CIVILIAN SERVICE 

CONTRACT 

INVENTORIES

Opportunities Exist to 

Improve Agency 

Reporting and Review 

Efforts

Report to Congressional Committees

September 2012

GAO-12-1007

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-1007, a report to 

congressional committees 

September 2012

CIVILIAN SERVICE CONTRACT INVENTORIES

Opportunities Exist to Improve Agency Reporting 

and Review Efforts

Why GAO Did This Study

In fiscal year 2011, civilian agencies 

reported $161 billion in contract 

obligations, $126 billion (almost 80 

percent) of which were for services 

such as professional management and 

information technology support. 

Concerned about agencies’ reliance on 

contractors, Congress included a 

requirement in the Consolidated 

Appropriations Act of 2010 for civilian 

agencies to compile and review an 

annual inventory of service contracts to 

examine certain issues, such as 

contractors performing inherently 

governmental functions or functions 

closely associated with inherently 

governmental functions, which would 

require enhanced management 

oversight. It also required OMB to 

develop guidance to assist agencies in 

meeting the act’s requirements and for 

GAO to report on agency efforts. 

GAO assessed agency efforts to 

(1) compile their fiscal year 2011 

inventories and (2) review and report 

on their fiscal year 2010 inventories. 

To meet these objectives, GAO 

analyzed agencies’ fiscal year 2011 

service contract inventories and fiscal 

year 2010 service contract inventory 

review reports and compared them to 

legislative requirements, OMB 

guidance, and federal procurement 

data. 

What GAO Recommends

GAO recommends that OMB (1) work 

with agencies to improve how 

compliance with the act and with OMB 

guidance is monitored and (2) clarify

guidance to agencies for compiling and 

reporting on their inventories. OMB 

generally concurred with our 

recommendations.

What GAO Found

Civilian agencies did not fully comply with statutory requirements for compiling 

fiscal year 2011 service contract inventories. For example, because the 

information is not currently readily available, the Office of Management and 

Budget (OMB) directed the 49 agencies that were required to submit inventories 

to defer the collection of three statutorily required data elements for each 

contract—the role the services played in achieving agency objectives, the total 

dollar amount invoiced for services under the contracts, and the number and 

work locations of contractor and subcontractor personnel. Progress, however, is 

being made to collect this information for future inventories. OMB directed 

agencies to start collecting information on the role services play in achieving 

agency objectives for new contracts awarded on or after March 1, 2012. A 

proposed Federal Acquisition Regulation rule was published in April 2011 to start 

collecting the remaining two data elements directly from contractors. We also 

found several instances where agencies significantly underreported obligations in 

their inventories, either because they misinterpreted or did not follow OMB 

guidance. For example, the General Services Administration underreported 

obligations by approximately $6.4 billion. Without complete and accurate service 

contract inventories, OMB and Congress cannot meaningfully compare service 

contract obligations among agencies, or develop spending trends for agencies, 

thus limiting the overall utility of the inventories. 

Nine of the 49 civilian agencies did not submit a report on their fiscal year 2010 

inventory review to OMB, as required. Of the 40 agencies that submitted reports 

on their inventory reviews, 5 agencies identified 3 contracts where contractors

could be performing inherently governmental functions and 104 instances where 

contractors were performing closely associated with inherently governmental 

functions. It is unclear, however, based on the 40 agency reports, whether these 

results were a real indication of the agencies’ effective and appropriate use of 

contractors or due to the different approaches agencies used to conduct the 

reviews. Agencies did not include important context in their reports, such as the 

number of contracts or the percentage of their inventories reviewed. As shown in 

the figure below, of the 25 agencies that reported the number of contracts they 

reviewed, most reviewed 50 or fewer contracts. OMB intends to have agencies 

share lessons learned, including the use of cross-functional teams, to help future 

review efforts.

Number of Contracts Agencies Reviewed 

View GAO-12-1007. For more information, 

contact John Hutton at (202) 512-4841 or 

HuttonJ@gao.gov. 
Page i GAO-12-1007 Civilian Service Contract Inventories 

Letter 1 

Background 3

The Utility of Service Contract Inventories May Be Diminished by 

Incomplete Data and Different Reporting Methodologies 7

Inventory Review and Reporting Efforts Could Be Improved 11

Conclusions 18

Recommendations for Executive Action 19

Agency Comments and Our Evaluation 19

Appendix I Scope and Methodology 22

Appendix II Forty-Nine Agencies Required to Report on Service Contract 

Inventories 24

Appendix III GAO Contact and Staff Acknowledgments 26

Related GAO Products 27

Tables

Table 1: Illustrative List of Special Interest Functions 6

Table 2: Agencies Not Submitting Fiscal Year 2010 Inventory 

Review Reports to OMB 12

Table 3: Selected Agency Inventory Analysis Findings and 

Resolutions 15

Figures

Figure 1: Illustration of Variations in Service Contract Obligations 

for Fiscal Year 2011 by Inventory Methodology (Using 

GSA Obligations) 10

Figure 2: Number of Contracts Agencies Reviewed 13

Contents
Page ii GAO-12-1007 Civilian Service Contract Inventories 

Abbreviations

ADP Automated Data Processing

Commerce Department of Commerce

DHS Department of Homeland Security

DOT Department of Transportation

FAIR Act Federal Activities Inventory Reform Act of 1998

FAR Federal Acquisition Regulation

FPDS-NG Federal Procurement Data System-Next Generation

GSA General Services Administration

HHS Department of Health and Human Services

NASA National Aeronautics and Space Administration

OFPP Office of Federal Procurement Policy

OMB Office of Management and Budget

State Department of State

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Page 1 GAO-12-1007 Civilian Service Contract Inventories 

United States Government Accountability Office 

Washington, DC 20548

September 27, 2012

Congressional Committees

Federal agencies rely on a multisector workforce of federal employees 

and contractor personnel to perform services needed to carry out their 

missions. These services include professional management support, 

information technology support, and medical support. In fiscal year 2011, 

federal civilian agencies reported $161 billion in total contract obligations, 

of which $126 billion, or almost 80 percent, were for services. 

Determining whether services should be performed by federal employees, 

contractor personnel, or a mixture of each is an important economic and 

strategic decision essential to the federal government’s effective and 

efficient use of taxpayers’ dollars. Certain functions that government 

agencies routinely perform, such as setting federal policy, issuing rules 

and regulations, or making best value determinations among contractors 

competing to provide needed goods or services are considered to be 

“inherently governmental” and must be performed by federal employees. 

In some cases, contractors may be performing services that are 

considered to be “closely associated with inherently governmental” 

functions, such as services to support policy makers or procurement 

officials. Agencies must give special management attention to these 

activities to guard against their expansion into inherently governmental 

functions. Other services, such as facilities maintenance or information 

technology support, may be obtained through a private contractor. 

In 2009, however, the President issued a memorandum on government 

contracting that expressed concerns about whether agencies have 

become overly reliant on contractors and if the government has 

outsourced services appropriately.1

 

1

The White House memorandum, Government Contracting (Mar. 4, 2009).

In particular, the President noted that 

the line between inherently governmental functions—those that must be 

performed by federal employees—and other services that may be 

contracted for has been blurred. In the memorandum, the President 

directed the Office of Management and Budget (OMB) to lead a series of 

contracting-related efforts including clarifying when outsourcing for 

services is appropriate.

 
 

Page 2 GAO-12-1007 Civilian Service Contract Inventories 

Congress has also expressed concern with agencies’ reliance on 

contractors and has directed OMB and other federal agencies to examine 

similar workforce issues, which include identifying functions that are not 

appropriate for contractors to perform or require increased government 

oversight. The Consolidated Appropriations Act of 2010 requires civilian 

federal agencies to compile an annual inventory of their service contracts 

and review their contracts and information in the inventories to determine, 

among other things, whether contracts are being performed in 

accordance with laws and regulations.2

In May 2011, we reported on OMB’s guidance and agency efforts to 

compile their fiscal year 2010 inventories.

In addition, the act requires that 

after reviewing the annual inventory, each agency must report to OMB on 

the actions taken to consider and convert functions from contractor to 

federal employee performance. Under the act, OMB is required to 

develop guidance to assist agencies in meeting the law’s requirements 

and to ensure that agencies compile their inventories in a consistent 

manner. The act also requires GAO to report to Congress on OMB’s 

guidance, and agency implementation of the service contract inventory 

requirement for fiscal years 2010 and 2011.

3

To assess agencies’ efforts to compile their fiscal year 2011 inventories, 

we reviewed the act, OMB guidance, and the proposed Federal 

Acquisition Regulation (FAR) rule on service contract inventories.

For this report, we assessed 

civilian agencies’ efforts to (1) compile their fiscal year 2011 inventories 

and (2) review and report on their fiscal year 2010 inventories. 

4 In 

addition, we obtained and reviewed available civilian agency inventories 

to determine whether they contained data elements required by OMB 

guidance. Further, we compared the obligations reported in their 

inventories with the Federal Procurement Data System— Next 

Generation (FPDS-NG) data.5

 

2

Pub. L. No. 111-117, § 743 (2009).

While our prior work identified data 

3

GAO, OMB Service Contract Inventory Guidance and Implementation, GAO-11-538R 

(Washington, D.C.: May 27, 2011).

4

The Federal Acquisition Regulation is the regulation used by federal executive agencies 

for acquisition of supplies and services with appropriated funds. 

5

FPDS-NG is the primary governmentwide contracting database, providing information on 

government contracting actions, procurement trends, and achievement of socioeconomic 

goals, such as small business participation. 
 

Page 3 GAO-12-1007 Civilian Service Contract Inventories 

reliability issues with FPDS-NG, for the purposes of this report, we found 

FPDS-NG data to be sufficiently reliable to determine how agencies 

compiled their inventories.6

We conducted this performance audit between April 2012 and September 

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.

To assess agencies’ efforts to review and 

report on their fiscal year 2010 inventories, we reviewed civilian agencies’ 

reports of the fiscal year 2010 inventory reviews to determine the number 

of contracts reviewed, the methodologies used, and the workforce issues 

identified. In cases where agencies identified contracts that may involve 

inherently governmental, or closely associated with inherently 

governmental functions, we did not independently assess whether the 

functions were in fact inherently governmental or closely associated with 

inherently governmental functions. We also selected five civilian 

agencies—the Department of Health and Human Services (HHS), the 

Department of Homeland Security (DHS), the Department of 

Transportation (DOT), the General Services Administration (GSA), and 

the National Aeronautics and Space Administration (NASA)—for a more 

in-depth review as to how they compiled and reviewed their service 

contract inventories. We selected these agencies because they represent 

approximately 42 percent of civilian agency service contract obligations 

for fiscal year 2011. Appendix I provides a detailed description of our 

scope and methodology.

The Consolidated Appropriations Act of 2010 requires the heads of 

executive civilian agencies subject to the Federal Activities Inventory 

Reform (FAIR) Act of 1998 to annually submit to OMB an inventory of 

service contract actions by December 31 of each year, beginning with 

 

6

For past reports on FPDS-NG see GAO, Contracting Strategies: Data and Oversight 

Problems Hamper Opportunities to Leverage Value of Interagency and Enterprisewide 

Contracts, GAO-10-367 (Washington, D.C.: Apr.29, 2010); and Federal Contracting: 

Observations on the Government’s Contracting Data Systems, GAO-09-1032T

(Washington, D.C.: Sept. 29, 2009).

Background
 

Page 4 GAO-12-1007 Civilian Service Contract Inventories 

fiscal year 2010 contracts.7 The requirement, according to OMB, applies 

to 49 executive agencies. Appendix II lists these agencies. The 

inventories are to include 15 data elements for all contracts awarded or 

extended in the preceding fiscal year, such as services purchased by the 

agency, the role the services played in achieving agency objectives, the 

total dollar amount obligated for services, and the number and work 

location of contractor and subcontractor personnel compensated under 

each contract. Agencies are required to make their inventories publicly 

available no later than 30 days after they submit their inventory to OMB.8

The act also directs agencies to review their inventories within 180 days 

of the December 31 deadline to ensure that:

• each personal service contract is being performed according to laws 

and regulations;9

• the agency is giving special management attention to functions that 

are closely associated with inherently governmental functions;

• the agency is not using contractor personnel to perform inherently 

governmental functions;

• the agency has specific safeguards and monitoring systems in place 

to ensure that work performed by contractors has not changed or 

expanded during performance to become an inherently governmental 

function;

• the agency is not using contractor personnel to perform critical 

functions that could jeopardize the ability of the agency to maintain 

control of its mission and operations; and

• there are sufficient internal agency resources to effectively manage 

and oversee contracts.

 

7

Pub. L. No. 111-117, § 743 (2009). The Federal Activities Inventory Reform Act of 1998, 

as amended (31 U.S.C. § 501 note), requires agencies to submit annual lists of activities 

that are not inherently governmental functions. Executive agencies subject to the FAIR Act 

include executive departments such as DHS, and independent establishments, such as 

NASA. 

8

Pub. L. No. 111-117, § 743(c).

9

A personal services contract is characterized by the employer-employee relationship it 

creates between the government and the contractor’s personnel. The government is 

normally required to obtain its employees by direct hire under competitive appointment or 

other procedures required by the civil service laws. Agencies are not permitted to award 

personal services contracts unless specifically authorized by statute to do so. (FAR § 

37.104.)
 

Page 5 GAO-12-1007 Civilian Service Contract Inventories 

Agencies must also identify contracts that (1) have been poorly 

performed, either because of excessive costs or inferior quality, and 

(2) should be considered for conversion to performance by federal 

employees, also known as insourcing, or an alternative acquisition 

approach to enable the agency to efficiently utilize its resources and 

achieve its public mission. The law requires that each agency include with 

its current inventory a report on the actions taken as a result of reviewing 

their prior year’s inventory and to make the report publicly available.

To aid agencies in establishing systems to collect the contract inventory 

information and to ensure consistency across agencies, the act required 

the Director of OMB to develop and disseminate guidance to agencies by 

March 1, 2010. OMB issued the guidance in November 2010. We 

previously reported on differences between the act and OMB guidance.10

• identify and record more than one type of service purchased for each 

contracting action entered into the system; 

For example, although the act did not set a minimum dollar threshold for 

the contracts included in the inventories, OMB directed agencies to report 

only on contract actions over $25,000. Additionally, OMB directed 

agencies to only report the data elements included in FPDS-NG. As a 

result, agencies did not report three data elements required by the statute 

in their fiscal year 2010 inventories—(1) the role the services played in 

achieving agency objectives, (2) the total dollar amount invoiced for 

services under the contract, and (3) the number and work location of 

contractor and subcontractor personnel. In recent reviews of both DOD 

and civilian agencies inventories, we also reported that FPDS-NG does 

not allow agencies to:

• capture any services performed under contracts that are 

predominantly for supplies; and

• capture service contracts awarded on behalf of an agency by other 

agencies.11

 

10GAO-11-538R.

 

11GAO, Defense Acquisitions: Further Actions Needed to Improve Accountability for 

DOD’s Inventory of Contracted Services, GAO-12-357 (Washington, D.C.: Apr. 6, 2012), 

GAO-11-538R; and Defense Acquisitions: Further Action Needed to Better Implement 

Requirements for Conducting Inventory of Service Contract Activities, GAO-11-192 

(Washington, D.C.: Jan. 14, 2011). 
 

Page 6 GAO-12-1007 Civilian Service Contract Inventories 

OMB also provided guidance to agencies on conducting and reporting 

their fiscal year 2010 inventory reviews. The guidance states that the 

reviews shall be informed through appropriate techniques, such as 

sampling of contract files, interviewing program managers and contracting 

officer technical representatives, and using other supplemental 

information-gathering methods as needed. Under OMB’s guidance, 

agencies should give heightened management consideration to certain 

“special interest functions” that require increased management attention 

due to heightened risk of workforce imbalance, such as agencies 

becoming overreliant on contractor personnel. OMB anticipated that 

professional and management services and information technology 

support services posed an increased risk of agencies losing control of 

their missions and operations. Table 1 provides an illustrative list of the 

special interest functions identified by OMB.

Table 1: Illustrative List of Special Interest Functions

Professional and Management Services

Cost Benefit Analyses

Policy Review/Development Services

Program Evaluation Services

Program Management/Support Services

Program Review/Development Services

Specifications Development Service

Management Services/Contract and Procurement Support

Intelligence Services

Engineering and Technical Services

Systems Engineering Services

Personal Services Contracts

Information Technology Support Services

Automated Data Processing (ADP) Systems Development Services

Automated Information Systems Services

ADP System Acquisition Support Services

ADP Backup and Security Services

Source: OMB.

The guidance also stated that as part of agencies’ reviews of professional

and management services, agencies should include acquisition support 

and an appropriate sampling of policy and program management and 

development services, and additional functions where the agency may be 
 

Page 7 GAO-12-1007 Civilian Service Contract Inventories 

at risk of overreliance on contractors or other challenges, such as 

inadequate contract management support.

In our review of fiscal year 2011 service contract inventories, we found 

that 48 of the 49 agencies compiled their inventories. However, agencies 

are continuing to defer collection of three required data elements, per 

OMB guidance. While most agencies followed OMB’s methodology for 

compiling inventories, some agencies used different methodologies. As a 

result, OMB and Congress cannot meaningfully use these service 

contract inventories to compare service contract obligations among 

agencies or develop spending trends, and agencies did not have a 

complete universe of service contracts to consider for review. 

OMB directed agencies to prepare a fiscal year 2011 service contract 

inventory, submit the inventory to OMB, and make it publicly available by 

January 30, 2012. During the course of our review we sought to obtain 

the inventories from each agency’s website and found that as of July 

2012, 14 of the 49 agencies did not make their inventories publicly 

available. We followed up with OMB and the agencies and eventually 

obtained inventories from 13 of those 14 agencies. For the remaining 

agency—the Court Services and Offender Supervision Agency for D.C.—

we could not find evidence that it compiled its service contract inventory 

for fiscal year 2011, and nor did it do so for fiscal year 2010. OMB staff 

indicated that they reminded the agency of its responsibility to prepare 

and submit an inventory, but they did not devote resources to compelling 

a response when the agency was not responsive. OMB staff explained 

that the agency’s total spending is well under 1 percent of civilian agency 

spending and attention on this initiative was more effectively devoted to 

other agencies and issues. OMB continued to direct agencies to defer 

collection of three statutorily required data elements—the role the 

services played in achieving agency objectives, total dollar amount 

invoiced for services under the contracts, and the number and work 

locations of contractor and subcontractor personnel. The lack of this 

required information diminished the utility of the inventory because

agencies do not have good visibility as to the number of contractor 

personnel or their role in supporting agency activities. 

Progress, however, is being made towards collecting this information. For 

example, OMB directed agencies to start collecting information on the 

role services play in achieving agency objectives for new contracts 

awarded on or after March 1, 2012. The guidance states that agencies 

The Utility of Service 

Contract Inventories 

May Be Diminished by 

Incomplete Data and 

Different Reporting 

Methodologies

Agencies Are Not Fully 

Complying with Inventory 

Reporting Requirements
 

Page 8 GAO-12-1007 Civilian Service Contract Inventories 

are to report, in the “description of requirement” field in FPDS-NG, 

whether the services provided under the contract are predominantly for 

functions closely associated with inherently governmental ones, critical 

functions, or other functions. According to OMB guidance, by identifying 

closely associated and critical functions at the time of award, agencies 

can prioritize which contracts may require increased management 

attention and oversight to ensure that mission creep does not result in 

contractor personnel performing inherently governmental functions, and 

ensure that the agency does not lose control of its mission and 

operations. While this information may be helpful in identifying which 

service contracts may require additional oversight or be appropriate 

candidates for insourcing, it is not clear that this information will provide a 

full description of the role contractors played in achieving agency 

objectives. OMB staff indicated that they will review this issue, along with 

others, as they consider revisions to the guidance based on initial agency 

experience. 

Information on the remaining two data elements—total dollar amount 

invoiced for services under the contracts and the number and work 

locations of contractor and subcontractor personnel—will continue to be 

deferred pending the outcome of a proposed FAR rule on service contract 

inventories. The proposed rule would create a new FAR subpart to 

address responsibilities for collection, management, and reporting of the 

inventory information. The rule would also create a new contract clause to 

be used in contracts that meet certain dollar thresholds and would require 

contractors to submit the following information for covered service 

contracts (1) the contract number and, when applicable, order number; 

(2) the total dollar amount invoiced for services performed during the 

previous fiscal year under the contract; (3) the number of contractor direct 

labor hours expended on the services during the previous fiscal year; and 

(4) the number of direct-labor hours expended on services performed by 

first-tier subcontractors.12

 

12Federal Acquisition Regulation; Service Contract Reporting Requirements, 76 Fed. Reg. 

22,070 (Apr. 20, 2011).

The proposed FAR rule is being reviewed by 

OMB and OMB staff anticipated that the rule would be finalized later this 

fall. The proposed rule provides that collection of the information be 

phased in over the next 4 years. Information will be collected directly from 

contractors through a web portal and housed in the System for Award 

Management. No additional hard copy reporting will be required. 
 

Page 9 GAO-12-1007 Civilian Service Contract Inventories 

OMB provided guidance to civilian agencies for compiling their service 

contract inventories, including the structure and scope of the inventories. 

To standardize the structure of the service contract inventories, OMB 

provided a template for agencies to organize contract activities by product 

and service code.13

• Forty-five agencies reported on all the data elements in OMB’s 

standard template. The other three agencies did not include certain 

data elements, such as the extent to which the contract was 

competed, the product and service code and description, and the date 

signed. OMB staff was unaware that these agencies had not reported 

on all data elements.

To establish the scope of the service contract 

inventories, OMB directed agencies to include all service contract actions 

over $25,000 that were awarded in fiscal year 2011. Agencies were to 

include contract actions that they have funded, including contract actions 

made on their behalf by other agencies, and exclude contract actions that 

they have made on another agency’s behalf with the other agency’s 

funding. We found the following based on our review of 48 available 

civilian agency inventories:

• Forty-three agencies generally followed OMB’s guidance to report on 

obligations on all contract actions over $25,000. Five agencies, 

however, did not. One agency—DOT—reported information on fiscal 

year 2010 obligations for its fiscal year 2011 inventory. DOT officials 

were unaware of this error until our review. A DOT official told us DOT 

sent a revised inventory with the correct fiscal year 2011 information 

to OMB. Three agencies—the National Endowment for the 

Humanities, the Selective Service System, and the U.S. Trade and 

Development Agency—incorrectly interpreted OMB’s guidance as 

limiting the scope of the inventory to just new awards for that fiscal 

year. As a result, these agencies underreported their inventories. 

OMB staff told us that they intended for civilian agencies to include all 

changes in obligations over $25,000 occurring in fiscal year 2011, 

regardless of when the contract award occurred. The fifth agency—

GSA—did not follow OMB’s guidance to include all contract actions 

over $25,000 awarded in fiscal year 2011. Instead, GSA included in 

its inventory only the obligations for contract actions related to the 

 

13Product and service codes describe the products, services, and research and 

development purchased by the federal government. The codes indicate what was bought 

for each contract action in FPDS-NG.

Most Agencies Followed 

OMB Guidance When 

Compiling Their 

Inventories
 

Page 10 GAO-12-1007 Civilian Service Contract Inventories 

special interest function product and service codes identified by OMB 

as priority areas for the inventory review. As a result, GSA excluded 

approximately $6.4 billion in service contracts from its inventory. In 

response to these findings, GSA officials noted that they are in the 

process of creating a new report with the correct information, which 

will be submitted to OMB. We used GSA as an example in figure 1 to 

illustrate the potential differences in obligations that would be reported 

based on the three different methodologies we identified. For 

instance, GSA’s obligations would be about $116 million if it only 

reported on special interest functions, $4.5 billion if it only reported on 

new awards, and $6.5 billion if it reported on all obligations for fiscal 

year 2011. 

Figure 1: Illustration of Variations in Service Contract Obligations for Fiscal Year 

2011 by Inventory Methodology (Using GSA Obligations)

Note: The information used for this analysis was based on data we obtained from FPDS-NG in 

February 2012. While we recognize that the data may change slightly over time after the end of a 

fiscal year, the analysis represents a snapshot of obligations for that time frame. 

OMB staff were unaware that some agencies used different 

methodologies to compile their inventories. OMB staff stated that

differences in agency methodologies were not readily apparent when they 

initially reviewed the inventories because data is organized differently 
 

Page 11 GAO-12-1007 Civilian Service Contract Inventories 

than how it would otherwise appear in FPDS-NG. In the absence of a 

consistent methodology, OMB and Congress cannot meaningfully 

compare service contract obligations among agencies or develop 

spending trends for agencies. Further, agency use of a different 

methodology resulted in a smaller population of contracts to sample from 

for their review. OMB staff acknowledged that the inconsistency in 

reporting methods may limit the utility of the inventories.

Forty of the 49 agencies conducted a review of their fiscal year 2010 

inventory and reported the results of their review. The other 9 agencies 

did not submit an inventory report to OMB or make their reports publicly 

available. Most agencies that conducted a review followed OMB guidance 

and reported on the number of product and service codes reviewed and 

the obligations for these product and service codes. However, since OMB 

did not require agencies to report the number of contracts reviewed or the 

percentage of obligations associated with the contracts reviewed, it is 

unclear how much of their inventories agencies actually reviewed. Based 

on reports submitted to OMB, 5 of the 40 agencies identified workforce 

issues such as functions that are not appropriate for contractors to 

perform, require increased government oversight, or require agencies to 

change the mix of contractor and government personnel performing a 

function. Specifically, the 5 agencies identified a total of 3 contracts where 

contractors could be performing inherently governmental functions and 

104 instances of contractors performing closely associated with inherently 

governmental functions. Agency officials identified several practices that 

may be effective for future reviews and decision-making efforts.

OMB directed agencies to conduct a meaningful review of their fiscal year 

2010 inventory and identify at a minimum (1) the special interest functions 

studied by the agency, including the dollars obligated to those specific 

product and service codes in fiscal year 2010; (2) the methodology used 

to support their reviews; (3) their findings; and (4) the actions taken or 

planned by the agency to address any identified weaknesses or 

challenges. Agencies were also directed to submit an inventory review 

report to OMB and make the report publicly available.

We collected the required reports for 40 of the 49 agencies, either from 

their websites or OMB. OMB staff confirmed that the remaining 

9 agencies, which accounted for less than 1 percent of civilian agency 

service contract obligations for fiscal year 2010, did not submit the 

Inventory Review and 

Reporting Efforts 

Could Be Improved

Most Agencies Reviewed 

Their Fiscal Year 2010 

Inventory, but the Extent 

of Review Is Unclear
 

Page 12 GAO-12-1007 Civilian Service Contract Inventories 

required information or made it publicly available. Table 2 lists these 

agencies.

Table 2: Agencies Not Submitting Fiscal Year 2010 Inventory Review Reports to 

OMB 

Broadcasting Board of Governors

Court Services and Offender Supervision Agency for D.C.

Federal Energy Regulatory Commission

Federal Maritime Commission

Merit Systems Protection Board

National Archives and Records Administration

National Endowment for the Arts

Selective Service System

U.S. Trade and Development Agency

Source: GAO analysis of reports collected through civilian agencies’ websites and OMB. 

We followed up with these agencies to determine why they did not submit 

the required information and received one response from the National 

Endowment for the Arts as to why it had not conducted an inventory 

review. An agency official told us the National Endowment for the Arts did 

not conduct a fiscal year 2010 inventory review because it did not have 

any service contracts for special interest functions as defined in OMB’s 

guidance.

Based on the reports submitted to OMB by 40 agencies, we observed 

that 

• Thirty-four agencies reported on the number of product and service 

codes reviewed and the associated obligations for these product and 

service codes. The number of product and service codes and 

obligations reviewed varied widely. For example, GSA reviewed 4 

product and service codes, while HHS reviewed 31 codes. OMB staff 

expected variance because agencies were directed to select service 

codes that warranted the agency’s increased management attention 

or posed an increased risk of workforce imbalances.

• Twenty-five agencies reported on the number of contracts they 

reviewed; however, OMB did not require agencies to provide this 

information. The number of contracts reviewed ranged from one 

contract by the Federal Labor Relations Authority to more than 
 

Page 13 GAO-12-1007 Civilian Service Contract Inventories 

2,000 contracts by the Department of the Interior. As shown in 

figure 2, the majority of the agencies reviewed less than 50 contracts. 

Figure 2: Number of Contracts Agencies Reviewed

More than a third of the 25 agencies, however, did not provide enough 

context in their reports for us to determine the percentage of contracts 

they reviewed, or the percentage of obligations that the selected contracts 

represented. This information would provide an indication of the extent to 

which agencies reviewed their inventories and context that would be 

important for oversight purposes. For example, DOT reported 

approximately $1.2 billion in contract obligations for the product and 

service codes it reviewed. The agency reviewed 42 contracts, but did not 

report how they selected these contracts or the percentage of obligations 

the contracts covered. These 42 contracts could represent anywhere from 

all of the contracts to a small fraction of the contracts in those product and 

service codes. NASA was one of the agencies that reported on the 

percentage of obligations covered under the contracts they reviewed. 

NASA reported that the eight contracts it chose to review represented 

more than 70 percent of the $3.2 billion in obligations for the two product 

and service codes on which it focused its review. 

The Consolidated Appropriations Act of 2010 required agencies to review 

their fiscal year 2010 inventories and report on the findings and actions 

taken as a result of the review. Of the 40 reports that were submitted to 

OMB, 5 agencies—the Department of Commerce (Commerce), DHS, 

GSA, HHS, and the Department of State (State)—identified a total of 3 

contracts where contractors could potentially be performing inherently 

Some Agencies Reported 

Workforce Issues 
 

Page 14 GAO-12-1007 Civilian Service Contract Inventories 

governmental functions and 104 instances of contractors performing 

closely associated with inherently governmental functions. 

• State identified two of the contracts where contractors could 

potentially perform inherently governmental functions, but did not 

identify, in its report, how many contractor personnel were involved. 

State officials explained that no inherently governmental functions 

have been outsourced. In its report, State identified a contract where 

contractors could potentially perform inherently governmental 

functions. State officials told us that this contract was for private 

security contractors that perform security functions. Officials explained 

that while this contract was originally thought to potentially include 

inherently governmental functions, upon further analysis, they 

determined that strategies currently in place—including increased 

oversight, pre-mission briefs, video recording of movement, and 

recording of radio traffic—mitigated this risk. In its report, State 

explained that the departure from government control is only 

temporary, and government officials typically provide contingency 

direction to contractors in these instances.

• DHS identified one contract as containing potentially inherently 

governmental functions. This contract was for watch officer support for 

the Transportation Security Administration Call Center. DHS officials 

stated that this contract included 5.5 full-time equivalent positions, 

which the component planned to insource, but has delayed action 

pending an organizational review to determine if the agency still 

needs the positions.

• Each of the five agencies reported instances where contractors were 

identified as performing functions closely associated with inherently 

governmental functions. HHS was the only agency that reported that it 

insourced positions as a result of their findings. The other four 

agencies provided mixed responses as to whether their project 

managers or contracting officers’ representatives provided sufficient 

monitoring of activities and performance for these contracts. For 

example, State reported that while one contract received special 

management attention, a number of acquisition and program staff 

were unclear whether there was sufficient oversight for their contracts. 

The act and OMB guidance also directed agencies to ensure that there 

are sufficient internal resources to effectively manage and oversee 

contracts. To do this, for example, DHS asked its components to report 

the number of federal workers providing oversight and management of 

service contracts. Similarly, NASA officials told us that they conducted 
 

Page 15 GAO-12-1007 Civilian Service Contract Inventories 

interviews with contracting officers and contracting officers’ 

representatives to determine whether contractor personnel had 

appropriate oversight. 

Three of the five agencies we reviewed—DHS, HHS, and NASA—

identified workforce issues and took steps to resolve them. Table 3 

summarizes these findings and the actions that these agencies have 

taken or planned to take to resolve their workforce issues. While the 

resolutions were outlined in the agencies’ reports, we followed up with the 

agencies to obtain the status of their resolutions.

Table 3: Selected Agency Inventory Analysis Findings and Resolutions

Agency Workforce issue Proposed resolution Resolution status

DHS One contract containing potentially inherently 

governmental functions

Insource 5.5 full-time equivalents Officials stated that this 

resolution is pending 

internal review

HHS Two functions at risk of becoming inherently 

governmental functions

Insource 22 full-time equivalents; redefine 

contractor roles and responsibilities

Officials stated that this 

resolution is complete

Two functions that are closely associated with 

inherently governmental functions

Insource 14 full-time equivalents; eliminate 

unnecessary contractor positions; reassign work 

to federal employees

HHS noted in its report 

that this resolution was 

complete

NASA Federal full-time equivalents needed to 

maintain control and oversight of mission

Insource 4 full-time equivalents Officials stated that this 

resolution is complete

Source: GAO analysis of civilian agency data.

As shown in the table, some agencies reported their workforce issues as 

functions, while others reported them in terms of contracts. Agencies that 

report their issues in terms of contracts present a challenge because a 

service contract can include multiple functions. As a result, it is unclear 

whether the issue identified is pertinent to the entire contract or a specific 

function within a contract. 

Officials at two of the five agencies we visited stated more generally that if 

workforce issues were to be identified, the agencies may not be able to 

take immediate action due to resource limitations. For example, officials 

from DHS cited instances where components could not implement 

insourcing recommendations because they could not secure the full-time 

equivalent positions to do so. While OMB requires that agencies report, at 

a minimum, the actions taken or planned by the agency to address any 

identified weaknesses or challenges, OMB staff agreed with our 

observation that it would be helpful if agencies also reported on the 

resolution of any findings identified as part of their inventory review in 
 

Page 16 GAO-12-1007 Civilian Service Contract Inventories 

future reports. We recently reported that DOD had not resolved workforce 

issues identified during its fiscal year 2009 inventory review and in some 

instances, contractors continued to perform functions identified as being 

inherently governmental a year after they were originally identified.14 

According to OMB staff, some agencies struggled with their inventory

review efforts and OMB intends to have agencies share lessons learned 

to help facilitate future efforts. Officials at the five agencies we selected 

for a more in-depth review identified several practices they found effective 

in reviewing their fiscal year 2010 inventories, including using crossfunctional teams, leveraging existing related efforts, and obtaining 

management support. Two of these agencies also used the inventories 

for strategic sourcing purposes.15

• Using Cross-Functional Teams: Four of the five agencies we 

reviewed employed cross-functional teams and some agency officials 

noted that the team helped them to resolve workforce issues. For 

example, the DHS cross-functional teams included representatives 

from acquisition, budget and finance, general counsel, and human 

resources at both the department and component levels. DHS officials 

stated that the department-level team is equipped to resolve issues 

involving costly or high-visibility contracts and has enabled DHS to 

determine if workforce balance issues were widespread or only 

affected certain components. HHS also used cross-functional teams, 

which allowed the agency to identify and expeditiously resolve 

workforce imbalance issues. For instance, HHS identified two 

functions in the areas of acquisition assistance and human resource 

classification specialists that the agency felt were more appropriately 

suited for execution by federal employees. HHS took corrective action 

by hiring 14 government employees, eliminating unnecessary 

contractor support and reassigning work to federal employees as 

necessary. 

• Leveraging Existing Efforts: Two agencies—NASA and DHS—

leveraged other ongoing efforts to conduct their reviews, thus 

 

14GAO-12-357. 

15Strategic sourcing is the collaborative and structured process of critically analyzing an 

organization’s spending and using this information to make business decisions about 

acquiring commodities and services more effectively and efficiently.

Agencies Identified 

Practices That May Help 

Future Efforts
 

Page 17 GAO-12-1007 Civilian Service Contract Inventories 

reducing the amount of additional resources dedicated to the effort. 

For example, NASA incorporated the findings of an ongoing 

information technology program and a workforce pilot into their 

service contract inventory review. NASA reported it selected the 

workforce pilot because portions of the work being studied were 

perceived to be either critical or inherently governmental functions. 

Further, leveraging knowledge gained from the information technology 

program allowed NASA to include several high visibility information 

technology acquisitions in their reviews without having to 

independently review all the contracts associated with them. 

DHS relied on its existing Balanced Workforce Strategy to conduct the 

required inventory reviews and used its standardized Balanced 

Workforce Strategy Tool to review 212 service contracts. The tool is 

an automated decision support survey that enables components to 

categorize work as inherently governmental, personal services, 

closely associated with an inherently governmental function, or a 

critical function. The tool is also intended to facilitate an assessment 

of mission risk, level of contractor oversight needed, mitigation 

strategies, and cost analysis. Based on component responses, the 

tool is to provide a recommended sourcing decision on whether the 

work is appropriate for federal or contractor performance, or both.

• Obtaining Management Support: Officials at four of the five 

agencies we reviewed had significant and visible management 

support and involvement, which helped facilitate inventory review 

efforts and department-level decision making. For example, the 

Assistant Secretary for Financial Resources at HHS, who also serves 

as the agency’s Chief Acquisition Officer, issued a memorandum to 

division heads outlining the requirements of the inventory review 

process. According to HHS’ senior procurement executive, this helped 

ensure participation from all divisions, and the agency was able to 

address redundancies and duplications from an enterprisewide 

perspective because of management involvement in the review. In 

contrast, GSA officials stated that management was kept up to date 

on, but did not actively participate in, the effort. Additionally, the GSA 

official responsible for overseeing the inventory review said that, to his 

knowledge, the inventory had not been used for any department-level 

decision making. 

• Strategic Sourcing: Some agencies reported that they used the 

inventories to identify redundancies and duplications, which led to 

strategic sourcing decisions. For example, HHS officials stated that 

the agency used its inventory to obtain visibility into redundant 
 

Page 18 GAO-12-1007 Civilian Service Contract Inventories 

contracts across the department. As a result, it consolidated 

15 service contracts into 4 contracts, resulting in an estimated savings 

of $20 million. DOT reported that it concentrated its analysis efforts on 

management support services contracts to identify ways to reduce 

spending in these areas by 15 percent by the end of fiscal year 2012.

The Consolidated Appropriations Act of 2010 required agencies to collect 

information and compile an inventory of their service contracts and review 

the inventories to help agency officials determine, among other things, 

whether they have the right balance of contractor and in-house resources 

needed to accomplish their missions. If the service contract inventories 

are to be a valuable management tool, it is essential that civilian 

agencies’ inventories contain comprehensive, accurate, and actionable 

data. OMB plays an important role in ensuring that agencies are meeting 

statutory requirements and providing useful information. OMB efforts to 

date have been focused on issuing guidance to agencies on how to 

compile, review, and report on their service contract inventories. 

However, civilian agency efforts are in the early stages and agencies 

have not been able to meet all the requirements for compiling and 

reviewing the service contract inventories. In some cases this is due to 

the fact that some of the statutorily required data elements to be 

contained in the inventories are not available. Under the proposed FAR 

rule, if finalized, agencies would start collecting unavailable, but required 

data elements directly from contractors. In other cases, agencies 

misinterpreted or did not follow OMB’s guidance, which caused them to 

significantly underestimate the scope of their inventories. 

Although most agencies followed OMB guidance for reporting on their 

inventory reviews, it is unclear based on the information provided in their 

reports whether the results of the reviews were a real indication of the 

agencies’ effective and appropriate use of contractors or due to the 

different approaches used to conduct the inventory reviews. When 

workforce issues were identified, such as contractors performing 

potentially inherently governmental functions, agencies did not 

consistently report on the number of contractor personnel and functions 

involved. Further, three of the five agencies that we reviewed identified 

workforce issues and took corrective action. However, the agencies did 

not report if the issues had been fully resolved. Agencies were not 

required to report on either the number of contracts or the percentage of 

their inventories they reviewed. As a result, many of the reports did not 

have important context on the scope of the analyses performed. Without 

OMB’s continued guidance and agency commitment to improve the 

Conclusions
 

Page 19 GAO-12-1007 Civilian Service Contract Inventories 

compliance, consistency, and context for the inventory and inventory 

reviews, the utility of the inventories for agency decision making and OMB 

and congressional oversight will be limited.

To help improve civilian agency compliance for compiling, reviewing, and 

reporting on inventories, we recommend that the Administrator of OMB’s 

Office of Federal Procurement Policy work with agencies to improve how 

compliance with statutory and OMB requirements is monitored, which 

might include agencies designating accountable officials to ensure 

appropriate internal management attention and responsiveness.

To help ensure that the service contract inventories contain consistent 

and reliable information and that the service contract inventory analysis 

reports have sufficient information to provide greater context and value, 

we recommend that the Administrator of OMB’s Office of Federal 

Procurement Policy clarify guidance to:

• Require agencies to fully describe in their inventory review reports the 

scope of the inventory reviews, including information such as the 

number of contracts and the percentage of contracts reviewed for 

each product and service code selected and the total universe of 

contracts;

• Require agencies to consistently report on the number of contractor 

personnel and functions that were involved with the workforce issues 

identified during their inventory reviews; and 

• Require agencies to include, as part of their inventory review reports, 

the status of agency efforts to resolve findings identified in previous 

reviews until they are resolved.

We requested comments on a draft of this report from DHS, DOT, HHS, 

GSA, NASA, and OMB. HHS and NASA responded that they did not have 

comments. DHS, DOT, and GSA provided us with technical comments, 

which we incorporated as appropriate. OMB provided comments via email, stating that it generally concurs with our recommendations. More 

specifically, OMB stated that it believes a service contract inventory is a 

useful management tool for assisting an agency in better understanding 

how contracted services are being used to support mission and 

operations and where opportunities may exist for improvement. Moving 

forward, OMB commented that the Office of Federal Procurement Policy 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 20 GAO-12-1007 Civilian Service Contract Inventories 

(OFPP) intends to work with agencies to strengthen their use of this tool 

by sharing lessons learned and best practices derived from the initial 

inventories, such as the promising practices highlighted in the report. 

OMB also commented on our first recommendation and asked that we 

modify it to shift primary responsibility for monitoring inventory compliance 

from OMB to the civilian agencies. OMB stated that OFPP is a policymaking organization, not an enforcement agency, and greater progress 

can be achieved if OFPP works collaboratively with agencies by 

continually refining the guidance to make it a more useful management 

tool and ensuring agencies are doing effective self-governance, such as 

with the help of an accountable official that can liaison with OFPP to 

ensure appropriate management attention is being given to this initiative. 

In recognition that conducting and reviewing the service contract 

inventory is an agency responsibility, and to ensure that civilian agencies 

are held accountable for complying with statutory and OMB requirements, 

we agreed to modify the recommendation.

We are sending copies of this report to the Director of the Office of 

Management and Budget; Secretaries of the Department of Health and 

Human Services, the Department of Homeland Security, and the 

Department of Transportation; the Administrators of the General Services 

Administration and the National Aeronautics and Space Administration; 

and interested congressional committees. In addition, the report is 

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

If you have any questions about this report or need additional information, 

please contact me at (202) 512-4841 or huttonj@gao.gov. Contact points 

for our Office of Congressional Relations and Public Affairs may be found 

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

appendix IV.

John P. Hutton

Director

Acquisition and Sourcing Management
 

Page 21 GAO-12-1007 Civilian Service Contract Inventories 

List of Committees

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 Richard J. Durbin

Chairman

The Honorable Jerry Moran

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

United States Senate

The Honorable Darrell E. Issa

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Jo Ann Emerson

Chairwoman

The Honorable José E. Serrano

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

House of Representatives
Appendix I: Scope and Methodology

Page 22 GAO-12-1007 Civilian Service Contract Inventories 

Section 743 of the 2010 Consolidated Appropriations Act directed GAO to 

report on the second annual service contract inventory that civilian 

agencies were required to submit to the Office of Management and 

Budget (OMB) by December 31, 2011. To satisfy the mandate, we 

assessed civilian agencies’ efforts to (1) compile their fiscal year 2011 

inventories and (2) review and report on their fiscal year 2010 inventories. 

To assess civilian agencies’ efforts to compile their fiscal year 2011 

inventories, we reviewed the act and OMB guidance to determine what 

data elements were required to be included in the service contract 

inventories. In addition, we obtained and reviewed available civilian 

agency inventories to determine whether they contained data elements 

required by OMB guidance. We also reviewed the proposed Federal 

Acquisition Regulation (FAR) rule on service contract inventories and 

interviewed staff from OMB to determine the status of efforts to collect all 

required inventory data elements. In addition, we used OMB guidance 

and conducted a logic check for five selected agencies—the Department 

of Health and Human Services, the Department of Homeland Security, 

the Department of Transportation, the General Services Administration, 

and the National Aeronautics and Space Administration—to ensure that 

the obligations reported by these agencies were close to our own analysis 

of the Federal Procurement Data System—Next Generation (FPDS-NG) 

data. These agencies were selected because they represent 

approximately 42 percent of total fiscal year 2011 service contract 

obligations for civilian agencies. In addition, they are also among the 

agencies with the largest obligations for the special interest functions 

identified by OMB for heightened management consideration because 

they present an increased risk of losing control of mission and operations.

During our logic check, we identified differences between obligations the 

agencies reported in their inventories and what we obtained by applying 

OMB guidance. To determine if these differences were more widespread, 

we expanded our logic check to all available agency inventories. To 

determine possible reasons for these differences, we pulled data from 

FPDS-NG by funding agency using eight different methodologies for fiscal 

year 2011—all obligations for service contract actions; obligations for 

service contract actions over $25,000; obligations for new awards; 

obligations for new awards over $25,000; all obligations for special 

interest product and service code contract actions; obligations for special 

interest product and service code contract actions over $25,000; 

obligations for new awards on special interest product and service code 

contract actions; and all obligations for new awards on special interest 

product and service code contract actions over $25,000. After our initial 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology

Page 23 GAO-12-1007 Civilian Service Contract Inventories 

comparison, we determined that the difference between the obligations in 

all categories and those above $25,000 was small. In addition, we 

determined that only one agency had reported its inventory using the 

special interest function methodology. Therefore, we reported only three 

main methodologies—all obligations, new awards, and special interest 

functions. While our prior work identified data reliability issues with FPDSNG, for the purposes of this report, we found FPDS-NG data to be 

sufficiently reliable for determining how agencies compiled their 

inventories. We also identified agencies with missing elements to 

determine what data elements were missing from their inventories.

To assess the result of agencies’ efforts to review and report on their 

fiscal year 2010 inventories, we reviewed civilian agencies’ reports on the 

fiscal year 2010 inventory review submitted to OMB to determine the 

number of contracts that were analyzed, the methodologies used, and the 

workforce issues identified. While we reported the workforce issues 

identified, we did not independently assess whether the functions the 

civilian agencies identified were in fact inherently governmental or closely 

associated with inherently governmental functions. In addition, for the five 

selected agencies, we interviewed officials to identify the resources used 

and methodologies they applied to conduct the reviews, as well as 

challenges they encountered, lessons learned, and practices they 

identified that can be applied to future reviews. We also met with agency 

officials to determine the extent to which agencies have used their 

reviews for decision making, including workforce planning and strategic 

sourcing efforts, and to determine how agencies identified instances in 

which contractors were performing inherently governmental functions or 

functions closely associated with inherently governmental functions.

We conducted this performance audit between April 2012 and September 

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: Forty-Nine Agencies Required to 

Report on Service Contract Inventories 

Page 24 GAO-12-1007 Civilian Service Contract Inventories 

Agency for International Development 

Broadcasting Board of Governors

Commodity Futures Trading Commission

Consumer Product Safety Commission

Court Services and Offender Supervision Agency for D.C.

Defense Nuclear Facilities Safety Board

Department of Agriculture

Department of Commerce 

Department of Education

Department of Energy 

Department of Health and Human Services 

Department of Homeland Security 

Department of Housing and Urban Development 

Department of Justice 

Department of Labor 

Department of State 

Department of the Interior 

Department of Transportation 

Department of the Treasury 

Department of Veterans Affairs 

Environmental Protection Agency 

Equal Employment Opportunity Commission

Federal Communications Commission

Federal Election Commission

Federal Energy Regulatory Commission

Federal Labor Relations Authority

Federal Maritime Commission

Federal Trade Commission

General Services Administration 

International Trade Commission

Merit Systems Protection Board

National Aeronautics and Space Administration 

National Archives and Records Administration

National Endowment for the Arts

National Endowment for the Humanities

National Labor Relations Board

National Science Foundation 

National Transportation Safety Board

Nuclear Regulatory Commission 

Office of Management and Budget

Office of Personnel Management 

Office of Special Counsel

Peace Corps

Appendix II: Forty-Nine Agencies Required to 

Report on Service Contract Inventories 
Appendix II: Forty-Nine Agencies Required to 

Report on Service Contract Inventories 

Page 25 GAO-12-1007 Civilian Service Contract Inventories 

Railroad Retirement Board

Securities and Exchange Commission

Selective Service System

Small Business Administration 

Social Security Administration 

U.S. Trade and Development Agency
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 26 GAO-12-1007 Civilian Service Contract Inventories 

John P. Hutton, (202) 512-4841 or huttonj@gao.gov 

Key contributors to this report were Cheryl Andrew, Assistant Director; 

Richard Burkard; Danielle Greene; Laura Jezewski; Julia Kennon; Bryan 

Miller; and Guisseli Reyes-Turnell.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 27 GAO-12-1007 Civilian Service Contract Inventories 

Defense Acquisitions: Further Actions Needed to Improve Accountability 

for DOD’s Inventory of Contracted Services. GAO-12-357. Washington, 

D.C.: April 6, 2012.

Government Operations: OMB Service Contracts Inventory Guidance and 

Implementation. GAO-11-538R. Washington, D.C.: May 27, 2011.

Defense Acquisitions: Further Action Needed to Better Implement 

Requirements for Conducting Inventory of Service Contract Activities. 

GAO-11-192. Washington, D.C.: January 14, 2011.

Related GAO Products

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