Office of Inspector General

Audit Report

FAA POLICIES AND PLANS ARE

INSUFFICIENT TO ENSURE AN 

ADEQUATE AND EFFECTIVE 

ACQUISITION WORKFORCE

Federal Aviation Administration

Report Number: ZA-2011-148

Date Issued: August 3, 2011
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FAA Policies and Plans are Insufficient 

to Ensure an Adequate and Effective Acquisition 

Workforce

Federal Aviation Administration

Report Number: ZA-2011-148

Date: August 3, 2011

From: Mary Kay Langan-Feirson

Assistant Inspector General

 for Acquisition and Procurement Audits

Reply to 

Attn. of: JA-60

To: Federal Aviation Administrator

In fiscal year 2010, the Federal Aviation Administration (FAA) obligated over 

$3.7 billion on contracts for goods and services. FAA plans to increase its annual 

major investments funding by half a billion dollars between fiscal year 2008 and 

fiscal year 2012.

1

In 2008, FAA launched an ambitious planning effort to develop strategies for 

hiring, training, developing, and retaining acquisition employees. In 2009, FAA 

issued its initial Acquisition Workforce Plan on the agency’s workforce needs 

from fiscal year 2009 through fiscal year 2011, and updated the plan in 2010 to 

project these needs through fiscal year 2014.

This increase helps fund important modernization programs, 

including the Next Generation Air Transportation System (NextGen)—a system 

intended to accommodate increased air traffic, which is expected to triple by 2025. 

At the same time, 20 percent of FAA’s acquisition workforce is eligible to retire, 

with a cumulative retirement eligibility of 40 percent by fiscal year 2015. FAA’s

significant contracting budget coupled with the projected attrition emphasizes the 

need for effective acquisition workforce planning.

2 As part of our recent audit on 

NextGen,3

 1 Capital investment funding from DOT’s budget estimate for FAA, fiscal years 2010 to 2012.

we reviewed the 2009 plan and found that it lacked sufficient 

development to ensure FAA staff would have the skills and expertise needed to 

effectively manage and oversee FAA’s acquisitions.

2 FAA’s Acquisition Workforce Plan is updated annually. 3 OIG Report Number AV-2010-068, “Timely Actions Needed to Advance the Next Generation Air Transportation 

System,” June 16, 2010. All OIG reports are available on our website at www.oig.dot.gov.
2

Given the risks an inadequate workforce poses on FAA’s multibillion dollar 

contracting budget, we assessed FAA’s Acquisition Workforce Plan to determine 

whether it comprehensively identifies FAA’s acquisition workforce and the 

required skills and competencies needed now and in the future, and whether it 

addressed gaps in the hiring and development of this important workforce. We 

also determined whether FAA identified and implemented the programs, policies, 

and practices needed to ensure it has an adequate acquisition workforce. Our audit 

included a comprehensive review of the initial plan, including assessments based 

on regulations and best practices, and discussions with officials on the updated 

plan. We conducted our audit between December 2009 and May 2011 in 

accordance with generally accepted government auditing standards. Our scope and 

methodology are discussed in detail in exhibit A.

RESULTS IN BRIEF

FAA’s Acquisition Workforce Plan is not comprehensive. The 2009 plan excluded 

acquisition employees in a number of FAA’s lines of business,4

FAA has not sufficiently addressed gaps in hiring and developing its acquisition 

workforce. FAA reported that it met 99 percent of its overall acquisition 

workforce hiring target for fiscal year 2009;

as well as its 

support contractor and service contract staff. While FAA’s updated 2010 plan 

includes acquisition staff from additional lines of business, the plan continues to 

omit both Federal and contractor acquisition employees working on FAA’s

support services contracts, such as FAA’s Systems Engineering 2020 (SE-2020) 

contracts, which have a potential maximum value of greater than $7 billion. 

Excluding these employees creates significant risks in administering contracts. For 

example, poor contract administration of the Air Traffic Controller Optimum 

Training Solution (ATCOTS) support services contract contributed to cost 

overruns totaling $46 million during the contract’s first 2 years. Further, FAA did 

not require Technical Officer Representatives (TORs) to be included in the plan, 

despite their role in overseeing and evaluating contractor performance. In addition,

the plan lacks competency models for about a third of FAA’s acquisition roles.

5

 4 FAA is divided into individual organizations called “lines of business.” For example, FAA’s Air Traffic 

Organization (ATO) is one of FAA’s lines of business.

however, this percentage is

misleading because three of seven ATO service units exceeded their overall hiring 

targets, while the remaining four fell short. FAA also hired more employees in 

some categories and fewer in others than the plan called for. For example, 

according to FAA data, FAA hired almost double the number of contracting 

officers than the plan called for, yet hired less than 40 percent of the engineers 

5 FAA has compiled fiscal year 2010 hiring data for publication in its 2011 Acquisition Workforce Plan; however, 

further assessment of this data is needed to determine whether the data addresses FAA’s hiring needs across all lines 

of business and for each acquisition discipline.
3

needed to support acquisition programs. FAA’s lack of adherence to its workforce 

plan—combined with a lack of accurate hiring data—suggests that additional 

controls are needed to ensure a fully staffed acquisition workforce. For example, 

FAA could not accurately determine whether it hired enough program managers 

and engineers for its NextGen unit because FAA’s hiring data does not include 

information on the acquisition discipline for many of the unit’s employees. FAA 

also lacks the controls needed to ensure that its workforce is qualified and properly 

trained. In one case, FAA granted unlimited warrant authority to an uncertified 

contracting officer.

6

Finally, FAA has not fully implemented the programs, policies, and practices 

needed to ensure an adequate workforce. FAA’s plan is vague about specific 

approaches and milestones for hiring, training, and certifying its workforce. 

FAA’s plans also lack internal certification programs for about half of its

acquisition disciplines, which would ensure that employees have the experience, 

education, and skill set to perform acquisition duties. In addition, FAA is not 

effectively communicating the agency’s workforce planning efforts to its 

acquisition employees. More than half of the acquisition employees in our random 

sample of 63 out of 879 had not read FAA’s 2009 Acquisition Workforce Plan;

and several acquisition employees were reluctant to meet with us because they did 

not believe they were part of the acquisition workforce.

We are making a series of recommendations aimed at strengthening FAA’s

acquisition workforce planning.

BACKGROUND

In March 2009, the President stated that a strong acquisition workforce is critical 

to meeting each agency’s unique mission, and he called on Federal agencies to 

perform thorough management and oversight of its contracts.7 In response, the 

Office of Management and Budget (OMB) issued an Acquisition Workforce 

Development Strategic Plan in October 2009,

8

 6 FAA policy as well as Office of Management and Budget (OMB) and departmental best practices state that 

contracting officers must be certified at an appropriate level to support their warrant obligations. For example, a 

contracting officer with an unlimited warrant should complete the highest level of contracting officer certification, 

Level III.

which provides a structured 

approach to improving both the capacity and capability of the civilian acquisition 

workforce. The strategic plan expands on OMB’s Office of Federal Procurement 

7 Presidential Memorandum for the Heads of Executive Departments and Agencies: “Government Contracting,”

March 4, 2009. 8 OMB OFPP Memorandum: “Acquisition Workforce Development Strategic Plan for Civilian Agencies—FY 2010-

2014,” October 27, 2009.
4

Policy’s (OFPP) April 2005 policy letter issued to establish a governmentwide

framework for creating a Federal acquisition workforce.9

Since 2009, OIG has identified FAA’s acquisition workforce as a concern in our 

Department of Transportation’s Top Management Challenge reports.

10

Figure 1. Increase in FAA Capital Funding for Fiscal Years 2008-

2012 

The 

transition to NextGen has significantly increased FAA’s acquisition workload and 

will require new skills and additional resources. In fiscal year 2009, FAA’s

acquisition funding increased to accommodate NextGen contracts. In fiscal year 

2012 contract funding is expected to exceed fiscal year 2008 funding by half a 

billion dollars (see figure 1).

Source: FAA and OIG

In fiscal year 2009, 20 percent of FAA’s acquisition workforce was eligible to 

retire; by fiscal year 2015, 40 percent will be eligible to retire. In July 2009, OMB 

issued a memorandum requiring agencies to develop and implement policies, 

practices, and tools for managing the multi-sector workforce, which includes both 

 9 OMB OFPP Policy Letter 05-01: “Developing and Managing the Acquisition Workforce,” April 15, 2005. 10 OIG Report No. PT-2010-008, “Top Management Challenges,” November 16, 2009, and Report No. 2011-010, “Top 

Management Challenges,” November 15, 2010. 

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

2008 

(Actual)

2009 

(Actual)

2010 

(Actual)

2011 

(Requested)

2012 

(Requested)

Remaining Facilities and Equipment NextGen Funding

*in millions
5

Federal and contractor employees.

11 OMB identified three steps that agencies 

should take immediately to achieve an effective balance of public and private 

labor resources: (1) adopt a framework for planning and managing the multi-sector 

workforce; (2) conduct a pilot human capital analysis of at least one program, 

project, or activity where the agency has concerns about the extent of reliance on 

contractors; and (3) use in-sourcing guidelines that facilitate consistent and sound 

application of statutory requirements. In 2008, the National Academy of Public 

Administration (NAPA) and the Government Accountability Office (GAO) made 

a number of recommendations in two separate reports on actions FAA needed to 

take to address its acquisition workforce challenges.12

In response to the NAPA report, FAA issued its 2009 Acquisition Workforce Plan, 

which laid out FAA’s assessment of the skills and competencies needed for its 

current and future acquisition workforce, established initial hiring strategies for 

acquisition categories, and described FAA’s new certification and training 

programs. In 2010, FAA issued an update of its Acquisition Workforce Plan, 

which projects its acquisition workforce needs through fiscal year 2014.

In particular, NAPA found 

that FAA’s acquisition workforce would require greater emphasis in 26 technical 

competencies needed for NextGen implementation, including acquisition 

planning, contractor performance management, and contract administration.

FAA’S ACQUISITION WORKFORCE PLANS ARE NOT 

COMPREHENSIVE

FAA’s 2009 Acquisition Workforce Plan excluded acquisition staff in a number of 

FAA’s lines of business, as well as its support contractor and service contract 

staff. While FAA’s 2010 plan includes additional lines of business, it continues to 

exclude support services contracts—both contractors that provide acquisition 

support and FAA oversight staff. FAA also does not require TORs to be included 

in the plan, despite their important role in regional contract oversight. At the same 

time, FAA’s plan relies on workforce data that were gathered through interviews 

with FAA managers, yet FAA did not sufficiently verify the data to ensure the 

accuracy. Finally, the plan lacks competency models for about a third of its 

acquisition disciplines.

 11 OMB Memorandum M-09-26, “Managing the Multi-Sector Workforce”, July 29, 2009. 12 NAPA report, “Identifying the Workforce to Respond to a National Imperative: The Next Generation Air

Transportation System,” September 2008. GAO report, “Next Generation Air Transportation System, Status of 

Systems Acquisition and the Transition to the Next Generation Air Transportation System,” September 2008.
6

FAA’s Acquisition Workforce Plan Does Not Identify Its Entire 

Acquisition Workforce

FAA uses both Federal employees and private contractors to fulfill its mission. 

However, FAA’s 2009 Acquisition Workforce Plan was limited to Federal 

employees who work for ATO’s National Airspace (NAS) capital investment 

programs.

13 The 2009 plan excluded FAA’s other lines of business and several 

staff offices, including the acquisition workforce for Regions and Center 

Operations (ARC).

14

Additionally, FAA’s 2010 plan continues to focus on the Federal rather than 

contractor workforce. For example, the initial and updated plans exclude both the 

contractor and Federal workforce that perform acquisition functions for FAA’s

support service contracts, including high-value contracts, such as SE-2020 and 

ATCOTS, potentially valued at $7 billion and $859 million, respectively. In 

September 2010, we reported that FAA did not have enough qualified acquisition 

personnel to administer the multimillion dollar support service contract for its 

ATCOTS program.

While FAA’s 2010 plan added ARC and additional lines of 

business, it still excludes some sectors within FAA (see exhibit B).

15

According to FAA, only Federal employees were identified in the plans because 

they provide long-term staffing, whereas contractors are used to address 

fluctuating staff and skill requirements. In contrast, OMB’s July 2009 

memorandum requires agencies to adopt a framework for planning and managing 

both the contractor and Federal workforce.

Poor contract administration, due in part to an inadequate 

acquisition workforce, contributed to cost overruns of $28 million during the first 

year of the contract and $18 million during the second year.

16

Further, FAA does not require that TORs be included in the plan. TORs play an 

important role in overseeing contract work and giving technical direction to 

contractors at FAA’s numerous regional facilities, such as air traffic control 

centers. By not requiring TORs to be included in workforce planning, FAA has 

created a significant gap in its efforts to effectively oversee its contracts. For 

Specifically, OMB stresses the 

importance of identifying the proper roles of contractors and Federal employees 

and achieving the most effective balance of public and private labor resources.

 13 These employees are directly engaged in the design and development of mission-critical technologies and systems 

that provide the backbone for NAS. 14 ARC delivers shared services throughout the agency and the Aeronautical Center, such as acquisition and real estate 

functions throughout FAA, as well as materiel management functions for both FAA and the Department of 

Transportation. 15 OIG Report No. AV-2010-126, “FAA’s Air Traffic Controller Optimum Training Solution Program: Sound Contract 

Management Practices Are Needed to Achieve Program Outcomes,” September 30, 2010. 16 OMB Memorandum M-09-26, “Managing the Multi-Sector Workforce”, July 29, 2009.
7

example, our ongoing review of FAA’s En Route Automation Modernization 

(ERAM) found that the program’s TORs did not receive adequate training and 

lacked a full understanding of their contract oversight responsibilities.17

Failure to fully and accurately identify FAA’s acquisition workforce has 

significant risks, especially as increasingly complex NextGen programs require 

new approaches and skills. For example, our audit of Automatic Dependent 

Surveillance-Broadcast (ADS-B)—a $4 billion ground and aircraft surveillance 

system—found that it will be difficult for FAA to develop in-house expertise to 

effectively oversee NextGen since much of ADS-B’s infrastructure will be 

embedded in contractor-owned commercial equipment and networks. This limits 

FAA’s access to and understanding of ADS-B equipment. Further, our ongoing 

review of ERAM—a $2.1 billion air traffic software program—showed that 

FAA’s acquisition workforce has ineffectively managed and overrelied on support 

contractors to administer the contract.

18 Poor contract administration may be 

contributing to the program’s 4-year delay and potential $500 million cost 

overrun.19

Acquisition Disciplines and Number of Acquisition Employees Were 

Not Accurately Captured in FAA’s Plans

We identified numerous discrepancies in the information provided in FAA’s

acquisition workforce plans. Through interviews with a random sample of 63 out 

of 879 FAA acquisition employees, we identified inaccuracies in the acquisition 

disciplines entered for 16 employees—for example, one program manager was 

incorrectly listed as “engineer.” We also found that time spent on acquisition 

duties was inaccurately recorded for 26 employees. Further, FAA based its 2009 

plan on an incomplete list of acquisition employees. FAA’s Technical Operations 

service unit alone omitted 110 acquisition employees that should have been

identified in the 2009 plan.

These discrepancies are largely the result of FAA’s process for identifying its 

acquisition workforce. Whereas OMB considers critical acquisition workforce 

roles to be (1) contracting staff, (2) contracting officer’s technical representatives, 

and (3) program management, FAA uses an expanded definition that includes five 

additional acquisition labor categories, such as research and engineering (see 

 17 A similar issue has been identified in our ongoing review of FAA’s SE-2020 contracts. TORs play a key role in 

overseeing SE-2020 task orders; however, they are not required to complete training or a certification program. 18 Our ongoing ERAM audit work is looking further into this issue. 19 OIG Report No. AV-2011-002, “FAA Faces Significant Risks in Implementing the Automatic Dependent 

Surveillance-Broadcast Program and Realizing Benefits,” October 12, 2010. OIG Audit Announcement, “Progress 

and Problems Implementing the En Route Automation Modernization Program,” September 14, 2010.
8

exhibit C).

20

Consequently, FAA managers are left to interpret FAA’s definition and identify 

employees who fall within it. Some managers counted employees who were not 

part of the acquisition workforce and omitted others who were. For example, in 

identifying their contracting officer technical representatives (COTRs), some 

managers may have included TORs and Contracting Officer’s Representatives 

(CORs), which technically are not considered COTRs, while other managers did 

not. Ultimately, FAA has no assurance that the information it receives is accurate 

enough to support plans for hiring, training, and developing its current and future 

acquisition workforce.

Further, FAA defines its acquisition workforce by role rather than job 

series, and as a result, FAA cannot rely on its personnel database to distinguish 

acquisition employees from non-acquisition employees. Instead, FAA relies on its 

managers’ knowledge of employees’ acquisition roles to identify the acquisition 

workforce. At the same time, FAA is continually revising how it defines 

“acquisition workforce” as FAA decides whether employees—such as spectrum 

engineers—should be included. FAA did not effectively communicate the 

definition of acquisition workforce to its acquisition employees. Ten of the 

acquisition employees we interviewed did not believe they were part of FAA’s

acquisition workforce.

FAA Workforce Plan Lacks Competency Models for Key Acquisition 

Disciplines

Competency models specify the knowledge, skills, and abilities that an employee 

needs to perform a role or function. As such, they provide the foundation for 

training, hiring, and performance management. While FAA’s methodology for

developing competency models was comprehensive,21

Prior to issuing its 2010 plan, FAA completed competency models for logistics. 

However, competency models for test and evaluation, specialized support, and 

acquisition law—a new discipline in the 2010 plan—are still incomplete. 

According to officials from FAA’s Office of Acquisition Policy, Workforce 

the 2009 plan lacked 

competency models for test and evaluation, specialized support, and logistics—

three of FAA’s eight acquisition roles. Without complete competency models for 

these acquisition disciplines, it may be more difficult for FAA to ensure that all of 

its training courses target skill areas crucial to the agency’s mission and that new 

employees will possess the skills most needed by the agency.

 20 In 2009, FAA defined its core acquisition workforce as those employees whose primary functions involve (1) the 

acquisition of mission-critical NAS infrastructure and (2) direct engagement of projects or programs that fall within 

the specific phases of FAA’s acquisition management lifecycle. 21 FAA based its acquisition competency models on input from its acquisition leaders and Government best practices 

from the Federal Acquisition Institute (FAI) and the Department of Defense. FAA also participated in FAI’s

competency self-assessments in 2008.
9

Development, and Evaluation, FAA is working with contractors to develop these 

competencies for future updates of the plan.

FAA HAS NOT SUFFICIENTLY ADDRESSED GAPS IN HIRING 

AND DEVELOPING ITS ACQUISITION WORKFORCE

FAA has not hired a sufficient number of employees to meet its acquisition 

workforce needs. Four out of seven ATO service units are understaffed, and FAA 

lacks enough COTRs and engineers to support acquisition programs. In addition, 

FAA’s tracking systems do not effectively monitor the hiring, training, and 

certification of its acquisition workforce.

FAA Has Not Met Its Acquisition Staffing Demands

Based on its interviews with FAA managers, FAA determined that ATO service 

units needed an additional 350 acquisition employees through fiscal year 2011, 

including 201 for fiscal year 2009 alone. According to FAA’s 2010 Acquisition

Workforce Plan, FAA met 99 percent of its overall acquisition workforce hiring 

target for fiscal year 2009.

22

 22 FAA has compiled fiscal year 2010 hiring data for publication in its 2011 Acquisition Workforce Plan; however, 

further assessment of this data is needed to determine whether the data addresses FAA’s hiring needs across all lines 

of business and for each acquisition discipline.

However, FAA data showed that three ATO service 

units hired more acquisition staff than demanded—as much as 80 percent more—

while four ATO units remained understaffed (see table 1). Officials from FAA’s

acquisition policy office noted that the plan’s projected hiring demands are 

considered guidelines rather than strict requirements and believe that concerns 

regarding the risk of staffing shortfalls for some service units due to overstaffing 

in other service units are not warranted. While the plan may serve as a guide, the 

risks associated with some locations not meeting their missions because of 

understaffing could impact acquisitions throughout FAA.
10

Table 1. Percentage of Fiscal Year 2009 Hiring Demand Achieved 

in ATO 

ATO Service Unit

Demand 

(additional staff 

needed) Net Gain*

Percent of 

Demand 

Achieved

Technical Operations 24 2 8.33%

En Route 7 5 71.43%

System Operations 39 29 74.36%

Terminal 15 13 86.67%

NextGen 76 97 127.63%

Finance 10 14 140.00%

Acquisition and Business 30 54 180.00%

TOTAL 201 214 106.47%

*

Net gains are the sum of gains minus losses.

Source: FAA and OIG

FAA also did not verify all acquisition workforce hiring data. Our verification of 

the hiring data found significant omissions. For example, while NextGen hiring 

data show that more employees were hired than called for in the plan, the 

discipline fields for many of these employees were blank or incorrect. As a result, 

FAA could not determine whether it met its demands for acquisition disciplines, 

such as program managers and engineers.

Within the ATO service units other than NextGen, two acquisition disciplines did 

not meet hiring demand—COTRs and engineers (see table 2).
11

Table 2. Percentage of Fiscal Year 2009 Hiring Demand Achieved

by Acquisition Disciplines in ATO Units Other than NextGen

Acquisition Discipline

Demand

(additional staff 

needed) Net Gains*

Percent of 

Demand 

Achieved

COTR 4 1 25.00%

Engineering and Research 59 23 38.98%

Logisticians 1 1 100.00%

Program Management 13 15 115.38%

Specialized Support 9 10 111.11%

Business and Financial 12 19 158.33%

Contracting Officers 30 54 180.00%

Testing and Evaluation 0 0 N/A

*

Net gains are the sum of gains minus losses.

Source: FAA and OIG

Officials from FAA’s acquisition policy office also noted that many of the new 

contracting staff are entry level and lack the skills and competencies FAA needs to 

support its acquisition programs.

OMB best practices call for collaboration between agencies’ acquisition and 

human resources departments to ensure that workforce plans focus on long-term 

staffing and developmental needs, rather than simply filling vacancies. FAA hired 

a contractor to develop workforce recruitment plans instead of working with its 

own human resources department during the initial phases of workforce planning. 

Although the human resources department was later invited to participate in 

implementing the plan’s recruitment strategies, implementation efforts were 

hampered by disagreements between human resources and the contractor. For 

example, the contractor had suggested hiring strategies that did not comply with 

established FAA hiring policies, such as developing a hiring website for women 

and minorities.

FAA Lacks Adequate Tracking Systems to Monitor Acquisition 

Workforce Hiring, Training, and Certification

Until recently, FAA calculated hiring updates at the end of each year, which did 

not allow FAA to gauge whether it was meeting hiring goals throughout the year. 

Officials from FAA’s acquisition policy office report that FAA recently began 

monthly tracking of its hiring. However, those officials acknowledge that the

multiple systems and databases FAA uses to track the hiring, training, and 
12

certification of its acquisition workforce are inadequate for workforce planning. 

FAA developed a coding system in the Federal Personnel Payroll System 

(FPPS)—the agency’s existing personnel database—to identify acquisition 

employees and track their certification. However, FAA lacks consistent processes 

to ensure FPPS data are useful. For example, newly hired acquisition employees 

are not coded as “acquisition” in the system because FAA has not yet established a 

consistent coding process with its human resources department. We found 

inaccurate data in the system, including the following:

• Fourteen acquisition employees originally coded as “acquisition” in FPPS had 

their codes inadvertently changed to “non-acquisition.”

• One employee coded as part of FAA’s acquisition workforce no longer worked

for FAA.

• None of the certification codes in the system were verified. FAA used “0” as a 

placeholder for all employees’ certification codes.

23

• Sixteen of the 63 acquisition employees in our sample had been tagged with 

incorrect acquisition disciplines. For example, one employee was described as 

an engineer but is actually a full-time project manager.

A “0” indicates that an 

employee is uncertified, yet we confirmed that some employees coded with “0” 

were certified.

FAA’s official training record system—Electronic Learning Management System 

(eLMS)—also contained errors. In our sample of 63 employees, 36 employees’

training records were incomplete; other employees’ training records listed courses 

that the employees did not take. FAA also lacks documented internal controls to 

ensure that certification data are accurate and up-to-date.

Reconciling the data in FAA’s multiple systems can add to these weaknesses—as 

OMB warns in its acquisition workforce planning guidance.24

Without reliable information systems, FAA cannot ensure that its acquisition 

employees have completed required training and certification. We found cases 

where contracting officers and COTRs did not complete required refresher training

or were not appropriately certified. In one case, FAA granted unlimited warrant 

For example, the 

spreadsheets FAA uses to track certification of its COTRs, contracting specialists, 

and program managers have not been used to update FPPS certification data.

 23 According to FAA’s numeric coding system, a “0” indicates that the employee has no certification, while a “1,” “2,”

or “3” indicates the level of certification achieved. 24 OMB OFPP Memorandum, “Acquisition Workforce Development Strategic Plan for Civilian Agencies—FY 2010-

2014,” October 27, 2009.
13

authority25

FAA HAS NOT FULLY IMPLEMENTED ACQUISITION 

WORKFORCE PROGRAMS, POLICIES, AND PRACTICES

to a contracting officer who lacked the highest certification, which 

FAA requires for managing contracts of unlimited value. In another case, a 

contracting officer admitted to signing invoices that exceeded the officer’s warrant 

authority.

FAA lacks the programs, policies, and practices needed to ensure an adequate and 

effective acquisition workforce. Although FAA has developed training programs

for its acquisition workforce, it has yet to specify the resources needed to 

implement its general workforce strategies. FAA has developed internal 

certification programs for only half its acquisition disciplines and lacks an 

effective approach for communicating its workforce planning efforts to its 

acquisition workforce.

The 2009 plan outlines four general strategies for improving FAA’s acquisition 

workforce: (1) fill gaps according to supply and demand analyses, (2) develop and 

execute a consolidated acquisition sourcing plan, (3) create an integrated 

acquisition career program, and (4) institutionalize an acquisition workforce 

planning process. FAA has also developed several metrics to measure its progress

in developing an effective acquisition workforce, including number of new hires, 

percentage of employees certified, and attrition rates. However, FAA has not 

specified the resources and procedures needed to implement the strategies or meet 

the metrics. Specifically, the plan lacks logistical details such as timelines, 

milestones, deliverables, and planned funding needed to keep FAA accountable 

for and on schedule with hiring, training, and certifying its acquisition workforce.

Certifying acquisition staff provides another level of assurance that FAA 

employees have the experience, education, and skill set to perform their 

acquisition duties. FAA currently has certification programs for four of the 

acquisition disciplines identified in its 2009 plan—contracting, COTRs, program 

management, and logistics. In contrast, the Department of Defense has developed 

internal certification programs for 15 of its acquisition disciplines, including test 

and evaluation, 2 separate business disciplines, and 4 separate engineering 

disciplines.

 25 FAA’s Federal Acquisition Executive delegates contracting authority to contracting officers through a written 

certificate of appointment, also known as a warrant, which authorizes the individual to legally bind FAA. Warrants 

define the dollar and scope limitations of the authority. An unlimited warrant allows transactions at any dollar 

value.
14

Finally, FAA has not effectively communicated the agency’s workforce planning 

efforts to its acquisition workforce. FAA has not communicated its definition of 

acquisition workforce to the entire agency. Thirty-three—or more than half—of 

the acquisition employees in our sample had not read FAA’s 2009 Acquisition 

Workforce Plan. Moreover, 10 acquisition employees we interviewed were not 

aware that they were part of FAA’s acquisition workforce. Consequently, even if 

employees did read the plan, they may not have realized that the plan and the new 

certification requirements in the plan applied to them.

CONCLUSION

An effective acquisition workforce is critical to ensuring that the Government’s

multibillion dollar contracts provide the best value for taxpayer dollars. While 

FAA’s acquisition policy office has devoted significant resources collecting 

workforce data and developing projection models to establish hiring goals, its 

workforce plan and implementation of the plan lack the rigor needed to ensure 

FAA has the right number of qualified Federal employees and contractors to 

manage its complex and demanding acquisitions. Until FAA implements a 

workforce plan that identifies all of its acquisition workforce needs and an 

effective hiring, training, and certification strategy that complies with its plan, it

will continue to put at risk its ability to effectively oversee its acquisitions, 

including its billion dollar NextGen contracts.

RECOMMENDATIONS

To ensure FAA comprehensively identifies its acquisition workforce and required 

competencies, we recommend that FAA’s Director of Acquisition Policy,

Workforce Development, and Evaluation:

1. Develop a standard definition of acquisition workforce and clarify which 

employees are included in each acquisition discipline. Communicate this

definition to all staff involved in identifying the acquisition workforce. 

2. Identify the entire FAA acquisition workforce, including contracted and 

Federal employees for all lines of business. Develop and implement tools and 

internal controls to ensure that FAA accurately identifies its acquisition 

workforce.

3. Determine the best mix of labor resources by identifying the proper roles of 

both contractors and Federal employees, along with the skills sets and expertise 

needed for each group.
15

4. Assess the function and role of TORs. Determine the need to include TORs as 

a part of FAA’s acquisition workforce.

5. Complete competency models for all acquisition disciplines.

6. Determine the need for certification programs for each acquisition discipline, 

and review existing certification programs to determine whether certifications 

should be internal or external. Document justifications for decisions made, and 

include these justifications in the next update of the plan.

To ensure that FAA sufficiently addresses gaps in hiring and developing its 

acquisition workforce, we recommend that the Director:

7. Document reasons for when FAA cannot meet its hiring goals, both overall 

hiring goals and specific hiring targets, for FAA’s lines of business and 

acquisition disciplines.

8. Establish processes for tracking workforce hiring, training, and certification. 

Validate hiring data by requiring that service units identify the discipline fields 

for newly hired acquisition employees.

9. Enforce employee development policies to ensure that all acquisition 

workforce employees complete required training. In particular, ensure that 

contracting officers meet minimum certification requirements for their warrant 

authority.

To ensure FAA fully implements the programs, policies, and practices needed to 

ensure an adequate workforce, we recommend that the Director:

10.Include details on the resources, specific steps, timelines, milestones, and 

deliverables needed to implement future updates to the Acquisition Workforce 

Plan.

11.Notify all acquisition employees of their acquisition roles and duties and 

ensure that they are aware of applicable certification requirements.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided FAA with our draft report on May 25, 2011, and received its 

response on June 27, 2011. FAA's response is included as an appendix to this 

report.26

 26 FAA's informal technical comments are not included.

In its response, FAA concurred with 10 of our 11 recommendations and 
16

partially concurred with one. Although FAA concurred with the majority of our 

recommendations, FAA raised concerns that some of our conclusions are 

misleading and that we do not appropriately recognize the progress the Agency 

has made to date. We acknowledged in our report that FAA has made strides in its 

acquisition workforce planning through its updated 2010 workforce plan. For 

example, FAA has expanded its workforce planning to include additional lines of 

business and has developed additional competency models to specify the skills and 

abilities needed to perform acquisition roles. FAA also reported that it has begun 

tracking its acquisition workforce for large support service contracts and updated 

its Acquisition Management System (AMS) to require all designated contract 

administration staff to certify as COTRs. We believe these positive steps will 

advance FAA’s acquisition planning. However, we have made numerous 

recommendations to ensure that FAA has the right number of qualified Federal 

employees and contractors to manage its complex acquisitions. FAA has already 

implemented many of these recommendations, as we shared our findings with 

FAA throughout our audit.

FAA’s response also stated that our criticism that its 2009 workforce plan was not 

comprehensive is misleading, as the initial plan was never intended to be more 

than a first step. We recognize that acquisition workforce planning is a challenge 

for all Federal agencies and support FAA’s efforts at taking the first step. 

However, in addition to evaluating FAA’s first steps, we wanted to offer a big 

picture view of FAA’s acquisition planning and the steps FAA must take to 

effectively oversee its acquisitions now and in the future. For that reason, we 

regularly updated FAA with our preliminary findings, and FAA implemented 

many of our recommendations.

In addition, FAA indicates that our report offers an inaccurate perspective of its 

staffing levels. We disagree. While FAA’s response cites its 2010 hiring data, our 

conclusions are based on comprehensive analysis of FAA’s own fiscal year 2009 

hiring data. This data showed that the Agency needed an additional 59 engineers 

in fiscal year 2009, but only gained 23—or 38.98 percent—of its engineer demand 

in service units other than NextGen.

27

For all recommendations, except 2, 3, and 11, corrective actions taken or planned 

by FAA address the intent of our recommendations. We consider these 

recommendations (1, 4, 5, 6, 7, 9, and 10) resolved, but open pending our 

Therefore, our assertion that FAA hired less 

than 40 percent of the engineers it needs to support acquisition programs remains 

accurate. Despite concern with our staffing calculations, FAA has concurred with 

our recommendation to document the reasons when it does not meet its annual 

staffing projections.

 27 Because NextGen hiring data contained many blank and incorrect fields, we could not determine whether FAA met 

NextGen’s demand for engineers.
17

verification that the planned actions are complete. Although FAA has provided 

sufficient planned actions for recommendation 8, we request that FAA submit a 

target date for completion of those actions.

For recommendation 2, FAA partially concurred, stating that it does not have the 

resources to include contractors in the workforce plan, but expects program 

officials to “consider” the balance of Federal and contractor FTEs28

Additionally, FAA cannot effectively accomplish recommendation 3, identifying 

the best mix of labor resources, without first completing recommendation 2. 

Accordingly, we request that FAA provide clarification of how it will use the 

contractor count from recommendation 2 to complete recommendation 3. Finally, 

for recommendation 11, FAA did not define the outreach process it plans to use to 

ensure all acquisition employees are aware of roles, duties, and applicable 

certification requirements; therefore, we are requesting that FAA provide us with 

this information as well. Accordingly, we consider all three of these 

recommendations open and unresolved.

required when 

validating current and future staffing requirements. It is unclear to us, however, 

how FAA program managers can "consider" available contractors, if contractors 

are not counted as part of FAA’s acquisition workforce. In addition, FAA states 

that it complies with the OMB’s multi-sector workforce analysis requirements as 

related to the Service Contract Inventory. However, OMB’s guidance on Service 

Contract Inventories requires that inventories account for the number of contractor 

and first tier subcontractor employees, which FAA is currently not doing for its 

acquisition workforce. Accordingly, we are requesting that FAA clarify how it 

plans to count its entire acquisition workforce, including both Federal and 

contracting employees. We also request that FAA submit a planned completion 

date for this recommendation.

ACTIONS REQUIRED

In accordance with Department of Transportation Order 8000.1C, we request that 

you provide a response within 30 days to this report that clearly indicates how you 

will resolve recommendations 2, 3, and 11. We request that you provide a plan for 

counting contractors for recommendation 2, clarify how results from 

recommendation 2 will be used to complete recommendation 3, and describe the 

outreach process for recommendation 11. We also request that you clarify the 

target date for recommendation 8.

 28 Full-Time Equivalent (FTE): the staffing of Federal civilian employee positions, expressed in terms of annual 

productive work hours.
18

We appreciate the courtesies and cooperation of FAA representatives during this 

audit. If you have any questions concerning this report, please call me at (202) 

366-5225 or Terry Letko, Program Director, at (202) 366-1478.

#

cc: Assistant Secretary for Administration

Federal Aviation Administrator

Associate Administrator, Regions and

Center Operations, FAA

Vice President of Acquisition and

Business Services, FAA

Director of Acquisition Policy, 

 Workforce Development, and 

 Evaluation, FAA

Martin Gertel, M-1

Anthony Williams, AAE-001
19

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted our audit work from December 2009 through May 2011 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.

We reviewed OMB guidance on acquisition workforce planning, as well as 

National Association of Public Administrators (NAPA) and General 

Accountability Office (GAO) reports, which provided recommendations to 

improve FAA’s acquisition workforce. We also reviewed FAA’s Acquisition 

Management System (AMS), which establishes acquisition policies and

procedures for FAA, and other applicable laws and regulations.

We interviewed officials from FAA’s acquisition workforce policy office, human 

resource department, and training office. We also spoke with members of FAA’s

Acquisition Executive Council, Acquisition Workforce Council, and strategic 

working groups to determine FAA’s progress for implementing its 2009 

Acquisition Workforce Plan. To verify whether FAA met its hiring needs, we 

examined FAA’s hiring numbers for fiscal year 2009. Further, we independently 

verified FAA’s acquisition workforce tally and its training and certification 

spreadsheets against DOT’s Federal Personnel Payroll System (FPPS) and 

electronic Learning Management System (eLMS), which are additional systems 

FAA uses to track acquisition training and certification.

To verify the data in FAA’s tracking systems, we selected a random sample of 63 

FAA acquisition employees from a universe of 879 acquisition employees 

identified in FPPS. During the interviews, we determined whether the employees’

education, training, and certification corresponded with FAA’s records and 

whether the employees completed the required training courses and certification 

for their acquisition roles. To verify each employee’s skills and competencies, we 

requested copies of the employees’ certifications, warrants, and other relevant 

documentation.
20

Exhibit B. Comparison of FAA’s 2009 and 2010 Acquisition Workforce 

Plans

EXHIBIT B. COMPARISON OF FAA’S 2009 AND 2010 

ACQUISITION WORKFORCE PLANS*

 

2009 2010

Employees and demand

Core acquisition employees 960 1,500

Hiring demand 350 400

Lines of business included in plan

Air Traffic Organization (ATO) 

 ATO employees directly engaged in NAS capital investment programs  

 ATO Mission Support Services

 ATO Service Center

Aviation Safety (AVS) 

Airports (ARP)

Commercial Space Transportation (AST)

Staff offices included in plan

Aviation Policy Planning and Environment (AEP)

Civil Rights (ACR) 

Communications (AOC)

Financial Services (ABA)

Government and Industry Affairs (AGI)

Human Resources Management (AHR)

International Affairs (API) 

Chief Counsel (AGC) 

Regions and Center Operations (ARC) 

Information Services/Chief Information Officer (AIO)(CIO) 

Security and Hazardous Materials Safety (ASH) 

* Factors contributing to the increase in acquisition employees reported in 2010 plan are the inclusion of other FAA 

lines of business beyond ATO and further redefinition of the acquisition workforce.

Source: FAA
21

Exhibit C. Description of FAA’s Acquisition Disciplines

EXHIBIT C. DESCRIPTION OF FAA’S ACQUISITION DISCIPLINES

 

Acquisition Discipline Description

Program/Project 

Management

Program management involves establishing, tracking, managing, and 

reporting all facets of programs and projects, including budget, 

technical requirements, personnel, and customer needs. This job 

family includes those who are officially designated as a program 

manager, project manager, or project lead with authority and 

responsibility for the management and oversight of Federal Aviation 

Administration (FAA) major and non-major acquisition programs or 

projects. 

Engineering and 

Research

Engineering is the discipline and profession of applying scientific 

knowledge and using natural laws and physical resources to design 

and implement materials, structures, machines, devices, systems, and 

processes that realize a desired objective and meet specified criteria. 

Testing and Evaluation

This discipline includes those who are responsible for testing systems 

and programs to ensure they meet specifications, as well as those who 

lead testing activities.

Business and Financial 

Management

Employees in this job family use their knowledge of financial systems 

and business processes to develop, coordinate and integrate 

performance-based budgets; develop metrics; manage, track and 

report financial transactions; develop cost projections; develop 

recommendations to mitigate financial risks; and provide financial and 

investment analysis, including return on investment (ROI).

Contracting

This discipline is responsible for all processes and procedures involved 

in establishing and maintaining contractual relationships. This includes 

understanding the technical requirements, assisting with the 

development of the acquisition strategy, developing a procurement 

strategy plan, reviewing statements of work, evaluating cost estimates, 

determining contractor responsibility, performing administration by 

determining contractor compliance, negotiating cost or price or 

technical changes, monitoring contractor performance, and approving 

payments. 

Contracting Officer 

Technical 

Representative (COTR)

The discipline resolves technical issues, gives technical direction to the 

contractor and interprets technical processes and procedures for the 

contracting officer. 

Integrated Logistics 

Support (ILS)

Integrated Logistics Support is the critical functional discipline that 

plans, establishes and maintains an ILS system for the life cycle of 

FAA products and services. 

Specialized Support

Individuals that support acquisition-related programs but do not fit any 

of the roles above. This can include: safety manager, information 

system specialist, air traffic specialist, administrative functions, 

training.

Source: FAA
22

Exhibit D. Major Contributors to This Report

EXHIBIT D. MAJOR CONTRIBUTORS TO THIS REPORT

Terry Letko Program Director

Name Title

Dory Dillard-Christian Project Manager

Michele Scott Senior Auditor

Christina Lee Analyst

Heather Voda Analyst

Petra Swartzlander Senior Statistician

Karen Sloan Communications Officer
23

Appendix. Agency Comments

APPENDIX. AGENCY COMMENTS

Federal Aviation

Administration

Memorandum

Date: 

To: Mary Kay Langan-Feirson, Assistant Inspector General for Acquisition 

and Procurement Audits 

From: Clay Foushee, Director, Office of Audit and Evaluation, AAE-1 

Subject: OIG Draft Report: FAA Policies and Plans are Insufficient to Ensure an 

Adequate and Effective Workforce 

The Federal Aviation Administration (FAA) is concerned that the OIG draft report does 

not appropriately recognize the progress the Agency has made to date. It is the Agency’s 

view that a more accurate title would be “FAA Has Made Strides in Acquisition 

Workforce Planning and Development.” 

FAA Achieved Significant Strides in Acquisition Workforce Planning

FAA’s initial acquisition workforce planning document was, as the OIG’s draft report 

recognized, an ambitious planning effort, intended to take the first incremental step 

towards comprehensive acquisition workforce planning. In accord with OPM direction to 

sharpen planning for mission critical positions, FAA focused its initial efforts on the 

workforce associated with the Capital Investment Plan (CIP). The acquisition workforce 

plan was labeled “Phase 1,” with the intent to expand to other FAA lines of business in 

the 2010 update, which FAA accomplished. Further iterations will continue to expand 

and refine our acquisition workforce planning efforts. As a result, criticizing the plan for 

not being comprehensive, is misleading, as it was never intended as anything more than a 

first step.

In FY2009, FAA began developing a staffing model for the acquisition workforce. FAA 

used capital investment programs as an organizing construct for the model and examined 

current and historical staffing patterns for Federal employees and contractor support. This 

included a sampling of 47 acquisition programs of various Acquisition Categories 

(ACAT 1-5, based on criteria such as cost, complexity, risk and potential impact to 

safety) and in various phases of the acquisition lifecycle (research and analysis, 

investment analysis, early solution implementation, mid solution implementation, late 
24

Appendix. Agency Comments

solution implementation). Consistent with government-wide findings, collecting accurate 

data on contractor FTEs was especially challenging, and FAA decided to focus, at least 

initially, on the Federal employee workforce. This decision was consistent with our 

objective, as the main focus of the acquisition workforce planning effort is to help ensure 

FAA has a cadre of capable Federal employees to provide consistent, long-term staffing 

and maintain core in-house capabilities vital to the successful management of FAA’s 

major systems acquisitions.

FAA now tracks acquisition workforce gains and losses on a monthly basis and updates 

its planning projections on an annual basis. Data is captured down to the program level. 

FAA is now in the process of expanding its efforts to include acquisition personnel on 

major service contracts such as SE 2020.

FAA Clarified Policy around Technical Officer Representatives

FAA has also resolved issues associated with the use of Technical Officer 

Representatives. Effective in the FAA’s Acquisition Management System (AMS) April 

2011 Quarterly Update, the terms “Task Order Representative” and “Contracting 

Officer’s Representative” were eliminated. All persons appointed by the Contracting 

Officer to support contract administration are now designated Contracting Officer 

Technical Representatives (COTR). In order to be appointed as a COTR, each individual 

must receive a training certification from the Contracting/COTR Career Programs Team, 

Acquisition Career Management Group. Training requirements are established in AMS 

Policy Chapter 5. COTRs that provide direct support to Capital Investment Plan 

programs are included in the Acquisition Workforce Plan. All other agency COTRs are 

tracked separately.

FAA Has Complete Set of Competency Models

FAA has developed, and provided in its 2009 acquisition workforce plan, a complete set 

of competency models for Program/Project Management, Research/ Engineering, 

Business and Financial Management, Contracting, Contracting Officer’s Technical 

Representative, and Leadership. The 2010 plan added competency models for Cost 

Estimating and Integrated Logistics. In FY 2011, FAA completed the competency model 

for Test & Evaluation Specialists (December 2010) and updated/refined its model for 

System Engineering (May 2011). The only profession for which a competency model has 

not been developed is Acquisition Attorney. FAA conducted a benchmarking study in 

2010 and did not find any organization using a formal competency model for the 

Acquisition Attorney role. The only other role identified by the FAA is “Specialty 

Support,” which is not a candidate for a competency model due to the varied nature of 

the work performed by individuals in this category. 

FAA Implemented Measures Necessary to Monitor and Maintain Acquisition 

Workforce
25

Appendix. Agency Comments

Since launching its ambitious planning effort to develop strategies for hiring, training, 

developing, and retaining acquisition employees in September 2009, FAA has: 

• refined definitions of the acquisition workforce and specific professions and 

disciplines; 

• developed an infrastructure and increased collaboration and review protocols to 

support the collection, analysis, and reporting of acquisition workforce data; 

• added and refined competency models for acquisition disciplines/professions; 

• initiated development of an acquisition workforce community portal, including an 

automated certification application process to streamline the certification process, 

track training leading to certification, and create a data warehouse; 

• enhanced the workforce planning process to collect information at the program 

level to improve fidelity of projections; and 

• developed guidance for individuals and their managers to help guide career 

development.

The OIG draft report offers an inaccurate perspective relating to staffing levels for certain 

expertise. For example, the FAA is operating well within the range of engineering staff 

needed to support acquisition programs. When FAA published the 2010 plan (June 2010) 

FAA’s staffing level for engineers was 90% of the FY 2010 demand projection for 

engineers. At the close of FY 2010, FAA’s actual-on-board count was at 93% of its 

projected staffing requirement for engineers. As a result, the OIG’s assertion that FAA 

has hired less than 40 percent of the engineering expertise needed to support its 

acquisition programs is misleading. 

FAA now has measures in place to collect, analyze, and report accurate data on its 

acquisition workforce. Since the 2009 plan, FAA has developed and implemented new 

data collection and validation protocols. Definition of the core acquisition workforce and 

professions/disciplines have been refined, staff coordinate monthly with a steady cadre of 

points-of-contact in the Lines of Business/Service Units to collect gains and loss data, 

data is recorded and maintained in a database that has been refined since the 2009 plan, 

monthly data reports are provided to the Acquisition Workforce Council, and annual 

validation and demand projection updates are vetted up to the representative Council 

executive. 

FAA also has certification programs in place that meet or exceed Executive Branch 

“Federal Acquisition Certifications” (FAC) – FAC-Contracting, FAC-COTR, and FACP/PM. Additionally, FAA provides training, graduate level certificate programs, and 

offers industry certification opportunities for myriad other acquisition disciplines and is 

actively enhancing the competency models and designing additional certification 

programs as appropriate. 

Responses to Recommendations:
26

Appendix. Agency Comments

OIG Recommendation 1: Develop a standard definition of “acquisition workforce” and 

clarify which employees are included in each acquisition discipline. Communicate this 

definition to all staff involved in identifying the acquisition workforce.

FAA Response: Concur. FAA has developed a standard definition of the acquisition 

workforce and has communicated it to all staff involved in identifying the acquisition 

workforce. FAA’s Acquisition Workforce Council reviewed and refined the definition of 

the acquisition workforce and the profession/discipline descriptions in December 2010

and the Acquisition Career Management (ACM) group worked closely with staff in each 

service unit/line of business to apply the definitions during a validation of the onboard 

acquisition workforce in March 2011. Employee listings were then generated by 

organization, and provided to the Acquisition Workforce Council for review. The reports 

included the profession/discipline identified for each employee. The ACM group collects 

gains, losses, and movement data monthly from the service unit/line of business staff and 

provides a detailed report to the Council each month, which includes name, organization, 

profession, and program assignment. Through this process, we enter employees into the 

acquisition workforce database upon entry. Based upon the actions described above, we 

consider final action complete on this recommendation as of March 2011.

OIG Recommendation 2: Identify the entire acquisition workforce, including 

contracted and Federal employees for all lines of business. Develop and implement tools 

and internal controls to ensure that FAA accurately identifies its acquisition workforce.

FAA Response: Partially Concur. Every line of business that has core acquisition 

employees is included in the plan. FAA’s core acquisition workforce consists of Federal 

employees in those lines of business/service units that are primary providers of 

acquisition services on FAA’s Capital Investment Plan (CIP) programs, therefore not 

every line of business is included. The staff managing large support services contracts 

identified in FAA’s CIP, such as SE 2020, are now being tracked as part of the 

acquisition workforce and will be included in the 2011 plan update. Additionally, 

contracting officers and specialists who award and administer the full array of service 

contracts have always been included in the plans. 

FAA has been working to stabilize its processes, tools, and internal controls for 

identifying, tracking, validating and reporting its acquisition workforce. Through these 

stabilization efforts, FAA has developed a process for identifying Federal acquisition 

workforce membership changes from its lines of business/service units on a monthly 

basis. Acquisition workforce data are maintained in database tools to support tracking 

and reporting.

The purpose and focus of the Acquisition Workforce Plan is to ensure FAA has a stable 

cadre of Federal employees to provide consistent, long-term staffing and maintain core 

in-house capabilities necessary to be successful managing FAA’s major systems 

acquisitions. FAA uses Capital Investment Plan programs as the basis for workload 

projections, and projects staffing requirements based on program workload. In this 

constrained budget environment, FAA does not have the resources to do the level of 

analysis required to include contractor FTEs in the workforce plan, and FAA is not aware 

of any other agency including contractor FTEs in their acquisition workforce plans. 

While FAA does not have plans to formally count contractor FTEs in the workforce plan, 
27

Appendix. Agency Comments

during the annual process of validating current staffing and projecting future staffing 

requirements, program officials are expected to consider the balance of Federal 

employees and contractor FTEs required for the acquisition workload. FAA is also 

complying with OMB “multi-sector workforce analysis” requirements related to Service 

Contracts Inventory, in which we assess service contracts to determine how contracted 

services are being used and if contractors are being used in an appropriate manner (e.g., 

not performing inherently governmental work). FAA has fulfilled the intent of this 

recommendation with regard to its Federal acquisition workforce, and based on the 

information provided above, the agency considers final action complete on the 

recommendation.

OIG Recommendation 3: Determine the best mix of labor resources by identifying the 

proper roles of both contractors and Federal employees, along with the skill sets and 

expertise needed for each group.

FAA Response: Concur. As explained in the response to recommendation 2, this is 

being done through the workforce planning process, as well as through the Service 

Contracts Inventory reviews and reports to OMB (FY 2011 review completed June 

2011). Competency models are being used to identify the skill sets and expertise needed. 

Additionally, FAA’s has instituted a Support Contract Review Board (SCRB) that 

reviews all support contracts of $10 million or more, prior to CFO approval. Items 

reviewed include designation and training of COTRs; program office’s assessment that it 

has sufficient resources to adequately monitor the contractor’s performance; and labor 

category information. FAA’s competency models for the acquisition disciplines will be 

provided to the SCRB to help inform their reviews. While FAA will continue to update 

these processes, based on the information provided, it considers action complete on this 

recommendation.

OIG Recommendation 4: Assess the function and role of TORs and CORs. Determine 

the need to include TORs and CORs as part of FAA’s acquisition workforce.

FAA Response: Concur. Effective in the FAA’s Acquisition Management System 

(AMS) April 2011 Quarterly Update, the terms “Task Order Representative” and 

“Contracting Officer’s Representative” were eliminated. All persons appointed by the 

Contracting Officer to support contract administration are now designated Contracting 

Officer Technical Representatives (COTR). In order to be appointed as a COTR, each 

individual must receive a training certification from the Contracting/COTR Career 

Programs Team, Acquisition Career Management Group. Training requirements are 

established in AMS Policy Chapter 5. COTRs are part of FAA’s acquisition workforce. 

We consider action on this recommendation to be complete as of April 2011.

OIG Recommendation 5: Complete competency models for all disciplines.

FAA Response: Concur. FAA has reviewed the acquisition disciplines, identified any 

additional areas that would benefit from competency models, and developed such models 

for these remaining areas. Notably, FAA completed the Test & Evaluation competency 

model in December 2010. FAA also completed an update to the System Engineering 

competency model in May 2011. At this time, FAA has no specific plans to develop a 

competency model for Acquisition Attorneys. A benchmarking study FAA conducted in 

2010 did not find any organization using a formal competency model for the Acquisition 
28

Appendix. Agency Comments

Attorney role. The only other role identified by the FAA for which a competency model 

does not exist is “Specialized Support,” which is not a candidate for a competency model 

due to the varied nature of the work performed by individuals in this category.

The competency models will continue to be reviewed and updated/refined on an ongoing 

basis to ensure they stay relevant. To stay abreast of government and industry 

competency model work, FAA participates on cross-agency Functional Advisory Boards 

chaired by OMB/FAI and engages with industry certification associations (for example, 

Project Management Institute, International Council of System Engineering, International 

Test & Evaluation Association, National Contract Management Association). Based on 

the actions described above, FAA considers action complete on this recommendation.

OIG Recommendation 6: Determine the need for certification programs for each 

acquisition discipline.

FAA Response: Concur. Certification policy has already been established for 

Program/Project Managers, Contracting Officers/Specialists, COTRs, and logistics 

specialists. For Cost Estimators, Test & Evaluation Specialists, and Systems Engineers, 

detailed competency models and dictionaries, tailored to FAA and with tiered-proficiency 

expectations, have been developed and workgroups are mapping training/development 

recommendations to the competencies and developing proposals for certification 

programs. Needs for other acquisition-related certification programs will be assessed 

before the end of FY 2012. 

OIG Recommendation 7: Document reasons for when FAA cannot meet its hiring 

goals, both overall hiring goals and specific hiring targets, for FAA lines of business and 

acquisition disciplines.

FAA Response: Concur. FAA will begin documenting reasons when it does not meet its 

annual acquisition workforce staffing projections. The workforce demand projections in 

the Acquisition Workforce Plan are for planning purposes, to guide regular and recurring 

assessment of staffing levels and balance and make appropriate decisions regarding how 

to shift work or resources to best meet priorities. For the acquisition workforce, 

projecting staffing requirements is not a precise science due to the nature of the work. As

stated in a May 2000 report by the National Academy of Public Administration, entitled 

Guide to Workforce Planning, “Workforce Planning does not require absolute accuracy 

in forecasting; being approximately right is sufficient. Moreover, plans should be updated 

annually, providing an opportunity to keep refining forecasts of future needs and 

challenges.” FAA will document reasons when it does not meet its annual staffing 

projections following the close of each fiscal year, by November 15, 2011 for FY 2011.

OIG Recommendation 8: Establish processes for tracking workforce hiring, training, 

and certification. Validate hiring data by requiring that service units identify discipline 

fields for newly hired acquisition employees.

FAA Response: Concur. FAA is now tracking gains and losses to the acquisition 

workforce on a monthly basis. Gains and losses data collected are by service unit/line of 

business and includes corresponding individual employee data including acquisition 

profession/discipline, program assignment(s) by Capital Investment Plan designator, and 

whether employee is a reassignment into/out of the acquisition workforce from within the 
29

Appendix. Agency Comments

service unit/LOB, a new hire to FAA and the acquisition workforce or loss to the FAA 

(e.g., to another agency, industry, retirement), or a transfer from or to another service 

unit/LOB (and which other service unit/LOB). Reports are provided to the Acquisition 

Workforce Council monthly.

Training is tracked through FAA’s electronic Learning Management System (eLMS) and 

workforce certifications are tracked through a certification database maintained by the 

FAA Acquisition Career Management (ACM) group. The database facilitates data 

collection, accuracy, and reporting. Additionally, the ACM group is piloting a new 

automated certification application and approval process. Certification status reports for 

Contracting Officers/ Specialists and Program/Project Managers are updated and reported 

to the Acquisition Workforce Council monthly. The ACM group also manages and tracks 

other certifications. The ACM group is currently populating a database that provides a 

certification and warrant record for each member of the acquisition workforce. Because 

of an ever-changing workforce, this must be a continuous process as described above. 

FAA requests that the OIG close this recommendation.

OIG Recommendation 9: Enforce employee development policies to ensure that all 

acquisition workforce employees complete required training. In particular, ensure that 

contracting officers meet minimum certification requirements for their warrant authority.

FAA Response: Concur. As stated in the response to Recommendation 8, the ACM 

group is tracking and reporting monthly certification status for employees who have 

certification requirements. Additionally, there are two FAA FY 2011 business plan 

targets specific to certification: (1) 95 percent of Acquisition Category (ACAT) 1 and 2 

programs are managed by a level 3 certified program manager; and (2) 80 percent of 

entry-level contracting specialists achieve level 1 certification within 15 months of hire. 

This is an ongoing process, and FAA requests the OIG close this recommendation. 

OIG Recommendation 10: Include details on the resources, specific steps, timelines, 

milestones, and deliverables needed to implement future updates to the Acquisition 

Workforce Plan.

FAA Response: Concur. Additional detail regarding milestones and deliverables will be 

included in future updates to the Acquisition Workforce Plan, starting with the next 

update expected to be completed on September 30, 2011. More specific project 

plans/steps will be maintained internally by the ACM group and Acquisition Workforce 

Council.

OIG Recommendation 11: Notify all acquisition employees of their acquisition roles 

and duties and ensure they are aware of applicable certification requirements.

FAA Response: Concur. Additional outreach will be conducted this fiscal year to ensure 

each acquisition employee is notified, specifically, that they are included as part of the 

Acquisition Workforce and are aware of the Acquisition Workforce Plan and applicable 

certification requirements. Additionally, the 2011 update to the plan will include a 

“Profile” section for each acquisition profession (as was done in the 2010 plan).