DEFENSE 

MANAGEMENT

Actions Needed to 

Ensure National 

Guard and Reserve 

Headquarters Are 

Sized to be Efficient

Report to Congressional Requesters

November 2013

GAO-14-71

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-71, a report to 

congressional requesters

November 2013

DEFENSE MANAGEMENT

Actions Needed to Ensure National Guard and 

Reserve Headquarters Are Sized to Be Efficient

Why GAO Did This Study

DOD has sought to reduce costs by 

assessing headquarters and overhead

functions. Both the Army and Air Force 

have two reserve components—a 

National Guard and Reserve—that 

have at least 75 headquarters located 

throughout the United States, its 

territories, and overseas that manage 

subordinate units or perform overhead 

functions. These headquarters have a 

mix of full-time and part-time 

personnel. GAO was asked to review 

issues related to reserve-component 

headquarters. This report (1) discusses 

trends in funded positions at reservecomponent headquarters and (2) 

evaluates the extent to which DOD has 

established and implemented 

processes to efficiently size its reservecomponent headquarters. To do so, 

GAO reviewed statutes and DOD 

guidance, analyzed personnel data 

and headquarters assessments, and 

interviewed DOD and state officials.

What GAO Recommends

GAO recommends that DOD externally 

validate the National Guard Bureau’s 

personnel requirements and include 

the bureau in its annual report to 

Congress; reassess requirements for 

the 54 state Joint Force headquarters; 

and develop schedules for reassessing 

headquarters overseen by the Army 

and Air Force. DOD concurred with 

recommendations to report data to 

Congress and establish schedules for 

reassessing headquarters and partially 

concurred with recommendations to 

externally validate the bureau’s 

personnel requirements and assess 

requirements for the state Joint Force 

headquarters. GAO continues to 

believe these recommendations are 

valid as discussed in the report. 

What GAO Found

Between fiscal years 2009 and 2013, the total number of funded positions—both

full-time support and part-time—at the Department of Defense’s (DOD) 75 Army 

Reserve and Air Force Reserve (Reserves) component headquarters grew from 

about 30,200 to 31,900 positions (about 6 percent overall). Some organizations 

grew more markedly, among them the National Guard Bureau (17 percent); Army 

National Guard Directorate (44 percent); Air National Guard Readiness Center 

(21 percent); and the Office of the Chief of the Army Reserve (45 percent). DOD 

officials attribute growth to the conversion of contractor workload into civilian 

positions and increased missions assigned at certain headquarters. Over the 

same period, staff levels at the National Guard’s 54 state Joint Force 

headquarters remained flat and the Air Force Reserve shrank by 4 percent.

DOD has processes in place that are intended to ensure that the number of 

funded positions at its reserve-component headquarters are set at the minimum 

level needed to accomplish their mission, but it has not consistently followed 

those processes at 68 of the 75 headquarters that GAO reviewed. As a result, 

DOD is unable to determine whether National Guard and Reserve headquarters 

are sized to be efficient. The National Guard has begun evaluating some 

personnel requirements, but its efforts do not fully address the management 

issues GAO identified:

• The National Guard Bureau, which may continue to grow to accommodate its 

Chief’s placement on the Joint Chiefs of Staff, is determining its own 

requirements without external validation. This is inconsistent with Joint Staff, 

Army, and Air Force processes, which generally involve an external review. 

In addition, Congress’s ability to oversee the bureau’s size is limited because 

DOD’s annual report on its Major DOD Headquarters Activities does not 

include data on the bureau and its more than 600 staff. 

• The National Guard has not fully assessed its 54 state headquarters—which 

contain nearly 21,900 funded positions—since the 1980s. GAO’s prior work 

shows that agencies can reduce costs by consolidating and centralizing 

functions and eliminating unneeded duplication. The National Guard Bureau, 

Army National Guard Directorate, and Air National Guard Readiness Center 

each assess a portion of the state headquarters, but there is no process to 

assess the headquarters’ personnel requirements in their entirety and 

ongoing efforts do not provide a holistic review. 

• The Army and Air Force have not fully reassessed 13 of the 20 reserve 

component headquarters for which they are responsible. The Army has a 

reassessment backlog, and the Air Force does not require periodic 

reassessments and reassesses its headquarters on an ad hoc basis. Some 

headquarters with significant growth are among those that have not been 

reassessed, including the Office of the Chief of the Army Reserve and the Air 

National Guard Readiness Center. In contrast, 5 of the 7 reassessed 

organizations subsequently reduced their staff levels such as the Air Force 

Reserve’s three numbered air forces, which have shrunk by more than a third 

since 2009. The Army and Air Force agree their headquarters should be 

reassessed, but they have not scheduled reassessments across their 

reserve components.

View GAO-14-71. For more information, 

contact John H. Pendleton at (202) 512-3489 

or pendletonj@gao.gov.
Page i GAO-14-71 Defense Management

Letter 1 

Background 4

The Number of Military and Civilian Personnel Positions at 

Reserve-Component Headquarters Has Increased 13

Processes Intended to Efficiently Size and Oversee ReserveComponent Headquarters Have Not Been Consistently Applied 18

Conclusions 32

Recommendations for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I Scope and Methodology 38

Appendix II Summary of Efforts to Study Merger of the Army’s and Air 

Force’s Reserve Components 45

Appendix III Profile for the National Guard Bureau, Army National Guard 

Directorate, and Air National Guard Readiness Center 51

Appendix IV Profile for the National Guard State Joint Force Headquarters 53

Appendix V Profile for the Office of the Chief of the Army Reserve and U.S. 

Army Reserve Command 55

Appendix VI Profile for the Army Reserve Regional Support Commands 57

Appendix VII Profile for the U.S. Army Reserve Functional Commands 59

Contents 
Page ii GAO-14-71 Defense Management

Appendix VIII Profile for Air Force Reserve Command and Headquarters, Air 

Force Reserve 62

Appendix IX Profile for the Air Force Reserve Numbered Air Forces 64

Appendix X Content for Interactive Figures in Background Section 66

Appendix XI Comments from the Department of Defense 69

Appendix XII GAO Contact and Staff Acknowledgments 74

Tables

Table 1: Fiscal Year 2013 Authorized Military End Strength and 

Estimated Presequestration Base Budget by Component 5

Table 2: Processes for Determining Reserve-Component 

Headquarters Personnel Requirements 20

Table 3: Federal Organizations Responsible for Determining and 

Validating Personnel Requirements at State Joint Force 

Headquarters and a Description of Requirements 26

Table 4: Status of Army and Air Force Manpower Assessment 

Processes for Reserve-Component Headquarters 30

Table 5: Nongeneralizable Sample of Reserve-Component 

Headquarters Visited during the Audit 41

Table 6: Organizations Interviewed over the Course of the Audit 43

Figures

Figure 1: Federal and State Organizational Structure of the 

National Guard (See Appendix X for table summarizing 

text in the interactive figure) 7

Figure 2: Organization of Army Reserve Headquarters (See 

Appendix X for table summarizing text in the interactive 

figure) 10
Page iii GAO-14-71 Defense Management

Figure 3: Organization of Air Force Reserve Headquarters (See 

Appendix X for table summarizing text in the interactive 

figure) 12

Figure 4: Trends in Funded Reserve-Component Headquarters’ 

Positions by Component from Fiscal Year 2009 through 

Fiscal year 2013 15

Abbreviations

DOD Department of Defense

Reserves Army Reserve and Air Force Reserve

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Page 1 GAO-14-71 Defense Management

441 G St. N.W.

Washington, DC 20548

November 12, 2013

The Honorable Mike Coffman

House of Representatives 

The Honorable Jim Cooper 

House of Representatives 

In anticipation of constrained resources, the Department of Defense 

(DOD) has undertaken a series of efficiency initiatives since 2010 that are 

intended, among other things, to reduce excess overhead costs, eliminate 

unneeded headquarters, and reduce headquarters staff size. In early 

2013, the Secretary of Defense announced the Strategic Choices and 

Management Review, which builds on prior efforts and is intended to 

assess the potential effect of further reductions, shape the budget, and 

provide the foundation for the 2014 Quadrennial Defense Review.1

In July 

2013, the Secretary of Defense announced plans to reduce the budgets 

and personnel of some major headquarters by 20 percent over a 5-year 

period. However, the DOD-led efforts to date have not focused on 

reserve-component organizations. The Army and Air Force each have 

two reserve components2

—a National Guard and Reserve—and each has 

numerous headquarters organizations that manage and oversee 

subordinate units, or perform administrative or overhead functions. 

We have issued several reports recently on defense headquarters and on 

the department’s ability to determine the right size and mix of personnel it 

needs to perform various functions. For example, in May 2013 we found 

that authorized military and civilian positions at the geographic combatant 

commands—excluding U.S. Central Command—increased by about 50 

percent from fiscal year 2001 through fiscal year 2012. We also 

determined that DOD’s process for sizing its geographic combatant 

 

1

The Quadrennial Defense Review is a legislatively mandated review of DOD strategy and 

priorities. The Quadrennial Defense Review will set a long-term course for DOD as it 

assesses the threats and challenges that the nation faces and rebalances DOD’s 

strategies, capabilities, and forces to address current conflicts and future threats.

2

The reserve components of the Armed Forces include the Army National Guard of the 

United States, the Army Reserve, the Navy Reserve, the Marine Corps Reserve, the Air 

National Guard of the United States, the Air Force Reserve, and the Coast Guard 

Reserve. Our review is focused on the Army and Air Force organizations.

 
 

Page 2 GAO-14-71 Defense Management

commands exhibits several weaknesses, including the absence of a 

comprehensive, periodic review of the size and structure of these 

commands and inconsistent use of personnel-management systems to 

identify and track assigned personnel. DOD concurred with our 

recommendation that it improve its visibility over its headquarters 

personnel, but did not concur with our recommendation that it conduct 

comprehensive and periodic reviews of the geographic combatant 

commands’ size.3

In another May 2013 report, to improve DOD’s 

understanding and management of its total workforce,4 we recommended 

that the Secretary of Defense direct the Under Secretary of Defense for 

Personnel and Readiness to revise DOD’s policies and procedures for 

determining the appropriate workforce mix and the identification of critical 

functions. DOD partially concurred with our recommendation stating that it 

justifies its workforce size on the basis of workload, rather than 

competency or skill gaps.5

In 2012, we found that DOD’s reporting to 

support congressional oversight of its Major DOD Headquarters Activities

did not include all major headquarters.6

In 2010 and 2011, we reported 

that DOD had experienced challenges in determining the number of 

funded positions for certain Army and Air Force headquarters due to flaws 

with developing, maintaining, and implementing their manpower 

processes. 7 DOD generally concurred with the findings and 

recommendations in these reports. 

In response to your request, we examined whether opportunities exist to 

improve the efficiency of DOD’s reserve-component headquarters while 

 

3

GAO, Defense Headquarters: DOD Needs to Periodically Review and Improve Visibility 

Of Combatant Commands’ Resources, GAO-13-293 (Washington, D.C.: May 15, 2013).

4

DOD’s total workforce consists of three main components: military personnel (including 

the active military and the reserve and guard forces), civilians, and contractors providing 

support to the department.

5

GAO, 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).

6

GAO, Defense Headquarters: Further Efforts to Examine Resource Needs and Improve 

Data Could Provide Additional Opportunities for Cost Savings, GAO-12-345 (Washington, 

D.C.: Mar. 21, 2012).

7

GAO, Military Personnel: Enhanced Collaboration and Process Improvements Needed 

for Determining Military Treatment Facility Medical Personnel Requirements, GAO-10-696

(Washington, D.C.: July 29, 2010); and Military Training: Actions Needed to Assess 

Workforce Requirements and Appropriate Mix of Army Training Personnel, GAO-11-845

(Washington, D.C.: Sept. 20, 2011).
 

Page 3 GAO-14-71 Defense Management

meeting defense strategy needs.8Specifically, this report (1) discusses 

trends in funded positions at reserve-component headquarters and (2) 

evaluates the extent to which DOD has established and implemented 

processes to size its reserve-component headquarters and provide 

information for congressional oversight. Also at your request, appendix II 

provides information on DOD’s efforts to study the potential merger of 

reserve-component headquarters.

To address our objectives, we reviewed data on funded positions for 

military and civilian personnel at the Army’s and Air Force’s reservecomponent headquarters for fiscal year 2009 through fiscal year 2013. 

We selected these years because Army officials stated that the Army 

Reserve component headquarters structure has remained relatively 

constant since 2009. We did not review contractor positions as part of this 

review because officials from three of the four components told us that 

they were unable to determine the number of contractor positions at the 

reserve-component headquarters we identified. To identify component 

headquarters, we reviewed DOD and military-service guidance; 

organization charts; and interviewed Office of the Secretary of Defense, 

National Guard, Army Reserve, and Air Force Reserve officials. We 

focused our review on Army or Air Force reserve-component 

headquarters that are (1) nondeployable and (2) perform many of the 

management headquarters functions identified by DOD in its major 

headquarters instruction.9 We then provided DOD, Joint Staff, National 

Guard, and Reserve officials with an opportunity to comment on our final 

list of 75 headquarters and these officials agreed the headquarters we 

identified met these criteria, while noting that they were not all designated 

as Major DOD Headquarters Activities. To identify trends in funded 

positions for the Army, we analyzed funded positions as documented on 

the Army’s personnel requirements documents referred to as tables of 

distribution and allowance.

10 For the Air Force, we analyzed funded 

 

8 This review was conducted in response to a 2012 request from Representative Mike 

Coffman and Representative Jim Cooper—then Ranking Member, House Armed Services 

Subcommittee on Oversight and Investigations. 

9

Department of Defense Instruction 5100.73, Major DOD Headquarters Activities (Dec. 1, 

2007, incorporating changes June 12, 2012).

10The Army uses two types of personnel requirements documents for the headquarters we 

identified: tables of distribution and allowance and full-time support tables of distribution 

and allowance. 
 

Page 4 GAO-14-71 Defense Management

positions documented on its headquarters’ unit manpower documents. To 

evaluate DOD’s processes for determining headquarters personnel 

requirements11 and provide information to Congress, we reviewed DOD 

and military-service guidance, DOD reports, and manpower assessments 

for reserve-component headquarters between fiscal year 2009 and fiscal 

year 2013. We also interviewed knowledgeable officials. For more 

information on the scope and methodology for this review, see appendix I.

We conducted this performance audit from July 2012 to November 2013, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The National Guard has two elements—the Army National Guard and the 

Air National Guard—that mostly consist of part-time forces responsible for 

both federal and state missions. The Army Reserve and Air Force 

Reserve (Reserves) also largely consist of part-time forces and are 

responsible for only federal missions. In addition to these part-time forces, 

both the National Guard and the Reserves use full-time personnel for 

duties that can include pay processing, personnel actions, preparing and 

monitoring training schedules, and other tasks that cannot be effectively 

executed through the use of part-time personnel. These full-time 

positions—which DOD calls full-time support12—in general are more 

expensive than part-time personnel because they are paid as full-time 

employees and receive greater compensation and benefits such as 

retirement, health-care, and education.

As table 1 shows, the Army National Guard is authorized approximately 

358,000 soldiers, and the Army Reserve approximately 205,000 soldiers, 

 

11For the purposes of this report, personnel requirements are positions that the Army and 

Air Force have approved for funding on a manpower document for the headquarters we 

identified. 

12Full-time support personnel consist of five categories of personnel including: full-time 

reservists (active Guard/Reserve), military technicians, active-component personnel, nondual-status technicians, and federal civilian employees. Full-time support personnel 

provide services and administrative support to the part-time drilling reservists.

Background 
 

Page 5 GAO-14-71 Defense Management

which collectively constitute about 50 percent of the Army’s total 

authorized end strength.13 Likewise, the Air National Guard has 

approximately 105,000 military personnel, and the Air Force Reserve has 

approximately 71,000 military personnel, which collectively are about 35 

percent of the Air Force’s authorized end strength. 

Table 1: Fiscal Year 2013 Authorized Military End Strength and Estimated 

Presequestration Base Budget by Component

Military 

service Component

Authorized end 

strength

Estimated budget (dollars in 

billions) a

Army

b

Active Army 552,100 $105.85

Army National 

Guard 358,200 17.45 

Army Reserve 205,000 8.60 

Total Army 1,115,300 $131.90

Air Force Active Air Force 329,460 124.38

Air National Guard 105,700 10.00 

Air Force Reserve 70,880 5.32

Total Air Force 506,040 $139.70

Source: GAO analysis of DOD data.

Notes: Budget data are from DOD budget-justification materials.

a

Numbers for each component come from the National Defense Authorization Act, Fiscal Year 2013, 

Pub. L. No. 112-239 (2013). Authorized end strength is the number of personnel that each 

component of a military service is authorized by Congress to have at the end of a given fiscal year.

b

Estimated budget for the active components includes presequestration amounts of funds 

appropriated for fiscal year 2013 for Base Budget Military Personnel; Operation and Maintenance; 

Research, Development, Test, and Evaluation; Military Construction; Procurement; and certain other 

accounts as identified in DOD’s budget-justification materials. Estimated budget for the reserve 

components includes presequestration amounts appropriated for fiscal year 2013 for Base Budget 

Military Personnel, Operation and Maintenance, Military Construction, and estimated Procurement 

funding based on DOD’s budget-justification materials.

Each state’s National Guard forces have a dual role as both a state and 

federal force, while the Reserves are strictly a federal force. Although the 

National Guard has a dual role, the federal government provides funding 

for National Guard personnel when they are conducting training and other 

 

13Authorized end strength is the number of personnel that each component of a military 

service is authorized by Congress to have at the end of a given fiscal year. 
 

Page 6 GAO-14-71 Defense Management

federal missions.14 In fiscal year 2013, federal funding for National Guard 

personnel totaled about $11.1 billion. In addition, the federal government 

provides about 90 percent of the funding for National Guard installation 

base-operation and maintenance costs. The National Guard’s dual state 

and federal role means that state Governors have command and control 

over National Guard units when they are not performing federal missions 

or other federal service. 

The National Guard and Reserves maintain a number of nondeployable 

headquarters that are responsible for managing and overseeing 

subordinate units. Of the 75 headquarters we identified, 57 reside within 

the National Guard. The National Guard’s headquarters include the 

National Guard Bureau, Army National Guard Directorate, Air National 

Guard Readiness Center, and the National Guard’s 54 Joint Force 

headquarters—which DOD refers to as Joint Force Headquarters-State—

located in each state, the District of Columbia, Puerto Rico, the Virgin 

Islands, and Guam.15 In addition, appendixes III and IV provide detailed 

information on the locations, missions and responsibilities of these 

headquarters. Figure 1 shows the organizational structure of the National 

Guard.

 

14National Guard members train for their federal missions under state control with federal 

funding. Federal funding is also provided for some other state-controlled missions, such 

as the National Guard’s counterdrug support operations and weapons of mass destruction 

civil support teams and when authorized by the President for other domestic operations, 

such as the response to Hurricane Katrina. 

15For the purposes of this report, we refer to the 54 Joint Headquarters-State as “state 

Joint Force headquarters.” 

National Guard 

Headquarters
Page 7 GAO-14-71 Defense Management

Source: GAO analysis of DOD guidance and data. 

National

Guard Bureau

54 Joint Force 

Headquarters

Army National

Guard Directorate

Air National Guard 

Readiness Center

State headquarters

Nondeployable federal headquarters

Communication and coordination relationship, but no command and control

Governor

Adjutant

General

Figure 1: Federal and State Organizational Structure of the National Guard 

Interactivity instructions: Click on an office with a red circle to view more information.

 See Appendix X for table summarizing text in the interactive figure.
 

Page 8 GAO-14-71 Defense Management

The National Guard Bureau is managed by the Chief of the National 

Guard Bureau—a 4-star General who was placed on the Joint Chiefs of 

Staff in 2011.16 Reporting to the Chief are two Lieutenant Generals who 

manage the Army National Guard Directorate and the Air National Guard 

Readiness Center, respectively. When not activated for federal missions, 

each state’s National Guard’s forces are commanded by the Adjutants 

General who also command the states’ Joint Force headquarters. The 

state Joint Force headquarters each consist of a Joint staff element, Army 

staff element, and Air staff element. Each of these elements is subject to 

different processes for reassessing and validating personnel 

requirements. These headquarters are responsible for coordinating the 

planning, training, and execution of National Guard homeland defense, 

civil support, and other domestic emergency missions within the United 

States. They also manage the National Guard’s readiness and prepare 

National Guard units for federal mobilization. The Army National Guard 

provides a balance of maneuver (combat), maneuver support, and 

maneuver sustainment capabilities. The Air National Guard provides a 

broad range of ready combat and combat-support capabilities such as 

tactical airlift and special operations. 

The Army Reserve and Air Force Reserve maintain 18 nondeployable

headquarters that manage or oversee subordinate units. The Army 

Reserve provides maneuver support and maneuver sustainment 

capabilities as well as individual soldiers through the Individual Ready 

Reserve and Individual Mobilization Augmentation programs.17 We 

identified 13 nondeployable Army Reserve headquarters that include the 

Office of the Chief of the Army Reserve, U.S. Army Reserve Command, 4 

regional support commands, and 7 functional commands. See 

appendixes V through VII for detailed information on the locations, 

missions, and responsibilities of these headquarters. The Office of the 

Chief of the Army Reserve and the U.S. Army Reserve Command are 

 

16See National Defense Authorization Act for Fiscal Year 2012, Pub. L. No. 112-81 § 512 

(2011).

17The Individual Ready Reserve is a manpower pool consisting principally of personnel 

that have had training, served previously in the active component or in the selected 

reserve, and have some period of their military service obligation remaining. Individual 

Mobilization Augmentees are trained reservists that fill an active component, Selective 

Service System, or Federal Emergency Management Agency organization’s billet on short 

notice. 

Army Reserve and Air 

Force Reserve 

Headquarters
 

Page 9 GAO-14-71 Defense Management

commanded by the same18 Lieutenant General who, by law, also sits on 

the Army Staff.19 Reporting to the Chief are 11 General officers who 

command support and functional commands, ensure the readiness of 

personnel, and maintain reserve installations within the United States, as 

shown in figure 2.

 

18DOD refers to the arrangement in which the incumbent officer has responsibilities to two 

organizations as a “dual hat” position. 

1910 U.S.C. § 3031(b)(9).
Page  GAO-14-71 Defense Management

Source: GAO analysis of DOD guidance and data. 

Office of the Chief of 

the Army Reserve

U.S. Army Reserve 

Command

Deployable or training Army Reserve headquarters

Nondeployable Army Reserve headquarters

Headquarters commanded by the same commanding officer

Administrative command

4 regional support 

commands

9 operational 

commands

6 training

commands

5 functional

commands 4 support

commands

Army Reserve 

operational units

2 functional

commands

Figure 2: Organization of Army Reserve Headquarters 

Interactivity instructions: Click on an office with a red circle to view more information. See Appendix X for table summarizing text in the interactive figure.
 

Page 11 GAO-14-71 Defense Management

The Air Force Reserve provides a broad range of combat and combatsupport capabilities. We identified five nondeployable headquarters that 

include Headquarters, Air Force Reserve; Air Force Reserve Command; 

and the 4th, 10th, and 22nd Air Forces. See appendixes VIII and IX for 

detailed information on the locations, missions and responsibilities of 

these headquarters. Headquarters, Air Force Reserve, and Air Force 

Reserve Command are commanded by the same Lieutenant General

who, by law, also sits on the Air Staff.20 Reporting to the Chief are three 

General officers who help to ensure the readiness of Air Force Reserve 

forces, as shown in figure 3. 

 

2010 U.S.C. § 8031(b)(7).
Page 12 GAO-14-71 Defense Management

Source: GAO analysis of DOD guidance and data. 

Air Force Reserve 

operational units

3 Numbered

Air Forces

Headquarters,

Air Force Reserve

U.S. Air Force

Reserve Command

Deployable Air Force Reserve units

Nondeployable Air Force Reserve headquarters

Headquarters commanded by the same commanding officer

Communication and coordination relationship, but no command and control

Figure 3: Organization of Air Force Reserve Headquarters 

Interactivity instructions: Click on an office with a red circle to view more information.

 See Appendix X for table summarizing text in the interactive figure.
 

Page 13 GAO-14-71 Defense Management

The Joint Chiefs of Staff, the Army, and the Air Force have processes to 

size and structure headquarters organizations. In general, these 

processes seek to provide the minimum number of personnel needed to 

accomplish missions and performance objectives. Additionally, Congress 

requires DOD to report personnel data21 for its Major DOD Headquarters 

Activities to support congressional oversight of these headquarters.22

These headquarters are listed in a DOD instruction.23 Prior to 2008, 

Congress placed a cap on the number of personnel that could be 

assigned to such headquarters; however, Congress removed this cap in 

2008.

Our analysis found that the overall number of funded military and civilian 

positions at the Army’s and Air Force’s reserve-component headquarters 

has steadily increased since fiscal year 2009, primarily due to DOD’s 

reassignment of workload from contractors to full-time federal civilians 

and increased mission requirements.24 These increases have come amid 

broader DOD efforts since 2010 to constrain or reduce headquarters. 

 

21DOD is required to provide Congress with an annual Defense Manpower Requirements 

Report on a number of personnel issues, including the number of personnel assigned to 

major DOD headquarters activities in the previous year and estimates of such numbers for 

the current and subsequent fiscal year. See 10 U.S.C. § 115a(f).

22DOD defines major DOD headquarters activities as those headquarters (and the direct 

support integral to their operation) whose primary mission is to manage or command the 

programs and operations of the DOD, the DOD components, and their major military units, 

organizations, or agencies. DOD maintains an approved list of its Major DOD 

Headquarters Activities. 

23DOD Instruction 5100.73, Major DOD Headquarters Activities (Dec. 1, 2007 

incorporating changes June 12, 2012). 

24In a February 2012 report, we found that DOD officials generally could not determine the 

number of contractor full-time equivalents whose functions were in-sourced because DOD 

contracts for services, not positions, and the number of contractor full-time equivalents 

used to perform a service is determined by each private-sector provider. GAO, Defense 

Workforce: DOD Needs to Better Oversee In-sourcing Data and Align In-sourcing Efforts 

with Strategic Workforce Plans, GAO-12-319 (Washington, D.C.: Feb. 9, 2012).

The Number of 

Military and Civilian 

Personnel Positions at 

Reserve-Component 

Headquarters Has 

Increased 
 

Page 14 GAO-14-71 Defense Management

Between fiscal year 2009 and 2013, the total number of positions funded25

for the 75 reserve-component headquarters we identified grew from about 

30,200 to about 31,900—an increase of nearly 6 percent, as shown in 

figure 4.26 Overall, the National Guard increased by about 1,350 funded 

positions (5 percent) and the Reserves by about 330 funded positions (7 

percent). The National Guard’s growth was driven by increases in the 

Army National Guard Directorate, which grew by about 750 funded 

positions over the period (about 44 percent). The National Guard Bureau, 

Air National Guard Readiness Center, and 54 state Joint Force 

headquarters increased about 17 percent, 21 percent, and 1 percent, 

respectively. The number of funded positions also increased at the Army 

Reserve’s headquarters, which grew by about 15 percent, but decreased 

at the Air Force Reserve’s headquarters by about 4 percent over the 

same period. 

 

25According to National Guard and Reserve officials, funded positions are not always 

filled, meaning that the actual number of personnel working at headquarters may be less 

than the number that was approved to be funded on the personnel requirements 

documents. Military-service officials stated that comparison of funded positions is the 

most-accurate way to evaluate changes in headquarters size over time because actual 

headcount fluctuates on a daily basis.

26We limited our assessment of personnel requirements to positions that: were assigned 

to the headquarters, included military personnel or civilians, were funded by the federal 

government, and did not complete work in support of more than one component (for 

example, recruiting positions were excluded because the Army Reserve and the active 

duty Army share recruiting resources)

Funded Positions at 

Reserve-Component 

Headquarters Have Grown 

Overall since 2009
 

Page 15 GAO-14-71 Defense Management

Figure 4: Trends in Funded Reserve-Component Headquarters’ Positions by 

Component from Fiscal Year 2009 through Fiscal Year 2013

Notes: These data reflect funded civilian and military positions. Some DOD personnel, referred to as 

“dual-status technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. For these personnel, DOD budgets for two positions. Consequently, in our calculations, we 

included the approximately 8,000 dual-status technicians in both the full-time civilian and part-time 

military totals for each fiscal year. Additionally, personnel categorized as “Active Guard and Reserve” 

occupy both a full-time military position as well as a part-time military position. Consequently, in our 

calculations we included the more than 5,000 Active Guard and Reserve positions in both the full-time 

military and part-time military totals for each fiscal year.

Of the nearly 1,700 positions DOD added to these headquarters, 

approximately 37 percent (more than 620 positions) were for full-time 

support positions. The percentage of funded positions that were allocated 

for full-time personnel varied by headquarters. For example, nearly 100 

percent of the positions funded for the National Guard Bureau, Air 
 

Page 16 GAO-14-71 Defense Management

National Guard Readiness Center, Army National Guard Directorate27, 

U.S. Army Reserve Command, and Headquarters, Air Force Reserve, 

were for full-time support in fiscal year 2013. In contrast, approximately 

45 percent of funded positions at the state Joint Force headquarters and 

33 percent of funded positions at the Army Reserve’s functional 

commands were for full-time positions in fiscal year 2013. Appendixes III 

through IX provide more-detailed analysis of positions funded at the 

headquarters we identified.

Our analysis shows that the National Guard has consistently allocated a 

greater percentage of its funded military and civilian positions to its 

headquarters than the other reserve components.

28 Specifically, funded 

positions at the Army National Guard headquarters we identified equaled 

6 percent of its estimated military and civilian funded positions in fiscal 

year 2013 (about 22,800 of its 389,350 estimated civilian and military 

funded positions).29 This contrasts with the other reserve components we 

examined, which have 2 to 3 percent of their military and civilian funded 

positions in nondeployable headquarters. National Guard officials said 

that the Army National Guard has allocated more funded positions to its 

headquarters for several reasons, including the National Guard’s need to 

prepare for and execute homeland defense and civil support missions, 

recruit its own personnel, and maintain a U.S. Property and Fiscal office 

in each state.

 

27In addition to having full-time civilian and Active Guard and Reserve personnel the Army 

National Guard Directorate has a group of personnel that are categorized as “Active Duty 

for Operational Support”. Active Duty for Operational Support is an authorized voluntary 

tour of active duty that is performed at the request of an organizational or operational 

commander, or as a result of reimbursable funding, among other things. The purpose of 

this category is to provide the necessary skilled manpower assets to support existing or 

emerging requirements.

28The National Guard includes 55 joint organizations (the National Guard Bureau and the 

54 state Joint Force headquarters) that include both Army and Air elements. We counted 

positions funded for the Army and Air staff at these joint headquarters toward the total 

number of Army or Air Force funded headquarters positions in the table above. 

29Estimated civilian and military funded positions were provided by each of the Army’s and 

Air Force’s reserve components for fiscal years 2009 through 2012. We calculated the 

estimated number of funded positions for fiscal year 2013 using the number of military 

positions Congress authorized for each component for that year and DOD’s budgetjustification materials. 
 

Page 17 GAO-14-71 Defense Management

National Guard and Reserve officials told us that there are two main 

drivers of growth since 2009 in funded positions at reserve-component 

headquarters—DOD’s 2010 effort to reduce its reliance on contractors by 

reassigning their workload to federal civilian positions, referred to as “insourcing,” and expanded mission requirements.30 In April 2009, the 

Secretary of Defense announced his intention to reduce DOD’s reliance 

on contractors and increase the number of civilian positions.31 Reserve 

component officials said that DOD’s in-sourcing effort was a significant 

driver of growth in civilian positions. For example, Army National Guard 

officials said that DOD’s in-sourcing effort contributed to an increase in 

over 700 civilian positions at the Army National Guard Directorate. 

Likewise, Air National Guard officials said that DOD’s in-sourcing effort 

caused the Air National Guard Readiness Center to add 180 funded 

positions. 

The other driver of growth in funded positions identified by reservecomponent officials was expanded mission requirements. Army Reserve 

officials noted that the 7th Civil Support Command’s increase of 71 

funded positions from fiscal year 2009 to fiscal year 2011 was the result 

of the Army closing a second Army activity and adding missions at the 

command. In a second instance, Army Reserve officials attributed growth 

at the Office of the Chief of the Army Reserve to the addition of new 

functions such as the Employer Partnership Office.32 National Guard 

 

30In a February 2012 report, we found that DOD officials generally could not determine the 

number of contractor full-time equivalents whose functions were in-sourced because DOD 

contracts for services, not positions, and the number of contractor full-time equivalents 

used to perform a service is determined by each private-sector provider. GAO-12-319. 

31Section 324 of the National Defense Authorization Act for Fiscal Year 2008 added a 

section 2463 to Title 10 of the United States Code, which requires DOD to develop 

guidelines and procedures that provide for special consideration to be given to using DOD 

civilian employees to perform new functions or certain categories of functions currently 

performed by contractor personnel. As part of this effort, the Secretary of Defense 

established in-sourcing targets for all DOD service components, which led to additional 

civilian positions being added. 

32According to senior Army Reserve officials, growth in the Office of the Chief of the Army 

Reserve also was driven by the transfer of functions between staff elements. For example, 

officials said that in fiscal year 2012 the Army Reserve Installation Management 

Directorate was added to the Office of the Chief of the Army Reserve’s personnel 

requirements document as a result of an agreement between the Chief of the Army 

Reserve and the Commander of the Army Installation Management Command. Officials 

said that 10 military and 33 civilian positions were added to the Office of the Chief of the 

Army Reserve in fiscal year 2013 as a result of that decision.

Reassignment of 

Contractor Workload to 

Civilian Positions and New 

Missions Have Driven 

Growth in Funded 

Positions 
 

Page 18 GAO-14-71 Defense Management

officials attributed the increase of over 250 funded positions at the state 

Joint Force headquarters to mission growth resulting from the 

establishment of civil-support capabilities such as implementation of the 

Homeland Response Forces33 beginning in fiscal year 2011. National 

Guard officials also said that the National Guard Bureau may grow in the 

future as a result of the Chief of the National Guard Bureau’s placement 

on the Joint Chiefs of Staff in 2011.

Although DOD has processes in place that generally seek to provide the 

minimum number of personnel needed to accomplish missions and 

performance objectives, these processes have not been consistently 

applied at 68 of the 75 headquarters we identified. For instance, the 

National Guard Bureau has been determining its own personnel 

requirements with no external review and validation since 2010 and has 

been growing steadily since 2009. In addition, DOD has not included data 

on the National Guard Bureau in its required Defense Manpower 

Requirements Report to Congress.34 In fiscal year 2013, the National 

Guard had about 21,900 funded positions at its 54 state Joint Force 

headquarters, but the processes for determining personnel requirements 

for these headquarters are fragmented35 among the National Guard 

Bureau’s Joint staff, the Army National Guard, and the Air National 

Guard. Finally, the Army and Air Force have not determined personnel 

requirements or fully reassessed within required time frames the 

personnel requirements at 13 of the 20 headquarters. Consequently, 

DOD lacks assurance that the Army’s and Air Force’s reserve-component 

headquarters are being staffed with the minimum personnel needed to 

perform their assigned missions.

 

33The 2010 Quadrennial Defense Review introduced 10 state-controlled Homeland 

Response Forces that consist of National Guard forces. 

34See 10 U.S.C. § 115a(f).

35Fragmentation refers to those circumstances in which more than one federal agency (or 

more than one organization within an agency) is involved in the same broad area of 

national need, and opportunities exist to improve service delivery. 

Processes Intended to 

Efficiently Size and 

Oversee ReserveComponent 

Headquarters Have 

Not Been Consistently 

Applied 
 

Page 19 GAO-14-71 Defense Management

The Joint Chiefs of Staff, the Army, and the Air Force have separate 

processes for determining and reassessing headquarters’ personnel 

requirements. DOD’s overarching manpower-management directive 

states that it is DOD policy that personnel requirements are driven by 

workload, and shall be established at the minimum levels necessary to 

accomplish mission and performance objectives.36 Joint Staff guidance 

emphasizes that personnel requirements may change in light of changes 

in technology and missions, and Army guidance provides that 

requirements are to be adjusted in response to changes.37 This is 

consistent with our prior work in the area of strategic human-capital 

management, which has found that high-performing organizations 

periodically reevaluate their resources, including personnel, to obtain the 

complete and reliable data needed to ensure that resources are properly 

matched to requirements.38 These organizations seek to identify their 

current and future personnel requirements—including the appropriate 

number of employees, key competencies, and skills mix for mission 

accomplishment—and the appropriate deployment of personnel across 

the organization. One purpose of the external review is to help ensure 

that joint activities have the minimum personnel with the appropriate skills 

and experience needed to carry out assigned missions. Similarly, Army 

and Air Force assessment practices generally include a review of 

personnel requirements by either a higher-level command or an external 

organization.

39 However, the Air Force’s process does not apply to the 

reserve component headquarters organizations we identified, which do 

not have external review of their personnel requirements. The processes 

 

36Department of Defense Directive 1100.4, Guidance for Manpower Management (Feb. 

12, 2005).

37Chairman of the Joint Chiefs of Staff, Instruction 1001.01a (Oct. 1, 2010). Department of 

the Army, Manpower Management, Regulation 570-4 (Feb. 8, 2006).

38GAO, Human Capital: A Model of Strategic Human Capital, GAO-02-373SP

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

39Army Regulation 570-4 requires that all personnel requirements for Army organizations 

must be reviewed and validated by the Assistant Secretary of the Army for Manpower and 

Reserve Affairs with assistance from the U.S. Army Manpower Analysis Agency. 

Additionally, this guidance states that the Chief of the National Guard Bureau has the 

authority to determine full-time support requirements for the National Guard’s state Joint 

Force headquarters. Air Force Instruction 38-201 requires Major Command staff to review 

manpower standards for applicability and reapply them to subordinate organizations at 

least every 2 years.

DOD Processes for 

Overseeing Headquarters 

Emphasize Periodic 

External Review to 

Validate Personnel 

Requirements
 

Page 20 GAO-14-71 Defense Management

applicable to reserve-component headquarters organizations are 

discussed in table 2.

Table 2: Processes for Determining Reserve-Component Headquarters Personnel Requirements 

Process Description

Reserve-component headquarters currently 

subject to process

Joint Chiefs of Staff 

Joint Manpower and 

Personnel Program

DOD uses its Joint Manpower and Personnel Program to 

review and approve personnel requirements at the 

combatant commands and other DOD joint activities. This 

process provides procedures to enable the Joint Staff to 

determine whether a proposed increase in positions is 

warranted.

• National Guard Bureau 

• National Guard state Joint Force 

headquarters’ Joint staff element

Department of the 

Army 

a

Manpower 

Management 

The Army uses its Manpower Management process to 

independently reassess total personnel requirements at its 

headquarters—including the Army staff at each state Joint 

Force headquarters under the oversight of the Army 

National Guard Directorate —by having personnel 

requirements reviewed and validated by the Assistant 

Secretary of the Army for Manpower and Reserve Affairs 

with assistance from the U.S. Army Manpower Analysis 

Agency.

• Office of the Chief of the Army Reserve

• U.S. Army Reserve Command

• Army Reserve Regional Support Commands

• Army Reserve Functional Commands

• Army National Guard Directorate

• National Guard state Joint Force 

headquarters Army staff element

Department of the 

Air Force

a

The Air Force has not established a process to determine 

and reassess personnel requirements for its reservecomponent headquarters. According to Air Force officials, 

commanders have authority to make changes to 

headquarters’ positions should they be required, but would 

have to request additional funding to obtain additional 

positions beyond what has already been validated by the 

Air Force. 

b

• Headquarters, Air Force Reserve

• Air Force Reserve Command

• Air National Guard Readiness Center

• Numbered Air Forces

• National Guard state Joint Force 

headquarters Air staff elementa

Source: Joint Staff, Army, and Air Force.

 

Notes: 

a

The state Joint Force headquarters consist of a Joint staff element, Army staff element, and Air staff 

element. Each of these elements is subject to different processes for reassessing and validating 

personnel requirements. These headquarters provide command and control for civil-support missions 

within their respective states as well as some homeland defense missions. 

b

Air Force officials told us that the Air Force has not developed guidance that requires personnel at 

the reserve-component headquarters we identified to be periodically reassessed or validated.

Under an informal agreement with the Joint Staff, the National Guard 

Bureau has been determining its own personnel requirements without 

validation by a higher-level command or external organization. Since 

2010, the number of funded positions at the bureau increased by 17 

percent and could grow further, according to National Guard Bureau 

officials. The DOD directive governing the National Guard Bureau 

provides that the National Guard Bureau’s personnel requirements should 

be managed in the same manner as other joint activities to the greatest 

extent possible. Joint activities are generally subject to the Joint Staff’s 

National Guard Bureau 

Personnel Requirements 

Are Not Being Externally 

Validated
 

Page 21 GAO-14-71 Defense Management

Joint Manpower and Personnel Program. According to officials, this 

program includes review, approval, and documentation of a headquarters’ 

personnel requirements by an external organization.40

According to Joint Staff and National Guard officials, in 2010, the Joint 

Staff and the National Guard Bureau reached an informal agreement that 

the bureau would maintain control for determining and validating its own 

personnel requirements. However, this agreement is inconsistent with the

Joint Staff’s regular personnel requirements reassessment process and 

differs from the military-service practices. National Guard Bureau and 

Joint Staff officials gave three reasons for this agreement. First, Joint 

Staff officials said that this agreement was reached because the bureau 

wanted to maintain control over its personnel requirements. Second, the 

National Guard Bureau is too dissimilar from other joint activities—such 

as the combatant commands—for which the Joint Staff is responsible. 

Third, the Joint Staff lacks the resources to assume responsibility for 

validating the bureau’s personnel requirements. 

Recognizing that recent developments warrant a re-evaluation of the 

National Guard Bureau’s personnel requirements, the National Guard 

Bureau started two efforts intended to enable it to define its personnel 

requirements. The National Guard Bureau has started an initiative called 

“Project Muster” to realign its headquarters processes to support the new 

roles and responsibilities of the Chief and Vice Chief of the National 

Guard Bureau and determine the personnel requirements needed to 

execute these responsibilities following the Chief’s placement on the Joint 

Chiefs of Staff. Officials responsible for the study said that it may show 

that the bureau will need to grow beyond its current size. In part because 

one of Project Muster’s baseline assumptions is that the bureau’s current 

manpower will be retained to meet preexisting requirements. 

In July 2013, while our review was underway, the Vice Chief for the 

National Guard Bureau asked that the U.S. Army Manpower Analysis 

Agency—with assistance from the Air Force Personnel Center—conduct 

 

40According to a DOD directive, the National Guard Bureau’s personnel are supposed to 

be managed under a joint manpower document—that is, a document that identifies the 

positions and spaces that have been validated for each element of a joint activity—in 

accordance with Chairman of the Joint Chiefs of Staff Instruction 1001.01a to the greatest 

extent possible. Department of Defense Directive 5105.77, National Guard Bureau (May 

21, 2008).
 

Page 22 GAO-14-71 Defense Management

an advisory analysis of positions at the National Guard Bureau to include 

its joint staff and the Office of the Chief of the National Guard Bureau. 

According to the U.S. Army Manpower Analysis Agency official 

responsible for the analysis, an advisory analysis entails a strategic look 

at a headquarters’ organizational structure. It is different from a personnel 

requirements study, which would assess individual workload, validate 

missions, and map processes. The Vice Chief’s request for an analysis 

was accepted by the U.S. Army Manpower Analysis Agency in August 

2013 and is currently scheduled for calendar year 2014.

Although both of these efforts are significant attempts to determine the 

bureau’s personnel requirements, neither of them will establish a process 

to periodically validate and reassess those requirements. Additionally, 

National Guard Bureau officials said that the Chief of the National Guard 

Bureau will continue to be the final authority on what requirements are 

approved for the bureau. By creating a system whereby an external 

organization is not independently assessing the National Guard Bureau’s 

personnel requirements the bureau has removed an independent check 

that could help ensure that the bureau is staffed with the appropriate 

number of personnel needed to execute its assigned missions and 

workload.

. 

Our analysis of DOD’s reserve-component headquarters found that 

DOD’s list of its Major DOD Headquarters Activities did not include the 

National Guard Bureau, even though the bureau meets the headquarters 

criteria specified in DOD’s instruction and is now commanded by a 4-star 

General who sits on the Joint Chiefs of Staff.41 DOD uses an instruction 

issued by the Office of the Secretary of Defense’s Director for 

Administration and Management that establishes the definitions and 

criteria that should be used to identify DOD’s Major DOD Headquarters 

Activities. This instruction also contains an enclosure that lists DOD’s 

Major DOD Headquarters Activities and this list is the basis for reporting 

required personnel data to Congress. In this instruction, DOD defines 

major DOD headquarters activities as those headquarters (and the direct 

support integral to their operation) whose primary mission is to manage or 

command the programs and operations of DOD, the DOD components, 

and their major military units, organizations, or agencies. In practice, DOD 

 

41Department of Defense Instruction 5100.73, Major DoD Headquarters Activities

(December 1, 2007). 

DOD Does Not List the 

National Guard Bureau as 

a Major DOD Headquarters 

Activity, and Its Personnel 

Data Have Not Been 

Reported to Support 

Congressional Oversight
 

Page 23 GAO-14-71 Defense Management

includes those headquarters that are commanded by a General or 

Admiral, or Lieutenant General or Vice Admiral or their equivalents. The 

National Guard Bureau meets both these criteria. In 2012, we reported 

that some other organizations that fit the definition of Major DOD 

Headquarters Activities were not included in DOD’s instruction. We 

recommended at that time that DOD revise its instruction to include all of 

its Major DOD Headquarters Activities.

42 Our review found that DOD has 

not updated its list to include the National Guard Bureau or the 

headquarters we identified in our 2012 report.43

 

DOD officials said that the National Guard Bureau was not included in its 

list of major DOD headquarters activities in the past because the National 

Guard Bureau had previously been a subactivity of the Army and Air 

Force; the National Guard Bureau has a National Guard mission that 

relates to the states, which is unusual for DOD’s headquarters; and 

officials did not focus on the National Guard Bureau being a headquarters 

that drives the department’s active-duty or Reserve missions. Officials 

from the Office of the Director of Administration and Management and the 

Assistant Secretary of Defense for Reserve Affairs agreed that the 

National Guard Bureau (including both the Office of the Chief and the 

Joint staff element) should be considered a major DOD headquarters 

activity and listed in DOD’s instruction; however, at the time of our review 

these officials did not have a schedule for further updating the instruction 

or the list of major DOD headquarters activities.

Having complete information about such headquarters activities is 

important for oversight because Congress has established reporting 

requirements that it can use to oversee the size of specific kinds of DOD’s 

headquarters, such as the National Guard Bureau.44 DOD is required to 

provide Congress with an annual Defense Manpower Requirements 

Report45 on a variety of personnel issues, including the number of military 

and civilian personnel assigned to major DOD headquarters activities in 

 

42GAO-12-345. 

43DOD made a technical update on June 12, 2012, to DOD Instruction 5100.73 that 

modified references, roles, responsibilities, and terms used throughout the instruction.

44See 10 U.S.C. § 115a(f).

45The Secretary of Defense is required to submit this report not later than 45 days after 

the submission of the President’s budget.
 

Page 24 GAO-14-71 Defense Management

the previous year, and estimates of such numbers for the current and 

subsequent year. Prior to 2008, DOD was subject to a statutory cap on 

the total number of personnel that could be assigned to Major DOD 

Headquarters Activities.

46 The National Defense Authorization Act for 

Fiscal Year 2008 repealed this cap, but required DOD to continue to 

report certain information about the size and composition of the staff 

assigned to Major DOD Headquarters Activities.

47 When fulfilling its 

reporting requirement, DOD uses the definitions and criteria in its 

instruction to identify DOD’s Major DOD Headquarters Activities and lists 

these headquarters in an enclosure. This list is the basis for reporting 

required personnel data to Congress, and because the bureau was not 

included in DOD’s list, its personnel data were not reported to Congress. 

Unless DOD revises its instruction to include the National Guard Bureau 

in its list of major DOD headquarters activities and reports the bureau’s 

personnel requirements data, Congress will continue to have limited 

information available to support oversight of this expanding headquarters 

activity.

The National Guard has not fully reassessed the personnel requirements 

of the 54 state Joint Force headquarters or their predecessor 

organizations—which collectively contain nearly 21,900 funded 

positions—since the 1980s despite changes in their organization and 

assigned missions. Our prior work has shown that cost savings may be 

achieved by consolidating and centralizing overlapping functions and 

eliminating unnecessary overlap and duplication.48 The state Joint Force 

headquarters consist of a Joint staff element, Army staff element, and Air 

staff element each of which is subject to different processes for 

reassessing and validating personnel requirements. Additionally, these 

headquarters have personnel that are assigned as the personal staff and 

special staff of the Adjutant General. The National Guard Bureau, Army 

National Guard Directorate, and Air National Guard Readiness Center 

 

46See National Defense Authorization Act for Fiscal Year 2008, Pub. L. No. 110-181, § 

901 (2008), repealing section 130a of Title 10 of the United States Code. 

47While the overall headquarters cap was repealed in 2008, various sectors of DOD’s 

headquarters workforce are still subject to similar statutory caps. For example, section 194 

of Title 10 of the United States Code, among other things, imposes a cap on headquarters 

management personnel of the defense agencies and DOD field activities. 

48GAO-12-345. GAO-13-279SP. 

DOD Lacks Assurance 

That the National Guard’s 

State Joint Force 

Headquarters Are Sized to 

Be Efficient 
 

Page 25 GAO-14-71 Defense Management

share responsibility for overseeing personnel requirements at the state 

Joint Force headquarters and there is not a process in place that enables 

the holistic assessment of personnel requirements at these headquarters. 

In the absence of a process that provides a holistic assessment of the 

state Joint Force Headquarters, National Guard officials noted that they 

have begun two efforts that are intended to assess personnel 

requirements at the state Joint Force headquarters: (1) a National Guard 

Bureau study evaluating personnel requirements for the Joint staff 

element at these headquarters and (2) an Army National Guard 

Directorate evaluation of functions—some of which include both Army 

National Guard and Air National Guard personnel—within these 

headquarters. We found that these efforts are limited and do not 

constitute a process that holistically assesses these headquarters’ 

personnel requirements. Without implementing a process to holistically 

assess personnel requirements for all three staff elements at these 

headquarters’, DOD lacks assurance that they are sized and structured to 

be efficient. 

National Guard officials said that they have not reassessed the personnel 

requirements for the National Guard’s 54 state Joint Force headquarters 

since the 1980s, even though there have been changes in the 

organization of these headquarters, including the missions assigned to 

them. The Army and the Air Force determined the personnel 

requirements for the Army and Air staff elements at the state Joint Force 

headquarters’ predecessor headquarters in 1982 on the basis of the 

number of personnel authorized for the state or territory as well as its 

population. 

The Army staff and Air staff elements are filled with Army National Guard 

and Air National Guard personnel respectively. The Joint staff element 

and the Adjutant General’s staff can be comprised of personnel from the 

Army National Guard, the Air National Guard, or both. Responsibility for 

overseeing personnel requirements of these staff elements is shared by 

the National Guard Bureau, Army National Guard Directorate, and Air 

National Guard Readiness Center, which have separate processes for 

determining, validating, and reassessing requirements for their respective 

staff elements, as shown in table 3. 

The National Guard Has Not 

Comprehensively Reassessed 

Its State Joint Force 

Headquarters 
 

Page 26 GAO-14-71 Defense Management

Table 3: Federal Organizations Responsible for Determining and Validating Personnel Requirements at State Joint Force 

Headquarters and a Description of Requirements

State Joint Force

headquarters staff 

element

Responsible 

organization

Process used to 

determine and validate 

personnel requirements Description of requirements 

Joint Staff National Guard 

Bureau

Joint Manpower and 

Personnel Program a

Joint staff element personnel requirements should be 

managed using joint manpower documents in accordance 

with Chairman of the Joint Chiefs of Staff Instruction 

1001.01a. This instruction requires the use of joint 

manpower documents and the validation of personnel 

requirements documented on those documents through the 

Joint Manpower and Personnel Process. 

Army Staff Army National 

Guard Directorate

Army Manpower Program Army staff element personnel requirements should be 

reassessed on a 2- to 5-year cycle. Personnel 

requirements are reviewed and validated by the Assistant 

Secretary of the Army for Manpower and Reserve Affairs 

with assistance from the U.S. Army Manpower Analysis 

Agency.

Air Staff Air National Guard 

Readiness Center

Air Force The Air Force does not have a requirement to reassess 

personnel requirements at its reserve-component 

headquarters above the wing level. 

Source: GAO analysis of Joint staff, Army, and Air Force data. 

Notes: 

a

In an April 2012 letter, the Joint Staff formally delegated responsibility to the National Guard Bureau 

for validating personnel requirements at the state Joint Force headquarters with the expectation that, 

although the state Joint Force headquarters would not be part of the joint staff’s overarching 

manpower program, its joint staff element would be managed by the National Guard Bureau using the 

same procedures.

We have previously found that government can reduce costs and improve 

operations through the elimination of unnecessary fragmentation, overlap, 

and duplication.49 Additionally, our 2012 report examining DOD’s 

headquarters and support organizations found that there may be 

additional opportunities for DOD to achieve cost savings by consolidating 

and centralizing overlapping functions and services. In our 2012 report, 

we recommended that DOD continue to examine opportunities to 

centralize administrative and command support services, functions, or 

programs.50 

 

49GAO-13-279SP. 

50GAO-12-345. 
 

Page 27 GAO-14-71 Defense Management

National Guard officials noted that they have two ongoing efforts that are 

intended to assess personnel requirements at the state Joint Force 

headquarters; however, we found that these efforts were limited and were 

not based on a process that holistically assessed personnel requirements 

for all three staff elements at these headquarters. 

First, as previously discussed, the National Guard Bureau has begun a 

two-phased study reassessing the personnel requirements for these 

headquarters’ Joint staff element; however, National Guard Bureau 

officials stated that the study would not examine the Army staff element or 

Air staff element portion of the state Joint Force headquarters. National 

Guard Bureau officials determined that on average each Joint staff 

element would need 30 personnel to perform core functions during the 

first phase of the study, which was completed January 2012. However, 

National Guard officials noted that the ultimate size and structure of the 

joint staff element will vary by state and should correlate with the state’s 

assigned missions and personnel. The second phase of the study is 

intended to develop a joint manpower document that would document the 

state headquarters’ ultimate size and structure. National Guard Bureau 

officials expect to complete this phase by fiscal year 2015. 

Second, in addition to the National Guard Bureau’s study, Army National 

Guard Directorate officials said that the absence of a holistic assessment 

of the state Joint Force headquarters contributed to their completing 

assessments of 17 functions, some of which are performed at these 

headquarters and are staffed with both Army National Guard and Air 

National Guard personnel. Army National Guard officials identified five 

offices within the Adjutant General’s personal staff that typically have both 

Army National Guard and Air National Guard personnel: the Chaplain’s 

Office, the Human Resources Office, the Office of the Judge Advocate 

General, the Public Affairs Office, and the Office of the Inspector General. 

Army National Guard officials said they are not required to collaborate 

with the Air National Guard when determining personnel requirements for 

these functions—although individual analysts may choose to do so at 

their discretion—and assessments only examine Army personnel 

requirements. Army National Guard officials also said that a recently 

completed study of the Chaplain’s office and an ongoing study of the 

Human Resources office had minimal collaboration with the Air National 

Guard. Further, Army National Guard officials noted that even if the Air 

National Guard were to be more heavily involved in the Army National 

Guard’s studies, there is not a process in place to estimate the workload 

for functions that have both Air National Guard and Army National Guard 

personnel.

Ongoing Personnel 

Requirements Studies Are 

Limited and Do Not Provide a 

Process for Holistically 

Assessing State Joint Force 

Headquarters’ Requirements 
 

Page 28 GAO-14-71 Defense Management

Three different organizations are responsible for assessing personnel 

requirements at the state Joint Force headquarters, and there is no 

process in place that provides a holistic assessment. As a result, the state 

Joint Force headquarters may be missing opportunities to consolidate or 

centralize overlapping functions and services and may be allowing 

personnel gaps or overlaps to develop or persist. For example, our review 

of the personnel requirements documents for the 54 state Joint Force 

headquarters shows that a number of similar positions are approved for 

both the Army staff element and the Air staff element within the same 

state. In one state’s Joint Force headquarters, the Army staff element 

allocated positions for five Judge Advocate Generals, two Public Affairs 

officials, and one Chaplain, while the Air Staff element allocated positions 

for two Judge Advocate Generals, one Public Affairs official, and two 

Chaplains. In a second state Joint Force headquarters, we found that the 

Army staff element allocated positions for three Judge Advocate 

Generals, three Public Affairs officials, and two Chaplains, while the Air 

staff element allocated positions for one Judge Advocate General, two 

Public Affairs officials, and one Chaplain. However, it is not clear whether 

these positions are all justified because the National Guard Bureau has 

not completed a holistic assessment of all the staff elements at these 

headquarters. 

While the National Guard Bureau’s and the Army National Guard’s efforts 

are important steps in determining personnel requirements at the state 

Joint Force headquarters, they are limited because the National Guard 

has not established a process for holistically assessing all three elements 

at these headquarters. Further, the Army National Guard and Air National 

Guard are not required to collaborate when determining personnel 

requirements, do not use a formal process to estimate workload for joint 

functions in their entirety, and do not have a means for ensuring these 

functions are staffed to be efficient. As a result, these studies are unlikely 

to ensure that the state Joint Force headquarters avoid gaps or overlaps 

in positions and have the minimum personnel required to perform their 

assigned missions. 

The Army and Air Force have not consistently implemented processes for 

ensuring their reserve-component headquarters have the minimum 

number of personnel, thereby hindering their ability to determine whether 

these headquarters have been sized to be efficient. Our analysis shows 

that 13 of the 20 Army and Air Force reserve-component headquarters 

have not been fully reassessed. Our analysis shows that 5 of the 7 

organizations that have been reassessed shrank from fiscal year 2009 

through fiscal year 2013. In contrast, several of the headquarters that 

The Army and Air Force 

Have Not Consistently 

Implemented Processes 

for Reassessing Personnel 

Requirements of ReserveComponent Headquarters
 

Page 29 GAO-14-71 Defense Management

showed significant growth were among those that have not been 

reassessed including the Office of the Chief of the Army Reserve and Air 

National Guard Readiness Center. As we previously noted, our work in 

the area of strategic human-capital management has shown that 

reassessing resource requirements—including personnel—enables 

organizations to achieve their missions and match resources to their 

needs.51 Table 4 shows the status of personnel requirement assessments 

at the Army and Air Force reserve-component headquarters we identified. 

 

51GAO-02-373SP. 
 

Page 30 GAO-14-71 Defense Management

Table 4: Status of Army and Air Force Manpower Assessment Processes for Reserve-Component Headquarters 

Military service 

Required 

reassessment time 

frame Headquarters

Status (year 

completed)

Army Optimally every 3 

years; at least once 

every 2–5 years

Army National Guard Directorate (2013)

Military Intelligence Readiness Command (2010)

Office of the Chief of the Army Reserve ◐(2009) a

U.S. Army Reserve Command ◐(2009) a

1st Mission Support Command ◐(2012) a

7th Civil Support Command ◐(2012) a

79th Sustainment Support Command ◐(2012) a

Army Reserve Medical Command ◐(2012) a

U.S. Army Civil Affairs and Psychological Operations Command ◐(2012) a

9th Mission Support Command ◐(2012) a

63rd Regional Support Command  b

88th Regional Support Command  b

99th Regional Support Command  b

81st Regional Support Command  b

Air Force None Air National Guard Readiness Center 

Headquarters, Air Force Reserve 

c

(2011)

Air Force Reserve Command

d

(2012)d

22nd Air Force

 

(2012)

4th Air Force

d

(2012)

10th Air Force

d

(2012)

Legend:

d

 Fully completed: The entire headquarters had its personnel requirements reassessed. 

◐ Partially completed: A portion of a headquarters had its personnel requirements reassessed. For 

example, personnel requirements for a function or a type of position could have been assessed 

independently from the headquarters as a whole. A partial assessment does not fully address 

reassessment requirements.

 None: No part of the headquarters had its personnel requirements reassessed.

Source: GAO analysis of Army and Air Force data

a

Although 13 reserve-component headquarters were not assessed in their entirety, some functions 

within the organizations were assessed; however, partial assessments do not fully address 

requirements established in Army Regulation 570-4.

b

The four Regional Support Commands are currently in the process of being assessed by the U.S. 

Army Manpower Analysis Agency.

c

The Air Force does not have a requirement for this reserve-component headquarters to be 

periodically assessed, and the personnel requirements for this headquarters have not been 

assessed. 

d

While not required by its guidance, in 2012 the Air Force conducted full assessments on these 

headquarters as part of its recent efficiencies review.
 

Page 31 GAO-14-71 Defense Management

According to Army Manpower Analysis Agency officials, most Army 

reserve-component headquarters have not had their personnel 

requirements fully reassessed because the U.S. Army Manpower 

Analysis Agency has a backlog of reassessments needing review and 

approval. The U.S. Army Manpower Analysis Agency validates52 the 

headquarters’ reassessment of their requirements.53 The Army’s 

manpower-management regulation requires that Army headquarters be 

reassessed not less than every 5 years and optimally every 3 years.54

Army officials said that a reassessment should generally include a review 

of the entire headquarters; however, there are some instances where 

commanders conduct a partial assessment—for example of a single 

function or type of position. Army officials said that the manpower 

analysis agency has prioritized its review and approval of personnel 

requirements reassessments and worked with the Army Reserve to 

establish a schedule through fiscal year 2016 for reassessing some 

headquarters; however, we found that several of the headquarters 

included in our review that had not recently been reassessed were not 

included in this schedule. Once the U.S. Army Manpower Analysis 

Agency validates an assessment, it is submitted to the Office of the Army 

Operations and Plans for approval. If an Army headquarters does not 

have a validated personnel requirements document, its personnel

requirements could be removed from its personnel requirements 

document during periodic force-structure reviews and excluded from the 

Army’s annual budget request. 

Air Force officials told us that one Air Force reserve-component 

headquarters we identified did not have its personnel-requirements 

assessed because such a periodic reassessment is not currently required 

in the Air Force’s guidance. Specifically, the guidance55 only requires 

 

52Validating a requirement means the U.S. Army Manpower Analysis Agency has 

analyzed whether manpower requested meets the workload being performed. 

53The U.S. Army Manpower Analysis Agency uses a five-phased approach when 

reassessing personnel requirements. This approach entails: (1) planning the study 

approach, scope, and timelines; (2) completing an initial analysis to validate the 

headquarters’ mission and review previous studies; (3) collecting and analyzing data on 

mission and workload; (4) developing a product with recommendations on workforce mix 

and staffing; and (5) validating and approving the final documentation.

54Army Regulation 570-4, Manpower Management (Feb. 8, 2006). 

55Air Force Instruction 38-201, Management of Manpower Requirements and 

Authorizations (May 14, 2013).
 

Page 32 GAO-14-71 Defense Management

headquarters embedded in its operational wings be reassessed at least 

every 2 years. In contrast, reassessments for the Air Force’s reservecomponent headquarters are done on an ad hoc basis. In 2011 and 2012, 

the Air Force Reserve reassessed five of its headquarters56 as part of its 

efforts to streamline its operations, not due to any requirement in 

guidance.57 Following this reassessment, the Air Force Reserve shrank 

the three numbered Air Force headquarters by more than one-third, and 

Headquarters, Air Force Reserve, by more than 10 percent. Another 

headquarters that was reassessed, the Air Force Reserve Command, 

grew in size by about 7 percent. According to Air Force officials, changes 

in headquarters personnel requirements are typically driven by changes 

in force structure, made in response to efficiency initiatives, or initiated by 

the headquarters’ commanding officer. Air Force officials said that it 

would be beneficial to apply a reassessment standard to all of the Air 

Force’s reserve-component headquarters, but the Air Force has not taken 

steps to initiate such reviews or revise the guidance to require them in the 

future. Unless the Army and Air Force periodically reassess their reservecomponent headquarters, they will lack assurance that these 

headquarters are sized with the minimal staff required and structured 

appropriately.

Amid DOD’s recent efforts to trim budgets by finding efficiencies and 

reducing overhead, some reserve-component headquarters have grown. 

While some of this growth is due to reducing reliance on contractors and 

expanding missions, DOD does not know whether its reserve-component 

headquarters are sized with the appropriate personnel needed to 

accomplish their missions today and in the future. Human-capital 

practices suggest that the size and structure of organizations need to be 

reassessed periodically. In total, 68 of 75 the reserve-component 

headquarters we reviewed have not been recently reassessed. Until 

these organizations are assessed, the Army and Air Force will lack 

assurance that they are sized and structured appropriately. Additionally, 

until DOD externally validates the National Guard Bureau’s personnel 

 

56The Air Force Reserve examined the Air Force Reserve Command and its three 

numbered Air Forces. 

57The Air Force Reserve created its Force Generation Center to streamline force 

identification, mobilization and deployment across the Air Force Reserve and improve the 

Commander’s visibility into current and planned resources commitments.

Conclusions 
 

Page 33 GAO-14-71 Defense Management

requirements, holistically assesses personnel requirements for its 54 

state Joint Force headquarters, and schedules reassessments for reserve 

component headquarters it will lack assurance that these headquarters 

are appropriately sized to accomplish their assigned mission.

The National Guard Bureau—whose Chief was recently placed on the 

Joint Chiefs of Staff—has grown about 17 percent since 2010 and is 

anticipating further growth related to its elevated role. However, the 

oversight process currently in place allows the National Guard Bureau to 

determine its personnel requirements without validation by a higher-level 

command or external organization. Furthermore, reports used to support 

congressional oversight have not included information on the bureau. 

Unless the bureau’s personnel requirements are validated by an external 

organization and related information is included in DOD’s report to 

Congress, both DOD and Congress will lack assurance that the bureau’s 

size and structure is appropriate for its mission.

For the 54 state Joint Force headquarters, fragmented review processes 

across the National Guard Bureau, Army National Guard, and Air National 

Guard have created an environment where similar and possibly 

overlapping positions have been approved for the three interconnected 

staff elements in each state. Their requirements have not been 

reassessed since the 1980s, and ongoing studies by the National Guard 

are too limited in scope to provide a comprehensive reassessment. As a 

result, no organization has examined the multiple staff elements at these 

headquarters for potential personnel gaps or overlaps that could hinder 

their ability to perform their missions or could waste resources. 

Finally, for those headquarters overseen by the Army and Air Force—

specifically 13 Army Reserve headquarters, 5 Air Force Reserve 

headquarters, the Army National Guard Directorate, and the Air National 

Guard Readiness Center—DOD has processes in place that if 

consistently implemented could help ensure that these headquarters are 

sized and structured appropriately. The Army and Air Force have not 

reassessed 13 of these 20 headquarters, and of the seven headquarters 

that were recently reassessed five shrank, some markedly. Until the Army 

and the Air Force reassess the remaining headquarters that they oversee 

DOD will lack assurance that these headquarters are sized and structured 

appropriately.
 

Page 34 GAO-14-71 Defense Management

To facilitate oversight of the size of DOD’s reserve-component 

headquarters and ensure that they have the minimum personnel needed 

to complete their assigned missions, we are making the following six 

recommendations.

To independently validate the personnel requirements for the National 

Guard Bureau, we recommend that the Secretary of Defense direct the 

Chief of the National Guard Bureau to implement the Joint Chief of Staff’s 

Joint Manpower and Personnel Process and have its personnel 

requirements periodically validated by a DOD organization external to the 

National Guard Bureau. 

To provide Congress the data it requires to oversee DOD’s Major DOD 

Headquarters Activities, we recommend that the Secretary of Defense 

include the National Guard Bureau among its list of Major DOD 

Headquarters Activities and report personnel associated with the National 

Guard Bureau in the Defense Manpower Requirements Report.

To minimize the potential for gaps or overlaps at the National Guard’s 

state Joint Force headquarters, we recommend that the Secretary of 

Defense direct the Chief of the National Guard Bureau to:

• develop a process for the Army National Guard and Air National 

Guard to collaborate when determining personnel requirements for 

joint functions at these headquarters and 

• assess and validate all personnel requirements at the state Joint 

Force headquarters to include the Army staff element and Air staff 

element.

To ensure that Army Reserve headquarters and the Army National Guard 

Directorate are properly sized to meet their assigned missions, we 

recommend that the Secretary of Defense direct the Secretary of the 

Army to ensure that these headquarters are reassessed and have their 

personnel requirements validated within required time frames by including 

them in the U.S. Army Manpower Analysis Agency’s schedule for 

reassessment and validation. 

To ensure that Air Force Reserve headquarters and the Air National 

Guard Readiness Center are properly sized to meet their assigned 

missions, we recommend that the Secretary of Defense direct the 

Secretary of the Air Force to modify the Air Force’s guidance to require 

that these headquarters have their personnel requirements reassessed 

on a recurring basis, and establish and implement a schedule for 

Recommendations for 

Executive Action
 

Page 35 GAO-14-71 Defense Management

reassessing personnel requirements for its reserve-component 

headquarters.

We provided a draft of this report to the Department of Defense for review 

and comment. In response, we received written comments which are 

reprinted in appendix XI. DOD concurred with three of our 

recommendations and partially concurred with the remaining three 

recommendations. DOD also provided technical comments which we 

incorporated into the report as appropriate.

DOD partially concurred with our first recommendation that the Secretary 

of Defense require the Chief of the National Guard Bureau have its 

personnel requirements periodically validated by a DOD organization 

external to the National Guard Bureau. DOD stated that while the 

department agrees that external validation is appropriate, it is DOD’s view 

that the appropriate means for obtaining this external validation is by 

establishing a vetting process that includes representatives from the 

Army, Air Force, and the National Guard Bureau. DOD therefore 

suggested that we modify our recommendation to reflect this. We believe 

DOD retains the flexibility to develop a vetting process that includes 

representatives from the organizations identified above so long as this 

process follows the guidelines described in DOD guidance and 

requirements are periodically validated by an organization external to the 

bureau. As a result we did not modify our recommendation as DOD 

suggested.

DOD concurred with our recommendation that the Secretary of Defense 

include the National Guard Bureau among its list of Major DOD 

Headquarters Activities and report personnel associated with the National 

Guard Bureau in its Defense Manpower Requirements Report. In its 

response to our recommendations DOD provided several technical 

comments that we addressed in the body of our report. 

The department also partially concurred with our recommendations that 

the Chief, National Guard Bureau modify the scope of its ongoing 

manpower study to reassess personnel requirements at the state Joint 

Force headquarters and validate these requirements including those for 

the Army and Air staff elements. In DOD’s response, the department 

detailed ongoing efforts to validate personnel requirements and stated 

that revising the scope of the National Guard Bureau’s study would 

eliminate the ability of the Army National Guard and Air National Guard to 

identify their own personnel requirements. The department further stated 

Agency Comments 

and Our Evaluation
 

Page 36 GAO-14-71 Defense Management

that when shared functions are being studied, coordination should be 

increased between the staff elements to ensure that the correct workload 

is captured, requirements are not duplicated, and process efficiencies are 

maximized. However, we found minimal coordination on studies 

examining the five functions that the National Guard identified as being 

staffed with both Army National Guard and Air National Guard personnel. 

For example, Army National Guard officials told us that a study of the 

Chaplain’s office was completed with minimal Air National Guard 

participation and only captures the Army National Guard’s personnel 

requirements. Similarly, Army National Guard officials said that the Air 

National Guard has been minimally involved in an ongoing evaluation of 

the Human Resources Office. We agree that closer coordination is 

warranted and have revised our recommendation to emphasize this while 

retaining the recommendation that the National Guard Bureau review and 

validate all personnel requirements at the state Joint Force headquarters 

including the Army staff element and Air staff element.

DOD also concurred with our recommendation that the Secretary of 

Defense direct the Secretary of the Army to ensure that Army Reserve’s 

headquarters and the Army National Guard Directorate have their 

personnel requirements validated within required time frames by including 

them in the U.S. Army Manpower Analysis Agency’s schedule for 

reassessment and validation. In its response to our recommendations, 

DOD noted it has several ongoing efforts that are intended to assess 

Army Reserve full-time support requirements, and institutional and 

operational headquarters. DOD also noted that the draft report was not 

specific as to whether this recommendation is intended to be applicable to 

the Army National Guard. We clarified our recommendation in response 

to DOD’s comments to specify that the Army Reserve’s headquarters and 

Army National Guard Directorate be included in the U.S. Army Manpower 

Analysis Agency’s schedule for reassessment and validation. 

DOD agreed with our last recommendation that the Secretary of Defense 

direct the Secretary of the Air Force to modify the Air Force’s guidance to 

require that these headquarters have their personnel requirements 

reassessed on a recurring basis, and establish and implement a schedule 

for reassessing personnel requirements for its reserve-component 

headquarters. In its response to our recommendations, DOD noted that 

the Air Force agreed to modify its guidance to require that reserve 

component headquarters have their personnel requirements reassessed 

on a recurring basis. Additionally, the Air Force intends to establish and 

implement a schedule for reassessing personnel requirements at these 
 

Page 37 GAO-14-71 Defense Management

headquarters. If implemented, these steps would satisfy the intent of our 

recommendation.

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 Secretary of Defense; the Secretary of 

the Army; the Secretary of the Air Force; the Joint Chiefs of Staff; the 

Chief, National Guard Bureau; the Chief, Army Reserve; and the Chief, 

Air Force Reserve. This report is also available at no charge on the GAO 

website at http://www.gao.gov. 

Should you or your staffs have any questions about this report, please 

contact John Pendleton at (202) 512-3489 or pendletonj@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made 

contributions to this report are listed in appendix XII.

John H. Pendleton

Director, Defense Capabilities and Management 
Appendix I: Scope and Methodology

Page 38 GAO-14-71 Defense Management

To conduct this work and address our objectives, we reviewed data on 

funded positions at the Army’s and Air Force’s reserve-component 

headquarters from fiscal year 2009 through fiscal year 2013. We selected 

these years because senior officials stated that the current reservecomponent headquarters structure has remained relatively constant over 

this period of time. We did not review contractor positions as part of this 

review because officials told us that they were unable to determine the 

number of contractor positions at the reserve-component headquarters 

we identified. On the basis of a review of Department of Defense (DOD) 

and service guidance,1 organization charts, and discussions with officials, 

we focused our review on 75 headquarters within the Army National 

Guard, Air National Guard, Army Reserve, and Air Force Reserve. We 

limited our review to nondeployable headquarters that perform many of 

the functions DOD identified as being characteristics of management 

headquarters. For the Army, these headquarters had their personnel 

requirements documented on tables of distribution and allowance, and we 

collaborated with Army National Guard and Army Reserve officials when 

developing our list. For the Air Force, we interviewed Air National Guard 

and Air Force Reserve officials to identify headquarters units that met our 

criteria. We then provided DOD, Joint Staff, National Guard, and Reserve 

officials with an opportunity to comment on our final list of 75 

headquarters and these officials agreed the headquarters we identified 

met these criteria, but noted that they were not all Major DOD 

Headquarters Activities. 

For all of the headquarters we identified, we limited our assessment of 

personnel requirements to positions that: were assigned to the 

headquarters, included military personnel or civilians, were funded by the 

federal government, and did not complete work in support of more than 

one component (for example, recruiting positions were excluded because 

the Army Reserve and the active-duty Army share recruiting resources). 

To ensure the reliability of the personnel data, we interviewed 

knowledgeable officials about the data and internal controls on the 

systems that contain them. We also analyzed the data in order to identify 

 

1

Department of Defense Directive 5105.77, National Guard Bureau (NGB) (May 21, 

2008). Department of Defense Directive 5105.83, National Guard Joint Force 

Headquarters-State (NG-JFHQs-State) (Jan. 5, 2011). Army Regulation 130-5, 

Organization and Functions of the National Guard Bureau (Dec. 30, 2001). Army

Pamphlet 10-1, Organization of the United States Army (June 14, 1994). Air Force

Instruction 38-101, Air Force Organization (Mar. 16, 2011, incorporating change May 2, 

2013).

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

Page 39 GAO-14-71 Defense Management

outliers or invalid data and removed these data from our dataset where 

appropriate. Finally, we shared our analysis with knowledgeable agency 

officials and asked them to verify its accuracy. On the basis of these 

steps we determined that the data were sufficiently reliable for the 

purposes of this audit.

To evaluate the extent to which DOD established and implemented 

processes to efficiently size its reserve-component headquarters and 

provide information for congressional oversight we took the following 

steps:

1. We evaluated the Joint Staff’s implementation of its process for 

assessing personnel requirements at the National Guard Bureau by 

reviewing relevant guidance and documentation and interviewing 

officials from the Joint Staff and the National Guard Bureau.2 Where 

available, we analyzed manpower assessments and manpower 

documents for the National Guard Bureau from fiscal year 2009 

through fiscal year 2013 and evaluated whether they met standards. 

We also compared the steps taken to assess the National Guard 

Bureau’s personnel requirements with Army and Air Force guidance 

and practices.3

2. We assessed DOD’s efforts to identify Army and Air Force reserve 

component major DOD headquarters activities and report personnel 

data for these headquarters by reviewing DOD guidance on major 

DOD headquarters activities; reviewing documentation and 

interviewing officials to identify reserve-component headquarters with 

those characteristics; and comparing identified headquarters’ 

functions to characteristics of Major DOD Headquarters Activities

identified in DOD’s guidance.4 We assessed section 194 of Title 10 of 

the United States Code to determine whether the statutory cap 

identified in that section applies to the headquarters we identified. We 

 

2

Department of Defense Directive 1100.4, Guidance for Manpower Management (Feb. 12, 

2005). Department of Defense Instruction 1100.22, Policy and Procedures for Determining 

Workforce Mix (Apr. 12, 2010). Department of Defense Directive 5105.77 National Guard 

Bureau (NGB) (May 21, 2008), . Chairman of the Joint Chiefs of Staff Instruction 

1001.01A, Joint Manpower and Personnel Program (Oct. 1, 2010).

3

Army Regulation 570-4, Manpower Management (Feb. 8, 2006). Air Force Instruction 38-

201, Management of Manpower Requirements and Authorizations (May 14, 2013).

4

DOD Instruction 5100.73 Major DOD Headquarters Activities (Dec. 1, 2007, incorporating 

changes, Jun. 12, 2012).
Appendix I: Scope and Methodology

Page 40 GAO-14-71 Defense Management

also reviewed the Defense Manpower Requirements Report for fiscal 

year 2012 and fiscal year 20135 to determine which headquarters 

were included in reports to Congress. Where we identified 

discrepancies, we spoke with DOD and service officials to identify the 

cause of these discrepancies. Finally, we assessed the National 

Guard Bureau’s ongoing study (Project Muster) seeking to establish 

baseline requirements for the National Guard Bureau by collecting 

relevant documentation and interviewing knowledgeable staff from the 

National Guard Bureau. 

3. We evaluated the National Guard Bureau’s implementation of its 

process for assessing personnel requirements at the 54 state Joint 

Force headquarters by reviewing relevant guidance6 and 

documentation and interviewing officials from the Joint Staff and the

National Guard Bureau. We analyzed manpower assessments and 

manpower documents from fiscal year 2009 through fiscal year 2013 

for the state Joint Force headquarters and evaluated whether they 

met standards established in guidance. We also conducted site visits 

to the state Joint Force headquarters for Delaware, Georgia, New 

Jersey, and Texas to determine whether manpower documents and 

assessments accurately documented these headquarters’ 

requirements given assigned personnel, missions, and workload. We 

selected these headquarters to obtain perspectives from state officials 

from states of varying size and with different numbers of National 

Guard, Army Reserve, and Air Force Reserve personnel. Finally, we 

assessed the National Guard Bureau’s ongoing state Joint Force 

headquarters requirements study seeking to establish baseline 

personnel requirements for these headquarters’ Joint staff element by 

collecting relevant documentation and interviewing knowledgeable 

staff from the National Guard Bureau. 

We evaluated the Army’s and Air Force’s implementation of their 

processes for assessing personnel requirements at service-specific 

 

5

Department of Defense, Defense Manpower Requirements Report Fiscal Year 2013 

(Washington D.C.: June 2013). Department of Defense, Defense Manpower 

Requirements Report Fiscal Year 2012 (Washington D.C.: April 2012).

6

Department of Defense Directive 5105.83, National Guard Joint Force HeadquartersState (NG-JFHQs-State (Jan. 5, 2011). Chairman of the Joint Chiefs of Staff Instruction 

1001.01A, Joint Manpower and Personnel Program (Oct. 1, 2010). 
Appendix I: Scope and Methodology

Page 41 GAO-14-71 Defense Management

headquarters by reviewing relevant guidance7 and documentation and 

interviewing officials from numerous Army and Air Force offices including 

the U.S. Army Manpower Analysis Agency, the Air Force Personnel 

Center, and Air Force Reserve Command. We then analyzed manpower 

assessments for each of the 20 service-specific headquarters we 

identified for fiscal year 2009 through fiscal year 2013 to determine (1) 

when the headquarters was most recently reassessed, (2) the scope of 

the assessment, and (3) whether they met requirements established in 

guidance for recurring reassessment and validation of headquarters’ 

personnel requirements. One analyst analyzed the assessments and a 

second analyst reviewed the analyst’s work. Any disagreements in the 

determination were resolved through discussion. We also visited the 

headquarters listed in table 5 to determine whether manpower documents 

and assessments accurately documented these headquarters’ personnel 

requirements given assigned personnel, missions, and workload.

Table 5: Nongeneralizable Sample of Reserve-Component Headquarters Visited 

during the Audit

Component Headquarters

National Guard • Army National Guard Directorate 

• Air National Guard Readiness Center

Army Reserve • Office of the Chief of the Army Reserve 

• U.S. Army Reserve Command

• 99th Regional Support Command

• Military Intelligence Readiness Command

Air Force Reserve • Headquarters, Air Force Reserve

• Air Force Reserve Command

• 22nd Air Force

State Headquarters • Joint Forces Headquarters-State for Delaware

• Joint Forces Headquarters-State for Georgia

• Joint Forces Headquarters-State for New Jersey

• Joint Forces Headquarters-State for Texas

Source: GAO.

To discuss whether DOD has studied merging the Army’s and Air Force’s 

reserve components to improve efficiency, we conducted a literature 

 

7

Department of Defense Directive 1100.4 (Feb. 12, 2005) and Department of Defense 

Instruction 1100.22 (Apr. 12, 2012). Army Regulation 570-4 (Feb. 8, 2006). Air Force 

Instruction 38-201 (May 14, 2013).
Appendix I: Scope and Methodology

Page 42 GAO-14-71 Defense Management

search, analyzed past studies, reviewed our prior work, and reviewed 

white papers by DOD and subject-matter experts examining mergers and 

the factors organizations use when evaluating the merits of a merger. We 

reviewed statutes as well as DOD and military-service guidance 

describing the organization and function of the Army's and Air Force’s 

reserve-component headquarters to understand their missions and how 

they are organized.8 To obtain perspectives on the implications of a 

merger, we interviewed officials from numerous offices including the 

Office of the Secretary of Defense; the National Guard Bureau; the

Department of the Army; the Office of the Chief, Army Reserve; the 

Department of the Air Force; and the Office of the Chief, Air Force 

Reserve. We also reviewed documentation and met with officials from 

four state Joint Force headquarters and select headquarters in the Army 

Reserve and Air Force Reserve. We interviewed officials and, where 

appropriate, obtained documentation at the organizations listed in table 6.

 

8

See e.g. 10 U.S.C. §§ 10502, 3031, and 8031. USAR Regulation 10-1, Army Reserve 

Regional Support Command (RSC) Organization and Functions Manual, (Oct. 1, 2010). 

Air Force Instruction 38-101 (Mar. 16, 2011); and Army Pamphlet 10-1 (June 14, 1994).
Appendix I: Scope and Methodology

Page 43 GAO-14-71 Defense Management

Table 6: Organizations Interviewed over the Course of the Audit

Department Organization

DOD Joint Chiefs of Staff (Joint Staff/J-1)

National Guard Bureau (Joint Staff)

Office of the Advisors to the Chief of the Joint Chiefs of Staff for 

National Guard Affairs and Reserve Affairs

Office of the Assistant Secretary of Defense for Reserve Affairs

Office of the Assistant Secretary of Defense–Homeland Defense 

and America’s Security Affairs

Reserve Force Policy Board

Army Army G/3/5/7 Force Management and Planning

Army Human Resources Command

Army National Guard Directorate

Army Reserve Forces Policy Committee

Assistant Secretary of the Army, Manpower and Reserve Affairs

Institutional Army Transformation Commission

Office, Chief Army Reserve

U.S. Army Force Management Support Agency

U.S. Army Forces Command

U.S. Army Manpower Analysis Agency

U.S. Army Reserve Command

Air Force 22nd Air Force

Air Force Personnel Center

Air Force Reserve Command

Headquarters, Air Force Reserve

Air National Guard Readiness Center

Deputy Assistant Secretary of the Air Force for Reserve Affairs 

(SAF/MRR) 

Force Generation Policy Branch

Manpower Programs Branch

Secretary of the Air Force (SAF)

State Headquarters Joint Forces Headquarters-State for Delaware

Joint Forces Headquarters-State for Georgia

Joint Forces Headquarters-State for New Jersey

Joint Forces Headquarters-State for Texas

Source: GAO.
Appendix I: Scope and Methodology

Page 44 GAO-14-71 Defense Management

We conducted this performance audit from July 2012 to November 2013, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 45 GAO-14-71 Defense Management

Department of Defense (DOD), special commissions, and some 

nondefense organizations have studied the concept of merging the Air 

Force’s and the Army’s reserve components. DOD considered merging 

some reserve components after World War II, during the Vietnam era, 

and during the wars in Afghanistan and Iraq. In addition, the 

Congressional Budget Office examined the costs and benefits of merging 

multiple components. Additionally, the 2005 Base Closure and 

Realignment Commission recommended that National Guard and 

Reserve units share facilities. Finally, DOD has taken steps, short of 

merging its reserve components, to address concerns about access to 

the federal reserves to assist the National Guard in domestic duties such 

as responding to floods or hurricanes.

DOD considered merging some reserve components after World War II, 

during the Vietnam era, and during the wars in Afghanistan and Iraq.

• The Committee on Civilian Components or “Gray Board.” In 

November 1947, the Secretary of Defense convened a six-member 

Committee on Civilian Components with representatives from the 

Army, Navy, and Air Force to broadly study the National Guard and 

Reserves. This committee found that National Guard units used 

during World War II required lengthy periods of training before being 

deployed. The committee’s report was also critical of state 

Governors—none of whom, it argued, had any direct responsibility for 

the national security—and it recommended merging the Army

National Guard and the Air National Guard with the Army Reserve 

and Air Force Reserve, respectively, to form two federally controlled 

Reserve forces.1 The Secretary of Defense did not endorse this 

recommendation. 

• Vietnam-era Proposals. DOD considered realigning the Army’s 

reserve components in 1961–1962 and 1964, when the Secretary of 

Defense put forth two plans that were intended to streamline or merge 

the Army National Guard and Army Reserve. The first plan proposed 

eliminating four National Guard divisions and four Army Reserve 

divisions. Subsequently, a subcommittee of the House Armed 

Services Committee conducted an inquiry into the defense posture of 

the reserve components. In August of 1962, the subcommittee issued 

 

1

Department of Defense, Committee on Civilian Components, Reserve Forces for National 

Security (June 1948).

Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components 

Department of 

Defense Studies
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 46 GAO-14-71 Defense Management

its report, which criticized the Secretary’s plan for its negative effect 

on morale, and because it did not address issues related to reservecomponent recruiting, retention, and equipment. The report also noted 

opposition from Army and reserve-component advisory boards. The 

Secretary of Defense did not implement the proposed approach. The 

Secretary’s second plan proposed merging all of the Army’s Guard 

and Reserve units under the management of the National Guard at 

the federal level. Under this plan, the Army Reserve’s units would 

have been eliminated and Army Reservists would be organized, 

trained, and equipped as individuals and not as units. Like the 

Secretary’s first plan, this proposal was not implemented due to 

congressional opposition.2

• Commission on the National Guard and Reserves. While large 

numbers of reservists were being deployed to Afghanistan, Iraq, and 

elsewhere, the Ronald W. Reagan National Defense Authorization Act 

for Fiscal Year 2005 created a 13-member, independent Commission 

on the National Guard and Reserves.3

Congress chartered the 

commission to assess a variety of issues related to the reserve 

components of the U.S. military and to make recommendations on 

those issues. The commission’s stated mission was to ensure that the 

National Guard and reserves are organized, trained, equipped, 

compensated, and supported to best meet the needs of U.S. national 

security. The commission issued three reports between 2006 and 

2008 studying, among other things, the roles and missions of the 

National Guard and other reserve components.4

The commission’s 

third report focused on the organizational and structural changes 

required to support an operational reserve force.5

A former staff 

member for the commission stated that the commission studied the 

feasibility and advisability of merging the National Guard with the 

 

2

The Department of Defense Appropriations Act 1966 (Pub. L. No. 89–213, § 639) 

provided funds for each reserve component separately and prohibited the Secretary of 

Defense from transferring funds to implement a realignment or reorganization of the Army 

Reserve components in that fiscal year. 

3

Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005, Pub. L. No. 

108-375, § 513 (2004).

4

The commission’s other objective was to study the compensation and other benefits 

provided for members of the reserve components.

5

Commission on the National Guard and reserves, Final Report to Congress and the 

Secretary of Defense, Transforming the National Guard and reserves into a 21st-Century 

Operational Force (Jan. 31, 2008). 
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 47 GAO-14-71 Defense Management

Army Reserve and the Air Force Reserve, but it ultimately concluded 

that doing so would not better enable the reserve component to 

execute its missions, and the process would be extremely difficult—

both politically and logistically—as well as costly to implement. The 

commission ultimately focused its report on (1) changes that could be 

made to remove cultural barriers that hamper the effective use of the 

reserve components, (2) changes to the categories used to manage 

the reserve components, (3) changes to the Office of the Secretary of 

Defense, and (4) changes within the reserve components and their 

headquarters. The commission made several recommendations 

across these areas; however, it did not recommend significant 

changes to the structure.

Previous studies of government reorganization and other types of 

mergers and transformations have found such endeavors to be complex 

and challenging, particularly during periods of government downsizing 

and budgetary pressures, and they can involve significant up-front costs.6

For instance, our review assessing the potential move of the Forest 

Service into the Department of the Interior found that, while there was the 

potential to improve federal land management through the consolidation, 

making the move would require careful consideration of a number of 

cultural, organizational, and legal factors and related transition costs, 

which could lead to unintended consequences if the merger were to take 

place.7

 The Congressional Budget Office examined the costs and benefits 

of merging components. Additionally, the 2005 Base Closure and 

Realignment Commission recommended reducing excess infrastructure 

by requiring National Guard and Reserve units to share facilities. 

• Congressional Budget Office. In a 1997 report presenting spending 

and revenue options for reducing the federal deficit, the 

Congressional Budget Office proposed merging the Army National 

Guard and the Army Reserve into a single entity that would retain the 

 

6

GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations, GAO-03-669 (Washington, D.C.: Feb. 11, 2009); GAO, 

Government Reorganizations: Issues and Principles, GAO/T-GGD/AIMD-95-166 

(Washington, D.C.: May 17, 1995); and National Commission on the Public Service, 

Government Reorganization: Strategies and Tools to Get it Done (August 2004).

7

GAO, Federal Land Management: Observations on a Possible Move of the Forest 

Service into the Department of the Interior, GAO-09-223 (Washington, D.C.: Feb. 11, 

2009).

Studies by 

Nondefense 

Organizations 
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 48 GAO-14-71 Defense Management

dual state and federal status of the current Army National Guard.8In 

its report, the Congressional Budget Office noted that laws and court 

rulings had removed many impediments to the President’s power to 

call up National Guard units, potentially making the federal reserves 

redundant. In addition, according to the Congressional Budget Office, 

many capabilities currently in the Army Reserve—such as helicopter 

transport units and medical units—might be useful to Governors 

during domestic crises. At the time, the Congressional Budget Office 

estimated that by eliminating duplicative administrative organizations 

and eliminating approximately 43,000 personnel from the Reserve, 

the Army could save over $500 million annually. It is unclear, 

however, whether similar cost savings could still be realized. 

• 2005 Base Closure and Realignment Commission. For the 2005 Base 

Realignment and Closure round, the Base Closure and Realignment 

Commission approved 44 recommendations that pertain to the 

reserve components which primarily directed the Army National Guard 

and the Army Reserve to create 125 Armed Forces Reserve Centers 

capable of accommodating both National Guard and Reserve units.9

According to DOD, these Armed Forces Reserve Centers should 

significantly reduce operating costs; however, we reported in 2013 

that DOD officials estimated the total cost to implement the 44 

recommendations was about $3 billion, and it is unclear whether the 

consolidations will result in cost savings over the long term.10

 

 

8

Congressional Budget Office, Reducing the Deficit: Spending And Revenue Options 

(March 1997). 

9

An Armed Forces Reserve Center is a joint-use facility that accommodates units from two 

or more reserve components. Its primary function is to provide administrative, training, and 

storage areas for the assigned military units.

10GAO, Military Bases: Opportunities Exist to Improve Future Base Realignment and 

Closure Rounds, GAO-13-149 (Washington, D.C.: Mar. 7, 2013). In 2007, we determined 

that more than 90 percent of these savings were associated with eliminating positions 

currently held by military personnel without corresponding end strength reductions. We 

have previously reported, and the Base Realignment and Closure Commission agreed, 

that military personnel position eliminations are not a true source of savings because DOD 

does not expect to reduce end strength correspondingly but rather intends to reassign or 

shift these personnel to vacant positions in other areas. GAO, Military Base Realignments 

and Closures: Plan Needed to Monitor Challenges for Completing More Than 100 Armed 

Forces Reserve Centers, GAO-07-1040 (Washington, D.C.: Sept. 13, 2007). 
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 49 GAO-14-71 Defense Management

In June 1993, following Hurricane Andrew, we noted that a large 

percentage of the type of DOD capabilities that are needed in disasters—

such as engineers, military police, supply and transportation personnel, 

and chaplains—reside in DOD’s reserve components, particularly in the 

Army Reserve.

11

At that time, and again in May 2006, in our report on the 

military’s response to Hurricane Katrina,12 we reported that the Reservists 

who responded to the disaster—all of whom were volunteers—constituted 

a relatively small portion of the response when compared to National 

Guard and active component forces because, while states were able to 

mobilize National Guard forces, no similar provisions existed to 

specifically mobilize Reserve forces for disaster response. 

Since Hurricane Katrina, two key steps have been taken to address 

DOD’s response to domestic incidents: (1) implementation of a command 

construct whereby a single military officer exercises authority over both 

federal military forces and state National Guard forces; and (2) 

implementation of new mobilization authorities.

• Dual-Status Commanders. The National Defense Authorization Act for 

Fiscal Year 2012 provided that a dual-status commander—military 

officers with authority over both federal military forces and state 

National Guard forces—should be the usual and customary command 

and control arrangement in situations when the armed forces and 

National Guard are employed simultaneously in support of civil 

authorities, including missions involving major disasters and 

emergencies. When an officer is appointed as a dual-status 

commander, he or she serves on federal active duty, sometimes 

referred to as Title 10 status, as well as on duty in or with the National 

Guard of a state, sometimes referred to as Title 32 status.13 Dual-

 

11GAO, Disaster Assistance: DOD’s Support for Hurricanes Andrew and Iniki and Typhoon 

Omar, GAO/NSIAD-93-180 (Washington, D.C.: June 18, 1993).

12GAO, Hurricane Katrina: Better Plans and Exercises Needed to Guide the Military’s 

Response to Catastrophic Natural Disasters, GAO-06-643 (Washington, D.C.: May 15, 

2006).

13Title 10 and Title 32 are titles of the United States Code that govern the operations of 

DOD and the National Guard respectively. When operating in Title 32 status, National 

Guard personnel, including dual-status commanders, are under the command and control 

of the state Governor. DOD and National Guard personnel operating in Title 10 status, 

including dual-status commanders, are under the command and control of the President 

and the Secretary of Defense.

Efforts to Improve 

Access to Federal 

Reserves and Federal 

Response to Domestic 

Incidents 
Appendix II: Summary of Efforts to Study 

Merger of the Army’s and Air Force’s Reserve 

Components

Page 50 GAO-14-71 Defense Management

status commanders exercise command on behalf of both the federal 

and the state chains of command and serve as the link between these 

two chains of command. According to DOD officials, dual-status 

commanders are intended to provide unity of effort, ensuring 

coordination of National Guard and federal military resources in 

response to domestic emergencies, natural disasters, or designated 

planned events. According to DOD officials, dual-status commanders 

have been used for select planned events since 2004 and helped 

coordinate response to Hurricane Sandy in 2012, wildfires in 

Colorado, and the bombing at the Boston Marathon in 2013. 

• Mobilization Authorities. DOD officials said that following Hurricane 

Katrina it was clear to them that the military needed to be empowered 

to respond more quickly to disasters. Ultimately, Congress approved 

new authorities in the National Defense Authorization Act for Fiscal 

Year 2012, one of which provided DOD with greater access to the 

federal reserve during domestic incidents.14 Section 12304a of Title 10 

of the United States Code states that when a Governor requests 

federal assistance in responding to a major disaster or emergency the 

Secretary of Defense may mobilize any individual or unit of the federal 

reserves involuntarily for up to 120 days to respond to the Governor’s 

request.15 The military services were using interim implementation 

guidance for these authorities at the time of our review and were 

waiting for DOD to finalize its guidance in September 2013. 

Additionally, DOD officials told us that Hurricane Sandy is the only 

domestic disaster thus far to use the new mobilization authorities 

under section 12304a. Since DOD is still developing its process for 

implementing these new authorities and has had limited experience 

using them it is too early to know whether they will better enable the 

states to access federal capabilities when responding to domestic 

disasters.

 

14Pub. L. No. 112-81, §§ 515 and 516 (2011) (codified at 10 U.S.C. §§ 12304a and 

12304b respectively).

1510 U.S.C. § 12304a.
Appendix III: Profile for the National Guard

Bureau, Army National Guard Directorate, and 

Air National Guard Readiness Center

Page 51 GAO-14-71 Defense Management

Appendix III: Profile for the National Guard 

Bureau, Army National Guard Directorate, 

and Air National Guard Readiness Center
Appendix III: Profile for the National Guard 

Bureau, Army National Guard Directorate, and 

Air National Guard Readiness Center

Page 52 GAO-14-71 Defense Management

Notes: Air National Guard officials said that growth in positions was driven largely by DOD’s insourcing effort. In April 2009, the Secretary of Defense announced his intention to reduce the 

department’s reliance on contractors and increase funding for new civilian authorizations. For 

example, Air National Guard officials said that DOD’s in-sourcing effort caused the Air National Guard 

Readiness Center to add 180 funded positions to the headquarters’ unit manning document; 

however, they could not determine the number of contractor positions that were eliminated as a result 

of this in-sourcing effort.

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time Guardsmen categories. 

In addition to having full-time civilian and Active Guard and Reserve personnel, the Army National 

Guard Directorate has a group of personnel that are categorized as “Active Duty for Operational 

Support”. Active Duty for Operational Support is an authorized voluntary tour of active duty that is 

performed at the request of an organizational or operational commander, or as a result of 

reimbursable funding, among other things. The purpose of this category is to provide the necessary 

skilled manpower assets to support existing or emerging requirements.

a

We included subordinate headquarters in the National Guard Bureau’s list of capabilities because 

these headquarters are under the management of the Chief of the National Guard Bureau.
Appendix IV: Profile for the National Guard 

State Joint Force Headquarters

Page 53 GAO-14-71 Defense Management

Appendix IV: Profile for the National Guard 

State Joint Force Headquarters 
Appendix IV: Profile for the National Guard 

State Joint Force Headquarters

Page 54 GAO-14-71 Defense Management

Notes: National Guard officials attributed the increase of over 250 funded positions at the state Joint 

Force headquarters to mission growth resulting from the establishment of civil support capabilities 

such as implementation of the Homeland Response Forces beginning in fiscal year 2011.

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time Guardsmen categories.

a

DOD Directive 5105.83, National Guard Joint Force Headquarters-State (NG-JFHQs-State) (Jan. 5, 

2011). 

b

Joint Force Headquarters-State evolved from predecessor Army National Guard and Air National 

Guard headquarters in each state that were established in the 1980s. In 2003, at the direction of the 

Chief of the National Guard Bureau, the predecessor headquarters were combined into the 54 Joint 

Force Headquarters-State each of which is commanded by an Adjutant General under the command 

of the Governor. This arrangement was formally recognized by DOD in 2011 with the issuance of 

DOD Instruction 5105.83.
Appendix V: Profile for the Office of the Chief 

of the Army Reserve and U.S. Army Reserve 

Command

Page 55 GAO-14-71 Defense Management

Appendix V: Profile for the Office of the Chief 

of the Army Reserve and U.S. Army Reserve 

Command 
Appendix V: Profile for the Office of the Chief 

of the Army Reserve and U.S. Army Reserve 

Command

Page 56 GAO-14-71 Defense Management

Notes: Army Reserve officials noted that changes in funded positions are partially driven by 

movement of positions between the Office of the Chief of the Army Reserve and U.S. Army Reserve 

Command. Additionally, officials said one significant driver of growth was the addition of new 

missions such as the addition of the Employer Partnership Office to the Office of the Chief of the 

Army Reserve. According to senior Army Reserve officials, growth in the Office of the Chief of the 

Army Reserve also is driven by the transfer of functions between staff elements. For example, 

officials said that in fiscal year 2012 the Army Reserve Installation Management Directorate was 

added to the Office of the Chief of the Army Reserve’s personnel requirements document as a result 

of an agreement between the Chief of the Army Reserve and the Commander for Army Installation 

Management Command. Officials said that 10 military and 33 civilian positions were added to the 

Office of the Chief of the Army Reserve in fiscal year 2013 as a result of this decision.

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time reservist categories.

a

Does not represent all capabilities managed by the U.S. Army Reserve Command. 
Appendix VI: Profile for the Army Reserve 

Regional Support Commands 

Page 57 GAO-14-71 Defense Management

Appendix VI: Profile for the Army Reserve 

Regional Support Commands 
Appendix VI: Profile for the Army Reserve 

Regional Support Commands

Page 58 GAO-14-71 Defense Management

Notes: Army Reserve officials noted that the Regional Support Commands were established in 2008 

and are relatively new organizations. Consequently, changes to the headquarters have been minimal 

because officials said they have needed to first establish a baseline to know what an appropriate 

number of personnel would be for these organizations.

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time Reservist categories.
Appendix VII: Profile for the U.S. Army Reserve 

Functional Commands

Page 59 GAO-14-71 Defense Management

Appendix VII: Profile for the U.S. Army 

Reserve Functional Commands 
Appendix VII: Profile for the U.S. Army Reserve 

Functional Commands

Page 60 GAO-14-71 Defense Management
Appendix VII: Profile for the U.S. Army Reserve 

Functional Commands

Page 61 GAO-14-71 Defense Management

Notes: Army Reserve officials told us that the functional commands’ growth was the result of, in 

certain cases, missions becoming more defined and absorbing other commands’ requirements, such 

as for the 79th Sustainment Support Command, 7th Civil Support Command, and 9th Mission 

Support Command. 

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time reservist categories.
Appendix VIII: Profile for Air Force Reserve 

Command and Headquarters, Air Force 

Reserve

Page 62 GAO-14-71 Defense Management

Appendix VIII: Profile for Air Force Reserve 

Command and Headquarters, Air Force 

Reserve
Appendix VIII: Profile for Air Force Reserve 

Command and Headquarters, Air Force 

Reserve

Page 63 GAO-14-71 Defense Management

Notes: Air Force Reserve officials told us that growth at Air Force Reserve Command resulted from 

the creation of its Force Generation Center, which was established to streamline force identification, 

mobilization, and deployment across the Air Force Reserve and improve the commander’s visibility 

into current and planned resource commitments. Officials told us that reduction in the size of 

Headquarters, Air Force Reserve, was driven by the commander having required the headquarters to 

identify positions for elimination as part of the Air Force’s efforts to improve efficiency. The 

headquarters is expected to have 96 funded positions in 2017.

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time reservist categories.
Appendix IX: Profile for the Air Force Reserve 

Numbered Air Forces

Page 64 GAO-14-71 Defense Management

Appendix IX: Profile for the Air Force 

Reserve Numbered Air Forces 
Appendix IX: Profile for the Air Force Reserve 

Numbered Air Forces

Page 65 GAO-14-71 Defense Management

Notes: Air Force officials said that the Numbered Air Forces reduced their manpower in part to create 

the Air Force Reserve Force Generation Center. Additionally, the Air Force Reserve altered the 

Numbered Air Forces’ responsibilities by making the wings responsible for ensuring they meet 

readiness requirements, a task that officials said was originally a Numbered Air Force responsibility. 

These data reflect funded civilian and military positions. Some DOD personnel, referred to as “dualstatus technicians,” are required, as a condition of employment, to be a drilling member of the 

National Guard or Reserves and thereby fill both a full-time civilian position and a part-time military 

position. Additionally, some DOD personnel, referred to as “Active Guard and Reserve,” occupy both 

a full-time military position as well as a part-time military position. Consequently, in our calculations, 

we included them in both the Active Guard and Reserve and the part-time reservist categories. 
Appendix X: Content for Interactive Figures in 

Background Section

Page 66 GAO-14-71 Defense Management

Component Headquarters type Missions and responsibilities

Army National 

Guard and Air 

National Guard

National Guard Bureau • A joint activity of the Department of Defense (DOD). 

• Participate with the Army and the Air Force staffs in the formulation, 

development, and coordination of all programs, policies, concepts, and 

plans pertaining to the National Guard; 

• Administer programs. 

• Assist in the organization, maintenance, and operation of National 

Guard units.

• Focal point at the strategic level for National Guard matters that are not 

under the authority of the military service. 

• Channel of communications between DOD and the states.

Joint Force 

Headquarters

Located in all 50 states, the District of Columbia, Puerto Rico, the Virgin 

Islands, and Guam.

Comprised of a Joint staff, Army staff, and Air staff.

The Adjutant General’s federal responsibilities include the following: 

Establishing temporary joint task force command elements ready to provide 

command and control for domestic operations. 

Accepting mutually agreed-upon federal liaison elements. 

Designating officers eligible to serve in dual-status and ensure that these 

officers facilitate unity of effort between state and federal military forces. 

Ensures homeland defense– and civil support–unique equipment is 

available for use should the unit owning the equipment deploy.

Advises the Governors and collaborates with DOD leadership.

Army National 

Guard

Army National Guard 

Directorate

Assists the Chief, National Guard Bureau, in carrying out the functions of 

the National Guard Bureau as they relate to the Army National Guard.

The Director, Army National Guard, under the supervision and control of the 

Chief, National Guard Bureau, performs those administrative and 

operational functions of the Chief pertaining to the Army National Guard and 

the Army National Guard of the United States.

Air National Guard Air National Guard

Readiness Center

Assists the Chief, National Guard Bureau, in carrying out the functions of 

the National Guard Bureau as they relate to the Air National Guard.

The Director, Air National Guard, under the supervision and control of the 

Chief, National Guard Bureau, performs those administrative and 

operational functions of the Chief pertaining to the Air National Guard and 

the Air National Guard of the United States.

U.S. Army 

Reserve

Office of the Chief of 

the Army Reserve

Serves as the Headquarters Army principal staff organization to organize 

and equip Army Reserve Forces. Provides direct support to the Chief of 

Staff of the Army in the execution of his function and Title X responsibilities, 

and commands the U.S. Army Reserve Command.

Responsible, subject to certain exceptions, for justification and execution of 

certain Army Reserve budgets, and is the director and functional manager 

of those appropriations; directing and managing the Army Reserve’s 

appropriations; managing the Army Reserve’s full-time support program; 

and submitting annual reports to the Secretary of Defense.

Appendix X: Content for Interactive Figures 

in Background Section
Appendix X: Content for Interactive Figures in 

Background Section

Page 67 GAO-14-71 Defense Management

U.S. Army Reserve 

Command

Provides command, control, and support to Army Reserve forces assigned.

Organizes, trains, and prepares Army Reserve units for mobilization and 

commitment to wartime theater of operations. Ensures wartime readiness of 

Army Reserve forces.

Regional Support 

Commands

Provides administrative and logistical support to all Army Reserve units and 

commands within their geographic area of responsibility. Manages all 

Operation and Maintenance, Personnel, Military Construction, and other 

appropriations for which requirements are justified as allocated by the U.S. 

Army Reserve Command and the Office of Chief, Army Reserve. 

Supervises all area maintenance support activities and equipment- concentration sites within its area of responsibility. Provides facility support 

to all Army Reserve units within its area of responsibility.

The Command Group of these commands is responsible for the following: 

Providing direction, guidance, and regional base-operations support to 

supported units within the region. The base-operations support is provided

in functional areas of personnel, logistics, force integration, programming 

and budgeting, finance and accounting, information management, 

emergency services, public works, historian, inspector general, religious, 

medical, legal, safety, public affairs, internal review, and management 

controls.

Managing and executing appropriations as authorized by U.S. Army 

Reserve Command and the Assistant Chief of Staff for Installation 

Management for base-operations support.

Implementing policies and intent of the U.S. Army Reserve Command 

commanding general.

Representing the Army Reserve before military and civilian organizations 

and agencies at various levels of command and government to include 

speaking engagements. 

Assisting with local community relations and representing the U.S. Army 

Reserve Command to foreign dignitaries on various occasions.

Functional Commands Maintain and provide training and, in certain cases, generate specific 

capabilities. 

Deploy subordinate units in support of federal missions.

U.S. Air Force 

Reserve

Headquarters, Air 

Force Reserve

Provides direct support to the Chief of Staff of the Air Force in the execution 

of his or her function and Title X responsibilities, and commands the U.S. 

Air Force Reserve Command.

Subject to certain exceptions, justify and execute the budgets for Air Force 

Reserve. Manages the full-time support program. Provides an annual report 

to the Secretary of Defense on the state of the Air Force Reserve and its 

ability to meet its missions.

Air Force Reserve 

Command

Provides citizen airmen to defend the United States and to protect its 

interests through air and space power.

Organizes, trains, and equips combat-ready forces. Directs operation of the 

three numbered Air Forces and provides all required major command–level 

support for all Air Force Reserve units and personnel. Maintains overall 

supervision of Air Force Reserve matters supporting Air Force war plans, 

programming documents, and mobilization actions. Retains administrative 

control over all Air Force Reserve units except for forces attached to the 

Commander, Air Force Forces.
Appendix X: Content for Interactive Figures in 

Background Section

Page 68 GAO-14-71 Defense Management

Numbered Air Forces Command assigned units. Ensure assigned units maintain operational 

readiness according to Air Force standards to include combat readiness, 

medical readiness, and inspection readiness. Provide assistance to, and 

operational readiness assessment of, assigned units through Operational 

Readiness Exercises and other discretionary events when warranted. 

Supervise and assist assigned units in planning for deployment and 

redeployment actions, major events, and contingencies. Advocate for 

assigned units. Implement plans, policies, and programs as developed and 

directed by Headquarters, Air Force Reserve Command.

Communicate with Lead Major Command on matters relating to training, 

inspection, operational mission coordination, and logistical support.

Assist units to implement command operational readiness and compliance 

processes. 

Manage resources across units.

Source: GAO analysis of DOD data.
Appendix XI: Comments from the Department 

of Defense

Page 69 GAO-14-71 Defense Management

Appendix XI: Comments from the 

Department of Defense
Appendix XI: Comments from the Department 

of Defense

Page 70 GAO-14-71 Defense Management
Appendix XI: Comments from the Department 

of Defense

Page 71 GAO-14-71 Defense Management
Appendix XI: Comments from the Department 

of Defense

Page 72 GAO-14-71 Defense Management
Appendix XI: Comments from the Department 

of Defense

Page 73 GAO-14-71 Defense Management
Appendix XII: GAO Contact and Staff 

Acknowledgments

Page 74 GAO-14-71 Defense Management

John H. Pendleton, (404) 679-1816 or PendletonJ@gao.gov

In addition to the contact named above, Suzanne K. Wren, Assistant 

Director; Timothy J. Carr; Joanna Chan; Susan C. Ditto; Michael J. 

Hanson; Tobin J. McMurdie; Anna Maria Ortiz; Michael D. Silver; Amie M. 

Steele; Karen N. Willems; Michael A. Willems; Alex Winograd; and Delia 

P. Zee made key contributions to this report.

Appendix XII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(351746)
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