United States General Accounting Office

GAO Report to Congressional Committees

February 1995 ACQUISITION

MANAGEMENT

Waivers to Workforce

Training, Education,

and Experience

Requirements

GAO/NSIAD-95-88

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-260059 

February 1, 1995

The Honorable Strom Thurmond

Chairman,

The Honorable Sam Nunn

Ranking Minority Member

Committee on Armed Services

United States Senate

The Honorable Floyd Spence

Chairman, 

The Honorable Ronald Dellums

Ranking Minority Member

Committee on National Security

House of Representatives

To address long-standing criticisms of the Department of Defense’s (DOD)

management of acquisition programs, Congress enacted the Defense

Acquisition Workforce Improvement Act (10 U.S.C. 1701 et seq.) on

November 5, 1990. The act was intended to professionalize DOD’s

acquisition workforce by establishing education, training, and experience

requirements that were to take effect over a 3-year period, beginning

October 1991.

The act permits DOD officials to waive specific qualification requirements if

(1) unusual circumstances justify the waiver or (2) the individual’s

qualifications obviate the need for meeting the requirements. It also

requires that, through 1998, our office annually report on DOD’s compliance

with the act’s waiver provisions. This is our fourth waiver report.1

 We have

also reported on DOD’s overall implementation of the act.2

In conjunction with the waivers, we also obtained information on DOD’s

use of fulfillments as authorized by an amendment to the act. Fulfillments

enable individuals to receive credit when they already have the required

competencies instead of taking training courses.

1

Defense Management: Implementation of the Defense Acquisition Workforce Improvement Act

(GAO/NSIAD-92-97, Jan. 31, 1992); Acquisition Management: Waivers to Acquisition Workforce

Training, Education, and Experience Requirements (GAO/NSIAD-93-128, Mar. 30, 1993); and DOD

Acquisition: Fiscal Year 1993 Waivers to Acquisition Workforce Requirements (GAO/NSIAD-94-92,

Feb. 16, 1994).

2

Acquisition Management: Implementation of the Defense Acquisition Workforce Improvement Act

(GAO/NSIAD-93-129, Apr. 26, 1993).

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Background The quality and professionalism of DOD’s acquisition workforce has been

an issue for over 30 years. In 1986, the President’s Blue Ribbon

Commission on Defense Management (the Packard Commission)

described the DOD acquisition workforce as “undertrained, underpaid, and

inexperienced.” In July 1989, DOD’s Defense Management Review reported

many of the same problems and recommended a series of specific

management initiatives to improve the acquisition process and more

effectively manage DOD resources.

The Defense Acquisition Workforce Improvement Act requires the

Secretary of Defense to establish an acquisition workforce with specific

experience, education, and training qualifications. Specific provisions of

the act require the Secretary of Defense to (1) establish a management

structure along with policies and regulations for implementing the act’s

provisions, (2) establish qualification requirements, (3) provide training

and education to meet these requirements, and (4) enhance civilian

opportunities to progress to senior acquisition positions.

Fiscal year 1994 was the first year that all the act’s provisions were in

effect. The effective dates for DOD’s implementation of the act’s

qualification requirements are staggered from October 1, 1991, through

October 1, 1993.

No later than October 1, 1991, newly appointed program managers of

major3

 and significant nonmajor defense acquisition programs were to

• complete the program management course4 (or a comparable course);

• possess acquisition experience, at least 8 years for major defense

acquisition programs (2 of which are in a systems program office or

similar organization), and at least 6 years for significant nonmajor

programs; and

• agree to a tenure requirement that they remain in their position until they

complete the first major milestone closest in time to the date they have

3

A “major defense acquisition program” is defined to include a DOD acquisition program that is not

highly sensitive or classified and whose research and development cost is expected to exceed

$300 million in fiscal year 1990 dollars or whose procurement cost is expected to exceed $1.8 billion in

fiscal year 1990 dollars. Significant nonmajor defense acquisition programs are other programs that are

estimated to require eventual total expenditures (based on constant fiscal year 1980 dollars) of more

than (1) $75 million in research, development, test and evaluation or (2) $300 million for procurement

for a major system.

4

The program management course is 20 weeks in length and is DOD’s primary defense acquisition

course. Taught at the Defense Systems Management College at Fort Belvoir, Va., this DOD-wide course

addresses a variety of acquisition issues, including policy, financial, technical, life-cycle, and contract

management. The Naval Post-Graduate School has been designated as an equivalent for purposes of

meeting the program management course requirements.

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served 4 years (3 years for program managers of significant nonmajor

defense acquisition programs) and sign a written agreement to remain on

active duty (or federal service) during the period.

Beginning October 1, 1992, deputy program managers must have 6 years of

acquisition experience and, along with program executive officers, have

completed the program management course. In addition, before being

assigned as a program executive officer and before general and flag

officers and civilian equivalents are assigned to a critical acquisition

position, they must have 10 years experience in acquisition positions. Four

years of this experience must have been in a critical acquisition position.

Senior contracting officials must have 4 years experience in contracting in

order to fill a critical position in contracting.

Beginning October 1, 1993, contracting officers must have (1) completed

all mandatory contracting courses; (2) gained at least 2 years of

contracting experience; and (3) received a baccalaureate degree with at

least 24 semester hours in business disciplines, or passed an equivalency

examination along with additional requirements established by the

Secretary of Defense.

Each service was also required to establish an acquisition corps consisting

of senior civilian and military personnel who meet specific education,

experience, and training requirements. An individual must be a member of

the acquisition corps to be appointed to a critical acquisition position.

According to the act, individuals in critical acquisition positions as of

October 1, 1993, who did not meet corps position requirements were

required to (1) meet those requirements within 6 months, (2) be given a

waiver, or (3) be removed from the position. If an individual occupying a

critical position does not meet the act’s education, training, or experience

requirements after a 6-month grace period, the service must either

“grandfather”5

 the individual or issue a waiver.

The act also requires the services to establish a management information

system capable of providing standardized information on acquisition

positions and the training, education, and experience of individuals filling

them. The services are to use the systems to monitor various acquisition

workforce personnel actions to ensure compliance with the act’s

requirements. DOD estimates that about 114,000 acquisition positions are

subject to the training, education, and experience requirements of the act.

5

The act excepts acquisition workforce employees having at least 10 years of acquisition experience as

of October 1, 1991.

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The National Defense Authorization Act for Fiscal Year 1993 authorized

the use of fulfillment standards as a substitute to the act’s training

requirements. The Secretary of Defense developed fulfillment standards in

January 1993 to include a formal process for determining whether an

individual has demonstrated competence in the areas of the mandatory

training courses. The fulfillment standards are effective retroactively to

November 5, 1990, and cease to be in effect on October 1, 1997.

Results in Brief During fiscal year 1994, the military services and DOD agencies granted a

total of 63 waivers (50 from the military services and 13 from DOD

agencies) to 59 individuals not meeting the education, training, and

experience requirements of the act. Fiscal year 1994 was the first time

defense agencies reported granting waivers. Of the waivers granted,

• 44 were for military personnel,

• 20 were for program managers and deputy program managers,

• 18 were for individuals in critical acquisition positions,

• 13 were for program managers or deputy program managers not meeting

tenure requirements, and

• 10 were for contracting officers.

No waivers were granted for the act’s program management course

requirement for program and deputy program managers.

The Air Force is requiring individuals already occupying critical

acquisition positions to meet the act’s training, education, and experience

requirements. Instead of grandfathering those already in critical positions,

the Air Force has issued temporary waivers to 177 individuals not meeting

the act’s requirements. These temporary waivers are different from the

other waivers in that they are set to expire in 17 months. Since the

temporary waivers were granted, 75 of the individuals have met the

requirements. The other services are grandfathering individuals already

occupying critical positions. The services did not have detailed data on

personnel being grandfathered.

Waivers Approved During fiscal year 1994, the military services and DOD agencies granted a

total of 63 waivers to 59 individuals not meeting the requirements. Most

were program managers and deputy program managers; and, as in 1993,

the majority of the waivers were granted to military personnel, seven of

whom were general officers. Ten waivers were granted to contracting

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officials and 18 waivers were given to individuals occupying critical

acquisition positions. Defense agencies granted waivers for the first time

in fiscal year 1994. Table 1 summarizes the waivers approved by each

service.

Table 1: Summary of Waivers

Approved for Fiscal Year 1994

Reason for waiver Army Navy Air Force

Defense

agencies Total

Acquisition experience 5 5 2 0 12

Tenure 5 2 16 0 23

Acquisition corps 1 3 4 10 18

Contracting officials 0 7 0 3 10

Total 11 17 22 13 63

Table 2 compares waivers granted in fiscal year 1994 with fiscal years 1992

and 1993. It shows that waivers for acquisition experience and tenure both

increased, while waivers for the program management course declined to

zero. In fiscal years 1992 and 1993, the program management course

requirement accounted for 70 percent and 33 percent of the waivers,

respectively. The decline is due, in part, to (1) the new fulfillment

standards published by DOD, (2) increases in courses available to meet the

requirements, and (3) a reduced backlog of personnel requiring the course.

The table also shows waivers to acquisition corps and contracting officer

requirements that took effect in October 1993.

Table 2: Waivers Approved Between

Fiscal Years 1992 and 1994 Reason why waiver was needed FY92 FY93 FY94

Lack of acquisition experience 22 4 12

Did not have program management course 23a 10 0

Did not fulfill tenure 3 16 23

Did not meet corps acquisition requirementsb • • 18

Did not meet requirements for contracting

positionsb

• • 10

aThe 22 individuals receiving waivers for acquisition experience also received waivers for the

program management course.

bThis requirement was not in effect in fiscal years 1992 and 1993.

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Acquisition Experience

Waived

Five Army waivers, five Navy waivers, and two Air Force waivers were

granted to individuals who lacked the required acquisition experience. All

12 waivers were given to military officers, 5 of whom were general officers

(4 in the Army and 1 in the Air Force). The number of acquisition

experience waivers has varied considerably from year to year; from

67 percent (22 of 33) in fiscal year 1992, to only 13 percent (4 of 30) in

fiscal year 1993, to 19 percent (12 of 63) in fiscal year 1994.

In fiscal year 1992, we noted that the Army waived requirements for

individuals who had no acquisition experience at all or who lacked several

years of acquisition experience. In 1994, the Army waived acquisition

experience requirements for officers who lacked, on average, 3.9 years of

experience necessary to meet the requirements of the act. The Air Force

waived requirements for two individuals and the Navy waived

requirements for four individuals needing an average of 4 and 2.7 years of

acquisition experience, respectively.

Tenure Waived Twenty-three waivers were granted to individuals who failed to fulfill the

tenure requirements. Like prior years, the majority of the tenure waivers

were for reassignment. For example, in fiscal year 1993, 50 percent (8 of

16) of the tenure waivers were for individuals being reassigned and in

fiscal year 1994, 74 percent (17 of 23) of the waivers were for individuals

being reassigned. Of these, 12 of the 17 individuals are Air Force

personnel. Five of the tenure waivers in fiscal year 1994 were for

individuals retiring before completing their required term, same as in fiscal

year 1993. One of the tenure waivers was for a promotion.

Acquisition Corps

Requirements Waived

Eighteen individuals not meeting the applicable education, experience,

and/or certification requirements received waivers because they were

already in critical positions. The Air Force approved only four of these

waivers. However, they also approved numerous temporary waivers for

essentially the same reason.

The Air Force is requiring individuals occupying critical acquisition

positions to join its acquisition corps and meet the act’s training,

education, and experience requirements. Consequently, it needed to

identify all Air Force personnel in critical acquisition positions who were

not certified as meeting the requirements. Using its management

information system, the Air Force identified 177 such individuals 

(91 military and 86 civilians). On December 23, 1993, the Air Force granted

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these individuals temporary waivers with an expiration date of March 1,

1995. Since the Air Force issued this list of individuals not meeting the

corps requirements, 75 individuals have met those requirements, 

46 individuals are no longer occupying a critical acquisition position, and 

56 individuals are still on the list. They have until March 1, 1995, to meet

the qualification requirements. In contrast, the Army and the Navy did not

issue temporary waivers, preferring the options of (1) permanent waivers

and (2) grandfathering individuals occupying critical acquisition positions.

Contracting Positions

Requirements

In general, the act’s requirements for contracting officers in acquisition

positions include (1) completion of mandatory contracting courses, (2) at

least 2 years of contracting experience, and (3) a baccalaureate degree or

at least 24 semester credit hours in specific disciplines. In fiscal year 1994,

10 individuals received waivers for such training, experience, and

education standards. In all cases, these individuals had not completed the

required education and/or experience.

Fulfillments Fulfillment means that the training requirement has been satisfied through

other means, such as experience. Individuals seeking fulfillment approval

must submit fulfillment packages to the authorized approval authority.

Each service has established its own fulfillment policies and procedures,

which vary considerably.

DOD officials believe that, generally, fulfilling the act’s requirements

through alternative means is more desirable than waiving the act’s

requirements. In fiscal year 1994, four fulfillments were approved for the

program management course—all for Army personnel.

DOD’s Office of the Director of Acquisition Education, Training, and Career

Development is not required to track fulfillments, but does so for two

courses: the Program Management 301 Course and the Information

Resources Management 302 Course. DOD officials believe that tracking

such statutory requirements improves general oversight and has allowed

them to appropriately influence the services’ implementation of the act’s

provisions.

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Agency Comments We provided DOD acquisition officials a draft of this report and we

discussed the report results with officials from the Army, the Navy, the Air

Force, and the Office of the Secretary of Defense. The officials generally

concurred with the information in this report.

Scope and

Methodology

Our review covered the Departments of the Army, the Navy, and the Air

Force; the Office of the Secretary of Defense; and the other DOD agencies.

We obtained the fiscal year 1994 waiver documentation and fulfillments

for the program management and the information resource management

courses from the Office of the Director, Acquisition Education, Training,

and Career Development Policy within the Office of the Secretary of

Defense. For those waivers submitted and approved, we assessed the

justification for the waivers using criteria contained in the act; DOD

Instruction 5000.52, Defense Acquisition Education, Training, and Career

Development Program, dated October 25, 1991; and the Under Secretary of

Defense’s October 25, 1991, policy memorandum, which was superseded

by DOD Instruction 5000.58, “Defense Acquisition Workforce,” dated

January 14, 1992.

The services’ and defense agencies’ management information systems

cannot readily identify and report on all acquisition personnel that do not

meet the act’s training, education, and experience requirements. However,

the Director, Acquisition Education, Training, and Career Development

Policy stated that they closely track acquisition corps waivers. We did not

independently assess the accuracy of data in DOD’s management

information systems.

We performed our review between August and December 1994 in

accordance with generally accepted government auditing standards.

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We are sending copies of this report to the Secretaries of Defense, the

Army, the Navy, and the Air Force and to other interested congressional

committees. We will also make copies available to others upon request.

Please contact me at (202) 512-4587 if you or your staff have any questions

concerning this report. Appendix I lists the major contributors to this

report.

David E. Cooper

Director, Acquisition Policy, Technology,

 and Competitiveness Issues

Page 9 GAO/NSIAD-95-88 Acquisition Management
Appendix I 

Major Contributors to This Report

National Security and

Internal Affairs

Division, Washington,

D.C.

James F. Wiggins, Associate Director

Clifton E. Spruill, Assistant Director

Cincinnati Field

Office

Rae Ann Sapp, Regional Manager Representative

Myra Watts, Evaluator-in-Charge

(705060) Page 10 GAO/NSIAD-95-88 Acquisition Management
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