4 t h Q u a r t e r 2 0 0 6

Resource Management

P B 4 8 - 0 6 - 4

Resourcing Operation 

Iraqi Freedom’s 

Operations and 

Sustainment:

Magnitude and 

Complexity

3

The Next Hurricane 

Katrina: A New Process 

for Reimbursement

9

I n s i d e

The Army Financial Management Community welcomes

The Honorable Nelson M. Ford, Assistant Secretary

of the Army (Financial Management and Comptroller)
Resource Management is an official professional Bulletin published 

quarterly and sponsored by the Assistant Secretary of the Army for 

Financial Management and Comptroller. Unless otherwise noted, material may be reprinted provided the author and RM are credited. Views 

expressed herein are those of the authors and not necessarily those of 

the Department of the Army or any element thereof. RM provides a 

forum for expression of mature, professional ideas on the art and science 

of Resource management. It is designed as a practical vehicle for the 

continuing education and professional development of resource managers through thought-provoking articles. Send all correspondence to: 

Managing Editor, Resource Management, Comptroller 

Proponency Office, Office of the Assistant Secretary of the Army 

(Financial Management and Comptroller) ATTN: SAFM-PO, 109 Army 

Pentagon, Washington, DC 20310-0109. Queries may be made by phone 

to DSN 222-7413 or commercial (703) 692-7413. Please send a copy of 

each submission to Managing Editor, SAFM-PO, ASST SEC ARMY FIN 

MGT, 109 ARMY PENTAGON, Washington, DC 20310-0109.

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Resource Management, Comptroller Proponency Office, Office of 

the Assistant Secretary of the Army (Financial Management and 

Comptroller) ATTN: SAFM-PO, 109 Army Pentagon, 

Washington, DC 20310-0109.

This medium is approved for 

official dissemination of material 

designed to keep individuals within the 

Army knowledgeable of current and 

emerging developments within their 

areas of expertise for the purpose 

of professional development. 

By order of the Secretary 

of the Army:

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General, United States Army 

Chief of Staff

Administrative Assistant to 

the Secretary of the Army

Joyce E. Morrow

Distribution: Special 

Assistant Secretary 

of the Army

Financial Management

and Comptroller

Nelson M. Ford

Managing Editor,

the Pentagon

Wilett Bunton
Resource Management

Contents

4th Quarter 2006 “Professional Development” P B 4 8 - 0 6 - 4

Resourcing Operation Iraqi Freedom’s Operations and Sustainment

Magnitude and Complexity! 3

Developing Projects in Lean Six Sigma 8

The Next Hurricane Katrina: A New Process for Reimbursement 9

Federal Employee or Contractor Employee? 13

Contractor Employees in the Federal Workplace Part 2 17

Capabilities-Based Costing: Approaches to 

Pre-Milestone-A Cost Estimating 21

Key Comptroller Civilian Career Program 

Results from the Army Civilian Attitude Survey for 

Fiscal Year 2005 and Fiscal Year 2003 23

4 t h Q u a r t e r 2 0 0 6 
The Army Financial Management Community welcomes the Honorable Nelson 

M. Ford, Assistant Secretary of the Army for Financial Management and 

Comptroller. Nelson Ford serves as the Assistant Secretary of the Army for 

Financial Management and Comptroller. His previous position was Principal 

Deputy Assistant Secretary of the Army for Financial Management and 

Comptroller. From 2002 through 2004, he was Deputy Assistant Secretary for 

Health Budgets and Financial Policy in the Department of Defense, where he 

was responsible for financial management, policy development and program 

evaluation for the Defense Health Program. Prior to returning to Federal service, 

Mr. Ford held senior management positions in academic medicine, medical 

manufacturing and health insurance. From 1997 to 2000, he was President 

and CEO of Clinipad, a manufacturer of disposable medical products. During 

the 1990’s, he was Chief Operating Officer of Georgetown University Medical 

Center, with responsibility for Georgetown Hospital and financial oversight of 

faculty practice plans, research activities and the medical and nursing schools. 

Earlier in his career, Mr. Ford was a partner with Coopers & Lybrand, providing 

strategic and financial consulting services to a wide range of healthcare 

clients. During the 1970’s, he was the Executive Secretary of the Health Care 

Financing Administration and worked on health policy matters in the Office of 

Management and Budget. He has served on many not-for-profit boards and 

advisory committees. Mr. Ford holds a bachelor’s degree in history from Duke 

University, a master’s in education from the University of Delaware and has 

completed additional professional training at the University of Pennsylvania. 

He lives in McLean, VA with his wife Cecilia. They have three grown children.

 4 t h Q u a r t e r 2 0 0 6

The Army Financial Management Community welcomes

The Honorable Nelson M. Ford, Assistant Secretary

of the Army (Financial Management and Comptroller)
Resourcing Operation Iraqi Freedom’s 

Operations and Sustainment 

Magnitude and Complexity!

by Colonel Thomas A. Horlander 

Operation Iraqi Freedom (OIF) is undoubtedly the 

most complex and challenging fiscal environment 

in our Nation’s military history. By its very 

nature as a full spectrum, contingency operation that 

concurrently transcends both the kinetic and non-kinetic 

fights from the tactical to strategic level of war, it is one 

of the most dynamic international security endeavors the 

United States (U.S.) Government has ever resourced. To 

have a full appreciation for the magnitude and complexity 

of resourcing Operation Iraqi Freedom from a “boots on 

the ground” perspective, we must first revisit our past as a 

nation and how we arrived at where we are today. 

In the 20th Century, the survival of the United 

States rested upon its ability to defeat its enemy in a 

conventional force on force conflict and then later in a 

nuclear showdown. Success in both of these conflicts 

depended on formidable armed forces capable of 

massing overwhelming forces and firepower at a critical 

place and time – in essence, having the ability to execute 

the Powell Doctrine. By comparison, this approach to 

warfare is simple to understand and prepare for. There 

were rules, a somewhat shared value of human life 

amongst the contenders and the looming threat of world 

devastation and destruction was the saving measure of 

restraint. The answer to victory was relatively simple - to 

achieve kinetic superiority that any potential adversary 

would not dare challenge. Over time, the country most 

capable of fielding and maintaining that overwhelming 

force and its ability to sustain it for a prolonged period 

of time would prevail as the victor. 

For the past century, the distribution of the Federal 

budget was appropriate for the security threat that we 

faced in the post-WWII bipolar world where the super 

power with the most lethal armed forces would prevail 

and did. In 21st Century warfare, we know that this is 

not enough to protect our national security interests 

4 t h Q u a r t e r 2 0 0 6
and secure peace in the world. Much 

of the difficulty the United States (U.S.) 

Government is experiencing today in 

achieving strategic success in the Middle 

East is simply because it is not organized 

nor resourced to conduct full spectrum 

combat operations and nation building 

to the magnitude required in Iraq. This 

should not be surprising to anyone but 

it is fundamental to understanding the 

resourcing challenges the warfighter 

faces everyday on the ground in Iraq. 

The distribution of the Federal budget 

during the last century manifests itself in 

full-spectrum capability voids at every 

level. Many try to explain this by stating 

that “the interagency process is broken” 

or “the U.S. Government remains a Cold 

War dinosaur.” The fact of the matter is, 

the U.S. Government was never organized 

nor resourced to do what we are asking of 

it today in the Global War on Terrorism 

(GWOT). And if America’s grand 

strategy in the Global War on Terrorism 

is to effectuate, together with its Allies, 

permanent change in the Middle East, 

this must change. Fortunate for America, 

the U.S. Government can reengineer its 

organizations and systems that over time 

will allow it to protect its national interest 

and the American people in this new 

21st Century warfare. The creation of the 

Department of Homeland Security is a 

perfect example of this flexibility. However, 

changes of this magnitude take years if 

not decades to realize their full benefits. 

Spending large sums of money in the short 

term is not enough; large bureaucratic 

organizations need years to mature before 

they can be effective. Over time, given 

the correct distribution of the Federal 

budget and focused investment in the 

lesser-resourced owners of the elements of 

national power, the United States will grow 

to be more effective and better prepared to 

fully address the full spectrum nature of the 

21st Century threat.

As pictorially displayed in the chart 

below, the end product of our 20th Century 

Federal budget system is a disproportionate 

distribution of the discretionary budget 

into the military element of national power 

which far exceeds any investments the U.S. 

Government has made in the diplomatic, 

informational and economic elements of 

national power. With such a resourcing 

construct that has persisted throughout 

the last century, the challenge becomes 

making a military centric distribution of 

resources work in such a way that there is 

a more equal distribution across the other 

three elements of national power. This 

is absolutely not to suggest that the U.S. 

Government redirect some of the Defense 

budget to the other lesser-resourced owners 

of the other three elements of power, but 

increase its investment in them so that when 

they are called upon, they are able to fully 

contribute to the mission. This poses a series 

of hard choices for the U.S. Government 

ranging from marginalizing other Federal 

programs to raising taxes or increasing the 

national debt – neither of which are viable 

options during election years.

Inevitably, the burden of a mission 

such as OIF falls squarely on the shoulder 

of the Military Commander. One could 

debate otherwise but the reality is that the 

Funding Elements of National Power (EONP)

My Assertion: Turning battlefield victories into post-conflict strategic success is problematic because the U.S. Government is not organized nor 

resourced for post-conflict operations. Follow the money!

Results: Full Spectrum Capability Voids-Kinetic Supremacy; Soldier 

is the first line diplomat; Insufficient Information Operations; Unresourced Economic Development Enablers 

Challange: How do we distribute and channel the current distribution 

of national monetary resources to produce strategic effects across all 

the Lines of Operations (LOO’s)? 

You are here

The KEY!

DIPLOMACY

INFORMATION

ECONOMIC

MILITARY MILITARY

DIPLOMACY INFORMATION

ECONOMIC

BALANCE

KINETIC NON-KINETIC

LOO’s LOO’s

Governance

Economic Development

Communicating

Transition

Security

Governance

Economic Development

Communicating

Transition

Security

ACTUAL RESOURCES DESIRED EFFECTS

Source: MNC-I CJ8

Multi National Corps - Iraq (MNC-I) CJ8: BUDGET BRIEFING

R E S O U R C E M A N A G E M E N T

 4 t h Q u a r t e r 2 0 0 6
Military Commander has the resources, 

organizational structure and established 

planning and operational capabilities in 

place, rendering him de-facto responsible 

for the operation. It did in post WWII 

Europe and the Pacific and it does in 

Operations Iraqi Freedom and Enduring 

Freedom. Today’s OIF resourcing 

challenge is how to tailor this defense 

centric national resourcing construct so 

that the Commander can impact all five 

lines of operations (LOOs) – governance, 

economic development, communicating, 

transition and security. This is tantamount 

to success in OIF and subsequently GWOT! 

Coming from a Corps Comptroller, you 

may be asking what does this have to 

do with resourcing the operations and 

sustainment of Operation Iraqi Freedom 

at the boots on the ground level? This 

national level resourcing paradigm is what 

ultimately drives the Military Commander’s 

resourcing decisions. Liken this to the 

computer operating software running in 

the background that allows your computer 

to run certain software programs but is 

limited when trying to operate the more 

complex automation programs. Military 

Commanders are resourced to have certain 

capabilities – primarily kinetic - and are 

not well-equipped to conduct full spectrum 

operations. In essence, he can’t run all the 

complex programs he needs to operate in 

order to be successful in this full spectrum 

conflict. At the time, the Commander may 

not be making the connection between 

the United States national level resourcing 

paradigm and the resourcing decisions he 

is faced with, even though this is clearly a 

part of his problem set. Subsequently, his 

only alternative is to seek non-traditional 

sourcing solutions – one being the use of 

the Army’s Operations and Maintenance 

Account (OMA) to source those full 

spectrum capability voids he must have to 

be effective, provided they fall within the 

confines of public law.

On the ground here in Iraq, this 

national-level resource distribution 

construct, firmly embedded in years 

of Cold War geopolitics and Super 

Power posturing, manifests itself in 

an abundance of unique resourcing 

challenges that characterize the everyday 

Comptroller operations of the Multi 

National Corps-Iraq.

1. Requirements Generation – Ebb and 

Flow. Even though the United States 

is in its fourth year of Operation 

Iraqi Freedom, the belief that 

there is a normalized, steady state 

environment that would allow for 

the warfighter to articulate his total 

annual requirements could not be 

further from the truth. Daily, the 

OIF Operations and Sustainment 

requirements change. Commanders 

must make decisions based upon a 

variety of factors – many of them 

outside their span of control. The 

enemy gets a vote! This does not 

however preclude the need to try 

and generate an annual budgetary 

projection. It should however provide 

one with an appreciation for how 

frequently and unpredictably, the 

operational requirements can and 

do change. This manifests itself 

into an ebb and flow of budgetary 

requirements that can change the 

program’s requirements by hundreds 

of millions of dollars with one or a 

series of operational decisions. The 

recent decision to extend a Stryker 

Brigade’s deployment is projected 

to increase the Command’s annual 

budget by $80M - $100M. Operation 

Iraqi Freedom is replete with examples 

of how the rapidly changing threat 

environment and those full-spectrum 

capability voids drive the Commander 

to make resource-intensive decisions 

across all the lines of operations to 

source operations for which he had 

no visibility when the Command 

submitted its annual Command 

Operating Budget (COB).

2. Heavy Dependency on Contractors.

It is an understatement to say that OIF 

is a heavily contracted operation. Well 

over half of what the MNC-I spends 

from its OMA account goes to pay 

contractors for goods provided and 

service performed. The largest contract 

by far, the Army’s LOGCAP (Logistics 

Civil Augmentation Program) contract 

provides for the life support of over 

130,000 U.S., coalition and civilian 

personnel serving in OIF and a variety 

of Corps Logistics Services Support 

and Troop Transportation Mission 

(CLSS/TTM) functions throughout 

Iraq. The magnitude and complexity 

of this contract alone requires a full 

complement of managers, accountants, 

auditors, etc...to ensure it provides the 

warfighter the support he requires in the 

most effective and efficient manner. The 

U.S. Army however, by design chose 

to depend on this large life support 

contract as it would prove to be less 

expensive when spread over a longer 

period of time when the operational 

tempo of the Army would ebb and 

flow between peace and small isolated 

conflicts to a full spectrum ground 

campaign. Other heavily contracted 

areas include new equipment fielding, 

sustainment and maintenance. Virtually 

every new system fielded by the 

U.S. Army is operated, serviced and 

maintained by a contracted workforce. 

Much of the Counter Improvised 

Explosive Devices fight and force 

protection operations today are sourced 

Much of the difficulty the United States government is 

experiencing today in achieving strategic success in the 

Middle East is simply because we are not organized nor 

resourced to conduct full spectrum combat

4 t h Q u a r t e r 2 0 0 6 
R E S O U R C E M A N A G E M E N T

with a contractor based workforce. 

While these can be considered military 

centric, several others heavily contracted 

efforts are clearly to compensate for 

the full-spectrum capability voids 

resulting from years of defense-centric 

Federal budgeting. Where this is most 

evident is in the areas of information 

operations, cultural advisors and C4I 

(Command, Control, Communications, 

Computers and Intelligence) operations, 

all sourced through a series of contracts 

that compensate for the absence of this 

capability in the uniformed ranks, civil 

service and the interagency.

3. Contingency Operations Budgeting. 

You have heard it said a hundred times. 

“You don’t know what you don’t know.” 

Although an oversimplified statement 

when talking about contingency budgets, 

it is never more true than here in OIF. 

In Operation Iraqi Freedom, the Multi 

National Corps-Iraq is the Title X 

headquarters for the theater and as such, 

budgets for all military units using OMA 

funding to conduct their operations. 

This is virtually every military command 

located in Iraq. Resourcing contingency 

operations requires a more frequent 

budgeting cycle. MNC-I conducts a 

monthly budgeting cycle where units 

submit their requirements on a spend 

plan, and then funds are distributed 

and executed every thirty days. While 

this drill is manpower intensive, it 

is necessary to ensure that a unit is 

resourced for its immediate needs that 

are often not foreseeable even 20 – 30 

days prior. While this process should not 

be attributed to full spectrum capability 

voids, many of the requirements that the 

commands are seeking to resource are 

meant to fill them.

4. New System Fielding. Operation 

Iraqi Freedom has seen the fielding 

of hundreds of new systems from the 

Add-On-Armor for wheeled vehicles 

and several Unmanned Aerial Vehicles 

(UAVs) and Intelligence, Surveillance 

and Reconnaissance (ISR) platforms to 

the advanced combat helmet/modular 

integrated communication helmet 

(MICH) and Enhanced Small Arms 

Protective Inserts (E-SAPI) plates. Many 

of these systems were fielded through 

a rapid fielding initiative, partially 

tested, and certainly without any clear 

and mature idea as to what it would 

cost to sustain them. These unknowns 

equate to budgetary unpredictability 

at all levels. The lack of any historical 

data by which to cost out the operations 

and maintenance of these systems 

leaves Program Managers, and the field 

with some vast unknowns on how to 

accurately forecast the annual cost of 

operating these systems in combat. 

5. Personnel & Organizational 

Turbulence. While this is not a 

Resource Management-specific 

problem, the personnel and unit 

turnovers in OIF cannot be discounted 

as not having a significant impact on 

the Command’s resourcing operations. 

“TOA (Transition of Authority) 

Season” is a highly turbulent time for 

a Command at every level and from 

every angle. Because of the technical 

nature of Resource management, 

and most people’s unfamiliarity with 

resourcing contingency operations in 

Operations Iraqi Freedom and sourcing 

non-traditional military capabilities, 

comptroller personnel turnover is 

especially challenging. Comptrollers 

must conduct some deliberate planning 

and coordinating to facilitate a smooth 

handover of responsibilities while 

concurrently supporting the ongoing 

combat operations. A unit’s TOA 

and/or frequent Worldwide Individual 

Augmentee System (WIAS) personnel 

turnover manifests themselves in a 

continuous steep learning curve, not 

like anything a Comptroller would 

experience at home station.

6. Cash or No Deal. The Iraqi banking 

industry is hamstrung with a history 

of distrust and oppression, adding 

an element of complexity to already 

complex business practices on the 

ground. Business transactions in Iraq 

are conducted on a cash basis with non 

U.S. vendors. There is no check cashing, 

use of a credit card or electronic transfer 

of funds when purchasing something 

from an Iraqi vendor. You either have 

U.S. dollars or Iraqi Dinar or you don’t 

conduct business on the local economy; 

and for an Iraqi to have U.S. dollars in 

his shirt pocket could mean death if 

discovered by the wrong person. There 

is no central banking system per se. 

The Iraqi banking system was designed 

by the Sadaam Hussein regime to be 

this way as a mechanism of control 

over its people. This manifests itself 

not only in an incredibly inefficient 

way of doing business and providing 

for ample opportunities to “skim off 

the top” but ultimately in a lack of 

international commerce. International 

business men, wanting to do business 

with Iraqis must find innovative ways to 

exchange payments, often through other 

country’s banks. This renders many fiscal 

initiatives that the U.S. considers routine, 

problematic in their implementation. 

For our soldiers on the ground, it has a 

host of implications, most evident in the 

requirement to transport large sums of 

cash around the battlefield. 

The fact of the matter is, 

the United States 

Government 

was never organized 

nor resourced to do what 

we are asking of it today 

in the Global War on 

Terrorism. 

R E S O U R C E M A N A G E M E N T

 4 t h Q u a r t e r 2 0 0 6
7. Boots on the Ground – Daily Business. 

Resource managers at the Division level 

and below face a completely different 

problem set than what they experience 

back at home station. Field Ordering 

Officers (FOOs), Project Purchasing 

Officers (PPOs), Pay Agents (PAs), 

warranted Contracting Officers (KOs), 

interpreters and cultural advisors are 

only a part of the daily challenges. All 

acquisitions and projects valued at 

greater than $200K must be first staffed 

through one of MNC-I’s Requirements 

Validation boards and then approved 

by the Corps Chief of Staff before it can 

be funded. Comptrollers primarily use 

OMA funding for their daily needs but 

several unique authorities and sources 

of funds [Rewards, Commanders 

Emergency Relief Program, Bulk funds, 

Detainee Release payments, Transition 

Team Integration Funds, Iraqi Security 

Force (Quick Reaction Force) Funds, 

etc...] are also used daily and add a 

complexity at the tactical level that 

cannot be experienced elsewhere. 

Tactical Comptrollers will quickly need 

to master the intricacies of the “fiscal 

triad” (Resource Managers, Finance 

Officers and Contracting Officers) to be 

effective in this maze of authorities and 

funding streams. The magnitude and 

complexity of this resourcing equation 

at the tactical level is unprecedented and 

is partially a byproduct of full spectrum 

capability shortfalls replete across OIF. 

To mitigate this, up-front and indepth 

training and study before deploying to 

Operation Iraqi Freedom is imperative.

Fundamentally, OIF Comptrollers 

should first understand how the historic 

distribution of the Federal budget resonates 

in their resourcing efforts on the ground 

in Iraq. This is the first step to appreciating 

why resourcing OIF is so challenging 

and getting past some of its frustrations. 

Comptrollers then can focus on learning the 

wealth of information that they will need to 

know to source the fight here in Iraq and 

then master the systems that allow them to 

manage that information. Much of this new 

information is about the systems, programs 

and resources in place to compensate for 

the full spectrum capability voids that 

characterize everyday OIF operations. 

Fundamentally, the process of funding 

military operations remain relatively 

constant no matter where you go - formulate 

the warfighter’s requirements, prioritize 

and defend them, fund and execute them 

and in a contingency environment, do all 

this simultaneously. This holds true in Iraq. 

The devil is still in the details and they are 

abundant in full spectrum warfare. Stick 

to the fundamentals; keep it simple; fully 

integrate the fiscal triad into everyday 

business processes and keep the fiscal 

law team within earshot, and it will not 

prove to be an insurmountable task but a 

rewarding one. If a deployed Comptroller 

is able to achieve an equilibrium of effort 

between knowledge and knowing how 

to operationalize that knowledge, he can 

overcome the complexity and magnitude of 

the challenges that await him here in Iraq 

and do what he was sent to do – resource 

the warfighter for full-spectrum warfare.

The list of challenges that a Comptroller 

should expect to face when deployed to 

Operation Iraqi Freedom is endless. It 

continues with new Commanders executing 

the fight differently, changing resourcing 

priorities, changing policies and leaders 

from the company up to the national level 

making decisions that ultimately impact 

the bottom line. What doesn’t change is 

the truism that policies are not worth the 

paper they are written on if we are not able 

to resource them and many of these policies 

require a more balanced distribution of 

the discretionary Federal budget to truly 

make their intended impact. Herein lies the 

challenge for every deployed Comptroller 

in OIF – how to source the Warfighter 

when virtually no variable in the resourcing 

equation is static, predictability is impossible 

to achieve and the resource base upon which 

he relies was never organized nor resourced 

for full spectrum warfare. 

About the Author:

Colonel Thomas Horlander is the MultiNational Corps - Iraq CJ8 Comptroller and 

V Corps G8 Comptroller. He is currently 

serving in Iraq.

4 t h Q u a r t e r 2 0 0 6 
Developing Projects in

Lean Six Sigma

By Ms. Shannon Merwin

Okay I have a project, 

what’s next?

Projects are easy to identify in most areas. 

Our customers, our employees, and our peers 

often guide us to potential projects. One of 

the best ways to find projects is to create a 

prime value chain map that tracks beginning 

and end points of an area’s overall process. It 

also identifies critical inputs, outputs, value 

add and non-value add process steps. While 

this seems like a large under taking, it often 

gives a larger view of the processes at hand 

and how they relate to accomplishing the 

overall strategic goals. Selecting the right 

project can have a tremendous impact on 

your process and should tie directly into the 

overall strategy of the area. 

What Method Best Fits 

a Project?

There are various tools that can be used 

to accomplish Lean Six Sigma (LSS) 

initiatives. As you can see from Figure 1, 

projects can be broken out into ‘Quick 

Win,’ Rapid Improvement Events (RIE), 

Lean, and Six Sigma. There is also 

integrated Lean Six Sigma* which combines 

the removal of non-value added process 

steps from the Lean perspective with the 

drive to make the process more precise 

from the Six Sigma standpoint. 

Once a project has been identified, the 

project owner should ask, what type of LSS 

tool would yield the best results? Some 

projects may already have a clear path for 

a solution identified (Quick Wins), while 

others need to drive deeper for a solution 

(Six Sigma). Caution should be used if 

initiating a “Quick Win.” “Quick Win” 

projects are best utilized when a solution 

to the problem has been clearly identified, 

and there is a low risk associated with 

the change. Rapid Improvement Events 

(RIE), Lean and Six Sigma projects use a 

more in-depth technique to determine the 

best solution to a process. To utilize RIE, 

Lean, and Six Sigma tools to their fullest 

capability, larger projects should be scoped 

to create multiple smaller projects, and the 

projects should be prioritized by impact 

and relevance to the overall strategic goals. 

RIE, Lean, and Six Sigma projects should 

be completed in three to six months, and 

those that exceed six months should be reevaluated for better definition. 

Summary

Regardless of what tool is used in 

accomplishing a project, the deliverables 

of the project must be clearly defined and 

linked to the overall leadership’s mission. 

Projects should be driven using the topdown/ bottom-up theory with senior 

leadership supporting the projects while 

Black Belts and Green Belts guide projects 

to completion. Large projects, should be 

scaled down into multi-generational projects 

so they remain manageable and can be 

completed in a timely manner. Projects 

should also drive to the bottom line and 

improve upon time, quality and cost while 

looking at integrating knowledge about 

customer needs (voice of the customer), 

Army needs and market forces. For 

assistance in developing projects in your 

area, contact your Deployment Advisor or 

Deployment Director. 

*Note: Six Sigma will eliminate defects 

but it will not address the question of how 

to optimize process flow; and the Lean 

principles exclude the advanced statistical 

tools often required to achieve the process 

capabilities needed to be truly ‘lean’.

About the Author

Ms. Shannon Merwin is a Program Analyst 

contractor with Dynetics Inc. in the Office 

of the Assistant Secretary of the Army 

(Financial Management and Comptroller).

• Quick Strike

• Bypass formal

DMAIC process

• Quick Strike

• 1–6 days 

• Process Mapping

• Cause & Effect

• One piece flow

• Cells 

• Visual Controls

• Pull Systems

• Kanban

• Set up Production

• TPM

• DMAIC Process

• Statistical Tools 

• Value Stream

Mapping

• PFMEA

• Cp Cpk

• Gage R&R

• ANOVA, 

 Hypothesis Tests,

 DOE, Optimization

• Solution Clearly

Defined & 

Developed

• Quick 

Implementation 

• Low Risk

• Minimal or 

No Capital 

Expenditures

• Quick Strike

• 1–6 days 

• Process Mapping

vCause & Effect

• Waste, Non Value

 Add

• Speed, Cycle Time

• Standardization

• Inventory 

 Performance

• Variance 

 Reduction

• Complex Problems

• Variation 

 Reduction

• Defect Prevention

• Stability 

 Predictability

• Design Excellence

Tools Focus on Improvement

Quick Win Rapid Improvement

Event (RIE) Lean Six Sigma

Figure 1: Types of Lean Six Sigma Initiatives

R E S O U R C E M A N A G E M E N T

 4 t h Q u a r t e r 2 0 0 6
A new process created by the United States 

Northern Command should increase the 

likelihood of control and distribution of 

 Reimbursable Budget Authority (RBA).

Over the past year, many articles have been written, 

in both this publication and others, depicting the 

heroism from members of each military service and 

Coast Guard in the operations following Hurricane 

Katrina. Taken together, these operations undoubtedly will be recorded in history as one of the most 

extraordinary challenges facing Department of 

Defense (DoD) and Coast Guard forces operating 

within the United States.

What hasn’t been told is how reimbursing units 

for their part of this event is still continuing today. 

Financial managers in DoD continue their efforts to 

collect costs and process reimbursements through 

the Federal Emergency Management Agency (FEMA) 

almost a year after Hurricane Katrina brought devastation to the Gulf region.

The Next Hurricane Katrina: 

A New Process for 

Reimbursement

By Lieutenant Colonel Dennis Bay, Lieutenant Colonel Andy Smith, and Major Susan Temmer

4 t h Q u a r t e r 2 0 0 6
Financial personnel at the United States 

Northern Command (USNORTHCOM) 

have been involved heavily in helping 

DoD activities seek reimbursement for 

operations during Hurricane Katrina. Out 

of these efforts was born a Concept of 

Operations (CONOPS) designed to assist 

in obtaining, tracking and monitoring 

RBA, and ultimately reimbursement for 

such operations (which are known formally 

as Defense Support of Civil Authorities 

(DSCA). This article provides a brief 

description of the new DSCA financial 

management process.

Birth of the DSCA Financial 

Management Process

In the aftermath of Hurricane Katrina, 

USNORTHCOM financial personnel were 

involved heavily in supporting DoD units, 

helping them to link their performance 

to FEMA mission assignments and 

clear the path to reimbursement for 

associated outlays. We saw firsthand the 

need to develop a process that would 

alleviate many of the headaches that 

financial managers were experiencing 

while determining how much they 

would be reimbursed and how to get 

those funds restored to their activities. 

In addition to our firsthand experience, 

we scoured numerous audit reports, 

after-action reports, and lessons learned. 

With all this in mind, we set out to turn 

“lessons observed” into “lessons learned,” 

thereby ensuring that the DoD financial 

management community did not make the 

same mistakes in future DSCA events.

How did we accomplish this task? A 

small team of USNORTHCOM financial 

managers formed to “work” DSCA-related 

issues. First, we organized and hosted 

a DSCA financial workshop in March 

2006. Attendees included more than 50 

personnel from across the Department. The 

discussions and recommendations captured 

during the workshop were briefed to Ms. 

Teresa McKay, then-Deputy Chief Financial 

Officer, Office of the Under Secretary of 

Defense (Comptroller). She, in turn, tasked 

us to develop a new process for use during 

the upcoming hurricane season.

An iterative development process 

followed, resulting in a revised process 

documented in a CONOPS dated 1 Jun 

06. USNORTHCOM received direction 

to oversee and conduct a beta test of the 

process for the 2006 hurricane season.

Who Does What?

This DSCA financial management 

process seeks to suballocate and track the 

RBA provided by a Primary Federal Agency 

(PFA)—such as FEMA—to compensate 

DoD for its support. This process does not 

apply to direct budget authority. The PFA 

request can be made under the authority of 

either the Economy Act or the Stafford Act.

Two teams will manage this process: a 

Financial Management Oversight (FMO) 

Team and a Financial Management 

Augmentation Team (FMAT). The FMO 

Team (to be determined by the Office of 

the Secretary of Defense) will guide the 

FMAT and provide senior leader updates 

and reports. The FMAT will suballocate, 

track, and adjust RBA destined for DoD 

units tasked to provide mission support. 

The military services still must collect cost 

information, bill a PFA such as FEMA, 

and provide reports. For DSCA missions 

during 2006 and 2007, the USNORTHCOM 

Comptroller will act as the FMO and 

provide oversight to the FMAT.

In June 2006, all DoD services and major 

Defense agencies were tasked to identify 

representatives to serve as members of 

the FMAT. These members serve as the 

primary liaison between the FMO Team, 

the Defense Coordinating Officer/Element 

(DCO/E, Figure 1), and units performing 

missions under the orders of a PFA. The 

FMAT will ensure that participating DoD 

components have issued appropriate 

guidance for accounting code structures, 

reimbursable guidance, and other 

requirements. The FMAT also must ensure 

that all requirements for RBA are identified 

immediately, with follow-through provided 

until completion of the operational and 

fiscal mission.

The FMAT may colocate at 

USNORTHCOM headquarters during 

major crises but may operate from 

R E S O U R C E M A N A G E M E N T

10 4 t h Q u a r t e r 2 0 0 6
members’ home stations (in a virtual 

manner) during smaller contingencies. 

What constitutes major versus minor crises 

still needs to be worked out; however, it is 

a safe bet that FMAT members will deploy 

if there is a projected landfall of a Category 

3 or higher hurricane. During such an 

event, the FMAT has a high probability 

of standing up at USNORTHCOM 

headquarters or other locations as 

designated by USNORTHCOM.

Four Subprocesses

There are four subprocesses in this 

newly developed and still untested DSCA 

financial management process:

• Activate Financial Management 

Augmentation Team or FMAT

• Distribute RBA

• Monitor RBA

• Conduct fiscal closure

Figure 1 provides an operational view of 

the DSCA financial management process.

Subprocess 1—Activate Financial 

Management Augmentation Team

To determine if the FMAT should be 

activated, three elements should exist: a 

request or an order from a PFA, (Figure 

1), such as FEMA; an execution order or 

deployment order from USNORTHCOM; 

and approval for reimbursement. (There 

are occasions where reimbursement is 

waived, in which case there would be no 

need to activate the FMAT.)

Once the three elements are in 

place, Subprocess 1.0 may begin. At this 

time, the size, location, and estimated 

duration of the FMAT will be decided 

based on the event and its anticipated 

magnitude. This decision will be made 

after collaboration between the FMO, 

the Defense coordinating officer, and the 

U.S. Army North’s Deputy Chief of Staff 

for Resource Management (ARNORTH 

G8—USNORTHCOM’s Army component). 

To provide a scalable financial management 

response to the event, there are several 

criteria that must to be considered. These 

criteria will define the makeup of the 

FMAT and may result in different FMAT 

structures, depending on the nature of 

the event and the financial management 

support required.

Funding language in the 

USNORTHCOM execution order directs 

the financial management point of contact 

for tasked units to contact the FMAT 

for RBA, (Figure 1). The FMAT will 

issue reimbursable authority based on a 

validated/approved request. Once approved, 

the unit will load the reimbursable 

authority into its service’s financial 

management system. The goal is to ensure 

that RBA, is suballocated according to tasks 

assigned in a deployment order.

Note that each DoD component 

determines the definition of a “unit” for 

FMAT purposes. This definition will be 

known in advance to assist the FMAT in 

the suballocation process. The unit contact 

should be the person or organization that 

has fiscal responsibility for the unit.

Subprocess 2.0—Distribute Reimbursable 

Budget Authority

Once tasked, the unit will contact the 

FMAT in accordance with the funding 

guidance in the USNORTHCOM execution 

order. The unit will report various data 

including requesting unit information 

(name, address, phone and fax numbers, 

e-mail address); contact information for 

the financial management point of contact; 

date/time/group of the deployment order; 

and the cost estimate for tasking. The 

unit also will report the PFA’s mission 

assignment or number as identified in the 

deployment order as the funding authority 

for the tasking. The FMAT receives the 

request and documents the information.

When a tasked unit submits a 

request for RBA, the FMAT will assess 

the request. If the request is valid and 

sufficient funding remains available on 

the PFA’s mission assignment or order, 

the FMAT will approve the request and 

issue reimbursable authority on a DSCA 

Reimbursable Authority Document (DRAD, Figure 1). Use of this document 

precludes the confusion that was identified 

as a major problem last year when, for 

example, five units were assigned to a 

Figure 1. Operational View of the DSCA Financial Management Process

EVENT

PFA

Orders

PFA

JCS/

N-NC

FMAT

UNIT

WARN

ORD

EXORD

DEPORD

Activate

FMAT

1.0

END

NO

YES

DSCA FM Process

Ops Mission

Complete ? 

Monitor

RBA

3.0

Distribute

RBA

2.0 Conduct

Fiscal

Closure

4.0

DEPORD

D-RAD

Legend:

JCS-Joint Chiefs of Staff 

WARNORD-Warming Order 

EXORD-Execution Order 

DEPORD-Deployment Order

N-NC North American Aerospace Defense Command

4 t h Q u a r t e r 2 0 0 6 11
mission assignment code containing $1 

million in funding, and all five units 

assumed they each had $1 million to 

spend. This new document should make 

clear who is using the mission assignment 

code and how much is allocated to each 

performing unit.

After the unit receives the D-RAD 

tasking document, it will load the RBA 

into the respective service’s financial 

management system using its standard 

procedures for funds control and eventspecific financial coding. For example, in 

the Air Force, RBA requires that a sales 

code and a job order number be loaded 

to identify the authority as associated 

with a particular PFA. DoD components 

should provide procedural guidance prior 

to the event.

Subprocess 3.0—Monitor Reimbursable 

Budget Authority

Once the RBA has been issued to 

the unit and loaded into the appropriate 

financial system, the new DSCA financial 

management process moves into the 

monitoring phase. Under Subprocess 

3.0, units monitor the RBA until all 

reimbursements are received and 

reported. The unit continually reviews 

actual expenses in light of remaining or 

anticipated expenses for each assigned 

task and compares them to the amount 

issued on the D-RAD tasking document 

that contained the authority. When 

appropriate, the unit either requests an 

adjustment to the reimbursable authority 

or provides a weekly update of its status. 

The FMAT assesses the reports or requests 

and determines whether to adjust the 

reimbursable authority or seek additional 

funds from the PFA. At the end of 

Subprocess 3.0, the operational mission 

should be complete.

Subprocess 4.0—Fiscal Closure

Subprocess 4.0 begins when the tasked 

unit determines that the PFA-directed 

mission has been completed (that is, all 

personnel and equipment have returned 

home). In Subprocess 4.0, units determine 

final estimates of expenses, properly 

complete the billing process, and close all 

orders from the PFA.

Tasked units provide their final 

reimbursable status to the FMAT. The 

FMAT uses the unit’s final estimate to 

determine if an adjustment to the RBA is 

needed.

Units will use the following inputs to 

complete the billing process: applicable 

guidance from their component, guidance 

from DoD or the Defense Finance and 

Accounting Service (DFAS), guidance from 

the PFA, and supporting documentation 

as required by billing instructions. After 

preparing bills, units will submit billing 

documents and supporting documents as 

prescribed. After DFAS processes the bill 

and the PFA accepts it, units will complete 

a closure certification form and provide 

this form to the FMAT.

The FMAT will use the closure 

certification forms from tasked units to 

verify that the PFA’s order can be closed and 

make necessary annotations in control log 

and related files. Ultimately, the FMAT will 

contact the Defense Coordinating Officer to 

coordinate closure of the PFA’s order.

Benefits of the New Process

The 2006 hurricane season provides the 

beta test for this new process. After the 

season—and associated adjustments based 

on lessons learned—we believe that the 

new process will have produced a muchimproved system for tracking DSCArelated RBA and associated transactions. 

Additionally, we expect that this new 

process and the up-front investment 

of resources (in the form of FMO and 

FMAT members) will eliminate the need 

to establish ad hoc organizations like FM 

Katrina. The new process also should 

reduce the use of direct dollars to finance 

reimbursable DSCA missions.

About the Author: 

Lieutenant Colonel Dennis Bay, Lieutenant 

Colonel Andy Smith, and Major Susan 

Temmer are Budget Analysts assigned to 

NORAD-USNORTHCOM/J8. 

R E S O U R C E M A N A G E M E N T

12 4 t h Q u a r t e r 2 0 0 6

Special Recognition

to the FMAT team for their hard 

work in developing the DSCA 

CONOPS; Mrs. Hirst, Mrs. 

Potvin, Mrs. Deb Weaver, Mrs, 

Christina Brims, Mr. Jon Hetzog, 

Mrs. Pam Sagert, Mrs. Lee Anne 

Tailaferro, Capt Laurie Lanpher
4 t h Q u a r t e r 2 0 0 6 13

FEDERAL EMPLOYEE or

CONTRACTOR EMPLOYEE?

by Mr. Matt Reres

Federal law provides a number of tests 

that distinguish between employees and 

contractors. As the proportion of contractors 

in the Federal workplace grows and the jobs 

done by Federal employees and contractors 

sometimes merge, it becomes critical to 

make the correct distinction. If you err, you 

may cause major problems for yourself and 

your organization.

Reasons for the Growth in 

the Number of Contractor 

Employees

“Doing more with less!” This is 

the proverbial mantra of each elected 

administration, especially in presidential 

election years. Achieving this stated goal 

often compels an administration to reduce 

the number of government employees by 

whatever means is most readily available: 

hiring freezes, buyouts, competitive 

sourcing, and other techniques. Each 

approach has made its rounds, and each has 

enjoyed a measure of success.

Yet, at the same time, as the number of 

civil servants in the Department of Defense 

has declined, the duties performed by 

these government employees have usually 

expanded. Moreover, paralleling the decline 

in the numbers of civil servants has been the 

steady migration of military personnel to 

more traditional military duties. With fewer 

How the law distinguishes between the two . . . and why that distinction is important to you!
14 4 t h Q u a r t e r 2 0 0 6

R E S O U R C E M A N A G E M E N T

hands to perform the duties generated by 

each new law and policy, other personnel 

resources have arisen to fill the expanding 

void caused by the disappearance of civil 

servants and the reassignment of military 

personnel. The source is primarily from the 

private sector, that is, contractor employees 

in the Federal workplace.

The number of contractor employees 

working in the Federal workplace has 

grown exponentially over the last decade. 

This phenomenon has provided exploding 

employment opportunities for both younger 

workers as well as retirees from civil service 

and military workforces. No one is surprised 

today that during one pay period, civil 

servants or military personnel are serving 

in mufti or in uniform and, in the next pay 

period, are contractor employees who often 

return to their former positions and perform 

identical duties in the same manner as they 

did before they “retired.”

Federal Employee or Contractor: 

A Key Distinction

Although nothing may seem to have 

changed during such transitions, in fact, a 

tectonic shift has occurred. The fundamental 

difference is that the allegiance of the 

employee has swung from the United States 

of America to that of a business interest.

All military personnel and civil servants 

swear an Oath of Allegiance to the United 

States before they undertake the duties 

of their positions. On the other hand, 

employees who work for a business firm give 

their allegiance to that business—and the 

primary purpose of a business is to produce 

a profit. While it is entirely appropriate for 

a business to seek a profit, that goal is far 

removed from the purposes of government.

Central to the difference between public 

and private sectors is the approach that 

Federal workers must employ with respect 

to their official duties. This is contrasted 

with employees from the private sector, 

whose motivations is vastly different. 

Before government employees may act, 

they first must identify the legal authority 

for their actions, and they must do this 

before they take action. It is their oath 

to the United States that compels this 

requirement to identify the legal basis for 

what they do each and every time. On the 

other hand, the employee of a contractor 

has no such duty; rather, a contractor 

employee must ascertain only that whatever 

is undertaken violates no legal prohibition 

or restriction.

The distance between these two 

approaches can be measured only in light 

years. To suppose that there is no real 

difference, that the distinction between a 

Federal employee and a contractor employee 

is only marginal, is to suggest that infusing 

Type B negative blood into a person 

with Type A positive blood will have no 

deleterious consequences, when, in fact, it 

is fatal.

Although some contractor employees 

in the Federal workplace present no 

issues to the Federal government, others 

who work in the Federal workplace are 

cause for concern. While there may be 

no issue with those contractors who 

perform custodial, clerical, maintenance, 

food service, and construction duties, 

there are major issues with any contractor 

employees who are placed in positions 

of responsibility where they may give 

direction or assign tasks to Federal 

employees. There is also an issue for the 

Federal government and its supervisors 

in directing, controlling, and supervising 

contractor employees in the Federal 

workplace.

The reason for a lack of concern with 

respect to the former type of contractor 

employees is that their performance of 

contractual duties is of a nonpersonal 

services nature. Cause for concern with 

respect to the latter type of contractor 

employees is that their performance of 

contractual duties may involve personal 

services, thus giving rise to personnel, fiscal, 

and ethics issues that are discussed in greater 

detail later in this article.

How to Distinguish

The status of a nonFederal worker 

sitting next to you should never be 

determined by his or her title alone. 

Administrative boards and Federal 

courts usually ignore labels, focusing 

instead on the facts and circumstances of 

each situation. These boards and courts 

analyze specific characteristics—such as 

behavioral and financial control and the 

relationship between the employer and 

the individual performing the services—

before making a determination whether 

the individual is classified as an employee 

or as an independent contractor under 

common law rules.

Because of the tax implications inherent 

in the distinction between an employee and 

an employee of an independent contractor, 

the Internal Revenue Service (IRS) issues 

many of the regulations that govern the 

decision—employee or independent 

contractor. In the past, the IRS has employed 

a list of 20 factors. (For a more complete 

treatment of this and other topics, please 

refer to the article on the ASMC Web 

site—www.asmconline.org/Armed Forces 

Comptroller/current issue highlights.) 

Recently, however, the IRS has increasingly 

employed three key factors in determining 

whether an individual is an employee or an 

independent contractor.

Behavioral Control

Does the government have the right 

to direct or control how the worker does 

the work? A worker is likely to be deemed 

a Federal employee when the Federal 

government has the right to direct and 

control the worker. If, for example, an 

individual receives extensive instructions 

from the Federal government on how 

work is to be done, this suggests that the 

individual may be acting as a Federal 

employee. Also, if the Federal government 

provides the individual with training 

about required procedures and methods, 

this suggests that the Federal government 

wants the work done in a certain way and, 

consequently, the individual may be deemed 

an employee.

Financial Control

Is there a right to direct or control the 

resourcing aspect of the work? For example, 

if the individual has made a significant 

investment in tools or other aspects of 

the work, then an independent contractor 
4 t h Q u a r t e r 2 0 0 6 15

status may exist. While there is no precise 

dollar test, the amount of dollars invested 

must have some significance, although a 

significant investment alone is unnecessary 

to establish an independent contractor 

status. Also, if the Federal government 

refuses to reimburse a worker for some or 

all of his or her business expenses, then the 

worker may be an independent contractor, 

especially if the unreimbursed business 

expenses are significant. Finally, if the 

individual worker realizes a profit or incurs 

a loss, this suggests that he or she may be 

in business for himself or herself and, thus, 

may be an independent contractor.

Relationship of the Parties

How do the Federal government and 

the individual worker perceive their 

relationship? For example, if individual 

workers receive benefits, this is an indication 

that they are employees. If, however, 

they receive no benefits, they could be 

considered either as Federal employees or 

as employees of an independent contractor. 

A written contract may also indicate what 

the individual and the Federal government 

intend. The existence of a contract may 

be critical, particularly if it is difficult, or 

impossible, to determine status based on 

other facts.

For a Federal supervisor attempting to 

distinguish between a Federal employee 

and an independent contractor, the 

list of four questions contained in the 

accompanying sidebar provides a guide. 

If the answer to any of the four questions 

is Yes, then the individual providing the 

service in question most likely could be 

classified as an employee of the Federal 

government. If the answers to all four 

questions are No, then an independent 

contractor relationship may be established.

Why the Distinction Matters

There are many reasons why it is 

important to determine whether an 

individual is acting as an employee of an 

independent contractor or as a Federal 

employee. Included are Antideficiency 

Act (ADA) implications, benefits and tax 

consequences, and the nature of restrictions 

on individual behavior in the workplace.

ADA Implications

One of the ADA statutes prohibits 

acceptance of personal services except when 

specifically authorized by law. For that 

reason, acceptance of unauthorized personal 

services from a contractor employee could 

result in an ADA violation, if determined 

under a formal investigation.

Benefits and Tax Consequences

Proper classification is important 

because, if the veil of independent 

contractor status is pierced and an 

administrative or judicial determination 

is made that the contractor employees 

in fact are Federal employees, such 

a determination may allow for these 

individuals to recover some of the plethora 

of benefits available to Federal employees 

that had been denied them during the 

entire period during which they were 

misclassified. Considering the burgeoning 

number of contractor employees in the 

workplace, the costs to agencies that 

misclassify contractor employees could be 

massive.

Also, as soon as an employer-employee 

relationship is established—and unless 

otherwise exempt under law—the Federal 

government is required to withhold certain 

deductions from its employees’ salaries 

and wages. If, however, the individual is 

classified as an employee of an independent 

contractor, the Federal government has no 

Questions that determine whether an individual is a 

Federal employee or a contractor employee:

Does this individual provide essentially the same service as an employee 

of the Federal government?

Has an individual previously been paid as a Federal government employee 

to perform essentially the same tasks?

Does the Federal government exercise control in establishing how the 

individual will perform or accomplish the service?

Will the individual supervise or direct Federal government employees as 

part of the service provided?
16 4 t h Q u a r t e r 2 0 0 6

R E S O U R C E M A N A G E M E N T

responsibility for withholding income and 

employment taxes; that duty falls to the 

independent contractor. Even so, the Federal 

government is responsible for reporting to 

the IRS on compensation over $600 paid to 

individuals who are classified as employees 

of independent contractors on Form 1099-

MISC, Miscellaneous Income.

In theory, the IRS may assess penalties 

for misclassification of an individual 

providing service to the Federal government. 

However, liability for Federal employment 

taxes may be relieved under some 

circumstances. (See the complete article on 

the ASMC Web site for more details.)

Restrictions on Conduct

The law imposes a series of restrictions 

on the workplace conduct of both Federal 

employees and independent contractors. 

Misclassification—classifying an individual 

as a contractor employee rather than a 

Federal employee—may cause an individual 

to violate some of these restrictions. These 

restrictions are discussed in more detail in 

the complete article on the ASMC Web site, 

to include the legal citations. A brief list of 

these restrictions includes the following:

• Acceptance of gifts: Federal employees 

face strict limits on gifts they may receive.

• Post-government employment 

restrictions: Federal employees have limits 

on work they may accept after leaving 

Federal service.

• Inherently governmental functions: 

Certain functions may be performed only by 

Federal employees.

• Civil service laws apply to Federal 

employees but never to contractor 

employees.

• Awards: Monetary and nonmonetary 

awards may be given to Federal employees, 

within established limits, but there is 

no provision to give awards directly to 

contractor employees.

• Conflicts of interest: Many rules apply 

to Federal employees.

What You Should Do

If you supervise contractor personnel, 

this article may have raised questions 

about the status of the individuals who 

work for you. If you wish, you can seek 

guidance from the IRS. If an individual 

believes that the Federal government has 

made an inappropriate determination, he 

or she may submit to the IRS a Form SS-8, 

Determination of Employee Work Status 

for Purposes of Federal Employment Taxes 

and Income Tax Withholding. During the 

pendency of the IRS’s determination (which, 

the IRS notes in Form SS-8 instructions, 

may require approximately four months), 

the individual provider should be paid as 

an employee. If the IRS determines the 

correct classification to be an independent 

contractor, then the taxes withheld will be 

remitted to the individual.

While you can seek IRS guidance, you 

first should speak to your local legal counsel 

regarding the status of those who work for 

you. Together, you and your counsel may 

be able to arrive at a proper classification. 

You also may want to change some of your 

personnel policies in order to arrive at the 

desired classification.

Whatever you do, the author hopes that 

this article has convinced you of one thing. 

The difference between a Federal employee 

and a contractor employee constitutes a 

distinction that makes a difference!

Remember: The essence of clear thinking 

is making the right distinctions.

About the Author:

Mr. Matt Reres is the Deputy General 

Counsel (Ethics & Fiscal) in the Army’s 

Office of the General Counsel.
4 t h Q u a r t e r 2 0 0 6 17

This final section highlights specific citations and authorities regarding contract employees in Federal workplaces. Part one of 

the article appeared in the 3rd Quarter 2006 publication of Resource Management and can be found at http://www.asafm.army.

mil/proponency/rm-mag/rm.asp.

Contractor Employees

by Mr. Matt Reres

Inappropriate Conduct by Government Employees—Contractors in the Federal Workplace

Gifts/Bribery/Illegal Gratuities

Contractor gives gift with fair market value over 5 Code of Federal Regulations (CFR) 2635.202(a)(1) General 

$20 to Government employee. prohibition on gifts from a prohibited source

Government employee solicits from a 5 CFR 2635.202(a)(1) Prohibition on soliciting

contractor employee

Government employee reveals bid or proposal 41 USC 423 (Procurement Integrity Act) 

information, or source selection information to 

contractor employee.

Government employee reveals information to Freedom of Information Act. Exemption 4 (5 USC 552(b)(4))

contractor employee that should be withheld from 

the public under the Freedom of Information Act

Government employee reveals personal 5 USC 552a. Privacy Act. 

information to contractor employee in violation 

of Privacy Act

Government employee gives contractor employee 5 CFR 2635.703(a) Use of Nonpublic Information. Prohibits improper

nonpublic information, which contractor employee use of nonpublic information 

uses for private purposes

Government employee reveals inside information to 5 CFR 2635.101(b)(8) No preferential treatment. 

 a contractor employee

in the Federal Workplace Part 2
18 4 t h Q u a r t e r 2 0 0 6

R E S O U R C E M A N A G E M E N T

Former government employee communicates with Representational prohibitions on Former Government Personnel.

government employee on a matter in which he or she 

was personally and substantially involved 18 USC 207

5 CFR 2637 Regulations concerning post employment conflict of interest. 

Implements 18 USC 207. 

18 USC 207(a)(i) Lifetime representational prohibition, implemented by 5 CFR 2637.201.

18 USC 207(a)(ii) Two-year representational prohibition, implemented by 5 CFR 2637.202 

and 203.

18 USC 207(c) One year representational prohibition on general officers and members of

the Senior Executive Service, implemented by 5 CFR 2637.204.

41 USC 423(c). Procurement Integrity Act. Mandatory reporting requirement of certain

employment contacts. Implemented by FAR 3.104-3(c) and 3.104-5. 

41 USC 423 (d) Procurement Integrity Act. One year ban on certain personnel accepting

compensation from a source awarded a contract. See also FAR 3.104-3(d).

18 USC 205 Prohibits Current Government Personnel from acting as an agent or 

attorney before federal agencies. Applies during periods of transition or

terminal leave. 

18 USC 203 Prohibits compensation for services before government agencies. Applies 

during periods of transition or terminal leave. 

5 CFR 2635.601-606 Disqualification required if seeking employment. 

Post Government Employment Prohibitions

Personal Services Contracts and Related Matters

FAR 37.104 Personal Services Contracts. Prohibits personal services contracts unless

specifically authorized by statute. Includes Pellerzi standards at FAR 37.104(d).

FAR 7.5. Inherently governmental functions. At FAR 7.503, prohibits the use of 

contractors to perform inherently governmental functions. 

FAR 37.114 Generally requires all contractor employees attending meetings, answering 

DOD telephones, etc. to identify themselves as such.

OMB Circular A-76 (Revised) Defines Inherently Governmental activities.

Office of Federal Procurement Policy (OFPP) Defines Inherently Governmental Functions. Rescinded by 

Policy Letter 92-1 OMB Circular A-76 (Revised), but is still cited at FAR 7.500 (inherently

governmental functions). 

FAR 37.104(d) (Pellerzi standards) The elements of the Pellerzi standards govern whether an employer-employee 

relationship exists. Incorporated at FAR 37.104(d). 
4 t h Q u a r t e r 2 0 0 6 19

Contractor Conduct and Government Employee Conduct in General

DFARS 203.70 DFARS 203.70 Contractor Standards of Conduct. Requires government 

contractors to conduct themselves with the highest degree of integrity 

and honesty.

31 USC 3729-3731 False Claims Act

5 USC 2101-9904 Government Employees. Civil Service Laws, which govern federal civil 

service employees, but do not apply to contract employees. Employee is 

defined at 5 USC 2105. These laws govern pay, leave, etc. 

FAR 3.101. FAR 3.101. General statement on Standards of Conduct. Requires 

government business be conducted in a manner above reproach, and, 

except as authorized by statute or regulation, with complete impartiality 

and with preferential treatment for none. States that the general rule is to 

avoid strictly any conflict of interest or even the appearance of a conflict of 

interest in Government-contractor relationships.

Awards 

5 USC 4501-4506 Civilian Employee Incentive Awards. Never Apply to Contractors. 

Implemented in the Army by AR 672-20. DoD 1400.25-M, Subchapter. 451, 

App 1 and 2, and AR 672-20 do permit a few awards for contractors. These 

should always be coordinated with the contracting officer. 

10 USC 1125 Military Awards. Never apply to contractor employees. Implemented in 

the Army by AR 600-8-22. 

5 USC 2101-9904 Government Employees. Civil Service Laws, which govern federal civil 

service employees, never apply to contract employees. Employee is 

defined at 5 USC 2105. These laws govern pay, leave, etc. 

DA Memo 600-70, 11 FEB 04 Prohibits coins purchased with appropriated funds from being awarded to 

contractor personnel. 

Conflicts of Interest/Appearances of a Conflict of Interest/Organizational Conflicts of Interest 

18 USC 208 Federal conflict of interest statute. 

5 CFR 2635.402 Federal conflict of interest regulation. Implements 18 USC 208. 

5 CFR 2635.101(b)(2) 2nd principle. Employees shall not hold financial interests that conflict

with their duties. See also Executive Order 12674.

5 CFR 2635.502 Personal and business relationships. Impartiality rule, also known as

appearances of a conflict of interest. Employees should not work on a 

particular matter if a reasonable person who is aware of the circumstances 

would question their ability to be impartial in the matter.

5 CFR 2635.101(b)(14) Employees shall endeavor to avoid actions creating the 

appearance that they are violating the law or ethical standards in 5 CFR

2635. See also Executive Order 12674, fourteenth principle. 

FAR 9.5 Organizational and Consultant Conflicts of Interest. Organizational 

conflicts of interest are defined at FAR 2.101.
20 4 t h Q u a r t e r 2 0 0 6

R E S O U R C E M A N A G E M E N T

Common Law Principles, Employee or Independent Contractor Relationship

E.g., Corban v Skelly Oil Co. (Court of Appeals Generally, the alleged employer’s right to control the employee’s

(CA) 5 Miss) 256 F2d 775, 9 OGR 663; conduct is the key element in the determination of whether there is an

Buchanan v United States (CA8 Minnesota) employment relationship. 

305 F2d 738; Kippen v Jewkes (CA10 Utah) 258 F2d 

869; Stewart v Midani (ND Georgia) 525 F Supp 843; The most important test in determining whether a person employed to do

Lewis v New Jersey, 170 Arizona 384, 825 P2d 5, 106 certain work is an independent contractor or a mere servant or employee

Arizona Adv Rep 22; Santiago v Phoenix Newspapers, is the control over the work reserved by the employer.

164 Arizona 505, 794 P2d 138, 64 Arizona Adv Rep 20;

Moore v Long Bell Lumber Co., 228 Arkansas 345, The employer’s power of control over the contractor may be determinative, 

307 SW2d 533; Parker Stave Co. v Hines, 209 or may simply be one of many relatively equal factors that a court must

Ark 438, 190 SW2d 620 examine to determine the nature of the employment relationship.

Broadly stated, a contractor who is under the control of the employer is a 

servant, while one who is not under such control is an independent contractor.

E.g., Osner v Boughner, 180 Michigan App 248, Under the ‘economic reality’ test, which examines the totality of the

446 NW2d 873, appeal granted, in part 435 circumstances surrounding the alleged employment, no single factor

Michigan 861, 457 NW2d 344, vacated, appeal conclusively establishes the existence or absence of an denied 

437 Michigan 955, 467 NW2d 592, employer-employee relationship.

reconsideration denied (Michigan) 

1991 Mich LEXIS 996.

E.g., Santiago v Phoenix Newspapers, 164 An employee is normally defined as a person in the service of another

Arizona 505, 794 P2d 138, 64 Arizona Adv under a contract of hire, which may be express, implied, oral, or written,

Rep 20; Weisman v Blue Shield of California and which gives the employer the right to control and direct the person

(4th Dist) 163 California App 3d 61, 209 in the material details of how the work is to be performed. (Contract of

California Reporter 169; Blankenship v Kootenai hire is not to be confused with independent contractor relationship.) 

County, 125 Idaho 101, 867 P2d 975; Trinity Lutheran 

Church, Inc. v Miller (Indiana App) 451 NE2d 1099; 

Richardson v APAC-Mississippi (Miss) 631 So 2d 143.

Note: Cases quoted arise in a commercial business context, as distinguished from cases which arise in a Federal civil service context. 

The author acknowledges the invaluable assistance of Mr. Arthur Kaff, Army Standards of Conduct Office, in compiling the above 

citations and authorities.

About the Author

Mr. Matt Reres is the Deputy General Counsel (Ethics & Fiscal) in the Army’s Office of the General Counsel.
4 t h Q u a r t e r 2 0 0 6 21

Abstract

The issue of early, rigorous evaluation of program costs 

is becoming more important as defense funding comes 

under greater scrutiny. Often at this point in the life 

cycle, a requirement or desired capability is known, 

but the manifestation of the solution is unknown or 

described only at a high level. Can capabilities alone 

be used to produce a cost estimate? If so, how can we 

link the proposed solution to existing systems if only a 

particular solution’s general capability set is known? 

This work submits that better strategic decisions 

within fiscal constraints could be made if Rough Order 

of Magnitude (ROM) estimates were available for 

proposed materiel or non-materiel solutions, based 

on that solution’s capability set. This project further 

proposes the use of a knowledge base to provide support 

for these estimates; it is known as the joint Capabilities 

Knowledge Base (CKB). By using the relevant entities 

extracted from CKB, a ROM cost estimate may be 

developed using a wide spectrum of techniques. 

According to Department of Defense (DoD) guidance 

dated June 19, 2006, the 2006 Quadrenniel Defense 

Review (QDR) report called upon senior departmental 

leaders to “better integrate the processes that define 

needed capabilities, identify solutions and allocate 

resources to acquire them in order to enable corporate 

decision-making that cuts across traditional stovepipes”. 

In response to this directive, DoD leaders are evaluating 

a new early lifecycle decision-making framework that 

includes a Concept Decision (CD) Review (supported by 

an Evaluation of Alternatives or EoA). The CD Process 

has been set forth as a way to combine requirements, 

capabilities portfolio evaluation, and resource allocation 

considerations in the pursuit of joint, efficient, and 

well-informed decision-making early in the acquisition 

life cycle. The Concept Decision will either replace or 

occur in conjunction with Milestone A to decide which 

of the prospective solutions provided by the EoA will 

best enhance overall United States defense capability 

while balancing priorities of cost, schedule, and risk 

management.

The issue of early and rigorous evaluation of program 

costs becomes more important as defense funding is 

scrutinized. Clearly, decision-makers need high-fidelity 

cost information at this key decision point, but more 

often than not, it is scant. Providing reliable, useful cost 

estimates early in the acquisition life cycle is challenging 

for several reasons. Often at this point in the life cycle, 

a requirement or desired capability is known, but the 

manifestation of the solution is unknown or described 

only at a high level. This is certainly a challenge, given 

that defense cost estimating is usually performed given a 

detailed system description. Given the changing face of 

the battlefield and warfare, proposed solutions are often 

unlike anything presently in existence.

As any cost estimator can confirm, there exists a 

spectrum of situations in which a cost estimate may 

be prepared. One theoretic extreme is creating a 

cost estimate in a situation where there is very little 

information about the item being estimated and no 

supporting data. The other extreme is when the entity 

being estimated is fully understood, and all data exists to 

estimate the cost exactly. In this case, the data are actual 

costs after the item has been developed, constructed, or 

bought. Figure 1 illustrates these extremes along with all 

points in between. 

Approaches to Pre-Milestone-A Cost Estimating

by Ms. Martha Roper

CAPABILITIES-BASED COSTING

Figure 1: The Cost Estimating Spectrum

Concept

Refinement

Technology

Development

System Development

& Demonstration

Production &

Deployment

Operations

& Support

System Development

& Demonstration

Production &

Deployment

Operations

& Support

Concept Refinement &

Technology Development

Analogy

Parametric Actuals

Engineering

 

 [Build-Up]

ROM Estimates Detailed Estimates

Methodology

A B C
22 4 t h Q u a r t e r 2 0 0 6

R E S O U R C E M A N A G E M E N T

As we progress from the point of 

no information to the point of perfect 

information, our cost estimating 

methodology changes to suit the 

information climate. For instance, when 

information about the item or service is 

higher-level and/or data is not readily 

available (Figure 1, left), cost estimators 

tend to rely upon analogies and parametric 

methods to produce their estimate. 

However, as we move toward the right, 

estimates tend to utilize more “datahungry” methodologies such as engineering 

builds and projections using actual costs to 

date. It is also clear to the casual observer 

that as we move along the spectrum from 

left to right, we may expect our estimate 

to be more reliable and closer to the actual 

cost at project or acquisition completion.

The pre-Milestone A costing 

environment is particularly challenging. 

This is the stage in which information is 

often extremely scarce. Figure 2 illustrates 

the “sub-spectrum” of pre-Milestone A 

data availability.

Depending upon the situation, there may 

be one or more proposed solutions to a set 

of capability gaps before Milestone A. The 

solution could be a materiel system such 

as a vehicle or software package, or a nonmateriel solution, such as a policy change or 

a training curriculum change. As one can 

see in Figure 2, the information regarding 

the proposed solution(s) could range from 

simply the desired capability expressed in 

very qualitative terms to a relatively detailed, 

well-developed concept with some technical 

platform specifications. The most commonlyoccurring scenario, however, is nearer to 

the middle where there exists high-level 

capabilities information along with some very 

general solution information.

Since every cost estimate of an item 

or project must be based on some type 

of past experience, pre-Milestone-A cost 

estimating is no exception. How can we 

link the proposed solution to existing 

systems (our past experience) if we 

know only a particular solution’s general 

capability set? Can capabilities alone be 

used to produce a cost estimate? If so, could 

that cost estimate be used in decisionmaking with any degree of confidence? 

Suppose we made the assumption that a 

system’s capabilities have a relationship to its 

cost. To the casual observer, this assumption 

seems rather logical. If we buy something 

that can do more, do it quicker, or do it 

better, then it should cost more. However, 

one can identify situations in which this 

assumption might not hold; if a particular 

computer technology is maturing at an 

accelerated rate, the cost to acquire that 

capability might not be correlated to the cost 

of acquiring a similar capability five years 

ago. Yet, even this example has a relationship 

between capability and cost upon closer 

inspection; to arrive at an acceptable cost 

estimate one must understand the rate of 

technology maturation (and this maturity 

information may or may not be available 

to the analyst). The question at hand, 

however, is whether or not capabilities can 

predict cost within some acceptable level of 

percentage error to provide decision makers 

with data that help prevent decisions that 

would yield negative future cost effects. In 

theory, these decisions can be avoided if a 

rough order of magnitude (ROM) estimate 

is available based on the proposed materiel 

solution’s set of capabilities. 

The capabilities costing team at 

ODASA-CE is currently tackling the 

challenging pre-Milestone-A costing 

environment. Our approach includes 

the use of a knowledge base that records 

current system cost information and 

capabilities. In fact, the Joint Capabilities 

Knowledge Base (CKB) is presently under 

construction. By using the relevant entities 

extracted from the CKB, a ROM cost 

estimate may be developed using a wide 

spectrum of techniques. 

Numerous costing approaches are 

being examined and developed as this 

project evolves; one of which follows: 

Let us assume that the set of capabilities 

requiring a cost estimate is rankordered; in other words, we know which 

capabilities among the group are most 

critical, somewhat necessary, or only 

slightly needed. Depending on whether 

the entities (that will be extracted from 

the CKB) have exact or partial matches 

in capabilities, we can then apply an 

appropriate weighting factor for certain 

combinations of capability matches; exact 

matches would receive a higher weighting 

than partial matches, for example. Next, 

relevant entities are extracted from the 

knowledge base that can be used in our 

cost estimate. The assigned weightings 

are applied. If a particular system entity 

is deemed to be even more relevant to the 

solution being estimated, it may be further 

emphasized in a variety of ways. 

Larger-scale case studies using realistic 

scenarios are under development to test the 

usefulness and strength of the methodology 

frameworks being considered, which 

include simplistic techniques like that 

described above to more intricate 

parametric and data mining approaches. 

It is important, however, to emphasize 

that cost estimates at this point in the life 

cycle are highly situation-specific, and thus 

methodologies under development are 

only recommended strategies. The analyst’s 

judgment is a key component.

About the Author:

Martha Roper is an Operations Research 

Analyst (ORA) with the Office of the Deputy 

Assistant Secretary of the Army for Cost and 

Economics. Cost and Economics (ODASACE). 

Concept

Refinement

Technology

Development

System Development

& Demonstration

Production &

Deployment

Operations

& Support

System Development

& Demonstration

Production &

Deployment

Operations

& Support

Concept Refinement &

Technology Development

Analogy

Parametric Actuals

Engineering

 

 [Build-Up]

ROM Estimates Detailed Estimates

gy

A B C

Less Detail More Detail

Capabilities Only Capabilities & General

Solution Information

Relatively Detailed,

Technical Platform Specs

Figure 2: Spectrum of Information Availability at Milestone A
CP 11 Civilian Supervisors Ten 

Most Favorable Items

The three most favorable responses in 

Fiscal Year 2003: 

• My job makes good use of my abilities: 

87% favorable 

• I find my work challenging: 85% 

favorable

• I feel free to go to my supervisor with 

questions or problems about my work: 

83% favorable

The three most favorable responses in 

Fiscal Year 2005:

• I know how my work relates to 

the agency’s goals and priorities: 

94% favorable

• Managers/supervisors/team leaders 

work well with employees of different 

backgrounds: 88% favorable

• My performance standards/expectations 

directly related to my organization’s 

mission: 87% favorable

CP 11 Civilian Supervisors Most 

Unfavorable Items

The three most unfavorable responses in 

Fiscal Year 2003: 

• I am satisfied with the processes used to 

fill vacancies at this installation/activity: 

31% unfavorable

• My supervisor provides me with career 

counseling: 30% unfavorable

• I would recommend that others pursue 

a career as a civilian with the Army: 

28% unfavorable

The three most unfavorable responses in 

Fiscal Year 2005:

• I have the flexibility to use pay setting 

flexibilities: 66% unfavorable

The Army Civilian Attitude Survey is the Army’s official attitude and opinion survey 

of the civilian workforce. The survey is voluntary and all Army civilian employees, 

supervisors, and managers are invited to participate in the survey process. The survey 

measures job satisfaction, workforce morale and many other key workforce issues.

 

 The following synopsis provides key highlights of the Comptroller Civilian Career Program

 (CP11) responses for fiscal year 2005 and fiscal year 2003. The next Army Civilian Attitude

Survey will be conducted in Fiscal Year 2007. A comparative analysis can not be performed

 because different questions were used in Fiscal Year 2003 and Fiscal Year 2005. In lieu of a

comparative analysis. The most favorable and unfavorable responses are provided.

❑✓

Key Comptroller Civilian 

Career Program 

Results from the Army Civilian Attitude 

Survey for Fiscal Year 2005 and Fiscal Year 2003

by Ms.Wilett Bunton

4 t h Q u a r t e r 2 0 0 6 23
• I have the flexibility to use retention 

incentives: 62% unfavorable

• I have the flexibility to use student loan 

repayments: 87% unfavorable

Comparative Analyses of 

Composite Labels

The Fiscal Year 2003 survey results were 

organized into fifteen composite labels. 

The Fiscal Year 2005 survey results were 

only organized into nine composite labels. 

A comparison of the composite labels for 

both surveys indicates 5 similar items. The 

results are:

a. Satisfaction with Civilian Personnel: In 

Fiscal Year 2005 the favorable results 

decreased by 20%; unfavorable increased 

by 10% and neutral increased by 10%.

b. Performance Culture: In Fiscal Year 

2005 the favorable results decreased by 

6%; unfavorable increased by 2% and 

neutral increased by 2%.

c. Training and Development: In Fiscal 

Year 2005 the favorable results increased 

by 5%; unfavorable decreased by 3% and 

neutral decreased by 1%.

d. Amount of Authority (similar label, not 

exact): In Fiscal Year 2005 the favorable 

results decreased by 37%; unfavorable 

increased by 45% and neutral decreased 

by 8%.

e. Fairness: In Fiscal Year 2005 the 

favorable results decreased by 6%; 

unfavorable increased by 1% and neutral 

increased by 7%.

Significant Changes:

Performance Culture results 

were consistent with CP 11 Civilian 

Employee results.

CP 11 Civilian Employee Ten 

Most Favorable Items

The three most favorable responses in 

Fiscal Year 2003: 

• My supervisor is competent in 

handling the technical parts of his/her 

job: 77% favorable 

• I feel free to go to my supervisor with 

questions or problems about my work: 

75% favorable

• My job makes good use of my abilities: 72%

The three most favorable responses 

in Fiscal Year 2005:

• I know how my work relates to the 

agency’s goals and priorities: 85%

• Managers/supervisors/team leaders 

work well with employees of different 

backgrounds: 78%

• My performance appraisal is a fair 

reflection of my performance: 78% 

CP 11 Civilian Employee Ten 

Most Unfavorable Items

The three most unfavorable responses in 

Fiscal Year 2003: 

• When promotions are made at this 

installation/activity, the best-qualified 

people are selected: 41%

• I am satisfied with the processes used to 

fill vacancies at this installation/activity: 

40% unfavorable

• Employees at this installation/activity 

are treated fairly with regard to 

job placements and promotions: 

39%unfavorable

The three most unfavorable responses in 

Fiscal Year 2005:

• In my work unit, steps are taken to deal 

with a poor performer who cannot or 

will not improve: 50% unfavorable

• Personnel Services: Provides career 

counseling to employees: 49% unfavorable

• Overall, what type of impact do you 

think NSPS will have on personnel 

practices in the DoD: 44% unfavorable

Comparative Analyses of Composite 

Labels

The Fiscal Year 2003 survey results were 

organized into eighteen composite labels. 

The Fiscal Year 2005 survey results were 

only organized into seven composite labels. 

A comparison of the composite labels for 

both surveys indicates 5 similar items. The 

results are:

a. Satisfaction with Civilian Personnel: In 

FY05 the favorable results decreased by 

14%; unfavorable increased by 8% and 

neutral increased by 4%.

b. Performance Culture: In Fiscal Year 

2005 the favorable results decreased by 

6%; unfavorable increased by 2% and 

neutral increased by 4%. 

c. Training and Development: In Fiscal 

Year 2005 the favorable results increased 

by 2%; unfavorable decreased by 1% and 

neutral decreased by 1%.

d. Leadership and Management (similar 

label, not exact): In Fiscal Year 2005 

the favorable results increased by 10%; 

unfavorable decreased by 8% and 

neutral decreased by 3%.

e. Fairness: In Fiscal Year 2005 the 

favorable results decreased by 6%; 

unfavorable increased by 4% and neutral 

increased by 3%.

Significant Changes:

Performance Culture results 

were consistent with CP 11 Civilian 

Supervisor results.

About the Author

Ms. Wilett Bunton is the Managing 

Editor of Resource Management and a 

Program Manager in the Office of the 

Assistant Secretary of the Army (Financial 

Management and Comptroller). 

R E S O U R C E M A N A G E M E N T

24 4 t h Q u a r t e r 2 0 0 6
Back Row: Mira Kim, Noah Cloud, Sukcha Pyon, Tom Willson, ChinHo Yo, Connie Lee, Amajtro Peterson, John Roub, 

Clemente Cecere, Gregory Mister, Hector Del Toro, Jackson Hawse, Peter Hanzelka, Brent Nelson, Hillari Hawkins, Cory 

Whitman, Hye Kyong O, Erica Fowler

Second Row: Ruth Crompton, Ellen Wong, Marlan Macklin, Sunghui Yu, Toria Clark-Stewart, Renee Scott, Nichole Hyter, 

Lillie Mims, Jackie Reed, Tomeka Murphy, Audra George, Jason Cooksey, Jimmie Sherode, Donnell Campbell, Brian 

Kulm, Erica Ignont

Front Row: Laura McKenzie, Tinarenel Davis, Jennifer Fitzgerald, Christi Kopp, Hector Ramos, Robert Davis, Kristy 

Shitaoka, Yonga Yi

Army Comptroller Course

Class 06-111, August 14 – September 01, 2006
Comptroller Proponency Office

Office of the Assistant Secretary of the Army 

(Financial Management and Comptroller)

Resource Management

Professional development bulletin

ISSN 0893–1828

ATTN: SAFM–PO, 109 Army Pentagon, 

Washington, DC 20310–0109.