Report to Congressional Committees

United States General Accounting Office 

GAO

April 2004 MILITARY 

PERSONNEL 

General and Flag 

Officer Requirements 

Are Unclear Based 

on DOD’s 2003 Report 

to Congress 

GAO-04-488 
www.gao.gov/cgi-bin/getrpt?GAO-04-488.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Derek Stewart 

at (202) 512-5559 or stewartd@gao.gov. 

Highlights of GAO-04-488, a report to 

congressional committees 

April 2004

MILITARY PERSONNEL

General and Flag Officer Requirements 

Are Unclear Based on DOD’s 2003 Report 

to Congress 

DOD’s March 2003 report to Congress did not fully disclose the results of the 

general and flag officer study or explain its recommendation not to seek 

additional authorizations (people) to meet validated requirements 

(positions). The general and flag officer study validated requirements for 

general and flag officer positions that exceeded congressional authorizations 

for both the active and reserve components. However, the validated 

requirements data generated by the study were not disclosed in the 

March 2003 report to Congress. In its report, DOD did not address the 

magnitude of the gap between validated requirements of 1,630 positions and 

congressional authorizations of 1,311—a difference of 319. DOD’s report also 

did not address the impact of “workarounds” used to fill the gap between 

requirements and authorizations, such as the practice of assigning colonels 

and Navy captains to general and flag officer positions. Fully disclosing the 

study results and discussing the implications of these findings in the 

March 2003 report to Congress would have provided a more complete 

picture of DOD’s general and flag officer requirements and may have helped 

to explain its recommendation not to seek additional authorizations. 

DOD used an established methodology to conduct a position-by-position 

validation of general and flag officer requirements. This methodology, 

known as job evaluation, has been widely used in the United States. Job 

evaluation, however, has numerous subjective features, including the 

selection of factors used for measurement. In addition, it is not designed to 

project emerging needs, such as those that could result from transformation 

efforts. Periodic updates could capture changes in requirements. Such 

limitations do not invalidate DOD’s methodology; however, an explicit 

acknowledgment and assessment of these limitations would have provided 

more context for the study results. In addition, the study did not clearly 

account for dual-hatted positions (where one individual holds more than one 

position simultaneously) or assess how each service’s authorizations were 

affected by the need to contribute general and flag officers to fill external 

(joint) positions. Addressing these issues could have enhanced the precision 

and usefulness of DOD’s study. In addition, we noted that while Congress 

directed DOD to ensure the Reserve Forces Policy Board participated in 

development of the report’s recommendations, the Board played a minimal 

role in producing DOD’s 2003 report. The Board registered strong objections 

to DOD’s recommendation not to seek additional authorizations now to meet 

validated requirements and to the limited role it played in the process. 

DOD, in conducting its 2003 general and flag officer study, incorporated 

some of the lessons learned from a GAO review of DOD’s 1997 general and 

flag officer study. DOD recognized the need to identify general and flag 

officer positions that could conceivably be converted from the military ranks 

to the civilian workforce, although it deferred this assessment until after the 

general and flag officer study was complete. DOD is currently assessing 

civilian conversion of general and flag officer positions. 

The Fiscal Year 2003 National 

Defense Authorization Act directed 

the Department of Defense (DOD) 

to assess whether general and flag 

officer authorizations were 

sufficient to meet all requirements. 

GAO’s objectives were to 

determine whether DOD (1) fully 

disclosed the results of its study in 

its March 2003 report to Congress 

and explained the rationale for any 

recommendations, (2) used an 

established methodology to meet 

the objectives of its study, and 

(3) incorporated lessons learned 

from a GAO review of DOD’s 1997 

general and flag officer study. The 

2003 act also directed DOD to 

review legislation affecting general 

and flag officer management. DOD 

included the results of its review in 

the March 2003 report, making 

several recommendations. GAO 

plans a separate review of these 

issues and recommendations. 

GAO recommends that DOD take 

the following actions: (1) clarify the

magnitude and impact of the gap 

between DOD’s validated 

requirements for general and flag 

officers and congressional 

authorizations, (2) periodically 

update its general and flag officer 

requirements, (3) enhance the 

precision and usefulness of the 

study results, and (4) incorporate 

the results of an ongoing study to 

assess civilian conversion of 

general and flag officer positions. 

In commenting on a draft of this 

report, DOD agreed with the 

recommendations. 
Page i GAO-04-488 General and Flag Officer Requirements 

Letter 1

Results in Brief 2

Background 4

Results of General and Flag Officer Study Were Not Fully 

Disclosed in DOD’s March 2003 Report to Congress 6

DOD Used an Established Methodology, but Precision and 

Usefulness of Results Could Be Enhanced 12

DOD Incorporated Lessons Learned From GAO’s Review of DOD’s 

1997 General and Flag Officer Study 21

Conclusions 24

Recommendations for Executive Action 25

Agency Comments and Our Evaluation 25

Scope and Methodology 26

Appendix I Sixteen Factors Used to Validate General and Flag 

Officer Requirements 29 

Appendix II Adjustments Made to General and Flag Officer 

Requirements After LMI’s Scoring Assessment 32 

Appendix III Comments From the Department of Defense 35 

Tables 

Table 1: Pay Grade, Title, and Insignia Worn at General and Flag 

Officer Ranks 4

Table 2: Validated Requirements for General and Flag Officer 

Positions in the Active Component 7

Table 3: Validated Requirements for General and Flag Officer 

Positions in the Reserve Component 8

Table 4: Congressional Authorizations for General and Flag 

Officers by Service 9

Table 5: Service Contributions to External (Joint) General and Flag 

Officer Requirements in the Active Component 

(as of December 2002) 19

Contents 
Page ii GAO-04-488 General and Flag Officer Requirements 

Table 6: Service Contributions to External (Joint) General and Flag 

Officer Requirements in the Reserve Component 

(as of December 2002) 19

Table 7: Pay Grade Adjustments Approved by the Senior Panel and 

Requested by Service and Joint Staff Senior Leadership 32

Figure 

Figure 1: Gap Between General and Flag Officer Authorizations 

and Requirements 11

Abbreviations 

DOD Department of Defense 

LMI Logistics Management Institute 

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Page 1 GAO-04-488 General and Flag Officer Requirements 

April 21, 2004 

The Honorable John W. Warner 

Chairman 

The Honorable Carl Levin 

Ranking Minority Member 

Committee on Armed Services 

United States Senate 

The Honorable Duncan Hunter 

Chairman 

The Honorable Ike Skelton 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

Congress places specific legislative limits on the military services’ general 

and flag officers, including ceilings on the maximum number of general 

and flag officers each service is authorized. In the Fiscal Year 2003 

National Defense Authorization Act, Congress directed the Secretary of 

Defense to study general and flag officer authorizations and to provide an 

assessment of whether authorizations were sufficient to meet all general 

and flag officer requirements. The mandate directed the Secretary of 

Defense to submit the results of this study in a report to Congress. The 

Department of Defense (DOD) conducted a study to validate general and 

flag officer requirements and subsequently submitted a report to Congress 

in March 2003. The 2003 act required GAO to evaluate DOD’s study. As 

agreed with your offices, our objectives were to determine whether DOD 

(1) fully disclosed the results of the general and flag officer study in its 

March 2003 report to Congress and explained the rationale for any 

recommendations, (2) used an established methodology to meet the 

objectives of its study, and (3) incorporated lessons learned from a GAO 

review of DOD’s 1997 general and flag officer study. The 2003 act also 

directed DOD to review legislation affecting the management of general 

and flag officers. DOD included the results of its review in the March 2003 

report and made several recommendations. We plan to conduct a separate 

review of these management issues and recommendations; we do not 

address them in this report. 

To conduct our review, we reviewed the results of DOD’s general and flag 

officer requirements study, supporting documentation, and the March 2003 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-488 General and Flag Officer Requirements 

report to Congress. We also discussed the study methodology with DOD 

officials in the Office of the Under Secretary of Defense for Personnel and 

Readiness, the military services, the Joint Staff, and others. We conducted 

our review from October 2003 to March 2004 in accordance with generally 

accepted government auditing standards. More information on our scope 

and methodology is provided at the end of this letter. 

DOD officials worked with a contractor to support the study effort and 

participated in developing and refining the study methodology, gathering 

and validating the data, and reviewing and approving the study results. The 

study results were also vetted through the service and Joint Staff senior 

leadership before being finalized. For DOD’s general and flag officer study, 

“authorizations” were defined as the number of general and flag officers 

allowed under the law (people) and “requirements” as billets the DOD 

components claim should be filled by a general or flag officer (positions). 

DOD’s March 2003 report to Congress did not fully disclose the results of 

the general and flag officer study or explain its recommendation that 

authorizations not be increased to meet validated requirements. The 

general and flag officer study validated requirements for general and flag 

officer positions that exceeded congressional authorizations for both the 

active and reserve components. However, the validated requirements data 

generated by the study were not disclosed in the March 2003 report to 

Congress. DOD did not address the magnitude of the gap between 

validated requirements of 1,630 general and flag officer positions and 

congressional authorizations of 1,311 general and flag officers—a 

difference of 319. DOD also did not address the impact of “workarounds” 

used to fill the gap between validated requirements and congressional 

authorizations, such as the practice of assigning colonels and Navy 

captains to general and flag officer positions. Although DOD’s March 2003 

report makes several recommendations concerning management of 

general and flag officers, the report did not recommend additional 

authorizations until other options could be explored for more effectively 

managing its senior leadership. However, the report did not explain what 

these other options might be or otherwise provide a convincing case that 

current congressional authorizations were sufficient in light of the study 

results. Fully disclosing the study results and discussing the implications 

of these findings in the March 2003 report to Congress would have 

provided a more complete picture of DOD’s general and flag officer 

requirements and may have helped to explain DOD’s recommendation not 

to seek additional authorizations. 

Results in Brief 
Page 3 GAO-04-488 General and Flag Officer Requirements 

DOD used an established methodology to conduct a position-by-position 

validation of general and flag officer requirements. This methodology, 

known as job evaluation, has been widely used in the United States. 

Job evaluation, however, has numerous subjective features, including the 

selection of factors used for measurement. In addition, it is not designed 

to project emerging needs, such as those that could result from 

transformation efforts. Periodic updates could capture changes in 

requirements. Such limitations do not invalidate DOD’s methodology; 

however, an explicit acknowledgement and assessment of these 

limitations would have provided more context for the study results. In 

addition, the study did not clearly account for dual-hatted positions 

(where one individual holds more than one position simultaneously) or 

assess how each service’s authorizations were affected by the need to 

contribute general and flag officers to fill external (joint) positions. 

Addressing these issues could have enhanced the precision and 

usefulness of DOD’s study. In addition, we noted that while Congress 

directed DOD to ensure the Reserve Forces Policy Board participated in 

development of the report’s recommendations, the Board played a 

minimal role in producing DOD’s 2003 report. The Board registered 

strong objections to DOD’s recommendation not to seek additional 

authorizations now to meet validated requirements and to the limited role 

it played in the overall process. 

DOD, in conducting its 2003 general and flag officer study, incorporated 

some of the lessons learned from a GAO review of DOD’s 1997 general 

and flag officer study. A notable improvement was the use of a single 

methodology and set of factors in the 2003 study to evaluate general and 

flag officer positions across all the services and the joint community. DOD 

also improved its tracking and documentation of adjustments made to 

study results. Finally, DOD recognized the need to identify general and flag 

officer positions that could conceivably be converted from the military 

ranks to the civilian workforce, although it deferred this assessment until 

after the general and flag officer study was complete. DOD is currently 

assessing civilian conversion of general and flag officer positions. 

This report contains recommendations to DOD aimed at clarifying the 

magnitude and the impact of the gap between validated requirements 

for general and flag officer positions and congressional authorizations, 

updating general and flag officer requirements on a periodic basis, 

enhancing the precision and usefulness of the study results, and 

incorporating the results of the ongoing study to assess civilian conversion 

of general and flag officer positions. In its comments on a draft of this 

report, DOD agreed with the report’s recommendations. 
Page 4 GAO-04-488 General and Flag Officer Requirements 

Congress has established four military ranks above the rank of colonel (for 

the Army, Air Force, and Marine Corps) and captain (for the Navy). 

Table 1 displays the pay grade designation, title of rank, and insignia worn 

by officers at general and flag officer ranks. 

Table 1: Pay Grade, Title, and Insignia Worn at General and Flag Officer Ranks 

 Title of rank 

Pay grade Army, Air Force, Marine Corps Navy Insignia

O-10 General Admiral 4 stars 

O-9 Lieutenant General Vice Admiral 3 stars 

O-8 Major General Rear Admiral 2 stars 

O-7 Brigadier General Rear Admiral (lower half) 1 star 

Sources: Title 10 U.S. Code and DOD. 

Within the Office of the Under Secretary of Defense for Personnel and 

Readiness, the Officer and Enlisted Personnel Management office is 

responsible for general and flag officer matters, including the application 

of related legislation. Each of the services and the Joint Staff has a general 

officer matters office that is responsible for management of general and 

flag officers within their organization. Management of reserve component 

general and flag officers falls under the service general officer matters 

offices, the service reserve chiefs, and the National Guard Bureau. Their 

responsibilities include managing the selection, promotion, assignment, 

and retirement of general /flag officers in addition to coordination with 

other DOD and non-DOD organizations. 

The Reserve Forces Policy Board, acting through the Assistant Secretary 

of Defense for Reserve Affairs, is the principal policy adviser to the 

Secretary of Defense on matters relating to the reserve components. 

The Board was created by an act of Congress in 1952. Among its duties, 

the Board evaluates proposals by its members or other agencies for 

changes to existing laws and policies and recommends appropriate 

actions. The Board is composed of 24 members, including a civilian 

chairman and the assistant secretaries of the Army, Navy, and Air Force 

responsible for reserve components. 

Background 

General and Flag Officer 

Ranks 

Roles and Responsibilities 
Page 5 GAO-04-488 General and Flag Officer Requirements 

The Fiscal Year 1997 National Defense Authorization Act directed the 

Secretary of Defense to review existing statutory general and flag officer 

authorizations and submit a report to Congress. The act also directed GAO 

to evaluate DOD’s study. The military services and Joint Staff conducted 

their own studies. On the basis of these study results, DOD developed a 

draft report; however, it never issued a final report. We testified on DOD’s 

study in April 1997 and issued a report in June 1997 that discussed the 

draft DOD report.1

 Congress included similar mandate language in the 

Fiscal Year 2003 National Defense Authorization Act. As in 1997, the 

Secretary of Defense was directed to review existing statutory general and 

flag officer authorizations and submit a report to Congress.2

 The report 

was to include any recommendations (together with the rationale) 

concerning revision of the limitations on general and flag officer grade 

authorizations. The act also stated that certain provisions of the Fiscal 

Year 1997 National Defense Authorization Act would apply.3

 One of the 

applicable provisions from the 1997 act directed GAO to evaluate 

DOD’s study.4

To respond to the 2003 mandate, the Office of the Secretary of Defense 

contracted with the Logistics Management Institute (LMI) to assess and 

validate general and flag officer requirements. The results of the 

requirements study were expected to serve as a baseline of validated 

general and flag officer positions and provide a basis for future efforts, 

such as identifying innovative ways to manage senior leadership. The 

Assistant Secretary of Defense (Force Management Policy)5

 established a 

working panel and a senior panel to support LMI’s review. The working 

panel was chaired by the Director, Officer and Enlisted Personnel 

Management, and included representatives from the military services’ and 

Joint Staff’s general and flag officer management offices and from the 

 1

 U.S. General Accounting Office, General and Flag Officers: DOD’s Draft Study Needs 

Adjustments, GAO/T-NSIAD-97-122 (Washington, D.C.: Apr. 8, 1997) and U.S. General 

Accounting Office, General and Flag Officers: Number Required Is Unclear Based on 

DOD’s Draft Report, GAO/NSIAD-97-160 (Washington, D.C.: June 16, 1997). 

2

 Public Law 107-314, section 404(c). 

3

 Public Law 107-314, section 404(c)(2) and corresponding provision in Public Law 104-201, 

sections 1213(b) through (e). 

4

 Public Law 104-201, section 1213 (e). 

5

 This position has been replaced by the Principal Deputy Under Secretary of Defense 

(Personnel and Readiness). 

Congressional Mandates 

in 1997 and 2003 to 

Review Authorizations 

DOD’s Study of General 

and Flag Officer 

Requirements and the 

March 2003 Report to 

Congress 
Page 6 GAO-04-488 General and Flag Officer Requirements 

Office of the Secretary of Defense. The senior panel was chaired by the 

Deputy Assistant Secretary of Defense for Military Personnel Policy, with 

participation by the service personnel chiefs, the Joint Staff’s Director for 

Manpower and Personnel, and representatives from the Office of the 

Secretary of Defense. The general and flag officer study was completed in 

March 2003. DOD subsequently submitted its report to Congress on 

March 31, 2003.6

DOD has conducted several previous reviews of its general and flag 

officer requirements. In the 1997 draft report, DOD identified a need for 

1,472 general and flag officers, including 1,018 active component and 

454 reserve component officers. According to DOD, the 1997 study was the 

first to integrate active and reserve component requirements. A 1988 DOD 

study found a requirement for 1,436 general and flag officer positions. 

A 1978 DOD study identified a requirement for 1,419 general and flag 

officers. In 1972, DOD identified a requirement for 1,304 general and flag 

officers. Congressional authorizations for general and flag officers 

typically have been lower than requirements identified in DOD’s studies. 

The general and flag officer study validated total requirements for 

1,630 general and flag officer positions. Congress, since fiscal year 1996, 

has authorized the services a total of 1,311 general and flag officers, a 

difference of 319. DOD, in the March 2003 report to Congress, 

recommended no additional authorizations to meet validated 

requirements. DOD did not explain its rationale for keeping authorizations 

at current levels, except to say that other options for managing general 

and flag officers were being considered. The report also did not provide 

the requirements data generated by the general and flag officer study, nor 

did it address the magnitude or the impact of the gap between 

requirements and authorizations. 

 6

 Office of the Under Secretary of Defense (Personnel and Readiness), Review of 

Active Duty and Reserve General and Flag Officer Authorizations (Washington, D.C.: 

March 2003). 

Previous DOD Studies 

of General and Flag 

Officer Requirements 

Results of General 

and Flag Officer Study 

Were Not Fully 

Disclosed in DOD’s 

March 2003 Report 

to Congress 
Page 7 GAO-04-488 General and Flag Officer Requirements 

The general and flag officer study validated requirements for a total of 

1,630 general and flag officer positions, including 1,039 validated 

requirements in the active component and 591 validated requirements in 

the reserve component. Tables 2 and 3 display results from DOD’s study. 

Table 2: Validated Requirements for General and Flag Officer Positions in the Active Component 

 Service/external (joint) 

 Army Air Force Navy Marine Corps External (joint)aTotal

By grade 

O-7 145 104 133 27 115 524

O-8 101 82 52 40 65 340

O-9 34 31 33 12 30 140

O-10 6 8 6 2 13 35

Total 286 225 224 81 223 1,039

By functional area 

Operations 97 92 56 38 78 361

Combat development 70 20 13 14 8 125

Material 52 40 60 6 22 180

Headquarters staff 44 54 72 22 113 305

Special staff 23 19 23 1 2 68

Total 286 225 224 81 223 1,039

Source: GAO analysis of DOD data. 

a

In the general and flag officer study, internal (service-specific) positions were separated from 

external (joint) positions. 

DOD Study Validated 

Requirements for 

1,630 General and Flag 

Officer Positions 
Page 8 GAO-04-488 General and Flag Officer Requirements 

Table 3: Validated Requirements for General and Flag Officer Positions in the Reserve Component 

 Service/external (joint) 

 Army Air Force Navy Marine Corps External (joint)aTotal

By grade 

O-7 163 157 47 5 28 400

O-8 70 66 18 7 30 191

Total 233 223 65 12 58 591

By functional area 

Operations 98 67 18 10 8 201

Combat development 79 10 1 0 4 94

Material 22 16 10 0 5 53

Headquarters staff 16 106 24 2 40 188

Special staff 18 24 12 0 1 55

Total 233 223 65 12 58 591

Source: GAO analysis of DOD data. 

a

In the general and flag officer study, internal (service-specific) positions were separated from 

external (joint) positions. 

Title 10 of the U.S. Code establishes service-specific ceilings for active 

duty general and flag officers that total 877.7

 Title 10 also authorizes 

12 general and flag officer positions to be allocated by the Chairman of 

the Joint Chiefs of Staff to the services for joint duty positions. These 

authorizations, called the “Chairman’s 12,” do not count against the service 

ceilings.8

 In addition, DOD is authorized a maximum of 422 reserve 

component general and flag officers. Title 10 of the U.S. Code establishes 

service ceilings for reserve component general and flag officers.9

 Congress 

last revised service ceilings in fiscal year 1996. Table 4 displays 

congressional authorizations for general and flag officers. 

 7

 10 U.S.C., section 526. 

8

 10 U.S.C., section 526(b). 

9

 10 U.S.C., section 12004. The provision excludes from these ceilings officers serving in 

certain positions, including those serving as adjutants general or assistant adjutants general 

of a state, those serving in the National Guard Bureau, and others. 
Page 9 GAO-04-488 General and Flag Officer Requirements 

Table 4: Congressional Authorizations for General and Flag Officers by Service 

 Active component 

Service Service ceiling Chairman’s 12aReserve component Total

Army 302 5 207 514

Air Force 279 3 157 439

Navy 216 4 48 268

Marine Corps 80 0 10 90

Total 877 12 422 1,311

Sources: Title 10 U.S. Code and DOD. 

a

The Chairman’s 12 are not associated with specific positions. As a matter of policy, the Chairman of 

the Joint Chiefs of Staff has allocated these positions to the services (Chairman of the Joint Chiefs of 

Staff Instruction 1331.01B). The Marine Corps was not allocated any Chairman 12 positions because 

it lacked sufficient general and flag officers at the O-9 and O-10 levels to contribute to this pool. 

On the basis of the general and flag officer study results, DOD found that 

the number of validated requirements for general and flag officer positions 

exceeded the number of general and flag officers currently authorized 

under law. DOD concluded in its March 2003 report to Congress that all 

current authorizations for active and reserve general and flag officers 

were needed. Although DOD’s report made several recommendations 

concerning management of general and flag officers,10 DOD recommended 

no change to the authorized number of general and flag officers or their 

grades at this time. 

DOD, in the March 2003 report, did not explain its rationale for keeping 

general and flag officer authorizations at current levels. DOD’s stated 

rationale for not requesting additional authorizations was that before the 

department considers proposing a legislative increase in authorizations, it 

must look at other innovative ways to meet these requirements. DOD did 

not specify the options it would consider except to say that it intended to 

review its overall senior leadership needs, including both civilian and 

military leaders, and might seek authority to manage senior leaders under 

an overall ceiling. DOD stated that until this review was complete, the 

services would continue to meet their internal and external general and 

 10 For example, the report recommends that legislation limiting the number of active 

officers who may serve above the grade of O-7 to no more than 50 percent of the total 

number of general and flag officers be repealed. 

DOD Did Not Explain 

the Rationale for 

Keeping Authorizations 

at Current Levels 
Page 10 GAO-04-488 General and Flag Officer Requirements 

flag officer requirements using available management tools as 

“workarounds,” such as use of individuals selected for promotion to higher 

grades and frocking authority.11 DOD did not state when this review would 

be complete. 

In the March 2003 report, DOD did not address the magnitude or the 

impact of the gap between validated requirements and authorizations. The 

general and flag officer study summarized the validated requirements by 

active and reserve component, by service, and by grade. More detailed 

data was provided in a database of validated requirements that was 

developed as part of the study. However, the March 2003 report did not 

disclose this data or address the magnitude of the gap between validated 

requirements and authorizations. The total gap between validated 

requirements and authorizations was 319. In the active component, the 

study validated requirements for 1,039 general and flag officer positions, 

compared with 889 authorizations (a difference of 150). In the reserve 

component, the study validated requirements for 591 general and flag 

officer positions, compared with 422 authorizations (a difference of 169). 

These gaps are illustrated in figure 1. 

 11 10 U.S.C., section 777(d) authorizes the services to allow up to 55 colonels/Navy captains 

to wear the insignia of brigadier general/rear admiral (lower half) prior to promotion, a 

practice known as “frocking.” An officer may be frocked only after the Senate has approved 

the promotion, and the officer is serving in or has received orders to serve in a position for 

which the grade to which the officer has been approved for promotion is authorized. 

10 U.S.C., section 777(b). 
Page 11 GAO-04-488 General and Flag Officer Requirements 

Figure 1: Gap Between General and Flag Officer Authorizations and Requirements 

While the March 2003 report noted that the services would continue to use 

frocking and other “workarounds” to meet requirements, it did not address 

the impact of these workarounds. Following are examples of workaround 

issues that DOD did not address in its report: 

• How do the services determine which positions to fill with an officer at a 

lower grade? Are some validated requirements going unfilled altogether? 

• Do officers at lower pay grade levels have legal authority to carry out all 

duties required of a general and flag officer position? 

• Does the practice of assigning lower grade officers to general and flag 

officer positions affect the ability of an organization to perform its 

mission? 

• What is the impact of these workarounds on the overall management of 

general and flag officers and of officers in lower grades? 

• Are there benefits to using these workarounds, such as providing 

developmental opportunities for officers in lower grades? Do the benefits 

outweigh any negative effects of using these workarounds? 

• To what extent have each of the services used these workarounds? 
Page 12 GAO-04-488 General and Flag Officer Requirements 

DOD used an established methodology known as job evaluation to assess 

general and flag officer requirements. Job evaluation methodologies have 

been widely used in the United States to assess job value and rank one job 

against another. One limitation of job evaluation is that it has numerous 

subjective features, including the selection of job factors to be assessed. 

The factors used in DOD’s study were subject to differing interpretations. 

Another limitation is that the methodology is based on an existing 

organizational structure at a designated point in time. The methodology is 

not designed to capture new or emerging needs, such as those resulting 

from DOD transformation efforts or other changes in the department. 

Periodic updates could capture changes in requirements. Such limitations 

do not invalidate DOD’s methodology; however, an explicit 

acknowledgment and assessment of these limitations would have provided 

more context for the study results. In addition, the study did not clearly 

account for dual-hatted positions or assess how each service’s 

authorizations were affected by the need to contribute general and flag 

officers to fill external (joint) positions. Addressing these issues could 

have enhanced the precision and usefulness of DOD’s study. In addition, 

we noted that while Congress directed DOD to ensure the Reserve 

Forces Policy Board participated in development of the report’s 

recommendations, the Board played a minimal role in producing the 

DOD 2003 report. The Board registered strong objections to 

DOD’s recommendation not to seek additional authorizations now to 

meet validated requirements and to the limited role it played in the 

overall process. 

To assess and validate general and flag officer requirements, DOD applied 

an established methodology known as job evaluation. Job evaluation 

methodologies have been widely used in the United States and were used 

in past general and flag officer studies, including the 1997 and 

1988 studies. Job evaluation is a formal procedure for hierarchically 

ordering a set of jobs in terms of their value or worth to the organization. 

No universally accepted approach to job evaluation exists, and several 

types of job evaluation methodologies may be used. DOD’s 2003 study was 

not explicit about the type of job evaluation methodology used but 

appeared to be a point-factor system. While point-factor systems may vary, 

the basic steps involved are gathering job descriptions for all jobs, 

selecting the factors to be used for measurement, identifying benchmarks 

for comparing jobs in a similar industry or field, assigning weights to the 

factors, assigning numerical values to the selected factors, and 

establishing a rank band. DOD’s study included all of these steps in its job 

evaluation methodology except for identifying benchmarks. Benchmarks 

DOD Used an 

Established 

Methodology, but 

Precision and 

Usefulness of Results 

Could Be Enhanced 

DOD Used Job Evaluation 

Methodology to Assess 

General and Flag Officer 

Requirements 
Page 13 GAO-04-488 General and Flag Officer Requirements 

are typically used when the purpose of the evaluation is to determine 

appropriate compensation. 

The steps in the general and flag officer study were as follows: 

• At LMI’s request, the services and the Joint Staff submitted data on all of 

their general and flag officer positions and on a sample of colonel and 

Navy captain positions. 

• The working panel established five functional groups to categorize the 

positions to be assessed. These five groups were operations, combat 

development, material, headquarters staff, and special staff. The working 

panel and LMI selected factors to be used in the assessment and weighted 

the factors for each functional group. 

• LMI placed the submitted positions into the five functional groups. The 

senior panel validated the functional groups, the factors, and the 

weighting. 

• For the positions to be assessed, the services and the Joint Staff gathered, 

validated, and entered information about each factor into a database 

created by LMI. 

• Using the database information, nine LMI scorers assessed each position 

by assigning numerical values to the factors and rank-ordered the 

positions within their functional groups. The LMI scorers were retired 

military officers representing a cross section of the military services, as 

well as the active and reserve components. They were divided into three 

panels of three members each. 

• The senior panel reviewed and validated the LMI scoring, including the 

breakpoints between pay grades (for example, between O-7s and O-8s). 

Results were then vetted through the service and Joint Staff senior 

leadership. 

A basic aim of job evaluation methodologies is to interject objectivity into 

what is inherently a subjective process—assigning the relative value of 

work to an organization. Nevertheless, subjectivity is commonly a part of 

job evaluation. For example, the factors selected for measurement and the 

weighting of the factors are based on subjective judgment. Also, the 

process of scoring jobs is subjective, as are management adjustments to 

the study results. 

A second limitation of job evaluation methodology is an assumption that 

an existing organizational structure can serve as an adequate starting point 

for the assessment. The methodology reviewed current positions and was 

not designed to capture new or emerging needs. According to the Joint 

Staff, the study methodology, as well as time constraints, did not give them 

Job Evaluation 

Methodology Has 

Certain Limitations 
Page 14 GAO-04-488 General and Flag Officer Requirements 

the opportunity to identify unresourced general and flag officer 

requirements. DOD efforts to reorganize the Army, alter the overseas 

presence of U.S. troops, and transfer thousands of military jobs to the 

civilian workforce, if implemented, could change requirements for general 

and flag officers. Such changes could be captured through periodic 

updates to the requirements. According to an official in the Office of the 

Under Secretary of Defense for Personnel and Readiness, the services and 

Joint Staff have been asked to submit new general and flag officer 

requirements to keep the data current. We agree that identifying new 

requirements is a necessary step to keep the data up-to-date; however, 

these new requirements are not going through the kind of job evaluation 

assessment and validation DOD used in its study. 

We found that neither the DOD study nor the March 2003 report to 

Congress addressed the limitations in the methodology selected. For 

instance, neither document specified the subjective features of the 

methodology or the assumptions underlying the study. In addition, they 

did not explicitly state the steps taken to test the reliability or validity of 

the study. These issues do not invalidate the results of the general and flag 

officer study, but an explicit acknowledgement and assessment of these 

issues would have provided more context for the study results. 

A critical step in job evaluations is the selection of factors to be measured. 

Because the factors are used to assess job value, the selection of these 

factors can influence the study results. LMI reviewed the factors used in 

the 1997 general and flag officer study and found similarities among them 

that could be traced to a set of 16 factors that predated the 1997 study. The 

origin of the 16 factors, however, is unclear. According to the general and 

flag officer study, the 16 factors originated in the deliberations of the Bolte 

commission in the late 1950s.12 An LMI official told us neither LMI nor the 

services could locate the original source document for the 16 Bolte 

factors; hence, LMI used a secondary service source to identify these 

factors. Two service regulations—Marine Corps Order 5311.4, 

dated September 30, 1986, and OPNAV Instruction 5420.87A, 

 12 The Department of Defense Ad Hoc Committee to Study and Revise the Officer 

Personnel Act of 1947, chaired by General Charles L. Bolte, USA (retired), was established 

to study the basic laws, regulations, and practices pertaining to the career management 

pattern of officer personnel. In 1960, the committee issued its report, A Concept of 

Career Management for Officer Personnel of the Armed Services (Washington, D.C.: 

Dec. 16, 1960). We did not find any mention of the 16 factors in the published Bolte report. 

Factors Used to Measure 

Job Value Open to 

Differing Interpretations 
Page 15 GAO-04-488 General and Flag Officer Requirements 

dated February 12, 1981—listed the 16 factors. (See app. I for a list of the 

16 factors.) 

The working panel made minor adjustments to the wording of the factors, 

and the senior panel approved their use for the study. DOD officials told 

us that the factors were broad enough to cover the significant aspects of 

general and flag officer positions, although one service official expressed 

concern that nuances between the services were not captured. The 

services and the Joint Staff were responsible for gathering the data on the 

factors for the positions and for entering this data into a database. The 

services and Joint Staff asked other offices (such as major commands and 

reserve component offices) and individuals (including general and flag 

officers) to provide the needed information. 

This decentralized process left the factors open to differing 

interpretations. We selected a small number of similar general and flag 

officers and, comparing the information provided, noted inconsistencies in 

how the services and Joint Staff applied the factors. For example, the 

superintendents of the three service academies (the U.S. Military 

Academy, the U.S. Naval Academy, and the U.S. Air Force Academy) have 

the same function (combat development and training of future officers), 

the same rank (O-9), and oversee roughly similar numbers of personnel. 

However, the position descriptions for the superintendents vary greatly, 

even in terms of quantitative criteria like the magnitude of personnel and 

physical resources. In one case, overall dollar figures are given; in the 

second case, a budget breakdown is provided; and in the last case, the 

number and type (but not value) of equipment is provided. Information 

ranged from vague (“the Superintendent currently has sufficient authority 

to make decisions and commit resources within the scope of his position”) 

to detailed (“formulates and directs the execution of policies, procedures, 

and programs required to accomplish the [academy’s] mission—cadet 

leader development system; cadet honor system and honor code; 

academic curriculum, military and physical programs; strategic vision, 

planning, and communications; [and] manpower and resource allocation”). 

During our review, we noted other issues concerning the methodology 

used to conduct the requirements study. 

• The methodology did not allow for clear-cut differentiation between O-6 

and O-7 positions and between O-7 and O-8 positions. Differentiation 

among the higher grades was more clear-cut. One service official said the 

factors were easier to apply to the higher grades. 

Other Methodological 

Issues 
Page 16 GAO-04-488 General and Flag Officer Requirements 

• Factors were weighted identically for a diverse array of general and 

flag officer positions. The functional groups contained between 123 and 

562 positions, with the result that the same weighting was applied to a 

diverse array of positions. For example, the same weighting was applied 

to the following Army positions in the special staff functional group: the 

Deputy Chief of Chaplains, the Assistant Judge Advocate General for 

Military Law and Operations, and the Dean of the Academic Board at the 

U.S. Military Academy. 

• Several service officials expressed concern about the short time frame for 

conducting the study. Officials from one service told us they had not had 

time to verify the information submitted for all the service’s general and 

flag officer positions and instead did spot checks of the information. 

Some general and flag officers are dual-hatted, simultaneously holding 

more than one position. One goal of the general and flag officer study was 

to identify dual-hatted positions and assess them as a single position. 

When LMI initially requested information on each position, it asked the 

military services and the Joint Staff to identify whether any other 

dual-hatted titles were associated with the position. LMI created a 

separate field—other titles (if dual hatted)—to capture this information in 

the requirements database. Our analysis of the 1,630 positions in the 

database showed that 113 positions were listed in this field as having other 

titles. For assessment purposes, each dual-hatted pair was considered as a 

single position and categorized as either an Army, an Air Force, a Navy, 

a Marine Corps, or an external (joint) position. 

Our review showed that despite these efforts, the study did not clearly 

account for dual-hatted positions. First, the study did not distinguish 

whether positions were dual-hatted for organizational efficiencies or 

due to limited manpower. Separate studies of general officers conducted 

for the Army and Marine Corps under the 1997 mandate stated that 

dual-hatted positions may be created to increase efficiency of operations 

or administration. On the other hand, they may also be created to 

maximize leadership or management within the constraint of available 

authorization ceilings. The Marine Corps study stated that “sorting out 

these two different reasons is an important part of any study which 

purports to determine requirements, rather than to accommodate to 

scarcities.”13 The general and flag officer study did not address these 

 13 Kapos Associates Inc, Analysis of U.S. Marine Corps General Officer Billet 

Requirements, KAI 152-96F (Washington, D.C.: July 31, 1996). 

2003 Study Did Not Clearly 

Account for Dual-Hatted 

Positions 
Page 17 GAO-04-488 General and Flag Officer Requirements 

different reasons for dual-hatting. As a result, requirements for general and 

flag officers could be different than the study data showed. 

Second, we found a small number of dual-hatted positions that were 

counted as separate requirements. Although an LMI official acknowledged 

that one pair of dual-hatted positions was double-counted, our analysis of 

the 113 positions listed as dual-hatted showed that at least 6 pairs of 

positions were counted separately in the requirements database. Three 

pairs of positions were internal to the Marine Corps, two pairs were 

Army/external (joint) positions, and one pair was internal to the Army. 

• In the Marine Corps, the following dual-hatted positions were included 

as separate positions: the Deputy Commanding General, 1st Marine 

Expeditionary Force, and the Commanding General, 1st Marine 

Expeditionary Brigade; the Deputy Commanding General, 

2nd Marine Expeditionary Force, and the Commanding General, 

2nd Marine Expeditionary Brigade; and the Deputy Commanding 

General, 3rd Marine Expeditionary Force, and the Commanding General, 

3rd Marine Expeditionary Brigade. 

• The Army/external (joint) dual-hatted positions that were included as 

separate positions were the Deputy Commanding General, Eighth 

U.S. Army, and C-3/J-3, United Nations Command/Combined Forces 

Command/U.S. Forces Korea; and the Deputy Assistant Chief of Staff 

C/J-4, United Nations Command/Combined Forces Command/U.S. Forces 

Korea and Deputy Commanding General (Support), Eighth U.S. Army. 

• In the Army, the Program Executive Office for the Army’s Air and Missile 

Defense and the Deputy Commanding General (Acquisition), U.S. Army 

Space and Missile Defense Command, were dual-hatted but included as 

separate positions. 

A third problem was a lack of consistency in identifying dual-hatted 

positions. Although the requirements database had the other titles 

(if dual-hatted) data field, we identified at least 37 positions that listed 

nothing under this field but included one or more dual-hatted titles 

elsewhere in their position descriptions. Thus, while the database 

identified 113 dual-hatted positions, other dual-hatted positions included 

in the database were not clearly identified as such. 
Page 18 GAO-04-488 General and Flag Officer Requirements 

DOD’s general and flag officer study did not assess how each service’s 

authorizations were affected by the need to contribute general and flag 

officers to fill external (joint) positions. As a result, direct comparisons 

between the requirements generated by the study and congressional 

authorizations are difficult. Without knowing how many general and flag 

officers each service contributes to the external (joint) community, we 

cannot be certain of the exact number of personnel each service needs to 

meet all of its commitments, internal and external. As shown in table 4, 

Congress establishes authorizations by service. Congress does not provide 

separate authorizations for external (joint) requirements, except for the 

Chairman’s 12 exemptions from the overall service ceilings. External 

(joint) requirements are filled from service authorizations. 

In the general and flag officer study, internal (service-specific) positions 

were separated from external (joint) positions. However, the study did not 

show the extent to which each service contributed general and flag 

officers from their authorizations to fill external (joint) requirements. 

While service contributions to external (joint) requirements fluctuate 

due to the rotational nature of these assignments, service contributions 

can be determined at a given point in time. We used Joint Staff data from 

December 2002 to determine which service was filling each of the 

223 active component external (joint) requirements (see table 5) and each 

of the 58 reserve component external (joint) requirements (see table 6) 

validated by the general and flag officer study. 

External (Joint) 

Requirements Were Not 

Tracked Back to Each 

Service’s Authorizations 
Page 19 GAO-04-488 General and Flag Officer Requirements 

Table 5: Service Contributions to External (Joint) General and Flag Officer Requirements in the Active Component 

(as of December 2002) 

Grade Army Air Force Navy Marine Corps No servicea

Total

O-10 3 5 3 2 0 13

O-9 7 9 7 3 4 30

O-8 24 23 9 5 3 64

O-7/O-8b 0 0 0 0 1 1

O-7 32 40 24c7 10d113

O-6 0 0 0 0 2e 2

Total 66 77 43 17 20 223

Source: GAO analysis of DOD data. 

a

The Joint Staff data did not identify the service filling some external (joint) positions. 

b

The Joint Staff data identifies positions that may be filled by an officer at either the O-7 or O-8 grade 

level. 

c

One position (a Navy O-7 position) was listed as a reserve component position in the requirements 

database but an active component position in the Joint Staff data. We have included this position as a 

reserve component position. 

d

One position (an O-7 position with no service identified) was listed as a reserve component position 

in the requirements database but an active component position in the Joint Staff data. We have 

included this position as a reserve component position. 

e

These positions were submitted as O-6 positions and validated as O-7 positions in the general and 

flag officer study. 

Table 6: Service Contributions to External (Joint) General and Flag Officer Requirements in the Reserve Component 

(as of December 2002) 

Grade Army Air Force Navy Marine Corps No servicea

Total

O-8 11 8 3 0 4 26

O-7/O-8b 8 2 0 0 2 12

O-7 5 9 3c0 3d20

Total 24 19 6 0 9 58

Source: GAO analysis of DOD data. 

a

The Joint Staff data did not identify the service filling some external (joint) positions. 

b

The Joint Staff data identifies positions that may be filled by an officer at either the O-7 or O-8 grade 

level 

c

One position (a Navy O-7 position) was listed as a reserve component position in the requirements 

database but an active component position in the Joint Staff data. We have included this position as a 

reserve component position. 

d

One position (an O-7 position with no service identified) was listed as a reserve component position 

in the requirements database but an active component position in the Joint Staff data. We have 

included this position as a reserve component position. 
Page 20 GAO-04-488 General and Flag Officer Requirements 

The data in tables 5 and 6 allow for a more direct comparison between 

requirements and authorizations. For example, the Army’s authorization 

for active duty generals is 302 plus the Army’s 5 exemptions for the 

Chairman’s 12, for a total of 307 authorized general officers. According to 

DOD’s requirements data, the Army needs 286 general officers to meet its 

internal active component requirements. Based on the data in table 5, 

Army general officers also filled 66 external (joint) requirements in the 

active component. As a result, the Army had total active component 

requirements—including internal and external—of 352 general officers, 

compared with active component authorizations for 307 generals, a 

difference of 45 generals. Using these calculations for the other services, 

active component requirements exceeded active component 

authorizations by 20 for the Air Force, 47 for the Navy, and 18 for the 

Marine Corps. The actual differences between individual service 

requirements and authorizations may be greater because the Joint Staff 

data did not identify the service filling 20 of the external (joint) active 

component requirements. 

The Fiscal Year 1997 National Defense Authorization Act directed the 

Secretary of Defense to include the Reserve Forces Policy Board in the 

department’s general and flag officer study. This same provision applied in 

2003. Subsection 1213(d) of the 1997 act states: 

“The Secretary of Defense shall ensure that the Reserve Forces Policy Board participates in 

the internal Department of Defense process for development of the recommendations of 

the Secretary contained in the report under subsection (a).” 

We noted during our review that the Reserve Forces Policy Board played a 

minimal role in producing the DOD 2003 report. The Board was not 

involved with the preparation of the general and flag officer study but was 

given the opportunity to comment on the study and the draft DOD report 

prior to its submission to Congress. The Board provided written comments 

on the report in April 2003 concurring with DOD’s conclusion that all 

current congressional authorizations for general and flag officers were 

needed, but registering strong objections to DOD’s recommendation not to 

seek additional authorizations now to meet validated requirements and to 

the limited role it played in the overall process. 

The Reserve Forces Policy Board had a more active role in DOD’s 1997 

general and flag officer study. In a memorandum to the Secretary of 

Defense, the Chairman of the Reserve Forces Policy Board at that time 

indicated the Board was pleased with its level of participation in the 1997 

Reserve Forces Policy 

Board Had Minimal 

Role in Producing 

DOD’s 2003 Report 
Page 21 GAO-04-488 General and Flag Officer Requirements 

study. The Chairman stated, “We believe our ‘independent voice’ is 

captured in this report and trust our views will be appropriately 

considered. We are pleased to share with you that [the Office of the 

Secretary of Defense] and the Services wholeheartedly embraced our 

participation. We were well represented at all levels of participation and 

our views were objectively considered.... In our view, this report was truly 

a Total Force effort.” 

DOD, in conducting its 2003 general and flag officer requirements study, 

incorporated some of the lessons learned from a GAO review of DOD’s 

1997 study. A notable improvement was the use of a single methodology 

and set of factors in the 2003 study to evaluate general and flag officer 

positions across all the services and the joint community. DOD also 

improved its tracking of study results and its documentation of 

adjustments made by the services and the Joint Staff. As in 1997, DOD did 

not identify and assess general and flag officer positions that could 

conceivably be converted to the civilian workforce. However, DOD has 

begun this assessment and expects to have results by July 2004. 

In 1997, the services and Joint Staff each conducted separate reviews of 

their general and flag officer requirements and, in doing so, used different 

job evaluation methodologies and factors. We noted in our review of the 

1997 study that differing methodologies made cross-service comparisons 

difficult, even when comparing similar positions from one service to 

another. The separate service reviews together created at least 24 different 

definitions of a general or flag officer. At the time, the Office of the 

Secretary of Defense stated that it permitted the services to use their own 

methodologies for three reasons: (1) The methodology selected had to 

recognize the unique mission and structure of each service. (2) There was 

no single definition of a general and flag officer and no one way to conduct 

job evaluations. The different methodologies were deemed valid. (3) Using 

existing methodologies and recently completed studies saved time. We 

stated that a single methodology, consistently applied, would have been a 

better approach than using different methodologies. 

In 2003, DOD used a single methodology and one set of factors to assess 

all general and flag officer positions. The Office of the Secretary of 

Defense, the services, and the Joint Staff representatives on the working 

and senior panels worked together with LMI to conduct the study. DOD 

officials we interviewed generally agreed with the approach of using a 

single methodology and set of factors. One official who had also 

DOD Incorporated 

Lessons Learned 

From GAO’s Review 

of DOD’s 1997 

General and Flag 

Officer Study 

2003 Study Assessed 

General and Flag Officer 

Requirements Using a 

Single Methodology 
Page 22 GAO-04-488 General and Flag Officer Requirements 

participated in the 1997 study said the services had to spend time 

defending their service-specific methodologies and findings. The use of a 

single methodology in the 2003 study avoided this problem. The process 

promoted interaction and discussion among the organizations represented 

on the working and senior panels. 

In job evaluations, judgments and decisions by executives about job value 

and study results are expected to be made as part of the process. 

Adjustments made to study results on the basis of executive judgment 

should be explained. In our review of DOD’s 1997 study, we found that 

there were discrepancies between what the service secretaries 

recommended and what their own service studies found and that these 

discrepancies were not explained in DOD’s draft 1997 report. The service 

secretaries recommended, in the aggregate, a total number of 

authorizations that was 123 less than the number of requirements 

identified by the service studies (995 recommended authorizations 

compared with 1,118 requirements). When the service secretaries 

developed their recommendations, they did not explain the basis for their 

adjustments to the study results. We recommended that the Secretary of 

Defense modify the draft 1997 report to include an explanation of the 

criteria used by the service secretaries to modify the results of the 

services’ studies. 

For the 2003 study, we found that DOD tracked the adjustments made to 

the requirements at each step in the process, from the time the positions 

were originally submitted through final vetting by service and Joint Staff 

senior leadership. DOD’s study showed the number of general and flag 

officer positions originally submitted by the services and Joint Staff 

(1,625),14 the number as assessed by LMI scorers (1,627), the number 

approved by the senior panel (1,629), and the final study results following 

a review by service and Joint Staff senior leadership (1,630). While net 

adjustments in the total number of requirements were minimal (a net 

increase of five positions), adjustments to the grades of individual 

positions were made at each step in the process. These adjustments were 

tracked in the requirements database. 

 14 The services and Joint Staff also submitted a select number of O-6 positions to be 

included in the study. 

DOD Improved Tracking 

and Documentation of 

Adjustments to Study 

Results 
Page 23 GAO-04-488 General and Flag Officer Requirements 

Our analysis of the requirements database showed that LMI scorers made 

adjustments to a total of 74 positions. Of these 74 positions, 20 had been 

submitted as O-7/O-8 positions. LMI scored these 20 positions as belonging 

at one grade or the other, with 8 positions being assessed as O-8 and 

12 positions being assessed as O-7. The other 54 positions represented 

“grade inversions,” where LMI scorers assessed the position at a pay grade 

level different from that submitted. Of the 54 grade inversions, 47 were 

downgrades (that is, for example, going from an O-8 to an O-7), and 7 were 

upgrades. The senior panel then had an opportunity to adjust the results of 

LMI’s scoring, and service and Joint Staff senior leadership vetted the 

requirements and made their own adjustments before the study results 

were finalized. The senior panel and the service and Joint Staff senior 

leadership made adjustments to a total of 38 positions. All but 1 of these 

38 adjustments involved positions scored as grade inversions by the LMI 

scorers. (See app. II for more information on these 38 adjustments.) 

We found that, in contrast with the 1997 study, the reasons for adjusting 

the LMI scoring results were documented in most cases. DOD was able to 

produce documentation, such as a spreadsheet and e-mail messages, to 

explain most of the adjustments. Our review of this documentation 

showed that an explanation was provided for 34 of the 38 adjustments and 

was lacking for the other 4 adjustments. In a few cases, the documented 

explanation was brief. For instance, the senior panel upgraded an Army 

reserve position from O-7 (LMI’s scoring assessment) back to O-8 (the 

grade as originally submitted). The panel’s rationale was as follows: “Keep 

as O-8; important info left out; Dep Vice Cmdr for Homeland Defense; 

$900m budget.” In other cases, the explanation for the adjustment was 

more detailed. For example, the senior panel upgraded the President of 

the Naval War College from O-8 (LMI’s scoring assessment) back to O-9 

(the grade as originally submitted). To support this adjustment, the Navy 

submitted a 2-page addendum to expand upon the original position 

description. 

In 1997, we found that the services had not fully evaluated the potential for 

military to civilian conversions as part of their general and flag officer 

studies. We noted that the need for additional general and flag officers 

could be reduced by converting general and flag officer positions that do 

not require a uniformed servicemember to civilian status. At that time, we 

recommended that the Secretary of Defense modify the draft 1997 report 

to include an evaluation of the potential to convert nonmilitary essential 

general and flag officer positions to civilian status. 

DOD Deferred an 

Evaluation of General and 

Flag Officer Positions That 

Might Be Considered for 

Civilian Conversion 
Page 24 GAO-04-488 General and Flag Officer Requirements 

As part of its 2003 study, DOD did not consider which positions could 

conceivably be converted from the military ranks to the civilian 

workforce. DOD stated in its March 2003 report to Congress that following 

completion of the general and flag officer review, DOD would look at its 

senior leadership requirements—military and civilian. “We must look at 

the entire pool of senior leaders, to include DOD civilians, to assess how 

many we need overall to effectively manage the Department,” the report 

stated. “Once we have agreement on an overall number, we will seek 

additional flexibility to manage within an overall ceiling and assign the 

best qualified individual where needed.” 

In July 2003, DOD approved a contract with LMI to assess general and flag 

officer positions for potential civilian conversion. The statement of work 

calls for LMI to perform a “billet-by-billet assessment of each validated 

general and flag officer requirement to determine whether the position 

could be filled by a senior civilian.” DOD has commissioned separate 

studies to assess Senior Executive Service requirements. An official in the 

Office of the Secretary of Defense said the LMI civilian conversion study 

will pave the way for analysis of future legislative and policy proposals. 

LMI is to provide study results within a year of the contract date. 

DOD’s March 2003 report to Congress did not provide complete 

information on whether general and flag officer authorizations were 

sufficient to meet all requirements. Specifically, DOD’s 2003 report to 

Congress did not fully disclose the results from its general and flag officer 

study or address the magnitude or the impact of the gap between 

requirements and authorizations. Fully disclosing the study results and 

discussing the implications of its findings would help to explain DOD’s 

recommendation not to seek additional authorizations. In addition, the 

methodology used in the study was not designed to capture new or 

emerging needs that could result from DOD transformation efforts or 

other changes in the department. Such changes could be captured through 

periodic updates to the requirements validated through the 2003 study. In 

the absence of periodic updates, the validated requirements could become 

out-of-date. DOD also could enhance the precision of the requirements 

data by more clearly accounting for dual-hatted positions and could 

enhance the usefulness of the results by assessing the impact of external 

(joint) requirements on service authorizations. Finally, the requirements 

data could be improved by incorporating the results of the ongoing civilian 

conversion study. 

Conclusions 
Page 25 GAO-04-488 General and Flag Officer Requirements 

Addressing these issues would help DOD establish a solid baseline of 

validated general and flag officer requirements that will assist DOD as it 

assesses senior leadership (civilian/military) requirements and manages 

general and flag officers. In addition, clarification of DOD’s requirements 

would assist congressional decision makers in making adjustments to the 

maximum number of general and flag officers authorized to each service. 

We recommend that the Secretary of Defense direct the Under Secretary 

of Defense for Personnel and Readiness to take the following four actions: 

• Clarify the magnitude and impact of the gap between DOD’s validated 

requirements for general and flag officers and congressional 

authorizations. This assessment should include (1) an analysis of the 

impact caused by the workarounds DOD uses to fill the gap between 

requirements and authorizations and (2) a more complete explanation of 

its recommendation not to seek additional authorizations in light of the 

study results showing that requirements exceeded authorizations. 

• Update general and flag officer requirements periodically by identifying, 

assessing, and validating new general and flag officer requirements that 

emerge from DOD transformation efforts or other changes in the 

department. 

• Take steps to enhance the precision and usefulness of the general and flag 

officer requirements. At a minimum, DOD should more clearly account for 

all dual-hatted positions in terms of whether each position is dual-hatted 

for efficiency or out of necessity due to shortages in general and flag 

officer authorizations. Positions that are dual-hatted out of necessity 

should be treated as separate positions for purposes of identifying 

requirements. In addition, to the extent possible, DOD should track service 

contributions of general and flag officers to external (joint) requirements 

to assess whether each service’s authorizations are sufficient to meet both 

internal and external requirements. 

• Incorporate the results of the ongoing civilian conversion study in a future 

update of general and flag officer requirements. 

DOD provided written comments on a draft of this report. In its comments, 

DOD concurred with our recommendations and indicated that it will 

(1) address the impact of the gap in requirements and the use of 

workarounds in a separate study on alternative methods for dealing with 

the gap in requirements, (2) review all dual-hatted positions and add the 

additional information to the established requirements database, and 

(3) incorporate the results of the ongoing civilian conversion study in a 

future update of general and flag officer requirements. Regarding our 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 26 GAO-04-488 General and Flag Officer Requirements 

recommendation to periodically update general and flag officer 

requirements, DOD indicated that its current procedures were adequate. 

However, as we stated in our report, these additional requirements are not 

going through the kind of job evaluation assessment and validation DOD 

used in its study. DOD could use the methodology developed for the 

baseline study to ensure that any additional requirements are validated. 

As we noted in our report, the assessment process resulted in validated 

requirements that in some cases differed from the requirements 

originally submitted by the services and the Joint Staff. Regarding our 

recommendation that DOD track the military services’ contributions of 

general and flag officers to external (joint) requirements, DOD stated that 

it will closely monitor service participation in this arena and that current 

safeguards mitigate the impact of joint participation. We continue to 

believe that an assessment of whether general and flag officer 

authorizations are sufficient to meet all requirements necessitates the 

inclusion of both internal service as well as external (joint) requirements. 

Furthermore, this assessment should be made at the service level because 

Congress has established service-specific authorization levels. DOD’s 

comments are reprinted in their entirety in appendix III. DOD also 

provided technical comments, which we have incorporated as appropriate. 

To determine whether DOD fully disclosed the results of its general and 

flag officer study in its March 2003 report to Congress and explained the 

rationale for any recommendations, we obtained and analyzed the 

results of the general and flag officer study, the database of validated 

requirements, supporting documentation, and the March 2003 report. We 

also reviewed laws and regulations pertaining to general and flag officers. 

We discussed the study with, and obtained documentation from, 

representatives of the Under Secretary of Defense for Personnel and 

Readiness, the Office of General Counsel (Office of the Secretary of 

Defense), LMI, and the military services’ and Joint Staff’s general officer 

matters offices. We also reviewed the Reserve Forces Policy Board’s 

comments on the general and flag officer study, met with Board staff, and 

obtained documentation concerning the Board’s involvement in the study. 

The scope of our review did not include an assessment of 

recommendations made by DOD concerning the management of general 

and flag officers. We plan to conduct a separate review of these 

management issues and recommendations. 

To assess the methodology used in the 2003 study, we reviewed prior DOD 

studies of general and flag officer requirements and the results of our 

review of DOD’s 1997 study, for which we had conducted an extensive 

Scope and 

Methodology 
Page 27 GAO-04-488 General and Flag Officer Requirements 

literature review on job evaluation methods. We also reviewed a study by a 

public policy research contractor,15 contacted another outside researcher 

who was familiar with the study, and reviewed other literature on job 

evaluation. We reviewed the steps used to conduct the 2003 study and the 

origin and application of factors used in the assessment. We discussed the 

methodology with DOD and LMI officials. We also determined how the 

study accounted for dual-hatted positions and external (joint) 

requirements. Regarding dual-hatted positions, we examined selected 

positions from the requirements database. We also compared dual-hatted 

positions in the database with service and DOD-wide rosters of general 

and flag officers. Regarding external (joint) requirements, we examined 

Joint Staff data to determine the services’ contributions to meeting 

validated external (joint) general and flag officer requirements. We did not 

review the study findings to determine whether requirements for 

individual positions were validated appropriately through the study. 

To determine whether DOD incorporated lessons learned from our review 

of DOD’s 1997 general and flag officer study, we reviewed the findings and 

recommendations from our 1997 review and compared these lessons 

learned to the approach used in the 2003 study. To assess the tracking and 

documentation of adjustments made to study results, we analyzed the 

requirements database. We then obtained from DOD documentation 

concerning adjustments that were made to the study results by the senior 

panel and the service and Joint Staff senior leadership. We also reviewed 

DOD’s plans for a follow-on study concerning conversion of general and 

flag officer positions to the civilian workforce. 

We are sending copies of this report to the Secretary of Defense and the 

Director, Office of Management and Budget. In addition, the report will be 

available at no charge on GAO’s Web site at http://www.gao.gov. 

 15 RAND National Defense Research Institute, Job Evaluation Methods, PM-638-OSD 

(Jan. 1997). This study was prepared for the Office of the Secretary of Defense. 
Page 28 GAO-04-488 General and Flag Officer Requirements 

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

contact me at (202) 512-5559 (stewartd@gao.gov) or Brenda S. Farrell at 

(202) 512-3604 (farrellb@gao.gov). Major contributors to this report were 

Thomas W. Gosling, J. Paul Newton, and Bethann E. Ritter. 

Derek B. Stewart 

Director, Defense Capabilities and Management 
Appendix I: Sixteen Factors Used to Validate 

General and Flag Officer Requirements 

Page 29 GAO-04-488 General and Flag Officer Requirements 

1. Characteristics of function 

a. Type (e.g., command, general or coordinating staff, special staff, 

manager, deputy, specialist, etc.) 

b. Scope (e.g., operational command, training command, installation 

command, personnel management, officer personnel management, 

legal affairs, information, etc.) 

c. Level of function (e.g., national, secretarial, service, theater, field 

command, etc.) 

2. Grade and position of 

a. superior 

b. principal subordinates 

c. lateral points of coordination 

(relative position within the military or governmental structure within 

which the position’s function is performed) 

3. Supervision over position 

a. Proximity (remoteness or closeness of supervision) 

b. Degree (independence of operation) 

4. Official relations with U.S. and foreign governmental officials and with 

the public 

a. Nature (e.g., reports to, works for, keeps informed, provides 

liaison, etc.) 

b. Extent (e.g., primary function, frequent requirement, continuous 

additional duty, occasional requirement, etc.) 

c. Level of official relations with U.S. and foreign governmental 

officials and with the public (e.g., governmental department or agency, 

national or local government, civil organizations, industry, press, 

non-governmental organizations [NGO], private volunteer 

organizations [PVO], etc.) 

Appendix I: Sixteen Factors Used to Validate 

General and Flag Officer Requirements 

Nature of the Position 
Appendix I: Sixteen Factors Used to Validate 

General and Flag Officer Requirements 

Page 30 GAO-04-488 General and Flag Officer Requirements 

5. Reflection of national emphasis and determination (relation of position 

to national objectives and programs, special conditions under which the 

position was first established or other reasons why the position reflects 

national will) 

6. Special qualifications required by the position (any special qualifications 

such as advanced education, or particular training or experience, which 

are essential to the proper execution of positional responsibilities) 

7. Mission(s) of organization and the special requirements of the position 

as it relates to the mission(s) (the nature of the responsibilities that are 

associated with the position and the need for multidimensional “executive 

skills.” The mission of the organization is the key, day-to-day activities that 

are accomplished.) 

8. Number, type, and value of resources managed and employed. Data 

should be displayed within three categories: operational control, 

administrative control, and immediate staff within each subsection. 

a. Military forces (number and type of forces normally assigned or 

programmed for planned or special operations) 

b. Personnel (number of personnel by officer and warrant officer, 

enlisted, and civilian) 

c. Value of equipment and properties (total value of equipment, 

supplies, and real property displayed in millions) 

d. Total obligation authority 

e. Foreign resources (scope and type of foreign resources involved, 

if any) 

f. Other important resources 

9. Geographical area of responsibilities (the size, location, and, if 

appropriate, the criticality of the land, sea, or air spaces involved) 

10. Authority to make decisions and commit resources (the scope of the 

position with respect to specific authority delegated to or withheld from 

the position in either routine or emergency situations) 

Magnitude of 

Responsibilities 
Appendix I: Sixteen Factors Used to Validate 

General and Flag Officer Requirements 

Page 31 GAO-04-488 General and Flag Officer Requirements 

11. Development of policy (involvement in the development of policy 

within the specific functional areas associated with the position, e.g., 

budget, program, communications, or manpower) 

12. National commitment to international agreements (authority to make 

commitments to foreign nations or involvement in negotiating such 

commitments for the United States) 

13. Auxiliary (supporting) authorities and responsibilities inherent in the 

position (inherent requirements charged to the position by virtue of 

situation, location, proximity, tradition, etc.) 

14. Impact on national security or other national interests (effect of 

mission accomplishment or position performance on the protection of 

national interests or the advancement of national programs) 

15. Importance to present and future effectiveness and efficiency of the 

national defense establishment (effect on the force structure, operational 

capabilities, status of combat readiness, quality of personnel and 

equipment, cost effectiveness, command and control means, management 

procedures and techniques, responsiveness to national needs, or other 

factors) 

16. Effect on the prestige of the nation or the armed forces (how 

effectiveness or accomplishment reflects on the stature of the nation and 

its armed forces, and influences the credibility of national aims and 

capabilities) 

Significance of 

Actions and Decisions 
Appendix II: Adjustments Made to General 

and Flag Officer Requirements After LMI’s 

Scoring Assessment 

Page 32 GAO-04-488 General and Flag Officer Requirements 

This appendix lists the 38 general and flag officer positions where 

adjustments were made after the Logistics Management Institute (LMI) 

scorers conducted their assessment. The Department of Defense (DOD) 

components (the military services and Joint Staff) submitted the pay grade 

level for each general and flag officer position reviewed. LMI scorers 

assessed the positions to validate the grade level. The senior panel 

reviewed the results of LMI’s scoring assessment, made adjustments, and 

approved the validated requirements. The requirements were then vetted 

through the senior leadership of the services and the Joint Staff, who 

requested further adjustments. With these adjustments, the study results 

were finalized. Table 7 shows, for each of the 38 positions, the adjustments 

to the position’s pay grade as approved by the senior panel and vetted 

through the senior leadership. 

Table 7: Pay Grade Adjustments Approved by the Senior Panel and Requested by Service and Joint Staff Senior Leadership 

 Pay grade 

Position 

DOD component 

(military service 

or external-joint) 

... as submitted 

originally by the 

DOD component

... as 

assessed by 

LMI scorers

... as approved 

by the senior 

panel 

... as vetted 

through service 

and Joint Staff 

senior leadership

Active component 

President, Naval War College Navy O-9 O-8 O-9 O-9

Commandant, Naval District 

Washington 

Navy O-8 O-7 O-8 O-8

Director Marine Corps Staff, 

Headquarters/U.S. Marine Corps 

Marine Corps O-8 O-7 O-8 O-8

Commanding General, U.S. Army 

Military District of Washington 

Army O-8 O-7 O-8 O-8

Deputy Chief of Staff, UNC/USFK, 

U.S. PACOM/UNC/CFC/USFKa

External (joint) O-8 O-7 O-8 O-8

Director, Customer Support Office, 

National Imagery and Mapping 

Office 

External (joint) O-7 O-6 O-7 O-7

Assistant Wing Commander, 

1st Marine Aircraft Wing 

Marine Corps O-6 O-6 O-6 O-7

Reserve component 

Mobilization Assistant (MA) to 

Commander, Air Force Space 

Command 

Air Force O-8 O-7 O-8 O-8

Deputy Commander for 

Mobilization and Reserve Affairs, 

U.S. Southern Command 

External (joint) O-8 O-7 O-8 O-8

Appendix II: Adjustments Made to General 

and Flag Officer Requirements After LMI’s 

Scoring Assessment 
Appendix II: Adjustments Made to General 

and Flag Officer Requirements After LMI’s 

Scoring Assessment 

Page 33 GAO-04-488 General and Flag Officer Requirements 

 Pay grade 

Position 

DOD component 

(military service 

or external-joint) 

... as submitted 

originally by the 

DOD component

... as 

assessed by 

LMI scorers

... as approved 

by the senior 

panel 

... as vetted 

through service 

and Joint Staff 

senior leadership

Deputy Commander for 

Mobilization and Reserve Affairs, 

U.S. Special Operations Command 

External (joint) O-8 O-7 O-8 O-8

MA to Commander, U.S. Strategic 

Command (Air Force) 

External (joint) O-8 O-7 O-8 O-8

MA to Commander, U.S. Strategic 

Command (Navy) 

External (joint) O-8 O-7 O-8 O-8

MA to Deputy Commander in 

Chief, U.S. Transportation 

Command 

External (joint) O-8 O-7 O-8 O-8

Deputy Commander for 

Mobilization and Reserve Affairs, 

U.S. Army Pacific Command 

Army O-8 O-7 O-8 O-8

MA to Commander, U.S. Pacific 

Command 

External (joint) O-8 O-7 O-8 O-8

MA to Director, Intelligence, 

Surveillance, and 

Reconnaissance, AF/XO 

Air Force O-8 O-7 O-8 O-8

Deputy Commander, U.S. Pacific 

Fleet 

Navy O-8 O-7 O-8 O-8

Assistant to the Commander, 

Air Force Space Command 

Air Force O-8 O-7 O-8 O-8

Assistant to the Commander, 

Air Combat Command 

Air Force O-8 O-7 O-8 O-8

Assistant to the Commander, 

Air Mobility Command 

Air Force O-8 O-7 O-8 O-8

Assistant to the Commander, 

Pacific Air Force 

Air Force O-8 O-7 O-8 O-8

Assistant to the Commander, 

U.S. Air Forces Europe 

Air Force O-8 O-7 O-8 O-8

Assistant to the Commander, 

U.S. Pacific Command 

Air Force O-8 O-7 O-8 O-8

Deputy Commander for Resources 

and Readiness, U.S. Naval Forces 

Europe 

Navy O-8 O-7 O-8 O-8

Deputy Commanding General, 

U.S. Army Pacific 

Army O-8 O-7 O-8 O-8

MA to Director, Aerospace 

Operations, Air Combat Command 

Air Force O-8 O-7 O-7 O-8

MA to Director, Operations, 

Air Mobility Command 

Air Force O-8 O-7 O-7 O-8
Appendix II: Adjustments Made to General 

and Flag Officer Requirements After LMI’s 

Scoring Assessment 

Page 34 GAO-04-488 General and Flag Officer Requirements 

 Pay grade 

Position 

DOD component 

(military service 

or external-joint) 

... as submitted 

originally by the 

DOD component

... as 

assessed by 

LMI scorers

... as approved 

by the senior 

panel 

... as vetted 

through service 

and Joint Staff 

senior leadership

Assistant Vice Commander, 

Air Force Reserve Command 

Air Force O-8 O-7 O-7 O-8

MA to Deputy Chief of Staff, 

Air and Space Operations, AF/XO 

Air Force O-8 O-7 O-7 O-8

MA to Deputy Chief of Staff, Plans 

and Programs, AF/XP 

Air Force O-8 O-7 O-7 O-8

MA to Deputy Chief of Staff, 

Installations and Logistics, AF/IL 

Air Force O-8 O-7 O-7 O-8

MA to Deputy Chief of Staff, 

Warfighting Integration, AF/XI 

Air Force O-8 O-7 O-7 O-8

MA to Commander, Air Force 

Reserve Command 

Air Force O-8 O-7 O-7 O-8

MA to Director, Legislative Liaison, 

SAF/LL 

Air Force O-8 O-7 O-7 O-8

Deputy Director of Naval Reserve, 

N095B, OPNAV/RPN 

Navy O-7 O-8 O-7 O-7

Deputy Commander, Naval 

Air Force Pacific 

Navy O-7 O-6 O-7 O-7

Director of C4, State Headquarters Air Force O-7 O-6 O-7 O-7

MA to Commander, Air Intelligence 

Agency 

Air Force O-7 O-6 O-7 O-7

Source: GAO analysis of DOD data. 

a

United Nations Command/U.S. Forces Korea, U.S. Pacific Command/United Nations 

Command/Combined Forces Command/U.S. Forces Korea. 
Appendix III: Comments From the 

Department of Defense 

Page 35 GAO-04-488 General and Flag Officer Requirements 

Appendix III: Comments From the 

Department of Defense 
Appendix III: Comments From the 

Department of Defense 

Page 36 GAO-04-488 General and Flag Officer Requirements 

Now on p. 25. 

Now on p. 25. 
Appendix III: Comments From the 

Department of Defense 

Page 37 GAO-04-488 General and Flag Officer Requirements 

Now on p. 25. 

Now on p. 25. 

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