DOD Acquisition: Fiscal Year 1993 Waivers to Acquisition Workforce
Requirements (Letter Report, 02/16/94, GAO/NSIAD-94-92).

The Defense Acquisition Workforce Improvement Act, seeking to
professionalize the Pentagon's acquisition workforce, imposes education,
training, and experience requirements.  The act allows DOD to waive
qualification requirements for program managers and other acquisition
personnel.  During fiscal year 1993, the military granted a total of 30
waivers for 26 persons--three fewer than in the previous year.  No
waivers were granted for contracting officers.  Significant differences
exist, however, between the fiscal year 1992 and 1993 waivers.  Compared
to fiscal year 1992, the documentation supporting the waivers contained
less information on the unusual circumstance or the individuals'
qualifications that obviated the need to meet the standards.  However,
the Director of Acquisition Education, Training, and Career Development
said that his office reviews the documentation to ensure compliance with
the act.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-94-92
     TITLE:  DOD Acquisition: Fiscal Year 1993 Waivers to Acquisition 
             Workforce Requirements
      DATE:  02/16/94
   SUBJECT:  Labor force
             Waivers
             Education or training
             Documentation
             Defense procurement
             Personnel management
             Military personnel
             Civilian employees
             Compliance
             Hiring policies
IDENTIFIER:  DOD Defense Management Review
             Defense Acquisition Education, Training, and Career 
             Development Program
             
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Cover
================================================================ COVER


Report to Congressional Committees

February 1994

DOD ACQUISITION - FISCAL YEAR 1993
WAIVERS TO ACQUISITION WORKFORCE
REQUIREMENTS

GAO/NSIAD-94-92

DOD Acquisition


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense

Letter
=============================================================== LETTER


B-247174

February 16, 1994

The Honorable Sam Nunn
Chairman, Committee on Armed Services
United States Senate

The Honorable Ronald V.  Dellums
Chairman, Committee on Armed Services
House of Representatives

On November 5, 1990, the Defense Acquisition Workforce Improvement
Act (10 U.S.C.  1701 et seq.) was enacted to address public and
congressional criticism of the Department of Defense's (DOD)
management of its acquisition programs.  The intent of the act is to
professionalize DOD's acquisition workforce.  The act imposes
education, training, and experience requirements, which take effect
over a 3-year period, beginning in October 1991. 

The act permits DOD officials to waive specific qualification
requirements pertaining to program managers and other acquisition
personnel.  It also requires that, through 1998, we annually report
on DOD's compliance with the act's waiver provisions.  This is our
third report required by the act.\1


--------------------
\1 Defense Management:  Implementation of the Defense Acquisition
Workforce Improvement Act (GAO/NSIAD-92-97, Jan.  31, 1992);
Acquisition Management:  Waivers to Acquisition Workforce Training,
Education, and Experience Requirements (GAO/NSIAD-93-128, Mar.  30,
1993). 


   BACKGROUND
------------------------------------------------------------ Letter :1

The quality and professionalism of DOD's acquisition workforce has
been an issue for over 30 years.  In 1986, the President's Blue
Ribbon Commission on Defense Management (the Packard Commission)
described the DOD acquisition workforce as "undertrained, underpaid,
and inexperienced." In July 1989, DOD's Defense Management Review\2
reported many of the same problems and recommended a series of
specific management initiatives to improve the acquisition process
and more effectively manage DOD resources. 

The Defense Acquisition Workforce Improvement Act is designed to
improve the effectiveness and quality of DOD's acquisition workforce,
which is composed of 11 functional career fields, such as program
management, contracting, and logistics.  Specifically, the act (1)
establishes a management and career development structure headed by
the Director of Acquisition Education, Training, and Career
Development Policy, in the Office of the Secretary of Defense; (2)
establishes qualification standards and assignment period
requirements for the acquisition workforce; (3) requires the
establishment of an acquisition corps, which consists of a group of
selected senior civilian employees (GS-13 and above) and military
personnel (O-4 and above) from the acquisition workforce; and (4)
requires the designation of critical acquisition positions, which are
generally to be filled by civilians in grades GS-14 or above or
military personnel in grades O-5 and above.  Membership in an
acquisition corps is a prerequisite for future appointments to
critical acquisition positions. 

Qualification requirements for acquisition personnel are not new. 
Since 1987, program managers have been required by law to complete
the Defense System Management College's program management course or
a comparable course.  Since 1990, program managers and general or
flag officers have been required to have 8 years experience in the
acquisition, support, and maintenance of weapon systems, including at
least 2 years in a procurement command.  The current act expands upon
these provisions by including other acquisition disciplines and more
stringent experience requirements. 

The effective dates for the act's qualification requirements are
staggered from 1991 through 1993.  Beginning October 1, 1991, the act
required that newly appointed program managers of major and
significant nonmajor defense acquisition programs

  complete the program management course (or an equivalent course) at
     the Defense Systems Management College,

  possess acquisition experience:  at least 8 years for major defense
     programs (2 of which are in a systems program office or similar
     organization) and at least 6 years for significant nonmajor
     programs, and

  agree to a tenure requirement that they remain in their position
     until the completion of the first major milestone closest in
     time to the date they have served 4 years and sign a written
     agreement to remain on active duty (or in federal service)
     during this period. 

Beginning October 1, 1992, deputy program managers must have 6 years
of acquisition experience and, along with program executive officers,
have attended the program management course.  In addition, before
being assigned as a program executive officer and before general and
flag officers and civilian equivalents are assigned to a critical
acquisition position, they must have 10 years experience in
acquisition positions.  Four years of this experience must have been
in a critical acquisition position.  Senior contracting officials
must have 4 years experience in contracting in order to fill a
critical position in contracting. 

Beginning October 1, 1993, specific qualification requirements went
into effect for contracting officers.  They must have (1) completed
all mandatory contracting courses; (2) gained at least 2 years of
contracting experience; and (3) received a baccalaureate degree with
at least 24 semester hours in business disciplines, or passed an
equivalency exam along with additional requirements established by
the Secretary of Defense.  In addition, each service must have
established an acquisition corps, and individuals serving in critical
acquisition positions must be corps members. 

According to DOD policy, waivers to the above qualification
requirements may be granted by the service secretary or his or her
designee if (1) unusual circumstances justify the waiver or (2) the
individual's qualifications obviate the need for meeting the
standards. 


--------------------
\2 On the basis of the Packard Commission findings, the President
directed the Secretary of Defense to review DOD's management and
develop a plan to fully implement the Commission's recommendations. 
In response, the Secretary established the Defense Management Review
in February 1989. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

During fiscal year 1993, the military services granted a total of 30
waivers for 26 individuals--3 fewer than fiscal year 1992.  Most of
the waivers were for program managers.  No waivers were granted for
contracting officers.  As in fiscal year 1992, DOD agencies did not
grant any waivers in fiscal year 1993. 

There were some significant differences between the fiscal year 1992
and 1993 waivers. 

Compared to fiscal year 1992, the documentation provided to support
the waivers contained less information regarding the unusual
circumstances that existed or the individuals qualifications that
obviated the need for meeting the standards.  However, the Director
of Acquisition Education, Training, and Career Development stated
that his office reviews the documentation to assure compliance with
the act. 


   WAIVERS ISSUED
------------------------------------------------------------ Letter :3

During fiscal year 1993, the military services granted a total of 30
waivers for 26 individuals (23 program managers, a deputy program
manager, a program executive officer, and a general officer).  No
waivers were granted for contracting officers.  Ten of the 30 waivers
granted were for individuals, both military and civilian, who lacked
the required program management course.  Four waivers were for
individuals lacking the required acquisition experience, and 16
waivers were for those who did not meet the tenure requirement. 
Twenty-two (85 percent) of the 26 individuals receiving waivers were
military personnel, 7 of whom were general officers.  As in fiscal
year 1992, DOD agencies did not grant any waivers in fiscal year
1993.  Table 1 summarizes the waivers approved by each service. 



                           Table 1
           
            Summary of Waivers Approved for Fiscal
                          Year 1993

Reason waiver was                              Air
needed                    Army      Navy     Force     Total
--------------------  --------  --------  --------  ========
No program                   2         4         4        10
 management course
Insufficient                 3         1         0         4
 acquisition
 experience
Did not fulfill              3         6         7        16
 tenure
============================================================
Total                        8        11        11        30
------------------------------------------------------------
Three fewer waivers were granted in fiscal year 1993 compared to
fiscal year 1992, even though the act's requirements expanded in
fiscal year 1993 to include specific qualification requirements for
contracting officers.  Data were not available on the proportion of
waivers granted in fiscal year 1992. 

There were some significant differences between the fiscal year 1992
and 1993 waivers.  For example, in fiscal year 1992, 3 of the 33
waivers granted were for not completing the tenure requirement.  In
fiscal year 1993, waivers to the tenure requirement accounted for 16
of the 30 waivers granted.  In fiscal year 1992, the Army issued a
disproportionately higher number (about 70 percent) of the waivers. 
As shown in table 1, waivers were more evenly distributed among the
services in fiscal year 1993.  Also in fiscal year 1992, the majority
of waivers were for general officers, whereas in 1993 the majority
were for field grade officers. 


      WAIVERS TO PROGRAM
      MANAGEMENT COURSE
---------------------------------------------------------- Letter :3.1

The primary explanation for granting the 10 waivers to the program
management course was that the individuals were otherwise qualified
based on education and/or experience.  Four waivers were for
civilians; six were for military officers, four of whom were general
officers.  Program management course waivers decreased from fiscal
year 1992, when they accounted for a majority of the waivers issued. 

The high number of program management course waivers in fiscal year
1992 reflected an increased demand for the course--a demand that was
created by the act's requirement.  This demand, coupled with the
course's limited availability at the Defense Systems Management
College in Virginia, led to a sizable backlog.  To help reduce the
course backlog, the Office of the Under Secretary of Defense declared
in August 1992 that the Naval Post Graduate Course in California
would also satisfy the program management course requirement.  This
decision allows former and future graduates to fulfill the course
requirement.  Like the program management course in Virginia, this
course offers instruction in a variety of acquisition issues,
including financial, technical, life-cycle, and contract management. 


      WAIVERS TO ACQUISITION
      EXPERIENCE
---------------------------------------------------------- Letter :3.2

As shown in table 1, three Army waivers and one Navy waiver were
granted to individuals who lacked the required acquisition
experience.  All four waivers were given to military officers, two of
whom were general officers. 

In contrast to fiscal year 1992, individuals waived in fiscal year
1993 came closer to meeting the experience requirement.  For example,
some individuals waived in 1992 had no acquisition experience at all;
others lacked several years of experience.  In 1993, only one
individual had a significant shortfall in experience--49 months.  Two
other individuals lacked only 3 and 6 months of experience,
respectively.  The fourth waiver was for a program executive officer
who did not have the requisite program manager/deputy program manager
experience. 


      TENURE WAIVED
---------------------------------------------------------- Letter :3.3

Sixteen waivers were granted to individuals who failed to fulfill the
tenure requirements.  Five of these waivers were for people retiring,
and three were for those being promoted.  Eight individuals were
being reassigned.  The waiver justification data did not explain why
these reassignments were necessary. 


   WAIVER JUSTIFICATIONS REVIEWED
------------------------------------------------------------ Letter :4

The act requires a written rationale for each waiver.  The written
rationales provided in fiscal year 1992 contained more specific
information about the education and experience qualifications of
individuals receiving waivers than those provided in fiscal year
1993.  In some cases, the waiver justifications did not contain
detailed information on the unusual circumstance or the individual's
qualifications.  The Director of Acquisition Education, Training, and
Career Development stated that his office screens the waivers
submitted from the services and follows up when necessary to ensure
that they are consistent with the requirements of the act. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

In commenting on a draft of this report, DOD generally concurred with
the report.  However, DOD pointed out that new provisions susceptible
to waivers have been added each year and therefore comparisons
between the years are of limited value.  We believe that a comparison
of waivers between fiscal years adds perspective to the number of
waivers granted and indicates the impact of added provisions.  Also,
waiver comparisons between fiscal years can identify potential
problems or trends that may require explanation and/or management
attention. 

DOD also stated that the information provided on the waiver forms
meets the requirements of the act.  DOD noted that the waiver forms
indicate that the waiver was granted either because of unusual
circumstances or that a determination was made by an authorized
official that the individual's qualifications obviated the need to
meet the requirements.  We believe having a signed waiver form
represents the minimum compliance with the law that calls for a
written rationale for each waiver.  DOD's comments are reprinted in
their entirety in appendix I. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :6

Our review covered the Departments of the Army, Navy, and Air Force;
the Office of the Under Secretary of Defense; and the other DOD
agencies.  We obtained the 1993 waiver documentation from officials
in the Office of the Director, Acquisition Education, Training, and
Career Development.  For those waivers submitted and approved, we
assessed the justification for the waivers using criteria contained
in the act; DOD Instruction 5000.52, Defense Acquisition Education,
Training, and Career Development Program, dated October 25, 1991; and
the Under Secretary of Defense's October 25, 1991, policy memorandum,
which was superseded by DOD Instruction 5000.58, "Defense Acquisition
Workforce," dated January 14, 1992. 

This review was conducted between June and December 1993 in
accordance with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to the Secretaries of Defense,
the Army, the Navy, and the Air Force and to other interested
congressional committees.  We will also make copies available to
others upon request. 

Please contact me at (202) 512-4587 if you or your staff have any
questions concerning this report.  Major contributors to this report
are listed in appendix II.




David E.  Cooper
Director, Acquisition Policy, Technology
 and Competitiveness Issues




(See figure in printed edition.)Appendix I
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
============================================================== Letter 



(See figure in printed edition.)



(See figure in printed edition.)

Now on pp.  2-3. 



(See figure in printed edition.)

Now on pp.  3-5. 

Now on pp.  5-6. 



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

James F.  Wiggins, Associate Director

CINCINNATI REGIONAL OFFICE

Rae Ann Sapp, Issue Area Manager
Myra A.  Watts, Evaluator-in-Charge
Norbert Trapp, Senior Evaluator
