Acquisition Management: Waivers to Workforce Training, Education, and
Experience Requirements (Letter Report, 02/01/95, GAO/NSIAD-95-88).

The Defense Acquisition Workforce Improvement Act was intended to
professionalize the Defense Department's (DOD) acquisition workforce by
establishing education, training, and experience requirements that were
to take effect over three years beginning in October 1991.  The act
allows DOD to waive qualification requirements if unusual circumstances
justify it or if the individual's qualifications obviate the need for
meeting the requirements.  This is GAO's fourth report on DOD's
compliance with the act's waiver provisions.  GAO also provides
information on DOD's use of fulfillments, which enable individuals to
receive credit when they already have the required competencies instead
of taking training classes.

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

 REPORTNUM:  NSIAD-95-88
     TITLE:  Acquisition Management: Waivers to Workforce Training, 
             Education, and Experience Requirements
      DATE:  02/01/95
   SUBJECT:  Defense procurement
             Military personnel
             Procurement regulation
             Waivers
             Human resources training
             Education or training
             Labor force
             Compliance
             Personnel management
IDENTIFIER:  Defense Acquisition Education, Training, and Career 
             Development Program
             DOD Defense Management Review
             
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Cover
================================================================ COVER


Report to Congressional Committees

February 1995

ACQUISITION MANAGEMENT - WAIVERS
TO WORKFORCE TRAINING, EDUCATION,
AND EXPERIENCE REQUIREMENTS

GAO/NSIAD-95-88

Acquisition Management


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

  DOD - Department of Defense
  ABC - ABCDEFG

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


B-260059

February 1, 1995

The Honorable Strom Thurmond
Chairman,
The Honorable Sam Nunn
Ranking Minority Member
Committee on Armed Services
United States Senate

The Honorable Floyd Spence
Chairman,
The Honorable Ronald Dellums
Ranking Minority Member
Committee on National Security
House of Representatives

To address long-standing criticisms of the Department of Defense's
(DOD) management of acquisition programs, Congress enacted the
Defense Acquisition Workforce Improvement Act (10 U.S.C.  1701 et
seq.) on November 5, 1990.  The act was intended to professionalize
DOD's acquisition workforce by establishing education, training, and
experience requirements that were to take effect over a 3-year
period, beginning October 1991. 

The act permits DOD officials to waive specific qualification
requirements if (1) unusual circumstances justify the waiver or (2)
the individual's qualifications obviate the need for meeting the
requirements.  It also requires that, through 1998, our office
annually report on DOD's compliance with the act's waiver provisions. 
This is our fourth waiver report.\1 We have also reported on DOD's
overall implementation of the act.\2

In conjunction with the waivers, we also obtained information on
DOD's use of fulfillments as authorized by an amendment to the act. 
Fulfillments enable individuals to receive credit when they already
have the required competencies instead of taking training courses. 


--------------------
\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); and DOD Acquisition:  Fiscal Year 1993 Waivers to Acquisition
Workforce Requirements (GAO/NSIAD-94-92, Feb.  16, 1994). 

\2 Acquisition Management:  Implementation of the Defense Acquisition
Workforce Improvement Act (GAO/NSIAD-93-129, Apr.  26, 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
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 requires the
Secretary of Defense to establish an acquisition workforce with
specific experience, education, and training qualifications. 
Specific provisions of the act require the Secretary of Defense to
(1) establish a management structure along with policies and
regulations for implementing the act's provisions, (2) establish
qualification requirements, (3) provide training and education to
meet these requirements, and (4) enhance civilian opportunities to
progress to senior acquisition positions. 

Fiscal year 1994 was the first year that all the act's provisions
were in effect.  The effective dates for DOD's implementation of the
act's qualification requirements are staggered from October 1, 1991,
through October 1, 1993. 

No later than October 1, 1991, newly appointed program managers of
major\3 and significant nonmajor defense acquisition programs were to

complete the program management course\4 (or a comparable course);

possess acquisition experience, at least 8 years for major defense
acquisition 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 they complete the first major milestone closest in time to the
date they have served 4 years (3 years for program managers of
significant nonmajor defense acquisition programs) and sign a written
agreement to remain on active duty (or federal service) during the
period. 

Beginning October 1, 1992, deputy program managers must have 6 years
of acquisition experience and, along with program executive officers,
have completed 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, contracting officers 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 examination along with additional requirements
established by the Secretary of Defense. 

Each service was also required to establish an acquisition corps
consisting of senior civilian and military personnel who meet
specific education, experience, and training requirements.  An
individual must be a member of the acquisition corps to be appointed
to a critical acquisition position.  According to the act,
individuals in critical acquisition positions as of October 1, 1993,
who did not meet corps position requirements were required to (1)
meet those requirements within 6 months, (2) be given a waiver, or
(3) be removed from the position.  If an individual occupying a
critical position does not meet the act's education, training, or
experience requirements after a 6-month grace period, the service
must either "grandfather"\5 the individual or issue a waiver. 

The act also requires the services to establish a management
information system capable of providing standardized information on
acquisition positions and the training, education, and experience of
individuals filling them.  The services are to use the systems to
monitor various acquisition workforce personnel actions to ensure
compliance with the act's requirements.  DOD estimates that about
114,000 acquisition positions are subject to the training, education,
and experience requirements of the act. 

The National Defense Authorization Act for Fiscal Year 1993
authorized the use of fulfillment standards as a substitute to the
act's training requirements.  The Secretary of Defense developed
fulfillment standards in January 1993 to include a formal process for
determining whether an individual has demonstrated competence in the
areas of the mandatory training courses.  The fulfillment standards
are effective retroactively to November 5, 1990, and cease to be in
effect on October 1, 1997. 


--------------------
\3 A "major defense acquisition program" is defined to include a DOD
acquisition program that is not highly sensitive or classified and
whose research and development cost is expected to exceed $300
million in fiscal year 1990 dollars or whose procurement cost is
expected to exceed $1.8 billion in fiscal year 1990 dollars. 
Significant nonmajor defense acquisition programs are other programs
that are estimated to require eventual total expenditures (based on
constant fiscal year 1980 dollars) of more than (1) $75 million in
research, development, test and evaluation or (2) $300 million for
procurement for a major system. 

\4 The program management course is 20 weeks in length and is DOD's
primary defense acquisition course.  Taught at the Defense Systems
Management College at Fort Belvoir, Va., this DOD-wide course
addresses a variety of acquisition issues, including policy,
financial, technical, life-cycle, and contract management.  The Naval
Post-Graduate School has been designated as an equivalent for
purposes of meeting the program management course requirements. 

\5 The act excepts acquisition workforce employees having at least 10
years of acquisition experience as of October 1, 1991. 


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

During fiscal year 1994, the military services and DOD agencies
granted a total of 63 waivers (50 from the military services and 13
from DOD agencies) to 59 individuals not meeting the education,
training, and experience requirements of the act.  Fiscal year 1994
was the first time defense agencies reported granting waivers.  Of
the waivers granted,

44 were for military personnel,

20 were for program managers and deputy program managers,

18 were for individuals in critical acquisition positions,

13 were for program managers or deputy program managers not meeting
tenure requirements, and

10 were for contracting officers. 

No waivers were granted for the act's program management course
requirement for program and deputy program managers. 

The Air Force is requiring individuals already occupying critical
acquisition positions to meet the act's training, education, and
experience requirements.  Instead of grandfathering those already in
critical positions, the Air Force has issued temporary waivers to 177
individuals not meeting the act's requirements.  These temporary
waivers are different from the other waivers in that they are set to
expire in 17 months.  Since the temporary waivers were granted, 75 of
the individuals have met the requirements.  The other services are
grandfathering individuals already occupying critical positions.  The
services did not have detailed data on personnel being grandfathered. 


   WAIVERS APPROVED
------------------------------------------------------------ Letter :3

During fiscal year 1994, the military services and DOD agencies
granted a total of 63 waivers to 59 individuals not meeting the
requirements.  Most were program managers and deputy program
managers; and, as in 1993, the majority of the waivers were granted
to military personnel, seven of whom were general officers.  Ten
waivers were granted to contracting officials and 18 waivers were
given to individuals occupying critical acquisition positions. 
Defense agencies granted waivers for the first time in fiscal year
1994.  Table 1 summarizes the waivers approved by each service. 



                           Table 1
           
            Summary of Waivers Approved for Fiscal
                          Year 1994

                                            Defense
Reason for                             Air  agencie
waiver              Army     Navy    Force        s    Total
---------------  -------  -------  -------  -------  =======
Acquisition            5        5        2        0       12
 experience
Tenure                 5        2       16        0       23
Acquisition            1        3        4       10       18
 corps
Contracting            0        7        0        3       10
 officials
============================================================
Total                 11       17       22       13       63
------------------------------------------------------------
Table 2 compares waivers granted in fiscal year 1994 with fiscal
years 1992 and 1993.  It shows that waivers for acquisition
experience and tenure both increased, while waivers for the program
management course declined to zero.  In fiscal years 1992 and 1993,
the program management course requirement accounted for 70 percent
and 33 percent of the waivers, respectively.  The decline is due, in
part, to (1) the new fulfillment standards published by DOD, (2)
increases in courses available to meet the requirements, and (3) a
reduced backlog of personnel requiring the course.  The table also
shows waivers to acquisition corps and contracting officer
requirements that took effect in October 1993. 



                           Table 2
           
            Waivers approved between Fiscal Years
                        1992 and 1994

Reason why waiver was needed        FY92      FY93      FY94
------------------------------  --------  --------  --------
Lack of acquisition experience        22         4        12
Did not have program                23\a        10         0
 management course
Did not fulfill tenure                 3        16        23
Did not meet corps acquisition         -         -        18
 requirements\b
Did not meet requirements for          -         -        10
 contracting positions\b
------------------------------------------------------------
\a The 22 individuals receiving waivers for acquisition experience
also received waivers for the program management course. 

\b This requirement was not in effect in fiscal years 1992 and 1993. 


      ACQUISITION EXPERIENCE
      WAIVED
---------------------------------------------------------- Letter :3.1

Five Army waivers, five Navy waivers, and two Air Force waivers were
granted to individuals who lacked the required acquisition
experience.  All 12 waivers were given to military officers, 5 of
whom were general officers (4 in the Army and 1 in the Air Force). 
The number of acquisition experience waivers has varied considerably
from year to year; from 67 percent (22 of 33) in fiscal year 1992, to
only 13 percent (4 of 30) in fiscal year 1993, to 19 percent (12 of
63) in fiscal year 1994. 

In fiscal year 1992, we noted that the Army waived requirements for
individuals who had no acquisition experience at all or who lacked
several years of acquisition experience.  In 1994, the Army waived
acquisition experience requirements for officers who lacked, on
average, 3.9 years of experience necessary to meet the requirements
of the act.  The Air Force waived requirements for two individuals
and the Navy waived requirements for four individuals needing an
average of 4 and 2.7 years of acquisition experience, respectively. 


      TENURE WAIVED
---------------------------------------------------------- Letter :3.2

Twenty-three waivers were granted to individuals who failed to
fulfill the tenure requirements.  Like prior years, the majority of
the tenure waivers were for reassignment.  For example, in fiscal
year 1993, 50 percent (8 of 16) of the tenure waivers were for
individuals being reassigned and in fiscal year 1994, 74 percent (17
of 23) of the waivers were for individuals being reassigned.  Of
these, 12 of the 17 individuals are Air Force personnel.  Five of the
tenure waivers in fiscal year 1994 were for individuals retiring
before completing their required term, same as in fiscal year 1993. 
One of the tenure waivers was for a promotion. 


      ACQUISITION CORPS
      REQUIREMENTS WAIVED
---------------------------------------------------------- Letter :3.3

Eighteen individuals not meeting the applicable education,
experience, and/or certification requirements received waivers
because they were already in critical positions.  The Air Force
approved only four of these waivers.  However, they also approved
numerous temporary waivers for essentially the same reason. 

The Air Force is requiring individuals occupying critical acquisition
positions to join its acquisition corps and meet the act's training,
education, and experience requirements.  Consequently, it needed to
identify all Air Force personnel in critical acquisition positions
who were not certified as meeting the requirements.  Using its
management information system, the Air Force identified 177 such
individuals
(91 military and 86 civilians).  On December 23, 1993, the Air Force
granted these individuals temporary waivers with an expiration date
of March 1, 1995.  Since the Air Force issued this list of
individuals not meeting the corps requirements, 75 individuals have
met those requirements,
46 individuals are no longer occupying a critical acquisition
position, and
56 individuals are still on the list.  They have until March 1, 1995,
to meet the qualification requirements.  In contrast, the Army and
the Navy did not issue temporary waivers, preferring the options of
(1) permanent waivers and (2) grandfathering individuals occupying
critical acquisition positions. 


      CONTRACTING POSITIONS
      REQUIREMENTS
---------------------------------------------------------- Letter :3.4

In general, the act's requirements for contracting officers in
acquisition positions include (1) completion of mandatory contracting
courses, (2) at least 2 years of contracting experience, and (3) a
baccalaureate degree or at least 24 semester credit hours in specific
disciplines.  In fiscal year 1994, 10 individuals received waivers
for such training, experience, and education standards.  In all
cases, these individuals had not completed the required education
and/or experience. 


   FULFILLMENTS
------------------------------------------------------------ Letter :4

Fulfillment means that the training requirement has been satisfied
through other means, such as experience.  Individuals seeking
fulfillment approval must submit fulfillment packages to the
authorized approval authority.  Each service has established its own
fulfillment policies and procedures, which vary considerably. 

DOD officials believe that, generally, fulfilling the act's
requirements through alternative means is more desirable than waiving
the act's requirements.  In fiscal year 1994, four fulfillments were
approved for the program management course--all for Army personnel. 

DOD's Office of the Director of Acquisition Education, Training, and
Career Development is not required to track fulfillments, but does so
for two courses:  the Program Management 301 Course and the
Information Resources Management 302 Course.  DOD officials believe
that tracking such statutory requirements improves general oversight
and has allowed them to appropriately influence


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

We provided DOD acquisition officials a draft of this report and we
discussed the report results with officials from the Army, the Navy,
the Air Force, and the Office of the Secretary of Defense.  The
officials generally concurred with the information in this report. 


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

Our review covered the Departments of the Army, the Navy, and the Air
Force; the Office of the Secretary of Defense; and the other DOD
agencies.  We obtained the fiscal year 1994 waiver documentation and
fulfillments for the program management and the information resource
management courses from the Office of the Director, Acquisition
Education, Training, and Career Development Policy within the Office
of the Secretary of Defense.  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. 

The services' and defense agencies' management information systems
cannot readily identify and report on all acquisition personnel that
do not meet the act's training, education, and experience
requirements.  However, the Director, Acquisition Education,
Training, and Career Development Policy stated that they closely
track acquisition corps waivers.  We did not independently assess the
accuracy of data in DOD's management information systems. 

We performed our review between August and December 1994 in


---------------------------------------------------------- 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.  Appendix I lists the major
contributors to this report. 

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


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I


   NATIONAL SECURITY AND INTERNAL
   AFFAIRS DIVISION, WASHINGTON,
   D.C. 
--------------------------------------------------------- Appendix I:1

James F.  Wiggins, Associate Director
Clifton E.  Spruill, Assistant Director


   CINCINNATI FIELD OFFICE
--------------------------------------------------------- Appendix I:2

Rae Ann Sapp, Regional Manager Representative
Myra Watts, Evaluator-in-Charge
