ARLINGTON 

NATIONAL 

CEMETERY

Additional Actions 

Needed to Continue 

Improvements in 

Contract Management

Report to Congressional Committees

December 2011

GAO-12-99

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-99, a report to 

congressional committees

December 2011

ARLINGTON NATIONAL CEMETERY 

Additional Actions Needed to Continue 

Improvements in Contract Management 

Why GAO Did This Study

Arlington National Cemetery (Arlington) 

contains the remains of more than 

330,000 military servicemen and 

women, family members, and others. 

In June 2010, the Army Inspector 

General issued a report identifying 

numerous deficiencies at Arlington, 

including those related to contracting. 

In response, the Secretary of the Army 

issued guidance creating the position 

of the Executive Director of the Army 

National Cemeteries Program (ANCP) 

to manage Arlington and requiring

changes to address the deficiencies 

and improve cemetery operations.

Public Law 111-339 directed GAO to 

(1) identify the number, duration of, 

and dollar amount spent on current 

contracts used to support operations at 

Arlington and (2) assess the extent to 

which the Army has put processes and 

procedures in place to provide for the 

effective management and oversight of 

contracts supporting Arlington. GAO 

analyzed data from contracting offices 

and other sources on contracts active 

during fiscal year 2010 and 2011 and

above $100,000 and reviewed contract 

files; analyzed guidance, policies, 

plans and other documentation from 

Arlington and other organizations; and 

interviewed agency officials. 

What GAO Recommends

GAO recommends that the Army 

implement a method to track complete 

contract data, ensure support 

agreements clearly identify roles and 

responsibilities for contracting, and 

determine the number and skills 

necessary for contracting staff. DOD

partially concurred with the 

recommendations, but said the report

did not adequately reflect Army-wide 

efforts underway. 

What GAO Found

Roughly $35 million was obligated under 56 Arlington contracts and task orders 

valued over $100,000 and active during fiscal years 2010 and 2011. These 

contracts supported cemetery operations, construction and facility maintenance, 

and new efforts to enhance information technology systems for the automation of 

burial operations. ANCP does not award its own contracts, but instead obtains 

contracting support in two different ways. Thirty-five contracts in GAO’s review 

were awarded by three contracting organizations that directly supported ANCP. 

For the remaining 21 contracts and task orders, ANCP partnered with other Army 

organizations with expertise in areas such as information technology and 

construction. Those organizations, in turn, used contracting offices to support 

Arlington needs. Many of the contracts GAO reviewed have now ended, while 

those still ongoing may continue through fiscal years 2012-2014, depending on 

ANCP needs. While ANCP has taken steps to improve visibility of contracts and 

financial management capabilities more broadly, it does not currently maintain 

complete data to identify and track contracts supporting its operations. Without 

such data, ANCP may continue to face difficulties in ensuring the effective 

management and oversight of its contracts and related funding. 

ANCP has taken numerous actions to correct identified contracting deficiencies

and improve contract management at multiple levels, including coordination with 

other Army organizations for specialized assistance and manpower. ANCP

signed new agreements with the Army Contracting Command and the Army 

Corps of Engineers that identify broad responsibilities between these

organizations for providing contract support. However, similar agreements in 

place with other organizations, such as the Army Information Technology Agency

and the Army Analytics Group, do not specifically address contract management 

roles and responsibilities in support of Arlington’s information technology efforts. 

Although these responsibilities are generally understood by officials at present, 

they may be less clearly understood in the future when personnel have changed. 

ANCP has also taken steps to improve internal guidance for contract 

management and staff training, although these efforts are ongoing. Likewise, 

ANCP has increased dedicated acquisition staff support for its contracting efforts, 

but has not yet fully determined the appropriate number, skill levels, and 

arrangements necessary to meet its contracting needs. Newer contracts 

supporting Arlington show improvement in the use of sound acquisition practices, 

with steps taken to consolidate requirements and better document acquisition 

planning, award, and oversight activities. The success of ANCP’s acquisition 

outcomes will depend on continued management focus from ANCP and its 

contracting partners to leverage their expertise while mitigating associated risks. 

While the Army has made significant progress, further actions are necessary to 

ensure sustained attention to contract management, and institutionalize progress 

made to date, particularly as the current spotlight fades.

View GAO-12-99. For more information, 

contact Belva M. Martin at (202) 512-4841 or 

martinb@gao.gov.
Page i GAO-12-99 Arlington National Cemetery

Letter 1 

Background 3

Arlington Relies on Contracting Support but Does Not Maintain 

Complete Data to Track Existing Contracts 6

Management of Arlington Contracts Improved, but Contracting 

Support Responsibilities and Staffing Arrangements Not Yet 

Fully Defined 16

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 27

Appendix I Objectives, Scope, and Methodology 30

Appendix II Comments from the Department of Defense 33

Appendix III GAO Contact and Staff Acknowledgments 36

Table

Table 1: Current Army National Cemeteries Program Contracting 

Support Positions 21

Figures

Figure 1: Summary of Arlington Reviews and Identified Contracting 

Issues 5

Figure 2: Arlington Contract Obligations by Category 8

Figure 3: Distribution of Arlington Contracts by Office 9

Contents
Page ii GAO-12-99 Arlington National Cemetery

Abbreviations

ANCP Army National Cemeteries Program

BOSS Burial Operations Support System 

DOD Department of Defense

FPDS-NG Federal Procurement Data System-Next Generation

GFEBS General Fund Enterprise Business System

GIS Geographic Information System

IG Inspector General

ITA Information Technology Agency

MICC Mission and Installation Contracting Command

NCR National Capital Region

USACE U.S. Army Corps of Engineers

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 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-12-99 Arlington National Cemetery

United States Government Accountability Office

Washington, DC 20548

December 15, 2011

Congressional Committees

The Army’s management of Arlington National Cemetery (Arlington) has

come under scrutiny following the discovery of burial errors and the 

identification of serious management deficiencies affecting cemetery 

operations. Established during the Civil War, the cemetery contains the 

remains of more than 330,000 military servicemen and women, family 

members, and other individuals, including two U.S. Presidents. It 

conducts an average of 27 funerals each day, hosts numerous 

ceremonies throughout the year, and has approximately 4 million visitors 

annually. In response to reports in 2009 alleging mismanagement at 

Arlington, the Secretary of the Army directed the Army Inspector General 

(IG) to review Arlington’s management and operations. In June 2010, the 

Army IG reported on numerous deficiencies and made more than 100 

recommendations for corrective action, which covered a span of issues 

including cemetery policies and procedures, management and training, 

command structures, information assurance compliance, and 

contracting.1

Concerns with contract management are not unique to Arlington. We 

have previously reported on numerous issues in this area throughout the 

Department of Defense (DOD). Defense contract management continues 

to be on our high-risk list, where we have noted that the lack of welldefined requirements, the use of ill-suited business arrangements, and 

the lack of an adequate number of trained acquisition and contract 

At the same time, the Secretary of the Army assigned new 

leadership for Arlington and issued Army Directive 2010-04, Enhancing 

the Operations and Oversight of the Army National Cemeteries Program, 

requiring a number of changes to address the identified deficiencies and 

improve cemetery operations. Included in these changes was the creation 

of the new position of Executive Director of the Army National Cemeteries 

Program (ANCP), who reports directly to the Secretary of the Army and is 

responsible for overseeing operations at Arlington and the Soldiers’ and 

Airmen’s Home National Cemetery.

 

1

U.S. Army Inspector General Agency, Special Inspection of Arlington National Cemetery 

Final Report (Washington D.C.: June 2010).

 
Page 2 GAO-12-99 Arlington National Cemetery

oversight personnel contribute to unmet expectations and place the 

department at risk for paying more than is necessary.2

In December 2010, Congress passed Public Law 111-339 requiring 

several reports on the management of Arlington including by the 

Secretary of the Army on the execution of and compliance with Army 

Directive 2010-04 and other related matters beginning in 2011. The act 

also directed GAO to assess the management and oversight of contracts 

at Arlington, as well as a number of other issues related to management 

at the cemetery more generally. This report addresses issues specifically 

associated with contracting; we are reporting separately on the Army’s 

efforts to address identified management deficiencies; the information 

and assistance provided to families regarding efforts to detect and correct 

burial errors; and factors that may affect the feasibility or advisability of 

transferring jurisdiction of Arlington to the Department of Veterans 

Affairs.3

We defined current contracts as those contracts or task orders that were 

newly awarded or modified during fiscal year 2010 and the first three 

quarters of fiscal year 2011 with planned or total obligations above 

$100,000. To identify such contracts, we gathered and analyzed data 

from the contracting offices and other Army organizations currently 

providing assistance to Arlington. To assess the reliability of the data 

provided by the contracting offices, we compared their data to that 

(1) included in Federal Procurement Data System-Next Generation 

(FPDS-NG), (2) provided by officials at ANCP, and (3) gathered by the 

Deputy Assistant Secretary of the Army (Procurement) as well as the 

Army Audit Agency. While we found some information from the 

contracting offices to be incomplete, we used these other data sources to 

To satisfy the mandate as it relates to contracting, we 

(1) identified the number, duration of, and dollar amount spent on current 

contracts and task orders used to support operations at Arlington, 

including those used to support information technology systems for the 

automation of burial operations; and (2) assessed the extent to which the 

Army has put processes and procedures in place to provide for the 

effective management and oversight of contracts supporting Arlington.

 

2

GAO, High-Risk Series: An Update, GAO-11-278 (Washington D.C.: Feb. 16, 2011).

3

GAO, Arlington National Cemetery: Management Improvements Made, but a Strategy is 

Needed to Address Remaining Challenges, GAO-12-105 (Washington D.C.: Dec. 15, 

2011). 
 

Page 3 GAO-12-99 Arlington National Cemetery

identify additional Arlington contracts that met our criteria. To report on 

the duration of contracts we identified, we used contract documents and 

information from agency officials to determine the period of performance 

associated with the contract or task order. To report dollars obligated 

during fiscal year 2010 and the first three quarters of fiscal year 2011 

under the contracts we identified, we relied on data from the FPDS-NG 

and compared these to data provided by the contracting offices. Because 

we were able to use the additional data sources indicated above to 

identify contracts supporting Arlington and associated obligations, we 

consider the data to be sufficiently reliable for our purposes.

To assess the processes and procedures in place to provide for the 

effective management and oversight of contracts and to address prior 

recommendations from the Army IG, we obtained and analyzed guidance, 

policies, and other documentation from officials at ANCP, contracting 

offices, and other Army organizations. To assess the implementation of 

Army Directive 2010-04 specific to contracting, we reviewed the 

procurement management reports compiled by and interviewed officials 

from the Deputy Assistant Secretary of the Army (Procurement). We 

reviewed file documentation for all of the contracts identified as part of our 

first objective to assess the effectiveness of management and oversight 

of individual contracts and task orders. We interviewed officials from 

ANCP and Arlington, other Army organizations, and the Department of 

Veterans Affairs National Cemetery Administration. A more detailed 

description of our scope and methodology is included in appendix I.

We conducted this performance audit from March 2011 through 

December 2011 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.

Arlington does not have its own contracting authority, and as such, relies 

on other contracting offices within the Army to award and manage 

contracts on its behalf. The acquisition life cycle has multiple phases and, 

in general, responsibilities for ensuring successful outcomes are shared 

between both program offices, like Arlington, and the contracting offices 

that provide support. The phases and responsibilities include:

Background 
Page 4 GAO-12-99 Arlington National Cemetery

• Acquisition initiation—the program office identifies its needs, and 

works jointly with the contracting office to define requirements and 

plan for the acquisition.

• Contract award—the contracting office, with assistance from the 

program office, puts the business arrangement in place through the 

award of the appropriate type of contract to meet the need.

• Manage and assess contractor performance—the program and 

contracting offices work together to ensure receipt of goods and 

management of contractors providing services consistent with the 

terms of the contract, with the program office generally responsible for 

providing oversight.

At the time the Army IG issued its June 2010 report, Arlington relied 

primarily on support from both the Army Contracting Command’s 

Contracting Center of Excellence4

 

4

The Contracting Center of Excellence has been incorporated into the Army Contracting 

Command-National Capital Region Contracting Center. 

and the U.S. Army Corps of Engineers 

(USACE). The Army IG found that procurements were not in compliance 

with applicable federal, defense, and Army acquisition regulations, and 

indicated that some procurements were not aligned with each 

organization’s core competency. For example, the Army IG reported that 

Arlington officials with little to no experience or training in acquisition 

spent over $5.5 million in mostly failed efforts to develop and acquire 

information technology systems, including the Total Cemetery 

Management System, intended to modernize Arlington’s business 

operations. At the same time, those contracting offices supporting 

Arlington also did not adhere to existing acquisition regulations, 

contributing to poor acquisition outcomes, according to the Army IG 

report. As part of the initial steps to address contracting deficiencies and 

implement Army Directive 2010-04, the Secretary of the Army required 

that other Army organizations conduct additional reviews of Arlington 

contracts. Figure 1 below summarizes the scope and findings related to 

contracting of the reviews conducted to date.
Page 5 GAO-12-99 Arlington National Cemetery

Figure 1: Summary of Arlington Reviews and Identified Contracting Issues

a

The Army Inspector General also completed an interim review of Arlington’s progress in January 

2011.

These reviews have all resulted in a number of recommendations to 

ANCP and the contracting offices providing support. For example, the 
Page 6 GAO-12-99 Arlington National Cemetery

Army IG recommended that contracting offices ensure that appropriate 

oversight mechanisms were in place; that contracting officers receive 

sufficient training, and that the Army conduct additional reviews of 

Arlington contracts. The Deputy Assistant Secretary of the Army 

(Procurement) recommended that Arlington and the contracting offices 

establish or update standard operating procedures and support 

agreements for contracting, ensure that contract files fully document the 

decisions made throughout the contract award process, and provide 

training for staff on contract award and oversight procedures. The Army 

Audit Agency recommended that USACE strengthen requirements for 

independent government cost estimates, and establish performance 

standards for contracting support personnel that address contract quality 

and compliance with regulations and sound business principles. In 

response to the requirements contained in Public Law 111-339, the 

Secretary of the Army provided a report to Congress on implementation 

of Army Directive 2010-04 on September 18, 2011. That report was 

based substantially on the September 2011 Army IG report.5 Both of 

those reports identified significant progress made at Arlington overall and 

with regard to previous deficiencies related to contract management, with 

additional recommendations focused on the continuation of efforts 

currently underway.

Contracting offices obligated roughly $35.2 million under 56 contracts and 

task orders for Arlington that were active in fiscal years 2010-2011 and 

that supported cemetery operations, construction and facility 

maintenance, and new efforts to enhance information technology systems 

for the automation of burial operations. ANCP obtains contracting support 

in different ways. Thirty-five of those contracts were awarded by three 

contracting organizations that worked directly with ANCP. For the 

remaining 21 contracts and task orders, ANCP partnered with other Army 

organizations with expertise in areas such as information technology and 

construction. Those organizations, in turn, used contracting offices to 

support Arlington needs. More than half of the contracts and task orders 

we reviewed are now over, while those that remain may continue through 

fiscal years 2012-2014, depending on cemetery needs. ANCP has also 

developed new support relationships to address previous contracting 

 

5

U.S. Army Inspector General Agency, Inspection of the Army National Cemeteries 

Program and Arlington National Cemetery (Washington, D.C.: September 2011). 

Arlington Relies on 

Contracting Support 

but Does Not 

Maintain Complete 

Data to Track Existing 

Contracts 
Page 7 GAO-12-99 Arlington National Cemetery

concerns. While ANCP has taken steps to improve visibility of contracts 

and financial management capabilities more broadly, it does not currently 

maintain complete data to identify and track contracts supporting its 

operations. Without such data, ANCP may continue to face difficulties in 

ensuring the effective management and oversight of its contracts and 

related funding.

Using data from multiple sources, we identified 56 contracts and task 

orders for Arlington valued over $100,000 under which roughly 

$35.2 million was obligated6 during fiscal year 2010 and the first three 

quarters of fiscal year 2011 to support cemetery operations.7

 

6

By comparison, Arlington received a total of $85 million in appropriated funds for fiscal 

years 2010 and 2011 combined. Arlington receives its funding under the Cemeterial 

Expenses, Army appropriation. The funds are classified as a no-year appropriation, 

meaning that they are available for obligation for an indefinite period of time. The $35 

million obligated under the contracts and task orders we identified may include funding 

appropriated in fiscal years prior to 2010 and 2011. 

Figure 2 

indicates the types of goods and services which Arlington received during 

this timeframe under contracts we reviewed.

7

We included one purchase order valued just under $100,000 that was awarded by 

USACE in support of the Interment Management System.

ANCP Relies on Multiple 

Contracting Offices to 

Support Its Operations
Page 8 GAO-12-99 Arlington National Cemetery

Figure 2: Arlington Contract Obligations by Category

In general, ANCP obtains contracting support in two different ways. In 

some cases, ANCP acts as the primary program office, working directly 

with contracting offices to define requirements, ensure the appropriate 

contract vehicle, and provide contract oversight. In other instances, 

Arlington partners with another program office to leverage expertise and 

get help with defining requirements and providing contract oversight. 

Those program offices, in turn, use other contracting arrangements to 

obtain services and perform work for Arlington. Figure 3 below identifies 

these contracting relationships, and shows the number of contracts and 

dollars obligated by contracting office for the contracts and task orders we 

reviewed.
Page 9 GAO-12-99 Arlington National Cemetery

Figure 3: Distribution of Arlington Contracts by Office 

a

Figure represents contracts or task orders active during fiscal year 2010 and the first three quarters 

of fiscal year 2011 and above $100,000.

b

The Mission and Installation Contracting Command as well as the National Capital Region 

contracting office are part of the Army Contracting Command.

For more than half of the contracts and task orders we identified, ANCP 

served as the primary program office and worked directly with three 

contracting offices to meet cemetery needs. These 35 contracts were 

awarded by offices within the Mission and Installation Contracting 

Command (MICC), the Army Contracting Command-National Capital 

Region (NCR) contracting office, and the Naval Supply Systems 
Page 10 GAO-12-99 Arlington National Cemetery

Command Weapon Systems Support Office.8

For the remaining 21 contracts and task orders, ANCP did not work 

directly with a contracting office, but partnered with other Army program 

offices. These program offices, rather than ANCP, then worked with 

various contracting offices that awarded contracts and task orders to 

support Arlington needs. For example, USACE was responsible for 14 

contracts and task orders which mainly covered construction and 

engineering support services to maintain the existing grounds and 

buildings at Arlington and begin efforts to expand the cemetery. Of these 

14 contracts and task orders, 10 have ended; 2 provide for performance 

into fiscal year 2012; and the period of performance for the remaining 2 

was not clearly indicated in contract file documentation. The remaining 7 

contracts and task orders, described below, awarded under this approach 

were used to develop and enhance existing information technology 

capabilities.

To address contract 

management issues identified in the June 2010 Army IG report, during 

the latter part of fiscal year 2010 and beginning of fiscal year 2011, ANCP 

transitioned the contracting support mission from NCR to the MICC. 

ANCP coordinated with the MICC-Fort Belvoir contracting office to review 

and consolidate existing requirements and reduce the number of 

contracts supporting cemetery operations. As such, 23 of the contracts 

awarded by the NCR contracting office have now ended. Of the 10 

contracts awarded by the MICC-Fort Belvoir contracting office, 2 have 

ended and 8 may continue through fiscal year 2014 depending on 

cemetery needs. The MICC-Fort Myer contracting office modified an 

existing contract to support heating, ventilation, and air conditioning 

services at Arlington through fiscal year 2012. Finally, the Naval Supply 

Systems Command Weapon Systems Support office awarded a contract 

to support the scanning and digitization of Arlington burial records ending 

at the beginning of fiscal year 2012.

Officials at ANCP indicated that, in response to significant deficiencies 

related to information assurance and the acquisition of information 

technology, they decided to leverage existing Army expertise in 

information technology management, rather than attempting to develop 

such capabilities independently as was the case under the previous 

 

8

Two task orders were issued by the National Capital Region contracting office on behalf 

of the Information Technology Agency, and are not included in the 35 contracts and task 

orders discussed here.
Page 11 GAO-12-99 Arlington National Cemetery

Arlington management. ANCP is coordinating with organizations including 

the Army Information Technology Agency (ITA), the Army Analytics 

Group, and the Assistant Chief of Staff for Installation Management, on 

efforts to update their capabilities and comply with Army information 

assurance and automation standards. For example, ITA now provides 

broad program assistance to help manage Arlington’s information 

technology infrastructure. In support of Arlington requirements, ITA 

utilized four task orders under existing contracts awarded by the Defense 

Information Technology Contracting Office and NCR that provide 

information technology support services into fiscal year 2012. For 

example, the Defense Information Technology Contracting Office 

obligated funds under an existing task order supporting the ITA 

Consolidated Customer Service Center, which provides support to 

Arlington to answer, track, and document phone calls to the cemetery.

As required by Public Law 111-339, we identified current contracts 

associated with five specific information technology systems used by 

Arlington for the automation of burial operations. We found that two of 

these systems had active task orders in place; one system is in use but is 

not covered under a contract awarded on behalf of Arlington; and the final 

two systems are no longer in use. The following provides more detail on 

each system:

• Interment Scheduling System: ANCP uses this application to record, 

schedule, and coordinate interment and inurnment services in 

electronic form. The Army Communications-Electronics Command 

modified an existing task order to provide support into fiscal year 2012 

for the Army Analytics Group’s effort to provide information assurance 

for the Interment Scheduling System, and to consolidate Arlington 

burial operations data with other sources into a database called the 

Research Tool. ANCP is using the Research Tool to aid in its 

gravesite accounting responsibilities, and it integrates data from: 

(1) the Interment Scheduling System, (2) grave cards, (3) record of 

interment cards, (4) headstone images, and (5) the Department of 

Veterans Affairs Burial Operations Support System, which Arlington 

uses to order headstones and grave markers.

• Geographic Information System (GIS): The USACE Army Geospatial 

Center issued two task orders with a period of performance from fiscal 

years 2011-2012 to support operations by the Assistant Chief of Staff 

for Installation Management to help ANCP establish digital mapping 

capabilities for grave plots, grave markers, and the cemetery grounds. 

Officials anticipate that through these efforts, they will be able to fully 
Page 12 GAO-12-99 Arlington National Cemetery

assimilate GIS applications for assigning and managing gravesite 

information, including the ability for Arlington to use updated digital 

maps of the grounds and for visitors to search for grave locations 

online and at the Visitors Center and to view headstone photographs.

• Burial Operations Support System (BOSS): ANCP does not use 

contracts for BOSS. While Arlington staff use BOSS to order 

headstones and grave markers, officials from the Department of 

Veterans Affairs stated that the National Cemetery Administration 

funds all contract support related to BOSS and the purchase of 

headstones for all eligible veterans, including those buried at 

Arlington. They noted that ANCP does not reimburse the Department 

of Veterans Affairs for any costs associated with veterans’ 

headstones.

• Interment Management System and the Total Cemetery Management 

System: ANCP is no longer using these two systems, which were 

legacy systems intended to modernize business operations in effect 

prior to June 2010 under the previous Arlington administration. During 

fiscal year 2010, USACE awarded one contract to support 

maintenance of the Interment Management System, which was 

intended to carry out scheduling and data storage functions. The NCR 

contracting office also awarded one contract for information 

technology support services, to include management of the Total 

Cemetery Management System, which was intended to incorporate 

GIS capabilities and link systems for scheduling interments and 

ordering headstones. However, the period of performance for both 

contracts has ended. According to ANCP officials and evidence from 

the contract files, these two systems were never implemented and 

further development of these systems will not be pursued.

We have previously reported that the effective acquisition of services 

requires reliable data to enable informed management decisions.9

 

9

GAO, Defense Acquisitions: Tailored Approach Needed to Improve Service Acquisition 

Outcomes, 

With 

such data, organizations can be more strategic in planning and managing 

service acquisitions and ensure they have visibility into how and where 

acquisition dollars are spent. ANCP has taken steps to improve visibility 

of contracts; however, it does not currently maintain complete data on 

contracts supporting its operations. In a review of contracts supporting 

GAO-07-20 (Washington, D.C.: Nov. 9, 2006).

ANCP Does Not Currently 

Maintain Complete Data to 

Track Contracts 

Supporting Operations 
Page 13 GAO-12-99 Arlington National Cemetery

Arlington going back to 2003, the Army Audit Agency had difficulties 

identifying a comprehensive list of contracts supporting Arlington, noting 

that the multiple sources of data they used each produced unique 

contract actions not identified in other sources, which offered little 

assurance of a complete universe of contracts.10

A contract specialist detailed to ANCP in September 2010 developed and 

maintained a spreadsheet to identify and track data for specific contracts 

covering daily cemetery operations and maintenance services. Likewise, 

ANCP resource management staff maintain a separate spreadsheet that 

tracks purchase requests and some associated contracts, as well as the 

amount of funding provided to other organizations through the use of 

military interdepartmental purchase requests. Neither of these 

spreadsheets identifies the specific contracts and obligations associated 

with Arlington’s current information technology and construction 

requirements. While ANCP staff track data and information associated 

with specific construction projects underway through coordination with 

USACE, they do not track data that identify individual contracts used to 

support these projects; the ANCP staff noted that they rely on USACE to 

do so.

While we found 

information on Arlington contracts from various sources, including internal 

ANCP data, existing contract and financial systems, and the 

organizations that provide contracting support, limitations associated with 

each of these sources make identifying and tracking Arlington’s contracts 

as a whole difficult.

Existing data systems also do not readily identify all contracts for 

Arlington. FPDS-NG is the primary system used to track governmentwide 

contract data, including DOD and the Army. The Arlington funding office 

identification number, a unique code that is intended to identify 

transactions specific to Arlington, is not consistently used in this system 

and, in fact, was used for only 34 of the 56 contracts in our review. 

According to officials from the USACE Baltimore District, they do not use 

the Arlington funding office identification number when entering contract 

data because ANCP provides funds to USACE through the use of military 

interdepartmental purchase requests and the funding identification that is 

used at that point is one associated with USACE. ANCP officials noted 

 

10Army Audit Agency, Contracting Operations in Support of Arlington National Cemetery: 

U.S. Army Corps of Engineers, North Atlantic Division, Baltimore District, A-2011-0144-

ALC (Alexandria, Va.: 2011).

Internal ANCP Data

Existing Contract and Financial 

Systems
Page 14 GAO-12-99 Arlington National Cemetery

that they do not have control over this data entry process and that it may 

need to be addressed through broader policy guidelines.11

In October 2010 and consistent with a broader Army initiative, ANCP 

implemented the General Fund Enterprise Business System (GFEBS)

In addition, in 

our review of the task orders supporting ITA efforts, we were unable to 

identify the specific scope of work undertaken directly for Arlington and 

the funds obligated for these task orders based either on data from 

FPDS-NG, or based on contract documents, given that the task orders 

also include work performed for other organizations. At the time of our 

review, officials at ANCP and at the MICC-Fort Belvoir stated that they 

were exploring the use of additional data resources to assist in tracking 

Arlington contracts, including the Virtual Contracting Enterprise, an 

electronic tool intended to help enable visibility and analysis of elements 

of the contracting process.

12

We also found that Army contracting offices had difficulty in readily 

providing complete and accurate data to us on Arlington contracts. For 

example, the NCR contracting office could not provide a complete list of 

active contracts supporting Arlington during fiscal years 2010 and 2011 

and in some cases did not provide accurate dollar amounts associated 

with the contracts they did identify. In one case, data from NCR indicated 

that about $8.5 million had been obligated against a contract for 

landscaping services, whereas contract documents and FPDS-NG data 

to enhance financial management and oversight, and to improve their 

capability to track expenditures. However, while GFEBS more readily 

identifies funds obligated and disbursed for some contracts, ANCP 

officials noted that there are cases, especially when ANCP transfers 

money to agencies that do not currently use GFEBS, where this 

information is not available through this system. For example, we found 

that GFEBS data did not identify the specific information technology 

contracts supported by the Army Communications-Electronics Command, 

Army Geospatial Center, Naval Supply Systems Command Weapon 

Systems Support office, and others.

 

11We have previously noted that DOD lacks basic data about its service contracts that 

could help it determine how it contracts for services and how reliant it is on contractors. 

See GAO, Defense Acquisitions: Actions Needed to Ensure Value for Service Contracts, 

GAO-09-643T (Washington D.C.: Apr. 23, 2009).

12GFEBS is intended to improve financial, asset, and real property management and 

standardize processes across the Army.

Contracting Support 

Organizations 
Page 15 GAO-12-99 Arlington National Cemetery

showed that the total obligations for this same contract were only 

$2.1 million. USACE also had difficulty providing a complete list of active 

Arlington contracts for this time frame. For example, we found additional 

contracts that USACE did not initially identify, as well as other contracts 

and task orders provided to us that were not actually active during our 

covered time frame. USACE did, however, provide accurate dollar 

amounts associated with the contracts they were able to identify. The 

MICC-Fort Belvoir contracting office was able to provide a complete list of 

the recently awarded contracts supporting Arlington with accurate dollar 

amounts for this time frame, and those data were supported by similar 

information from Arlington. The MICC-Fort Belvoir contracts were 

awarded after the June 2010 Inspector General report and in close 

coordination with the contract specialist detailed to ANCP.

Without complete data on existing contracts, ANCP leadership may be 

without sufficient information to identify, track, and ensure the effective 

management and oversight of its contracts. In a March 2011 report, the 

Army Audit Agency found that due to poor financial oversight under the 

previous Arlington administration, Arlington incurred about $27.8 million in 

obligations during fiscal years 2004 through 2010, but for which funds had 

not been disbursed as of September 2010.13 The Army Audit Agency also 

identified about $10 million of these obligations that could potentially be 

recovered and used for other purposes.14

 

13Army Audit Agency, Arlington National Cemetery Budget Execution, A-2011-0078-FFM 

(Alexandria, Va.: 2011).

The Army Audit Agency further 

reported that comprehensive financial oversight at Arlington would 

improve its ability to account for the status of available funding. The Army 

IG stated in its September 2011 report that ANCP had successfully 

recovered $15 million of the obligations that will no longer require 

payment and the ANCP budget officer noted that the management team 

is currently focusing on recovering remaining funds associated with 

previous contracts. The Executive Director of ANCP recently stated that 

recovering past obligations could potentially help fund needed increases 

in a number of areas, including manpower, equipment, and training at the 

cemetery. Because Arlington’s appropriation has a no-year classification, 

14An obligation is a definite commitment that creates a legal liability of the government for 

the payment of goods and services ordered or received; a disbursement is a payment 

during the fiscal year to liquidate government obligations. 
Page 16 GAO-12-99 Arlington National Cemetery

its funds are available indefinitely.15 This fact, combined with data 

limitations that we and others have noted, could make it difficult for ANCP 

to identify and recover previously obligated contract funds that could 

potentially be used for other purposes.

The Army has taken a number of steps at different levels to provide for 

more effective management and oversight of Arlington contracts in 

responding to deficiencies identified by the Army IG, including to better 

align ANCP support relationships with the expertise of its partners.16

 

15We have also noted that no-year appropriations should not be made in the absence of 

compelling programmatic or budgetary reasons. See GAO, No-Year Appropriations in the 

Department of Agriculture, PAD-78-74 (Washington, D.C.: Sept. 19, 1978).

At 

the organizational level, ANCP signed new agreements with the Army 

Contracting Command and USACE that identify broad responsibilities for

how contract support will be provided. ANCP has also worked with other 

Army organizations to define roles and responsibilities with respect to 

information technology support; however, the agreements governing 

these relationships are not specific as to the management of contracts. 

ANCP has also focused on the training of contracting personnel and is 

taking steps to formalize policies and procedures for contract 

management. At the same time, ANCP has also increased the use of 

dedicated contracting staff to manage and improve its acquisition 

processes, but has not yet fully determined the appropriate number, skill 

levels, and arrangements needed to meet its needs moving forward. 

While more recent contracts supporting Arlington are generally improved 

as compared with contracts awarded prior to June 2010, recent reviews 

continue to identify risks at some contracting locations. Going forward, 

sustained attention on the part of ANCP and its partners will be important 

to ensure contracts of all types and risk levels are managed effectively.

16In a separate report, we found that the Army has taken positive steps to address 

management deficiencies and has implemented improvements across a broad range of 

areas beyond contract management, but identified additional opportunities to build upon 

and institutionalize improvements in areas such as information technology and workforce 

planning, assessing and improving cemetery performance, and coordinating with other 

operational partners. See GAO-12-105. 

Management of 

Arlington Contracts 

Improved, but 

Contracting Support 

Responsibilities and 

Staffing Arrangements 

Not Yet Fully Defined
Page 17 GAO-12-99 Arlington National Cemetery

In response to recommendations in multiple Army reviews, ANCP 

established new agreements with the Army Contracting Command and 

USACE in August and December, respectively, of 2010. These actions 

are consistent with the Office of Management and Budget’s Guidelines for 

Assessing the Acquisition Function,

17 which addresses how to conduct 

acquisition assessments under OMB Circular A-123, and states that 

clearly defining and integrating roles and responsibilities are key to 

aligning acquisitions with agency missions and needs. We have reported 

that a key factor in improving DOD’s service acquisition outcomes—that 

is, obtaining the right service, at the right price, in the right manner—is 

having defined responsibilities and associated support structures.18

ANCP’s agreement with the Army Contracting Command states that it will 

assign appropriate contracting offices to provide support, in coordination 

with ANCP, and will conduct joint periodic reviews of new and ongoing 

contract requirements. In April 2011, ANCP also signed a separate 

agreement with the MICC, which is part of the Army Contracting 

Command, that outlines additional responsibilities for providing 

contracting support to ANCP. While this agreement states that the MICC, 

through the Fort Belvoir contracting office, will provide the full range of 

contracting support, it does not specify the types of requirements at 

Arlington that the MICC-Fort Belvoir will support, nor does it specify that 

other offices within the command may also do so. The MICC-Fort Myer 

contracting office is also managing a small number of modifications to 

existing contracts on ANCP’s behalf. Officials at ANCP stated that 

contracting support from the MICC-Fort Myer office is coordinated 

through the MICC-Fort Belvoir, although the agreement also does not 

currently specify that the MICC-Fort Belvoir is responsible for this type of 

coordination. As part of its efforts to provide contracting support to ANCP, 

the MICC-Fort Belvoir office has established regular meetings with ANCP 

staff to plan and track the status of acquisitions.

The agreement signed with USACE states that it will, in coordination with 

ANCP, assign appropriate offices to provide contracting support and that 

USACE will provide periodic joint reviews of ongoing and upcoming 

requirements. According to USACE officials, in October 2011 ANCP and 

 

17Executive Office of the President, Office of Management and Budget, Office of Federal 

Procurement Policy, Guidelines for Assessing the Acquisition Function (May 2008).

18GAO-07-20. 

ANCP Has New 

Agreements in Place, but 

Has Not Yet Fully Defined 

Specific Contracting Roles 

and Responsibilities
Page 18 GAO-12-99 Arlington National Cemetery

USACE were in the process of finalizing an overarching program 

management plan which, if implemented, provides additional detail about 

the structure of and roles and responsibilities for support. This plan 

identifies that the North Atlantic Division of USACE is responsible for the 

overall management of support to ANCP, with the Norfolk District having 

primary responsibility for project delivery and execution. At the time of our 

review, six different organizations within USACE were providing support 

for ANCP requirements based on the type of expertise needed, and 

officials from USACE indicated they would continue to determine the 

appropriate organization to support Arlington on a case-by-case basis. 

USACE and ANCP have also established a Senior Executive Review 

Group which updates the senior leadership at both organizations on the 

status of ongoing efforts. Thus far, two meetings of this group have taken 

place, and an official we spoke with at ANCP indicated that they have 

already seen improvement in the level of coordination.

ANCP has also put agreements in place with other organizations, 

including ITA and the Army Analytics Group, which provide program 

support and expertise to manage information technology infrastructure 

and enhance operational capabilities. For example, the agreement in 

place with ITA identifies the services that will be provided to Arlington, 

performance metrics against which ITA will be measured, as well as 

Arlington’s responsibilities. These organizations are also responsible for 

managing the use of contracts in support of their efforts. While ITA

officials noted that they rely heavily on contractor support to provide 

information technology capabilities to their customers, their agreement 

with ANCP does not specifically address roles and responsibilities 

associated with the use and management of these contracts supporting 

Arlington requirements. Officials from both ITA and the Army Analytics 

Group, along with the Army Communications-Electronics Command, 

indicated that they were generally responsible for determining when to 

use their existing contracts to support efforts related to Arlington, ensuring 

that specific requirements are defined and contract oversight takes place. 

Although these officials told us that they currently understand their 

responsibilities, without being clearly defined in the existing agreements, 

roles and responsibilities may be less clear in the future when personnel 

change.
Page 19 GAO-12-99 Arlington National Cemetery

In response to previous findings, ANCP has taken a number of steps to 

improve contracting practices within the organization, including 

developing new internal policies and procedures and improving training 

for staff responsible for providing contract oversight. ANCP, working with 

the MICC, has also dedicated additional staff resources to improve 

contract management. Many of these efforts were in process at the time 

of our review, including decisions on contracting staff needs, and their 

success will depend on continued management attention.

Arlington has taken several steps to more formally define its own internal 

policies and procedures for contract management. Office of Management 

and Budget guidance notes that policies and procedures embody the 

basic principles that govern the way an agency performs the acquisition 

function.19

 

19Executive Office of the President, Office of Management and Budget, Office of Federal 

Procurement Policy, Guidelines for Assessing the Acquisition Function (May 2008).

In July 2010, the Executive Director of ANCP issued guidance 

stating that the Army Contracting Command and USACE are the only 

authorized contracting centers for Arlington. Furthermore, the Executive 

Director also issued a memo in June 2010 indicating that ANCP’s Chief of 

Staff has the authority to approve purchase requests, which officials 

indicated includes those associated with the use of contracts. Officials at 

ANCP and the MICC-Fort Belvoir are continuing efforts to (1) develop 

standard operating procedures associated with purchase requests; 

(2) develop memoranda for all ANCP employees that outline principles of 

the procurement process, as well as training requirements for contracting 

officer’s representatives; and (3) create a common location for reference 

materials and information associated with Arlington contracts. ANCP 

officials stated that they expect to finalize development of this guidance 

by December 2011. Working with the MICC-Fort Belvoir, Arlington has 

also taken steps to ensure that staff receive appropriate training to 

provide for better contract management and oversight. This includes 

coordinating training support from the Defense Acquisition University on 

contract planning and execution, as well as one-on-one training with the 

contracting officer’s representatives. In May 2011, the Executive Director 

issued guidance requiring contracting officer’s representative training for 

all personnel assigned to perform that role. At the time of our review, all of 

the individuals serving as contracting officer’s representatives had 

ANCP Is Developing New 

Policies and Procedures, 

but Has Not Yet Fully 

Determined Contracting 

Staff Needs

ANCP Contracting Policies and 

Procedures 
Page 20 GAO-12-99 Arlington National Cemetery

received training for that position, and officials identified training as an 

area on which they plan to continue to focus in the future.20

In its September 2011 follow-on report, the Army IG also noted the 

progress ANCP has made with regard to documenting policies and 

procedures and training, but made additional recommendations in this 

area. For example, the Army IG noted an increased emphasis on 

acquisition training, specifically in the areas of contract formation and 

contract management. The report recommended Arlington continue to 

develop a comprehensive training program to ensure all employees have 

the knowledge and skills necessary to be proficient in the core

competencies necessary to accomplish its mission. The Army IG also 

recommended that ANCP continue to develop and document appropriate 

standard operating procedures, policies, and guidance. In response, 

ANCP concurred with each of these recommendations.

In response to Army Directive 2010-04, the U.S. Army Manpower 

Analysis Agency and the U.S. Army Force Management Support Agency 

completed a study in July 2010 which assessed Arlington’s manpower 

needs. The study identified the need for three full-time contract specialist 

positions within Arlington based on an analysis of the contract workload in 

place at the time. However these positions have not been filled to date. 

Instead, ANCP’s needs have been met through the use of staff provided 

by the MICC. For example, in September 2010, a contract specialist was 

detailed to Arlington on a full-time basis to help improve internal contract 

management processes, among other duties. Table 1 describes current 

ANCP contracting support positions by level and funding arrangements.

 

20Army guidance on managing service acquisitions notes that effective contract 

surveillance requires appropriate monitoring of contractor performance, and we have 

reported on the need to train personnel to ensure that adequate surveillance occurs. For 

example, see GAO, Defense Acquisitions: Actions Needed to Ensure Value for Service 

Contracts, GAO-09-643T (Washington, D.C.: Apr. 23, 2009).

ANCP Contracting Support 

Staff
Page 21 GAO-12-99 Arlington National Cemetery

Table 1: Current Army National Cemeteries Program Contracting Support Positions

Positions Identified in Army 

National Cemeteries Program 

Table of Distribution and 

Allowances

Positions Provided by the Mission and Installation Contracting Command-Fort Belvoir

Funded by the Army National Cemeteries 

Program

Funded by the Mission and Installation 

Contracting Command-Fort Belvoir

GS-13 Contract Specialist GS-13 Contract Specialist

• Manage and oversee contracting support

GS-14 Contract Specialist

• Provide external coordination and 

oversight

GS-12 Contract Specialist GS-12 Contract Specialist

• Manage contracting workload

GS-13 Contract Specialist

• Coordinate government purchase card 

program

GS-12 Contract Specialist GS-12 Contract Specialist

• Responsible for contracting actions

GS-12 Contract Specialist

• Provide liaison support between Army 

National Cemeteries Program and Fort 

Belvoir

GS-12 Quality Assurance Specialist

• Assist with training and contract oversight 

efforts

Contractor

• Responsible for contracting actions

Contractor

• Provide assistance in requirements 

development

Contractor

• Responsible for contracting actions

Source: Department of the Army.

Note: Gray = filled position

White = unfilled position

ANCP officials, including the Executive Director, have since identified the 

need for a contracting specialist at the GS-14 level, which is not currently 

reflected in Arlington’s Table of Distribution and Allowances.21

 

21For certain organizations within the Army, a Table of Distribution and Allowances is an 

authorization document that prescribes the organizational structure and the personnel and 

equipment requirements and authorizations to perform a specific mission. We discuss 

additional information related to ANCP’s workforce planning and staffing beyond 

contracting in a separate report, 

At the time 

of our review, ANCP officials stated that they intended to request an 

update to their staffing allowance for fiscal year 2013 to fill this new 

position, but do not intend to fill the GS-12 positions in the foreseeable 

future. Officials at ANCP and the MICC-Fort Belvoir contracting office 

stated that they are also evaluating staffing requirements to determine the 

appropriate number, skill level, and location of contracting personnel who

are funded by ANCP and provided by the MICC-Fort Belvoir under the 

GAO-12-105. 
Page 22 GAO-12-99 Arlington National Cemetery

current support agreement between the two organizations. As shown in 

the table, the MICC-Fort Belvoir is providing additional support beyond 

those positions funded by ANCP to help ensure adequate support for 

ANCP’s requirements. Arlington personnel we spoke with noted benefits 

from this dedicated staff support. For example, the dedicated quality 

assurance specialist started working directly with staff at Arlington in May 

2011 and stated that he has focused on training, teaching, and mentoring 

the Arlington contracting officer’s representatives on their basic duties, 

surveillance activities, and documentation requirements.22 The 

contracting officer’s representatives at Arlington stated that they have 

worked closely with the quality assurance specialist on developing 

surveillance schedules and checklists and to ensure their files are 

complete.

USACE has also taken steps to improve its own processes, procedures, 

and training for contract management, including issuing a corrective 

action plan to address findings from the 2010 Army IG report and 

procurement management review. The corrective action plan details 

initiatives to instill policy, procedures, and acquisition discipline through 

standardized processes and training. For example, USACE is 

implementing a contracting officer’s representative database and 

conducting enterprise training on the development of quality assurance 

surveillance plans and contract closeout training. The corrective action 

plan details responsibilities for implementing these actions at all levels 

within the organization. In addition to the corrective action plan, USACE 

initiated an acquisition process improvement plan at the Baltimore 

District, including an analysis of the underlying causes of the deficiencies 

identified through prior reviews, as well as tasks organized around 

improving business process and policies; documentation and compliance; 

engagement, leadership, and culture; organization, staffing, and 

resources; and training.

While progress has been made, subsequent reviews have continued to 

indicate risks associated with contracting at USACE. Specifically, a June 

2011 Army Audit Agency report on Arlington contracts at the USACE 

 

22The contracting officer’s representative serves as the onsite technical subject matter

expert assessing contractor performance against contract performance standards and 

recording and reporting this information, including inspecting and accepting supplies and 

services. 

Contracting Support 

Organizations Are 

Implementing Changes to 

Address Deficiencies
Page 23 GAO-12-99 Arlington National Cemetery

Baltimore District contracting office noted that while corrective actions 

planned or taken will likely improve contract quality in the future, 

additional corrective actions are needed to reduce the risk of similar 

issues recurring.23

Although no longer directly supporting contracting requirements for 

Arlington at the time of our review, NCR was also taking steps to improve 

its own processes, procedures, and training for contract management. 

NCR issued a corrective action plan to address deficiencies and 

recommendations identified in a program management review performed 

by the Deputy Assistant Secretary of the Army (Procurement). The 

specific corrective actions include finalizing contract support agreements, 

providing support to contracting officer’s representatives, training, 

reassigning information technology requirements, performing reviews of 

all open Arlington requirements, and developing new standard operating 

procedures. An April 2011 procurement management review stated that 

NCR’s corrective actions were complete or near completion. According to 

this review, NCR implemented ACC Pamphlet 70-1, Interim Army 

Contracting Command Contracting Officer’s Representative Policy Guide, 

and developed a Contracting Officer’s Representative Management Plan 

in accordance with this pamphlet to address the deficiency of contracting 

officer’s representative appointment letters and training certificates 

missing from contract files. A November 2011 report by the Army Audit 

USACE has elected to transfer support of Arlington 

contracts from the Baltimore District to the Norfolk District, and has been 

in the process of executing that transition over the past few months. In 

two recent procurement management reviews conducted during July and 

August of 2011, contracting officials within USACE continued to identify 

concerns at both the Baltimore and Norfolk Districts, and rated certain 

aspects of contracting operations, including pre-award and post-award 

contract execution as medium or high risk. Although these reviews are 

not specific to Arlington, given their relationship, ANCP contracting 

success will depend substantially on the ability of USACE to continue to 

improve its practices.

 

23Army Audit Agency, Contracting Operations in Support of Arlington National Cemetery: 

U.S. Army Corps of Engineers, North Atlantic Division, Baltimore District, A-2011-0144-

ALC (Alexandria, Va.: 2011). 
Page 24 GAO-12-99 Arlington National Cemetery

Agency found that corrective actions planned or taken by NCR should 

improve the quality of future contracting activities.24

Prior reviews of Arlington have identified numerous issues with contracts 

in place prior to the new leadership at ANCP. While our review of similar 

contracts found common concerns, we also found that newly awarded 

contracts reflect improvements in acquisition practices. Our previous 

contracting-related work has identified the need to have well-defined 

requirements, sound business arrangements (i.e., contracts in place), and 

the right oversight mechanisms to ensure positive outcomes. In the case 

of those recent Arlington contracts, we found examples of improved 

documentation designating contracting officer’s representatives and 

certifying training in contract files for both NCR and the MICC-Fort 

Belvoir. Additionally, Arlington took steps to better define and consolidate 

existing requirements for services supporting daily cemetery operations. 

In light of the issues identified by the Army IG, ANCP advised NCR not to 

exercise the remaining option years for such contracts. Instead, the 

period of performance was extended for a short time while new contracts 

were competed and awarded by the MICC-Fort Belvoir. For example, 

three different contracts previously in place supported Arlington 

requirements for landscaping, but were consolidated into a single contract 

to cover the same services. Staff at Arlington responsible for oversight 

indicated that this has helped to simplify their responsibilities as 

contracting officer’s representatives.

Newly awarded contracts also reflected more specific requirements for 

contractor performance when compared with prior contracts for similar 

services. For example, the new contract for headstone installation 

services now defines specific steps the contractor is to take to ensure 

verification of the decedent’s name and grave number on the temporary 

headstone, prior to setting the headstone, and also instructs the 

contractor not to remove the temporary marker. Additionally, any 

discrepancies are to be promptly reported to the contracting officer’s 

representative. The previous headstone contract was silent on this 

procedure. Likewise, Arlington’s new information technology-related 

efforts reflect improvements from those conducted prior to June 2010, 

 

24Army Audit Agency, Contracting Operations in Support of Arlington National Cemetery: 

Army Contracting Command National Capital Region, A-2012-0021-ALC (Alexandria, Va.: 

2011). 

Recent Arlington 

Contracts Reflect 

Improved Acquisition 

Practices
Page 25 GAO-12-99 Arlington National Cemetery

including the newly issued task orders associated with development of 

Arlington’s Geographic Information System. The Deputy Assistant 

Secretary of the Army (Procurement) reported that although the prior 

administration at Arlington had eight contracts to develop this system, 

nothing was actually deployed, contract deliverables were not clear, and 

contract file documentation for acquisition planning and oversight was 

missing. While development of this capability is still ongoing, the contract 

files for the associated task orders issued by the Army Geospatial Center 

contained more complete documentation of acquisition planning, 

competition, and oversight activities. Similarly, requirements in the most 

recent contract awarded for document-scanning efforts to digitize burial 

records are much more detailed. The performance work statement for the 

new contract specifically lists the different types of cards to be scanned, 

such as record of interment cards, grave cards, and reservation cards, 

and the type of data to be collected from each card. The current scanning 

contract also lists the specific data fields—including cemetery section 

number; gravesite location; gravesite status; first, middle, and last name 

of the decedent; date of interment; and branch of service—to be entered 

as part of the data entry services; none of which was specified in the 

statement of work for a prior contract awarded in 2005 to scan Arlington 

records. At the time of our review, many of these efforts were still 

underway, so while initial steps taken reflect improvement, their ultimate 

success is not yet certain.

In its June 2010 review, the Army IG noted that most of Arlington’s 

contracts were of a small dollar value compared to other major Army 

contracts; and therefore may not receive the same level of attention as 

other, more costly contracts. Our prior work has shown that in some 

cases, dollar value may not be a good proxy for determining risk. For 

example, some high-dollar contracts could pose relatively little risk to 

achieving the agency’s mission. Conversely, certain lower dollar contracts 

may pose higher risk and, therefore, require greater management 

attention.25

 

25

Many of the contracts and task orders we reviewed for 

Arlington bear the characteristics of acquisitions that are traditionally 

considered to be low risk. For example, the majority provided for 

payments to be made on a firm-fixed price basis, which entails less risk 

for the government; many were for commercial services, which allows for 

GAO-07-20. 

Risk Factors Remain for 

ANCP Acquisitions
Page 26 GAO-12-99 Arlington National Cemetery

the use of streamlined acquisition procedures; and many had dollar 

values below existing thresholds for activities such as the completion of 

formal, written acquisition plans. In its more recent report detailing 

progress at Arlington, the Army IG noted that the contract files for smaller 

dollar value actions awarded by the MICC-Fort Belvoir contracting office 

generally contained more errors than did the files for larger dollar value 

actions. Accordingly, the Army IG made a series of new 

recommendations to ensure continued attention to Arlington contracts, 

including that the Army Contracting Command and USACE include all 

Arlington contracting actions in the review process at levels above the 

contracting officer until the Deputy Assistant Secretary of the Army 

(Procurement) determines those contracts to be low risk. It also 

recommended that both organizations continue to assess and target 

areas of improvement within their respective commands and provide 

appropriate corrective actions to strengthen the quality of the acquisitions 

supporting Arlington. If implemented appropriately, these steps may help 

to ensure continued attention to the management of Arlington’s contracts 

in the future.

Since June 2010, the Army has taken a number of positive actions to 

address problems caused by a previous lack of adherence to sound 

acquisition practices at Arlington National Cemetery. While significant 

progress has been made, our work suggests that further action is needed 

to ensure future success. Although ANCP has taken steps to improve its 

internal financial management capabilities, it does not yet have a 

cohesive way of identifying and tracking complete data on all contracts. 

ANCP relies heavily on other organizations to achieve its mission, which 

leverages their expertise but can introduce risks. Ensuring that roles and 

responsibilities are more fully defined between ANCP and its partners can 

help to mitigate such risks. Further, ANCP has utilized its contract support 

relationships to obtain dedicated personnel to improve its own internal 

acquisition management capabilities. However, ANCP has not yet 

completed a needs assessment which could inform decisions such as 

whether and how to make these arrangements permanent. Ensuring the 

availability of more complete and accurate information on contracts; 

strengthening and clarifying support relationships; and having the right 

mix of people will help ANCP ensure sustained attention to contract 

management and institutionalize progress made to date, particularly as 

the current spotlight fades.

Conclusions 
Page 27 GAO-12-99 Arlington National Cemetery

To ensure continued improvement in the management and oversight of 

contracts, we recommend that the Secretary of the Army direct the 

Executive Director of the Army National Cemeteries Program, in 

coordination with other Army organizations as appropriate, to take the

following three actions:

• identify and implement a method by which complete and accurate 

data on contracts supporting Arlington’s operations will be tracked and 

clearly designate responsibility for doing so;

• ensure that support agreements clearly assign roles and 

responsibilities associated with the decision to use, manage, and 

oversee contracts supporting Arlington’s operations; and

• determine, based on an assessment of Arlington’s needs, the 

appropriate number and required skill levels associated with 

contracting positions necessary to support Arlington and ensure those 

positions are filled.

We provided a draft of our report to DOD for review and comment. We 

received DOD’s written response from the Executive Director of ANCP 

which is reprinted in appendix II. The Executive Director also provided 

technical comments, which we addressed in the report as appropriate.

DOD partially concurred with all three of our recommendations, agreeing 

that there is a need to take actions to address the issues we raised but 

indicating that our recommendations did not adequately capture Armywide efforts currently underway. We believe our report reflects the 

significant progress made by Arlington and recognizes actions highlighted 

by the Executive Director. We continue to be encouraged by the Army's 

focus on improving contracting practices and believe that implementation 

of our recommendations will help to institutionalize the positive steps 

taken to date. With respect to our recommendation to identify and 

implement a method to track complete and accurate data on contracts 

supporting Arlington’s operations, the Executive Director noted the Army’s 

intention to implement a methodology based on an electronic tool which is 

expected to collect and reconcile information from a number of existing 

data systems. Our report acknowledges development of this tool, now 

planned for implementation in April 2012. However, we also identified 

shortcomings associated with some of these data systems and continue 

to believe that implementation of this methodology should take these 

shortcomings into account. The Executive Director noted planned actions 

expected for completion by March 2012 that, if implemented, would 

satisfy the intent of our other two recommendations. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 28 GAO-12-99 Arlington National Cemetery

We are sending copies of this report to appropriate congressional 

committees, the Secretary of Defense, the Secretary of the Army, and the 

Secretary of Veterans Affairs. In addition, this report will be available at 

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

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

at (202) 512-4841 or martinb@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 major contributions to this report are 

listed in appendix III.

Belva M. Martin

Director, Acquisition and Sourcing Management
Page 29 GAO-12-99 Arlington National Cemetery

List of Committees

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Joseph I. Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Patty Murray

Chairman

The Honorable Richard Burr

Ranking Member

Committee on Veterans’ Affairs

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Darrell E. Issa

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Jeff Miller

Chairman

The Honorable Bob Filner

Ranking Member 

Committee on Veterans’ Affairs

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-12-99 Arlington National Cemetery

Public Law 111-339 directed GAO to report on the management and 

oversight of contracts at Arlington National Cemetery (Arlington) as well 

as a number of other issues related to management at Arlington more 

generally. This report addresses issues specifically associated with 

contracting; we are reporting separately on the Army’s efforts to address 

identified management deficiencies; the information and assistance 

provided to families regarding efforts to detect and correct burial errors; 

and factors that may affect the feasibility or advisability of transferring 

jurisdiction of Arlington to the Department of Veteran’s Affairs and the 

potential for collaboration between the two departments.1

We defined current contracts as those contracts or task orders that were 

newly awarded or modified during fiscal year 2010 and the first three 

quarters of fiscal year 2011 with planned or total obligations above 

$100,000. We requested data identifying such contracts from the U.S. 

Army Corps of Engineers (USACE); the Mission and Installation 

Contracting Command (MICC)-Fort Belvoir and MICC-Fort Myer 

contracting offices; and the Army Contracting Command National Capital 

Region (NCR). We also asked officials from the organizations providing 

information technology assistance to Arlington, including the Army 

Information Technology Agency, Army Analytics Group, and the Office of 

the Assistant Chief of Staff for Installation Management to identify current 

contracts they relied on to support Arlington. We used data provided by 

these organizations, information from the procurement management 

reviews conducted by the Deputy Assistant Secretary of the Army 

(Procurement), as well as interviews with officials at Arlington currently 

responsible for information technology efforts and the Department of 

Veterans Affairs to identify contracts and task orders in support of the 

Total Cemetery Management System, Interment Scheduling System, 

Interment Management System, the Geographic Information System, and 

To satisfy the 

mandate related to contracting, we (1) identified the number, duration of, 

and dollar amount spent on current contracts used to support operations 

at Arlington, including those used to support information technology 

systems for the automation of burial operations; and (2) assessed the 

extent to which the Army has put processes and procedures in place to 

provide for the effective management and oversight of contracts 

supporting Arlington.

 

1

GAO, Arlington National Cemetery: Management Improvements Made, but a Strategy is 

Needed to Address Remaining Challenges, GAO-12-105 (Washington D.C.: Dec. 15, 

2011). 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-12-99 Arlington National Cemetery

the Burial Operations Support System. To assess the reliability of the 

data provided by the contracting offices, we compared their data to those

(1) included in the Federal Procurement Data System-Next Generation 

(FPDS-NG), (2) provided by officials at the Army National Cemeteries 

Program (ANCP), and (3) gathered by the Deputy Assistant Secretary of 

the Army (Procurement) as well as the Army Audit Agency as part of their 

respective reviews of Arlington contracts. Through these comparisons, we 

determined that the MICC-Fort Belvoir and MICC-Fort Myer offices 

provided reliable data identifying Arlington contracts. After multiple 

attempts, USACE provided a more complete list of contracts although 

they did not identify all Arlington contracts, and they also included 

contracts that were no longer active during fiscal year 2010 or 2011. The 

NCR contracting office also provided a more complete list of contracts 

after multiple attempts, but did not identify all Arlington contracts. 

Because we were able to use the additional data sources indicated above 

to identify contracts supporting Arlington, we consider the data we 

compiled to be sufficiently reliable for our purposes.

To report on the duration of contracts we identified, we used contract 

documents and information from contracting officials to determine the 

period of performance associated with each contract or task order. To 

report dollars obligated during fiscal year 2010 and the first three quarters 

of fiscal year 2011 under the contracts we identified, we relied on data 

from the FPDS-NG. We compared these data to obligations reported by 

the contracting offices, and determined data from FPDS-NG to be reliable 

for our purposes. In a small number of cases, work was performed for 

Arlington and other organizations under the same task order or 

modification to an existing task order or contract, and as a result, 

obligations in FPDS-NG reflected work beyond that which specifically 

supported Arlington. In these instances, we used contract documents and 

information from agency officials to identify obligations specifically 

associated with Arlington.

To assess the processes and procedures in place to provide for the 

effective management and oversight of contracts and to address prior 

recommendations from the Army IG, we obtained and analyzed guidance, 

policies, and other documentation from officials at Arlington, the 

contracting offices providing support, and other Army organizations. To 

assess the implementation of Army Directive 2010-04 specific to 

contracting, we reviewed the procurement management reports compiled 

by and interviewed officials from the Deputy Assistant Secretary of the 

Army (Procurement). We also reviewed plans, reports, and other 

information and interviewed officials from USACE and the NCR 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-99 Arlington National Cemetery

contracting office to identify steps taken by those organizations to 

improve contract management. We interviewed senior officials from the 

Army National Cemeteries Program (ANCP), which oversees Arlington 

National Cemetery, as well as other ANCP officials responsible for 

contracting and financial management. We also interviewed officials from 

the Army Information Technology Agency, the Army Analytics Group, the 

Office of the Assistant Chief of Staff for Installation Management, the 

Army Records Management and Declassification Agency, and the 

Department of Veterans Affairs, National Cemetery Administration to 

discuss efforts to enhance information technology at Arlington.

To assess the effectiveness of management and oversight of individual 

contracts and task orders, we reviewed documentation from the files for 

the 56 current contracts we identified as supporting operations at 

Arlington, as well as 10 older contracts and task orders associated with 

information technology efforts underway prior to June 2010. Using a data 

collection instrument, we reviewed documents and information associated 

with all phases of the acquisition process, including pre-award acquisition 

planning, contract award, and post-award administration and oversight. 

The NCR contracting office, USACE, Defense Information Technology 

Contracting Organization, and Army Communications-Electronics 

Command each utilized task orders under existing indefinite delivery 

indefinite quantity contracts, or in some cases, modifications to existing 

task orders to support Arlington. In these instances, we focused our 

review on contract file documentation associated with the task orders or 

modifications related to Arlington. We interviewed officials currently 

designated as contracting officer’s representatives at Arlington and 

reviewed contract surveillance documentation to assess the effectiveness 

of current oversight practices.

We conducted this performance audit from March 2011 through 

December 2011 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: Comments from the Department 

of Defense

Page 33 GAO-12-99 Arlington National Cemetery

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 34 GAO-12-99 Arlington National Cemetery
Appendix II: Comments from the Department 

of Defense

Page 35 GAO-12-99 Arlington National Cemetery
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 36 GAO-12-99 Arlington National Cemetery

Belva M. Martin, (202) 512-4841 or martinb@gao.gov

In addition to the contact named above, Brian Mullins, Assistant Director; 

Kathryn Edelman; Julie Hadley; Kristine Hassinger; Julia Kennon; Lina 

Khan; Jean McSween; Roxanna Sun; and Bob Swierczek also made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff Acknowledgments

(120967)
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