Accessible Version

FEDERAL REAL

PROPERTY

Additional Authorities 

and Accountability 

Would Enhance the 

Implementation of the 

Federal Buildings 

Personnel Training 

Act of 2010

Report to the Ranking Member, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

October 2015

GAO-16-39

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-39, a report to the 

Ranking Member, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

October 2015

FEDERAL REAL PROPERTY

Additional Authorities and Accountability Would 

Enhance the Implementation of the Federal Buildings 

Personnel Training Act of 2010

Why GAO Did This Study

The federal government’s 

management of its real property 

holdings costs billions of dollars and 

has been on GAO’s High Risk List 

since 2003. Some agencies lack the 

staff expertise needed to oversee 

building management activities. GAO 

was asked to report on the status of 

the implementation of the Act, which 

directed GSA to, among other things, 

consult with the training industry to 

identify core competencies for federal 

buildings personnel and required these 

personnel to demonstrate proficiency 

in these competencies. 

This report examines (1) the progress 

GSA has made in implementing the 

Act’s requirements, (2) the actions 

selected agencies have taken to 

respond to the Act, and (3) the factors 

that have affected implementation of 

the Act. To conduct this study, GAO 

reviewed the Act and agency 

documentation and studies. GAO also 

interviewed officials from GSA as well 

as DOD, DOE, DOI, DOJ, and VA. 

Together with GSA, the agencies GAO

interviewed occupy about 90 percent of 

federal real property gross square 

footage.

What GAO Recommends

GAO recommends that GSA develop a 

legislative proposal to establish agency 

authorities and reporting 

responsibilities—as well as an 

interagency group—to enhance 

accountability for implementation of the 

Act. GSA stated that it agreed with the 

report’s findings and would work with 

the appropriate agencies to address 

them. 

What GAO Found

The General Services Administration (GSA) has largely met its lead-agency 

responsibilities for implementing the Federal Buildings Personnel Training Act of 

2010 (the Act) government-wide. For example, it has identified core 

competencies and a recommended curriculum for federal buildings personnel. 

While not required by the Act, GSA has also drafted a charter for an interagency 

advisory board to help coordinate government-wide implementation and has 

developed software tools to assist agencies with compliance efforts. GSA is in 

the process of implementing the requirements for its own employees. GSA has 

identified affected personnel, directed them to inventory their qualifications, and 

assessed their skills. GSA must still align job descriptions and performance 

reviews with the Act’s requirements and implement contractor compliance efforts. 

Of the five selected agencies GAO reviewed, the Departments of Defense (DOD) 

and Energy (DOE) have taken some actions to respond to the Act, while the 

Departments of Justice (DOJ), Interior (DOI), and Veterans Affairs (VA) have not 

yet determined how to respond. For example, DOD is conducting a pilot program 

through its Defense Health Agency to align five positions with the core 

competency model GSA developed, while DOI’s National Park Service has only 

discussed potential responses to the Act. As a result, little is known about the 

numbers of federal and contractor employees at these agencies covered by the 

Act or the status of their compliance with the Act. 

The pace of implementation of the Act has been limited by at least four factors 

that make compliance essentially voluntary. First, the Act does not provide any 

agency with the authority to enforce compliance government-wide. According to 

GSA, it is not authorized to issue official government-wide guidance on 

implementation, and it has come to see its role as advisory. In addition, the Act 

does not provide an implementation role for the Office of Personnel 

Management, the agency generally responsible for government-wide personnel 

related issues. Second, agencies are not required to report the status of their 

employees’ compliance with the Act, a circumstance that leaves agencies with 

little incentive to determine how many employees are affected or complying. 

Third, the Act did not provide funding for additional training, and according to 

agency officials, many other priorities compete for limited training resources. 

Fourth, no interagency group has been established that ensures consistent 

implementation of the Act government-wide. This gap has resulted in a lack of 

coordinated implementation policy and guidance. While GSA has taken steps to 

create such a group, this process is still in the development stage. Federal 

internal control standards emphasize that establishing good human capital 

policies and practices, including ensuring that personnel are properly trained, is 

critical for achieving results and improving organizational accountability. These 

standards also call for assessing the quality of performance over time. Such an 

assessment would include monitoring training practices. Further, prior GAO work 

has found that agencies can benefit from considering government-wide reforms 

when planning training programs and that the coordinated efforts of several 

agencies through interagency groups can help develop policy, guide program 

implementation, and conduct oversight and monitoring.

View GAO-16-39. For more information, 

contact David Wise at (202) 512-2834 or 

wised@gao.gov.
Letter 1

Page i GAO-16-39 Federal Real Property 

GSA Has Largely Met Its Lead-Agency Responsibilities and Has 

Begun Implementing the Act for Its Own Employees 3

Selected Agencies Have Taken Some Action, but Overall 

Response to the Act Has Been Limited 10

Various Factors Have Contributed to Limited Implementation of 

the Act 13

Conclusions 15

Recommendation for Executive Action 16

Agency Comments 16

Appendix I: Objectives, Scope, and Methodology 18

Appendix II: Comments from the U.S. General Services Administration 21

Appendix III: GAO Contact and Staff Acknowledgments 22

GAO Contact 22

Staff Acknowledgments 22

Appendix IV: Accessible Data 23

Accessible Text and Data Tables 23

Agency Comments 24

Table

Table 1: Agency and Other Interviewees 19

Figure

Figure 1: The General Services Administration’s (GSA) Federal 

Buildings Personnel Training Act of 2010 Competency 

Model 6

Accessible Text for Figure 1: The General Services 

Administration’s (GSA) Federal Buildings Personnel 

Training Act of 2010 Competency Model 23

Accessible Text for Appendix II: Comments from the General 

Services Administration 24

Contents
Page ii GAO-16-39 Federal Real Property 

Abbreviations 

the Act Federal Buildings Personnel Training Act of 2010

BOP Bureau of Prisons 

DHA Defense Health Agency 

DOD Department of Defense 

DOE Department of Energy 

DOI Department of the Interior

DOJ Department of Justice

GSA General Services Administration

NPS National Park Service 

OPM Office of Personnel Management 

PBS Public Buildings Service 

VA Department of Veterans Affairs 

VHA Veterans Health Administration

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-39 Federal Real Property 

441 G St. N.W.

Washington, DC 20548

October 20, 2015

The Honorable Thomas R. Carper

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Senator Carper:

The federal government’s management of its real property holdings—

comprising hundreds of thousands of buildings and permanent structures 

across the country, and costing billions of dollars annually to operate and 

maintain—has been on the Government Accountability Office’s (GAO) 

High Risk List since 2003.1 The federal government has made advances 

in real property management but continues to face long-standing 

challenges. We have previously reported that some agencies lack the 

staff expertise needed to oversee building management activities. For 

example, some agencies lack dedicated, skilled energy managers as well 

as trained staff capable of overseeing and managing energy savings 

performance contracts.2 Ensuring that energy management staffs are well 

trained is one of three effective energy management practices we 

identified.3

The Federal Buildings Personnel Training Act of 2010 (the Act)4 was 

enacted in December 2010. Congressional committee reports 

accompanying the Act state that it was enacted to help ensure that 

federal buildings are operated to maximize their performance and retain 

their values while protecting and leveraging taxpayer investment through 

 

1GAO, High Risk Series: An Update, GAO-15-290 (Washington, D.C.: February 2015).

2An energy savings performance contract is a type of share-in-savings contract under 

which agencies use private funds to finance energy conservation measures. For more see 

GAO, Energy Savings Performance Contracts: Additional Actions Needed to Improve 

Federal Oversight, GAO-15-432 (Washington, D.C.: June 2015). 

3GAO, Federal Energy Management: Agencies Are Taking Steps to Meet HighPerformance Federal Building Requirements, but Face Challenges, GAO-10-22

(Washington, D.C.: October 2009).

4Pub. L. No. 111-308, 124 Stat. 3283 (Dec. 14, 2010).

Letter
efficient building operations and management,

Page 2 GAO-16-39 Federal Real Property 

5 as well as to help support 

energy efficiency goals for federal buildings.6 The Act directed the 

General Services Administration (GSA), in consultation with 

representatives of professional societies, industry associations, and 

apprenticeship training providers, to take the following actions 

government-wide:

1. Identify the core competencies necessary for federal personnel to 

perform building operations and maintenance, energy management, 

and safety and design functions not later than 18 months after 

enactment of the Act, and update them annually thereafter;

2. Identify a course, certification, degree, license, or registration that can 

be used to demonstrate proficiency in each core competency. Also 

identify ongoing training with respect to each core competency; and

3. Develop or identify comprehensive continuing education courses to 

ensure the operation of federal buildings is in accordance with 

industry best practices and standards.

In addition, the Act requires GSA, along with the Department of Energy 

(DOE), in consultation with the heads of other appropriate federal 

departments and agencies and representatives of professional societies, 

industry associations, and apprenticeship training providers, to develop a 

recommended curriculum relating to facility management and the 

operation of high-performance buildings not later than 18 months after the 

date of the Act, and update the curriculum annually thereafter.7

The requirements outlined in the Act apply to federal and contractor 

employees. Individuals are to demonstrate proficiency in each core 

competency related to their position not later than 1 year after each is 

identified. If hired after the date of such identification, the employee has 1 

year to demonstrate proficiency. You asked us to report on the status of 

implementation of the Act. We reviewed (1) progress GSA has made in 

 

5S. Rep. No. 111-212, at 2 (2010).

6H.R. Rep. No. 111-662, at 2 (2010). 

7According to Section 401(12) of the Energy Independence and Security Act of 2007, a 

high-performance building is a building that integrates and optimizes on a life-cycle basis 

all major high-performance attributes, including energy conservation, environment, safety, 

security, durability, accessibility, cost-benefit, productivity, sustainability, functionality, and 

operational considerations.
implementing the requirements of the Act, (2) actions selected federal 

agencies have taken in response to the Act, and (3) factors that have 

affected implementation of the Act.

To determine the progress GSA and other federal agencies have made in 

responding to the provisions of the Act since its passage in 2010 as well 

as the factors affecting that progress, we reviewed the Act, congressional 

committee and Congressional Budget Office reports, and agency 

documentation and reports. We also interviewed officials from GSA and 

five selected federal agencies—the Departments of Defense (DOD), 

Energy (DOE), the Interior (DOI), Justice (DOJ), and Veterans Affairs 

(VA)—and representatives of industry groups. We selected the five 

agencies on the basis of the gross square footage of federal real property 

they occupy, according to 2014 Federal Real Property Profile data, and 

because they were included in initial meetings about the Act that GSA 

held in 2011. Together with GSA, the agencies we interviewed occupy 

about 90 percent of federal real property gross square footage. We did 

not evaluate the effectiveness of the core competencies GSA established 

or assess the effectiveness or results of selected agencies’ use of the 

core competencies. We also discussed with the Office of Personnel 

Management (OPM) OPM’s role in implementing the Act governmentwide. We conducted this performance audit from February 2015 to 

October 2015 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.

Page 3 GAO-16-39 Federal Real Property 

GSA Has Largely Met 

Its Lead-Agency 

Responsibilities and 

Has Begun 

Implementing the Act 

for Its Own 

Employees
GSA has identified the core competencies—knowledge, skills, and 

abilities—and related training to meet the government-wide requirements 

of the Act for federal and contract employees and has begun 

implementing the requirements for its own personnel but has not yet 

finalized compliance methods for contractors. In 2011, GSA began 

working to create an approach for federal buildings personnel to use to 

satisfy the Act’s requirements by demonstrating proficiency in the core 

competencies. To develop the core competencies, GSA contacted more 

than 20 federal agencies and subagencies that hold and operate 

buildings and coordinated meetings with officials as well as with 

representatives from professional societies, industry associations, nonprofit organizations, and private training groups. GSA held follow-on 

consultations with agencies it identified as holding large amounts of 

federal real property, since those agencies cover the vast amount of 

federal real property holdings.

In June 2012, GSA published a set of core competencies for federal 

buildings personnel, began creating software tools for demonstrating and 

documenting proficiency in the core competencies, and announced a list 

of GSA-recommended training courses linked to the core competencies 

and covering the topics of facility management and the operation of highperformance buildings.

Page 4 GAO-16-39 Federal Real Property 

8 Although 7 core-competency areas are called for 

in the Act, in developing them, GSA expanded them to 12. In addition to 

the 7 categories of building operations, building maintenance, energy 

management, sustainability, water efficiency, safety, and building 

performance measures, GSA identified 5 more: technology; design; 

project management; business, budget and contracting; and leadership 

and innovation as core competency areas. Under these 12 areas, GSA 

identified 43 core competencies and 232 specific demonstrations of each 

core competency that GSA called “performances.” Employees 

demonstrate proficiency in the core competencies relevant to their 

positions by completing performances that show they have gained skills 

and knowledge through experience and training. GSA laid out all these 

elements in what it calls a competency model. Under GSA’s approach, 

the individual agency defines what actual compliance means for its own 

particular employees. GSA envisions employees working with their 

 

8The original course list contained 12 free government courses. GSA published the core 

competencies and related training on a website, www.fmi.gov, which GSA established in 

2012 as an implementation resource for agencies. This website is also used to provide 

Act-related guidance and clarification to agencies and to announce policy changes.

GSA Has Completed Most 

of Its Requirements for 

Government-wide 

Implementation and Is 

Drafting an Interagency 

Framework for 

Collaboration
supervisors to document the tasks and training. In addition, GSA 

developed—along with DOE officials and in consultation with 

representatives of other federal departments and agencies, industry, and 

academia—a recommended curriculum related specifically to the fields of 

facility management and the operation of high-performance buildings.

To help agencies prioritize training efforts, GSA has since streamlined 

this approach by designating as high-priority 9 competency areas, 21 

core competencies, and 88 performances that could potentially have the 

most impact on building operating efficiency and cost. GSA—working with 

an informal body of facility representatives from various landholding 

agencies—identified 3 career areas of responsibility most closely aligned 

with the core competencies: facility management, energy management, 

and facilities operations and maintenance. GSA did this to develop 

consistent guidance that could help agencies whose employees may 

have similar titles but perform different functions assign the appropriate 

performances to the appropriate personnel. See figure 1 for a visual 

representation of GSA’s competency model.

Page 5 GAO-16-39 Federal Real Property 
Figure 1: The General Services Administration’s (GSA) Federal Buildings Personnel Training Act of 2010 Competency Model

Page 6 GAO-16-39 Federal Real Property 
As required by the Act, GSA made annual updates to the core 

competencies and recommended curriculum in 2013 and 2014. In the 

2014 update, GSA created a new, more rigorous process requiring 

independent subject matter experts to review potential private and 

government training offerings and assess how well they aligned with the 

core competencies.

Page 7 GAO-16-39 Federal Real Property 

9 This effort resulted in an increase of courses in the 

recommended curriculum from 12 no-cost government courses to 135 

government and private courses. Currently, 107 of 135 courses—almost 

80 percent—are provided by private training organizations, and 28 are 

provided by or in collaboration with government agencies.

Also in the 2014 update, GSA announced recommended methods for 

buildings personnel who are federal employees to both demonstrate 

proficiency in the core competencies and take steps to improve 

professional development. To assist in this approach, GSA has launched 

two software tools, which were described and partially demonstrated for 

us by the GSA official responsible for leading GSA’s implementation 

efforts. The first is a basic assessment tool agencies can use to 

determine whether buildings personnel have demonstrated the core 

competencies related to their positions, and are therefore in compliance 

with the Act. Through an online exam format, the official said the tool 

allows workers to demonstrate knowledge by answering a series of 

questions about the 88 high-priority performances related to their 

positions. The tool was designed to take into account any existing 

certificates or advanced training the employee may have already earned. 

According to the official, the other tool is a professional development 

system that moves beyond basic compliance by allowing employees to 

plan and accomplish advanced training related to the core competencies 

through creating individual training plans linked to GSA-approved 

government and private training options.

According to the official responsible for leading GSA’s implementation 

efforts, to potentially help coordinate government-wide implementation, 

GSA has drafted a charter for an interagency advisory board composed 

of facilities operations and maintenance personnel and human capital 

executives at federal landholding agencies. The official said that to date 

no such group has championed the implementation of the Act’s 

 

9Under the Act, core competencies can be demonstrated through a course, certification, 

degree, license, or registration.
requirements across the federal government. While GSA shares internal 

guidance and procedures informally on its www.fmi.gov website and 

through presentations to industry associations, the Federal Facilities 

Council, and individual agencies, GSA could expand its advisory role 

through such a group and, according to the official, provide examples of 

best practices and guidelines for implementation, and seek consensus on 

them. However, according to GSA officials, previous experience suggests 

that without being formally established in law or by executive order, 

participation by other agencies would likely be too low to be effective. 

There is no planned GSA completion date for creating this interagency 

advisory board.

GSA has taken steps to implement the requirements of the Act for its 

employees using its core competency approach but has yet to complete 

all its planned work. In 2014, GSA directed its Public Buildings Service 

(PBS) personnel in occupational series covered by the Act to take a webbased inventory of their completed training. GSA then assessed their 

training against the high-priority performances for their occupational 

series and identified areas where the employees needed improvement. 

Specifically, GSA found that collectively, the 1,142 employees who 

participated in the inventory had completed 36 percent of the required 

performances for their positions. In a July 2014 report on the assessment 

effort, GSA specified seven methods for PBS workers to voluntarily 

improve their proficiency levels in the core competencies. For example, 

GSA encouraged workers to use individual development plans to guide 

their training and identified free online training for energy management 

and water efficiency, which the official responsible for leading GSA’s 

implementation efforts indicated were two competency areas revealed in 

the PBS assessment as areas in which employees needed additional 

training. In addition, GSA developed a formal on-the-job training program 

that includes a guide, mentoring activities, and checklists to help reinforce 

knowledge gained. GSA also updated PBS’s building manager job 

descriptions for existing and new staff by (1) rewriting them to include 

high-priority performances related to the core competencies and (2) 

including the high-priority performances in each employee’s performance 

review criteria.

GSA has started—but has yet to complete—the following tasks to 

continue its implementation of the Act for its own employees:

· Although GSA has rewritten job descriptions and performance 

assessment criteria for approximately 640 PBS employees to include 

Page 8 GAO-16-39 Federal Real Property 

GSA Has Begun 

Implementation of the Act 

for Its Own Employees
high-priority performances, GSA has yet to determine whether the 

agency is ready to transfer the employees to the new job descriptions 

and performance assessment criteria. GSA plans to update previously 

identified gaps in Act-related training for PBS employees by requiring 

them to complete a new inventory of their training, which GSA’s 

official in charge of implementation estimated will be completed after 

September 2015. GSA will then assess their training against the highpriority performances for their positions.

· According to the official responsible for leading GSA’s implementation 

efforts, GSA is still exploring a way for PBS employees participating in 

structured on-the-job training to have the training verified in person by 

GSA’s subject matter experts. However, according to this official, 

while the technical content for the training is complete, GSA is still 

finalizing its process to select, vet, and monitor the performance of 

subject matter experts, and GSA has not specified a completion date.

GSA has not yet determined how many GSA contract staff are subject to 

the Act and is still in the planning stages for implementing potential 

methods for contractor compliance. GSA officials said they have 

discussed—but have not yet begun—a number of tasks related to 

contractor training. GSA has drafted standard contract language requiring 

companies bidding for facility operations and maintenance work to 

provide documentation. The companies would be required to describe 

how certain contract employees subject to the Act who could work in 

GSA-held buildings have either demonstrated the core competencies 

relevant to their positions or are currently participating in continuing 

education related to them. According to the GSA official responsible for 

leading GSA’s implementation efforts, GSA plans to conduct a pilot 

project to test the proposed language and approach using a GSA 

contract, and if successful, the language could be applied later to Federal 

Supply Schedule contracts

Page 9 GAO-16-39 Federal Real Property 

10 and incorporated by other agencies into their 

own internal operations and maintenance contracts for buildings 

personnel. In addition, the official noted that GSA is committed to 

implementing this approach but has not determined a target completion 

date. Similarly, he said GSA has considered using contract language 

 

10Federal agencies can procure goods and services directly from vendors through Federal 

Supply Schedule contracts, which are long-term government-wide contracts with 

commercial firms established to streamline government purchasing of commercial 

products and services and to leverage the buying power of the federal government. 

GSA Is Still Planning Its 

Implementation Approach 

for Contractors
related to the core competencies as a compliance mechanism for contract 

workers in federally leased buildings, but added that GSA has focused on 

buildings personnel who are federal and contract employees working in 

federally owned facilities because the agency considers those employees 

a higher priority than contractors working in leased federal facilities.

Of the five agencies we reviewed—two, the Departments of Defense 

(DOD) and Energy (DOE)—have taken some actions to respond to the 

Act while three—the Departments of Justice (DOJ), the Interior (DOI), and 

Veterans Affairs (VA)—have not yet determined how to respond. While all 

five agencies encourage or provide training for their facilities 

management staffs

Page 10 GAO-16-39 Federal Real Property 

11 and participated in GSA’s early planning sessions 

on government-wide implementation, three have not taken additional 

action. For example, they have issued no written plans or guidance 

memorandums, and none of them has moved beyond the initial 

discussion phase into the planning or execution phase. As a result, at this 

time little is known about the numbers of federal and contractor 

employees covered by the Act at these agencies or the status of their 

compliance with the Act. According to the official responsible for leading 

GSA’s implementation efforts, while agencies are in charge of defining 

what individual compliance means for their own employees, to fully 

respond, they should be engaging in a continual process of assessing 

employees’ training levels, determining where there are gaps in training,

and outlining ways to improve training for employees.

DOD is the largest holder of federal real property and because of its 

ongoing efforts to comply with earlier workforce realignment mandates 

and to ensure that implementation of the Act is consistent across DOD, 

officials decided to embark on a pilot program with the Defense Health 

Agency (DHA).12 For the pilot, a DOD contractor surveyed DHA 

employees in five positions that had the most significant impact on the 

finances and operations of facilities—central utility plant supervisor;

energy manager; facility manager; heating, ventilation, and air-

 

11For example, VA provides some training through its Veterans Health Administration 

Employee Education System and its VA Facilities Management School, and DOI provides 

some training through its DOI University.

12DHA was created in 2013 and is a joint, integrated combat support agency for the Army, 

Navy, and Air Force medical services. DHA also supports the delivery of health services to 

beneficiaries of the military health system. 

Selected Agencies 

Have Taken Some 

Action, but Overall 

Response to the Act 

Has Been Limited
conditioning (HVAC) controls technician; and project engineer—to 

determine how well the competencies for those positions aligned with 

GSA’s core competencies and job performances and whether there are 

gaps in training. DOD completed the initial pilot at two installations in 

June 2015 and published a final report of its results in July 2015. Next, 

according to DOD’s program analyst for implementation of the Act, DOD 

plans to integrate the applicable competencies and related training 

opportunities for DHA’s employees in the five key positions into GSA’s 

professional development tool. Beyond DOD’s DHA effort, the official said 

DOD plans to conduct pilots for facility management positions at several 

Army, Navy, and Air Force installations, and he stated that DOD has not 

made any changes to position descriptions. According to officials 

representing the three military services, they are waiting for the results of

these pilots before embarking on any implementation actions of their own.

DOE has identified approximately 5,500 federal and contractor 

employees who are subject to the Act’s requirements and has taken steps 

to assess their proficiency in the 12 competency areas.

Page 11 GAO-16-39 Federal Real Property 

13 In 2013, DOE 

directed program offices to report and track employees’ compliance, 

identify gaps in training, and assign supervisors to document employees’

compliance. DOE surveyed these federal and contractor employees to 

determine their existing training, assessed their training against the 12 

competency areas, identified gaps in proficiencies, and identified training 

opportunities for them. DOE provided us with the results of its summary 

assessments for 41 sites, and according to the assessments, most sites 

employed at least one person proficient in each competency area. 

However, because DOE defined a site-level demonstration of proficiency 

in a competency area to mean that at least one individual representing 

that site is proficient in the competency area, the results of DOE’s 

summary assessments did not provide us enough detail to determine how 

many individuals were proficient in each of the 12 competency areas.

Three of our selected agencies—DOI, DOJ, and VA—have not yet 

determined how to respond to the Act as none of them has moved 

beyond the initial discussion phase into the planning or execution phase.

 

13Although DOE focused on competency areas, GSA designed its competency model for 

individuals to demonstrate proficiency at the performance level. See figure 1. 
· DOI delegates management of DOI’s real property to six bureaus, the 

largest of which is the National Park Service (NPS). While senior DOI 

officials in Facilities and Property Management and Human 

Resources were generally unaware of any departmental response to 

the Act, a senior NPS official told us that NPS has had internal 

discussions about the Act and was trying to determine how to achieve

compliance.

· Senior DOJ officials in the Justice Management Division noted that 

most of the department’s buildings are correctional institutions that are 

held by the Bureau of Prisons (BOP) and that the officials had not yet 

determined how many staff would be subject to the Act. These DOJ 

officials were awaiting a briefing and further clarification from GSA, 

and senior BOP officials indicated that they were just becoming aware 

of the Act.

· VA holds and operates 167 medical centers through its Veterans 

Health Administration (VHA). VHA officials said they participated in a 

pilot project with GSA to develop competencies for professional and 

trade staff in three positions at VA medical centers. The goal was to 

use GSA’s competencies to help VHA develop standardized 

competencies for each position and then determine if staff met them. 

However, VHA officials indicated they were not able to complete this 

effort before the pilot project ended. In part because officials said they 

are awaiting more formal guidance or direction from GSA, VA at the 

departmental level is not currently planning or executing specific 

responses to the Act. However, GSA officials stated that the Act does 

not provide GSA a role in providing more formal government-wide 

guidance.

Although we found limited progress at the five agencies we reviewed, 

officials from four of the five agencies recognized the potential benefits 

from implementation of the Act. For example, DOD officials shared a 

DOD memorandum that noted that DOD’s components could benefit from 

an expanded training catalog, more affordable training, and stronger 

justification of the need for more training funds. Officials from DOD and 

VA agreed that identifying additional training and strengthening employee 

competency could benefit facility operations. In addition, officials from VA 

said that the Act could produce a stronger workforce and attract more 

competent staff.

Page 12 GAO-16-39 Federal Real Property 
We found that the pace of implementation has been limited by four factors 

that make federal buildings personnel compliance with the Act’s 

requirements essentially voluntary.

· No agency has the authority to enforce government-wide 

compliance. Because the Act does not give any agency the authority 

to enforce compliance of the Act government-wide, GSA sees its role 

as advisory. For example, an official from GSA’s Office of 

Government-wide Policy said that while GSA shares its internal 

guidance and procedures informally with other agencies, GSA is not 

authorized to issue official government-wide guidance on 

implementation. In addition, no agency monitors government-wide 

compliance with the Act’s requirements. We asked officials from the 

Office of Personnel Management (OPM) why the agency has not 

been involved in implementing the Act, and were given two reasons: 

(1) the Act did not direct OPM to do so and (2) GSA did not request 

OPM’s implementation assistance for any changes that would affect 

policies administered under OPM’s authorities, such as the 

management of government-wide position classifications. Federal 

internal control standards emphasize that a good control environment 

requires clearly defining key areas of authority and responsibility and 

establishing appropriate lines of reporting.

Page 13 GAO-16-39 Federal Real Property 

14

· Agencies are not required to report progress. The Act does not 

require federal agencies to submit specific buildings personnel 

training improvement plans or progress reports to GSA, or to 

Congress, as has been mandated in other workforce improvement 

legislation. For example, legislation enacted in 2009 included a 

provision aimed at improving DOD’s civilian workforce and also 

included a list of specific reporting requirements for DOD, such as 

assessments of the current and future critical skills and competencies 

of its civilian workforce.15 A U.S. Army official said that without a 

similar reporting requirement, there is no “trigger” to prompt 

compliance with the Act’s requirements. Furthermore, since the 

language in the Act directs individuals—not agencies—to comply with 

the requirements, there is no clear mandate for agencies on exactly 

how to achieve individual compliance. Without a requirement for 

 

14GAO, Internal Control: Standards for Internal Control in the Federal Government,

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

15The National Defense Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, div. 

A., title XI, § 1108 (Oct. 28, 2009), codified as amended at 10 U.S.C. § 115b. 

Various Factors Have 

Contributed to Limited 

Implementation of the 

Act
federal agencies to report on their efforts related to the Act, there is 

little incentive for them to account for how many of their employees 

are subject to the Act and whether those covered employees are 

complying. Federal internal control standards state that an agency’s 

ongoing monitoring of its internal controls should assess the quality of 

its performance over time.

Page 14 GAO-16-39 Federal Real Property 

16 This assessment would include 

monitoring the progress of initiatives to establish appropriate practices 

for training and evaluating personnel.

· Agencies report having limited training and implementation 

funds. Officials generally agreed that implementation has been 

limited by the current fiscal environment—including mandatory 

spending cuts required by the sequestration. This fiscally constrained 

environment has impacted agency training budgets, an impact that 

has resulted in increased internal competition for limited training 

resources. A VA official said the Act’s lack of dedicated funding has 

limited large-scale implementation and resulted in an uncoordinated, 

inconsistent approach. VA officials responsible for facilities operations 

guidance and policies requested $15 million in additional funding for 

fiscal year 2013 to fund VA’s response to the Act but were unable to 

secure the funds. The VA official said that in contrast, an earlier VA 

facilities workforce improvement effort included dedicated funding 

targeted for specific training and education, allowing the agency to 

place energy managers in field facilities and improve the knowledge 

and skills of employees in leadership positions, such as maintenance 

and operations supervisors and chief engineers. While there are free 

training options available, the GSA official responsible for leading the 

agency’s implementation efforts agreed that the Act’s lack of 

dedicated funding acts as a “braking” mechanism as some agencies 

may be delaying assessing employee skill levels for fear of not having 

sufficient funding to provide the required training identified as a result 

of these assessments. However, according to federal internal control 

standards, the management of an agency’s human capital is essential 

to achieving results and is an important part of internal control.17 This 

management includes continually assessing employee skill levels and 

providing training opportunities that allow employees to develop and 

maintain required skills.

 

16GAO/AIMD-00-21.3.1.

17GAO/AIMD-00-21.3.1.
· No interagency mechanism exists for guiding implementation.

No interagency group has been created to ensure consistent 

implementation of the Act across the government, a situation that has 

resulted in a lack of coordinated implementation policy and guidance. 

This lack has also hindered the development of a potential formal 

collaboration mechanism for sharing leading practices. We have 

previously found that agencies can benefit from considering 

government-wide reforms when planning their training and 

development programs.

Page 15 GAO-16-39 Federal Real Property 

18 In addition, our past work has shown that 

one attribute of effective training and development programs is the 

extent to which an agency compares its training methods with those of 

other organizations, and we found that agencies benefit when they 

continuously look to others to identify innovative approaches that may 

relate to training and development efforts as well as lessons 

learned.19 Furthermore, we have previously reported that many of the 

meaningful results that the federal government seeks to achieve 

require the coordinated efforts of more than one federal agency.20 Our 

past work found that interagency groups are mechanisms that can be 

used to develop policy, guide program implementation, and conduct 

oversight and monitoring.21 GSA has taken steps to create such a 

group, but this process is still in the development stage.

Since passage of the Act in 2010, GSA has largely met its lead-agency 

responsibilities, which were designed to strengthen government-wide 

training for federal buildings personnel so they can operate federal 

buildings more efficiently and effectively. In consulting with others, 

identifying core competencies, and supplying approved training 

opportunities and a recommended method for employees to demonstrate 

their proficiency levels, GSA has provided a road map for implementation 

government-wide. In addition, by seeking an interagency mechanism to 

further government-wide collaboration, GSA has shown a willingness to 

 

18GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: March 2004).

19GAO-04-546G.

20GAO, Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: February 2014).

21GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: September 2012). 

Conclusions
actively encourage further federal agency participation, which is essential 

to the successful implementation of the Act.

Nevertheless, the pace of implementation government-wide remains slow 

because, among other things, no agency monitors or enforces 

compliance of the Act government-wide, and the Act does not effectively 

place responsibility for action directly on federal agencies. GSA has 

already conducted extensive outreach and created a core competency 

approach that agencies could use. Further steps could be taken to: (1) 

provide one agency with the authority to enforce compliance of the Act 

and monitor the actions agencies take to comply; (2) place responsibility 

directly on agencies to report progress on implementing the Act, including 

how they assess employees’ skills and improve their training; and (3) 

provide agencies with a mechanism for collaboration. Such measures 

could provide effective incentives for agencies to take the proactive steps 

necessary to attain individual employee compliance. Until such steps are 

taken, Congress cannot know the basic measures of the Act’s 

effectiveness, including how many employees are subject to the Act, the 

progress of its implementation, and the extent to which covered 

employees are complying.

We recommend that the Administrator of the General Services 

Administration develop a legislative proposal to enhance accountability 

for government-wide implementation of the Act. GSA should consider 

including the following in its proposal:

· establishing authorities for a single agency to monitor and enforce 

implementation of the Act;

· establishing agency responsibilities for reporting progress on 

implementation of the Act;

· establishing agency responsibilities for assessing employee skill 

levels related to the Act and identifying training that allows employees 

to develop and retain skills required by the Act; and

· establishing an interagency group to further government-wide 

collaboration on implementation of the Act.

We provided a draft of this report for review and comment to GSA, OPM, 

and the Departments of Defense, Energy, the Interior, Justice, and 

Veterans Affairs. GSA stated it agreed with the report’s findings and that it 

would work with the appropriate agencies to address these findings (see 

Page 16 GAO-16-39 Federal Real Property 

Recommendation for 

Executive Action

Agency Comments
app. II). OPM and the Departments of Defense, Energy, the Interior, and 

Justice had no comments. The Department of Veterans Affairs provided 

technical comments which we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 14 days from the 

report date. At that time, we will send copies to the Administrator of GSA, 

the Acting Director of OPM, the Attorney General, and the Secretaries of 

Defense, Energy, the Interior, and Veterans Affairs. In addition, the report 

will be available at no charge on the GAO website at http://www.gao.gov.

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

me at (202) 512-2834 or wised@gao.gov. Contact points for our Offices 

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.

Sincerely yours,

David Wise

Director, Physical Infrastructure Issues

Page 17 GAO-16-39 Federal Real Property 
Appendix I: Objectives, Scope, and 

Methodology

Our objective was to review the status of the implementation of the 

Federal Buildings Personnel Training Act of 2010 (the Act). To do so, we 

addressed the following questions:

1. What progress has GSA made in implementing the requirements of 

the Act?

2. What actions have selected federal agencies taken in response to the 

Act?

3. What factors have affected implementation of the Act?

To determine the progress GSA has made in responding to the provisions 

of the Act, we reviewed the Act, congressional committee and 

Congressional Budget Office reports, and GSA’s web sites and 

documents—including GSA’s required annual update of its core 

competencies and recommended curriculum, its www.fmi.gov web site, 

and a report on the implementation of the Act by GSA’s Public Buildings 

Service. We did not evaluate the effectiveness of the core competencies 

and recommended curriculum that GSA developed. In addition, we 

interviewed officials in GSA’s Office of Government-wide Policy, Office of 

Federal High-Performance Green Buildings, Office of Human Resources 

Management, and Public Buildings Service as well as representatives of 

several industry groups. (See table 1.)

To determine what actions agencies have taken in response to the Act, 

we selected five federal agencies—the Departments of Defense (DOD), 

Energy (DOE), the Interior (DOI), Justice (DOJ), and Veterans Affairs 

(VA)—on the basis of the gross square footage of federal real property 

they occupy, according to 2014 Federal Real Property Profile data, and 

because they were included in initial meetings about the Act that GSA 

held in 2011. Together with GSA, the agencies we selected occupy about 

90 percent of federal real property gross square footage, according to the 

2014 Federal Real Property Profile. Our determination of agency actions 

in response to the Act included interviews of agency program and human 

capital officials (see table 1) and reviews of agency documentation and 

reports. For example, we reviewed DOD’s report from the first phase of its 

Act-related pilot at the Defense Health Agency and DOE’s report 

documenting its assessment of staff’s compliance with the core 

competencies. We did not assess the effectiveness or results of selected 

agencies’ use of the core competencies.

To determine the factors that have affected implementation of the Act, we 

reviewed the Act and agency studies and reports, including DOD’s phase 

Page 18 GAO-16-39 Federal Real Property 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

1 pilot report and DOE’s summary analysis of the proficiency of its 

workforce in the 12 competency areas. We also reviewed prior GAO work 

on internal controls and human capital related to enhancing agency 

accountability and planning and developing training programs and 

interviewed agency officials and representatives from professional 

societies, industry associations, non-profit organizations, and private and 

government training groups. We also discussed with the Office of 

Personnel Management (OPM) OPM’s role in implementing the Act 

government-wide. For the agency interviews, we used standardized data 

collection instruments to maintain consistency across the interviews.

Table 1: Agency and Other Interviewees

Page 19 GAO-16-39 Federal Real Property 

Agency Interviewee

DOD Office of the Secretary of Defense

Defense Health Agency

Department of the Air Force

Department of the Army

Department of the Navy

DOE Federal Energy Management Program

Office of Property Management

DOI Office of Facilities and Property Management

Office of Human Resources

National Park Service

DOJ Justice Management Division

Office of Human Resources

GSA Office of Government-wide Policy

Office of Federal High-Performance Green Buildings

Public Buildings Service

Office of Human Resources Management

OPM Workforce and Succession Planning

VA Office of Management

Human Resources and Administration

Veterans Health Administration

Facilities Management School

Other Groups BOMI International

International Association of Plumbing and Mechanical Officials (IAPMO)

International Facility Management Association (IFMA)

Northwest Energy Efficiency Council (NEEC)

National Institute of Building Sciences (NIBS)
Appendix I: Objectives, Scope, and 

Methodology

Source: GAO. | GAO-16-39

Page 20 GAO-16-39 Federal Real Property 
Appendix II: Comments from the U.S. General 

Services Administration

Page 21 GAO-16-39 Federal Real Property 

Appendix II: Comments from the U.S. 

General Services Administration 
Appendix III: GAO Contact and Staff 

Acknowledgments

David Wise, (202) 512-2834 or wised@gao.gov

In addition to the contact named above, Steve Cohen, Assistant director; 

Gary Guggolz, Analyst-in-Charge; Hannah Laufe; Malika Rice; Kelly 

Rubin; Pamela Vines; and Michelle Weathers made key contributions to 

this report.

Page 22 GAO-16-39 Federal Real Property 

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Appendix IV: Accessible Data

Page 23 GAO-16-39 Federal Real Property 

Accessible Text for Figure 1: The General Services Administration’s (GSA) Federal Buildings Personnel Training Act of 2010 

Competency Model

Competency areas

Career areas of 

responsibility Core competencies Performance examples

1. Management of 

facilities operations 

and maintenance (High 

priority)

Facility 

management

1.1 Building systems (High priority);

1.2 Building interior;

1.3 Building exterior (High priority);

1.4 Other facility systems.

1.1.1 Demonstrate familiarity with 

building systems and knowledge 

of how they affect energy use 

(High priority).

2. Performance of 

facilities operations 

and maintenance (High 

priority)

Operations & 

maintenance

2.1 HVAC (High priority);

2.2 Electrical/mechanical systems (High priority);

2.3 Life safety systems;

2.4 General building maintenance;

2.5 Best practices and innovation (High priority).

2.1.1 Demonstrate ability to 

collect building systems’ 

operating and performance data 

(High priority).

3. Technology (High 

priority)

Facility 

management

3.1 Technology solutions (High priority);

3.2 Building automation systems (High priority);

3.3 Maintenance management system (High priority).

3.1.1 Demonstrate ability to 

monitor information and trends 

related to facility management 

and information technology 

solutions (High priority).

4. Energy management 

(High priority)

Energy 

management

4.1 Systems and demand reduction (High priority);

4.2 Assess initial conditions (High priority);

4.3 Commissioning and energy savings performance 

contracts (High priority);

4.4 Coordinate with public utilities (High priority);

4.5 Planning, project, and program management 

(High priority).

4.1.3 Demonstrate knowledge of 

demand response strategies 

such as thermal energy storage 

systems (High priority).

5. Safety Facility 

management, 

Operations & 

maintenance, 

Energy 

management

5.1 Basic requirements;

5.2 Infrastructure;

5.3 Contractor program oversight;

5.4 Occupant interface.

5.1.2 Complete electrical safety 

course and be familiar with 

electrical codes and regulations 

and best practices.

6. Design Facility 

management

6.1 Planning;

6.2 Infrastructure problems.

6.1.5 Demonstrate knowledge of 

green building certification 

systems used by the federal 

government and industry (High 

priority).

7. Sustainability (High 

priority)

Facility 

management, 

Operations & 

maintenance, 

Energy 

management

7.1 Background;

7.2 Regulations and requirements;

7.3 Implementation (High priority).

7.2.1 Demonstrate knowledge of 

the guiding principles for federal 

high performance and 

sustainable buildings, and federal 

mandates (High priority).

Appendix IV: Accessible Data

Accessible Text and 

Data Tables
Appendix IV: Accessible Data

Page 24 GAO-16-39 Federal Real Property 

Competency areas

Career areas of 

responsibility Core competencies Performance examples

8. Water efficiency 

(High priority)

Energy 

management

8.1 Regulations, goals, and best practices;

8.2 Water audit (High priority).

8.1.2 Demonstrate knowledge of 

federal water policy and goals 

found in laws and executive 

orders (High priority).

9. Project management Facility 

management, 

Operations & 

maintenance, 

Energy 

management

9.1 Initiate;

9.2 Execute;

9.3 Closeout;

9.4 Training.

9.1.2 Demonstrate knowledge 

and ability to follow project 

management processes and 

procedures per your 

organization’s preferred 

methodology.

10. Business, budget 

and contracting (High 

priority)

Facility 

management

10.1Total cost of ownership (High priority);

10.2Life cycle assessment (High priority);

10.3Contracting;

10.4Budget formulation and execution.

10.3.5 Demonstrate knowledge 

of and ability to effectively 

govern/oversee a contract to 

ensure compliance and full value 

of the service or product being 

provided.

11. Leadership and 

innovation (High priority)

Energy 

management

11.1Communication and administration;

11.2Personnel;

11.3Innovation (High priority);

11.4Enterprise knowledge and strategic decisionmaking (High priority).

11.3.7 Demonstrate ability to 

translate innovative ideas into 

actionable tasks (High priority).

12. Performance 

measurement (High 

priority)

Facility

management, 

Operations & 

maintenance, 

Energy 

management

12.1Federal Buildings Personnel Training Act;

12.2Acquiring data (High priority);

12.3Establishment and implementation (High priority).

12.2.2 Demonstrate knowledge 

of key building performance 

measures, where and how to 

read them, and reporting 

requirements (High priority).

Source: GAO illustration of General Services Administration information. | GAO-16-39

Accessible Text for Appendix II: Comments from the General Services 

Administration

U.S. General Services Administration 

1800 F Street NW

Washington, DC 20405

Telephone (202) 501-0800

Fax (202) 219-1243

www.gsa.gov

The Administrator

Agency Comments

General Services 

Administration

(542243)
Appendix IV: Accessible Data

September 30, 2015

The Honorable Gene L. Dodaro 

Comptroller General of the United States

U.S. Government Accountability Office 

Washington, DC 20548

Dear Mr. Dodaro:

The U.S. General Services Administration (GSA) appreciates the 

opportunity to review and comment on the U.S. Government 

Accountability Office (GAO) draft report entitled, Federal Real Property: 

Additional Authorities and Accountability Would Enhance the 

Implementation of the Federal Buildings Personnel Training Act of 2010 

(GAO-16-39). We have reviewed this report in depth and agree with the 

findings in the Report, and will work with the appropriate agencies to 

address the findings.

Thank you for the clarity and thoroughness of this Report. If you have any 

questions, please contact me at the number below, or Ms. Lisa A. Austin, 

Associate Administrator, Office of Congressional and Intergovernmental 

Affairs, at (202) 501-0563.

Sincerely,

Denise Turner Roth

Administrator

cc: Mr. David Wise, Director, Physical Infrastructure Issues, GAO

Page 25 GAO-16-39 Federal Real Property 
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. 

Listen to our Podcasts and read The Watchblog.

Visit GAO on the web at www.gao.gov.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

PleasrintoRecyldPapr.