Office of Inspector General 

DEPARTMENT OF HOMELAND SECURITY 

Acquisition Workforce Training 

and Qualifications 

 OIG-08-56 MAY 2008 

Table of Contents 

Executive Summary.............................................................................................................1 

Background..........................................................................................................................2 

Results of Audit ...................................................................................................................4 

DHS and Component Databases....................................................................................4 

Component Supporting Documentation ........................................................................6 

Government-wide Acquisition Career Management Information System ..................10 

DHS Management Directives ......................................................................................10 

DHS and Component Initiatives ..................................................................................12 

Conclusions........................................................................................................................13 

Recommendations..............................................................................................................13

Management Comments and OIG Analysis ......................................................................14 

Appendix A: Purpose, Scope, and Methodology.............................................................15 

Appendix B: Management Comments on the Draft Report ............................................16 

Appendix C: Acquisition Personnel Database Comparison, by Component ..................29 

Appendix D: Major Contributors to this Report..............................................................30 

Appendix E: Report Distribution ....................................................................................31 

Abbreviations 

ACMIS Acquisition Career Management Information System 

AWF DHS Acquisition Workforce Development Office within the Office of the 

Chief Procurement Officer 

CBP U.S. Customs and Border Protection 

CO Contracting Officer 

COTR Contracting Officer’s Technical Representative 

DHS Department of Homeland Security 

FAC-C Federal Acquisition Certification in Contracting 

FAC-P/PM Federal Acquisition Certification for Program and Project Managers 

OMB Office of Management and Budget 

PM Program Manager 

TSA Transportation Security Administration 
OIG 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

This report addresses the Department of Homeland Security’s 

acquisition management challenges for ensuring that contracting 

officers, program managers, and contracting officer’s technical 

representatives, herein referred to as acquisition personnel, meet 

the training and qualifications requirements for the size and 

complexity of the acquisitions to which they are assigned. 

Federal policy requires each agency to collect, maintain, and 

utilize information to ensure effective management of the 

acquisition workforce. However, the Department of Homeland 

Security, U.S. Coast Guard, Transportation Security 

Administration, and U.S. Customs and Border Protection do not 

have complete, reliable information and related supporting 

documentation about their acquisition personnel and their 

assignments. Without such information, the Department of 

Homeland Security has no assurance that qualified staff are 

managing its acquisitions. 

Moreover, several management directives relate to the acquisition 

workforce and the training and qualifications they need to manage 

major acquisitions. Some of these directives do not reflect current 

federal policy and are inconsistent with each other, creating 

confusion about which acquisitions require which levels of 

acquisition workforce certification. 

We are making 3 recommendations to improve the department’s 

ability to manage its acquisition workforce. Management 

generally concurred with our recommendations and we consider 

them resolved. 

Acquisition Workforce Training and Qualifications 

1
Acquisition Workforce Training and Qualifications 

2

 

Background 

With DHS spending about 39% of its budget annually through 

contracts, a high-performing acquisition workforce is fundamental 

to DHS’ ability to accomplish its missions. For example, skilled 

program managers are critical in developing accurate government 

requirements, defining measurable performance standards, and 

managing contractor activities to ensure that intended outcomes are 

achieved. DHS’ Acquisition Oversight Program Guidebook

further emphasizes this connection. 

“A good human capital management approach 

ensures that an agency has the right staff, in the 

right number, with the right skills, in the right 

places, to accomplish its mission effectively. This 

approach requires that an agency devote 

adequate resources to provide its acquisition 

workforce with the training and knowledge 

necessary to perform their jobs. It also requires 

long-range planning, including succession 

planning, to ensure the workforce has the 

necessary skills and qualifications to perform the 

acquisition function into the future.”

The National Defense Authorization Act for Fiscal Year 1996

requires agencies to manage effectively and uniformly their 

acquisition workforces, including accession, education, training, 

career development, and performance incentives. The Office of 

Management and Budget (OMB) refined this requirement “to 

establish the government-wide framework for creating a federal 

acquisition workforce with the skills necessary to deliver best 

value supplies and services, find the best business solutions, and 

provide strategic business advice to accomplish agency missions.”1

The OMB framework, formalized as the federal acquisition 

certification in contracting (FAC-C) and the federal acquisition 

certification for program and project managers (FAC-P/PM), 

specifies the education, training, and experience necessary to 

achieve three certification levels: I, II, or III for FAC-C and entry 

level/apprentice, mid-level/journeyman, and senior level/expert for 

FAC-P/PM. The higher the certification level an individual 

1

 OMB, Developing and Managing the Acquisition Workforce, Policy Letter 05-01, April 15, 2005; The 

Federal Acquisition Certification in Contracting Program, January 20, 2006; The Federal Acquisition 

Certification for Program and Project Managers, April 25, 2007. 
Acquisition Workforce Training and Qualifications 

3

attains, the larger the contract or program the individual can 

manage. For example, a DHS contracting officer must have a 

level III certification to sign procurement actions with total 

contract costs of more than $25 million, including options, award 

fees, and total potential contract ceilings. In contrast, a contracting 

officer with a level I certification can sign procurement actions up 

to the simplified acquisition threshold, which is currently 

$100,000. Table 1 shows another example of the distinctions 

between FAC-P/PM certification levels. Each certified individual 

must meet the previous level certification requirements before 

becoming eligible for a higher certification level. 

Table 1: Program/Project Manager Certification Levels and Roles and 

Responsibilities

Certification Roles and Responsibilities 

Entry Level / 

Apprentice 

Perform as a project team member and manage low risk and 

relatively simple projects or manage more complex projects 

under direct supervision of a more experienced manager. 

Mid-Level / 

Journeyman 

Manage projects or program segments of low to moderate 

risks with little or no supervision. 

Senior Level / 

Expert 

Manage and evaluate moderate to high-risk programs that 

require significant acquisition investment and agency 

knowledge and experience. 

Source: OMB, The Federal Acquisition Certification for Program and Project Managers, April 25, 

2007. 

The FAC-P/PM is not mandatory for all program managers, 

defined in the applicable DHS management directive as “the 

agency customer uniquely empowered to make final scope of 

work, capital investment, and performance acceptability decisions, 

and who is responsible for accomplishing program objectives . . . 

through the acquisition of . . . in-house, contract, or reimbursable 

support resources.” However, program managers assigned to 

major acquisitions must be certified at the senior level, unless an 

authorized official waives requirements in writing, on a case-bycase basis.2

According to FAC-P/PM, to maintain a valid certification, each 

individual must earn at least 80 continuous learning points every 

 

2

 OMB defines major acquisitions, in part, as “a system or project requiring special management attention 

because of its importance to the mission or function of the agency” (OMB, Planning, Budgeting, 

Acquisition, and Management of Capital Assets, Circular No. A-11, Part 7, July 2007). Agencies have 

discretion to expand the definition. DHS guidance is unclear on this point, as discussed in this report. 
Acquisition Workforce Training and Qualifications 

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2 years. Individuals earn points for training activities, such as 

teaching, self-directed study, and mentoring; courses completed to 

achieve higher certification; professional activities, such as 

attending, speaking, or presenting at professional seminars, 

publishing, and attending workshops; or educational activities, 

such as formal training and academic programs. FAC-P/PMs also 

earn points for developmental or rotational assignments. 

Results of Audit 

DHS, Coast Guard, TSA, and CBP do not have complete, reliable 

information and related supporting documentation about their 

contracting officers, program managers, and COTRs and their 

assignments. Without such information, DHS has no assurance 

that qualified staff are managing its acquisitions. Moreover, some 

management directives related to the acquisition workforce do not 

reflect current federal policy and are inconsistent with each other, 

creating confusion about which acquisitions require which levels 

of acquisition workforce certification. Some components are 

taking steps to improve oversight of their contracting officers’, 

program managers’, and COTRs’ training and qualifications. 

When fully implemented, these initiatives should improve DHS’ 

compliance with applicable requirements and its ability to manage 

efficiently its major acquisition workload. 

DHS and Component Databases 

Federal policy requires each executive agency to collect, maintain, 

and utilize information to ensure effective management of the 

acquisition workforce.3

 DHS and its components need complete, 

accurate, and reliable data on its contracting officers, program 

managers, and COTRs to ensure that the appropriate number and 

mix of certified acquisition personnel are overseeing DHS’ 

numerous mission-critical acquisitions. Moreover, DHS and its 

components also need accurate data so they can manage the 

workloads and training of their acquisition workforce. 

DHS and its components maintain databases of information on 

their contracting officers, program managers, and COTRs. Based 

on the purpose of the DHS Acquisition Workforce Development 

Office (DHS AWF) database, it should contain the same total 

number and same individual names as the 3 component databases. 

3

 OMB, Developing and Managing the Acquisition Workforce, Policy Letter 05-01, April 15, 2005. 
Acquisition Workforce Training and Qualifications 

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Instead, there were large differences in the number and names of 

acquisition personnel listed in the DHS AWF and component 

databases, as detailed in the tables below.4

The DHS AWF database contained 1,506 names of contracting 

officers, program managers, and COTRs for the Coast Guard, 

TSA, and CBP. By comparison, component databases contained 

2,136 names, 42% more than the DHS AWF database. 

1,322 of the 1,506 names 

(88%) in the DHS AWF 

database appeared in the 

component databases. 

However, the other 184 

names (12%) in the DHS 

AWF did not appear in the 

component databases. In 

addition, 814 names (38%) 

in the component databases were not in the DHS AWF database. 

Table 2: Database Comparison 

Names DHS AWF Components 

Listed in Both 1,322 1,322 

Unique 184 814 

Total 1,506 2,136 

Source: OIG analysis of agency data. 

We analyzed these results by acquisition role and component 

(Appendix C). Data on program managers had the highest match 

rate, with 90% overlap between the DHS AWF database and the 

components. The average match rate for contracting officers was 

85% and 88% for CBP and TSA COTRs. By component, CBP had 

the highest match rate with the DHS AWF database at 91%. By 

contrast, Coast Guard had 82% and TSA had 87%. 

We also compared the databases to the acquisition personnel 

assigned to the contracts we selected for the audit. The DHS 

components identified for us the acquisition personnel assigned to 

each contract during our review time frame, January 2006 to April 

2007. We then checked whether the names were in the component 

databases. The 3 component databases together contained between 

64% and 75% of the assigned personnel (Table 3). For example, 

the Coast Guard database contained 20 names of the 35 COTRs 

(57%) that Coast Guard officials told us were working on the 

contracts we selected. The TSA database contained 8 names of the 

12 contracting officers (67%) TSA officials told us were working 

on the contracts we selected. For each component reviewed, at 

least 1 individual assigned to the contract was not in the database. 

4

 We excluded Coast Guard COTRs from our analysis due to data compatibility problems. 
Acquisition Workforce Training and Qualifications 

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Table 3: Personnel Assigned to Selected Contracts Compared to 

Component Databases 

Component Contracting 

Officers 

Program 

Managers COTRs 

Component Coast Guard, CBP, and TSA

Component Databases 50 9 46 

OIG Selected Contracts 66 14 66 

Match Rate 76% 64% 70% 

Coast Guard 

Component Databases 28 1 20 

OIG Selected Contracts 38 2 35 

Match Rate 74% 50% 57% 

CBP 

Component Databases 14 3 13 

OIG Selected Contracts 16 7 16 

Match Rate 88% 43% 81% 

TSA 

Component Databases 8 5 13 

OIG Selected Contracts 12 5 15 

Match Rate 67% 100% 87% 

Source: OIG analysis of agency data. 

These discrepancies indicate that DHS and the 3 components do 

not have effective internal controls to ensure that they maintain 

complete and reliable data on their acquisition workforce. DHS is 

likely not complying with federal policies that require each 

executive agency to collect, maintain, and utilize information to 

ensure effective management of the acquisition workforce. At the 

same time, DHS and the 3 components probably do not have all 

the information they need, such as a current inventory of certified 

personnel and the acquisitions to which they are assigned, for 

sound acquisition workforce management decisions. 

Component Supporting Documentation 

Federal policy and DHS management directives for acquisition 

workforce certification require agencies to maintain supporting 
Acquisition Workforce Training and Qualifications 

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documentation for the certification process.5 For the most part, the 

acquisition personnel files that we reviewed did not have 

supporting documentation, such as applications, DHS 

certifications, training certificates, transcripts, and waivers. None 

of the components had complete training, warrant, and certification 

files for their contracting officers, program managers, and COTRs 

readily available. 

Coast Guard: Of the 75 Coast Guard contracting officers’, 

program managers’, and COTRs’ files we reviewed, 32 files (43%) 

had no documentation showing compliance with required basic 

skills training and 54 files (72%) had no evidence of skills 

currency (Table 4). Further, 13 of 35 COTR files (37%) had no 

evidence of procurement ethics training, a requirement that does 

not apply to contracting officers and program managers. 

Table 4: Supporting Documentation for Coast Guard Acquisition 

Personnel Assigned to Sample Contracts between January 2006 and 

April 2007 

Files Reviewed That Did Not Contain Sufficient Evidence 

Supporting 

Documentation Total 

(Percent of 

75 Total) 

Contracting 

Officers 

(Percent of 

38 COs) 

Program 

Managers 

(Percent of 

2 PMs) 

COTRs 

(Percent of 

35 COTRs)

DHS Certification 16 

(21%) 

2 

(5%) 

1 

(50%) 

13 

(37%) 

Skills Currency 54 

(72%) 

24 

(63%) 

2 

(100%) 

28 

(80%) 

Basic Skills Training 32 

(43%) 

19 

(50%) 

2 

(100%) 

12 

(34%) 

Application for DHS 

Certification 

41 

(55%) 

30 

(79%) 

2 

(100%) 

10 

(29%) 

Procurement Ethics 

Training n.a. n.a. n.a. 13 

(37%) 

n.a. Not applicable to this role. 

Source: OIG analysis of Coast Guard files.

 

5

 DHS, Contracting Officer Warrant Program, Management Directive 0740.2, March 12, 2004; COTR 

Certification, Appointment & Responsibilities, Management Directive 0780.1, December 20, 2004; 

Contracting Professional (GS-1102) Career Information, Management Directive 0781.1; February 22, 

2005; and Acquisition Certification Requirements for Program Manager, Management Directive 0782, 

May 26, 2004; OMB, Developing and Managing the Acquisition Workforce, Policy Letter 05-01, April 15, 

2005. 
Acquisition Workforce Training and Qualifications 

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We also examined the expiration dates of the contracting officer’s 

certifications. When a contracting officer’s certification expires, 

the contracting officer no longer meets required qualifications. For 

the 36 contracting officers whose files contained a DHS 

certification, 11 (31%) had expired as of July 31, 2007. The lapsed 

DHS certifications we reviewed had been expired for about 

6 months, on average, with the longest expired for 22 months. 

Only those employees with specific contracting officer authority 

known as a warrant may execute contracts on behalf of DHS. 

Coast Guard files we reviewed for active contracts contained 

expired warrants. Documentation the Coast Guard provided us 

indicated that 13% of the contracting officers assigned to contracts 

in our audit sample might be working with lapsed warrants. 

Compared to August 31, 2007, one contracting officer’s warrant 

had been expired for 20 months, 2 other contracting officers’ 

warrants had been expired for 5 months, and 2 others’ warrants had 

been expired for 3 months. 

As of October 15, 2007, Coast Guard had not provided us with all 

evidence of certification or warrant renewals or evidence of 

transferring these individuals’ responsibilities. Moreover, Coast 

Guard did not fully explain why the warrants have been allowed to 

expire or have not been renewed. Coast Guard officials told us 

that supervisors are responsible for ensuring that the contracting 

officers working for them have current warrants. While this is a 

reasonable first level of oversight, agencies need additional 

internal control measures to ensure that the supervisors fulfill this 

responsibility. 

TSA: The TSA files we reviewed were more organized and tended 

to contain more information than the Coast Guard files. 

Nevertheless, some files did not comply with applicable 

management directives and did not have supporting documentation 

to verify certification, skills currency, and basic skills training 

(Table 5). For example, 3 files of the 32 files (9%) we reviewed 

did not contain DHS certifications; 19 files (59%) did not contain 

evidence that the individual complied with skills currency 

requirements; 7 files (22%) did not indicate that the individual 

completed basic skills training (core courses). 
Acquisition Workforce Training and Qualifications 

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Table 5: Supporting Documentation for TSA Acquisition Personnel 

Assigned to Sample Contracts between January 2006 and April 2007 

Files Reviewed That Did Not Contain Sufficient Evidence 

Supporting 

Documentation Total 

(Percent of 

32 Total) 

Contracting 

Officers 

(Percent of 

12 COs) 

Program 

Managers 

(Percent of 

5 PMs) 

COTRs 

(Percent of 

15 COTRs)

DHS Certification 3 

(9%) 

0 

(0%) 

0 

(0%) 

3 

(20%) 

Skills Currency 19 

(59%) 

6 

(50%) 

2 

(40%) 

11 

(73%) 

Basic Skills Training 7 

(22%) 

4 

(33%) 

2 

(40%) 

1 

(7%) 

Application for DHS 

Certification 

5 

(16%) 

2 

(17%) 

0 

(0%) 

3 

(20%) 

Procurement Ethics 

Training n.a. n.a. n.a. 7 

(47%) 

n.a. Not applicable to this role. 

Source: OIG analysis of TSA files.

CBP: CBP was in the process of gathering additional information 

from its human resources department when we discontinued our 

audit work. Consequently, our analysis of CBP was limited. We 

reviewed the documentation CBP provided us initially and 

determined that some files did not contain certifications or 

contained expired certifications; many of the files did not contain 

evidence that the individuals completed ethics training (Table 6). 

For example, 12 of 40 personnel (30%) had no documentation of 

their DHS certifications in their files. 

Table 6: Supporting Documentation for CBP Acquisition Personnel 

Assigned to Sample Contracts between January 2006 and April 2007 

Files Reviewed That Did Not Contain Sufficient Evidence 

Supporting 

Documentation Total 

(Percent of 

40 Total) 

Contracting 

Officers 

(Percent of 

17 COs) 

Program 

Managers 

(Percent of 

7 PMs) 

COTRs 

(Percent of 

16 COTRs)

DHS Certification 10 

(25%) 

0 

(0%) 

6 

(86%) 

4 

(25%) 

Procurement Ethics 

Training n.a. n.a. n.a. 6 

(38%) 

n.a. Not applicable to this role. 

Source: OIG analysis of CBP files.
Acquisition Workforce Training and Qualifications 

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Government-wide Acquisition Career Management Information 

System 

By July 1, 2007, all civilian agencies were required to maintain 

complete and current acquisition workforce certification records in 

the Acquisition Career Management Information System 

(ACMIS).6

 DHS did not meet the deadline. DHS planned to 

populate its own learning management system, DHScovery, and 

enable it to interface with ACMIS. Schedule problems and 

technical issues prevented implementation of this plan. DHS 

delayed entering its data into ACMIS because it wanted to 

eliminate entry of certification and training information into 

multiple systems, according to the DHS official we interviewed. 

On June 28, 2007, the DHS Chief Procurement Officer notified the 

Office of Management and Budget that DHS would not meet the 

July 1, 2007, deadline and that DHS suspended its effort to 

integrate DHScovery and ACMIS. DHS estimated it would finish 

entering the requisite data into ACMIS by March 21, 2008. In 

April 2008, the responsible DHS official told us that the 

department did not meet the estimate. System problems and 

transition to a new support contractor delayed data entry. 

Not using ACMIS hindered the Federal Acquisition Institute’s 

ability to provide training curriculum support and oversight of the 

federal acquisition certification programs. The Federal Acquisition 

Institute is responsible for reviews of agency compliance with 

certification standards and providing enough on-line and classroom 

training for contracting officers, program managers, and COTRs 

government-wide. 

DHS Management Directives 

Several DHS management directives apply to such acquisition 

personnel as contracting officers, program managers, and COTRs. 

Some directives were not revised timely to reflect current federal 

requirements; others did not establish necessary polices; and others 

were inconsistent with one another. Consequently, their usefulness 

to the affected offices and staff was limited. 

OMB issued the certification program for contracting officers in 

January 2006; DHS did not issue an interim management directive 

6

 OMB, Developing and Managing the Acquisition Workforce, Policy Letter 05-01, April 15, 2005. 
Acquisition Workforce Training and Qualifications 

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to reflect the changes until April 2007, more than one year later. 

DHS officials told us that the differences between DHS 

management directives and FAC/C were not significant, so 

updating the directives was not urgent. 

OMB issued the new FAC-P/PM program requirements in April 

2007; as of October 2007, DHS had not revised its program 

management directive to reflect the new requirements. Significant 

differences exist between the FAC-P/PM program and the DHS 

program management directive. For example, the FAC-P/PM 

program requires entry level/apprentice certificate holders to have 

a minimum of 24 hours in earned value management; the DHS 

program management directive does not require any training in 

earned value management for level I certificate holders. 

Furthermore, some components have delayed implementing the 

new federal certification requirements because DHS delayed 

revising an existing management directive or issuing a new 

directive. DHS officials told us they planned to issue a revised 

directive by the end of calendar year 2007, but had not done so as 

of April 2008. 

DHS has not established policy on the development, selection, 

assignment, and management of program managers. According to 

the existing management directive, DHS will issue such guidance 

in its forthcoming acquisition workforce development program 

manual.7

 Until then, components are directed to use discretion in 

developing procedures for selection, assignment, and management 

of program managers. 

The absence of up-to-date guidance creates a challenge for DHS 

components to track program manager selections, assignments, 

skills currency, and certifications, and thereby ensure that only 

qualified employees have significant acquisition responsibilities. 

Some components have multiple, geographically dispersed 

program offices, increasing the complexity of tracking and 

managing program managers. According to one DHS official, 

some program offices cannot identify their assigned program 

managers. 

DHS does not follow its program manager management directive 

with regard to cost definitions and certification levels; instead, it 

uses the investment review process management directive.8

 The 

7

 DHS, Acquisition Certification Requirements for Program Manages, Management Directive 0782. 8

 DHS, Investment Review Process, Management Directive 1400, May 2003. 
Acquisition Workforce Training and Qualifications 

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investment review process management directive requires that a 

program manager for a single contract with contract costs 

exceeding $50 million9 have a level III certification (senior 

level/expert in FAC-P/PM), the highest level with the most 

education, training, and experience. By contrast, the DHS program 

manager directive10 stipulates that the program manager of a noninformation technology acquisition with program acquisition costs 

between $50 million and $100 million11 must have a level II 

certification (mid-level/journeyman in FAC-P/PM). The level II 

certification requires less education, training, and experience than 

the level III. Consequently, the inconsistencies in DHS directives 

might allow a level II program manager to be assigned to a larger 

acquisition than a level III program manager. 

DHS and Component Initiatives 

Some components are taking steps to improve oversight of their 

contracting officers’, program managers’, and COTRs’ training 

and qualifications. When fully implemented, these initiatives 

should improve DHS’ compliance with applicable requirements 

and its ability to manage efficiently its major acquisition workload. 

For example, TSA has a certification and management database 

that shows program managers’ current certifications and 

assignments. A TSA official told us they periodically reconcile 

their program manager certification management database to the 

DHS AWF database. TSA is developing a COTR certification and 

management system and has established a COTR support office in 

TSA’s Acquisition Office that will focus exclusively on COTR 

management and the certification program. Recently, Coast Guard 

implemented a contracting officer warrant management system, a 

system TSA uses, that will automate the warrant certification 

process. It will enforce DHS warrant guidelines, separation of 

duties, and internal controls. It will also generate reports on 

pending warrants and warrants by issuing authority. It will have a 

tickler feature to alert when warrants are about to expire and skills 

currency is due. 

9

 Contract cost, also known as total contract value, includes options, award terms, and total potential 

contract ceilings. 

10 DHS, Acquisition Certification Requirements for Program Manager, Management Directive 0782. 11 Program acquisition costs are program initiation, concept and technology development, capability 

development and demonstration, and production and deployment costs. 
Acquisition Workforce Training and Qualifications 

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Conclusions 

The absence of complete, accurate, and reliable data on contracting 

officers, program managers, and COTRs likely impedes DHS’ 

effective management of its acquisition workforce. Moreover, not 

providing high-quality information to the Federal Acquisition 

Institute complicates planning for recruiting, hiring, training, and 

budgeting. Finally, DHS’ untimely and inconsistent management 

directives add confusion to the already-complicated major 

acquisition process. 

The capabilities of DHS’ acquisition workforce will determine, to 

a great extent, whether major acquisitions fulfill DHS’ urgent and 

complex mission needs. Contracting officers, program managers, 

and COTRs make critical decisions on a nearly daily basis that 

increase or decrease an acquisition’s likelihood of success. DHS 

must devote adequate resources to ensure that it has “the right 

staff, in the right number, with the right skills, in the right places, 

to accomplish its mission effectively.”12

Recommendations 

We recommend that the Under Secretary for Management, 

together with component acquisition officials, 

Recommendation #1: Develop policies, procedures, and practices 

to maintain and regularly reconcile an accurate, current, and 

reliable inventory of contracting officers, program managers, and 

COTRs and their assignments that fully complies with 

government-wide requirements. 

Recommendation #2: Establish quality control policies, 

procedures, and practices to ensure that the requisite data are 

entered into ACMIS and agency officials have access to evidence 

that certified contracting officers, program managers, and COTRs 

meet education, training, and experience requirements. 

Recommendation #3: Revise DHS acquisition workforce related 

management directives to resolve inconsistencies and to reflect 

current federal training and qualifications requirements for 

contracting officers, program managers, and contracting officer’s 

technical representatives. 

 

12 DHS, Acquisition Oversight Program Guidebook, 0784 Publication, July 2005. 
Acquisition Workforce Training and Qualifications 

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Management Comments and OIG Analysis 

DHS did not fully concur with our findings, but generally 

concurred with our recommendations. DHS disagreed with our 

sampling methodology, asserting that it resulted in statistically 

insignificant samples. In addition, DHS maintained that 

differences between the components’ databases and that of DHS 

AWF are due, in part, to the lag between data entry into their 

respective databases. DHS also commented that these differences 

are expected because the components’ historical files contain more 

records than the DHS database that has existed for a few years. 

With respect to expired warrants, DHS stated that we did not prove 

contracting officers executed actions without proper authority. 

With respect to our methodology, the components were unable to 

provide us lists of current acquisition workforce personnel by 

position, i.e., contracting officer, program manager, and COTR. 

Consequently, we focused on the areas that would create risk for 

DHS mission accomplishment, that is, large, recent contracts. We 

then audited the records for the personnel involved in those 

contracts. We relied on the components to identify the individuals 

assigned to our sample contracts. We did not verify the accuracy 

and completeness of these lists the components provided us. 

The significant differences between the DHS and components’ 

databases indicate that periodic reconciliations have not been 

conducted. While the data entry lag time might explain some 

differences, it is unlikely the cause of the large number of 

differences. In addition, we disagree with DHS’ assertion that 

historical files account for the significant discrepancies. The 

components provided us lists of currently certified individuals that 

would reflect data that at most would be 4 years old, given the 

duration of a valid certification. With respect to expired warrants, 

it is up to the components to demonstrate that they have policies 

and procedures in place to ensure that only contracting officers 

with proper authority can execute contractual actions. 

DHS concurred with our recommendations and has initiated or is 

planning actions to improve the tracking of acquisition personnel 

and documentation of their qualifications and assignments. These 

actions are responsive to our recommendations, and, when fully 

implemented, will likely improve the situation. We consider these 

recommendations resolved, but open, until DHS fully implements 

the corrective actions. 
Appendix A 

Purpose, Scope, and Methodology 

Acquisition Workforce Training and Qualifications 

15

Our audit objective was to determine the adequacy of internal 

controls to ensure compliance with applicable training and 

qualifications requirements for DHS’ acquisition workforce. 

Our audit scope included the DHS Acquisition Workforce 

Development Office (DHS AWF) within the Office of the Chief 

Procurement Officer, Coast Guard, TSA, and CBP. We analyzed 

policies and procedures, conducted interviews with knowledgeable 

officials, and reviewed relevant files. We reviewed DHS AWF 

and component workforce data and assessed internal controls over 

the certification process. We selected a judgmental sample of noninformation technology contracts worth more than $5 million. The 

DHS components identified for us the acquisition personnel 

assigned to each selected contract. We did not independently 

verify the accuracy and completeness of the lists of acquisition 

workforce personnel the components provided us. 

We reviewed training, warrant, and certification records for the 

contracting officers, program managers, and contracting officer’s 

technical representatives (COTRs) who worked on our selected 

sample contracts between January 2006 and April 2007. We 

evaluated the files based on the DHS management directives in 

effect at the time. We completed our file review for all active 

Coast Guard and TSA contracts with values, including options, of 

$50 million or more. We also examined some CBP workforce 

files. We conducted our fieldwork for this audit between April 

2007 and September 2007, under the authority of the Inspector 

General Act of 1978, as amended, and according to generally 

accepted government auditing standards. 
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

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Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

17
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

18
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

19
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

20
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

21
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

22
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

23
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

24
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

25
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

26
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

27
Appendix B 

Management Comments on the Draft Report 

Acquisition Workforce Training and Qualifications 

28
Appendix C 

Acquisition Personnel Database Comparison, by Component 

Total Contracting Officers Program Managers COTRs* COAST 

GUARD, CBP, 

AND TSA 

COMBINED DHS 

AWF

Coast 

Guard, 

CBP 

and TSA

DHS 

AWF

Coast 

Guard, 

CBP, 

and TSA

DHS 

AWF

Coast 

Guard, 

CBP, 

and TSA

DHS 

AWF

CBP 

and 

TSA

Listed in Both 1,322 1,322 348 348 309 309 665 665 

Unique 184 814 60 150 36 33 88 631 

Total 1,506 2,136 408 498 345 342 753 1,296 

 

COAST 

GUARD

DHS 

AWF

Coast 

Guard

DHS 

AWF

Coast 

Guard

DHS 

AWF

Coast 

Guard 

Listed in Both 266 266 218 218 48 48 

Unique 57 98 44 91 13 7 

Total 323 364 262 309 61 55 

 

CBP

DHS 

AWF CBP

DHS 

AWF CBP

DHS 

AWF CBP

DHS 

AWF CBP 

Listed in Both 599 599 73 73 26 26 500 500 

Unique 56 348 1 22 2 2 53 324 

Total 655 947 74 95 28 28 553 824 

 

TSA

DHS 

AWF TSA

DHS 

AWF TSA

DHS 

AWF TSA

DHS 

AWF TSA 

Listed in Both 457 457 57 57 235 235 165 165 

Unique 71 368 15 37 21 24 35 307 

Total 528 825 72 94 256 259 200 472 

* We excluded Coast Guard COTRs from our analysis due to data compatibility problems. 

 

Source: OIG analysis of agency data.

Acquisition Workforce Training and Qualifications 

29
Appendix D 

Major Contributors to this Report 

Rosalyn G. Millman, Director 

Ruth Blevins, Audit Manager 

Sharon Trodden, Auditor-in-Charge 

Melissa Jones, Analyst 

Andre Marseille, Analyst 

Matthew Noll, Analyst 

Acquisition Workforce Training and Qualifications 

30
Appendix E 

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Chief Procurement Officer 

Assistant Secretary for Office of Legislative Affairs 

Commissioner, Customs and Border Protection 

Customs and Border Protection, OIG Audit Liaison 

Assistant Secretary, Transportation Security Administration 

Transportation Security Administration, OIG Audit Liaison 

Commandant, U.S. Coast Guard 

U.S. Coast Guard, OIG Audit Liaison 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as 

appropriate 

Acquisition Workforce Training and Qualifications 

31
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at 

(202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web site at 

www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal 

or noncriminal misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603 

• Fax the complaint directly to us at (202) 254-4292 

• Email us at DHSOIGHOTLINE@dhs.gov 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600 

Attention: Office of Investigations – Hotline 

245 Murray Drive, SW, Building 410 

Washington, DC 20528 

The OIG seeks to protect the identity of each writer and caller.