CIVILIAN 

INTELLIGENCE 

COMMUNITY

Additional Actions 

Needed to Improve 

Reporting on and 

Planning for the Use 

of Contract Personnel

Report to Congressional Requesters

January 2014

GAO-14-204

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-204, a report to 

congressional requesters

January 2014

CIVILIAN INTELLIGENCE COMMUNITY

Additional Actions Needed to Improve Reporting on and 

Planning for the Use of Contract Personnel

Why GAO Did This Study

The IC uses core contract personnel to 

augment its workforce. These 

contractors typically work alongside 

government personnel and perform 

staff-like work. Some core contract 

personnel require enhanced oversight 

because they perform services that 

could inappropriately influence the 

government’s decision making.

This report is an unclassified version of 

a classified report issued in September 

2013. GAO was asked to examine the 

eight civilian IC elements’ use of 

contractors. This report examines (1) 

the extent to which the eight civilian IC 

elements use core contract personnel, 

(2) the functions performed by these 

personnel and the reasons for their 

use, and (3) whether the elements 

developed policies and strategically 

planned for their use. GAO reviewed 

and assessed the reliability of the eight 

civilian IC elements’ core contract 

personnel inventory data for fiscal 

years 2010 and 2011, including 

reviewing a sample of 287 contract 

records. This sample is 

nongeneralizable as certain contract 

records were removed due to 

sensitivity concerns. GAO also 

reviewed agency acquisition policies 

and workforce plans and interviewed

agency officials.

What GAO Recommends

GAO is recommending that IC CHCO 

take several actions to improve the 

inventory data’s reliability and 

transparency and revise strategic 

workforce planning guidance, and 

develop ways to identify contracts for 

services that could affect the 

government’s decision-making 

authority. IC CHCO generally agreed 

with GAO’s recommendations.

What GAO Found

Limitations in the intelligence community’s (IC) inventory of contract personnel

hinder the ability to determine the extent to which the eight civilian IC elements—

the Central Intelligence Agency (CIA), Office of the Director of National 

Intelligence (ODNI), and six components within the Departments of Energy, 

Homeland Security, Justice, State, and the Treasury—use these personnel. The 

IC Chief Human Capital Officer (CHCO) conducts an annual inventory of core 

contract personnel that includes information on the number and costs of these

personnel. However, GAO identified a number of limitations in the inventory that 

collectively limit the comparability, accuracy, and consistency of the information 

reported by the civilian IC elements as a whole. For example, changes to the 

definition of core contract personnel and data shortcomings limit the 

comparability of the information over time. In addition, the civilian IC elements 

used various methods to calculate the number of contract personnel and did not 

maintain documentation to validate the number of personnel reported for 

37 percent of the 287 records GAO reviewed. Further, IC CHCO did not fully 

disclose the effects of such limitations when reporting contract personnel and 

cost information to Congress, which limits its transparency and usefulness.

The civilian IC elements used core contract personnel to perform a broad range 

of functions, such as information technology and program management, and 

reported in the core contract personnel inventory on the reasons for using these 

personnel. However, limitations in the information on the number and cost of core 

contract personnel preclude the information on contractor functions from being 

used to determine the number of personnel and their costs associated with each 

function. Further, civilian IC elements reported in the inventory a number of 

reasons for using core contract personnel, such as the need for unique expertise, 

but GAO found that 40 percent of the contract records reviewed did not contain 

evidence to support the reasons reported.

Collectively, CIA, ODNI, and the departments responsible for developing policies 

to address risks related to contractors for the other six civilian IC elements have 

made limited progress in developing those policies, and the civilian IC elements 

have generally not developed strategic workforce plans that address contractor 

use. Only the Departments of Homeland Security and State have issued policies 

that generally address all of the Office of Federal Procurement Policy’s

requirements related to contracting for services that could affect the 

government’s decision-making authority. In addition, IC CHCO requires the 

elements to conduct strategic workforce planning but does not require the 

elements to determine the appropriate mix of government and contract 

personnel. Further, the elements’ ability to use the core contract personnel

inventory as a strategic planning tool is hindered because the inventory does not 

provide insight into the functions performed by contractors, in particular those

that could inappropriately influence the government’s control over its decisions. 

Without guidance, strategies, and tools related to these types of functions, the 

eight civilian IC elements may not be well-positioned to identify and manage 

related risks. View GAO-14-204. For more information, 

contact Timothy J. DiNapoli at (202) 512-4841 

or dinapolit@gao.gov.
Page i GAO-14-204 Civilian Intelligence Community

Letter 1

Background 5

Limitations in the Inventory Undermine Ability to Determine Extent 

of Civilian IC Elements’ Reliance on Contractors 12

Inventory Provides Limited Insight into Functions Performed by 

Contractors and Reasons for Their Use 20

Limited Progress Has Been Made in Developing Policies and 

Strategies on Contractor Use to Mitigate Risks 24

Conclusions 29

Recommendations for Executive Action 30

Agency Comments and Our Evaluation 31

Appendix I Objectives, Scope, and Methodology 35

Appendix II Observations on Reliability of Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions 38

Appendix III Overview of the Eight Civilian Intelligence Community Elements 

and Their Respective Missions 46

Appendix IV Selected Office of Management and Budget Guidance Related to 

Considering and Mitigating Risks 47

Appendix V Intelligence Community Core Contract Personnel Definitions and 

Associated Major Changes by Fiscal Year 48

Appendix VI Comments from the Office of the Director of National Intelligence 50

Appendix VII GAO Contact and Staff Acknowledgments 54

Contents
Page ii GAO-14-204 Civilian Intelligence Community

Tables

Table 1: Available Response Options in the Core Contract 

Personnel Inventory for IC Elements to Report on 

Reasons for Using Contractors 22

Table 2: Criteria for Determining Whether Relevant Documents 

Validated Information Reported in Eight Civilian IC 

Elements’ Submissions to the Fiscal Years 2010 and 

2011 Core Contract Personnel Inventories 41

Figures

Figure 1: Civilian IC Elements and Their Respective Departments 6

Figure 2: Risk Associated with the Use of Core Contract 

Personnel 9
Page iii GAO-14-204 Civilian Intelligence Community

Abbreviations

CIA Central Intelligence Agency

DEA NN Drug Enforcement Administration’s Office of National

Security Intelligence

DHS I&A Department of Homeland Security’s Office of Intelligence

and Analysis

DNI Director of National Intelligence

DOD Department of Defense

DOE IN Department of Energy’s Office of Intelligence and

Counterintelligence

DOJ Department of Justice

FAR Federal Acquisition Regulation

FBI Federal Bureau of Investigation

FTE full-time equivalent

IC intelligence community

IC CHCO Intelligence Community Chief Human Capital Officer

ICD intelligence community directive

ODNI Office of the Director of National Intelligence

OFPP Office of Federal Procurement Policy

OMB Office of Management and Budget

State INR Department of State’s Bureau of Intelligence and Research

Treasury OIA Department of the Treasury’s Office of Intelligence and

Analysis

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Page 1 GAO-14-204 Civilian Intelligence Community

441 G St. N.W.

Washington, DC 20548

January 29, 2014

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

The Honorable Ron Johnson

Ranking Member

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Susan M. Collins

United States Senate

The intelligence community (IC) comprises 17 different organizations, or 

IC elements, across the federal government. Of these, eight are civilian 

IC elements—the Central Intelligence Agency (CIA), Department of 

Homeland Security’s Office of Intelligence and Analysis (DHS I&A), 

Department of Energy’s Office of Intelligence and Counterintelligence 

(DOE IN), Department of State’s Bureau of Intelligence and Research 

(State INR), Department of the Treasury’s Office of Intelligence and 

Analysis (Treasury OIA), Drug Enforcement Administration’s Office of 

National Security Intelligence (DEA NN), Federal Bureau of Investigation 

(FBI), and the Office of the Director of National Intelligence (ODNI). Like 

other federal agencies, these civilian IC elements rely on contractors to 

meet a variety of mission needs. In a 2013 report on intelligence oversight 

activities, Congress cited long-standing concerns about the IC’s reliance 

on contractors, which it noted increased dramatically after the terrorist 

attacks of September 11, 2001. In October 2009, the Director of National 

Intelligence (DNI), who serves as head of the IC, issued Intelligence 

Community Directive (ICD) 612 to define and establish IC-wide policy for 

managing the use of core contract personnel that support intelligence 

missions. As defined by ICD 612, core contract personnel provide a range 

of direct technical, managerial, and administrative support functions to IC 

elements—some of which may directly inform government decisions, 

such as intelligence collection, processing, and analysis, along with 
Page 2 GAO-14-204 Civilian Intelligence Community

program management. Core contract personnel are distinct from 

individual contract personnel who produce commodities or provide widely 

available commercial services such as building security. ICD 612 also 

states that core contract personnel typically work alongside government 

personnel, augment the government workforce, and perform staff-like 

work.

Determining whether services should be performed by federal employees, 

contract personnel, or a mixture of both is essential to the federal 

government’s effective and efficient use of taxpayers’ dollars. Further, 

while the use of contractors can provide benefits in supporting agency 

missions, such as flexibility to meet immediate needs and obtain unique 

expertise, their use can also introduce risks for the government to 

consider and manage. Federal acquisition regulations state that certain 

functions government agencies perform, such as setting agency policy 

and issuing regulations, are inherently governmental and must be 

performed by federal employees.1 In some cases, contractors perform 

functions closely associated with the performance of inherently 

governmental functions.2 For example, contractors performing certain 

intelligence analysis activities may closely support inherently 

governmental functions. Agencies should give special management 

attention to contractors performing services that closely support inherently 

governmental functions to guard against the potential for loss of 

government control and accountability for mission-related policy and 

program decisions.3

Our prior work has examined reliance on contractors and the mitigation of 

related risks at the Department of Defense (DOD), DHS, and several 

 1

Federal Acquisition Regulation (FAR) § 7.503(c) includes a list of functions that are 

considered to be inherently governmental.

2

Functions closely associated with the performance of inherently governmental functions 

are not considered inherently governmental, but may approach being in that category 

because of the nature of the function, the manner in which the contractor performs the 

contract, or the manner in which the government administers contractor performance. 

FAR § 7.503(d).

3

See generally FAR § 37.114(b), which requires agencies to provide special management 

attention to contracts for services that require the contractor to provide advice, opinions, 

recommendations, ideas, reports, analyses, or other work products, as they have the 

potential for influencing the authority, accountability, and responsibilities of government 

officials.
Page 3 GAO-14-204 Civilian Intelligence Community

other civilian agencies and found that they generally did not fully consider 

and mitigate risks of acquiring services that may inform government 

decisions.4

To determine the extent to which the civilian IC elements rely on core 

contract personnel, the functions performed by these personnel, and the 

factors that contribute to their use, we requested and reviewed data from 

each of the eight civilian IC elements: CIA, DEA NN, DHS I&A, DOE IN, 

FBI, ODNI, State INR, and Treasury OIA.

In this context, you asked us to review the civilian IC 

elements’ reliance on contractors. This report is a public version of the 

classified report that we provided to you in September 2013, which 

addressed: (1) the extent to which the eight civilian IC elements rely on 

core contract personnel; (2) the functions performed by core contract 

personnel and the factors that contribute to their use; and (3) whether the 

civilian IC elements have developed policies and guidance and 

strategically planned for their use of contract personnel to mitigate related 

risks. ODNI, in consultation with the other civilian IC elements, deemed 

some of the information in the September 2013 report as classified, which 

must be protected from public disclosure. Therefore, this report omits 

sensitive information about (1) the number and associated costs of 

government and core contract personnel and some details on how the 

civilian IC elements prepare the core contract personnel inventory, (2) 

specific contracts from civilian IC elements we reviewed, and (3) details 

related to the civilian IC elements’ or their respective departments’ 

progress in developing policies to mitigate risks related to contractors and

the civilian IC elements’ strategic workforce planning efforts.

5

 4

GAO, Managing Service Contracts: Recent Efforts to Address Associated Risks Can Be 

Further Enhanced, 

These data submissions were 

provided by the civilian IC elements to the IC Chief Human Capital Officer 

(IC CHCO) for use in the annual core contract personnel inventories. We 

reviewed five data fields related to information on obligations, the number 

of full-time equivalents (FTE) on core contracts, the functions performed 

by core contract personnel, and the reasons for using these personnel. 

GAO-12-87 (Washington, D.C.: Dec. 7, 2011); Contingency 

Contracting: Improvements Needed in Management of Contractors Supporting Contract 

and Grant Administration in Iraq and Afghanistan, GAO-10-357 (Washington, D.C.: Apr. 

12, 2010); Defense Acquisitions: Further Actions Needed to Address Weaknesses in 

DOD’s Management of Professional and Management Support Contracts, GAO-10-39 

(Washington, D.C.: Nov. 20, 2009); and Department of Homeland Security: Improved 

Assessment and Oversight Needed to Manage Risk of Contracting for Selected Services, 

GAO-07-990 (Washington, D.C.: Sept. 17, 2007).

5

DEA NN and FBI are components of the Department of Justice (DOJ).
Page 4 GAO-14-204 Civilian Intelligence Community

We originally planned to review fiscal years 2007 through 2011 inventory 

data. However, we could not conduct a reliability assessment of the data 

for fiscal years 2007 through 2009 due to a variety of factors. These 

factors include civilian IC element officials’ stating that they could not 

locate records of certain years’ submissions or that obtaining the relevant 

documentation would require an unreasonable amount of time. As a 

result, we generally focused our review on data from fiscal years 2010 

and 2011. To assess the data’s reliability, we selected a random 

nongeneralizable sample of 287 records—representing 222 contracts or 

purchase orders—and compared the information reported in these 

elements’ submissions for these years to contract documents.6

Observations from our nongeneralizable sample cannot be used to make 

projections about the eight civilian IC elements’ submissions as a whole.7

To determine whether the civilian IC elements have developed policies 

and guidance and strategically planned for their use of core contract 

personnel to mitigate related risks, we reviewed relevant acquisition 

policies and guidance, workforce planning documents, and strategic 

planning tools. We also interviewed human capital, procurement, or 

We determined that four of the five data fields we reviewed—fiscal year 

obligations, total FTEs, reason code, and budget category—were not 

sufficiently reliable for the purpose of our review. We present these data 

and their associated limitations where appropriate in the report. The fifth 

data field, primary contractor occupation and competency expertise, was 

sufficiently reliable, though we identified some limitations. Appendix II 

contains a more detailed discussion of our data reliability assessment. 

We also reviewed relevant IC CHCO guidance and documents and 

interviewed agency officials responsible for compiling and processing the 

data.

 6

For the purposes of this report, a contract record corresponds to one row of data in an 

element’s submission to the inventory for a particular fiscal year. One contract record can 

represent a contract, a purchase order, or multiple contracts. In addition, multiple contract 

records can constitute one contract or purchase order. The number of contract records we 

reviewed was a random sample of the contracts across all eight civilian IC elements and 

therefore cannot be used to determine the number of contracts for any individual civilian 

IC element or the civilian IC elements as a whole.

7

Our sample was not generalizable because two of the civilian IC elements removed 

certain records from the universe of records available for random selection. In addition, 

after making our initial random selection, we worked with several civilian IC elements to 

remove and replace certain records from our selection if they identified sensitivity 

concerns or could not readily locate relevant documents.
Page 5 GAO-14-204 Civilian Intelligence Community

program officials at each civilian IC element to discuss ongoing efforts 

related to developing policies and strategic planning to mitigate risks. We 

compared these plans, guidance, and tools to Office of Management and 

Budget (OMB) guidance that address risks related to contracting for work 

closely supporting inherently governmental and critical functions, 

including the Office of Federal Procurement Policy (OFPP) Policy Letter 

11-01, OMB’s Memorandum on Managing the Multisector Workforce, and 

OMB’s memoranda on service contract inventories.8 Further, we 

compared the civilian IC elements’ efforts to strategic human capital best 

practices identified in our prior work.9

A detailed description of our scope and methodology is included in 

appendix I. We conducted this performance audit from November 2012 to 

September 2013 in accordance with generally accepted government 

auditing standards. We subsequently worked with ODNI from September

2013 to December 2013 to prepare an unclassified version of this report 

for public release. Government auditing standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

Established by the Intelligence Reform and Terrorism Prevention Act of 

2004, DNI serves as head of the IC, acts as the principal advisor to the 

President and National Security Council on intelligence matters, and 

oversees and directs the implementation of the National Intelligence 

 8

OFPP Policy Letter 11-01, Performance of Inherently Governmental and Critical 

Functions (Sept. 12, 2011); OMB M-09-26, Managing the Multisector Workforce (July 29, 

2009); OFPP Memorandum for Chief Acquisition Officers and Senior Procurement 

Executives, Service Contract Inventories (Nov. 5, 2010); and OFPP Memorandum for 

Chief Acquisition Officers and Senior Procurement Executives, Service Contract 

Inventories (Dec. 19, 2011).

9

GAO, A Model of Strategic Human Capital Management, GAO-02-373SP (Washington, 

D.C.: Mar. 15, 2002).

Background

Organization of the IC
Page 6 GAO-14-204 Civilian Intelligence Community

Program.10 The IC comprises 17 different organizations, or IC elements, 

across the federal government represented by 6 executive departments. 

These IC elements include ODNI, seven other civilian IC elements, and 

nine military IC elements. The eight civilian IC elements within the scope 

of our review include two intelligence agencies and six intelligence 

components within five departments (see fig. 1).11

Figure 1: Civilian IC Elements and Their Respective Departments

For the purposes of 

this review, we are referring to the eight as the civilian IC elements. 

Appendix III provides additional information on each of the eight civilian 

IC elements’ missions.

 10The National Intelligence Program, overseen by ODNI, provides the resources needed 

to develop and maintain intelligence capabilities that support national priorities. Pub. L. 

No. 108-458, § 1011.

11The eight Department of Defense IC elements that were not within the scope of our 

review were Air Force Intelligence, Surveillance and Reconnaissance; Army Military 

Intelligence; the Defense Intelligence Agency; Marine Corps Intelligence; the National 

Geospatial-Intelligence Agency; the National Reconnaissance Office; the National 

Security Agency; and Naval Intelligence. We also did not include DHS’s Coast Guard 

Intelligence and Criminal Investigations in our review because the Coast Guard is 

considered a military organization.
Page 7 GAO-14-204 Civilian Intelligence Community

IC CHCO officials indicated they are responsible for leading the design, 

development, and execution of human resource strategies, plans, and 

policies for the IC. In this role, IC CHCO works with both the civilian and 

military IC elements to collect and maintain information on the use of core 

contract personnel throughout the IC. Since fiscal year 2007, IC CHCO 

has compiled an annual core contract personnel inventory to provide 

information to Congress and others about the IC’s use of core contract 

personnel. This effort was in response to concerns from Congress that 

the IC relied too heavily on contractors and could not account for the 

number and costs of contract personnel on an annual basis.

The core contract personnel inventory includes information on both the 

civilian and military IC elements’ contracts for over 10 different data 

fields.12 IC CHCO uses information from the inventory to develop an 

annual briefing for Congress, which includes year-to-year changes in the 

number of and reasons for using core contract personnel across the IC. In 

addition, since fiscal year 2011, IC CHCO has prepared a statutorily 

required IC-wide annual personnel level assessment.13

To prepare the inventory, IC CHCO provides guidance and a data call to 

the IC elements on an annual basis that details how the elements should 

report information on their core contracts from the previous fiscal year. 

Civilian IC element officials stated that generally their elements’

contracting, program, finance office, or a combination thereof, collects 

and reports the information for the data call.

As part of this 

assessment, IC CHCO is required, in consultation with all of the IC 

elements, to report on the current, projected, and prior five fiscal years’

number and costs of core contract personnel, as well as present the 

budget submission for personnel costs for the upcoming fiscal year.

 12The different data fields include information such as the name of the contractor, amount 

of funds obligated in a fiscal year, number of total direct labor hours, number of contractor 

FTEs, and reason for using a contractor to perform the service. The number and types of 

data fields available vary by fiscal year.

13Intelligence Authorization Act for Fiscal Year 2010, Pub. L. No. 111-259, § 305(a).

IC Core Contract 

Personnel Inventory
Page 8 GAO-14-204 Civilian Intelligence Community

For more than 20 years, OMB procurement policy has indicated that 

agencies should provide a greater degree of scrutiny when contracting for 

services that can affect the government’s decision-making authority.14

Without proper management and oversight, such services risk 

inappropriately influencing the government’s control over and 

accountability for decisions that may be supported by contractors’ work. 

The policy therefore directs agencies to ensure that they maintain 

sufficient government expertise to manage the contracted work. The 

Federal Acquisition Regulation also addresses the importance of 

management oversight associated with contractors providing services 

that have the potential to influence the authority, accountability, and 

responsibilities of government employees.15 Core contract personnel 

perform the types of functions that may affect an IC element’s decisionmaking authority or control of its mission and operations. While core 

contract personnel may perform functions that closely support inherently 

governmental work, these personnel are generally prohibited from 

performing inherently governmental functions, which require discretion in 

applying government authority or value judgments in making decisions 

that can only be performed by government employees.16

 14OFPP Policy Letter 92-1, Inherently Governmental Functions (Sept. 23, 1992 

[Rescinded]); OFPP Policy Letter 93-1, Management Oversight of Service Contracting 

(May 18, 1994).

Figure 2 

illustrates how the risk of contractors influencing government decision 

making is increased as core contract personnel perform functions that 

closely support inherently governmental functions.

15FAR § 37.114(b).

16Certain civilian IC elements have the authority to hire personal services contractors. The 

FAR does not explicitly prohibit these contractors from performing inherently governmental 

functions.

Risks Related to Reliance 

on Core Contract 

Personnel
Page 9 GAO-14-204 Civilian Intelligence Community

Figure 2: Risk Associated with the Use of Core Contract Personnel

OMB has initiated a number of government-wide interrelated efforts that 

help to address the risks related to relying on contractors for services that 

are closely associated with inherently governmental work or critical to an 

agency’s mission (see app. IV for additional information on these OMB 

policy requirements). Although the IC elements are not required to 

address certain aspects of the OMB policies, either because of the 

classified nature of the contracts or because the IC element is a 

component of an executive department, these efforts provide IC elements 

with leading practices related to considering and mitigating risks when 

relying on contractors to perform services that are closely associated with 

inherently governmental and critical functions. The IC elements are also 

required to follow applicable IC-wide guidance and federal laws and 

regulations on the use of contractors. In addition, the departmental 

elements—the six civilian IC elements that are components within 

executive departments—must comply with related departmental policies 

and guidance. For example, DEA NN must comply with federal laws and 
Page 10 GAO-14-204 Civilian Intelligence Community

regulations as well as all applicable OMB, DOJ, DEA, and IC-wide 

guidance.

OMB’s July 2009 guidance and our prior work have emphasized that 

decisions regarding the use of contractors should be based on strategic 

workforce planning regarding what types of work are best done by 

government personnel or by contractors.17 Specifically, agencies should 

identify the appropriate mix of government and contract personnel on a 

function-by-function basis, especially for functions that are critical to an 

agency’s mission. The OMB guidance requires an agency to have 

sufficient internal capability to control its mission and operations when 

contracting for these critical functions. Our prior work has found that 

agencies should have overarching strategic-level guidance related to the 

extent to which contractors should be used, and agencies’ strategic 

workforce planning documents should contain evidence of strategic 

considerations of contractor use.18 In May 2013, we found that DOD had 

not yet assessed the appropriate mix of government and contract 

personnel in its strategic workforce plans as required by law and, as a 

result, was hampered in making more informed strategic workforce 

decisions. We recommended that DOD revise existing workforce policies 

and procedures to address the determination of the appropriate workforce 

mix.19

OFPP’s September 2011 Policy Letter 11-01 builds on past federal 

policies on closely supporting inherently governmental functions by 

including a detailed checklist of responsibilities that must be carried out 

when agencies rely on contractors to perform services that closely 

support inherently governmental functions. The policy letter also builds 

upon past OMB guidance by seeking to broaden agencies’ focus to 

include critical functions, which can pose a risk if not carefully monitored. 

The policy letter establishes criteria agencies are to use in identifying their 

critical functions, which are functions that are necessary to the agency to 

effectively perform and maintain control of its mission and operations. The 

DOD partially concurred with this recommendation and noted that it 

had efforts underway to determine the workforce mix.

 17OMB M-09-26 (July 29, 2009); GAO-02-373SP.

18GAO, Human Capital: A Self-Assessment Checklist for Agency Leaders, 

GAO/OCG-00-14G (Washington, D.C.: September 2000).

19GAO, Human Capital: Additional Steps Needed to Help Determine the Right Size and 

Composition of DOD’s Total Workforce, GAO-13-470 (Washington, D.C.: May 29, 2013).
Page 11 GAO-14-204 Civilian Intelligence Community

policy letter further states that the more important the function, the more 

important it is that the agency have internal capability to maintain control 

of its mission and operations. The policy letter requires executive branch 

departments and agencies to develop and maintain internal procedures to 

address the requirements of the guidance.

Further, OFPP’s November 2010 and December 2011 guidance on 

service contract inventories20 and our prior work21 have emphasized that 

an inventory of contracted services, if effectively developed and analyzed, 

can inform an agency’s strategic workforce planning efforts and help 

identify which contracts may require additional oversight. The inventories 

can assist an agency in understanding the extent to which contractors are 

being used to perform activities that closely support inherently 

governmental work or support the agency’s mission and operations. 

Civilian agencies and DOD are statutorily required to compile service 

contract inventories on an annual basis.22 In September 2012, we found 

that the civilian agencies did not have good visibility on the number of 

contractor personnel or their role in supporting agency activities because 

they had not yet collected these data in their fiscal year 2011 

inventories.23

Additionally, in May 2013, we found that DOD generally continued to have 

challenges collecting key data in its fiscal year 2011 inventory, which 

limited the utility, accuracy, and completeness of the inventory data.24

 20OFPP Memorandum, Service Contract Inventories (Nov. 5, 2010); OFPP Memorandum, 

Service Contract Inventories (Dec. 19, 2011).

Specifically, most DOD components, other than the Army, were not able 

to determine the number of contractor FTEs used to perform each 

contracted service and were still not able to identify and record more than 

one type of service purchased for each contracting action entered into the 

21GAO, Defense Acquisitions: Continued Management Attention Needed to Enhance Use 

and Review of DOD’s Inventory of Contracted Services, GAO-13-491 (Washington, D.C.: 

May 23, 2013); Civilian Service Contract Inventories: Opportunities Exist to Improve 

Agency Reporting and Review Efforts, GAO-12-1007 (Washington, D.C.: Sept. 27, 2012); 

and Sourcing Policy: Initial Agency Efforts to Balance the Government to Contractor Mix in 

the Multisector Workforce, GAO-10-744T (Washington, D.C.: May 20, 2010).

2231 U.S.C. § 501, note, and 10 U.S.C. § 2330a(a).

23GAO-12-1007.

24GAO-13-491.
Page 12 GAO-14-204 Civilian Intelligence Community

inventory. We made a number of recommendations to help implement 

and improve both the civilian agencies’ and DOD’s service contract 

inventories. For example, we recommended that OMB clarify guidance to 

require agencies to consistently report on the number of contract 

personnel. OMB generally concurred with our recommendations and 

agreed to work with the agencies to strengthen their use of service 

contract inventories by sharing lessons learned and best practices from 

the initial inventories.

Due to limitations in the core contract personnel inventory, we could not 

accurately determine the extent to which the eight civilian IC elements 

have used core contract personnel. The inventory contains two data 

fields—fiscal year obligations and total FTEs—that IC CHCO uses to 

identify the civilian IC elements’ extent of contractor reliance. IC CHCO 

used this inventory information to report to Congress that from fiscal year 

2009 to 2011, the number of core contract personnel for the civilian IC 

elements declined by approximately 30 percent. However, we identified 

several issues that limit the comparability, accuracy, and consistency of 

the information reported by the civilian IC elements as a whole. First, 

changes to the definition of core contract personnel and data reliability 

limitations identified by the elements for certain years hinder the ability to 

use the inventory to make year-to-year comparisons of cost and FTE 

data. Second, our analysis found that the reported contract costs for the 

fiscal years 2010 and 2011 inventories were inaccurate or inconsistently 

determined. Third, elements calculated the number of core contract 

personnel FTEs differently, affecting the consistency of the information 

reported. In addition, a lack of readily available documentation limits the 

civilian IC elements’ ability to validate the information reported. Further, 

IC CHCO did not clearly explain the effect of the limitations when 

reporting the information to Congress. On an individual basis, some of the 

limitations we identified may not raise significant concerns. When taken 

together, however, they undermine the utility of the information for 

determining and reporting on the extent to which the civilian IC elements 

use core contract personnel.

Limitations in the 

Inventory Undermine 

Ability to Determine 

Extent of Civilian IC 

Elements’ Reliance 

on Contractors
Page 13 GAO-14-204 Civilian Intelligence Community

Trends in the civilian IC elements’ use of core contract personnel from 

fiscal year 2007 to 2011 in terms of the number of personnel and 

associated costs cannot be identified due to changes in the definition of 

core contract personnel and known data shortcomings. However, IC 

CHCO used the inventory information to compare IC-wide core contract 

personnel use from year to year when reporting to Congress. In response 

to federal statute, IC CHCO prepares an annual personnel assessment 

that compares the current and projected number and costs of core 

contract personnel to the number and costs during the prior 5 years. 

According to IC CHCO, the number of core contract personnel FTEs and 

associated costs declined nearly one-third from fiscal year 2009 to fiscal 

year 2011. However, we could not validate the extent to which there was 

a change in the number of core contract personnel providing support as 

we determined that a significant portion of the reported reduction is 

attributable to definitional changes and improvements to data systems. 

Further, we assessed the reliability of the civilian IC elements’ reported 

information for the total FTEs and fiscal year obligations data fields and 

determined that the data were not sufficiently reliable for our purpose of 

identifying the extent of reliance on core contract personnel (see app. II).

Since IC CHCO’s initial data collection efforts for the core contract 

personnel inventory in fiscal year 2006, it has taken actions to further 

clarify and refine its guidance to address concerns that IC elements were 

interpreting the definition of core contract personnel differently and to 

improve the consistency of the information in the inventory. IC CHCO 

worked with the elements to develop a standard definition that was 

formalized with the issuance of ICD 612 in October 2009. Further, IC 

CHCO formed the IC Core Contract Personnel Inventory Control Board, 

which has representatives from all of the IC elements, to provide a forum 

to resolve differences in the interpretation of IC CHCO’s guidance for the 

inventory. As a result of the board’s efforts, IC CHCO provided 

supplemental guidance in fiscal year 2010 to either include or exclude 

certain contract personnel, such as those performing administrative 

support, training support, and information technology services. For 

example, the guidance stated that IC elements should include contract 

personnel who provide training that is unique to the IC mission but 

exclude those who provide training commercially available through a 

vendor. IC CHCO officials told us that changes made over time were 

intended to clarify the definition of core contract personnel and improve 

the consistency of the information in the inventory. Appendix V 

summarizes the major changes in the definition reflected in IC CHCO’s 

guidance from fiscal years 2007 through 2011.

Changes to Core Contract 

Personnel Definition and 

Data Shortcomings Limit 

Comparability of 

Obligation and FTE Data 

Across Years
Page 14 GAO-14-204 Civilian Intelligence Community

While these changes could improve the inventory data, it is unclear the 

extent to which the definitional changes contributed to the reported 

decrease in the number of core contract personnel and associated costs 

from year to year. For example, for fiscal year 2010, officials from one 

civilian IC element told us they stopped reporting information technology 

help desk contractors, which had been previously reported, to be 

consistent with IC CHCO’s revised definition. One of these officials stated 

consequently that the element’s reported reduction in core contract 

personnel between fiscal years 2009 and 2010 did not reflect an actual 

change in their use of core contract personnel, but rather a change in how 

core contract personnel were defined for the purposes of reporting to IC 

CHCO. The official told us that their reported information for fiscal year 

2010 was therefore not comparable to data from prior years, in part 

because of definitional changes.

Further, this civilian IC element identified data reliability limitations in the 

information reported to IC CHCO for certain fiscal years’ inventories, 

which the element has taken steps to address. However, while IC CHCO 

noted that this civilian IC element implemented an enhanced contract 

management system that affected the element’s reporting in the briefing 

and annual personnel level assessment, IC CHCO did not disclose how 

these improvements affected the ability to compare data across years. 

For its submission to the fiscal year 2011 inventory, officials from the 

civilian IC element stated that they used a new contract management 

system that provided more clarity into which FTEs and obligations should 

be included in the inventory and thus improved the reliability of their 

reported information. These officials acknowledged significant limitations 

with certain aspects of their reported data prior to fiscal year 2011 due to 

limitations with the contract management system used for those years. 

For example, officials told us that prior to the contract system upgrade, 

the system did not allow them to accurately separate out which 

obligations and FTEs on certain contracts should be considered core 

versus non-core. As a result, these officials stated that we should not 

compare the information reported from fiscal year 2010 to 2011 due to the 

improvements made in the contract management system.

However, IC CHCO included this civilian IC element’s data when 

calculating the IC’s overall reduction in number of core contract personnel 

between fiscal years 2009 and 2011 in its fiscal year 2011 briefing to 

Congress. In addition, IC CHCO included these data when comparing the 

number and costs of core contract personnel between fiscal year 2009 

and 2011 in the fiscal year 2013 personnel level assessment. OMB 

guidelines provide that agencies should ensure that disseminated 
Page 15 GAO-14-204 Civilian Intelligence Community

information be reliable, clear, and useful to the intended users.25

In addition, another civilian IC element changed its methodology for 

calculating core contract personnel FTEs over time, which limits the ability 

to compare this FTE information across certain years. Prior to its 

submission to the fiscal year 2010 inventory, this element calculated an 

estimated number of core contract personnel FTEs by applying a certain 

percentage to the number of contractor FTEs. For its submissions to the 

fiscal year 2010 and 2011 inventories, the element reported the actual 

number of core contract personnel FTEs. According to officials from this 

civilian IC element, because the methodology for calculating the number 

of core contract personnel FTEs fundamentally changed from fiscal year 

2009 to 2010, the data cannot be compared across these years. 

However, IC CHCO reported and compared these numbers in its annual 

briefings and personnel level assessments without including information 

on these changes and any associated limitations. IC CHCO officials 

stated that they rely on the IC elements to inform them of any 

methodological changes that would impact the information reported. In 

addition, IC CHCO officials stated that they identify any major differences 

between fiscal years and the associated causes. By not fully disclosing 

the appropriate qualifications for making year-to-year comparisons, the 

information reported in the briefings and personnel level assessments 

may not be consistent with leading practices outlined in OMB’s guidelines 

for disseminated information.

IC 

CHCO explained in the briefing and personnel level assessment that this 

civilian IC element’s rebaselining had an effect on the element’s reported 

number of contractor personnel for fiscal year 2010. IC CHCO did not 

explain that the rebaselining would limit the comparability of the number 

and costs of core contract personnel for both this civilian IC element and 

the IC as a whole because the element did not adjust the number and 

costs previously reported.

 25Office of Management and Budget, Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies. 67 Fed. 

Reg. 8452 (Feb. 22, 2002).
Page 16 GAO-14-204 Civilian Intelligence Community

The civilian IC elements’ core contract personnel costs for fiscal years 

2010 and 2011 could not be reliably determined, in part because our 

analysis identified numerous discrepancies between the amount of 

obligations reported by the civilian IC elements in the core contract 

personnel inventory and these elements’ supporting documentation for 

the records we reviewed. We compared the information reported for a 

sample of 287 records—representing 222 contracts or purchase orders—

from the civilian IC elements’ submissions for the fiscal years 2010 and 

2011 inventories. We found that the civilian IC elements either under- or 

over-reported the amount of obligations by more than 10 percent for 

approximately one-fifth of the records. In addition, the civilian IC elements 

could not provide complete documentation to validate the information 

reported for 17 percent of the records we reviewed. Overall, we were able 

to validate the amount of reported obligations for approximately 43 to 

77 percent of the records we reviewed at any one element. However, IC 

CHCO used the core contract personnel inventory information to report 

fiscal years 2010 and 2011 contract costs for the eight civilian IC 

elements in our review.

Civilian IC element officials identified several issues that may account for 

the discrepancies between the reported obligations and the 

documentation provided. For example, ODNI officials told us that the 

system used to report their fiscal year 2010 data had reliability issues, in 

part because the users had to manually enter obligations for certain 

contracts or manually delete duplicate contracts to avoid double-counting 

obligations. ODNI officials stated that a new contract management 

system was used for reporting contract obligations in their submission for 

the fiscal year 2011 inventory. According to these officials, the new 

system offers greater detail and improved functionality for identifying the 

amount of obligations on their contracts. While we observed an 

improvement in ODNI’s reporting of obligations from fiscal year 2010 to 

2011, we still identified discrepancies in 18 percent of ODNI’s fiscal year 

2011 records in our sample. ODNI officials noted that, even with the new 

system, they manually enter the information into the inventory 

submission, which may result in data entry errors.

Internal control activities, such as accurate and timely recording of 

transactions, help provide reasonable assurance of the reliability of 

reported information. According to federal internal control standards, for 

an agency to run and control its operations, it must have relevant, reliable 

Inventory Does Not 

Accurately and

Consistently Account for 

Contract Costs
Page 17 GAO-14-204 Civilian Intelligence Community

information relating to internal events.26

In addition, we found that the reported costs in the inventory, which 

support the personnel level assessments and briefings to Congress, may 

not fully account for the amount of obligations on certain core contracts in 

a given fiscal year based on the methods permitted by IC CHCO 

guidance. IC CHCO’s guidance for the fiscal years 2010 and 2011 

inventories generally requires IC elements to report on the total amount of 

funds obligated to contracts during the fiscal year. However, the guidance 

also indicates that reporting on a snapshot of active contracts on 

September 30 is an acceptable method for the large elements. This 

practice may lead to elements not fully accounting for the amount of 

obligations within a fiscal year on contracts. For example, officials from 

two civilian IC elements told us they do not report the amount of 

obligations on contracts or contract line items that are no longer active as 

of September 30.

IC CHCO officials stated that they 

review the IC elements’ submissions for outliers and obvious errors but 

rely on the elements to ensure the accuracy of the information, in part 

because IC CHCO does not have the staff resources for more extensive 

reviews. IC CHCO officials also explained that their role is to provide 

guidance to the IC elements for reporting the information to the inventory 

but not to audit the reliability of the information reported. While civilian IC 

element officials described some steps taken to help ensure the reliability 

of the information reported, such as reviewing the information reported for 

outliers or prohibiting changes without prior approval, these internal 

controls may not be sufficient in light of the challenges we identified.

27

 26Internal controls should provide reasonable assurance that the objectives of the agency 

are being achieved according to the following categories: effectiveness and efficiency of 

operations including the use of the entity’s resources; reliability of financial reporting, 

including reports on budget execution, financial statements, and other reports for internal 

and external use; and compliance with applicable laws and regulations. Internal controls 

may vary by agency due to a number of factors, such as the size and complexity of the 

organization. Examples of internal control activities include reviews by management, 

accurate and timely recording of transactions, and appropriate documentation of 

transactions and internal control. GAO, Standards for Internal Control in the Federal 

Government, 

Officials acknowledged that in some cases, 

obligations may not be reported as a result of the exclusion of inactive 

contracts or contract option periods. However, IC CHCO does not 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

27We were unable to determine the full magnitude of obligations not included in the 

inventory because we did not have a way to identify all contracts not reported by the 

civilian IC elements.
Page 18 GAO-14-204 Civilian Intelligence Community

disclose this methodology or its effects on the information it reports to 

Congress.

The number of core contract personnel providing support to the civilian IC 

elements for fiscal years 2010 and 2011 could not be reliably determined, 

in part because we found that the eight civilian IC elements used 

significantly different methodologies when determining the number of 

FTEs. For example, some civilian IC elements estimated contract 

personnel FTEs using target labor hours while other civilian IC elements 

calculated the number of FTEs using the labor hours invoiced by the 

contractor. As a result, the reported numbers are not comparable across 

these elements. The IC CHCO core contract personnel inventory 

guidance for both fiscal years 2010 and 2011 state that full accounting is 

the preferred method for identifying FTEs, but does not provide additional 

detail, such as specifying appropriate methodologies for calculating FTEs, 

requiring IC elements to describe their methodologies, or requiring IC 

elements to disclose any associated limitations with their methodologies.

Depending on the methodology used, an element can calculate a different 

number of FTEs for the same contract. For example, for one contract we 

reviewed at a civilian IC element that reports FTEs based on actual labor 

hours invoiced by the contractor, the element reported 16 FTEs for the 

contract. For the same contract, however, a civilian IC element that uses 

estimated labor hours at the time of award would have calculated 27 

FTEs. As a result, using different methodologies limits the comparability 

of civilian IC elements’ reported numbers and obscures what the 

information represents in a given fiscal year. IC CHCO officials stated 

they have discussed standardizing the methodology for calculating the 

number of FTEs with the IC elements but identified challenges, such as 

identifying a standard labor-hour conversion factor for one FTE. IC CHCO 

guidance for fiscal year 2012 instructs elements to provide the total 

number of direct labor hours worked by the contract personnel to 

calculate the number of FTEs for each contract, as opposed to allowing 

for estimates, which could improve the consistency of the FTE information 

reported across the IC. Since this methodology is different than the 

methodology used by several civilian IC elements to calculate their 

number of FTEs in the fiscal year 2010 and 2011 inventories, IC CHCO 

will be further limited in the extent to which it can compare FTE data 

across years.

In addition, we found that most of the civilian IC elements did not maintain 

readily available documentation of the information used to calculate the 

Lack of Detailed Guidance 

and Complete 

Documentation Limit 

Consistency of FTE 

Information Reported
Page 19 GAO-14-204 Civilian Intelligence Community

number of FTEs reported for a significant number of the records we 

reviewed. As a result, these elements could not easily replicate the 

process for calculating or validate the reliability of the information reported 

for these records. Federal internal control standards call for appropriate 

documentation to help ensure the reliability of the information reported.28

IC CHCO and the civilian IC element officials further identified several 

challenges related to elements’ preparation of their inventory 

submissions. Officials at several civilian IC elements stated that they 

experienced turnover in the staff who prepared their submissions over the 

years. As a result, these officials were unable to explain the methodology 

used by staff to report the information for certain submissions in prior 

years. IC CHCO officials stated that they frequently have to work with 

new staff at the elements to help them understand the reporting 

For 37 percent of the 287 records we reviewed, we could not determine 

the reliability of the information reported. Two of the civilian IC elements 

were able to provide documentation to support the number of FTEs 

reported for almost all of the records we reviewed, but the other civilian IC 

elements experienced challenges in providing documentation to varying 

degrees. For example, officials from one civilian IC element explained 

that they did not document how they calculated the number of core 

contract personnel FTEs at the time of reporting. As a result, these 

officials stated that it would be very time-consuming to replicate the 

process for making these calculations, and that, for contracts with higher 

numbers of contract personnel, it could take months to recreate the 

methodology used. In addition, another civilian IC element had challenges 

providing documentation for certain records, in part because some 

contracts included in the inventory are fixed-price contracts for which it 

does not negotiate or have insight into the number of FTEs. While IC 

CHCO does not require the IC elements to maintain documentation of 

their calculations, without complete documentation, elements cannot 

ensure the reliability of the information reported in their submissions or 

may not be able to replicate the methodology used to report the number 

of FTEs for their contracts. However, IC CHCO aggregates and compares 

the FTE data across the civilian IC elements when reporting to Congress 

and has not disclosed in its briefings or personnel level assessments that 

the FTEs, reported collectively or by element, reflect various definitions 

and methods of counting contract personnel.

 28GAO/AIMD-00-21.3.1.
Page 20 GAO-14-204 Civilian Intelligence Community

requirements because the elements did not have documentation of how 

prior staff reported certain information. In addition, for a large civilian IC 

element, many contracting and program officials can be involved in 

preparing the elements’ submissions, making it difficult to ensure 

consistency in reporting.

The civilian IC elements have used core contract personnel to perform a 

range of functions, such as human capital, information technology, and 

program management, and have reported in the core contract personnel 

inventory the reasons for using contractors for such functions. Due to 

limitations in the core contract personnel inventory, the number of core 

contract personnel performing these functions in support of the civilian IC 

elements and the reasons for their use cannot be reliably determined. We 

found for the contracts we reviewed, the civilian IC elements generally 

reported reliable information in the inventory on functions performed by 

contractors by selecting from one of over 20 broad categories. However, 

the limitations we identified in the inventory’s obligation and FTE data 

preclude the information on contractor functions from being used to 

determine the extent to which civilian IC elements contracted for each 

function. Further, in the inventory, the civilian IC elements provided 

information on their reasons for using core contract personnel, such as 

the need for unique expertise, but our analysis found that 40 percent of 

the contracts in our sample did not contain evidence of the reasons 

reported. As a result, we could not corroborate the information reported in 

the inventory on the reasons for using core contract personnel. Moreover, 

the most widely cited reason in the sample of contracts we reviewed does 

not describe why a civilian IC element contracted for a service but rather 

describes the nature of the contract.

As part of the core contract personnel inventory, IC CHCO collects 

information from the elements on contractor-performed functions using 

the primary contractor occupation and competency expertise data field. 

An IC CHCO official explained that this data field should reflect the tasks 

performed by the contract personnel. IC CHCO’s guidance for this data 

field instructs the IC elements to select one option from a list of over 20 

broad categories of functions for each contract entry in the inventory. 

Based on our review of relevant contract documents, such as statements 

of work, we were able to verify the primary contractor occupation and 

competency expertise reported for almost all of the records we reviewed. 

Using the primary contractor occupation and competency expertise data 

field in the core contract personnel inventory, the civilian IC elements 

Inventory Provides 

Limited Insight into 

Functions Performed 

by Contractors and 

Reasons for Their 

Use

Extent to Which Functions 

Are Performed by Contract 

Personnel Cannot Be 

Determined
Page 21 GAO-14-204 Civilian Intelligence Community

reported functions performed such as human capital, information 

technology, program management, administration, collection and 

operations, and security services, among others.

While we could verify the categories of functions performed for the 

contracts we reviewed, we could not determine the extent to which civilian 

IC elements contracted for these functions. Limitations we identified in the 

obligation and FTE data reported in the inventory precluded us from using 

the information on contractor functions to determine the number of 

personnel and their costs associated with each function category. For 

example, we were able to verify for one State INR contract that contract 

personnel performed functions within the systems engineering category, 

but we could not determine the number of personnel dedicated to that 

function because of unreliable obligation and FTE data.

In addition, IC CHCO provides information on contractor functions in its 

reports and briefings to Congress. However, it does not include the 

information it collects through the inventory’s primary contractor 

occupation and competency expertise data field. IC CHCO instead uses 

the budget category data field in the inventory as its source for

information on functions performed by core contractor personnel, citing a 

desire for information provided to Congress to align with the budget 

request. The budget category data field, however, reflects a contract’s 

funding source rather than the functions performed by personnel working 

under these contracts. By using budget category information as a proxy 

for contractor functions, IC CHCO does not adhere to leading practices 

outlined in OMB guidelines for disseminated information.29

 29Office of Management and Budget, Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies. 67 Fed. 

Reg. 8452 (Feb. 22, 2002).

OMB 

guidelines provide that agencies should ensure that disseminated 

information be accurate, clear, and useful to the intended users. IC 

CHCO and civilian IC element officials acknowledged that the budget 

category is not the best representation of the functions performed by 

contractors. For example, we found contracts from one civilian IC element 

that were reported as collection and operations for the budget category, 

as required by IC CHCO guidance, included services such as policy and 
Page 22 GAO-14-204 Civilian Intelligence Community

program development support, information technology, and 

administration.30

The reasons that the civilian IC elements use core contract personnel 

could not be reliably determined from the core contract personnel 

inventory information due to a lack of documentation to corroborate the 

reasons reported in the inventory. In preparing their inventory 

submissions, IC elements can select one of eight response options for the 

reason data field (see table 1).

Table 1: Available Response Options in the Core Contract Personnel Inventory for IC Elements to Report on Reasons for 

Using Contractors

Reason for using contract 

personnel Definition of reason from IC CHCO guidance

Discrete non-recurring task To accomplish a discrete, nonrecurring, or temporary project, work assignment, or task of 

definite duration or deliverable, such that the contract ends when the project, assignment, or 

task is completed.

Immediate surge To provide surge support for a particular IC mission area. In this regard, the use of a 

contractor enables the IC element to rapidly expand to meet a mission or business exigency, 

and then curtail that contract support when the exigency passes. A surge requirement may 

be of extended duration.

Insufficient staffing resources To perform work that would otherwise have been provided by a U.S. Government civilian 

given sufficient resources.

More efficient or effective To provide support or administrative services, where the provision of such services by 

contract personnel is determined to be effective or efficient.

Specified service To provide a specified service, including technical assistance, in support of a core mission or 

function, where that service is of indefinite quantity.

Transfer of institutional knowledge To maintain critical continuity or skills in support of a particular mission or functional area in 

the face of skills gaps, the loss (anticipated or otherwise) of mission-essential U.S. 

Government civilian or military personnel, or other similar exigency.

Unique expertise To provide unique technical, professional, managerial, or intellectual expertise to the IC 

element, where such expertise is not otherwise available from U.S. Governmental civilian or 

military personnel.

Other Requires explanation in contractor inventory comments.

Source: IC CHCO.

 30The IC CHCO core contract personnel inventory guidance instructs the elements to 

complete the budget category data field by reporting where the funding for the contract is 

assigned according to the Congressional Budget Justification Books.

Data on Reasons for 

Contractor Use Not 

Supported by 

Documentation and Do 

Not Always Provide Insight
Page 23 GAO-14-204 Civilian Intelligence Community

However, we could not verify the information reported by the civilian IC 

elements in the inventory due to a lack of corroborating documentation. 

For the 81 of the 102 records in our sample coded as unique expertise, 

we did not find evidence in the statements of work or other contract 

documents that the functions performed by the contractors required 

expertise not otherwise available from U.S. government civilian or military 

personnel. For example, ODNI contracts coded as unique expertise 

included services for conducting workshops and analysis, producing 

financial statements, and providing program management. Based on 

inventory submissions by both the civilian and military IC elements, IC 

CHCO reported to Congress that for fiscal year 2011, 57 percent of the 

core contract personnel FTEs were contracted for their unique expertise.

Further, we found that the most widely used reason response option 

among the records we reviewed—specified service—does not provide 

insight into the civilian IC elements’ reasons for using core contract 

personnel. Instead, this response option describes the nature of the 

contract. Of the 287 records we reviewed, civilian IC elements selected 

specified service as the reason for the contract for 45 percent of those 

records. For example, an official from one civilian IC element stated that 

they selected specified service for all of their contracts in the fiscal years 

2010 and 2011 inventories because, in accordance with the definition, 

they were buying services. However, these officials also cited the need 

for contractors due to personnel restrictions and budgetary 

considerations, which could correspond to the insufficient staffing 

resources response option.

Civilian IC element officials noted that the reasons for contractor use 

reported in the inventory are subjective and based on the knowledge of 

the contracting or program official at the time of reporting. IC CHCO does 

not require elements to maintain supporting documentation for their 

contract reason codes. As a result, the civilian IC elements could not 

provide documentation for 40 percent of the records we reviewed. 

Additionally, an official from one civilian IC element told us that there was 

confusion among program offices responsible for determining the reason 

code as to the specific meaning of certain response options for the 

reason code. Civilian IC element officials stated that multiple reasons 

could pertain for utilizing the contract, but they can only select one option 

for the purposes of the inventory. For example, while officials from one 

civilian IC element stated that many of their contractors are brought on 

board for their institutional knowledge and skills, this element’s inventory 

data does not reflect the transfer of institutional knowledge reason code 

for any of their reported contracts. Most of this element’s contracts were 
Page 24 GAO-14-204 Civilian Intelligence Community

coded as unique expertise, more efficient or effective, and specified 

service, which were supported by the contract documents. Due to the 

subjectivity of the coding, combined with the capability to only select one 

response and without requiring supporting documentation, the reasons 

identified in the civilian IC elements’ inventory submissions do not fully 

reflect why they use core contract personnel.

CIA, ODNI, and the executive departments, which are responsible for 

developing policies to address risks related to contractors for the other six 

civilian IC elements within those departments, have generally made 

limited progress in developing such policies. Further, the eight civilian IC 

elements have generally not developed strategic workforce plans that 

address contractor use. While DHS and State have issued policies and 

guidance that address generally all of OFPP Policy Letter 11-01’s 

requirements related to contracting for services that closely support 

inherently governmental functions, the other departments, CIA, and ODNI 

are in various stages of developing required internal policies to address 

the policy letter. In addition, the civilian IC elements’ decisions to use 

contractors are generally not informed by strategic workforce plans or 

other strategic-level guidance on the appropriate mix of government and 

contract personnel for functions that are critical to elements’ missions. 

The civilian IC elements’ ability to use the core contract personnel 

inventory as a strategic workforce planning tool is hindered because the 

inventory does not provide these elements insight into the functions 

performed by contractors or the extent to which contractors are 

performing functions that closely support inherently governmental 

functions or are critical. Without guidance, strategies, and tools related to 

services that closely support inherently governmental functions and 

critical functions, the civilian IC elements may not be well-positioned to 

identify and manage the related risks of contracting for those functions.

Limited Progress Has 

Been Made in 

Developing Policies 

and Strategies on 

Contractor Use to 

Mitigate Risks
Page 25 GAO-14-204 Civilian Intelligence Community

OFPP Policy Letter 11-01’s requirements related to contracting for 

services that closely support inherently governmental functions include 

giving special consideration to using federal employees to perform these 

functions, and if contractors are used to perform such work, giving special 

management attention to contractors’ activities. The policy letter includes 

a checklist of responsibilities that must be carried out when agencies rely 

on contractors to perform these functions and requires agencies to 

develop and maintain internal procedures to address the requirements of 

the guidance. OFPP, however, did not establish a deadline for when 

agencies need to complete these procedures. In 2011, we concluded that 

a deadline may help better focus agency efforts to address risks and 

therefore recommended that OFPP establish a near-term deadline for 

agencies to develop internal procedures, including for services that 

closely support inherently governmental functions. OFPP generally 

concurred with our recommendation and commented that it would likely 

establish time frames for agencies to develop the required internal 

procedures, but it has not yet done so.31

We assessed the extent to which CIA, ODNI, and the executive 

departments of the other civilian IC elements—DHS, DOE, DOJ, State, 

and Treasury—developed internal procedures to address the policy letter 

because the civilian IC elements within departments are not required to 

develop their own procedures to address the policy letter. The 

departmental civilian IC elements are subject to policies and guidance at 

the department level for considering and managing risks related to 

contracting for services that closely support inherently governmental 

functions. Our analysis found that DHS and State have issued policies 

and guidance that generally address all of these requirements, but CIA, 

ODNI, and the other three departments have not fully developed policies 

to do so.

Civilian IC element and department officials cited various reasons for not 

yet developing policies to address all of the OFPP policy letter’s 

requirements. For example, Treasury officials stated that the OFPP policy 

letter called for dramatic changes in agency procedures and thus elected 

to conduct a number of pilots before making policy changes. DOE officials 

stated that they are waiting for revisions to the Federal Acquisition 

Regulation, which would incorporate the OFPP policy letter’s 

 31GAO-12-87.

CIA, ODNI, and 

Departments of the Other 

Civilian IC Elements Have 

Not Fully Developed 

Policies That Address 

Risks Associated with 

Contractors Supporting 

Inherently Governmental 

Functions
Page 26 GAO-14-204 Civilian Intelligence Community

requirements, before reviewing and updating their acquisition policies as 

necessary.

OMB’s July 2009 memorandum on managing the multisector workforce 

and our prior work on best practices in strategic human capital 

management have indicated that agencies’ strategic workforce plans 

should address the extent to which it is appropriate to use contractors.32

Civilian IC element officials stated that their decisions to use contractors 

are made on a case-by-case basis and that budgetary considerations, 

government personnel ceilings, and the cost-effectiveness of contractors 

are key factors in their decisions on whether to use contractors. For 

example, officials from several civilian IC elements stated that due to 

recent budgetary considerations, they have made efforts to reduce their 

reliance on contractors, in part by converting contractor positions to 

government positions when possible. OMB’s July 2009 memorandum on 

managing the multisector workforce, however, indicates that assessments 

of the appropriate workforce mix should generally not focus around a 

particular outcome, such as reducing the number of contractors.

The civilian IC elements’ current strategic workforce plans, however, 

generally do not address the extent to which it is appropriate to use 

contractors, either in general or more specifically to perform critical 

functions, as called for in the OMB guidance. For example, ODNI’s 2012-

2017 strategic human capital plan outlines the current mix of government 

and contract personnel by five broad function types: core mission, 

enablers, leadership, oversight, and other. The plan, however, does not 

elaborate on what the appropriate mix of government and contract 

personnel should be on a function-by-function basis. The plan also 

discusses efforts to reduce the number of core contract personnel but 

does not elaborate on particular functions to target. In August 2013, ODNI 

officials informed us they are continuing to develop documentation to 

address a workforce plan.

33

 32OMB M-09-26 (July 29, 2009); 

The 

memorandum indicates that agencies should identify which types of work 

GAO-02-373SP; and GAO, Human Capital: A SelfAssessment Checklist for Agency Leaders, GAO/OCG-00-14G (Washington, D.C.: 

September 2000).

33OMB M-09-26 (July 29, 2009).

Decisions to Use 

Contractors Not Guided by 

Strategies on Appropriate 

Mix of Government and 

Contract Personnel
Page 27 GAO-14-204 Civilian Intelligence Community

should be done by government personnel and contract personnel based 

on program goals, priorities, and associated human capital needs.

While IC CHCO requires IC elements to conduct strategic workforce 

planning and prepare a human capital employment plan, neither effort 

requires the elements to determine the appropriate mix of personnel 

either generally or on a function-by-function basis. ICD 612 directs IC 

elements to determine, review, and evaluate the number and uses of core 

contract personnel when conducting strategic workforce planning but 

does not reference the requirements related to determining the 

appropriate workforce mix specified in OMB’s July 2009 memorandum or 

require elements to document the extent to which contractors should be 

used. IC CHCO also required IC elements to submit a 2012-2016 human 

capital employment plan, which was to include information on the current 

workforce mix and expected changes as well as information on elements’

efforts to examine the mix of government and contract personnel, as 

appropriate. One IC CHCO official, however, explained that some IC 

elements’ strategic workforce planning efforts are more robust than 

others, so the level of detail and information provided in the plans vary 

widely across the IC elements. Nevertheless, irrespective of an agency’s 

size, OMB’s guidance on managing the multisector workforce notes that 

agencies that have a strategic understanding of their current and 

appropriate mix of personnel for each function are better positioned to 

build and sustain the internal capacity necessary to maintain control over 

their missions and operations.

OFPP’s November 2010 memorandum on service contract inventories 

indicates that a service contract inventory is a tool that can assist an 

agency in conducting strategic workforce planning.34

 34OFPP, Service Contract Inventories (Nov. 5, 2010).

Specifically, an 

agency can gain insight into the extent to which contractors are being 

used to perform specific services by analyzing how contracted resources, 

such as contract obligations and FTEs, are distributed by function across 

an agency. The memorandum further indicates that this insight is 

especially important for contracts whose performance may involve critical 

functions or functions closely associated with inherently governmental 

functions. OFPP officials stated that the IC’s core contract personnel 

inventory serves this purpose for the IC and, to some extent, follows the 

Civilian IC Elements’

Ability to Use Inventory for 

Strategic Planning 

Hindered by Limited 

Information on Contractor 

Functions
Page 28 GAO-14-204 Civilian Intelligence Community

intent of the service contract inventories guidance to help mitigate risks. 

OFPP officials stated that IC elements are not required to submit 

separate service contract inventories that are required of the civilian 

agencies and DOD, in part because of the classified nature of some of 

the contracts. The core contract personnel inventory, however, does not 

provide the civilian IC elements with detailed insight into the functions 

their contractors are performing or the extent to which contractors are 

used to perform functions that support their missions and closely support 

inherently governmental work. Without complete and accurate information 

in the core contract personnel inventory on the extent to which 

contractors are performing specific functions, the civilian IC elements may 

be missing an opportunity to leverage the inventory as a tool for 

conducting strategic workforce planning and for prioritizing contracts that 

may require increased management attention and oversight.

We found that the data reported by the civilian IC elements in the primary 

contractor occupation and competency expertise data field accurately 

reflect the broad categories of contracted functions for each contract, but 

these data do not provide detailed information on the functions performed 

by contractors. Based on the contract documents we reviewed, such as 

statements of work, we identified at least 128 instances in the 287 

records we reviewed in which the primary contractor occupation and 

competency expertise data field did not reflect the full range of services 

listed in the contracts. This was due in part to IC CHCO’s guidance, which 

instructs the elements to select only one service from the list of multiple 

response options for each contract entry in the inventory. An IC CHCO 

official explained that elements are instructed to select the predominant 

type of service provided by the contract given that elements are not able 

to record more than one type of service purchased for each contract. The 

civilian IC element officials acknowledged that the primary contractor 

occupation and competency expertise coding is not fully reflective of the 

services the contractors are performing.

IC CHCO’s guidance, including ICD 612 and core contract personnel 

inventory guidance, do not require the elements to review all of their 

contracts, including classified contracts, to ensure that they identify and 

manage risks related to contracts for services that closely support 

inherently governmental or critical functions. In contrast, the civilian 

executive agencies are statutorily required to compile an annual service 

contract inventory, and as part of the inventory review process, agencies 

are required to ensure that they are not using contract personnel to 

perform critical functions in such a way that could affect the ability of the 

agency to maintain control of its mission and operations and giving 
Page 29 GAO-14-204 Civilian Intelligence Community

special management attention to functions that closely support inherently 

governmental functions. However, certain civilian IC elements’ contracts, 

along with classified contracts at the civilian IC elements, are excluded 

from the civilian agencies’ service contract inventories. For those 

elements with contracts that are excluded from the civilian agencies’

service contract inventories, identifying which contracts contain these 

types of functions in the core contract personnel inventory could help 

target agencies’ efforts to provide enhanced management attention.

The eight civilian IC elements, like other federal agencies, have long 

relied on contractors to support their missions. In fiscal year 2006, IC 

CHCO initiated data collection efforts for the core contract personnel 

inventory to collect information from elements on their use of these 

personnel and to report to Congress on the number of core contract 

personnel and their associated costs. IC CHCO and the civilian IC 

elements have taken and continue to take steps to improve the reliability 

of the reported information, such as standardizing how FTEs will be 

calculated for the fiscal year 2012 inventory. These are positive steps. 

Nevertheless, we identified several limitations, including definitional 

changes, inaccurate data, methodological differences, and poor 

documentation, that collectively undermine the utility of the information for 

determining the extent to which the civilian IC elements rely on core 

contract personnel. As a result, the IC CHCO cannot reliably report on 

statutorily required information comparing the number and cost of core 

contract personnel over time. By enhancing their internal controls, the 

civilian IC elements can help ensure that the data being reported to 

Congress are as accurate and complete as possible and consistent with 

OMB guidelines. Further, inherent limitations or changes in definitions or 

methodologies, including those intended to improve the data, can affect 

data accuracy, completeness, and comparability. Not fully disclosing 

these limitations and the effects of these changes limits the transparency 

and usefulness of the information reported to Congress.

Within the IC, core contract personnel perform functions that could 

influence the direction and control of key aspects of the U.S. intelligence 

mission, such as intelligence analysis and operations. Our prior work and 

OMB policies have underscored the importance of agencies having 

guidance, strategies, and reliable data to inform decisions related to the 

appropriate use of contractor personnel. Building on longstanding OMB 

policy, OFPP’s September 2011 guidance requires agencies to develop 

internal procedures to identify and oversee contractors providing services 

that closely support inherently governmental functions. Yet, of the 

Conclusions
Page 30 GAO-14-204 Civilian Intelligence Community

agencies we reviewed, ODNI, CIA, DOJ, DOE, and Treasury have not 

fully developed such procedures or established required time frames for 

doing so. Without these procedures in place, ODNI, CIA, and the civilian 

IC elements within these three departments risk not taking appropriate 

steps to manage and oversee contract personnel, particularly those 

performing work that could influence government decision making. In an 

effort to help manage the use of contractor personnel within the IC, 

elements are required by ICD 612 to conduct strategic workforce planning 

related to their use of core contract personnel. However, ICD 612 falls 

short of OMB’s July 2009 memorandum on managing the multisector 

workforce by not requiring the elements to document their assessment of 

the appropriate use of contractors or the appropriate mix of government 

and contractor personnel on a function-by-function basis. One tool 

identified by OFPP that can help agencies plan for the use of contract 

personnel and mitigate associated risks is a service contract inventory, 

which for the IC is the annual core contract personnel inventory. Yet, as it 

is currently structured, the core contract personnel inventory is limited in 

its ability to be an effective tool for doing so. As a result, the civilian IC 

elements cannot use the inventory to identify those services that require 

increased management attention under OFPP’s September 2011 

guidance. Additionally, ICD 612 and other IC CHCO guidance do not 

require elements to identify in the inventory those contracts that provide 

critical services or those that closely support inherently governmental 

functions. Consequently, civilian IC elements or their respective 

departments we reviewed are not well-positioned to assess the potential 

effects of relying on contractor personnel who perform such functions.

To improve congressional oversight and enhance civilian IC elements’

insights into their use of core contract personnel, we recommend that IC 

CHCO take the following two actions:

• When reporting to congressional committees, clearly specify 

limitations and significant methodological changes and their 

associated effects and

• In coordination with the IC elements, develop a plan to enhance 

internal controls for compiling the annual core contract personnel 

inventory. Such a plan could include requiring IC elements to 

document their methodologies for determining the number and costs 

of core contract personnel and the steps the elements took for 

ensuring data accuracy and completeness.

Recommendations for 

Executive Action
Page 31 GAO-14-204 Civilian Intelligence Community

To improve civilian IC elements’ or their respective departments’ ability to 

mitigate risks associated with the use of contractors, we recommend the 

Director of National Intelligence, Director of the Central Intelligence 

Agency, Attorney General of the United States, and Secretaries of Energy 

and the Treasury direct responsible agency officials to set time frames to 

develop guidance that fully addresses OFPP Policy Letter 11-01’s 

requirements related to closely supporting inherently governmental 

functions.

To improve the ability of the civilian IC elements to strategically plan for 

their contractors and mitigate associated risks, we recommend that IC 

CHCO take the following three actions:

• Revise ICD 612’s provisions governing strategic workforce planning to 

require the IC elements to identify their assessment of the appropriate 

workforce mix on a function-by-function basis;

• Assess options for how the core contract personnel inventory could be 

modified to provide better insights into the functions performed by 

contractors when there are multiple services provided under a 

contract; and

• Require the IC elements to identify contracts within the core contract 

personnel inventory that include services that are critical or closely 

support inherently governmental functions.

We provided a draft of our September 2013 classified report to CIA, DHS, 

DOE, DOJ, ODNI, State, and Treasury for review and comment. We 

received written comments from ODNI, which are reprinted in appendix 

VI, as well as technical comments that we incorporated into the draft as 

appropriate. In its written comments, ODNI generally agreed with the six 

recommendations that we directed to it.

With regard to our first recommendation to clearly specify limitations and 

significant methodological changes and their associated effects when 

reporting on the IC’s use of core contract personnel, ODNI agreed that IC 

CHCO will highlight all adjustments to the data over time and the 

implications of those adjustments in future briefings to Congress and 

OMB. Similarly, ODNI agreed with our second recommendation 

to develop a plan to enhance internal controls for compiling the annual 

core contract personnel inventory. ODNI stated that IC CHCO, in 

coordination with the IC Chief Financial Office, has added requirements 

for the IC elements to include the methodologies used to identify and 

count the number of core contract personnel and their steps for ensuring 

Agency Comments 

and Our Evaluation
Page 32 GAO-14-204 Civilian Intelligence Community

the accuracy and completeness of the data. ODNI further stated that IC 

CHCO intends to request the methodologies used by the IC elements for 

the fiscal year 2014 budget data call, which includes the core contract 

personnel inventory.

In commenting on our third recommendation, ODNI proposed that when 

ICD 612 is revised, IC CHCO will request notification on the mechanism 

by which each IC element adheres to OFPP Policy Letter 11-01. We 

believe IC CHCO’s proposal to monitor the IC elements’ implementation 

of OFPP Policy Letter 11-01 can help improve policies and guidance to 

mitigate the risks associated with using contractors across the IC. ODNI, 

however, did not directly address whether it will set time frames to 

develop guidance for use within ODNI to fully address OFPP Policy Letter 

11-01’s requirements. We continue to believe that ODNI as an IC element 

should set timeframes to develop its own guidance that fully addresses 

the OFPP policy letter.

With regard to our fourth recommendation to revise ICD 612’s provisions 

governing strategic workforce planning, ODNI stated that IC CHCO has 

recognized the need to update ICD 612 and will work to determine the 

most appropriate mechanism to identify the functions performed within a 

contract. ODNI further noted that IC CHCO proposed that IC elements be 

responsible for ensuring they are addressing the appropriate workforce 

mix when conducting workforce planning rather than requiring this 

information as part of core contract personnel inventory data collection 

efforts. We believe that ODNI’s comments are consistent with our 

recommendation.

Regarding our fifth recommendation to assess options for how the core 

contract personnel inventory could be modified to provide better insights 

into the functions performed by contractors when multiple services are 

provided under a contract, ODNI stated that IC CHCO will examine the 

requirement to provide insights into all functions under a contract to 

determine if there is a need to modify the inventory to capture that level of 

information. As we note in our report, having better insight into contractor 

functions through the core contract personnel inventory can help the 

civilian IC elements conduct strategic workforce planning and prioritize 

contracts that may require increased management attention and 

oversight.

For our sixth recommendation to require the IC elements to identify 

contracts within the core contract personnel inventory that include critical 

services or those closely supporting inherently governmental functions, 
Page 33 GAO-14-204 Civilian Intelligence Community

ODNI stated it will explore doing so. ODNI noted in its comments that the 

definition of core contract personnel in ICD 612 is already aligned with 

OFFP Policy Letter 11-01’s definition of contract personnel who perform 

services that closely support inherently governmental functions. As we 

note in our report, however, not all core contract personnel perform 

functions that closely support inherently governmental functions and 

therefore do not need enhanced management oversight required by 

OFPP. Further, the definition of core contract personnel does not identify 

those functions that are critical to an agency’s mission. OFPP Policy 

Letter 11-01 requires agencies to take different steps to manage the risks 

related to contractors performing critical functions, such as ensuring 

government personnel perform or manage these functions to the extent 

necessary to maintain control of their missions and operations. Clearly 

identifying which contracts within the core contract personnel inventory 

include services that closely support inherently governmental functions as 

well as those that include critical functions will better position the civilian 

IC elements to assess the potential effects of relying on contract 

personnel who perform such functions and take any necessary actions to 

mitigate risks.

CIA, DOE, DOJ, and Treasury did not comment on our recommendation 

to them but generally provided technical comments that we incorporated 

into the draft as appropriate. DHS and State also provided technical 

comments which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees and the Attorney General of the United States; 

the Director of National Intelligence; the Director of the Central 

Intelligence Agency; and the Secretaries of Energy, Homeland Security, 

State, and the Treasury. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report or need additional 

information, please contact me at (202) 512-4841 or dinapolit@gao.gov. 

Contact points for our Congressional Relations and Public Affairs may be 
Page 34 GAO-14-204 Civilian Intelligence Community

found on the last page of this report. Staff who made key contributions to 

this report are listed in appendix VII.

Timothy J. DiNapoli

Director

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

Methodology

Page 35 GAO-14-204 Civilian Intelligence Community

The objectives of this review were to determine (1) the extent to which the 

civilian intelligence community (IC) elements rely on core contract 

personnel; (2) the functions performed by core contract personnel and the 

factors that contribute to their use; and (3) whether the civilian IC 

elements have developed policies and guidance and strategically planned 

for their use of these contract personnel to mitigate related risks. The 

eight civilian IC elements covered by our review are the Central 

Intelligence Agency (CIA), the Department of Energy’s Office of 

Intelligence and Counterintelligence (DOE IN), Department of Homeland 

Security’s Office of Intelligence and Analysis (DHS I&A), Department of 

State’s Bureau of Intelligence and Research (State INR), Department of 

the Treasury’s Office of Intelligence and Analysis (Treasury OIA), Drug 

Enforcement Administration’s Office of National Security Intelligence 

(DEA NN), Federal Bureau of Investigation (FBI), and Office of the 

Director of National Intelligence (ODNI).1

To address our first and second objectives, we examined the civilian IC 

elements’ submissions to the fiscal years 2007 to 2011 core contract 

personnel inventories, when available. The submissions contain 

information on the elements’ core contracts from over 10 data fields, 

which vary by fiscal year. For the purposes of answering the first and 

second objectives, we focused on five data fields related to the elements’

extent of reliance on core contract personnel, the functions performed by 

these contract personnel, and the factors that contributed to their use: 

fiscal year obligations, total full-time equivalents (FTE), primary contractor 

occupation and competency expertise, budget category, and reason 

code. We were not able to assess the reliability of the information 

reported for these data fields in the elements’ submissions to the fiscal 

years 2007 to 2009 inventories for various reasons, such as elements not 

having records of their submissions for certain years. In addition, the 

information reported for the fiscal year obligations, total FTEs, budget 

category, and reason code data fields in the elements’ submissions to the 

fiscal years 2010 to 2011 inventories was not sufficiently reliable for our 

intended purposes of determining the civilian IC elements’ extent of 

reliance on core contract personnel, the functions performed by these 

personnel, or the factors that contribute to their use. We present this 

information with the associated limitations in the report where appropriate. 

Although we identified some limitations, the primary contractor occupation 

 1

DEA NN and FBI are components of the Department of Justice (DOJ).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-14-204 Civilian Intelligence Community

and competency expertise data field was sufficiently reliable for 

identifying the general types of functions performed. However, because 

neither the fiscal year obligations nor total FTEs data field was sufficiently 

reliable, we could not determine the extent to which the civilian IC 

elements use contract personnel to perform certain functions based on 

the primary contractor occupation and competency expertise data field. 

Appendix II contains a more detailed discussion of our sampling 

methodology and data reliability assessment.

We also reviewed the Intelligence Community Chief Human Capital 

Officer’s (IC CHCO) annual guidance to elements for preparing their 

submissions to the fiscal years 2007 to 2012 inventories and information 

reported in annual core contract personnel inventory briefings and 

personnel level assessments provided to Congress. We interviewed 

officials at IC CHCO and the eight civilian IC elements on the processes 

for collecting and reporting their information for the inventory.

To address our third objective, we compared the civilian IC elements’ or 

their respective departments’ relevant guidance, planning documents, 

and tools related to their use of contractors to Office of Management and 

Budget (OMB) guidance that address risks related to relying on 

contractors. We reviewed Office of Federal Procurement Policy (OFPP) 

Policy Letter 11-01 and compared the policy letter’s requirements 

addressing contracting for closely supporting inherently governmental 

functions to civilian IC elements’ or their respective departments’

acquisition policies and guidance to determine the extent to which the 

requirements were met.2 We reviewed OMB’s July 2009 Memorandum on 

Managing the Multisector Workforce and GAO’s prior work on strategic 

human capital best practices and compared the leading practices 

identified to the strategic workforce planning requirement in Intelligence 

Community Directive (ICD) 612 and civilian IC elements’ strategic human 

capital or other workforce plans to determine the extent to which the 

leading practices were implemented.3

 2

OFPP Policy Letter 11-01, Performance of Inherently Governmental and Critical 

Functions (Sept. 12, 2011).

We reviewed the leading practices 

identified in OMB’s November 2010 and December 2011 memoranda on 

3

OMB M-09-26, Managing the Multisector Workforce (July 29, 2009) and GAO, A Model of 

Strategic Human Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 

2002).
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-14-204 Civilian Intelligence Community

service contract inventories and the civilian IC elements’ data on 

functions performed by contractors.4

ODNI, in consultation with the other civilian IC elements, deemed some of 

the information in the September 2013 report as classified, which must be 

protected from public disclosure. Therefore, this report omits sensitive 

information about (1) the number and associated costs of government 

and core contract personnel and some details on how the civilian IC 

elements prepare the core contract personnel inventory, (2) specific 

contracts from civilian IC elements we reviewed, and (3) details related to 

the civilian IC elements’ or their respective departments’ progress in 

developing policies to mitigate risks related to contractors and the civilian 

IC elements’ strategic workforce planning efforts.

We reviewed IC CHCO guidance on 

core contract personnel to determine the extent to which it addressed 

services that closely support inherently governmental functions and 

critical functions. We also interviewed human capital, procurement, or 

program officials at each civilian IC element to discuss ongoing efforts 

related to strategic planning and developing policies to mitigate risks from 

each IC element or their respective departments.

We conducted this performance audit from November 2012 to September 

2013 in accordance with generally accepted government auditing 

standards. We subsequently worked with ODNI from September 2013 to 

December 2013 to prepare an unclassified version of this report for public 

release. Government auditing standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

 4

OFPP Memorandum for Chief Acquisition Officers and Senior Procurement Executives, 

Service Contract Inventories (Nov. 5, 2010); and OFPP Memorandum for Chief 

Acquisition Officers and Senior Procurement Executives, Service Contract Inventories, 

(Dec. 19, 2011).
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 38 GAO-14-204 Civilian Intelligence Community

We conducted an analysis to determine whether the eight civilian 

intelligence community (IC) elements’ submissions to the fiscal years 

2007 to 2011 core contract personnel inventories were sufficiently reliable 

for the purpose of identifying the extent to which these elements have 

relied on core contract personnel, the functions performed by these 

contract personnel, and the factors that contributed to their use.1 We 

examined data fields from the submissions related to these purposes, 

including the amount of obligations (fiscal year obligations), the number of 

contractor full-time equivalents (total FTEs), the types of functions 

performed by the contract personnel (primary contractor occupation and 

competency expertise), the type of funding used for the contract (budget 

category), and the reason for using contract personnel to perform a 

service (reason code).2 In addition, we reviewed the Intelligence 

Community Chief Human Capital Officer’s (IC CHCO) guidance to the 

elements for preparing their submissions and interviewed civilian IC 

element officials on their processes for compiling and reporting the 

information. We could not determine the reliability of the information 

reported for these data fields in the elements’ submissions to the fiscal 

years 2007 to 2009 inventories. In addition, we identified several 

concerns with the reliability of the information reported for the fiscal year 

obligations, total FTEs, budget category, and reason code data fields in 

the civilian IC elements’ submissions to the fiscal years 2010 and 2011 

inventories. As a result, we determined that the data in these submissions 

were not sufficiently reliable for the purposes of our review.3

 1

The eight civilian IC elements covered by our review are the Central Intelligence Agency 

(CIA), the Department of Energy’s Office of Intelligence and Counterintelligence (DOE IN), 

Department of Homeland Security’s Office of Intelligence and Analysis (DHS I&A), 

Department of State’s Bureau of Intelligence and Research (State INR), Department of the 

Treasury’s Office of Intelligence and Analysis (Treasury OIA), Drug Enforcement 

Administration’s Office of National Security Intelligence (DEA NN), Federal Bureau of 

Investigation (FBI), and Office of the Director of National Intelligence (ODNI).

Although we 

identified some limitations, the primary contractor occupation and 

2

We identified the budget category as related to our intended purposes because IC CHCO 

uses the data field in its briefings to Congress to provide information on the functions 

performed by core contract personnel.

3

Government auditing standards require that auditors assess the sufficiency and 

appropriateness of computer-processed information. According to GAO standards for 

assessing the reliability of computer-processed data, reliability means that data are 

reasonably complete, accurate, consistent, meet the audit’s intended purposes, and are 

not subject to inappropriate alteration. For more information about GAO’s data reliability 

standards, see GAO, Applied Research and Methods: Assessing the Reliability of 

Computer-Processed Data, GAO-09-680G (Washington, D.C.: July 2009).

Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 39 GAO-14-204 Civilian Intelligence Community

competency expertise data field was sufficiently reliable for identifying the 

broad types of functions performed. However, because neither the fiscal 

year obligations nor total FTEs data fields was sufficiently reliable, we 

could not determine the extent to which the civilian IC elements use 

contract personnel to perform certain functions based on the primary 

contractor occupation and competency expertise data field.

To determine the extent to which the civilian IC elements relied on core 

contract personnel, the functions performed by these contract personnel, 

and the factors that contributed to their use, we examined data from the 

eight civilian IC elements’ submissions to the core contract personnel 

inventory: fiscal year obligations, total FTEs, budget category, reason 

code, and primary contractor occupation and competency expertise. We 

planned to examine these five data fields for the civilian IC elements’

submissions to the fiscal years 2007 to 2011 inventories. We chose to 

assess the submissions for fiscal years 2007 to 2011 because IC CHCO 

published the first inventory in fiscal year 2007, and the fiscal year 2011 

inventory was the most recent data available at the time we started our 

review.4

We planned to review the civilian IC elements’ submissions to the fiscal 

years 2007 to 2011 core contract personnel inventories. However, we 

could not determine the reliability of their submissions for the fiscal years 

2007 to 2009 inventories for various reasons. For all but one of these 

elements, we were unable to assess at least one year of data because (1) 

element officials told us they did not have records of the data they 

submitted to IC CHCO, (2) element officials told us they had specific 

concerns about the reliability of data reported in certain fiscal years that 

would make it difficult for us to verify the data, or (3) obtaining relevant 

documentation would require an unreasonable amount of time. As a 

result, we assessed the reliability of the five data fields from the elements’

submissions to the fiscal years 2010 and 2011 inventories because we 

could assess the data for at least a majority of the elements for these 

years.

In addition, we chose to analyze data for these five fields 

because they were related to our audit objectives.

 4

IC CHCO conducted a pilot for the inventory in fiscal year 2006.

Methodology
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 40 GAO-14-204 Civilian Intelligence Community

To determine whether the five data fields from the civilian IC elements’

submissions to the fiscal years 2010 and 2011 inventories would be 

reliable for the purpose of our review, we interviewed IC CHCO and 

civilian IC element officials knowledgeable about the processes for 

compiling and reporting the information. In addition, we reviewed IC 

CHCO’s guidance to elements for preparing their submissions. We also 

assessed the accuracy, consistency, and completeness of the data in the 

submissions by analyzing the five data fields from the civilian IC 

elements’ submissions. We compared the information reported to 

information in relevant documentation for a sample of 287 records—

representing 222 contracts or purchase orders.5 For elements that 

reported 30 or fewer records in either fiscal year, we reviewed data for all 

reported records for both fiscal years. For elements that reported more 

than 30 records in either fiscal year, we selected a random, 

nongeneralizable sample of records from their submissions.6

We reviewed relevant documents to determine whether they validated the 

information reported in the civilian IC elements’ submissions to the fiscal 

year 2010 and 2011 core contract personnel inventories for the five data 

fields for each record in the sample. Table 2 below summarizes our 

criteria for making these determinations for each data field.

 5

For the purposes of this report, a contract record corresponds to one row of data in an 

element’s submission to the inventory for a particular fiscal year. One contract record can 

represent a contract, a purchase order, or multiple contracts. In addition, multiple contract 

records can constitute one contract or purchase order. The number of contract records we 

reviewed was a random sample of the contracts across all eight civilian IC elements and 

therefore cannot be used to determine the number of contracts for any individual civilian 

IC element or the civilian IC elements as a whole.

6

Our sample was not generalizable because two of the civilian IC elements removed 

certain records from the universe of records available for random selection. In addition, 

after making our initial random selection, we worked with several civilian IC elements to 

remove and replace certain records from our selection if they identified sensitivity 

concerns or could not readily locate relevant documents.
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 41 GAO-14-204 Civilian Intelligence Community

Table 2: Criteria for Determining Whether Relevant Documents Validated Information Reported in Eight Civilian IC Elements’

Submissions to the Fiscal Years 2010 and 2011 Core Contract Personnel Inventories

Data field Criteria for determining whether documents validated information reported

Fiscal year obligations We reviewed documents, such as the contract award or modifications signed in a given fiscal 

year, to determine the amount of funds obligated within a given fiscal year. If the total 

obligations identified were within 10 percent of the amount of obligations reported for the 

respective record in the submission, we considered the amount reported to be validated by 

available documents.

Total FTEs We reviewed documents, such as contractor invoices or contract award documents, to 

determine the number of FTEs for each record. For those records with at least 10 FTEs, if the 

number of FTEs we calculated was within 10 percent of the number of FTEs reported, then 

we considered the number reported to be supported by available documents. For those 

records with fewer than 10 FTEs, if the number of FTEs we calculated was within 1 FTE, then 

we considered the number reported to be validated.

Budget category Only CIA and ODNI provided documents that would allow us to validate this data field.a We 

reviewed the budget line item to determine whether the budget category reported for each 

record was accurate. 

Reason code We reviewed documents, such as the statement of work or justification for other than full and 

open competition, to determine whether the selected reason code category for each record 

was validated.

Primary contractor occupation and 

competency expertise

We reviewed documents such as the statement of work to identify the types of functions 

performed by the contract personnel and determined whether the selected category reflected 

the information in the documents.

Source: GAO.

a

The other civilian IC elements did not provide sufficient documentation for us to validate the 

information reported for the records we reviewed.

After our initial review of the documents, we provided the civilian IC 

elements with an overview of our determinations that indicated whether 

the documentation validated the information reported. In addition, we 

offered these elements an opportunity to provide additional 

documentation for records in which we identified discrepancies with the 

documents or lacked sufficient information to validate the reported data. 

In the instances in which elements provided additional documentation, we 

reviewed the documents and made adjustments to our determinations, as 

appropriate.

We made the following determinations of whether the information 

reported for the five data fields was sufficiently reliable for our intended 

purposes.

We determined that the information reported for the fiscal year obligations 

data field was not sufficiently reliable for our intended purpose of 

identifying the eight civilian IC elements’ extent of reliance on core 

Results of Analysis

Fiscal Year Obligations
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 42 GAO-14-204 Civilian Intelligence Community

contract personnel for several reasons. First, we could only validate the 

amount of obligations reported for approximately 62 percent of the 

records we reviewed. For an additional 21 percent of the records we 

reviewed, the civilian IC elements either under- or over-reported the 

amount of obligations by more than 10 percent.

Second, we identified inconsistencies between civilian IC elements’

methodologies for reporting the amount of obligations. Officials from six of 

the civilian IC elements stated that they reported the amount of 

obligations on core contracts that are active at any point within a given 

fiscal year while officials from two of the civilian IC elements told us they 

do not report the amount of obligations on certain contracts if they are not 

active on the date of reporting. As a result, the information reported 

cannot be compared across the eight civilian IC elements.

Lastly, the amount of obligations reported for two of the civilian IC 

elements does not reflect all of the obligations in a given fiscal year. First, 

these elements’ methodology would exclude certain obligations on core 

contracts that are active at some point during a fiscal year but not on the 

date of reporting. We were unable to determine the magnitude of 

obligations not included in the inventory because we did not have a way 

to identify contracts not reported by the civilian IC elements. Further, 

officials from these two elements stated that they also do not report 

obligations on contract option periods that are no longer active on the 

date of reporting even if the contract is active at that time.

We determined that the information reported for the total FTEs data field 

was not sufficiently reliable for our intended purpose of identifying the 

eight civilian IC elements’ extent of reliance on core contract personnel. 

First, the elements could not provide complete or readily available 

documentation to validate the information reported for approximately 37 

percent of the records.7

 7

While we initially identified records in which the information in relevant documents 

appeared to contradict the information reported, we did not break out this group for the 

purposes of this analysis for two key reasons. First, an element may calculate the number 

of FTEs using methods that cannot be verified through documents, such as counting the 

number of contract personnel working on a particular date or including the number of 

contractor vacancies in the number reported. In addition, elements may not have provided 

all relevant documents that would allow us to validate the information reported.

Total FTEs
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 43 GAO-14-204 Civilian Intelligence Community

Second, we identified inconsistencies in civilian IC elements’

methodologies for calculating the number of FTEs in their submissions to 

the fiscal years 2010 and 2011 inventories, thus limiting our ability to 

compare the number of FTEs reported across the elements. The civilian 

IC elements reported the number of FTEs by: (1) calculating estimates 

based on target labor hours, (2) calculating the number of labor hours 

invoiced by the contractor, (3) counting the number of contract personnel 

on board on a selected date and the number of approved contractor 

vacancies, or (4) using the amount of obligations and average labor hour 

rates.

Lastly, as noted above, officials from two of the civilian IC elements stated 

that they do not report certain contracts in their submissions if they are 

not active on the date of reporting. As a result, the number of FTEs on 

core contracts that are active at some point during a fiscal year but not on 

the date of reporting would not be reflected in these two elements’

submissions. We were unable to determine the magnitude of the number 

of FTEs not included in the inventory because we did not have a way to 

identify contracts not reported by these two elements.

We determined that the information reported for the budget category data 

field in the eight civilian IC elements’ submissions was not sufficiently 

reliable for our intended purpose of identifying the types of functions 

performed by core contract personnel. We intended to use this data field 

to describe the types of functions performed by core contract personnel 

because IC CHCO uses the budget category in its briefings to Congress 

to provide information on the functions performed by core contract 

personnel. The IC CHCO core contract personnel inventory guidance 

instructs the elements to complete the budget category data field by 

reporting where the funding for the contract is assigned according to the 

Congressional Budget Justification Books. Civilian IC element officials 

acknowledged that the budget category is not the best representation of 

the functions being performed by contractors. Based on our review of 

documents, we found that contracted functions are not necessarily 

reflected by the budget category designation. Further, we identified 

discrepancies between the budget category information reported and the 

information contained in relevant documents for approximately one-third 

of the records we reviewed for two of the civilian IC elements. Based on 

our review of the documents provided, the reported budget category 

information for one of these elements improved from fiscal year 2010 to 

2011. However, we still identified discrepancies between the information 

reported and relevant documents for 23 percent of the records we 

reviewed.

Budget Category
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 44 GAO-14-204 Civilian Intelligence Community

We determined that the information reported for the reason code data 

field in the eight civilian IC elements’ submissions was not sufficiently 

reliable for our intended purpose of identifying the factors for using core 

contract personnel because we could not determine the reliability of the 

information reported for a significant number of the records we reviewed. 

We could not validate the reported reason code based on the information 

in the documents provided for approximately 40 percent of the records we 

reviewed. Further, this percentage is even more pronounced for those 

records coded as a category other than specified service, which is a 

broad category defined as when the service being provided is of indefinite 

quantity. The civilian IC elements selected specified service for 

approximately 45 percent of the records we reviewed. For the 156 

remaining records coded as a category other than specified service, we 

could not validate the information reported for approximately 73 percent 

of the records.

In addition, we identified instances when multiple selection options could 

apply to a record. IC CHCO guidance requires elements to select one 

category per record. However, civilian IC element officials acknowledged 

that more than one response option can apply to a record and that 

officials at the time of reporting make a subjective determination of which 

option best applies. As a result, the subjective nature of the determination 

and that more than one record could apply to a record raises concerns 

about the consistency of the information reported.

Lastly, because we determined that the fiscal year obligations and total 

FTEs data fields were not sufficiently reliable for determining the extent of 

reliance on core contract personnel, we would not be able to use the 

information reported for these data fields to describe the extent to which 

the civilian IC elements used these personnel for particular reasons 

based on the reason code data field.

Although we identified some limitations, the information reported for the 

primary contractor occupation and competency expertise data field is 

sufficiently reliable for our intended purpose of identifying the types of 

functions performed by core contract personnel. Based on our review of 

relevant documents, we were able to find support for the selected 

response option for almost all of the records we reviewed.

However, we identified some limitations that would limit insight into the 

functions performed by the contract personnel. First, we identified 

instances when multiple selection options could apply to a record. The 

core contract personnel inventory guidance instructs the elements to 

Reason Code

Primary Contractor Occupation 

and Competency Expertise
Appendix II: Observations on Reliability of 

Eight Civilian Intelligence Community 

Elements’ Inventory Data Submissions

Page 45 GAO-14-204 Civilian Intelligence Community

select only one response option for each record. Based on the documents 

provided, we identified at least 128 instances in the 287 records we 

reviewed in which the primary contractor occupation and competency 

expertise data field did not reflect the full range of services listed in the 

documents. Civilian IC element officials acknowledged that the primary 

contractor occupation and competency expertise coding are not fully 

reflective of the services the contractors are performing. As a result, the 

information may not be consistently reported given the subjective nature 

of this data field.

Further, we identified a limited number of instances when the information 

may not be consistently reported as a function performed by the contract 

personnel. For example, an element may make a selection based on the 

mission the contractor supported or the contractor’s general area of 

expertise rather than the type of function performed.

Lastly, because we determined that the fiscal year obligations and total 

FTEs data fields were not sufficiently reliable for determining the extent of 

reliance on core contract personnel, we would not be able to use the 

information reported for these data fields to describe the extent to which 

the contract personnel performed certain types of functions based on the 

primary contractor occupation and competency expertise data field.
Appendix III: Overview of the Eight Civilian 

Intelligence Community Elements and Their 

Respective Missions

Page 46 GAO-14-204 Civilian Intelligence Community

Civilian intelligence community (IC) 

element Mission

Central Intelligence Agency (CIA) Collects, analyzes, evaluates, and disseminates foreign intelligence to assist the President 

and senior U.S. government policymakers in making decisions relating to national 

security.

Department of Energy Office of 

Intelligence and Counterintelligence (DOE 

IN)

Provides expert scientific, technical, analytic, and research capabilities to other agencies 

in the IC and participates in formulating intelligence collection, analysis, and information 

relative to foreign energy matters.

Department of Homeland Security Office 

of Intelligence and Analysis (DHS I&A) 

Equips DHS, other IC elements, departments, state, local, tribal, territorial, and private 

sector partners with the intelligence and information needed to keep the homeland safe, 

secure, and resilient.

Department of Justice (DOJ), Drug 

Enforcement Administration Office of 

National Security Intelligence (DEA NN)

Facilitates intelligence coordination and information sharing with other members of the IC 

and leverages its global law enforcement drug intelligence assets to enhance efforts to 

protect national security, combat global terrorism, and facilitate IC support to DEA’s law 

enforcement mission.

Department of State Bureau of 

Intelligence and Research (State INR)

Ensures that well-informed and independent analysis informs foreign policy decisions and 

that intelligence and counterintelligence activities support America’s foreign policy.

Department of the Treasury Office of 

Intelligence and Analysis (Treasury OIA)

Receives, analyzes, collates, and disseminates intelligence and counterintelligence 

information related to the operations and responsibilities of the entire Treasury 

Department. Publishes analytic products and intelligence information reports for senior 

leaders at Treasury and other policymakers and intelligence consumers throughout the 

government.

DOJ Federal Bureau of Investigation (FBI) Protects and defends against terrorist and foreign intelligence threats, upholds and 

enforces the criminal laws of the United States, and provides leadership and criminal 

justice services to federal, state, municipal, and international agencies and partners.

Office of the Director of National 

Intelligence (ODNI)

Serves as head of the IC; acts as the principal adviser to the President, National Security 

Council, and the Homeland Security Council for intelligence matters related to national 

security; and develops and ensures the execution of an annual budget for the National 

Intelligence Program based on budget proposals provided by the IC elements.

Source: GAO analysis of civilian IC elements’ information.

Appendix III: Overview of the Eight Civilian 

Intelligence Community Elements and Their 

Respective Missions
Appendix IV: Selected Office of Management 

and Budget Guidance Related to Considering 

and Mitigating Risks

Page 47 GAO-14-204 Civilian Intelligence Community

Office of Management and 

Budget (OMB) guidance

Selected requirements related to closely 

supporting inherently governmental 

functions

Selected requirements related to critical 

functions

Office of Federal Procurement 

Policy (OFPP), Management 

Oversight of Service Contracting, 

OFPP Policy Letter No. 93-1 

(Reissued) (May 18, 1994)

Agency officials must provide an enhanced 

degree of management controls and oversight 

when contracting for functions that closely 

support the performance of inherently 

governmental functions.

Not applicable

OMB Memorandum, Managing the 

Multisector Workforce, M-09-26 

(July 29, 2009)

Not applicable As part of determining whether it is appropriate 

to use contractors, fill critical functions only with 

government personnel to the extent required by 

the agency to maintain control of its mission 

and operations and by either government or 

contract personnel once the agency has 

sufficient internal capability to control its mission 

and operations.

OFPP Memorandum, Service 

Contract Inventories (November 5, 

2010); OFPP Memorandum, 

Service Contract Inventories 

(December 19, 2011)

Beginning with the fiscal year 2012 service 

contract inventory submissions, identify which 

contracts include services that are 

predominantly for functions closely associated 

to inherently governmental work.

Analyze the inventory to ensure the agency is 

giving special management attention to 

functions that are closely associated with 

inherently governmental functions.

Beginning with the fiscal year 2012 service 

contract inventory submissions, identify which 

contracts include services that are 

predominantly for functions that are critical.

Analyze the inventory to ensure that the agency 

is not using contractor employees to perform 

critical functions in such a way that could affect 

the ability of the agency to maintain control of 

its mission and operations.

OFPP Policy Letter 11-01: 

Performance of Inherently 

Governmental and Critical 

Functions (76 Fed. Reg. 56227, 

September 12, 2011)

Limit or guide a contractor’s exercise of 

discretion and retain control of government 

operations.

Assign a sufficient number of qualified 

government employees, with expertise to 

administer or perform the work, to give special 

management attention to the contractor’s 

activities.

Identify agency’s critical functions.

Ensure that government personnel perform 

and/or manage critical functions to the extent 

necessary for the agency to operate effectively 

and maintain control of its mission and 

operations.

Source: GAO analysis of OMB guidance.

Appendix IV: Selected Office of Management 

and Budget Guidance Related to 

Considering and Mitigating Risks
Appendix V: Intelligence Community Core 

Contract Personnel Definitions and Associated 

Major Changes by Fiscal Year

Page 48 GAO-14-204 Civilian Intelligence Community

Fiscal year Core contract personnel definition Summary of major changes from prior fiscal year

2007 Contracts that provide direct support to core intelligence 

community (IC) mission areas such as collection activities 

and operations; intelligence analysis and production; basic 

and applied technology research and development; 

acquisition and program management; and/or 

management and administrative support to these 

functions.

Also, these employees are functionally indistinguishable 

from U.S. government personnel whose mission they 

support. Consulting contractors are to be included when 

they provide primarily intellectual products or services. 

N/A

2008 Individuals employed by a private or independent 

contractor to provide analytical, technical, managerial, 

and/or administrative support to: (1) intelligence collection 

activities and operations; (2) intelligence analysis and 

production; (3) basic and applied technology research and 

development; (4) acquisition and program management; 

(5) enterprise information technology; and (6) ongoing 

operations and maintenance in support of a particular 

product; and/or support the general management and 

administration of an IC agency or element. 

From contracts that provide “direct support” to individuals 

that “support.”

Removes “such as” for mission areas and names six core 

IC mission areas.

Adds “enterprise information technology” and “operations 

and maintenance” as mission areas not previously listed.

From “management and administrative support to these 

functions” to “support the general management and 

administration of an IC agency or element.”

Removes that the “employees are functionally 

indistinguishable from U.S. government personnel whose 

mission they support.”

2009 Personnel that provide only direct support to core IC 

mission areas that include: (1) collection activities and 

operations (technical and human intelligence); 

(2) intelligence analysis and production; (3) basic and 

applied technology research and development; (4) 

acquisition and program management; (5) enterprise 

information technology; and (6) management or 

administrative support to these functions.

Also, these employees are functionally indistinguishable 

from U.S. government personnel whose mission they 

support.

From individuals that “support” to personnel that provide 

“only direct support.”

Specifies technical and human intelligence for collection 

activities and operations.

Reverts from “support the general management and 

administration of an IC agency or element” to “management 

or administrative support of these functions.”

Adds back in that the “employees are functionally 

indistinguishable from U.S. government personnel whose 

mission they support” but does not mention consulting 

contractors.

2010 Personnel that provide only direct support to core IC 

mission areas that include: (1) collection activities and 

operations (technical and human intelligence), 

(2) intelligence analysis and production, (3) basic and 

applied technology research and development, 

(4) acquisition and program management, (5) enterprise 

information technology, and (6) management or 

administrative support to these functions.

Also, these employees are functionally indistinguishable

from U.S. government personnel whose mission they 

support. 

No definitional change.

Guidance includes that personnel performing certain 

administrative support, training support, information 

technology services, and operations and maintenance will 

either be included or excluded depending on the types of 

services they provide.

Appendix V: Intelligence Community Core 

Contract Personnel Definitions and 

Associated Major Changes by Fiscal Year
Appendix V: Intelligence Community Core 

Contract Personnel Definitions and Associated 

Major Changes by Fiscal Year

Page 49 GAO-14-204 Civilian Intelligence Community

Fiscal year Core contract personnel definition Summary of major changes from prior fiscal year

2011 Personnel that provide only direct support to core IC 

mission areas that include: (1) collection activities and 

operations (technical and human intelligence), 

(2) intelligence analysis and production, (3) basic and 

applied technology research and development, (4) 

acquisition and program management, (5) enterprise 

information technology, and (6) management or 

administrative support to these functions.

Revision to “substantive work products may be 

incorporated in and/or indistinguishable from those of U.S. 

government personnel.”

Guidance further refines the inclusion or exclusion of 

personnel performing certain administrative support, 

information technology services, and operations and 

maintenance.

Source: GAO analysis of IC Chief Human Capital Officer information.
Appendix VI: Comments from the Office of the 

Director of National Intelligence

Page 50 GAO-14-204 Civilian Intelligence Community

Appendix VI: Comments from the Office of 

the Director of National Intelligence

See comment 1.

Note: GAO comments 

supplementing those in 

the report's text appear at 

the end of this appendix.
Appendix VI: Comments from the Office of the 

Director of National Intelligence

Page 51 GAO-14-204 Civilian Intelligence Community

See comment 2.
Appendix VI: Comments from the Office of the 

Director of National Intelligence

Page 52 GAO-14-204 Civilian Intelligence Community
Appendix VI: Comments from the Office of the 

Director of National Intelligence

Page 53 GAO-14-204 Civilian Intelligence Community

The following are GAO’s comments on the Office of the Director of 

National Intelligence (ODNI) letter, dated August 23, 2013.

1. ODNI’s observation that the number of core contract personnel 

reported during initial data collection efforts may not have fully or 

accurately reflected all core contract personnel due to the potential 

exclusion of some functions underscores our finding that the core 

contract personnel inventory data cannot be used reliably to make 

year-to-year comparisons or establish trends.

2. Our recommendation did not specify that the assessments of the 

appropriate workforce mix be addressed as part of the core contract 

personnel inventory. However, as discussed in our report, OFPP has 

indicated that a service contract inventory can assist an agency in 

conducting strategic workforce planning by providing insight into the 

extent to which contracted resources are distributed by function 

across an agency.

GAO Comments
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 54 GAO-14-204 Civilian Intelligence Community

Timothy J. DiNapoli, (202) 512-4841 or dinapolit@gao.gov

In addition to the contact above, John P. Hutton, Director (ret.); Johana R. 

Ayers, Acting Director; Molly W. Traci, Assistant Director; Laura Greifner; 

Julia M. Kennon; John A. Krump; Claire Li; Stephen V. Marchesani; Anne 

McDonough-Hughes; Kenneth E. Patton; Jared A. Sippel; and Roxanna 

T. Sun made key contributions to this report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(121180)
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