ARMY 

CONTRACTING

Leadership Lacks 

Information Needed to 

Evaluate and Improve 

Operations

Report to Congressional Requesters

June 2017

GAO-17-457

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-457, a report to 

congressional requesters

June 2017

ARMY CONTRACTING

Leadership Lacks Information Needed To Evaluate 

and Improve Operations

What GAO Found

Top Army leaders conduct department-wide contracting reviews, but they have 

not consistently evaluated the efficiency and effectiveness of the department’s 

contracting operations. Instead, they have primarily focused on efforts to obligate

funds before they expire, as well as competition rates and small business 

participation. In 2014, one of the Army’s key strategic planning documents 

established that contracting operations should adhere to schedule, cost, and 

performance objectives, but Army leaders have not established the timeliness, 

cost savings, and contractor quality metrics needed to evaluate contracting 

operations against such objectives. Without adequate metrics, Army leaders will 

not have the information needed to determine whether Army contracting 

operations are meeting the department’s objectives. Since 2012, Army leaders, 

including successive Assistant Secretaries of the Army (Acquisition, Logistics 

and Technology) (ASA(ALT)), have acknowledged a need for improvements in 

contracting and have taken positive intermittent steps, but GAO found that these 

leaders did not sustain the efforts or—alternately—provide a rationale for not 

doing so. GAO has previously found that leadership must provide clear and 

consistent rationales to effectively drive organizational transformations. If Army 

leadership does not document its rationale for key decisions, the Army’s 

contracting organizations may be missing critical information to effectively

improve operations going forward.

Top Army leaders have not evaluated the effects of major organizational 

changes on contracting operations despite repeatedly changing reporting 

relationships across contracting organizations since 2008, when the Secretary of 

the Army created the Army Contracting Command. The number of changes has 

increased since 2012, with five major changes in 2016.

Number of Major Organizational Changes Affecting Army Contracting Operations, 2008-2016 

Some Army leaders made organizational changes to centralize contracting 

decision-making, while others made changes intended to improve support to field 

operations. When Army leaders made these changes, they did not establish 

measurable objectives in accordance with federal standards for internal control, 

and officials from eight different Army organizations told GAO that the numerous

changes disrupted contracting operations and caused confusion. Further, GAO

found that disagreements over the associated risks and benefits have increased 

tensions among officials in the ASA(ALT) office and at the Army Materiel 

Command (AMC). In the absence of measurable objectives and authoritative 

data, it is unclear whether the benefits of the changes outweighed the costs to 

implement them.

View GAO-17-457. For more information, 

contact Marie A. Mak at (202) 512-4841 or 

MakM@gao.gov.

Why GAO Did This Study

In recent years, GAO and other 

organizations have raised concerns 

about Army contracting operations, 

which directly affect a wide range of 

Army activities. In fiscal year 2016

alone, the Army obligated more than 

$74 billion through contract actions.

GAO was asked to examine the Army’s

contracting operations. This report 

assesses the extent to which Army 

leaders have evaluated (1) the 

efficiency and effectiveness of 

contracting operations and (2) the 

effects of organizational changes on 

contracting operations.

GAO reviewed reports on Army 

contracting commissioned by the 

Secretary of the Army and an 

ASA(ALT); ASA(ALT) memos; Army 

guidance reorganizing AMC; and 

Army-wide contracting oversight 

briefings from fiscal years 2015 and 

2016. GAO also interviewed personnel 

in the Office of the ASA(ALT), at AMC,

and other contracting organizations.

What GAO Recommends

GAO is making eight recommendations 

to improve the Army’s contracting 

operations such as: developing metrics 

to assess contracting operations for

timeliness, cost savings, and 

contractor quality; documenting 

rationales for key decisions; and 

establishing measurable objectives to 

assess the effects of organizational 

changes on contracting operations.

The Army generally concurred with 

GAO’s recommendations, but did not 

agree to establish a contractor quality 

metric because contracting 

organizations cannot control all 

variables that affect quality. GAO 

continues to believe this action is 

needed as discussed in the report. 
Page i GAO-17-457 Army Contracting Leadership

Letter 1

Background 3

Top Army Leaders Conduct Department-wide Contracting 

Reviews, but They Have Not Consistently Evaluated the 

Efficiency and Effectiveness of Contracting Operations 8

Army Leadership Has Not Evaluated How Major Organizational 

Changes Have Affected Contracting Operations, and 

Competing Leadership Visions Have Increased Tensions 20

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 29

Appendix I Objectives, Scope, and Methodology 32

Appendix II Comments from the Department of the Army 36

Appendix III GAO Contact and Staff Acknowledgments 41

Tables

Table 1: Army, Air Force, and Navy Contracting Workforces, 

Fiscal Years 2007 to 2016 15

Table 2: Organizations Included in the Scope of our Army 

Contracting Review 33

Figures

Figure 1: The Contracting Life Cycle 4

Figure 2: Army Contracting Organizational Structure 6

Figure 3: Contract Execution across Army Organizations from 

Fiscal Year 2011-2015 7

Figure 4: Major Changes Army Leaders Made to Reporting 

Relationships across the Department’s Contracting 

Organizations, 2008-2016 21

Figure 5: Army Materiel Command’s Contracting Organizations in 

October 2007 and December 2016 23

Contents
Page ii GAO-17-457 Army Contracting Leadership

Abbreviations

ACC Army Contracting Command

AMC Army Materiel Command

ASA(ALT) Assistant Secretary of the Army (Acquisition, Logistics

 and Technology) 

CER Contracting Enterprise Review

CPARS Contractor Performance Assessment Reporting System

DASA(P) Deputy Assistant Secretary of the Army (Procurement)

HCA Head of Contracting Activity

LCMC Life Cycle Management Command

MEDCOM U.S. Army Medical Command

OPORD Operation Order

NGB National Guard Bureau

PALT Procurement Action Lead Time

PARC Principal Assistant Responsible for Contracting 

PEO Program Executive Office

USACE U.S. Army Corps of Engineers

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Page 1 GAO-17-457 Army Contracting Leadership

441 G St. N.W.

Washington, DC 20548

June 22, 2017

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable William M. “Mac” Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Army relies extensively on its contracting operations to execute its 

mission. In fiscal year 2016 alone, the Army obligated more than $74 

billion on contracts to acquire a wide range of products and services, 

including combat vehicles, aircraft, radios, missiles, ammunition, logistics 

support services, healthcare, and administrative services.

In recent years, the Army has faced challenges in executing its 

contracting operations. Specifically, in October 2015, we found that the 

Army had extensively used bridge contracts—extensions to existing 

contracts or new, short-term sole source contracts to incumbent 

contractors to avoid a gap in service when an existing contract is set to 

expire but the follow-on contract is not ready to be awarded.1 These sole 

source contracts effectively decreased competition and increased the risk 

that the government was paying too much. We subsequently issued a 

management letter to the Executive Director responsible for the contracts 

and recommended training to contracting officers about the appropriate 

use of bridge contracts.2 The Department of Defense concurred with our 

recommendation and indicated that the Army would issue guidance 

reminding contracting professionals about the proper use of bridge 

contracts, but the department has not yet taken the actions necessary to 

address the recommendation. Separately, in December 2015, we found 

 1

GAO, Sole Source Contracting: Defining and Tracking Bridge Contracts Would Help 

Agencies Manage Their Use, GAO-16-15 (Washington, D.C.: Oct. 14, 2015).

2

GAO, Army Contracting: Training and Guidance Needed to Ensure Appropriate Use of 

the Option to Extend Services Clause, GAO-16-262R (Washington, D.C.: Jan. 28, 2016).

Letter
Page 2 GAO-17-457 Army Contracting Leadership

that the Army Materiel Command (AMC) did not have enough contracting 

professionals due to several cost-cutting actions taken by the Army since 

fiscal year 2011 to implement mandated reductions and caps on future 

spending.3 We made four recommendations to ensure that the 

Department of Defense has the right people with the right skills to meet 

future needs. The department concurred with all four recommendations 

but has not yet addressed them. Moreover, a 2013 report on Army 

contracting issues, commissioned by the Office of the Assistant Secretary 

of the Army (Acquisition, Logistics and Technology) (ASA(ALT)), 

identified concerns about inconsistent levels of customer service, 

redundant activities, and inconsistent organizational structures, among 

other things.4

Given these challenges, you asked us to examine the Army’s contracting 

operations. This report assesses the extent to which Army leaders have 

evaluated (1) the efficiency and effectiveness of contracting operations 

and (2) the effects of organizational changes on contracting operations.

In order to assess the extent to which Army leaders have evaluated the 

efficiency and effectiveness of contracting operations, we reviewed key 

oversight documents including Contracting Enterprise Review (CER) 

briefings and Annual Summary Health Reports. CER briefings provide the 

Army’s senior contracting leaders with information about the Army’s 

contracting organizations, such as the number of contract actions they 

execute, obligation and competition rates, and small business 

participation; while Annual Summary Health Reports assess the extent to 

which these organizations comply with federal, defense, and Army 

contracting regulations. We determined that the data contained in the 

CER briefings were not sufficiently reliable for examining the Army’s 

contracting operations, and our discussion of CER data focuses on these 

limitations. We also reviewed all of the action items resulting from those 

CER briefings, strategic guidance such as the Army Campaign Plan, and 

the Army’s Federal Acquisition Regulation Supplement. We also 

interviewed personnel responsible for overseeing Army contracting 

operations in the Office of the ASA(ALT), including the ASA(ALT)’s 

Principal Military Deputy, the Deputy Assistant Secretary of the Army 

 3

GAO, Defense Acquisition Workforce: Actions Needed to Guide Planning Efforts and 

Improve Workforce Capability, GAO-16-80 (Washington, D.C.: Dec. 14, 2015).

4

Censeo Consulting Group, Army Contracting Organization: Structure and Authorities

(July 2013).
Page 3 GAO-17-457 Army Contracting Leadership

(Procurement) (DASA(P)), and the acting Deputy Assistant Secretary of 

the Army (Plans, Programs, and Resources); AMC leadership, including 

the Deputy Commander of AMC and the Deputy Commander of the Army 

Contracting Command (ACC); Heads of Contracting Activity (HCA) at the 

National Guard Bureau (NGB), the U.S. Army Corps of Engineers 

(USACE), and the U.S. Army Medical Command (MEDCOM); seven 

Principal Assistants Responsible for Contracting (PARC); and individuals 

responsible for executing contracting operations throughout the Army.

In order to identify the extent to which Army leaders have evaluated the 

effects of organizational changes on contracting operations, we reviewed 

the Gansler Commission report on Army contracting issued in 2007, a 

2013 report on Army contracting commissioned by the ASA(ALT), and 

documentation of Army decisions to change organizational structures.5

We also interviewed contracting professionals and senior leaders in the 

Office of the ASA(ALT), ACC, NGB, USACE, and MEDCOM; and 

requirements generators from eight additional organizations: three Life 

Cycle Management Commands (LCMC), and five Program Executive 

Offices (PEO).

We conducted this performance audit from May 2016 to June 2017 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.

The Army awards and administers contracts much like the rest of the 

federal government, adhering in broad terms to a generic contracting life 

cycle and the Federal Acquisition Regulation. Figure 1 depicts the 

contracting life cycle.

 5

The Gansler Commission Report on Army Acquisition and Program Management in 

Expeditionary Operations, Urgent Reform Required: Army Expeditionary Contracting (Oct. 

31, 2007); and Censeo Consulting Group, Army Contracting Organization: Structure and 

Authorities (July 2013).

Background
Page 4 GAO-17-457 Army Contracting Leadership

Figure 1: The Contracting Life Cycle

Throughout the contracting life cycle, three key groups have a role in 

meeting the Army’s needs: requirements generators, contracting 

professionals, and contractors themselves.

• Requirements generators are often located in PEOs or LCMCs. 

PEOs are responsible for large acquisition efforts involving major 

weapon systems, while LCMCs are responsible for sustaining many of 

these systems once they have been deployed. Within their respective 

areas of responsibility, both define requirements in documents such 

as statements of work, conduct market research, develop cost 

estimates, and produce written acquisition plans, as necessary. An 

Army official told us they can also participate in the source selection 

process and can serve as contracting officers’ representatives, 

monitoring contractors’ performance on behalf of the government.

• Contracting professionals such as contracting officers use 

information submitted by requirements generators to determine the 

type of contract the Army should award and how best to meet 

competition requirements. They also develop and publish solicitations 

requesting proposals from contractors, and, after receiving these 

proposals, they negotiate with contractors, as appropriate, and lead 

the source selection process. After contract award, contracting 

professionals ensure contractors comply with contractual quality 

assurance requirements and submit required reports in a timely 

manner, among other things. They also closeout the contract, which 

involves verifying that products and services were provided and 

making final payments to contractors.

• Contractors are responsible for delivering products and services to 

the Army in accordance with the terms of the contract. These products 

and services can include major weapon systems, complex research 

and development activities, and day-to-day administrative support, 

among other things.
Page 5 GAO-17-457 Army Contracting Leadership

This report primarily focuses on management of contracting 

professionals, but it is important to note that they alone cannot ensure 

contractors provide the products and services the Army needs, and that 

all three groups, along with senior leadership, play key roles in the 

efficient and effective delivery of products and services.

The Army’s contracting professionals are led by several senior executives 

who are responsible for overseeing the department’s contracting 

functions, delegating contracting authority, and minimizing the risk that 

contracting officers will perform improper acts. These contracting leaders 

include the following:

• The Assistant Secretary of the Army (Acquisition, Logistics and 

Technology) (ASA(ALT)) is the department’s Senior Procurement 

Executive. In this role, Army policy establishes for the ASA(ALT) the 

responsibility to oversee the department’s contracting operations, 

designating contracting activities, and delegating contracting authority.

• The Deputy Assistant Secretary of the Army (Procurement) 

(DASA(P)) supports the ASA(ALT)’s efforts to meet Senior 

Procurement Executive responsibilities involving policies and 

procedures. The DASA(P) also oversees and evaluates the Army’s 

contracting operations.

• Heads of Contracting Activity (HCA) are responsible for 

establishing criteria and procedures to ensure that only contracting 

officers with adequate knowledge and experience award and 

administer contracts. Additionally, the Army’s HCAs personally 

approve contracting decisions that reach a certain dollar amount or 

are particularly complex. The ASA(ALT) has delegated HCA authority 

to four senior contracting professionals at the following commands: 

AMC, NGB, USACE, and MEDCOM.

• Principal Assistants Responsible for Contracting (PARC) are the 

senior contracting officials within their respective contracting 

organizations. They are generally expected to report directly to their 

respective HCAs and are responsible for carrying out authorities 

HCAs delegate to them. Among other things, PARCs can select, 

appoint, train, and terminate contracting officers; approve acquisition 

plans; and waive certain contract requirements. They are also 

required to minimize the potential for contracting officers to be 

subjected to undue influence and to protect them from internal or 

external pressure to perform improper acts. The Army’s four HCAs 

have appointed a total of 24 PARCs.

Army’s Top Contracting 

Leaders
Page 6 GAO-17-457 Army Contracting Leadership

The Army’s contracting leaders, contracting professionals, and 

requirements generators reside in different Army organizations. Figure 2 

depicts the relationship between some of these individuals within the 

larger context of the Army’s organizational structure.

Figure 2: Army Contracting Organizational Structure

The Army’s PARCs often develop relationships with particular 

requirements generators over time. For example, one PARC at MEDCOM 

tends to work with requirements generators from the U.S. Army Medical 

Research and Materiel Command. However, the requirements generators 

do not always reside within the PARCs’ respective organizations. For 

example, requirements generators at PEO Aviation report to the 

ASA(ALT), but they are supported by the PARC at Redstone Arsenal—

one of the 18 PARCs that reports to the ACC commander, who serves as 

Army Contracting 

Organizational Structure
Page 7 GAO-17-457 Army Contracting Leadership

the AMC HCA. In another example, in fiscal year 2015, 45 percent of the 

funds obligated by the Aberdeen Proving Ground contracting center were 

intended to meet the requirements of ASA(ALT) organizations, as 

opposed to 32 percent intended to meet AMC requirements. Nonetheless, 

the PARC at Aberdeen Proving Ground reports to the AMC HCA.

In recent years, contracting professionals at AMC have executed the bulk 

of Army contracts, measured by both dollars obligated and actions 

executed. Figure 3 depicts the dollars obligated and actions executed by 

each of the four HCA organizations from 2011 to 2015.

Figure 3: Contract Execution across Army Organizations from Fiscal Year 2011-

2015
Page 8 GAO-17-457 Army Contracting Leadership

Appropriated funds, including those appropriated to the Army, can be 

classified various ways, including by duration of availability.6 The most 

common type of appropriation is available for obligation only during one 

specific fiscal year. Other types of appropriations are available for 

obligation for a definite period of time in excess of one fiscal year, while 

others are available for obligation for an indefinite period. At the end of 

the period of availability for an appropriation available for one fiscal year 

or for a definite period in excess of one fiscal year, the appropriation 

expires and is no longer available for incurring new obligations. The 

obligated and unobligated balance (if any) remain in an expired account 

for a period of 5 fiscal years, at which point any remaining unexpended 

balances are canceled and returned to the general fund of the Treasury.7

Since 2012, the ASA(ALT) and DASA(P) have used quarterly reviews in 

an effort to assess the overall health of Army contracting and drive 

improvements in contracting operations. However, they have not used 

these reviews to consistently evaluate the efficiency and effectiveness of 

the department’s contracting operations. Instead, several senior Army 

officials indicated that ensuring funds are obligated before they expire is 

the key measure for determining contracting success. In 2014, one of the 

Army’s key strategic planning documents established that contracting 

operations should adhere to schedule, cost, and performance objectives, 

but the ASA(ALT) and DASA(P) have not established the timeliness, cost 

savings, and contractor quality metrics needed to evaluate contracting 

operations against such objectives. Additionally, the ASA(ALT) has not 

established the metrics needed to effectively evaluate the size of the 

department’s contracting workforce. Further, the DASA(P) office has not 

consistently implemented the program it established to improve the 

department’s compliance with acquisition policies and regulations. Since 

2012, successive ASA(ALT)s have taken intermittent steps to improve 

evaluations of the Army’s contracting operations, but we found that they 

have not sustained these efforts.

 6

GAO, Principles of Federal Appropriations Law, 4th ed., 2016 rev., ch. 2, GAO-16-464SP 

(Washington, D.C.: March 2016).

7

GAO, Principles of Federal Appropriations Law, 3rd ed., GAO-04-261SP (Washington, 

D.C.: January 2004). 

Expiration of 

Appropriations

Top Army Leaders 

Conduct Departmentwide Contracting 

Reviews, but They 

Have Not 

Consistently 

Evaluated the 

Efficiency and 

Effectiveness of 

Contracting 

Operations
Page 9 GAO-17-457 Army Contracting Leadership

In 2012, recognizing that the Army’s contracting organizations lacked 

alignment on priorities and metrics, the ASA(ALT) and DASA(P) initiated 

quarterly Contracting Enterprise Reviews (CER) in an effort to increase 

enterprise-wide coordination, assess the overall health of Army 

contracting, and drive improvements in contracting operations. According 

to officials in the DASA(P) office, the intent of the CERs is to establish 

Army-wide contracting metrics and benchmarks, and provide 

opportunities for leadership to make recommendations to improve 

contracting procedures and increase efficiencies. The ASA(ALT) 

coordinated with the DASA(P) office to develop the CER metrics, which 

include the following information that DASA(P) officials collect about each 

HCA: obligation rates, contract actions, competition rates, and small 

business participation. The CERs also include self-reported information 

from the Army’s PARCs. This information is organized by the 

department’s four contracting organizations—ACC, MEDCOM, NGB, and 

USACE—and highlights the PARCs’ successes, such as important 

contract awards, and challenges, such as high attrition rates.

In February 2017, 5 years after the ASA(ALT) and DASA(P) initiated the 

CERs, personnel in the DASA(P) office told us they now consider the 

CER the best mechanism to communicate contracting information to 

senior leadership. However, we found that the Army had not taken some 

basic steps that would help improve contracting procedures and 

contracting health assessments. For example, we found that DASA(P) 

lacked documentation of action items coming out of any of the CERs 

except the one chaired by the ASA(ALT) for the second quarter of fiscal 

year 2016. Now that the CER is recognized as a key communication tool, 

DASA(P) officials told us they are working to address such shortcomings. 

Specifically, they are working to formally define CER policies and 

procedures and intend to do so by the end of fiscal year 2017. Among 

other things, they plan to formalize the process for tracking CER action 

items. DASA(P) representatives acknowledged that there have been 

inconsistencies in how they detailed the results of prior CER briefings. In 

addition, they stated that CER briefings had been treated as individual 

events and not viewed as part of an ongoing process to improve 

contracting operations across the Army. They explained that the 

forthcoming CER policies are intended to address these issues.

Army officials also plan to take steps in fiscal year 2017 to improve the 

reliability of the data presented in the CER briefings. We found several 

discrepancies with the data. For example, obligations and contract action 

data for certain organizations differed within the same CER briefings 

depending on whether the data came from the contracting organization or 

Contracting Oversight 

Officials Use Quarterly 

Reviews to Communicate 

Information to Senior Army 

Leaders, and Have Plans 

to Improve the Reviews in 

2017
Page 10 GAO-17-457 Army Contracting Leadership

DASA(P). In the third quarter fiscal year 2016 CER briefing, USACE 

reported that it completed 39,600 contracting actions and obligated $9.01 

billion. However, these figures were 14 and 16 percent higher, 

respectively, than figures DASA(P) officials reported for USACE in the 

same briefing. DASA(P) representatives told us that the CERs may 

contain internal discrepancies because different Army organizations pull 

data from source systems on different dates. However, none of the CER 

briefings contained caveats or amplifying information to explain any of the 

data discrepancies. DASA(P) representatives told us that the forthcoming 

CER policies are intended to improve the reliability of CER data and to 

clarify the causes of any discrepancies by providing as-of dates for data, 

among other things.

Army officials from contracting centers, PEOs, LCMCs, major commands, 

and department headquarters all told us that Army leadership focuses on 

obligation rates more than any other metric to determine whether 

contracting efforts have been successful. Senior leaders within AMC and 

ASA(ALT) also told us that the Army has an “obligation culture,” and the 

primary focus is ensuring that the Army obligates all of its funds before 

they expire. This focus is partially out of concern that the Army could miss 

opportunities to use available appropriations to meet the department’s 

needs if they expire. Additionally, Army leaders are concerned that 

appropriations in future years may decrease if the Army does not obligate 

all of its appropriations before they expire because it could appear that 

the Army was appropriated more funding than it needed. This issue is not 

unique to the Army, as appropriations are commonly available for 

obligation only during a specific fiscal year. A recent DASA(P) stated, 

however, that this limited perspective increases the risk that contractors 

will not provide the government goods and services in an efficient or 

effective manner. Further, contracting professionals and requirements 

generators repeatedly told us that obligating funds simply to prevent them 

from expiring does not drive the optimal contracting behavior, particularly 

in terms of cost savings.

When Assessing 

Contracting Operations, 

Army Leadership Has 

Primarily Focused on 

Obligation Rates
Page 11 GAO-17-457 Army Contracting Leadership

The ASA(ALT) and DASA(P) have not established the metrics needed to 

evaluate the Army’s contracting operations in terms of timeliness, cost 

savings, or contractor quality. In the absence of these metrics, they have 

not used CERs to consistently evaluate the efficiency and effectiveness of 

the Army’s contracting operations. As a result, it is unclear whether the 

department’s contracting operations have improved over time or instead 

have gotten worse, as several groups of requirements generators,

particularly officials from PEOs, have asserted.

The Army’s 2014 Campaign Plan—a key strategic planning document—

established that contracting operations should adhere to schedule, cost, 

and performance objectives. In practice, Army officials told us this 

involves awarding contracts in a timely manner, achieving cost savings 

through contracting activities, and acquiring quality products and services 

from contractors. Federal standards for internal control state that 

management should obtain information that links to an entity’s 

objectives.8 However, recent ASA(ALT)s and DASA(P)s have not 

established the metrics needed to evaluate the efficiency and 

effectiveness of contracting operations in terms of schedule, cost, or 

performance, in part, because of methodological disagreements. For 

example, contracting professionals and requirements generators disagree 

about how the amount of time it takes to award a contract should be 

measured. Contracting professionals argue that requirements generators 

can provide contracting professionals with poorly defined requirements, 

and, as such, the requirements generators may be responsible for delays 

that occur later in the contracting life cycle when contracting professionals 

have lead responsibility. Similarly, contracting professionals stated that 

they have not come to a consensus on how to measure cost savings 

attributable to contracting efforts. These cost saving measures could 

include comparing contractors’ initial bids to the final negotiated prices 

and avoiding fees, such as licensing fees. As for performance metrics, 

DASA(P) officials told us that they would like to evaluate contractor 

performance on a systemic basis. However, they have not identified an 

effective means to do so, largely due to a shortage of reliable information 

about contractors’ performance.

Through our interviews with Army officials, we identified the following 

challenges surrounding efforts to assess (1) the timeliness of contract 

 

8

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G, 

(Washington, D.C.: September 2014).

Army Contracting 

Leadership Has Not 

Established Metrics to 

Evaluate Its Operations In 

Terms of Timeliness, Cost 

Savings, or Contractor 

Quality
Page 12 GAO-17-457 Army Contracting Leadership

awards, (2) the cost savings attributable to contracting activities, and (3) 

the quality of contractors’ products and services.

Many Army officials consider the timeliness of contract awards the most 

important factor when it comes to contracting operations. Seven of the 

eight groups of requirements generators we interviewed stated that their 

primary concern involving contracting operations is getting their contracts 

awarded as quickly as possible. In June 2016, the ASA(ALT) reflected 

this concern following a CER briefing, directing ACC to address 

inconsistencies in how its contracting centers measure Procurement 

Action Lead Time (PALT). In general terms, PALT is the amount of time it 

takes a contracting organization to award a contract after receiving a 

requirements package from another organization, such as a PEO or 

LCMC. In September 2016, ACC established specific PALT guidelines for 

different types of contract actions—for example, 365 days for competitive 

contracts valued between $50 million and $250 million. However, the 

DASA(P) determined that the guidelines should only be considered a 

draft because his office should perform a more comprehensive PALT 

review and determine those guidelines for contracting operations 

department-wide. DASA(P) representatives told us they planned to initiate 

a year-long PALT assessment in May 2017 and establish departmentwide PALT guidelines by May 2018. However, neither the ASA(ALT) nor 

the DASA(P) has formalized this goal as a required deadline. Federal 

standards for internal control state that management should obtain 

information that links to an entity’s objectives.9 Until the DASA(P) 

representatives complete their PALT assessment, they will not obtain the 

information needed to establish department-wide PALT guidelines, and 

top Army leaders will not have the information needed to determine 

whether the department’s contracting operations are adhering to schedule 

objectives.

As important as timeliness is to requirements generators, timeliness can 

be at odds with other objectives, including cost savings. For example, one 

PARC stated that his contracting officers were able to get a better deal on 

a contract due to 3 weeks of extended negotiations with the contractor. 

He noted that if his contracting officers were assessed solely on 

timeliness, then perhaps they would not have taken the extra time needed 

to negotiate the better deal. As such, Army leaders may need multiple 

 9

GAO-14-704G.

Timeliness of Contract Awards

Cost Savings Attributable to 

Contracting Activities
Page 13 GAO-17-457 Army Contracting Leadership

metrics that reflect these real-world tensions in order to develop a 

comprehensive understanding of the department’s contracting operations.

A former DASA(P) told us that he directed the Army’s PARCs to report 

their organizations’ cost savings attributable to contracting in the fiscal 

years 2015 and 2016 CER briefings. However, the DASA(P) stated that 

he did not establish a standard methodology for calculating the savings, 

and Army contracting officials told us they can use several different 

methods to determine cost savings associated with contracting. For 

example, they can: (a) compare a contractor’s initial bid to the final 

negotiated price; (b) compare the price of a follow-on contract to the price 

of the predecessor contract; and (c) sum potential contract fees that were 

not realized, such as licensing fees. While these can all be legitimate 

methods for measuring savings, Army contracting officials also told us 

how these different methods could produce misleading results. For 

example, a contractor could submit an initial bid that is unrealistically high 

as part of a particular negotiation strategy, which could artificially inflate 

the savings attributable to contracting. The DASA(P) has not yet 

established a standard methodology for calculating savings, and, as a 

result, the CER briefings have not presented the information needed to 

effectively compare cost savings over time or across contracting 

organizations.

Incomplete data sets have also hindered efforts to calculate cost savings 

attributable to contracting activities. Only the PARCs from ACC reported 

any cost savings in CER briefings from the third and fourth quarters of 

fiscal year 2016. As a result, the extent to which the PARCs at NGB, 

MEDCOM, and USACE realized any cost savings is unclear. As 

previously noted, federal standards for internal control state that 

management should obtain information that links to an entity’s 

objectives.10 Until PARCs from NGB, MEDCOM, and USACE report cost 

savings in CER briefings, the ASA(ALT) and DASA(P) will continue to 

lack information needed to determine whether the department’s 

contracting operations are adhering to cost objectives.

The Army’s 2014 Campaign Plan established that contracting operations 

should adhere to performance objectives, and a recent DASA(P) told us 

that—when it comes to performance—requirements generators are 

primarily concerned with the performance of contractors, as opposed to 

 10GAO-14-704G.

Quality of Contractors’

Products and Services
Page 14 GAO-17-457 Army Contracting Leadership

the performance of contracting professionals. However, the CER briefings 

do not include any information on contractor performance—specifically 

the quality of their products and services. The Contractor Performance 

Assessment Reporting System (CPARS) is the government-wide 

database for collecting contractor performance information, and Army 

officials use information collected through CPARS to assist in source 

selections. However, Army officials do not use CPARS—or any other 

system—to provide Army leadership the information needed to compare 

contractors’ performance over time or across contracting organizations. 

The CER briefings identify the extent to which Army officials enter 

information into CPARS, but they do not present any information from 

CPARS on contractors’ actual performance. In theory, this information 

could help Army leadership understand the extent to which soldiers are 

receiving quality products and services, but, in practice, DASA(P) 

representatives do not feel the CPARS information is reliable for 

assessing contractor performance. They noted that the information 

contained in CPARS is subjective and that thousands of required entries 

are overdue. As a result, they have not yet identified an effective means 

to collect and report contractor performance data in aggregate. One 

alternative approach could involve surveys of requirements generators, 

as suggested in a 2013 report on Army contracting commissioned by the 

ASA(ALT), although this approach would likely include its own reliability 

challenges.11 Federal standards for internal control state that 

management should obtain information that links to an entity’s 

objectives.12 Until DASA(P) representatives identify an effective means to 

collect and report contractor performance data, top Army leaders will 

continue to lack information needed to determine whether the 

department’s contracting operations are adhering to performance 

objectives.

 11Censeo Consulting Group, Army Contracting Organization: Structure and Authorities

(July 2013). 

12GAO-14-704G.
Page 15 GAO-17-457 Army Contracting Leadership

Army officials at all levels we spoke with expressed concerns regarding 

the size or experience of the Army’s contracting workforce, but Army 

leaders responsible for contracting have not developed the metrics 

needed to effectively evaluate the scope of that workforce. For example, 

all eight groups of requirements generators that we spoke with identified 

either the size or experience levels of the contracting workforce as a main 

concern in being able to get their contracts awarded. Similarly, PARCs 

reporting to two of the Army’s four HCAs told us they faced significant 

workforce challenges. Our prior work has established that successful 

acquisition efforts depend on agency leadership investing in the 

acquisition workforce.13

According to the Office of the Secretary of Defense, as of September 30, 

2016, the size of the Army’s contracting workforce had decreased by 17 

percent from fiscal years 2007 to 2016, while the size of the contracting 

workforces at the Air Force and the Navy increased by 25 percent. 

Similarly, in December 2015, we found that most Department of Defense 

components sustained their acquisition workforce levels when faced with 

sequestration and other cost-cutting measures, but the Army did not.14

Table 1 shows how the size of the Army’s contracting workforce changed 

from fiscal years 2007 to 2016, compared to the contracting workforces at 

the Air Force and the Navy.

Table 1: Army, Air Force, and Navy Contracting Workforces, Fiscal Years 2007 to 2016

Military department

Contracting workforce

(fiscal year 2007)

Contracting workforce

(fiscal year 2016)

Contracting workforce 

percentage change

Army 9,632 7,959 -17 percent

Air Force 6,762 8,452 +25 percent

Navy 5,076 6,347 +25 percent

Source: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics. | GAO-17-457

The ASA(ALT) has struggled in recent years to identify how large the 

Army’s workforce should be based on its workload, and the responsibility 

for doing so has shifted from one deputy to another. The 2014 Army 

Campaign Plan assigned DASA(P) responsibility for determining the 

 

13GAO, Framework for Assessing the Acquisition Function at Federal Agencies, 

GAO-05-218G (Washington, D.C.: September 2005). 

14 GAO, Defense Acquisition Workforce: Actions Needed to Guide Planning Efforts and 

Improve Workforce Capacity, GAO-16-80 (Washington, D.C.: Dec. 14, 2015).

Army Contracting 

Leadership Has Not 

Established Metrics 

Needed to Effectively 

Evaluate the Contracting 

Workforce
Page 16 GAO-17-457 Army Contracting Leadership

appropriate size of the contracting workforce based on the Army’s 

mission requirements and deployments around the world.15 However, a 

recent DASA(P) told us there is currently no mechanism in place to meet 

this requirement, and explained that the Deputy Assistant Secretary of the 

Army (Plans, Programs, and Resources) is leading an effort to develop a 

contracting workforce model. The Deputy Assistant Secretary of the Army 

(Plans, Programs, and Resources), who also reports to the ASA(ALT), 

previously established a workforce model for program management. The 

Deputy Assistant Secretary’s representatives told us they collected data 

on contracting activities spanning the contracting life cycle, from preaward tasks through contract closeout, for their contracting workforce 

model in order to establish ratios between the amount of dollars the Army 

obligated in a given fiscal year and the contracting personnel on hand in 

the department at that time. They had expected the U.S. Army Manpower 

Analysis Agency would validate the contracting workforce model in fiscal 

year 2016, but, due to data collection issues, they now anticipate it will be 

validated in fiscal year 2018.

Officials from the Office of the Deputy Assistant Secretary of the Army 

(Plans, Programs, and Resources) stated that they are working to convert 

their data into a format the U.S. Army Manpower Analysis Agency uses to 

get the model validated—an important first step in determining the Army’s 

contracting workforce requirements. However, current plans indicate that 

the model will be based on past workload data and will not account for 

future changes involving several workload drivers, such as the type of 

contracting action, whether the acquisition was a product or service, or 

the source selection process. Therefore, the model could produce 

misleading results and understate the number of contracting officers 

needed to meet the Army’s demands. The Deputy Assistant Secretary’s 

representatives stated that the model will not account for changes in 

these variables because it is intended to serve as an initial baseline. They 

acknowledged that the current model is not the final solution for 

determining the Army’s contracting workforce requirements and that it is a 

work in progress. Federal standards for internal control state that 

management should internally communicate quality information in order 

to achieve objectives.16 Army leaders will need more robust information to 

effectively evaluate the department’s contracting workforce and determine 

 15Department of the Army, Army Campaign Plan 2014 Annex I (Washington, D.C., Nov. 5, 

2014).

16GAO-14-704G.
Page 17 GAO-17-457 Army Contracting Leadership

whether requirements generators’ concerns are valid. Until the ASA(ALT) 

and DASA(P) obtain this information, they will not know what steps are 

needed to enhance the department’s contracting workforce.

Since 2008, DASA(P)—responsible for overseeing the Army’s contracting 

operations—has been designated the lead Army official responsible for 

the department’s Procurement Management Review program, which is 

intended to ensure compliance with federal, defense, and Army 

acquisition policy and regulations. Individual reviews of contracting offices 

culminate in an overall organizational risk assessment of low, medium, or 

high; and corrective action plans to address findings and 

recommendations. This program is formally defined in the Army’s Federal 

Acquisition Regulation Supplement, which states that it shall be 

implemented in a tiered manner, with the PARCs, HCAs, and DASA(P) 

conducting complimentary assessments. Specifically, the guidance states 

that:

• reviews will be conducted for all contracting offices at least once every 

36 months;

• every HCA is to submit an Annual Summary Health Report to 

DASA(P) by October 31 each year; and

• DASA(P) officials will produce a holistic assessment of Army 

contracting annually by January 31 each year.

However, DASA(P) has not ensured reviews are conducted consistently 

and within a 36-month period, largely because contracting organizations 

told DASA(P) they did not have the staff needed to do so. For example, 

DASA(P) allowed NGB officials to put their reviews on hold from August 

2015 to January 2016 in order to focus on training their contracting 

officers. Similarly, at the beginning of fiscal year 2017, DASA(P) approved 

an ACC request for a 12-month extension to complete its reviews due to 

personnel shortages. Four years earlier, in fiscal year 2013, ACC did not 

conduct a review due to budget constraints. In another case, a DASA(P) 

representative told us that USACE did not submit an Annual Summary 

Health Report for fiscal year 2015 and did not provide DASA(P) a reason 

for not doing so. Further, when we reviewed 12 Annual Summary Health 

Reports provided by DASA(P)—spanning fiscal years 2013 through 

2015—we found that some contracting offices within ACC, NGB, and 

USACE had not been sufficiently evaluated during the previous 36 

months. Only MEDCOM had reviewed all of its contracting offices in the 

Army Contracting 

Leadership Has Not Met 

Reporting Requirements
Page 18 GAO-17-457 Army Contracting Leadership

time frame suggested by the Army’s Federal Acquisition Regulation 

Supplement.

In addition, DASA(P) did not produce the required holistic, independent 

assessment of Army contracting since 2012. DASA(P) officials stated that 

they could not produce holistic assessments of Army contracting during 

that time because of staffing shortages. Because DASA(P) did not 

implement the program in accordance with Army guidance during this 

time, the HCAs or PARCs self-reported their compliance ratings to the 

ASA(ALT) without independent DASA(P) reviews, as intended. This may 

have increased the likelihood that their findings contained errors or bias, 

and that the PARCs’ corrective action plans did not fully reflect the 

DASA(P)’s perspective. Previously, in fiscal years 2010 and 2011, 

DASA(P) had identified that more than 30 percent of the contracting 

offices they independently reviewed were at risk of serious adverse 

impacts to contracting operations. The deficiencies causing the adverse 

impacts could include violations of policies and statutes, as well as 

missing documentation. To resume the independent reviews, at the 

beginning of 2017, DASA(P) representatives said that they hired a new 

staff member to produce the holistic assessments, and that this staff 

member will initially produce an assessment covering fiscal years 2014 

through 2017 to account for years that DASA(P) previously missed. The 

hiring of this staff member is a positive step; however, it is too early to tell 

if this action alone will improve the rigor of the Procurement Management 

Review program.

In recent years, ASA(ALT)s have taken positive intermittent steps to 

improve the Army’s contracting operations, but they have not sustained 

these efforts. For example, in 2012, the ASA(ALT) initiated an effort 

intended to improve contracting operations by commissioning a study 

focused on courses of action that could strengthen the oversight, 

execution, and accountability of Army contracting. Among other things, 

this study noted that the metrics reported in the CERs focused on the 

administrative activities of the contracting organizations and did not 

measure the quality of their operations. This study included a series of 

recommendations intended to strengthen contracting oversight, and the 

ASA(ALT) issued a memorandum in October 2013 supporting the study’s 

recommendations. However, the ASA(ALT) at that time did not issue 

guidance for implementing the recommendations until January 2016, just 

prior to when this official left the Army.

Army Contracting 

Leadership Previously 

Initiated Efforts to Improve 

Contracting but Has 

Lacked Sustained 

Progress
Page 19 GAO-17-457 Army Contracting Leadership

The January 2016 guidance directed Army officials to develop criteria for 

evaluating the efficiency and effectiveness of contracting operations, 

among other things, but DASA(P) officials noted that the ASA(ALT)’s 

successor did not implement the guidance and did not offer a reason for 

not doing so. Instead, the new ASA(ALT) issued new guidance intended 

to improve the Army’s contracting operations through different, but 

similar, actions. The new guidance focused on: (1) eliminating redundant 

layers of management and oversight; (2) improving the accountability and 

transparency between contracting operations and its customers; and (3) 

improving the contracting workforce and workload. However, similar to 

the preceding ASA(ALT), the new ASA(ALT) issued this guidance one 

day before leaving the Army. This again left the responsibility for 

implementing newly stated contracting guidance to a successor 

ASA(ALT). Officials from the DASA(P) office told us that the current 

ASA(ALT) supports her predecessor’s efforts and intends to implement 

the guidance, but they also said that the next ASA(ALT) may not support 

the efforts, so they want to implement the guidance before the next 

transition.

Those who serve in the ASA(ALT) position may have reasons for not 

implementing their predecessors’ contracting policies, but if that is so, 

they should document and disseminate those reasons. We have 

previously found that leadership must provide clear and consistent 

rationales to effectively drive organizational transformations, and federal 

standards for internal control state that management should internally 

communicate quality information to achieve the entity’s objectives.17

Given the rate of turnover in the ASA(ALT) position, it is critical that 

individuals in that role provide their successors and the Army’s 

contracting workforce their rationales for key decisions, particularly when 

the decisions differ from their predecessors’ guidance. Without this 

information, future ASA(ALT)s may be deprived of critical insights that 

could help them improve Army contracting operations going forward or, at 

a minimum, help them avoid missteps that could degrade the 

effectiveness and efficiency of Army contracting.

In another example of inconsistent leadership, some ASA(ALT)s did not 

consistently chair CERs, even though the CER briefings are the main way 

for contracting leaders to convey contracting information to the ASA(ALT). 

 17GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations ̧ GAO-03-669 (Washington, D.C.: July 2, 2003); 

GAO-14-704G. 
Page 20 GAO-17-457 Army Contracting Leadership

Beginning with the implementation of the CERs in 2012, one ASA(ALT) 

chaired quarterly CERs regularly through fiscal year 2015. However, a 

new ASA(ALT) assumed the position in fiscal year 2016 and, according to 

DASA(P) officials, chaired only one CER due to competing management 

priorities, such as the acquisition of major weapon systems. Following the 

CER briefing that the ASA(ALT) attended, the ASA(ALT) directed ACC to 

take several specific actions that could help improve contracting 

operations, such as determining measures of contracting timeliness and 

methods to minimize workforce reductions. However, this was the only 

time that ASA(ALT) used a CER to direct improvements in contracting 

operations. We have previously found that leadership must set a tone at 

the top and demonstrate strong commitment to improve and address key 

issues.18 By not attending the CERs or otherwise providing feedback on 

the CER briefings, it may unintentionally send a signal to contracting staff 

that contracting issues are not a high priority. Additionally, ASA(ALT)s 

may miss opportunities to improve the Army’s contracting procedures and 

increase efficiencies.

From 2008 through 2016, top Army leaders repeatedly changed reporting 

relationships across the department’s contracting organizations, but they 

did not establish the measurable objectives needed to determine whether 

these changes were successful or if the benefits of the changes 

outweighed the costs to implement them. For example, successive 

ASA(ALT)s made organizational changes to centralize contracting 

decision-making, while a Secretary of the Army and an AMC commanding 

general made organizational changes intended to improve support to field 

operations. However, we found the Army did not establish the goals in 

terms of measurable objectives, so the degree to which the Army has 

achieved the goals is unclear. Additionally, officials from eight different 

Army organizations told us that the changes led to disruptions in 

contracting operations and caused confusion. Senior officials responsible 

for the changes acknowledged the need for measurable objectives to 

evaluate how the changes have affected contracting operations. 

However, these officials have not yet agreed upon specific metrics.

 18GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015).

Army Leadership Has 

Not Evaluated How 

Major Organizational 

Changes Have 

Affected Contracting 

Operations, and 

Competing 

Leadership Visions 

Have Increased 

Tensions
Page 21 GAO-17-457 Army Contracting Leadership

From 2008 to 2016, successive ASA(ALT)s, a Secretary of the Army, and 

an AMC commanding general repeatedly changed reporting relationships 

across the department’s contracting organizations in efforts to improve 

both contracting and field operations. See figure 4 for a timeline 

identifying major changes these Army leaders made from 2008 to 2016.

Figure 4: Major Changes Army Leaders Made to Reporting Relationships across the Department’s Contracting Organizations, 

2008-2016

Army Leaders Have 

Repeatedly Changed 

Contracting Units’

Reporting Relationships
Page 22 GAO-17-457 Army Contracting Leadership

In fiscal year 2007, the Army had 15 HCAs, including 8 within AMC. 

Between 2008 and 2016, the ASA(ALT) rescinded, consolidated, and 

reassigned HCA authority seven times in efforts to improve contracting 

operations, consolidate or clarify contracting professionals’ roles, and 

streamline procedures.

• In 2012, 4 years after the Secretary of the Army created ACC, the 

ASA(ALT) delegated HCA authority to the commanding generals of 

the ACC’s two subordinate commands: the Expeditionary Contracting 

Command and the Mission and Installation Contracting Command, 

which were created to provide contracting support to Army 

installations around the world.

• In 2013, the ASA(ALT) reduced the number of HCAs at MEDCOM 

from two to one. MEDCOM officials explained the ASA(ALT) took this 

action in order to clarify the role of contracting within the organization, 

among other reasons.

• In 2014, the ASA(ALT) consolidated HCA authority at AMC, reducing 

the number of HCAs from nine to one in order to address unclear and 

overlapping contracting authority within the command.

• In February 2015, ASA(ALT) transferred HCA authority from PEO 

Simulation, Training and Instrumentation—which acquires training and 

testing systems for the Army—to AMC when the head of the PEO’s 

contracting center started reporting to the ACC commander.

• In June 2015, the ASA(ALT) transferred HCA authority from the U.S. 

Central Command-Joint Theater Support Contracting Command—

which was responsible for contracting operations in Iraq and 

Afghanistan—to AMC when AMC contracting units took over the 

theater support contracting mission.

• In January 2016, the ASA(ALT) rescinded HCA authority from the 

Intelligence and Security Command due to poor communication 

between its HCA and PARC.

• In December 2016, ASA(ALT) reassigned HCA authority from the 

three commanding generals at AMC, NGB, and USACE to contracting 

professionals within those organizations. According to a former 

DASA(P), with these delegations, the ASA(ALT) emulated the 

MEDCOM model—where the Deputy Chief of Staff, Procurement is 

the HCA—to help ensure that the HCAs are individuals with 

contracting experience who can focus on contracting issues, rather 

than commanding generals who have broader responsibilities.
Page 23 GAO-17-457 Army Contracting Leadership

During the same period, 2008 through 2016, the Secretary of the Army 

and an AMC commanding general changed reporting relationships 

involving a total of 18 PARCs in efforts to improve the Army’s field 

operations. Specifically, these changes were intended to improve 

coordination between contracting centers, deployed forces, and 

logisticians within LCMCs, among others. Figure 5 identifies AMC’s 

contracting organizations at the beginning of fiscal year 2008 and at the 

end of calendar year 2016—before and after the reporting relationships 

changed.

Figure 5: Army Materiel Command’s Contracting Organizations in October 2007 and December 2016

Note: In 2016, AMC divided control over 3 PARCs between ACC and 3 LCMCs; and control over 6 

PARCs between ACC and ASC. At that time, AMC established that administrative control involved 

resources, personnel management, training, and discipline, among other things; operational control 

involved assigning tasks, designating objectives, and giving authoritative direction; and tactical control 

involved the detailed direction necessary to accomplish assigned tasks.
Page 24 GAO-17-457 Army Contracting Leadership

In 2008, the Secretary of the Army dissolved the Army Contracting 

Agency, which had reported to the ASA(ALT), and realigned its units 

under the newly created ACC—a subordinate command under AMC. The 

Secretary of the Army also gave operational control of other AMC 

contracting centers to ACC. These changes were intended to improve 

contracting centers’ relationships with Army units that conduct operations 

around the world.

Eight years later, in February 2016, an AMC commanding general issued 

an Operation Order (OPORD) which reassigned operational control for 3 

PARCs from ACC to 3 LCMCs, and tactical control for 6 other PARCs to 

the Army Sustainment Command. ACC retained administrative control 

over these PARCs. According to AMC officials, leaders made this change 

in order to better integrate the efforts performed by AMC’s subordinate 

commands. For example, AMC leaders explained that some PARCs 

should report to LCMCs because the LCMC commanders have the 

experience and perspective necessary to prioritize the PARCs’ work 

effectively. The LCMC commanders can review contracting priorities with 

both requirements generators and PARCs to ensure that they are all in 

agreement.

It is unclear whether the benefits of the major organizational changes 

Army leaders made from 2008 to 2016 have outweighed the costs 

because Army leaders did not establish the measurable objectives 

needed to assess the effectiveness of the changes. For the same reason, 

it is also unclear whether the changes have led to the desired outcomes. 

For example, when changing reporting relationships in 2016, including the 

OPORD changes and HCA reassignments, neither the AMC commanding 

general nor the ASA(ALT) established the measurable objectives needed 

to assess the costs and benefits of these changes. The AMC 

commanding general issued the OPORD in an effort to better integrate 

AMC’s subordinate commands, but the OPORD lacks measures needed 

to evaluate progress toward better integration, making it difficult to assess 

the OPORD’s long term effect. Similarly, the ASA(ALT) reassigned HCA 

authority in an effort to increase leadership focus on contracting but did 

not establish measures needed to evaluate the extent or benefits of 

increased leadership focus.

Federal standards for internal control state that agency management 

should define objectives in measurable terms so that performance toward 

Army Leadership Has Not 

Evaluated the Effects of 

Major Organizational 

Changes, Which Officials 

Said Disrupted Operations 

and Caused Confusion
Page 25 GAO-17-457 Army Contracting Leadership

achieving objectives can be assessed.19 In addition, the Office of 

Management and Budget’s guidelines for assessing an agency’s 

acquisition function state that agencies should assess their current 

organizational structure in response to organizational changes, and use 

outcome-oriented performance measures to assess the success of the 

acquisition function in order to support the agency’s missions and goals.20

Senior officials involved with the major organizational changes 

acknowledged the need for measurable objectives, but these officials 

have not yet agreed upon specific metrics. For instance, AMC officials 

told us that they are working to develop and implement metrics to assess 

contracting operations at regularly scheduled reviews but have not yet 

finalized the metrics. Additionally, Army officials have not linked the major 

organizational changes to metrics for measuring the timeliness of contract 

awards, cost savings attributable to contracting activities, and the quality 

of contractors’ products and services.

Measurable objectives are particularly important for the Army because the 

major organizational changes have come with costs, causing confusion 

and leading to disruptions in contracting operations. We have previously 

found that productivity often decreases after major organizational 

changes.21 For example, employees may be unsure how to conduct dayto-day operations while transitioning to a new organizational structure. 

The changes Army leaders made to reporting relationships across the 

department’s contracting organizations were not exceptions to this rule. 

Officials from eight Army organizations said the changes led to 

disruptions in contracting operations and confusion among subordinate 

commands. For example, officials from six Army organizations told us that 

the OPORD delayed contract reviews or led to duplicative meetings while 

AMC personnel were determining how to operate within the new 

organizational structure. Similarly, contracting officials from three Army 

organizations told us that when an ASA(ALT) reassigns HCA authority, as 

an ASA(ALT) did in December 2016, workloads increase at lower staff 

levels until the new HCA re-delegates certain decision-making authorities 

to the respective PARCs. This can prevent staff from focusing on their 

primary responsibilities and lead to less efficient operations.

 19GAO-14-704G.

20Executive Office of the President, Office of Management and Budget, Office of Federal 

Procurement Policy, Guidelines for Assessing the Acquisition Function (Washington, D.C.: 

May 2008).

21GAO-03-669.
Page 26 GAO-17-457 Army Contracting Leadership

In the absence of measurable objectives and authoritative data to assess 

the effectiveness of organizational changes, disagreements over the risks 

and benefits of some of the most recent changes have increased tensions 

between officials in the ASA(ALT) office and at AMC. When the AMC 

commanding general issued the OPORD in February 2016, officials in the 

ASA(ALT) office and in units subordinate to the ASA(ALT) expressed a 

number of concerns with potential implications of the OPORD, including 

the potential for LCMC commanders to influence PARC decisions 

inappropriately. Subsequently, ASA(ALT) officials proposed centralizing 

all contracting authority across Army contracting under the Office of the 

ASA(ALT), specifically in DASA(P). DASA(P) argued that centralizing 

HCA authority across Army contracting would better delineate contracting 

and command authority, retain contracting decisions within the 

contracting chain, encourage responsiveness to customer needs, and 

promote the independence of the contracting function. In order to 

centralize HCA authority into a single office, the ASA(ALT) would have 

rescinded the HCA authority for all the HCAs, including the AMC 

commander. AMC officials said they strongly opposed this proposal and 

told us it would degrade communication and integration between its 

subordinate units, displace the mission command of the Army, and 

ultimately lead to the isolation of subordinate contracting units.

Ultimately, in December 2016, the ASA(ALT) instead reassigned HCA 

authority from three commanders, including the AMC commander, to 

contracting professionals within their organizations. As noted earlier, the 

ASA(ALT) did so to help ensure that the HCAs are individuals with 

contracting experience who can focus on contracting issues, rather than 

commanding generals who have broader responsibilities and do not 

necessarily have contracting expertise. Officials at AMC were receptive to 

the change, but its benefits are not universally recognized. According to 

DASA(P) officials, one of the two other commanders that lost HCA 

authority was strongly opposed to the change, and the lack of measurable 

objectives deprives proponents of quantitative data that could be used to 

address such concerns.

In such an environment—characterized by a lack of measurable 

objectives and authoritative data, and increased tensions between 

officials in the ASA(ALT) office and at AMC—some of the Army’s key 

contracting leaders and requirements generators are concerned about the 

effectiveness of the current organizational structures. We found that Army 

personnel at six organizations were concerned that the OPORD created 

the potential for LCMC commanders to sway contracting to favor their 

own requirements or goals when it gave the LCMC commanders 

In the Absence of 

Measurable Objectives, 

Recent Disagreements 

about Reporting 

Relationships Have 

Increased Tensions 

among Officials
Page 27 GAO-17-457 Army Contracting Leadership

operational control over three PARCs. Army officials at two of those six 

organizations expressed concern that LCMC commanders might prioritize 

their own contracting requirements ahead of requirements from other 

organizations that depend on the three PARCs to meet their contracting 

requirements—particularly PEOs. Further, we heard officials voice 

concerns that LCMC commanders might pressure the PARCs to act 

against their best judgment in order to meet LCMC goals. For instance, 

officials expressed concerns that LCMC commanders might pressure 

PARCs to rush contract negotiations in order to more quickly acquire 

spare parts for fielded systems. In addition, some PARCs were 

concerned about the changes in rating chains, as LCMC commanders are 

now responsible for rating the three PARCs’ performance but have a 

limited understanding of contracting issues and the work the PARCs do 

for customers other than LCMCs. Officials told us that these concerns 

have not been realized to date, but, given the relatively short amount of 

time that has passed since the AMC commander issued the OPORD, it is 

still possible that they may be realized in the future. It is important to note 

that such concerns are often inherent in organizational structures where 

contracting professionals report to requirements generators.

The Army’s contracting professionals are critical to the department’s 

efforts to execute its missions. However, Army leadership has taken a 

relatively narrow view of the department’s contracting operations. By 

primarily focusing on ensuring that contracting officers are obligating 

funding before it expires, Army leadership has in effect promoted a “use 

or lose” perspective and deemphasized the efficiency and effectiveness 

of contracting operations. Senior leaders responsible for contracting are 

not systematically assessing the timeliness of contract awards, cost 

savings attributable to contracting activities, or the quality of contractors’

products and services. Additionally, they are not identifying whether they 

have a large enough workforce to meet the department’s contracting 

needs. As a result, Army leadership does not have the quantitative data 

necessary to determine whether the department’s contracting enterprise 

has the capacity needed to operate in an efficient and effective manner.

Moreover, as the ASA(ALT) is the Army’s senior most contracting official, 

it is important to set a tone at the top that contracting issues are a priority.

When ASA(ALT)s do not attend or weigh in on CERs, they signal that 

contracting is not a priority and diminish the concerns raised by 

contracting organizations; they also miss opportunities to improve 

contracting. Some senior Army leaders have taken intermittent steps to 

improve the department’s contracting operations, but inconsistent 

Conclusions
Page 28 GAO-17-457 Army Contracting Leadership

oversight reviews and leadership turnover have stalled key efforts. 

Leadership turnover will continue in the future, and, for this reason, it is 

critical that senior leaders—particularly ASA(ALT)s—document rationales 

for key decisions, especially when these decisions run counter to their 

predecessors’ thinking.

Finally, when senior leaders make organizational changes intended to 

improve operations, they must also establish measurable objectives that 

will allow them to assess progress toward their ultimate goals. In the 

absence of such measures, it is unclear whether issues that necessitated

the organizational changes have been addressed, and whether 

contracting outcomes are improving or getting worse. Importantly, without 

measurable objectives, it is difficult to counter any dissent and confusion 

among affected parties and support the merits of undertaking the 

changes.

To help Army leadership obtain the information needed to evaluate and 

improve contracting operations, we recommend the Secretary of the Army 

take the following eight actions:

1. Ensure the ASA(ALT) and DASA(P) establish and implement CER 

metrics to evaluate the timeliness of contract awards, cost savings 

attributable to contracting activities, and the quality of contractors’

products and services.

2. Ensure the ASA(ALT) and DASA(P) formally establish May 2018 as 

the required deadline for DASA(P) representatives to establish 

department-wide PALT guidelines.

3. Ensure the ASA(ALT) and DASA(P) establish a standard 

methodology for PARCs to calculate the cost savings they report in 

CER briefings; and ensure PARCs from NGB, MEDCOM, and USACE 

use the methodology to report their respective cost savings.

4. Ensure the ASA(ALT) and DASA(P) identify an effective means to 

collect and report contractor performance data.

5. Ensure the ASA(ALT) accurately determines the department’s 

contracting workforce requirements in accordance with the Army’s 

needs.

6. Ensure future ASA(ALT)s document their reasons for not 

implementing their predecessors’ contracting policies, as applicable.

Recommendations for 

Executive Action
Page 29 GAO-17-457 Army Contracting Leadership

7. Ensure ASA(ALT)s consistently chair or otherwise provide feedback 

on quarterly CERs in order to demonstrate commitment to improving 

contracting operations.

8. Ensure that Army leaders establish measurable objectives for 

organizational changes, such as (a) the February 2016 AMC OPORD, 

and (b) the December 2016 HCA delegations.

The Department of the Army provided written comments on a draft of this 

report. These comments are reprinted in appendix II and are summarized 

below. In the written comments, the Department of the Army generally 

concurred with our eight recommendations, although it did not concur with 

one part of our first recommendation. 

The Army concurred with two of the three parts of our first 

recommendation to establish CER metrics that evaluate (a) the timeliness 

of contract awards, and (b) cost savings attributable to contracting 

activities. The Army did not concur with the third part, in which we 

recommended that the ASA(ALT) and DASA(P) establish and implement 

a CER metric to evaluate the quality of contractors’ products and 

services. The Army stated concerns about using such a metric to 

measure the performance of the Army’s contracting organizations 

because contractor performance is related to multiple variables, including 

the quality of government oversight, many of which are not within the 

control of the Army’s contracting organizations. We agree that many 

factors beyond the contracting organization’s control can impact 

contractor performance. Nonetheless, to fulfill their contracting oversight 

responsibilities, we continue to believe the ASA(ALT) and DASA(P) 

should establish and implement a CER metric to evaluate the quality of 

contractors’ products and services; and identify how the quality of 

contractors’ products and services change over time, and how this quality 

varies across the Army’s contracting organizations. Further, this 

information should be included in the CERs because personnel in the 

DASA(P) office told us they consider the CERs the best mechanism to 

communicate contracting information to senior leadership. 

Regarding our second and third recommendations that the Army establish 

a deadline for department-wide PALT guidelines and establish a standard 

methodology for PARCs to calculate cost savings, the Army concurred 

and plans to establish guidance by June 2018 and will work with the 

PARCs to develop a cost saving methodology to incorporate into the CER 

briefings by the second quarter of fiscal year 2018.

Agency Comments 

and Our Evaluation
Page 30 GAO-17-457 Army Contracting Leadership

Regarding our fourth and fifth recommendations to collect and better 

report contractor performance data and accurately determine the 

department’s contracting workforce requirements, the Army concurred, 

and said it plans to focus on ensuring all contractor performance 

assessment reports are timely and complete. The Army said it also plans 

to take a number of actions to include validating and implementing a new 

predictive resource staffing model for the contracting workforce.

The Army concurred with our sixth recommendation to document 

ASA(ALT) reasons, as applicable, for not implementing predecessors’ 

contracting policies and stated that ASA(ALT) policies and procedures 

remain in effect until new direction is issued or the policy is formally 

rescinded with an explanatory rationale. 

The Army concurred with our seventh recommendation to ensure 

ASA(ALT)s consistently chair or provide feedback on quarterly CER 

briefings and is developing a standard operating procedure that will 

explain how feedback, improvements, and recommendations will be 

communicated to the contracting workforce.

The Army concurred with our eighth recommendation, which involves 

measurable objectives for organizational changes. The Army proposed 

several actions to address this recommendation, including developing 

and implementing a methodology to gauge the effectiveness of HCA 

delegations and future organizational changes. We believe the proposed 

actions may do so, but only if Army leaders measure the success of all 

major organizational changes affecting the department’s contracting 

operations, including those changes initiated by organizations outside the 

Office of the ASA(ALT), such as AMC. 

The Army also provided technical comments on the draft report, which we 

incorporated as appropriate.

We are sending copies of this report to the Secretary of the Army and 

other interested parties. In addition, the report is available at no charge on 

the GAO website at http://www.gao.gov.
Page 31 GAO-17-457 Army Contracting Leadership

If you or your staff have any questions about this report, please contact 

me at (202) 512-4841 or makm@gao.gov. Contact points for our Office of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix III.

Marie A. Mak

Director, Acquisition and Sourcing Management
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-17-457 Army Contracting Leadership

The objectives of this review were to examine the extent to which Army 

leaders have evaluated (1) the efficiency and effectiveness of contracting 

operations, and (2) the effects of organizational changes on contracting 

operations.

To address our objectives, we examined several key documents, 

including the 2007 report of the Gansler Commission on Army Acquisition 

and Program Management in Expeditionary Operations, a seminal work 

on Army contracting.1 We also reviewed a 2013 report on Army 

contracting commissioned by the Assistant Secretary of the Army 

(Acquisition, Logistics and Technology) (ASA(ALT)), which included 

recommendations for transforming Army contracting’s organizational 

structure and operations.2 Additionally, we examined strategic guidance, 

such as the Army’s Campaign Plan for 2014, and regulatory documents, 

such as the Army’s Federal Acquisition Regulation Supplement.3 Further, 

we reviewed documents issued by senior Army leaders, including an 

Operation Order (OPORD) a commanding general of the Army Materiel 

Command (AMC) issued in February 2016, which changed the reporting 

relationships for three of its contracting centers; and a memo an 

ASA(ALT) issued in October 2016, which directed the implementation of 

new contracting initiatives.4 In addition, we obtained Army Audit Agency 

reports on various Army contracting issues.

To address our objectives, we also interviewed personnel responsible for 

overseeing contracting operations throughout the Army. Specifically, we 

spoke to Army leaders in the Office of the ASA(ALT), including the 

ASA(ALT)’s Principal Military Deputy, a Deputy Assistant Secretary of the 

Army (Procurement) (DASA(P)), an acting DASA(P), and an acting 

Deputy Assistant Secretary of the Army (Plans, Programs, and 

Resources). We also interviewed three of the Army’s four Heads of 

 1

The Gansler Commission Report on Army Acquisition and Program Management in 

Expeditionary Operations, Urgent Reform Required: Army Expeditionary Contracting (Oct. 

31, 2007).

2

Censeo Consulting Group, Army Contracting Organization: Structure and Authorities

(July 2013).

3

Department of the Army, Army Campaign Plan 2014 (Washington, D.C., August 2013); 

and Army Federal Acquisition Regulation Supplement, 48 C.F.R. chapter 51.

4

Department of the Army, Memorandum for Heads of the Contracting Activity (HCA) and 

Principal Assistants Responsible for Contracting (PARC): Improvements to Army 

Contracting Processes (Washington, D.C.: October 2016); and Army Materiel Command 

Alignments, Operation Order 16-189 (Redstone Arsenal, Al.: February 2016).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-17-457 Army Contracting Leadership

Contracting Activity (HCA): the Director of Acquisitions at the National 

Guard Bureau (NGB), the Director of Contracting at the U.S. Army Corps 

of Engineers (USACE), and the Chief of Staff, Procurement at U.S. Army 

Medical Command (MEDCOM). We interviewed the deputy to the HCA at 

Army Materiel Command (AMC)—the Deputy Commander of the Army 

Contracting Command (ACC)—as well as the Deputy Commanding 

General of AMC. We also interviewed Army officials from seven other 

contracting organizations and eight organizations that generate 

contracting requirements: five Program Executive Offices (PEO), and 

three Life Cycle Management Commands (LCMC). We also interviewed 

officials from the Army Sustainment Command. Table 2 identifies the 

specific organizations.

Table 2: Organizations Included in the Scope of our Army Contracting Review

Organization type Organization name

Senior leadership Office of the Assistant Secretary of the Army (Acquisition, Logistics and Technology)

Army Materiel Command

Contracting

Army Contracting Command (ACC) Headquarters

ACC Aberdeen Proving Ground

ACC Redstone

ACC Rock Island

ACC Warren

National Guard Bureau, Head of Contracting Activity (HCA) Office

U.S. Army Corps of Engineers, HCA Office

U.S. Army Medical Command, HCA Office

Requirements generator

Army Sustainment Commanda

Aviation and Missile Command

Communications-Electronics Command

Program Executive Office (PEO) Aviation

PEO Combat Support & Combat Service Support

PEO Ground Combat Systems

PEO Intelligence, Electronic Warfare & Sensors

PEO Missiles & Space

TACOM (Not an acronym)

Source: GAO presentation of Army data. | GAO-17-457

a

For the purposes of this table, we have categorized the Army Sustainment Command as a 

requirements generator. However, Army officials told us that the command’s role in generating, 

managing, and prioritizing contracting requirements is limited. For that reason, we did not include the 

command in our assessments of the importance of timeliness and workforce issues to requirements 

generators.
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-17-457 Army Contracting Leadership

To assess the extent to which Army leaders have evaluated the efficiency 

and effectiveness of contracting operations, we reviewed key contracting 

oversight documents. Specifically, we obtained and examined 12 Annual 

Summary Health Reports produced by Army officials from fiscal years 

2013 to 2015. The Army’s Federal Acquisition Regulation Supplement 

requires that HCAs produce these reports as yearly assessments of their 

respective contracting operations. We also obtained and examined all of 

the Army’s quarterly Contracting Enterprise Review (CER) briefings for 

fiscal years 2015 and 2016, and documentation of the action items the 

ASA(ALT) issued following the second quarter fiscal year 2016 briefing; 

these were the only CER action items Army officials had documented 

through fiscal year 2016. The DASA(P) office develops the CER briefings 

in order to provide the ASA(ALT) and DASA(P) quarterly assessments of 

the overall health of Army contracting and to allow management to drive 

improvements. The CER briefings contain data DASA(P) officials obtain 

directly from source systems, such as the Federal Procurement Data 

System – Next Generation, and self-reported information from the Army’s 

Principal Assistants Responsible for Contracting (PARC).

In order to assess the reliability of the data in the CER briefings, we 

reviewed the data from each of the quarterly documents from fiscal years 

2015 and 2016, made comparisons, and identified discrepancies. We 

also reviewed source documents, such as the Annual Summary Health 

Reports and the 2013 Army contracting study.5 Further, we interviewed 

DASA(P) officials responsible for coordinating, compiling, and reviewing 

the CER data, and officials from Army contracting organizations that 

provided data and information presented in the CER briefings. We 

determined that the data contained in the CER briefings were not 

sufficiently reliable for examining the Army’s contracting operations, and 

our discussion in the report of CER data focuses on these limitations.

In order to obtain contextual information about the Army’s contracting 

evaluations, we interviewed officials from Army contracting organizations 

that provide DASA(P) officials data and information presented in the CER 

briefings, as well as DASA(P) officials responsible for coordinating, 

compiling, and reviewing the CER data.

 5

Censeo Consulting Group, Army Contracting Organization: Structure and Authorities

(July 2013).
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-17-457 Army Contracting Leadership

To assess the extent to which Army leaders have evaluated the effects of 

organizational changes on contracting operations, we identified major 

changes Army leaders made from 2007 through 2016. We focused on 

this time period because it accounts for the changes Army leaders made 

following the Gansler Commission’s 2007 report on the Army’s 

contracting, including the creation of ACC. We reviewed key documents 

surrounding these changes, including the 2009 general order from the 

Secretary of the Army that created ACC.6 We also reviewed memos 

ASA(ALT)s issued between 2007 and 2016, including six that rescinded, 

consolidated, and reassigned HCA authority; and others that focused on 

the implementation of new processes and practices for contracting 

operations. In addition, we reviewed a memorandum assembled by 

ASA(ALT) representatives that provided perspectives on the OPORD 

AMC issued in February 2016. It included observations from 7 Deputy 

Assistant Secretaries of the Army and 12 PEOs.

In order to obtain different perspectives on the Army’s organizational 

changes, we interviewed Army leaders from the Office of the ASA(ALT) 

and AMC, HCAs, PARCs, and requirements generators. In particular, we 

interviewed Army officials from the three contracting centers affected by 

the February 2016 AMC OPORD, as well as LCMCs, PEOs, and Army 

Sustainment Command.

We conducted this performance audit from May 2016 to June 2017 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.

 6

Army General Order 2009-20: Establishment of the United States Army Contracting 

Command as a Major Subordinate Command of the United States Army Materiel 

Command.
Appendix II: Comments from the Department 

of the Army

Page 36 GAO-17-457 Army Contracting Leadership

Appendix II: Comments from the Department 

of the Army
Appendix II: Comments from the Department 

of the Army

Page 37 GAO-17-457 Army Contracting Leadership
Appendix II: Comments from the Department 

of the Army

Page 38 GAO-17-457 Army Contracting Leadership
Appendix II: Comments from the Department 

of the Army

Page 39 GAO-17-457 Army Contracting Leadership
Appendix II: Comments from the Department 

of the Army

Page 40 GAO-17-457 Army Contracting Leadership
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 41 GAO-17-457 Army Contracting Leadership

Marie A. Mak, (202) 512-4841 or makm@gao.gov 

In addition to the contact listed above, W. William Russell (Assistant 

Director), Nathan Tranquilli (Assistant Director), Lauren A. Friedman, and 

Stephen V. Marchesani made significant contributions to this report. Peter 

Anderson, Kristine Hassinger, Julia Kennon, and Robin Wilson also 

contributed.

Appendix III: GAO Contact and Staff

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100847)
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