CHIEF ACQUISITION 

OFFICERS

Appointments 

Generally Conform to 

Legislative 

Requirements, but 

Agencies Need to 

Clearly Define Roles 

and Responsibilities

Report to the Committee on Homeland 

Security and Governmental Affairs, 

U.S. Senate

July 2012

GAO-12-792

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-792, a report to the 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

July 2012

CHIEF ACQUISITION OFFICERS

Appointments Generally Conform to Legislative 

Requirements, but Agencies Need to Clearly Define 

Roles and Responsibilities 

Why GAO Did This Study 

Federal agencies spent more than half 

a trillion dollars in fiscal year 2011 

through contracts to acquire goods and 

services in support of their missions, 

but have historically faced significant 

acquisition management challenges 

preventing them from getting the best 

return on their investments. The SARA 

legislation requires 16 federal civilian 

agencies to appoint a Chief Acquisition 

Officer to advise and assist agency 

leadership to help ensure that the 

agency’s mission is achieved through 

the management of its acquisition 

activities. GAO was asked to examine: 

(1) how agencies have filled the CAO 

position; (2) the extent to which CAOs 

are involved in performing the 

acquisition management functions set 

forth in the SARA legislation and Office 

of Management and Budget (OMB)

guidance; and (3) what challenges, if 

any, agency CAOs report in fulfilling 

their responsibilities. GAO 

administered a questionnaire to 16 

CAOs, reviewed documentation on 

CAOs’ roles and responsibilities, 

organizational placement, and 

backgrounds, and interviewed a 

number of CAOs and other acquisition 

officials.

What GAO Recommends

GAO recommends that the 

Administrator of OMB’s Office of 

Federal Procurement Policy work with 

the CAO Council to issue guidance 

directing agencies to more clearly

define CAOs’ roles and responsibilities.

The Administrator agreed with the 

recommendation.

What GAO Found

Most agencies have appointed Chief Acquisition Officers (CAO) in accordance 

with two of the three key requirements in the Services Acquisition Reform Act of 

2003 (SARA): that the CAOs be political appointees and have agency Senior 

Procurement Executives report directly to them. However, few CAOs have 

acquisition management as their primary duty; other areas of responsibility 

included financial, information, and human capital management. 

CAO Characteristics

Several CAOs noted that their additional responsibilities were not a detriment. 

Rather, they believe that performing multiple roles helps them positively influence 

acquisition management across their agencies. For example, the CAO at the 

Department of Commerce stated that his additional responsibilities gave him the 

ability to integrate planning, budgeting, risk management, human resources, and

acquisition to achieve the agency’s mission. 

CAOs reported varying levels of involvement in the acquisition management 

functions for which they are responsible. Generally, CAOs see their role as 

providing high-level oversight of the acquisition function as opposed to day-today management, which they typically delegated to the Senior Procurement 

Executive or other officials as permitted by the legislation. Many CAOs said that 

the amount of their involvement is related to several factors, such as the nature 

of goods and services that the agency buys and whether the agency has a 

centralized or decentralized acquisition function. 

Having clearly defined roles and responsibilities of stakeholders in the acquisition 

process is a key element of an effective acquisition function. Yet at many 

agencies, the statutory roles and responsibilities of the CAO position are not 

described in detail in acquisition regulations, policies, or other documentation. 

These agencies may be missing an opportunity to fully institutionalize the CAO 

position within their senior leadership structures.

CAOs at the 16 agencies generally did not report facing significant challenges 

related to the CAO position, such as the level of influence they have in their 

agency’s acquisition process, amount of control over acquisition budget 

resources, and access to agency leadership. Consistent with our prior work on 

the acquisition workforce, however, most CAOs reported that not having enough 

staff to manage acquisitions was moderately to extremely challenging. 

View GAO-12-792. For more information, 

contact William T.Woods at (202) 512-4841 or 

WoodsW@gao.gov.
Page i GAO-12-792 Chief Acquisition Officers

Letter 1 

Background 3

Agencies Have Established CAOs as a Focal Point for Acquisition, 

but Most Have Other Management Responsibilities and Short 

Tenures 6

CAO Involvement in Acquisition Management Functions Varies 14

CAOs Reported Few Significant Challenges and Generally Did Not 

Identify Changes Needed to Improve Their Effectiveness 21

Conclusions 23

Recommendation for Executive Action 24

Agency Comments and Our Evaluation 24

Appendix I Objectives, Scope, and Methodology 26

Appendix II Key Responsibilities of CAOs 29

Appendix III Comments from the Department of Health and Human Services 30

Appendix IV GAO Contact and Staff Acknowledgments 32

Tables

Table 1: CAO Agencies’ Contract Spending and Acquisition 

Management Challenges 5

Table 2: Official Titles and Management Responsibilities of Chief 

Acquisition Officers 8

Table 3: Summary of Observations on CAO Position in Agency 

Acquisition Regulations and Policies 20

Figures

Figure 1: CAO Characteristics 7

Figure 2: Organizational Placement of CAOs 11

Contents
Page ii GAO-12-792 Chief Acquisition Officers

Figure 3: CAO Turnover and Proportion of Time CAO Position 

Filled by a Permanent Official (from SARA Enactment 

through April 2012) 13

Figure 4: Level of CAO Involvement in the Eight Acquisition 

Functions Outlined in SARA Legislation and OMB 

Guidance 15

Figure 5: Delegation of Responsibilities Reported by CAOs across 

the Eight Acquisition Management Functions Outlined in 

SARA Legislation and OMB Guidance 17

Figure 6: Extent of Challenge Reported by CAOs in Fulfilling Their 

Acquisition Management Responsibilities 22

Abbreviations

CAO Chief Acquisition Officer

CFO Chief Financial Officer

CHCO Chief Human Capital Officer

CIO Chief Information Officer

DHS Department of Homeland Security

EPA Environmental Protection Agency

FAR Federal Acquisition Regulation

GSA General Services Administration

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

IG Inspector General

IT information technology

NASA National Aeronautics and Space Administration

OFPP Office of Federal Procurement Policy

OMB Office of Management and Budget

SARA Services Acquisition Reform Act of 2003

SPE Senior Procurement Executive

VA Department of Veterans Affairs

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Page 1 GAO-12-792 Chief Acquisition Officers

United States Government Accountability Office

Washington, DC 20548

July 26, 2012

The Honorable Joseph I. Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

In fiscal year 2011, federal agencies collectively spent more than half a

trillion dollars through contracts to acquire goods and services in support 

of their missions. With the United States facing increasing fiscal 

pressures, there is a need to ensure that federal agencies make the most 

efficient and effective use of their resources. However, agencies have 

historically faced significant acquisition management challenges that have 

prevented them from getting the best return on their investments in goods 

and services. To address these challenges, agencies must establish a 

strong foundation for an effective, efficient and accountable acquisition 

process, which includes proper organizational alignment and committed 

agency leadership. To this end, the Services Acquisition Reform Act of 

2003 (SARA)1

You asked that we review the implementation of the CAO position at 

federal agencies. In response, we examined: (1) how agencies have filled 

the CAO position; (2) the extent to which CAOs are involved in performing 

the acquisition management functions set forth in the SARA legislation 

and Office of Management and Budget (OMB) guidance, and (3) what 

challenges, if any, agency CAOs report in fulfilling their responsibilities. 

To address these objectives, we analyzed the SARA legislation and 

directives from OMB’s Office of Federal Procurement Policy (OFPP) to 

identify the key roles and responsibilities of the CAO position. We then 

requires 16 federal civilian agencies to establish the 

position of a Chief Acquisition Officer (CAO) to advise and assist agency 

leadership to help ensure that the agency’s mission is achieved through 

the management of its acquisition activities.

 

1 Pub. L. No. 108-136, § 1421, 117 Stat. 1663 (codified as amended at 41 U.S.C. § 1702). 

 
 

Page 2 GAO-12-792 Chief Acquisition Officers

administered a questionnaire by e-mail to the 16 civilian agencies2 within 

the scope of our review.3

We conducted this performance audit from October 2011 to July 2012 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 questionnaire requested information on, 

among other things, the CAOs’ organizational reporting relationships, 

tenure, involvement in acquisition management functions within the 

agency, and challenges experienced in fulfilling their CAO responsibilities. 

We received responses from all 16 agencies, though not all agencies 

provided responses to each question. We also collected and reviewed 

agency organizational charts, acquisition regulations and guidance, 

applicable policies and delegation orders, as well as biographical 

information, to identify the organizational placement, roles and 

responsibilities, and professional background of the CAO position within 

the agency. Finally, we conducted follow-up interviews to discuss the 

CAO’s roles and responsibilities with CAOs and acquisition officials at

seven agencies: Energy, the General Services Administration (GSA), 

Commerce, Department of Health and Human Services (HHS), Interior, 

Department of Homeland Security (DHS), and the National Aeronautics 

and Space Administration (NASA). We selected a nongeneralizable 

sample of agencies for follow-up interviews based upon the following 

criteria: review of the questionnaire responses, the agency’s procurement 

obligations in fiscal year 2010, and whether the agency’s Inspector 

General had identified acquisition-related issues as a major management 

challenge. Our review did not assess the effectiveness of individual CAOs 

or individual agencies’ acquisition functions. A more complete description 

of our objectives, scope, and methodology is provided in appendix I.

 

2 We sent the questionnaire to the Departments of Agriculture, Commerce, Education, 

Energy, Health and Human Services, Homeland Security, Housing and Urban 

Development, the Interior, Labor, State, Transportation, the Treasury, Veterans Affairs, 

the Environmental Protection Agency, the National Aeronautics and Space Administration, 

and the General Services Administration (GSA). 

3 The SARA legislation exempts the Department of Defense (DOD) from the CAO 

requirement. Legislation enacted prior to SARA required DOD to have an Under 

Secretary of Defense (Acquisition, Technology & Logistics) who has responsibilities 

similar to those of a CAO. Justice is not required to appoint a CAO under the SARA 

legislation, but has designated the Assistant Attorney General for Administration as the 

CAO. 
 

Page 3 GAO-12-792 Chief Acquisition Officers

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Chief Acquisition Officers provide a focal point for acquisition in agency 

operations. The SARA legislation requires that CAOs:

• be noncareer employees;4

• have acquisition management as their primary duty; and

• have the agency’s Senior Procurement Executive (SPE) report 

directly to them without intervening authority, or serve as both CAO 

and SPE.5

The SARA legislation outlined seven acquisition management functions 

CAOs are expected to perform within their agencies. Subsequent to the 

enactment of SARA, governmentwide directives and guidance have 

assigned CAOs responsibility for additional functions, such as internal 

control reviews of the acquisition function under OMB Circular A-123 and 

ensuring the quality of federal procurement data. The key functions of the 

CAO we reviewed are listed below; additional information on these 

functions is also available in appendix II:

• monitoring and evaluating agency acquisition activities;

• increasing the use of full and open competition;

• increasing performance-based contracting;

• making acquisition decisions;

• managing agency acquisition policy;

• acquisition career management;

• acquisition resources planning; and

• conducting acquisition assessments under OMB Circular A-123.

The SARA legislation also established a Chief Acquisition Officers 

Council that is chaired by OMB’s Deputy Director for Management, and 

 

4 For purposes of this report, we refer to noncareer employees as political appointees. For 

additional information, see GAO, Personnel Practices: Conversions of Employees from 

Political to Career Positions May 2005-May 2009, GAO-10-688 (Washington, D.C.: June 

28, 2010).

5 The Senior Procurement Executive position was established in 1983 prior to the creation 

of the CAO position (see Pub. L. No. 98-191, § 7). The Senior Procurement Executive is 

typically a career employee who is responsible for management direction of an agency’s 

procurement system, including implementation of the agency’s unique procurement 

policies, regulations, and standards.

Background 
 

Page 4 GAO-12-792 Chief Acquisition Officers

whose activities are led by the OFPP Administrator.6

Our prior work has emphasized the need for strong, effective leadership 

and the appropriate placement of the acquisition function within agencies 

among many key factors needed in order to facilitate efficient, effective, 

and accountable acquisition processes. Clear, strong, and ethical 

executive leadership, including a CAO, is key to obtaining and 

maintaining organizational support for executing the acquisition function.

The council is the 

principal interagency forum for monitoring and improving the federal 

acquisition system. Its activities include developing recommendations for 

the Director of OMB on acquisition policies and requirements; sharing 

best practices; and helping to address the hiring, training, and 

professional development needs of the acquisition workforce.

7

Most of the agencies required to appoint a CAO spend a substantial 

amount of funding each year through contracts to acquire goods and 

services in support of their missions, as shown below in table 1. Yet, 

acquisition management challenges persist among many of these 

agencies. Among the 16 agencies, 11 had acquisition-related issues 

identified as a major management challenge by their respective Inspector 

General (IG) in its most recent report on agency management challenges. 

Additionally, our high-risk list includes a number of areas related to 

acquisition management.8

 

6 Pub. L. No. 108-136, § 1422, 117 Stat. 1663, 1668 (2003).

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

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

8 GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: Feb. 2011).
 

Page 5 GAO-12-792 Chief Acquisition Officers

Table 1: CAO Agencies’ Contract Spending and Acquisition Management Challenges

Agency

Fiscal year 2011 funded 

contract obligations

(in billions)

Contract obligations as 

percentage of agency fiscal year 

2011 discretionary budget 

authority

Acquisition-related issues 

identified as a major management 

challenge by agency IG

Energy $21.3 82.9% X 

HHS $19.9 25.8% X 

Veterans Affairs $17.8 31.5% X 

DHS $14.8 35.1% X 

NASA $14.7 79.7% X 

State $9.2 35.2% X 

GSA $7.1 Not applicable X 

Treasury $7.0 52.0%

Agriculture $5.4 23.3%

Transportation $4.9 28.9% X 

Commerce $3.2 56.8% X 

Interior $3.0 25.7%

Labor $2.5 20.1% X 

Environmental Protection 

Agency $2.1 24.2%

Education $1.9 2.8% X 

Housing and Urban 

Development $1.8 4.8%

Source: GAO analysis of federal procurement data, OMB historical budget data, and Inspector General reports.

Note: GSA primarily funds its operations through fee revenue generated by its activities, as opposed 

to the use of appropriated funds.

Since the creation of the CAO position, other reviews have made 

recommendations related to its implementation at specific agencies:

• The Department of Labor IG has frequently reported on concerns that 

the agency has not been in compliance with the SARA requirement 

for the CAO to have acquisition management as the primary duty.

• A 2011 Department of Transportation IG report also found that the 

department’s acquisition organizational structure does not effectively 

support the department’s acquisition function, and noted that the CAO 

does not have acquisition management as the primary duty.
 

Page 6 GAO-12-792 Chief Acquisition Officers

The agencies within the scope of our review generally have established 

CAOs in a way that satisfies two of three key aspects of the legislation. 

The CAOs in place at these agencies are generally political appointees 

situated at top levels in their organization, and at most agencies, the 

Senior Procurement Executive reports directly to the CAO. However, very 

few agency CAOs have acquisition management as their primary duty, 

the third key requirement of the SARA legislation. Most of these CAOs 

have other significant management responsibilities within their agencies, 

such as serving as the Chief Financial Officer (CFO). Additionally, some 

CAOs and acquisition officials said it was a challenge in determining how 

to fill the position within their agency, because the SARA legislation did 

not provide an additional leadership slot specifically for the CAO position. 

Tenure in the CAO position also has been relatively short, as the average 

CAO tenure was about 2 years, and several agencies have had frequent 

turnover in CAOs.

As shown below in figure 1, most agency CAOs are political appointees 

and have the Senior Procurement Executives report directly to them, but 

few have acquisition management as their primary duty.

Agencies Have 

Established CAOs as a 

Focal Point for 

Acquisition, but Most 

Have Other 

Management 

Responsibilities and 

Short Tenures

CAOs Generally Appointed 

in Accordance with 

Requirements, but Few 

Have Acquisition 

Management as Their 

Primary Duty
 

Page 7 GAO-12-792 Chief Acquisition Officers

Figure 1: CAO Characteristics

• Twelve of the 16 agencies had a permanent CAO in place at the time 

we administered our questionnaire.9 Three agencies (Education, 

Department of Veterans Affairs (VA) and Department of Housing and 

Urban Development (HUD)) had an acting CAO, and the position was 

vacant at Energy, which is currently relying on the Senior 

Procurement Executive as its lead acquisition official.10

• At 13 agencies, the Senior Procurement Executive reports directly to 

the Chief Acquisition Officer without intervening authority. The Senior 

Procurement Executive does not report directly to the CAO at 2 

agencies—HHS and NASA. Officials at these agencies told us there is 

an informal reporting relationship between the two positions. HHS 

also noted that despite the indirect organizational relationship 

between the two positions, the CAO and Senior Procurement 

Executive communicate frequently on the department’s acquisition 

policies, priorities, and programs.

All 12 

permanent CAOs were political appointees, and 1 of the 3 acting 

CAOs was a political appointee.

• Only 3 of the CAOs in place during our review (DHS, GSA, and VA) 

reported that acquisition management was their primary duty, another 

requirement of the SARA legislation. When asked to estimate the 

amount of time spent on their CAO duties relative to their other 

 

9 Following the administration of our CAO questionnaire, 3 agencies reported changes in 

the CAO position. The GSA CAO left the agency in April 2012. GSA appointed an acting 

CAO in June 2012 who also serves as Senior Advisor to the Acting Administrator. The

Treasury CAO also left the agency in April 2012 and the position is held by an acting 

official who is a political appointee. HUD, which had an acting CAO at the time we 

administered our questionnaire, now has a permanent CAO who is a political appointee.

10 In the past, Energy’s CAO has been a political appointee to whom the SPE directly 

reported, and has had acquisition management as the primary duty.
 

Page 8 GAO-12-792 Chief Acquisition Officers

responsibilities, the average among the 14 agencies that provided a 

response was about 27 percent. Furthermore, only 3 of the 12 

permanent CAOs in place during our review had prior experience in 

acquisition or procurement prior to serving as CAO. Although SARA 

does not require the CAO to have a background in acquisition, this is 

one of many factors that could affect the CAO’s success in the 

position.

• As shown below in table 2, almost all of the CAOs in our review had 

additional management responsibilities and few had an official title of 

Chief Acquisition Officer. For example, at the Departments of State, 

Agriculture, and Commerce, the Assistant Secretary for Administration 

serves as the CAO. These officials’ additional areas of responsibility, 

among other things, include financial management, information 

management, equal employment opportunity, and emergency 

preparedness. 

Table 2: Official Titles and Management Responsibilities of Chief Acquisition Officers

Agency

Official title of the Chief Acquisition 

Officer 

Number of 

additional positions 

held within agency 

(excluding official 

title) 

Chief Acquisition Officer also serves as the

Chief Financial 

Officer 

Chief 

Human 

Capital 

Officer 

Chief 

Information 

Officer 

Agriculture Assistant Secretary for Administration 0 

Commerce Chief Financial Officer/Assistant Secretary 

for Administration

5 X X 

DHS Under Secretary for Management 0

Education Chief Financial Officer 1 X 

Energy Chief Acquisition Officer (vacant) 0

EPA Assistant Administrator 4 X 

GSA Chief Acquisition Officer 0 

HHS Assistant Secretary for Financial 

Resources

5 X 

HUD Deputy Secretary 3 

Interior Assistant Secretary, Policy, Management 

and Budget

7 X X 

Labor Assistant Secretary for Administration and 

Management

2 X X 

NASA Chief Financial Officer 2 X 

State Assistant Secretary for Administration 4 

Transportation Deputy Secretary 1 
 

Page 9 GAO-12-792 Chief Acquisition Officers

Agency

Official title of the Chief Acquisition 

Officer 

Number of 

additional positions 

held within agency 

(excluding official 

title) 

Chief Acquisition Officer also serves as the

Chief Financial 

Officer 

Chief 

Human 

Capital 

Officer 

Chief 

Information 

Officer 

Treasury Assistant Secretary for Management, 

Chief Financial Officer and Chief 

Performance Officer

2 X 

VA Principal Executive Director, Office of 

Acquisition, Logistics and Construction

0 

Source: GAO analysis of agency information

Although acquisition management is supposed to be a CAO’s primary 

duty, several CAOs we met with told us that having responsibility for 

additional management functions was not a detriment and often helped 

them positively influence acquisition management across their agency:

• At half of the 16 agencies, the Chief Acquisition Officer also serves in 

at least one additional “Chief” officer position. Similar to the SARA 

legislation, the legislation that created the Chief Human Capital Officer 

(CHCO) and Chief Information Officer (CIO) positions required that 

those respective functions be the primary duty of each position.11 We 

have raised concerns in prior work about those positions having 

additional significant responsibilities and whether an individual serving 

in these positions can deal effectively with an agency’s management 

challenges.12

• Some CAOs and acquisition officials also pointed out that the SARA 

legislation did not provide agencies an additional position specifically 

for the CAO, which created a challenge for agencies to determine how 

to fill the CAO position. For example, the NASA CAO noted in her 

Although this could be a concern with respect to CAOs 

who do not have acquisition management as their primary duty, the 

Office of Federal Procurement Policy noted that an agency’s Senior 

Procurement Executive provides high-level attention to the 

management of the acquisition function.

 

11 Chief Human Capital Officers Act of 2002, Pub .L. No. 107-296, § 1302, 116 Stat. 2287, 

2288; Information Technology Management Reform Act of 1996, Pub. L. No. 104-106, § 

5125, 110 Stat. 679, 684. 

12 GAO, Human Capital: Observations on Agencies’ Implementation of the Chief Human 

Capital Officers Act, GAO-04-800T (Washington, D.C.: May 18, 2004); and Chief 

Information Officers: Ensuring Strong Leadership and an Effective Council, 

GAO/T-AIMD-98-22 (Washington, D.C.: Oct. 27, 1997).
 

Page 10 GAO-12-792 Chief Acquisition Officers

questionnaire response that the agency has a low allocation of 

politically appointed positions. As a result, NASA gave the CAO duties 

to the CFO. NASA’s CAO stated that because the agency spends 

such a large amount of its budget through obligations on contracts, 

her role as the CFO is closely connected with her additional role as 

the CAO to effectively conduct acquisition management at NASA. 

Furthermore, the NASA CAO thought that having these two functions 

integrated was a positive aspect of her current position and helped 

her be an effective CAO, as opposed to having acquisition operate in 

a separate stovepipe.

• The CAO at Commerce emphasized the positive aspects of the 

agency’s organizational structure and approach to implementation of 

the CAO position. At Commerce, one individual serves in a number of 

roles that includes the CFO, CHCO, and Chief Performance Officer as 

well as the CAO. The CAO noted that this structure gave him the 

ability to integrate planning, budgeting, risk management, human 

resources, as well as acquisition to achieve the agency’s mission. As 

the individual who ties these functional areas together, he indicated 

he has the authority to get other groups within Commerce to work 

together. The Commerce CAO also stated that while he oversees the 

department’s budget as the CFO, he uses his CAO role to look at 

whether components have demonstrated a sound acquisition 

management approach in evaluating their budget requests. He also 

stated that if he were only the agency CAO he would not have as 

much authority in other functional areas to effectively manage the 

agency’s acquisition function.

• Likewise, the CAO at DHS said that he has oversight of many 

different management functions such as finance, budgeting, human 

resources, as well as acquisition. While this arrangement may appear 

to be in conflict with the statutory requirement that acquisition 

management be the CAO’s primary duty, he stated that having a 

larger area of responsibility gives him a fuller view of the entire 

acquisition cycle from requirements development and contract funding 

to service delivery. As a result, he reports that he spends a majority of 

his time on acquisition management issues because integrating the 

different management functions has a positive impact on the CAO’s 

ability to effectively manage acquisitions across DHS.

While the SARA legislation does not specify where CAOs should be 

located within their agency’s organization, as shown below in figure 2, we 

found that almost all of the 16 CAOs were positioned at their agency’s top 

management levels, reporting to either to the agency head or to an official 

one level removed from the agency head. The CAO at Energy reports to 

Almost All CAOs Are 

Positioned at Top 

Management Levels
 

Page 11 GAO-12-792 Chief Acquisition Officers

the Director of the Office of Management, who is more than one level 

removed from the agency head.

Figure 2: Organizational Placement of CAOs

The location of CAOs at high levels within their agencies may be by virtue 

of their official titles described above in table 2 rather than being 

specifically related to the CAO position. Nevertheless, several CAOs and 

acquisition officials we met with stressed the value of the CAO position in 

having access to agency leadership and other peers in ensuring that 

acquisition issues are being considered at top levels within the agency.

• Fourteen CAOs reported that they had at least sufficient access to 

their agency head, and that the CAO position was appropriately 

located for ensuring proper authority over their agency’s acquisition 

activities.

• Acquisition officials at the Department of Energy, where the CAO 

position has been vacant for several years, and whose questionnaire 

response noted that the CAO had neither sufficient nor insufficient 

access to the agency head, said that it would have been helpful to 

have a political appointee in the CAO role who could have high level 

interactions with agency leadership, better communicate acquisition 

related issues, and build effective working relationships with the CFO, 

CIO, and other senior agency officials.

• Additionally, acquisition officials with the Department of the Interior 

noted that as a political appointee, the CAO can work closely with 

other assistant secretaries in the department as well as with peers at 
 

Page 12 GAO-12-792 Chief Acquisition Officers

other agencies and OMB. They added that with the CAO placed at the 

assistant secretary level, the position can be more focused on 

strategic decisions, and can make final decisions on how resources 

will be deployed to achieve goals.

• Similarly, the HHS CAO said that by virtue of her position, she is able 

to interact as a peer with the leaders of the agency’s operating 

divisions and communicate the acquisition priorities of the agency and 

administration. She added that being CAO affords her a “seat at the 

table” to discuss acquisition issues when the agency is making 

mission decisions.

Twelve of the agencies have had a CAO serving in a permanent capacity 

more than two-thirds of the time since enactment of SARA, as shown 

below in figure 3. Education and VA have had a CAO serving in a 

permanent capacity less than 50 percent of the time.

13

 

13 While VA’s current CAO is a career official serving in an acting capacity, VA has sought 

to establish an Assistant Secretary for Acquisition, Logistics, and Construction who would 

serve as CAO in accordance with the SARA legislation requirements. 

The remaining 

time the CAO position has been vacant or held by an official in an acting 

capacity.

CAO Position Usually 

Filled by Permanent 

Official, but Tenures Have 

Been Short 
 

Page 13 GAO-12-792 Chief Acquisition Officers

Figure 3: CAO Turnover and Proportion of Time CAO Position Filled by a 

Permanent Official (from SARA Enactment through April 2012)

• Despite most agencies’ ability to fill the position with a permanent 

CAO, turnover in the CAO position varied among agencies, as 

evidenced by the number of acting and permanent CAOs in place 

since SARA’s enactment. Half of the agencies have had four or fewer 

CAOs in place, while other agencies have had higher turnover in the 

CAO position. For example, GSA and Treasury have each had nine 

CAOs in place since creation of the CAO requirement. The high 

turnover at GSA and Treasury equate to an average tenure for each 

CAO of about 10 months at GSA and about 11 months at Treasury 

since late 2003. In contrast, Commerce and HHS have had only two 

CAOs over the same timeframe, with an average CAO tenure at each 

agency of more than 3.5 years.
 

Page 14 GAO-12-792 Chief Acquisition Officers

• Since enactment of SARA, the average tenure of permanent CAOs 

has been 2.1 years. This is fairly consistent with a recent GAO review 

that found an average tenure of about 2.6 years for CIOs at 30 federal 

departments and agencies.14

While short tenures in the CAO position may be expected given the 

political nature of the position, this may work against an individual CAO’s 

ability to effectively implement needed changes in the acquisition function 

or new acquisition initiatives:

• Our prior work has noted that it can take 5 to 7 years to fully 

implement major change initiatives in large public and private sector 

organizations and to transform cultures in a sustainable manner, yet 

frequent turnover of political leadership in the federal government can 

make it difficult to obtain sustained attention to make needed 

changes.15

• Among the 76 permanent and acting CAOs that have been in place 

since the enactment of SARA, only 3 served in the position for 5 years 

or more.

CAOs reported they have differing levels of involvement in the 

management of their agency’s acquisition activities. For example, most 

CAOs indicated they were extremely or very involved in managing 

acquisition policy, but only somewhat or not at all involved in making 

acquisition decisions or conducting acquisition assessments. Generally, 

CAOs saw their role as providing high-level oversight of the acquisition 

function as opposed to day-to-day management, for which they typically 

relied on the Senior Procurement Executive and other senior procurement 

officials. Many CAOs told us that the amount of their involvement is 

related to several factors, such as the nature of goods and services that 

the agency buys and the extent the agency has a centralized or 

decentralized acquisition function. For example, in some agencies, CAOs 

are less involved because agency units and bureaus operate more 

autonomously with respect to acquisition management. Our review of 

 

14 GAO, Federal Chief Information Officers: Opportunities Exist to Improve Role in 

Information Technology Management, GAO-11-634 (Washington, D.C.: Sept. 15, 2011).

15 GAO, Major Management Challenges and Program Risks: A Governmentwide 

Perspective, GAO-03-95 (Washington, D.C.: Jan. 2003); and Results-Oriented Cultures: 

Implementation Steps to Assist Mergers and Organizational Transformations, 

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

CAO Involvement in 

Acquisition 

Management 

Functions Varies
 

Page 15 GAO-12-792 Chief Acquisition Officers

acquisition regulations and policies found that the roles and 

responsibilities of the CAO position are not described in detail across all 

the 16 agencies within the scope of our review. Without clearly defined 

roles and responsibilities within each federal agency, it will be challenging 

for these agencies to more permanently institutionalize the CAO position 

within their organizational structure and realize the benefits from the 

added attention it brings to acquisition management.

The SARA legislation broadly outlined acquisition management functions 

for CAOs and left it up to each agency how to implement them. Overall, 

CAOs reported varying levels of involvement in the various acquisition 

management functions we reviewed, as shown below in figure 4:

Figure 4: Level of CAO Involvement in the Eight Acquisition Functions Outlined in SARA Legislation and OMB Guidance

• CAOs reported being most involved in managing the direction of 

acquisition policy and least involved in two activities—making 

acquisition decisions and conducting assessments of the acquisition 

function under OMB Circular A-123.

• Only three CAOs (Agriculture, Labor, and DHS) reported being 

extremely or very involved in all eight acquisition management 

functions.

CAO Involvement in SARA 

Acquisition Management 

Functions Varied with 

Most CAOs Focused on 

High-Level Acquisition 

Oversight and Policy 

Management
 

Page 16 GAO-12-792 Chief Acquisition Officers

• In contrast, officials at four agencies (Education, Energy, HUD, and 

State) who were either serving as the acting CAO, recently appointed 

as the new permanent CAO, or serving as the senior procurement 

official while the CAO position was vacant, reported being somewhat 

or not at all involved in seven or more of the acquisition management 

functions.

Many CAOs see their role as providing high-level acquisition oversight 

rather than the day-to-day acquisition management that is more typically 

provided by other career procurement officials such as the Senior 

Procurement Executive and heads of contracting activities. As shown 

below in figure 5, a majority of CAOs reported that they delegate day-today responsibility for all eight CAO acquisition management functions to 

the Senior Procurement Executive and/or other senior procurement 

officials such as heads of contracting activities and competition 

advocates. The SARA legislation does not preclude CAOs from 

delegating these functions, and it is not surprising that there is a high 

degree of delegation given that CAOs have other significant management 

responsibilities and few had extensive prior experience in acquisition 

management.
 

Page 17 GAO-12-792 Chief Acquisition Officers

Figure 5: Delegation of Responsibilities Reported by CAOs across the Eight Acquisition Management Functions Outlined in 

SARA Legislation and OMB Guidance

Several CAOs we met with stated that they delegated acquisition 

management functions to others to ensure that these duties are 

performed by highly experienced procurement officials. Additionally, they 

could focus on other acquisition issues such as program management 

and rely on the agencies’ acquisition professionals to manage the 

agency’s contract award process and acquisition workforce.

• For example, the DHS CAO reported delegating seven of the eight 

CAO acquisition management functions to the Senior Procurement 

Executive and others, and said that he must take a larger view of the 

acquisition function that includes program management while the 

Senior Procurement Executive is more focused on the contract award 

process and management of contracting officers and contracting 

specialists. 

CAOs’ delegation of their responsibilities may also be expected given the 

roles of other agency officials in acquisition management.

• The Senior Procurement Executive position had been in place at 

federal agencies for many years before the CAO position was 

established. This position is typically filled by a career employee who 

is responsible for the management direction of the agency’s 
 

Page 18 GAO-12-792 Chief Acquisition Officers

procurement system, including implementation of agency unique 

procurement policies, regulations, and standards.16

• In addition, while increasing the use of full and open competition is 

one of the CAO responsibilities outlined in SARA, each executive 

agency is also required to designate a competition advocate who is 

responsible for promoting full and open competition, among other 

things.17

• Similarly, CAOs are responsible for acquisition career management, 

but the Office of Federal Procurement Policy also requires civilian 

executive agencies to designate an acquisition career manager who is 

responsible for, among other things, managing the development and 

identification of the acquisition workforce and providing input 

regarding short term and long term human capital strategic planning 

for the acquisition workforce.18

CAOs we spoke with stated there is no “one-size fits all” solution for how 

best to structure the CAO position and integrate the acquisition 

management responsibilities outlined by SARA. Many CAOs emphasized 

that the level of acquisition management oversight they provide is based 

upon several factors, which include the nature of the goods and services 

that the agency buys and the amount of decentralization in the agency’s 

acquisition function.

• For example, the CAO at HHS said that she is very involved in 

acquisition policy issues but the oversight of day-to-day acquisition 

management issues is handled by other officials because much of 

what HHS buys through contracts is done to support their operating 

divisions rather than acquisitions of major systems.

• The CAOs at both HHS and Interior reported that their agencies have 

a decentralized acquisition management structure where heads of 

operating divisions and bureaus execute most acquisition authority 

within their two agencies. HHS also stated that although the CAO 

does not approve acquisition decisions, acquisition management is 

achieved through the CAO’s roles in financial management, 

 

16 41 U.S.C. § 1702(c). 

17 41 U.S.C. § 1705 and Federal Acquisition Regulation §§ 6.501and 6.502.

18 Office of Federal Procurement Policy, Developing and Managing the Acquisition 

Workforce (Washington, D.C.: Apr. 15, 2005). 

CAO Involvement in 

Acquisition Management 

May Vary Due to Agency 

Characteristics and Other 

Attributes 
 

Page 19 GAO-12-792 Chief Acquisition Officers

performance measurement, and acquisition and grants policy and 

accountability.

In comparison, several CAOs at other agencies play a greater role in the 

acquisition process. These agencies also tended to have major 

acquisition programs and projects.

• The CAO at DHS reported having approval authority for individual 

acquisitions and since assuming the position in 2010 has revised the 

acquisition oversight structure. The CAO stated that these changes in 

the oversight structure at DHS are intended to decrease acquisition 

program risk and provide better insight into budget, schedule and 

performance information for approximately 135 major acquisition 

programs for which the CAO serves as the Acquisition Decision 

Authority.

• CAOs at other agencies who said they are more involved in 

acquisition management also reported having some form of decision 

authority over certain acquisitions. For example, the CAO at 

Commerce serves as co-chair of the agency’s Investment Reviews, 

which provide oversight, review, and advice to the Secretary and 

Deputy Secretary on both information technology (IT) and non-IT 

investments that meet certain criteria. This advice includes 

recommendations for approval or disapproval of funding for new 

systems and investments, or major modifications to existing systems 

or investments.

• Similarly, at the Department of Labor, a Procurement Review Board 

recommends to the CAO approval or disapproval of various 

acquisition decisions that meet certain thresholds or conditions and 

serves as a senior-level clearinghouse to review proposed 

noncompetitive acquisitions.

At many agencies, the CAO position was not clearly defined in 

documents that would form the basis for more permanently 

institutionalizing the CAO within their organizational leadership structure. 

Clearly defined roles and responsibilities for each stakeholder in the 

acquisition process is a key element of an effective acquisition function, 

as outlined in GAO’s framework for assessing the acquisition function 

within federal agencies.19

 

19

We found that the amount of detail on a CAO’s 

agency-specific authorities and responsibilities varies greatly based on 

GAO-05-218G. 

CAO Roles and 

Responsibilities Not 

Clearly Defined at Many 

Agencies
 

Page 20 GAO-12-792 Chief Acquisition Officers

the agency’s Federal Acquisition Regulation (FAR) supplement and other 

policy documentation we collected. As shown in table 3, at some 

agencies, the CAO position is described in detail while for others the only 

information about the CAO’s authorities and acquisition management 

responsibilities under SARA is a passing reference to the legislation that 

established the position.

Table 3: Summary of Observations on CAO Position in Agency Acquisition 

Regulations and Policies 

Agency

Defined in agency 

FAR supplements 

or acquisition 

manual

Some or all statutory 

responsibilities are 

listed in policy 

documentation

Neither defined nor 

statutory 

responsibilities listed 

in policy documents

Agriculture X 

Commerce X 

DHS X 

Education X X 

Energy X 

EPA X 

GSA X 

HHS X 

HUD X 

Interior X 

Labor X X 

NASA X 

State X 

Transportation X 

Treasury X 

VA X X 

Totals 6 6 7

Source: GAO analysis of agency acquisition regulations and other policy documentation.

• For example, the CAO position is defined or designated in FAR 

supplements or acquisition manuals by just 6 of the agencies.

• Detail on the CAO’s specific acquisition management responsibilities 

was listed in other policy documentation for only 6 of the agencies.

• At 7 agencies, the CAO position is not defined in their FAR 

Supplement or acquisition manual, nor are the acquisition 

management responsibilities listed in other policy documentation.
 

Page 21 GAO-12-792 Chief Acquisition Officers

Additionally, we found that agencies varied in how their acquisition policy 

guidance delegates authority for procurement matters with respect to the 

CAO. At half of the agencies, authority for procurement matters is 

delegated from the agency head through the CAO position to other 

agency officials. In contrast, at the other 8 agencies, this authority is 

delegated from the agency head directly to other agency officials such as 

the Senior Procurement Executive and/or bureau heads, bypassing the 

CAO. This may be due to agencies neglecting to update their acquisition 

policies and regulations since creation of the CAO position or to reflect a 

more recent organizational change.

• For example, the GSA Organizational Manual still refers to an Office 

of the CAO that reports to the Administrator, which, according to the 

CAO in place during our review, did not reflect the organizational 

reporting structure in the agency.

This lack of fully defined CAO roles and responsibilities, and at some 

agencies, outdated policies, may be an obstacle to ensuring that the CAO 

position is more permanently institutionalized within the agencies’ 

acquisition management and senior leadership structures.

CAOs at the 16 agencies generally did not report facing significant 

challenges related to the CAO position, such as the level of influence they 

have in their agency’s acquisition process, amount of control over 

acquisition budget resources, and access to agency leadership. However, 

most CAOs reported that not having enough staff to manage acquisitions 

was moderately to extremely challenging. As GAO and others have 

reported in recent years, the capacity and capability of the federal 

government’s acquisition workforce to oversee and manage contracts has 

been a challenge. Most CAOs did not believe any changes were needed 

to improve their effectiveness and also felt that they had the appropriate 

degree of authority to effectively fulfill their acquisition management 

functions.

We asked agency CAOs to indicate how much six management and 

resource issues that we identified challenged them in carrying out their 

responsibilities. As shown below in figure 6, CAOs generally answered 

that most areas we identified were not challenges for them.

CAOs Reported Few 

Significant Challenges 

and Generally Did Not 

Identify Changes 

Needed to Improve 

Their Effectiveness

Aside from the Sufficiency 

of Acquisition Staff, CAOs 

Reported Few Significant 

Challenges
 

Page 22 GAO-12-792 Chief Acquisition Officers

Figure 6: Extent of Challenge Reported by CAOs in Fulfilling Their Acquisition Management Responsibilities

Note: Responses in some challenge areas do not sum to 16 because “Not Applicable” or “Don’t 

Know” responses are not included.

• No CAOs reported being very or extremely challenged by their 

employment status (career official versus political appointee) in 

fulfilling their acquisition management functions or in having sufficient 

access to agency leadership.

• The CAOs at DHS, HHS, and State reported five of these areas as 

being not at all challenging. In contrast, the CAO at GSA and the 

career acquisition official at Energy reported being moderately to 

extremely challenged in most of the areas.

Despite the lack of challenges reported by CAOs related to most areas, 

11 CAOs reported the sufficiency of staff to manage acquisitions as a 

moderate to extreme challenge. These responses echo concerns from 

our prior work that the capacity and the capability of the federal 

government’s acquisition workforce to oversee and manage contracts 

have not kept pace with increased spending for increasingly complex 

purchases. Additionally, 6 of the 16 agencies’ IGs have identified the 

acquisition workforce as a source of serious management challenge in 

their most recent management challenge reports issued during 2011. 

However, none of the CAOs at these 6 agencies reported the sufficiency 

of acquisition staff as extremely or very challenging.

When asked if any other changes were needed to improve their 

effectiveness, 10 out of 16 CAOs reported that no changes were needed.

Six CAOs did provide some suggestions. For example, Energy’s 

response to our questionnaire stated that the CAO position needs 

Majority of CAOs Said No 

Additional Changes 

Needed to Improve Their 

Effectiveness
 

Page 23 GAO-12-792 Chief Acquisition Officers

improved resource support and full engagement with the agency’s senior 

leadership team. At EPA, the CAO responded that it would be helpful if 

there were a better understanding of the contracting process by agency 

management. The GSA CAO, who left the position during our review, 

believed that returning the CAO position to a direct report to the GSA 

Administrator would improve the position’s effectiveness at her agency. 

Following the completion of our CAO questionnaire, GSA appointed an 

Acting CAO who reports to the Acting GSA Administrator. CAOs at 

Transportation, Interior, and HUD reported that more budgetary resources 

and acquisition workforce staff are needed to improve their effectiveness. 

Despite these responses and other issues raised in our report, almost all 

the CAOs believed that they had the appropriate authority to fulfill their 

acquisition management responsibilities.

More than 8 years after the enactment of the SARA legislation, there is 

wide variation in how agencies have implemented the CAO position. On 

one hand, agencies have generally filled the CAO position with political 

appointees who sit at relatively high levels within their agencies in a 

position to ensure that acquisition is receiving attention from agency 

leadership. Many CAOs and acquisition officials we met with cited this as 

a key benefit of the CAO position. On the other hand, there are 

inconsistencies in the implementation of the law across agencies, with 

very few CAOs having acquisition management as their primary 

responsibility, although many CAOs cited the benefits to integrating 

acquisition management with their additional responsibilities. The CAO 

position is only one factor of many in an efficient, effective, and 

accountable acquisition function in agencies. Having an experienced 

Senior Procurement Executive is another. There is no one-size-fits-all 

approach to how to organize an effective acquisition function, and a 

CAO’s role should be suited to the nature and volume of an agency’s 

acquisition activities. Yet, agencies should ensure that they are 

maximizing their chances for success by having CAOs that are in a 

position to influence agency leadership and serve as a strong advocate 

for acquisition management, which includes having clearly defined roles 

and responsibilities for the CAO. Not all agencies have these, however, 

and may be missing an opportunity to ensure that the CAO position is 

fully institutionalized within agencies’ acquisition management and senior 

leadership structures. Given CAOs’ short tenures, a lack of defined roles 

and responsibilities could hinder a CAO’s ability to maximize time in the 

position and serve as an effective advocate for acquisition management.

Conclusions 
 

Page 24 GAO-12-792 Chief Acquisition Officers

To strengthen the functions of CAOs in acquisition management, we 

recommend that the Administrator of the Office of Federal Procurement 

Policy, working with the CAO Council, issue guidance to agencies 

directing them to ensure that CAO roles and responsibilities are more 

clearly defined in accordance with law and regulations, tailored to suit the 

agency’s acquisition activities, and documented as appropriate.

We sent copies of a draft of this report to OMB and the 16 agencies within 

the scope of our review. OMB’s Office of Federal Procurement Policy 

provided comments via e-mail, in which it concurred with our 

recommendation. The office also suggested that the report further 

highlight the role of the Senior Procurement Executive in providing day-today leadership of an agency’s acquisition function. We considered this 

suggestion and made changes to the report as appropriate.

We received communications from each of the 16 agencies, with 15 

providing no substantive comments. HHS provided additional information 

on the roles and responsibilities of the CAO, which we incorporated into 

the draft. HHS’s written comments are reproduced in appendix III. 

We are sending copies of this report to other interested congressional 

committees, the Director of the Office of Management and Budget, and 

the Secretaries of Agriculture, Commerce, Education, Energy, Health and 

Human Services, Homeland Security, Housing and Urban Development, 

the Interior, Labor, State, Transportation, the Treasury, and Veterans 

Affairs; the administrators of the Environmental Protection Agency and 

the National Aeronautics and Space Administration, and the Acting 

Administrator of General Services. In addition, this report will be available 

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

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 25 GAO-12-792 Chief Acquisition Officers

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

contact me at (202) 512-4841 or by e-mail at woodsw@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs are on 

the last page of this report. Key contributors to this report are listed in 

appendix IV.

William T. Woods

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

Methodology

Page 26 GAO-12-792 Chief Acquisition Officers

Our objectives were to assess: (1) how agencies have filled the Chief 

Acquisition Officer (CAO) position; (2) the extent to which CAOs are 

involved in performing the acquisition management functions set forth in 

the Services Acquisition Reform Act of 2003 (SARA) legislation and 

Office of Management and Budget (OMB) guidance, and (3) what 

challenges, if any, agency CAOs report in fulfilling their responsibilities for 

acquisition management. Our review did not assess the effectiveness of 

individual CAOs or individual agencies’ acquisition functions.

To address our objectives, we reviewed the SARA legislation and 

directives from OMB’s Office of Federal Procurement Policy to identify the 

key roles and responsibilities of the CAO position. We also reviewed 

previous GAO work on assessing the acquisition function and the 

implementation of other chief officer positions in the federal government. 

To learn more about CAOs’ characteristics, as well as CAOs’ involvement 

in acquisition management functions and challenges faced in fulfilling 

their responsibilities, we developed and administered a questionnaire by 

e-mail in an attached Microsoft Word form to the 16 civilian agencies1

within the scope of our review.2

 

1 We sent the questionnaire to the Departments of Agriculture, Commerce, Education, 

Energy, Health and Human Services, Homeland Security, Housing and Urban 

Development, the Interior, Labor, State, Transportation, the Treasury, Veterans Affairs, 

the Environmental Protection Agency, the National Aeronautics and Space Administration, 

and the General Services Administration (GSA). 

We pretested the questionnaire to ensure 

that the questions were relevant, clearly stated, and easy to understand. 

We also solicited comments on the draft questionnaire from members of 

the Chief Acquisition Officers Council. The questionnaire requested 

information on, among other things, the CAOs’ reporting relationships, 

involvement in acquisition management functions within the agency, the 

2 SARA required executive agencies described in certain sections of the Chief Financial 

Officers Act of 1990, Pub. L. No. 101-576 (see, 31 U.S.C. §§ 901(b)(1) and 901(b)(2)(C) 

(CFO Act)), to appoint a CAO. When SARA was enacted in 2003, the U.S. Code listed 

GSA under 31 U.S.C. § 901(b)(2)(C). In 2004, the Department of Homeland Security 

Financial Accountability Act, Pub. L. No. 108-330, § 3, amended the CFO Act to make a 

number of changes, including adding the Department of Homeland Security to the list of 

agencies required to have a CFO and changing GSA’s position on the CFO list. For the 

purposes of this report, we included GSA in our review, as it was listed in section 

901(b)(2)(C) of title 31 of the U.S. Code when SARA was enacted. The SARA legislation 

exempts the Department of Defense (DOD) from the CAO requirement. Legislation 

enacted prior to SARA required DOD to have an Under Secretary of Defense (Acquisition, 

Technology & Logistics) who has responsibilities similar to those of a CAO. Justice is not 

required to appoint a CAO under the SARA legislation, but has designated the Assistant 

Attorney General for Administration as the CAO. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-12-792 Chief Acquisition Officers

extent to which the CAO had delegated their acquisition management 

responsibilities to other officials, and challenges identified by GAO that 

CAOs may have experienced in fulfilling their responsibilities. We sent the 

questionnaire to agencies in November 2011. All questionnaires were 

returned by March 2012. We received responses from all 16 agencies, 

though not all agencies provided responses to each question.

To provide additional information on CAOs’ characteristics, involvement in 

acquisition management functions and challenges faced, as well as to 

corroborate information provided in the questionnaire responses, we 

collected and reviewed agencies’ organizational charts that showed the 

CAO’s position relative to the head of the agency and other senior 

officials; letters of delegation or other documents that formally designate 

the appointment of the CAO, the CAO’s resume or curriculum vitae 

describing their qualifications and experience related to the CAO position; 

applicable policies, guidance, position descriptions or functional 

statements for both the CAO and Senior Procurement Executive 

positions; applicable policies or orders that delegate the CAO’s 

responsibilities to other acquisition officials; agency acquisition function 

assessments performed under OMB Circular A-123; Acquisition Human 

Capital Plans or similar documents; agency strategic plans and 

performance reports; agency-specific acquisition regulations and 

acquisition manuals; and descriptions of acquisition metrics or 

performance measures the agency tracks. We also asked each agency to 

supply the name, time in office, and circumstances (whether they were in 

an acting or permanent position and whether they were a career 

employee or political appointee) of each of the individuals who had 

served as agency CAO and Senior Procurement Executive since 

enactment of the SARA legislation in November 2003.

To complement information gathered through the questionnaire and 

agency documentation, we conducted follow-up interviews to discuss the 

CAO’s roles and responsibilities with CAOs and acquisition officials at 

seven agencies: Commerce, Department of Homeland Security (DHS), 

Department of Health and Human Services (HHS), Interior, Energy, GSA, 

and the National Aeronautics and Space Administration (NASA). We used 

a nongeneralizable sample of agencies based upon the following criteria: 

review of the questionnaire responses, the amount of procurement 

spending as a portion of the agency’s fiscal year 2010 budget, and 

whether the agency’s Inspector General had identified acquisition-related 

issues as a major management challenge. We also met with officials from 

OMB’s Office of Federal Procurement Policy to discuss the roles and 

responsibilities of agency CAOs.
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-12-792 Chief Acquisition Officers

We conducted this performance audit from October 2011 to July 2012 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.
Appendix II: Key Responsibilities of CAOs

Page 29 GAO-12-792 Chief Acquisition Officers

CAO responsibility Source Description

Monitoring and evaluating 

agency acquisition 

activities

SARA legislation Monitoring the performance of acquisition activities and acquisition 

programs of the executive agency, evaluating the performance of those 

programs on the basis of applicable performance measurements, and 

advising the head of the executive agency regarding the appropriate 

business strategy to achieve the mission of the executive agency

Increasing the use of full 

and open competition

SARA legislation Increasing the use of full and open competition in the acquisition of 

property and services by the executive agency by establishing policies, 

procedures, and practices that ensure that the executive agency receives a 

sufficient number of sealed bids or competitive proposals from responsible 

sources to fulfill the Government’s requirements at the lowest cost or best 

value considering the nature of the property or service procured.

Increasing performancebased contractingSARA legislation Increasing appropriate use of performance-based contracting and 

performance specifications

Making acquisition 

decisions 

SARA legislation Making acquisition decisions consistent with all applicable laws and 

establishing clear lines of authority, accountability, and responsibility for 

acquisition decision-making within the executive agency

Managing agency 

acquisition policy

SARA legislation Managing the direction of acquisition policy for the executive agency, 

including implementation of the unique acquisition policies, regulations, 

and standards of the executive agency

Acquisition career 

management

SARA legislation Developing and maintaining an acquisition career management program in 

the executive agency to ensure that there is an adequate professional 

workforce 

Acquisition resources 

planning

SARA legislation As part of the strategic planning and performance evaluation process, 

assessing the requirements established for agency personnel regarding 

knowledge and skill in acquisition resources management and the 

adequacy of such requirements for facilitating the achievement of the 

performance goals established for acquisition management; developing 

strategies and specific plans for hiring, training and professional 

development to rectify any deficiency in meeting such requirements; and 

reporting to the head of the executive agency on the progress made in 

improving acquisition management capability.

Conducting acquisition 

assessments under OMB 

A-123

OMB Memorandum for Chief 

Acquisition Officers, May 21, 

2008, Conducting Acquisition 

Assessments under OMB 

Circular A-123, Guidelines 

for Assessing the Acquisition 

Function

Conducting entity-level internal control reviews of the acquisition function 

under OMB Circular A-123

Source: GAO analysis of SARA legislation and OMB memorandum. 

Appendix II: Key Responsibilities of CAOs
Appendix III: Comments from the Department 

of Health and Human Services

Page 30 GAO-12-792 Chief Acquisition Officers

Appendix III: Comments from the 

Department of Health and Human Services
Appendix III: Comments from the Department 

of Health and Human Services

Page 31 GAO-12-792 Chief Acquisition Officers
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 32 GAO-12-792 Chief Acquisition Officers

William T. Woods, (202) 512-4841 or woodsw@gao.gov

In addition to the contact named above, John Oppenheim (Assistant 

Director); Matthew Drerup; Kristine Hassinger; Lauren Heft; Jean 

McSween; Roxanna Sun; and Robert Swierczek made key contributions 

to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(121013)
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