though a non-institutionalized jointly-manned entity, does 
comply with the provisions of Department of Defense Directive 1100.4, 
Guidance for Manpower Management. The organization has implemented and 
continues to refine the implementation of the provisions outlined in 
this Directive to include requirements determination, resource 
allocations, manpower authorizations, and manpower planning. 

When JIEDDO was formed, the Army Task Force from which JIEDDO was 
constructed was staffed from temporary personnel resources, primarily 
military and contractor personnel, by the Army. Historical data 
indicates that at the time of transition the Army Task Force consisted 
of 174 billets, of which 99 were contractors, 1 was a SES, and 74 were 
military personnel, including four coalition officers. When JIEDDO was 
formed many of these individuals chose to remain with their parent 
organizations. Most contracted personnel did transfer to JIEDDO. 

At the direction of the DEPSECDEF, JIEDDO set up and conducted a 
Service Manpower Validation Board to review, validate, and authorize 
the manpower to support the JIEDDO requirements. The Board validated 
383 billets. The structure and manpower allocation recommended by the 
Board was approved by DEPSECDEF on 27 Jan 06 as reported to the 
military services in his Memorandum, dated February 14, 2006. The 
Service Manpower Validation Board authorized 129 US military billets, 
39 government civilian billets, five (5) coalition officer billets, and 
190 Contract Manpower Equivalent (CME) billets. Since the establishment 
of JIEDDO the leadership has received approval from the Army for an 
additional 54 government civilian billets (approved May 3, 2007) and 
has pending a request (November 30, 2007) for an additional 39 
government civilian employees. Additionally, the Army approved three 
military billets. Two were approved on May 3, 2007 and the third on 
July 19, 2007. The Navy approved one military billet. Two of those 
billets, the Deputy Director of the COIC and the Chief of the Resource 
Management Division, possess primarily inherently government 
supervisory responsibility over resource management and fiduciary 
oversight of JIEDDO assets. 

(See comment 11.): 

The success of JIEDDO as an organization depends on its ability to 
leverage the capabilities of each person employed within the 
organization. Our strategic human capital plan (encl) is a key step in 
providing our workforce with the means to reach its full potential. A 
copy of the final draft is attached. This plan is comprised of three 
overarching goals with objectives and action steps that can be taken to 
achieve outcomes and initiatives. These three goals are the essential 
first steps that must be in place in order to address the significant 
challenges that we are facing. 

* Goal 1: Build a well-balanced, world-class workforce with the 
knowledge, expertise, and abilities necessary to accomplish JIEDDO's 
mission; 

* Goal 2: Institute a framework of human resource policies and 
processes that model JIEDDO's business approach of rapid, responsive, 
and effective solutions; 

* Goal 3: Construct a physical and technological infrastructure that 
supports JIEDDO's world-class workforce; 

The Secretariat is developing a plan for achieving these goals and 
expects to achieve these goals by 2010. 

JIEDDO from its inception on 18 January 2006 has focused on creating 
the organizational structure best suited for the expanding and ever 
changing mission. The organization recognizes and has taken the 
necessary steps to increase government oversight and fiduciary control 
over all JIEDDO controlled and directed programs. The control and 
oversight of programs, projects, or initiatives controlled and directed 
by the military services and other Department of Defense and government 
departments, including those funded wholly or in part by JIEDDO, remain 
the responsibility of the service or organization overseeing and/or 
operating the program, project, or initiative. The manpower and 
resources applied to these programs are reported by the individual 
services and are not included in the JIEDDO reported manpower and 
resource components. The Service documented manpower is provided in the 
quarterly report to the Congress. 

(See comment 12.): 

JIEDDO is currently undergoing an annual JMD review and validation 
process and expects to validate requirements for an additional 18 
military and 27 government civilian billets to provide enhanced 
government oversight and fiduciary control over the organization's 
resources. This chart identifies the manpower growth by JMD category 
over the two year history of JIEDDO and known projections for the 
future. 

Figure: EVOLUTION OF JIEDDO STAFFING LEVELS:  

This figure is a combination line chart showing the evolution of JIEDDO 
staffing levels. 

[See PDF for image] 

Sources: FY04 data obtained from approval briefing from JIEDDOTF 
manning requirements dated 2 Nov 05. FY05 data obtained from a JIEDDO 
Billet Staffing Summary dated 30 January 2006. FY06 data based on 
authorized JMD positions dated 14 February 2006. FY07 Data based on 
authorized JMD positions dated 3 May 2007.

[End of figure] 

As noted in the above chart, JIEDDO in its short two-year existence has 
focused on increasing the number of military and civilian billets 
required to ensure proper resource and fiduciary oversight. In the 
first year (FY06), JIEDDO requested and received Army support for an 
additional 54 government civilian billets and three (3) Army military 
billets to perform inherently governmental functions. The US Navy 
provided one (1) senior military billet to oversee our Resource 
Management Division. This represents an increase of 135 percent in 
manpower billets associated with government oversight of JIEDDO 
resources. In the second year, JIEDDO requested an additional 39 
government civilian billets (encl). This request is still pending at 
the Army. JIEDDO has also initiated a JMD review to determine areas 
where additional government oversight would be warranted. The review is 
still on-going but the organization has identified 57 additional 
government positions that if supported by the Army will further enhance 
the performance of inherently governmental responsibilities. It is 
expected that after a detailed review by the JIEDDO senior leadership, 
the requests for additional manpower will be submitted to the 
respective military services for consideration. The civilian billets 
will be requested from the Army as it is the executive agent for 
civilian personnel support. The formal submission is expected to be 
released in late March 2008. 

JIEDDO's official JMD authorizes 192 contractors (Contract Manpower 
Equivalent) s. The Service Validation Board in Jan 2006 approved 190. 
Two additional CMEs were requested in February 2007 and supported in 
May 2007 by the Army. The CME program was established by the Department 
of Defense to compensate for the lack of sufficient government civilian 
billets. In the current annual JMD review, the JIEDDO staffs have 
identified an additional eight CME billets to enhance operational 
oversight of JIEDDO programs and initiatives. In addition to the CMEs 
authorized in the Joint Manning Document, JIEDDO employs other 
contractor personnel under various contract instruments. These 
additional contractor billets are necessary to support JIEDDO 
initiatives, programs, projects, and provide administrative support and 
are categorized as Below-The âLine (BTL) and constrained by funding 
limitations. At the request of the GAO and in an effort to provide 
further clarification, the BTL category was further broken out into 
IAPT, LOEs, and BMS. The following definitions previewed with the GAO 
are consistently applied in accounting for manpower and ensures a 
commonality in reporting: Joint Improvised Explosive Devise Defeat 
Organization (JIEDDO) Manpower Definitions: 

1. Joint Manning Document (JMD) 

* JIEDDO Manning; 

- Military, government civilians, and Contractor Man-year Equivalent 
(CME) personnel reflected in the approved JIEDDO JMD (3 May 2007); 

- Serve as the baseline around which appropriate structures are built 
to address critical integration missions; 

- Standard Joint Task Force Headquarters (SJTFHQ) â Counter-IED 
Operations Integration Center (COIC); 

- Core element of military, government civilian, or CME personnel 
assigned to the COIC; 

2. Basic Mission Staff (BMS) and Below the Line (BTL) Contractors; 

- Augment the JMD approved counter IED mission staff, providing 
additional capability in support of the JIEDDO mission; 

- Approved by the JIEDDO senior leadership based on available funding 

3. Partners; 

* Liaison Personnel (LNO) 

- Representatives of external agencies that provide interagency 
assistance in support of the JIEDDO mission; 

- Individuals are normally military, government civilian employees, or 
contractors; 

- Support is funded by the parent agency. JIEDDO may reimburse salary 
and travel related expenses; 

* COIC-Interagency partnership Team (IAPT); 

- Individuals that represent agencies involved in the integration of 
external capabilities in support of the counter-lED mission; 

- Individuals may be military, government civilians, or contractors 
with the appropriate experience and access; 

- JIEDDO may fund salary and/or travel expenses as agreed jointly by 
the represented agency; 

* Interns; 

- Students or recent university graduates participating in a supervised 
program, attached to JIEDDO, to gain knowledge and insight in the 
JIEDDO concept of operation and JIEDDO sponsored programs; 

4. Level of Effort (LOE) (Interim Mission-based Capability); 

- Individuals that are retained to provide mission essential support on 
an interim or limited term basis to support the execution of specific 
elements of the mission; 

- Individuals provide support through an approved government services 
contract vehicle providing level of effort support for requirements for 
various programs for a defined duration in support of the warfighter. 

5. Field Service Representatives; 

- Individuals retained as part of a services contract to install, 
maintain, and service procured or contracted equipment and software 
programs. 

- Services are provided on an as needed basis. 

These definitions were approved by the JIEDDO senior leadership and 
have been frequently disseminated to the JIEDDO staff. It is 
understandable that one might find individuals who are not directly 
involved in the manpower management process that may not fully 
understand the meaning of these definitions. JIEDDO will make every 
effort to ensure wider dissemination of these definitions. 

A report to the Congress on the manpower authorized on the JMD to 
support the JIEDDO mission is submitted on a quarterly basis in 
response to language in the annual Department of Defense Authorization 
and the Department of Defense Appropriations bills. These reports, at 
the direction of the Department, are also used to report the manpower 
applied, funded, and controlled by the military services in support of 
the Department of Defense counter-IED mission. The service manpower 
contributions are applied by the services to support their internal 
counter- lED programs and are not part of the manpower used to support 
JIEDDO counter-lED programs, projects, and initiatives. Therefore, the 
service internal counter-lED manpower component is not accounted or 
documented on the JIEDDO JMD or manning document. In some cases, JIEDDO 
funding supports initiatives under the management and direction of the 
Services. In these instances, the Services normally account for and 
report the manpower contributions. 

JIEDDO also responds regularly to manpower data requests from the 
Congress and other Departmental and government agencies. As an example, 
the Report to the Congress in May 2007 requested in the FY 2007 Senate 
Appropriations bill asked JIEDDO to report all assigned civilian, 
military, and those individuals detailed from other agencies. The 
report also asked for an accounting of "all contractor support that is 
provided through various contracts." In the report, JIEDDO provided 
full accountability for all manpower billets and personnel. 

The Report suggests that JIEDDO does not include field service 
representatives, interagency liaisons, law enforcement training 
personnel, interagency partnership team members and infrastructure 
contractors working at the Counter-lED Operational Integration Center. 
The charts below from the Senate Report were provided to the GAO in 
response to a request for this data. It covers interagency liaisons, 
law enforcement training personnel, and interagency partnership team 
members. 

(See comment 13.): 

Table: 

[See PDF for image] 

[End of table] 

In an effort to provide complete transparency, JIEDDO solicited and 
obtained from firms under contract to provide services for JIEDDO 
supported programs and initiatives the number of Full Time Equivalent 
(FTE) manpower required to accomplish the contracted support. The firms 
translated the FTEs into manpower equivalents for the May 2007 report 
to the Congress. Normally under Part 37 "Service Contracting" of the 
Federal Acquisition Regulation (FAR) the effort expended in support of 
such contracts are reported as the number of FTEs. For the May 2007 
report to the Congress the FTEs represented the equivalent of 474 
manpower equivalents. 

Table: 

[See PDF for image] 

[End of table] 

Section 37.102 of the FAR indicates that performance-based acquisition 
(see subpart 37.6) is the preferred method for acquiring services 
(Public Law 106-398, section 821). JIEDDO's contracted support falls 
within this definition. In order to fill approved Contractor billets, 
JIEDDO works hand in hand with various DoD Contracting Agencies in 
order to ensure that those contracts that are let are done so in 
accordance with the guidelines detailed with FAR 37.1 and 37.2. 
Furthermore, surveillance plans are utilized to provide a guide to 
systematically and effectively monitor the contractor's performance to 
ensure compliance with the terms and conditions of the contract. The 
Contracting Officer's Representative (COR) documents the contract file 
with sufficient information to support decisions to exercise option 
years and outline corrective procedures to be taken against the 
contractor for deficient performance and determine if and when the 
government should intercede or terminate the contract." 

JIEDDO also applies the definitions outlined in the FAR in categorizing 
the contracted manpower that is applied to directed, funded, and 
supported programs and initiatives. The JIEDDO definition cited above 
are consistent with the intent of the FAR. These definitions were 
previewed with the GAO team prior to being implemented. 

The chart below was provided to the GAO in October. Subsequent updates 
were also provided. 

The manpower management process is overseen by the Chief of the 
Secretariat supported by a staff of manpower and personnel subject 
matter experts within the Secretariat and within the supported 
divisions and the two agencies. All requirements are reviewed, 
assessed, validated, and justified prior to submission through the 
Joint Improvised Explosive Device Defeat (JIEDD) Capability Approval 
and Acquisition Management Process (JCAAMP) process to the senior 
leadership for consideration. To refine the processes and to help 
validate the requirements, JIEDDO employs an outside agency to work 
with the requesting organizational entities. Each manpower proposal is 
reviewed to ensure that the tasks are properly identified and 
categorized and the manpower requirement properly articulates the 
capabilities required to perform the task. Following the review and 
assessment by the Secretariat staff and the outside agency, the 
requirement is entered into the JCAAMP process. 

Through the JCAAMP process, all manpower requirements identified by the 
organizational entities and validated by the Secretariat are reviewed 
by the COS Council and presented to the Executive Committee for 
consideration and approval. The COS Council consists of representatives 
of each of the JIEDDO Divisions, the Joint Center of Excellence (JCOE), 
and the Counter-IED Operational Integration Center (COIC). The 
Executive Committee includes the Director, the Deputy Director, the 
Deputy Director for Operations and the Deputy Director for 
Intelligence. The JCAAMP process ensures that manpower and other 
resource requirements are appropriate and adequate and comply with the 
intent of the provisions of DoD 1100.4 and all other issuances of the 
Department of Defense associated with the management of departmental 
manpower and resources. 

JIEDDO manpower requirements are generally related to new programs, 
initiatives, and projects developed in response to the ever-changing 
improvised explosive device threat. JIEDDO manpower requirements are 
driven by workload required to perform specific tasks as defined by the 
program, project or initiative approved by the JIEDDO senior 
leadership. Such proposals, projects and initiatives go through a 
series of detailed review and analysis prior to approval by the senior 
leadership. These include the JCAAMP, the JROC, JR2AB, JIPT, the SRSG 
and various internal and external Departmental oversight committees 
prior to approval. For programs and initiatives, in excess of 25 
million dollars additional approval processes exist that require 
approval at the Secretary level. Manpower requirements associated with 
staff and infrastructure requirements are reviewed through the JCAAMP 
process, which includes review by the COS Council, the Executive 
Committee, and final approval by the Director. All manpower 
requirements are proposed and sustained at the lowest level possible to 
ensure the accomplishment of the mission. Additionally, JIEDDO manpower 
is revalidated annually as part of the Annual JMD Review process. The 
2007 JMD Review assessed approximately 100 new manpower requirements 
but only approved 29 additional permanent civilian billets, 25 
temporary civilian billets and 4 military billets for submission to the 
Services for consideration. Because of the revalidation of 
requirements, several of the new requirements were met by the 
redistribution of existing manpower assets. A similar review is 
currently on-going for 2008. 

As an example of the level of effort taken to validate new manpower 
requirements, the Counter- IED Operational Integration Center (COIC) 
recently contracted for a Personnel Management Review that sought to 
validate the organization's missions, functions statements, and 
manpower requirements. The organization applied the workload standards 
accepted by the Officer of the Secretary of Defense Policy and 
Requirements, the Office of the Secretary of Defense Program Analysis 
and Evaluation, and the Joint Staff in determining manpower 
authorizations. The analysis captured total workload performed by 
existing personnel and developed appropriate Full time Equivalent (FTE) 
requirements for each task. The standards were applied to each of the 
organizational elements producing an accurate assessment of the 
manpower needed to achieve the missions assigned. This detailed 
analysis was used to support the organization's manpower request 
submitted for consideration in the current JMD Review. 

The Report notes a preference on the part of the JIEDDO leadership to 
employ contractor personnel rather than government civilians and 
military personnel. JIEDDO has been aggressively taking the necessary 
steps to increase the number of military and civilian billets required 
to provide effective government oversight. However, the time required 
to obtain the additional billets has forced JIEDDO to rely on 
contractor personnel to fill temporarily requested government civilian 
requirements. JIEDDO since its establishment has requested 54 
additional government civilian billets, has pending with the Army a 
request for 39 additional government civilian billets and is currently 
reviewing a potential request for 27 additional government civilian 
billets. The timelines for establishing, classifying, and hiring 
government civilians does not lend itself to expeditious filling of 
critical manpower billets. The timeline for obtaining approval of 
additional billets normally exceeds 165 days. Following the approval of 
a billet, the average processing time to fill such valid vacancies, 
from initiation of position classification to selection, was an 
additional 171 days. As an example, in the May 2007 time period 56 of 
the 93 JIEDDO billets were vacant. Today, JIEDDO has 46 vacant 
government civilian billets. The hiring process was further exacerbated 
by the quality of the applicants and unattractiveness of the 25 Term 
billets with limited appointments. Further challenging the process is 
the need for highly specialized scientific and professional skills 
required by JIEDDO's unique mission. Such time lags in the recruitment 
processes have placed a significant strain on the organization's 
ability to meet its government oversight and fiduciary 
responsibilities. 

(See comment 14.): 

JIEDDO has solicited the help of senior Army and Defense officials in 
an effort to shorten the hiring process timelines and to ensure that 
the best qualified individuals are recruited and hired. With the 
assistance of the Deputy Under Secretary of Defense for Civilian 
Personnel Policy, the Army appointed a "Strategic Advisor" to assist 

JIEDDO in addressing civilian personnel management issues. The Chief of 
the Secretariat has initiated a weekly reporting process providing the 
Civilian Personnel Advisory Center (CPAC) the status of pending 
civilian personnel actions that: (1) require CPAC classification, (2) 
require job announcements, (3) are awaiting release of a referral list, 
(4) awaiting the extension of a Tentative Job Offer (TJO) following 
selection, (5) awaiting a Firm Job Offer (FJO) after the TJO has been 
accepted, and (6) the positions where FJOs have been accepted but a 
report date has not been established. This is intended to ensure that 
both the CPAC and JIEDDO have a firm accountability of pending hiring 
actions. 

While these actions have provided some relief to the hiring process, 
the timelines for hire have not improved substantially. Pending the 
approval of the current request under consideration by the Army JIEDDO 
will have 85 vacant government civilian billets that will require 
expeditious recruitment and hire. 

The GAO report cites several examples of individuals not accounted for 
on the JIEDDO JMD and manning document. The report cites the staff of 
the Joint Testing Board as one example. This agency is an element of 
the Army and is accounted for on their Table of Distributions and 
Authorizations (TDA). While it is recognized that JIEDDO provides some 
funding for this organization, its primary mission is in support of the 
Army. The report also cites the use of contractors to pilot unmanned 
aerial vehicles. The program that these individuals are involved with 
is managed by the Army as well. As noted earlier, Service manpower 
contributions that are applied by the Services to support their 
internal counter-lED programs are accounted for and reported by the 
Services. Since the Joint Test Board is an Army entity it is not 
accounted or documented on the JIEDDO JMD or manning document. 

(See comment 15.): 

As noted earlier field service representatives based on the contract 
vehicle that solicits the service being provided are tracked as Full 
Time Equivalent (FTE) effort applied to perform the contracted tasks. 
The report to the Senate included the FTE's converted to actual 
manpower applied to these functions on 1 May 2007. JIEDDO recognizes 
that the tasks contracted for drives the level of manpower contribution 
required to achieve the contracted service and that the level of FTE 
will or may fluctuate on a daily basis. The report to the Senate was an 
attempt to provide visibility on this category of support and was not 
intended to reflect a continuous manpower commitment associated with 
the specific service contracts. JIEDDO does track the FTEs associated 
with the effort of field service representatives and complies with the 
guidance outlined in the Secretary of the Army direction on accounting 
for contract services as outlined in the Secretary's guidance of 7 
January 2005. JIEDDO also complies with the manpower accountability 
requirements outlined in the Federal Acquisition Regulation. 

Since the Army is the executive agent for support of JIEDDO, the 
command recognizes the responsibility to apply the Army guidance on 
contracting and has systematically taken the necessary steps to 
transition all contracts under the Army contracting system. JIEDDO has 
been working diligently to implement the provision of the Secretary of 
the Army Memorandum of 7 January 2005 that outlines the procedures for 
accounting for contract services. As these programs are transitioned to 
the Services, the provisions of the Army guidance are applied 
consistent with the policies for contracting of services outlined in 
the Federal Acquisition Regulation. Additionally as programs are 
transferred to the Services, the control, funding and accountability 
are also transferred. As an example, this fiscal year, the Law 
Enforcement Program will be transferred to the Army. Once the transfer 
is completed, the manpower and funding associated with this program 

will be reported by the Army and not JIEDDO. 

The Report notes that the contractors maintaining the infrastructure at 
the Counter-IED Operational Integration Center (COIC) are not being 
accounted for on the JIEDDO JMD and manning documents. The facility 
occupied by the COIC is contracted for by the Office of the Secretary 
of Defense (OSD). The facility houses other government agencies. The 
manpower associated with support of this facility also services the 
other agencies. JIEDDO recognizes and has begun to track the manpower 
specifically associated with the JIEDDO occupied portion of the 
facility. The actual number of individuals involved in this process 
attributed to JIEDDO support is under negotiation between JIEDDO and 
the OSD. Once this number is validated manpower that specifically can 
be attributed to the support of JIEDDO will be tracked on the JIEDDO 
manning document. 

JIEDDO has continuously and systematically applied additional controls 
to the management of the manpower associated with the command's 
program, projects, and initiatives. As an example, in November 2007 
JIEDDO migrated all civilian billets under the National Security 
Personnel System (NSPS). The NSPS strengthens our ability to accomplish 
the mission in an ever-changing national security environment and 
accelerates the Department's efforts to create a Total Force (military, 
civilian personnel, Reserve, Guard, and contractors), operating as one 
cohesive unit, with each performing the work most suitable to their 
skills. NSPS provides a human resources system that appropriately 
recognizes and rewards our employees' performance and the contributions 
to the JIEDDO mission. 

JIEDDO has also instituted the Manpower Staffing Request System within 
the JCAMMP program to formalize the management of new manpower 
requirements. The purpose of the JIEDDO MSRF is to provide an 
efficient, centralized, and automated method for requesting additional 
manpower and personnel. JIEDDO has formulated and published common 
manpower definitions cited earlier to provide consistency in the 
application of manpower resources. 

(See comment 16.): 

JIEDDO has also issued various policy statements that refine the 
manpower management process. As an example, Policy Memorandum 25 
provides guidance on the selection and hiring of GS/GG 14 and 15s 
setting standards for the selection processes and mandating Deputy 
Director review prior to final selection. Policy Memorandum 24 set 
policy for the reimbursement of PCS expenses as a recruitment tool. The 
entitlements provided in each case will be in accordance with the 
policies published by the Department of the Army as executive agent for 
our civilian component. 

Policy Memorandum 20 establishes management controls, rules, methods, 
procedures, and devices to be used to ensure that business is conducted 
ethically. These controls assure the JIEDDO leadership that resources-
military and civilian personnel, property, and funds are employed and 
accounted for properly. The JIEDDO management control process ensures 
the periodic evaluation of the organization's most critical controls. 
The management control process also provides a means for disclosing any 
shortcomings detected. The process involves assessing safety 
operations, safeguarding resources, complying with laws and policy, and 
using resources efficiently and effectively. The process also helps 
identify vulnerabilities and minimize risks. Management controls are a 
leadership responsibility and an essential part of being prudent 
stewards of the organizations limited resources. 

Policy Memorandum 13 provides guidance on duty hours, overtime, 
compensatory time and other administrative policy applicable to the 
staff. Memorandum 16A speaks directly to the control of personnel 
requiring that all civilian employees and contractor report the hours 
worked in support of JIEDDO initiatives. The effort was initiated to 
obtain a clear understand of the workload required to support the 
JIEDDO missions. 

Policy Memorandum 28 requires that all JIEDDO activities that seek to 
propose organizational changes to include; internal organizational 
structures, manpower increases, and/or recategorizations or 
reallocations of manpower or personnel must submit through the 
Secretariat a formal proposal for review by the COS Council and 
approval for the Director. The underlying guidance recognizes that with 
the unique challenges brought on by the counter-lED fight, there is a 
need to reflect on the organizational structure, manning, and processes 
that have supported our efforts. There is a realization that the 
organization must evolve in response to the ever-changing threat but 
such an evolution must be structurally sound. The policy also 
recognizes that such evolution should not disrupt the synergy that has 
been the underpinning of our successes. Finally, the policy recognizes 
that any structural changes be responsive to the mission and to the 
needs of the individuals who are dedicated to the resolution of the IED 
problem. 

Another action initiated by JIEDDO was to institute a formal records 
management program (mentioned earlier in our response). JIEDDO 
Directive 1015.1A outlines the responsibilities for life-cycle 
management (creation, maintenance and use, and disposition) of 
information as records in all media, including electronic. This 
includes the documentation supporting the management of manpower. While 
in the infancy, the program will help to ensure that all manpower 
requirements are appropriately documented and reinforce JIEDDO's effort 
to enhance accountability of the organization's manpower. 

JIEDDO is also in the process of developing and instituting matrices to 
enable an assessment of the organizational functions, missions, goals 
and processes. These matrices will reinforce the manpower and personnel 
management processes insuring that manpower resources are allocated to 
the most needed requirements and to provide increasingly granular 
alignment of resources against missions. The data will also support the 
development of manpower requirements. This will support the development 
of a synergy in the application of manpower and personnel. It is 
expected that a fully developed matrices system will be in place by the 
end of 2009. 

These initiatives have had a positive affect on the ability of the 
organization to effectively manage and oversee the manpower and 
personnel programs. JIEDDO had and will continue to work systematically 
to enhance its oversight and accountability of all categories of 
personnel and to refine policies, procedures, and processes to manage 
the command manpower and personnel resources.

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

The following are our comments on the Department of Defense's (DOD) 
letter dated February 14, 2008. 

GAO Comments: 

1. DOD states that before our audit commenced, JIEDDO had worked 
diligently to formalize and document its processes to ensure that 
internal controls were in place. Further, DOD asserts that "many of 
these processes were finalized during the audit timeframe," and then 
lists details on four specific "samples" where JIEDDO has "finalized, 
documented and implemented processes and procedures." While we 
recognize that JIEDDO has undertaken efforts to improve its operations 
and resource management, the specific efforts described in DOD's 
comments overstate the status and degree of implementation regarding 
these four "samples." Specifically, responses 2 through 5 summarize our 
conclusions regarding the status and potential effectiveness of JIEDDO 
"samples" contained in DOD's comments. 

2. Before our review began in May 2007, JIEDDO planned to spin off part 
of an existing division to form a new acquisition oversight division. 
JIEDDO did not identify the planned division as relevant to our audit 
objectives, and while we were aware of the plans for the new division, 
we did not see documented objectives, plans, or policies describing the 
division's role or purpose. The first policy document JIEDDO issued 
outlining the oversight division's responsibilities was a broad 
instruction issued in November 2007, which was too late for us to 
review in the conduct of our audit. Further, as of mid-February 2008, 
JIEDDO was still drafting a roles and procedures manual to implement 
the instruction's requirements for the new division, and none of the 
five civil service positions planned for the division had been 
filled.[Footnote 29] Consequently, this particular "sample" cited in 
the DOD comments does not by itself support the statement that JIEDDO 
has "finalized, documented and implemented processes and procedures." 

3. JIEDDO issued this instruction to define and implement JIEDDO's 
"rapid acquisition management responsibilities" established in its 
charter documents and presented to us when we met to close out our 
fieldwork.[Footnote 30] To follow up on the comprehensiveness of the 
instruction related to the internal control weaknesses we identified 
during our review, we had brief follow-up conversations with JIEDDO 
personnel involved in the development of the instruction. At that time, 
we determined that specific steps regarding addressing the control 
weaknesses identified were not fully developed because JIEDDO divisions 
had not yet documented or developed the specific roles, 
responsibilities, processes, and procedures at the division level. 
Further, JIEDDO had not yet identified the persons who would 
participate in developing and drafting proposed division-level 
instructions for coordination and approval. One official stated that to 
have done so before issuing the instruction would have delayed issuance 
by 1 to 2 months. As with the prior item cited in DOD's comments on our 
recommendation, this instruction does not by itself support the 
statement that JIEDDO has "finalized, documented and implemented 
processes and procedures." 

4. While JIEDDO has established the Records Management Division in 
recognition of the importance of good documentation, it is still an 
effort in development and not fully implemented. The comments provided 
state that some elements of JIEDDO's records management processes and 
procedures are still in draft and are not scheduled to be initially 
operational until March 2008 or fully operational until May 2008. Based 
on DOD's comments, we again conclude that establishment efforts for 
this division do not support the summary statement that JIEDDO has 
"finalized, documented and implemented processes and procedures." 

5. JIEDDO is in the process of adopting a new financial management 
system, adapted from an existing system, and is expecting full 
implementation of the new system by March 2008. While JIEDDO has 
identified the objectives of the new system and lists expected 
improvements for the organization, the comments clearly indicate that 
all requirements for the new system have not yet been gathered, which 
makes full implementation by March 2008 uncertain. Further, given the 
tasks yet to be accomplished for full implementation, JIEDDO's new 
system status does not support the summary statement that JIEDDO has 
"finalized, documented and implemented processes and procedures." 

6. DOD states emphatically that funding authorizations are always made 
and documented according to the criteria in JIEDDO's charter directive. 
As we reported, this was not the case for the items we selected in our 
review. DOD identified a new resource management checklist in its 
comments, and while it constitutes a new control measure that is a 
positive step, we were not able to test compliance with the new control 
or assess its effectiveness. 

7. JIEDDO's reasons for initial assignment and change in its lines of 
operations accounting do not address the specific inconsistency and 
potential impact on the reliability of its financial reports that we 
reported when JIEDDO moved Joint IED Defeat Test Board expenses to its 
attack the network line of operation. Further, changes in controls over 
recording of fund use into expenditure categories or lines of operation 
are either still in development or were not sufficiently developed for 
us to evaluate their effectiveness in meeting our recommendation's 
intent. 

8. DOD's statements acknowledge JIEDDO's internal control weaknesses. 
The actions proposed and those already taken, if fully implemented, 
would substantially address the intent of our recommendation. 

9. Expressing full agreement with the findings in our report, DOD 
proposed an alternative approach for communicating the status of its 
efforts to Congress. We agree that DOD's approach for reporting its 
progress in implementing internal control measures satisfies the 
overall intent of our recommendation. Consequently, we modified our 
original recommendation to reflect this change. 

10. JIEDDO outlines steps that it is taking toward identifying and 
tracking civilian, military, and contractor personnel and to improve 
its personnel management practices that we highlighted in our report. 
While a positive first step, other efforts are needed to 
comprehensively account for all personnel, as noted in comments 11 
through 16. 

11. JIEDDO introduces processes that do not directly address our 
recommendation. We were aware of the development of JIEDDO strategic 
human capital plan, and based on our review of JIEDDO's working 
documents, we concluded that the strategic human capital plan would not 
directly address the extent to which JIEDDO would identify and track 
all of its personnel. Also, JIEDDO had not instituted prior to the 
conclusion of our audit its Manpower Staffing Request System within the 
JCAAMP program to formalize the management of new manpower 
requirements. While these steps may assist JIEDDO in improving its 
personnel management, they do not directly address our recommendation. 

12. We recognize and understand DOD's comments regarding accounting for 
JIEDDO personnel who staff programs under the control and direction of 
the military services and other DOD and government departments, 
including those funded wholly or in part by JIEDDO. However, we believe 
that as an organization, JIEDDO has an interest in accounting for all 
civilian, military, and contractor personnel working in any capacity 
for JIEDDO, as a matter of sound personnel management. This information 
can be collected and reported with caveats stating that the personnel 
are, in whole or part, funded by JIEDDO. 

13. DOD noted that our report suggested that JIEDDO does not account 
for categories of contractor personnel, such as field service 
representatives, interagency liaisons, law enforcement training 
personnel, interagency partnership team members, and infrastructure 
contractors, and stated that the information was included in the Senate 
report. During our audit and as stated in our report, we recognized 
that this information with the associated charts was included in the 
Senate report, but we found that it was not included in any of JIEDDO's 
personnel documentation or daily staffing reports prior to the 
development of the Senate report. As a result, we questioned why JIEDDO 
did not account for these categories of personnel in its daily staffing 
reports or in other personnel documentation. 

14. DOD explained JIEDDO's challenges in hiring staff and the steps it 
is taking to increase the number of military and civilian billets and 
to facilitate the hiring of civilian employees by working with the Army 
and the Office of the Secretary of Defense. While these steps appear to 
address our recommendation and other areas of concern, we cannot 
validate the information because these steps occurred after we 
completed our audit. 

15. We disagree with DOD's statement that JIEDDO provides some funding 
for the staff of the Joint Test Board. According to financial 
documentation we obtained and corroborated with interviews, the Joint 
Test Board's primary mission is to provide support to JIEDDO as stated 
in JIEDDO's charter, DOD Directive 2000.19E. 

16. See comment 11. 

[End of section] 

Appendix III GAO Contact and Staff Acknowledgments: 

GAO Contact: 

William M. Solis, (202) 512-8365 or [email protected]: 

Acknowledgments: 

In addition to the contact named above, the following individuals made 
contributions to this report: Cary Russell, Assistant Director; Grace 
Coleman; Eric Essig; Paul Kinney; Ronald La Due Lake; Stephen Lipscomb; 
Lonnie McAllister; Paulina Reaves; James Reynolds; Brian Shiels; Glenn 
Slocum; Yong Song; and John Strong. 

[End of section] 

Footnotes: 

[1] Congressional Research Service, Improvised Explosive Devices (IEDs) 
in Iraq and Afghanistan: Effects and Countermeasures (Washington, D.C.: 
Aug. 28, 2007). 

[2] S. Rep. No. 109-292 at 239-40 (2006). 

[3] GAO, Defense Management: A Strategic Plan Is Needed to Guide the 
Joint Improvised Explosive Device Organization's Efforts to Effectively 
Accomplish Its Mission, GAO-07-377C (Washington D.C.: Mar. 28, 2007). 

[4] DOD Directive 1100.4, "Guidance for Manpower Management," para. 
4.4.10 (Feb. 12, 2005). 

[5] S. Rep. No. 110-37 at 26-27 (2007). 

[6] DOD uses MIPRs as the primary documents to order goods or services 
from other DOD components. MIPRs are prepared on DD Form 448, "Military 
Interdepartmental Purchase Request," and include a description of the 
supplies or services requested, unit price, total price, period of 
performance, and fund citation. 

[7] In this case, the acquiring department would be one of the military 
services and the requiring department would be JIEDDO. 

[8] OMB Circular A-123, Management's Responsibility for Internal 
Control, Section I (2004). 

[9] 31 U.S.C. Â§ 3512 (2007). 

[10] GAO, Internal Control: Standards for Internal Control in the 
Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999). 

[11] S. Rep. No. 110-37 at 26-27 (2007). 

[12] DOD Directive 1100.4, "Guidance for Manpower Management," para. 
4.4.10.1 (Feb. 12, 2005). 

[13] S. Rep. No. 110-37 at 26-27 (2007). 

[14] GAO/AIMD-00-21.3.1. 

[15] We have issued many reports that highlight the importance of 
addressing internal control weaknesses. For example, see GAO, Premium 
Class Travel: Internal Control Weaknesses Governmentwide Led to 
Improper and Abusive Use of Premium Class Travel, GAO-07-1268 
(Washington, D.C.: Sept. 28, 2007); Financial Audit: Significant 
Internal Control Weaknesses Remain in the Preparation of the 
Consolidated Financial Statements of the U.S. Government, GAO-07-805 
(Washington, D.C.: July 23, 2007); and Veterans Affairs: Lack of 
Accountability and Control Weaknesses over IT Equipment at Selected VA 
Locations, GAO-07-1100T (Washington, D.C.: July 24, 2007). 

[16] GAO/AIMD-00-21.3.1. 

[17] JIEDDO issued JIEDDO Instruction 5000.01 on November 9, 2007, to 
define and implement the rapid acquisition management responsibilities 
for counter-IED efforts contained in DOD Directive 2000.19E. 

[18] GAO/AIMD-00-21.3.1. 

[19] GAO/AIMD-00-21.3.1. 

[20] GAO/AIMD-00-21.3.1. 

[21] The statement is required by FMFIA to disclose material weaknesses 
identified through an evaluation to determine the effectiveness of an 
entity's internal controls for its overall program, administrative, and 
operational activities and describe the plans and schedules to correct 
identified weaknesses. 

[22] Department of Defense Office of the Inspector General, Department 
of the Army Purchases from Government sources, Report No. D-2007-075 
(Arlington, Va.: Mar. 22, 2007). 

[23] GAO-07-377C. 

[24] Field service representatives are contractors who are responsible 
for providing a range of support (goods and services) needed while an 
equipment item or system is in use in the field versus in production or 
manufacture. 

[25] The Joint Test Board is an organization within the Army and funded 
by JIEDDO that the Deputy Secretary of Defense directed be established. 
Its mission is to synchronize testing of communications and counter-IED 
and other systems, to ensure that they can operate and are compatible 
with other JIEDDO initiatives currently fielded in Iraq and 
Afghanistan. The board has been in operation since fiscal year 2006 
with current fiscal year 2007 funding commitments of $92 million. 

[26] OMB Circular A-76 (Revised), Performance of Commercial Activities, 
Attachment A, sec. B.1.a (2003). 

[27] GAO, Military Operations: High-Level DOD Action Needed to Address 
Long-standing Problems with Management and Oversight of Contractors 
Supporting Deployed Forces, GAO-07-145 (Washington, D.C.: Dec. 18, 
2006). 

[28] We excluded 1 of the top 10 attack the network initiatives because 
its sensitive nature and remote location made obtaining documentation 
difficult. 

[29] There are approximately 20 positions identified in the new 
division. Two military staff currently manage the contract staff 
filling the other positions in the division. 

[30] Joint IED Defeat Organization Instruction 5000.01, Joint 
Improvised Explosive Device Defeat Capability Approval and Acquisition 
Management Process (JCAAMP), (Nov. 9, 2007). 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability.  

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "Subscribe to Updates."  

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to:  

U.S. Government Accountability Office: 
441 G Street NW, Room LM: 
Washington, D.C. 20548:  

To order by Phone: 
Voice: (202) 512-6000: 
TDD: (202) 512-2537: 
Fax: (202) 512-6061:  

To Report Fraud, Waste, and Abuse in Federal Programs:  

Contact:  

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: [email protected]: 
Automated answering system: (800) 424-5454 or (202) 512-7470:  

Congressional Relations:  

Ralph Dawn, Managing Director, [email protected]: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548:  

Public Affairs: 

Chuck Young, Managing Director, [email protected]: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: 

*** End of document. ***