NATIONAL 

LABORATORIES

DOE Needs to 

Improve Oversight of 

Work Performed for 

Non-DOE Entities

Report to Congressional Committees

October 2013

GAO-14-78

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-78, a report to 

congressional committees

October 2013

NATIONAL LABORATORIES

DOE Needs to Improve Oversight of Work Performed 

for Non-DOE Entities

Why GAO Did This Study

DOE’s 17 national laboratories house 

cutting-edge scientific facilities and 

equipment, ranging from highperformance computers to ultra-bright 

X-ray sources for investigating 

fundamental properties of materials.

DOE allows the capabilities of the 

laboratories to be made available to 

perform work for other federal 

agencies and nonfederal entities

through its WFO program, provided 

that the work does not hinder DOE’s 

mission or compete with the private 

sector, among other things. GAO was 

asked to review the WFO program. 

GAO examined (1) the amount and 

type of work conducted under the

program, (2) the extent to which DOE 

has ensured that WFO program

requirements are met, and (3) the 

extent to which program performance 

is measured against WFO program 

objectives. GAO reviewed DOE and 

laboratory data and documents, 

internal and external review reports, 

and interviewed officials from DOE and 

the laboratories.

What GAO Recommends

GAO recommends, among other 

things, that DOE take steps to ensure 

compliance with project approval 

requirements; require laboratories to 

establish written procedures for 

charging costs to projects; specify what 

the annual program reviews should 

include; produce annual reports on 

WFO activities; and establish

performance measures for the WFO 

program. DOE generally agreed with 

the report and its recommendations.

What GAO Found

In fiscal years 2008 through 2012, the Department of Energy (DOE) performed 

about $2 billion annually of Work for Others (WFO) projects, as measured by the 

costs incurred. Although the amount of WFO performed has remained relatively 

constant over the last 5 years overall, WFO as a percentage of the total work 

performed at the laboratories—measured in total laboratory costs incurred—has 

declined from 17 percent in fiscal year 2008 to about 13 percent in fiscal year 

2012. In fiscal year 2012, the WFO program included more than 6,500 projects.

About 88 percent of this work was for other federal agencies, with the majority of 

it performed for the Department of Defense. For example, one project for the 

Army applies a laboratory’s expertise in laser decontamination of surfaces to 

develop a system that will remove chemical agent residues from equipment. The 

remaining WFO work was sponsored by nonfederal entities, including state and 

local governments, universities, private industry, and foreign entities. 

DOE officials have not ensured that WFO program requirements are consistently 

met. For example, a DOE official is required to determine whether a proposed 

WFO project has met DOE requirements for accepting work before approving, or 

certifying, the work and this responsibility may not be delegated to the 

laboratories. However, DOE officials from site offices at 8 of the 17 laboratories 

reported that these determinations were made by the laboratories and that the 

DOE officials did not take steps to independently verify the determinations prior 

to approving the work. DOE also cannot ensure that the full costs of materials 

and services for WFO projects are charged to sponsors because 12 of 17 

laboratories have limited or no written procedures for developing WFO project 

budgets or charging costs to ongoing projects, two important steps for recovering 

the full costs of materials and services. A 2013 DOE Office of Inspector General 

report found that the costs of administering WFO projects at one laboratory were 

allocated to DOE projects, resulting in an estimated $400,000 in WFO project 

costs that were not reimbursed to the laboratory. DOE requires that its program 

offices annually review the WFO program at each of its laboratories. However, 

DOE requirements do not specify what the reviews should include, and DOE 

program offices varied in what they consider to be an annual review. DOE also 

requires the department’s Chief Financial Officer to report annually on the 

activities conducted under the WFO program, but DOE officials told GAO that 

they no longer produce the report because the requirement is outdated, choosing 

instead to fulfill data requests on a case-by-case basis. As a result, DOE does 

not have data that are comparable across laboratories or over time.

DOE has not measured the extent to which WFO program performance is 

measured against program objectives and has not established performance

measures to do so. Some DOE site offices and laboratories have taken steps to

evaluate the performance of the WFO program, but these steps are not 

consistent across the laboratories, do not incorporate key attributes of successful 

performance measures, and do not address the WFO program objectives. 

Recent internal and external reviews of the laboratories have recommended that 

DOE establish clear measures to evaluate laboratory WFO program performance 

against the WFO program objectives. DOE officials told GAO that they do not 

believe it is appropriate to develop one set of measures for all laboratories and 

that they do not plan to do so.

View GAO-14-78. For more information, 

contact David C. Trimble at (202) 512-3841 or 

trimbled@gao.gov
Page i GAO-14-78 DOE's Work for Others Program

Letter 1

Background 5

DOE Has Performed About $2 Billion of Work under the WFO 

Program Annually, but the Amount and Sponsors of Work Varied 

Among Laboratories 9

DOE Has Not Ensured That WFO Program Requirements Are 

Consistently Met 14

DOE Has Not Measured WFO Program Performance against 

Established Objectives 20

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 26

Appendix I Scope and Methodology 29

Appendix II List of the 17 Department of Energy (DOE) National 

Laboratories 32

Appendix III Department of Energy National Laboratory Work For Others 

Costs and Total Costs, as Measured in Costs Incurred, in 

Fiscal Year 2012 34

Appendix IV Comments from the Department of Energy 35

Appendix V GAO Contact and Staff Acknowledgments 39

Tables

Table 1: Amount of Work for Others (WFO) Performed and as a 

Percentage of Total Work Performed at the Department of 

Energy (DOE) Laboratories for Fiscal Year 2012 11

Table 2: Key Attributes of Successful Performance Measures 22

Contents
Page ii GAO-14-78 DOE's Work for Others Program

Figures

Figure 1: Location of the 17 Department of Energy (DOE) National 

Laboratories 7

Figure 2: Amount of Work for Others (WFO) Performed and Total 

Work at the 17 Department of Energy (DOE) National 

Laboratories, Fiscal Years 2008 through 2012 10

Figure 3: Sponsors of Work for Others (WFO) Performed at the 17 

Department of Energy (DOE) National Laboratories, 

Fiscal Year 2012 13

Abbreviations

CAS Cost Accounting Standards

CFO Office of the Chief Financial Officer

DHS Department of Homeland Security

DOD Department of Defense

DOE Department of Energy

GPRA Government Performance and Results Act

M&O management and operating

NAPA National Academy of Public Administration

NASA National Aeronautics and Space Administration

NNSA National Nuclear Security Agency

STARS Standard Accounting and Reporting System

TEPCO Tokyo Electric Power Company

WFO Work for Others

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-14-78 DOE's Work for Others Program

441 G St. N.W.

Washington, DC 20548

October 25, 2013

The Honorable Fred Upton

Chairman

The Honorable Henry Waxman

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable Timothy F. Murphy

Chairman

The Honorable Diana DeGette

Ranking Member

Subcommittee on Oversight and Investigations

Committee on Energy and Commerce

House of Representatives

Since the 1940s, the Department of Energy’s (DOE) national laboratories 

and specialized research facilities have played a central role in advancing 

research in physics and other basic and applied sciences. As one of the 

largest research agencies in the federal government, DOE spends billions 

of dollars each year on publicly funded research to support its diverse 

missions, including advancing scientific research and technology 

development, ensuring efficient and secure energy, and ensuring the 

safety and reliability of the nation’s nuclear weapons stockpile. In fiscal 

year 2012, from its appropriations DOE allocated nearly $11 billion to its 

17 national laboratories. These laboratories house cutting-edge scientific 

facilities and equipment, ranging from high-performance computers to 

ultra-bright X-ray sources for investigating fundamental properties of 

materials. The majority of the research and development funded by DOE 

is carried out under the department’s direction and overseen by scientists, 

engineers, and others employed at the 17 national laboratories, 16 of 

which are managed and operated by contractors under management and 

operating (M&O) contracts,1

 1

M&O contracts are agreements under which the government contracts for the operation, 

maintenance, or support, on its behalf, of a government-owned or -controlled research, 

development, special production, or testing establishment wholly or principally devoted to 

one or more of the major programs of the contracting federal agency. See Federal 

Acquisition Regulation, 48 C.F.R. § 17.601.

and 1 of which DOE directly manages and 
Page 2 GAO-14-78 DOE's Work for Others Program

operates.2

To allow non-DOE entities to benefit from the significant public investment 

in DOE’s laboratories and from the unique and highly specialized facilities 

and scientific and technical expertise at these laboratories, DOE operates 

the Work for Others (WFO) program. This program allows work to be 

performed at the laboratories for both federal agencies and nonfederal 

entities, provided that several requirements are met, including that WFO 

projects do not hinder DOE’s mission or compete with the private sector. 

Several laws provide the foundation for DOE’s WFO program. The 

Economy Act of 1932 allows federal agencies to obtain goods and 

services from other agencies as long as the work cannot be performed as 

conveniently or cheaply by the private sector and is in the best interests 

of the federal government.

The M&O contractors include universities, private companies, 

and nonprofit organizations.

3 The Atomic Energy Act of 1954 also provides 

DOE the authority to perform work for other federal agencies, as well as 

for state and local governments, private-sector organizations, academic 

institutions, and foreign entities, if private-sector facilities or laboratories 

are not adequate for the purpose.4 In addition, the Energy Reorganization 

Act of 1974 gives the Nuclear Regulatory Commission special access to 

DOE research and development capabilities.5

DOE has established program and financial management policies, 

requirements, and procedures for WFO that are contained in several DOE 

directives. DOE Order 481.1C establishes WFO management 

requirements, program roles and responsibilities, as well as defines the 

program’s objectives.

6

 2

At DOE’s National Energy Technology Laboratory, DOE employees—rather than 

employees of one of DOE’s contractors—carry out the laboratory’s activities.

These objectives include providing access to DOE 

laboratories—including National Nuclear Security Agency (NNSA) 

3

31 U.S.C. § 1535.

4

42 U.S.C. § 2053.

5

42 U.S.C.A. § 5801.

6

DOE, Work for Others (Non-Department of Energy Funded Work), DOE Order 481.1C 

(Washington, D.C.: Mar. 14, 2011).
Page 3 GAO-14-78 DOE's Work for Others Program

laboratories7

• be consistent with or complementary to the missions of DOE and the 

facility to which the work is to be assigned;

—to accomplish goals that may be otherwise unattainable by 

federal agencies and nonfederal entities and avoid duplication of effort at 

federal facilities, to provide access for non-DOE entities to DOE’s unique 

and highly specialized facilities when private-sector facilities are 

inadequate, to increase the research and development interaction 

between the laboratories and industry, and to maintain core 

competencies and enhance the science and technology base at the 

laboratories. DOE’s WFO order also establishes requirements for project 

selection, program reviews, and annual reporting on WFO activities 

performed by DOE. According to the order, WFO projects must meet the 

following criteria:

• avoid adverse impact to programs assigned to the facility;

• not place the facility in direct competition with the domestic private 

sector; and

• not create a detrimental future burden on DOE resources.

DOE Order 522.1 requires that the entity requesting the work reimburse 

the laboratory for the full cost of the work—including labor, materials, 

overhead, and other costs—plus a federal administrative charge, unless 

waived under departmental guidelines.8

In a time of uncertainty over future federal budgets and calls to reduce 

spending, DOE may have difficulty sustaining its current laboratory 

structure. Under budget pressure, DOE’s Office of Inspector General 

officials and others have observed that the laboratories could become 

dependent on reimbursements received under the WFO program to 

maintain the laboratories’ current facilities. In this context, you asked us to 

review the WFO program at DOE’s laboratories. Our objectives were to 

determine (1) the amount and type of work conducted under DOE’s WFO 

program, (2) the extent to which DOE has ensured that WFO program 

requirements are met, and (3) the extent to which DOE and the 

 7

Congress created NNSA as a semiautonomous agency within DOE in 1999 (Title 32 of 

the National Defense Authorization Act for Fiscal Year 2000, Pub. L. No.106-65, § 3201 et 

seq.). Although the DOE order related to WFO makes separate reference to NNSA and its 

facilities, including NNSA laboratories, for purposes of this report references to DOE or its 

program offices will include NNSA. 

8

DOE, Pricing of Departmental Materials and Services, DOE Order 522.1 (Washington, 

D.C.: Nov. 3, 2004).
Page 4 GAO-14-78 DOE's Work for Others Program

laboratories have measured WFO program performance against WFO 

program objectives.

To determine the amount and type, or sponsors, of the work conducted 

under DOE’s WFO program, we reviewed DOE data on the amount of 

work performed under the WFO program in total and by laboratory for 

fiscal years 2008 through 2012, as measured by costs incurred for WFO 

projects. We also obtained total costs incurred for each laboratory for 

fiscal years 2008 through 2012. To assess the reliability of these data, we 

interviewed DOE officials who oversee them for DOE’s Office of the Chief 

Financial Officer (CFO) to understand how the data are collected and 

reported. We also reviewed recent external audits of DOE’s financial 

reporting system and financial data. We determined that the data were 

sufficiently reliable to describe the amount of WFO activities performed at 

the laboratories. To determine the amount of work conducted by federal 

and nonfederal sponsors under the program, we gathered data on the 

costs of WFO activities performed for federal versus nonfederal sponsors. 

In addition, we interviewed DOE headquarters and site officials and 

officials for the 17 laboratories to gather examples of projects performed 

for federal and nonfederal sponsors. We visited 3 laboratories and 

contacted the remaining 14 laboratories by telephone. To determine the 

extent to which DOE has ensured that WFO program requirements are 

met, we reviewed federal regulations; DOE requirements; and DOE and 

laboratories’ policies and procedures governing the WFO program, 

including those for approval of WFO projects; cost recovery for WFO 

projects (i.e., development of project budgets and charging of costs); and 

reports of reviews of WFO programs. To determine the extent to which 

DOE and the laboratories have measured WFO project performance 

against program objectives, we reviewed DOE orders; performance 

requirements for WFO projects, if any, in DOE contracts with laboratories; 

DOE evaluations of laboratories’ performance; and laboratories’ strategic 

plans and procedures for establishing and executing WFO projects. We 

discussed laboratories’ strategies and goals for the WFO program and 

WFO program performance measurement with DOE headquarters and 

site officials and officials from each of the laboratories. See appendix I for 

a more detailed description of our scope and methodology.

We conducted this performance audit from August 2012 to October 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 
Page 5 GAO-14-78 DOE's Work for Others Program

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

DOE program offices manage the department’s 17 national laboratories 

and support the department’s diverse missions, as follows:

• The Office of Science oversees 10 national laboratories and, for fiscal 

year 2012, received appropriations of more than $4.3 billion to 

operate these laboratories. The Office of Science is the nation’s single 

largest funding source for basic research in the physical sciences, 

supporting research in energy sciences, advanced scientific 

computing, and other fields.

• NNSA oversees 3 national laboratories and, for fiscal year 2012, 

received appropriations of more than $4.6 billion to operate these 

laboratories. NNSA helps support understanding of the physics 

associated with the safety, security, and reliability of nuclear weapons 

and maintains core competencies in nuclear weapons science, 

technology, and engineering.

• The Office of Nuclear Energy oversees 1 laboratory and received 

appropriations for fiscal year 2012 totaling more than $1 billion to 

operate this laboratory. The primary mission of the Office of Nuclear 

Energy is to advance nuclear power as a resource capable of meeting 

the nation’s energy, environmental, and national security needs by 

resolving technical, cost, safety, proliferation resistance, and security 

barriers.

• The Office of Fossil Energy oversees 1 laboratory and received 

appropriations for fiscal year 2012 totaling more than $551 million to 

operate this laboratory. The Office of Fossil Energy’s primary mission 

is to ensure reliable fossil energy resources for clean, secure, and 

affordable energy while enhancing environmental protection.

• The Office of Energy Efficiency and Renewable Energy oversees 1 

laboratory and received appropriations for fiscal year 2012 totaling 

over $271 million to operate this laboratory. The Office of Energy 

Efficiency and Renewable Energy’s mission is to develop solutions for 

energy-saving homes, buildings, and manufacturing; sustainable 

transportation; and renewable electricity generation.

• The Office of Environmental Management oversees 1 laboratory and, 

for fiscal year 2012, received appropriations of about $7.6 million to 

operate this laboratory. The Office of Environmental Management is 

responsible for cleaning up hazardous wastes left from decades of 

nuclear weapons research and production.

Background
Page 6 GAO-14-78 DOE's Work for Others Program

See figure 1 for the locations of the laboratories managed by the various 

program offices. DOE also maintains individual site offices that provide 

federal oversight at 16 of the 17 laboratories.9 In addition, DOE’s field 

CFOs are responsible for overseeing financial activities at each location.10

 9

With the exception of DOE’s National Energy Technology Laboratory, which reports 

directly to DOE headquarters, each DOE laboratory is overseen by a single federal site 

office that reports to DOE headquarters. Similarly, each NNSA laboratory is overseen by a 

single federal office, called a field office, and each field office reports directly to NNSA 

headquarters. For the purposes of this report, we will use the term site office to indicate 

the federal office overseeing the laboratories.

For a complete list of DOE’s national laboratories and more information 

on each, see appendix II.

10A total of seven field CFOs oversee financial activities at the 17 national laboratories. 
Page 7 GAO-14-78 DOE's Work for Others Program

Figure 1: Location of the 17 Department of Energy (DOE) National Laboratories

DOE’s WFO program aims to provide benefits to organizations such as 

U.S. companies or academic institutions that have work performed at the 

laboratories and to the national laboratories as well. For example, 

according to a 2011 DOE report to Congress,11

 11DOE, U.S. Department of Energy Work for Others at the National Laboratories Report to 

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

the WFO program helps 
Page 8 GAO-14-78 DOE's Work for Others Program

to leverage DOE investment in the laboratories by further developing 

technical expertise for accomplishing critical tasks needed to fulfill DOE’s 

mission priorities. Furthermore, according to the DOE report, the WFO 

program can also help the national laboratories to retain highly trained 

scientists and engineers in support of DOE and national priorities by, for 

example, providing opportunities for them to stay engaged during times 

when mission critical work has slowed.

According to officials from DOE and laboratories and DOE 

documentation, a potential WFO project begins when an entity desiring to 

have work performed becomes aware of the capabilities available at a 

laboratory. Entities can become aware of these capabilities in a number 

of different ways, including as a result of networking by laboratory 

researchers and scientists, by responding to funding opportunity 

announcements of other federal agencies, or through information posted 

on the laboratories’ public websites. Once a potential project has been 

identified, representatives of the entity (i.e., the sponsor) and the 

laboratory begin to negotiate the work to be performed and the estimated 

costs. When the laboratory and sponsor have agreed to the terms of 

work, DOE site officials review the proposed WFO agreement. Finally, if 

the terms are approved by DOE and the sponsor has provided 

certification of funding or advance payment for the work, a DOE 

contracting officer certifies that the requirements have been met for the 

laboratory to conduct the work.

DOE’s WFO order establishes DOE policy and requirements for 

accepting, authorizing, and administering such work. This order applies to 

work for all non-DOE entities except the Department of Homeland 

Security (DHS), which is covered by a separate order, and is not 

considered to be WFO work.12

 12The Homeland Security Act of 2002, Pub. L. No. 107-296, Title III, § 309 (2002) 

authorizes DOE to accept and perform work at its laboratories in support of Homeland 

Security activities on an equal basis to other missions at the laboratories. Accordingly, 

work performed by DOE for DHS is covered by a separate order that differs from the WFO 

order in one key way: while work performed under the WFO order must not adversely 

impact DOE mission-related work assigned to the facility performing the WFO, work 

performed for DHS has no such limitation. In part because of this difference, DHS work is 

not considered to be WFO. See DOE, Reimbursable Work for the Department of 

Homeland Security, DOE Order 484.1 (Washington, D.C.: Mar. 14, 2011).

In addition, under the WFO order, each 

site office is responsible for establishing its own procedures and 

processes for the review and approval of work performed under WFO 
Page 9 GAO-14-78 DOE's Work for Others Program

agreements and for conducting periodic reviews of laboratory policies and 

procedures for negotiating and administering WFO projects. 

Requirements for establishing prices and charges for materials and 

services sold or provided to outside entities either directly or through the 

department’s M&O contracts are established through DOE’s pricing order, 

including for the WFO program.13

The total amount of work performed under the WFO program, as 

measured by costs incurred for WFO projects, has remained relatively 

constant over the last 5 fiscal years overall, but the amount of WFO work 

performed and the sponsors of the work varied widely among the 

laboratories.

In fiscal years 2008 through 2012, DOE performed about $2 billion of 

work annually under the WFO program, as measured by costs incurred 

(see fig. 2). Although the amount of work performed under the WFO 

program has remained relatively constant over the last 5 years, it has 

declined slightly relative to total work performed at the laboratories during 

this period. From fiscal year 2008 through fiscal year 2011, total work 

performed at the laboratories increased from $12.0 billion to $17.1 billion 

and fell to $16.3 billion in fiscal year 2012. As a result, the proportion of 

WFO performed as a percentage of total work performed declined from 

17 percent in fiscal year 2008 to about 13 percent in fiscal year 2012. In 

fiscal year 2012, more than 6,500 WFO projects were carried out at 

DOE’s laboratories.

 13DOE, Pricing of Departmental Materials and Services, DOE Order 522.1 (Washington, 

D.C.: Nov. 3, 2004).

DOE Has Performed 

About $2 Billion of 

Work under the WFO 

Program Annually, but 

the Amount and 

Sponsors of Work 

Varied Among 

Laboratories

Amount of Work 

Performed under the WFO 

Program Has Been About 

$2 Billion Annually
Page 10 GAO-14-78 DOE's Work for Others Program

Figure 2: Amount of Work for Others (WFO) Performed and Total Work at the 17 

Department of Energy (DOE) National Laboratories, Fiscal Years 2008 through 2012

Note: Because Work for Others (WFO) agreements can span multiple years, the amounts shown in 

the figure for WFO performed are the costs incurred by the laboratories for each of the fiscal years. 

The total laboratory costs incurred are the operating costs incurred for all laboratory activities. Totals 

may not add due to rounding.

During the period we reviewed, each of DOE’s 17 national laboratories 

performed some work on WFO projects, with some laboratories involved 

in significantly more WFO activities than others. In fiscal year 2012, the 

amount of work performed by the laboratories on WFO projects ranged 

from about $1.5 million at the National Energy Technology Laboratory to 

over $803 million at the Sandia National Laboratories. The proportion of 

WFO activities relative to all work at the laboratories also varied widely. 

Specifically, work performed on WFO projects as a percentage of total 

work performed at the laboratories ranged from less than 1 percent at the 

National Energy Technology Laboratory to nearly 33 percent at the 

Sandia National Laboratories (see table 1).

Amount of WFO 

Performed Varied by 

Laboratory
Page 11 GAO-14-78 DOE's Work for Others Program

Table 1: Amount of Work for Others (WFO) Performed and as a Percentage of Total 

Work Performed at the Department of Energy (DOE) Laboratories for Fiscal Year 

2012

Dollars in thousands

DOE National Laboratory

Amount of 

WFO 

performed 

Total work 

performed 

Percentage of 

total work 

performed

Sandia National Laboratories $803,313 $2,437,990 32.9%

Lawrence Livermore National Laboratory 242,975 1,628,530 14.9

Oak Ridge National Laboratory 206,770 1,532,200 13.5

Los Alamos National Laboratory 197,770 2,298,488 8.6

Pacific Northwest National Laboratory 182,399 877,366 20.8

Idaho National Laboratory 148,506 849,413 17.5

Lawrence Berkeley National Laboratory 118,320 804,545 14.7

Argonne National Laboratory 85,132 756,078 11.3

Brookhaven National Laboratory 50,823 726,971 7.0

National Renewable Energy Laboratory 33,756 508,932 6.6

Savannah River National Laboratory 25,563 1,080,017 2.4

Thomas Jefferson National Accelerator 

Facility

8,250 177,822 4.6

SLAC National Accelerator Laboratory 8,226 362,929 2.3

Fermi National Accelerator Laboratory 5,722 424,843 1.3

Ames Laboratory 4,106 36,751 11.2

Princeton Plasma Physics Laboratory 3,227 82,615 3.9

National Energy Technology Laboratory $1,498 $1,713,844 0.1%

Total $2,126,357 $16,299,334 13.0%

Source: GAO analysis of DOE data.

Note: The amount of Work for Others (WFO) performed and the total work performed reported in this 

table is the costs incurred by each laboratory for fiscal year 2012. Totals may not add due to 

rounding.

According to DOE officials, the variation in the amount of WFO performed 

is due in large part to differences in the core mission capabilities of each 

laboratory. For example, Sandia National Laboratories has extensive 

expertise in systems engineering, a capability that is heavily utilized by 

other federal agencies. According to the officials, other laboratories’

capabilities are less in demand and, therefore, less WFO work is 

performed at these laboratories.
Page 12 GAO-14-78 DOE's Work for Others Program

DOE’s laboratories carried out a variety of WFO projects for many 

different sponsors, but the majority of the work was for other federal 

agencies—in particular, the Department of Defense (DOD). Of the $2.1 

billion in work performed on WFO projects in fiscal year 2012, over $1.8 

billion, or about 88 percent, was for other federal agencies, with DOD 

sponsoring about $1.5 billion, or 71 percent of the work performed (see 

fig. 3). The majority of the work performed under the program for DOD for 

fiscal year 2012 was carried out at six national laboratories—Idaho, 

Lawrence Livermore, Los Alamos, Oak Ridge, Pacific Northwest, and 

Sandia. The type of work sponsored by DOD included a variety of 

projects. For example, Pacific Northwest National Laboratory has 

developed a software technology for the Air Force that performs, among 

other things, automatic topical analysis and organization of large 

collections of documents graphically. The laboratory is training the Air 

Force on applying the software to a diverse set of Air Force data to help 

analysts extract information to better identify potential uses for emerging 

technologies. In another example, the Idaho National Laboratory has 

applied its expertise in the area of laser decontamination of surfaces to 

develop and deploy a laser cleaning system for the Army. The objective 

of the project is to develop a system to, among other things, remove 

chemical agent residues from contaminated surfaces and equipment so 

that equipment can be reused, reduce personnel exposure risks, and 

reduce secondary waste streams.

Type, or Sponsors, of WFO 

Projects Performed Varied 

by Laboratory
Page 13 GAO-14-78 DOE's Work for Others Program

Figure 3: Sponsors of Work for Others (WFO) Performed at the 17 Department of 

Energy (DOE) National Laboratories, Fiscal Year 2012

Note: Totals may not add due to rounding.

Other federal agencies also sponsored a variety of WFO projects in fiscal 

year 2012, such as climate change and energy efficiency research 

conducted at the Lawrence Berkeley National Laboratory for the 

Environmental Protection Agency, and plutonium production research 

conducted at the Idaho National Laboratory for the National Aeronautics 

and Space Administration’s (NASA) space exploration program. For more 

information on the amount and type of work carried out at each 

laboratory, see appendix III.

Nonfederal entities sponsored $251.5 million, or 12 percent, of the WFO 

performed at the laboratories in fiscal year 2012. Sponsors and types of 

projects included the following:

• State and local governments. For example, officials in Sonoma 

County, California, entered into an agreement with the Lawrence 

Berkeley National Laboratory to conduct research on local rivers and 

dams to better understand the natural riverbed processes that occur 

as a function of dam and pumping operations, including sedimentation 

and evolution of biomass. These processes can lead to clogging of 

the riverbed, which in turn can limit the ability to pump water from 

beneath the riverbed as is needed for subsequent distribution as 
Page 14 GAO-14-78 DOE's Work for Others Program

drinking water in the county. Under the current phase of this WFO 

project, the laboratory is using its hydrological, geochemical, and 

biological tools and expertise to quantify the riverbed clogging 

mechanisms and to represent them in a computer model.

• Colleges and universities. For example, researchers at the University 

of Chicago studied the structures of proteins and, in particular, how 

proteins in lung cancer patients are affected by certain drugs. These 

researchers set up a WFO agreement with Argonne National 

Laboratory, under which the laboratory drew upon its extensive 

protein sequence database and its research capabilities to assist the 

university in analyzing, modeling, detecting, and characterizing 

proteins in lung cells. Under this agreement, Argonne National 

Laboratory also updated and maintained a database of protein 

structures that will be accessible to the broad biology community.

• Private industry. For example, GE Global Research, a private 

research laboratory, has entered into a WFO agreement with 

Lawrence Livermore National Laboratory to help refine wind prediction 

and control capabilities at wind farms. Under this agreement, the 

laboratory is evaluating high-resolution wind farm modeling tools in 

natural terrain using high-performance computers to run wind 

simulation and forecasting models.

• Foreign entities. For example, following the events at the Fukushima 

Daiichi Nuclear Power Station resulting from the earthquake and 

tsunami in March 2011, Tokyo Electric Power Company (TEPCO) 

entered into a WFO agreement with the Savannah River National 

Laboratory and the Pacific Northwest National Laboratory. The 

laboratories were to evaluate and define the scope of work for TEPCO 

to accomplish a number of tasks including the prevention of 

underground water contamination and the treatment and disposal of 

nuclear waste. The laboratories each drew upon their expertise in 

these areas to develop a schedule for how the work could proceed 

and to identify the necessary equipment, materials, facilities, 

personnel, and the costs to perform the work.

DOE has not ensured that WFO program requirements are consistently 

met. Specifically, DOE has not ensured compliance with requirements for 

the approval of WFO projects, cost recovery, program reviews, and 

annual reporting.

DOE Has Not Ensured 

That WFO Program 

Requirements Are 

Consistently Met
Page 15 GAO-14-78 DOE's Work for Others Program

According to DOE’s WFO order, WFO projects must meet specific DOE 

requirements, including being consistent with or complementary to DOE’s 

missions and those of the laboratories, not hindering those missions, and 

not placing the laboratories in direct competition with the domestic private 

sector. A DOE contracting officer or other authorized DOE designee is 

required to determine whether a proposed WFO project has met all of 

these requirements before approving or certifying the work. These 

determinations may not be delegated to the laboratories. However, DOE 

officials from site offices at 8 of the 17 laboratories told us that the 

laboratories provide written justification in the WFO package to support, 

or determine, that some or all of the requirements are met and that the 

DOE officials have often accepted the laboratories’ determinations 

without taking steps to independently verify them. DOE officials cited 

various reasons for relying on the laboratories to make the 

determinations. For example, an official from one site office told us that 

he relies on the laboratory’s determination that WFO projects are 

consistent with the mission. He explained that he does not believe that 

the laboratory would accept work that would be inconsistent with its 

mission. Similarly, an official at another DOE site office explained that she 

relies on the laboratory’s determination that the work cannot be 

performed by the private sector because she believes the laboratory staff 

are better informed about the capabilities available in the private sector. 

By relying on the laboratories’ determinations without taking steps to 

independently verify the information, DOE does not have assurances that 

the WFO projects selected meet DOE’s requirements. The DOE Office of 

Inspector General has identified the WFO program as a priority area and 

is reviewing laboratories with major WFO programs to determine whether 

they meet internal control and compliance requirements established by 

DOE.

DOE’s pricing order requires that the department charges for the full cost 

of materials and services provided to external organizations, including the 

amounts charged for work under the WFO program. DOE has not 

ensured, however, that all laboratories have formal, written procedures for 

developing WFO project budgets or charging costs to ongoing projects, 

two important steps for recovering the full costs of materials and services 

DOE Has Relied on 

Laboratories’

Determinations That WFO 

Projects Meet 

Requirements for Approval

DOE Has Not Ensured 

That Cost Recovery 

Procedures for WFO 

Projects Are in Place
Page 16 GAO-14-78 DOE's Work for Others Program

provided.14

In addition, DOE field CFOs do not always review costs charged to WFO 

projects in accordance with DOE’s pricing order, which requires that 

DOE’s field CFOs conduct biennial reviews of the pricing of materials and 

services and other costs charged to WFO projects at the laboratories. 

Under the pricing order, the reviews are required to include steps to 

ensure that (1) prices charged conform to the requirements of OMB 

Circular A-25 and departmental pricing policy or other legislative 

authority, as applicable; (2) adequate documentation exists for prices 

established for materials and services; and (3) exceptions to the full cost 

recovery requirements were limited to those authorized in the order. The 

reviews are intended to provide assurance to the department’s CFO that 

the full cost of the work, including all applicable direct and indirect costs, 

Specifically, five laboratories have detailed, written 

procedures for developing WFO project budgets and charging costs to 

projects that include, among other things, detailed instructions on the 

types of costs to include in a WFO project budget and specific instructions 

for calculating the costs and for ensuring that the costs of the work are 

charged to the sponsor. However, while the remaining laboratories did 

provide a description of their WFO budget development and cost charging 

processes, five of these laboratories had limited written procedures or 

tools in place for these processes. For example, one laboratory had a 

template that could be used to prepare a WFO budget but did not have 

detailed, written requirements or procedures for using this tool. The 

remaining seven laboratories did not provide any formal, written 

procedures to guide the development of WFO project budgets or the 

charging of costs. Without detailed, written guidance, DOE may not be 

able to ensure that its cost recovery requirements are consistently met.

 14DOE laboratory contractors are required by 48 C.F.R. 9903.202 to develop Cost 

Accounting Standards (CAS) disclosure statements. These statements describe 

contractors’ cost accounting practices and procedures and are reviewed and approved by 

DOE officials. DOE officials told us that these CAS disclosure statements serve as written 

procedures used for cost recovery and assignment of costs to ongoing projects, but we 

found that five of the laboratories also developed detailed, written procedures for staff to 

use when developing WFO project budgets and charging costs to projects.
Page 17 GAO-14-78 DOE's Work for Others Program

is charged to the sponsor of each WFO project.15 We requested DOE’s 

most recent biennial review reports of WFO project pricing for each of the 

17 laboratories. Reviews for 16 of the 17 laboratories were provided.16

These reviews were conducted by the seven field CFOs that oversee the 

laboratories and covered fiscal years 2010 and 2011.17

 15DOE requires advance payment before beginning work on a WFO project. Specifically, 

under DOE requirements, WFO projects for federal sponsors may not begin until a valid 

reimbursable agreement has been executed, and certification of funding has been 

completed. Under DOE’s financial management policy, sponsors of nonfederal WFO 

projects must provide a 60-day cash advance of funds before work can begin (DOE, 

“Reimbursable Work, Revenues, and Other Collections,” chap. 13 in DOE Financial 

Management Accounting Handbook).

We found that 6 of 

the 16 reviews did not include steps to ensure that prices for WFO 

projects conformed to DOE requirements. For example, in order to ensure 

that adequate documentation exists for prices established for materials 

and services charged to sponsors of WFO projects, reviewers need to 

examine pricing documentation for a sample of WFO projects. Reports for 

6 reviews indicated that, for a sample of WFO projects, pricing 

documentation for overhead and administrative costs was examined, but 

the reports did not provide evidence that documentation to support direct 

costs—such as labor and materials—was examined. Furthermore, one 

biennial pricing review was conducted by the laboratory instead of by the 

DOE field CFO, as required, and no details on the review steps were 

provided in the report. Reports for 9 of the 16 reviews indicated that a 

sample of WFO projects was reviewed. Reviewing a sample of WFO 

projects can provide useful information, such as identifying errors in costs 

charged to those projects. For example, 2 of the reviews that included an 

examination of a sample of WFO project documentation identified errors 

in general and administrative costs charged to WFO projects that resulted 

in either undercharges or in overcharges to the sponsor. In the case of 

undercharges, DOE paid part of the sponsor’s cost of the WFO project. In 

the case of overcharges, the sponsor subsidized a portion of DOE’s 

mission work. The DOE Office of Inspector General has also identified 

16DOE’s National Renewable Energy Laboratory did not provide a biennial pricing review. 

Instead, they provided a letter from the Golden, Colorado field office (the DOE field office 

responsible for oversight of the laboratory) stating the Golden field office is in full 

compliance with biennial pricing review requirements because each WFO proposal 

request is reviewed by a budget analyst and the field CFO.

17Biennial pricing reviews cover a 2-year period. The biennial pricing reports that we 

reviewed were the most recent reviews conducted and covered the 2-year period of fiscal 

years 2010 and 2011.
Page 18 GAO-14-78 DOE's Work for Others Program

errors related to the charging of general and administrative costs to WFO 

projects in their audits of WFO programs at the laboratories. For example, 

a 2013 review at Lawrence Berkeley National Laboratory found that costs 

of administering WFO projects were allocated in part to other DOE 

projects, resulting in estimated $400,000 in project costs that the sponsor 

did not reimburse to the laboratory.18

DOE’s WFO order requires each DOE program office to annually review 

the WFO program at each of its laboratories to ensure compliance with 

WFO policies and procedures. The order does not specify what the 

reviews should include. As a result, the program offices varied in what 

they consider to be their annual review. For example, DOE Office of 

Science program officials explained that they believe their annual WFO 

planning efforts with the laboratories fulfill the program review 

requirements in the WFO order. Specifically, each of the Office of Science 

laboratories develops a plan that contains a section that summarizes the 

laboratory’s WFO portfolio and discusses the WFO strategy for the future. 

DOE Office of Science officials told us that, as part of this process, each 

federal site office manager provides a review of the laboratory’s ongoing 

WFO program operations and proposed WFO funding level that includes 

a statement about the adequacy of the laboratory’s management and 

oversight of WFO activities. However, these plans were primarily focused 

on planning for WFO project work to be performed in the future and were 

not reviews to ensure compliance with WFO policies and procedures. 

NNSA officials told us that they had performed annual reviews of their 

WFO program since 2008; however, in response to our request for 

information, they provided one briefing from 2012 that focused on 

improving the WFO agreement processing times.

Program officials also conducted reviews of WFO policies and procedures 

at 6 of the 16 site offices. However, officials from the Office of Science 

told us that these reviews were not conducted to satisfy the annual review 

requirement in the WFO order because they focused on the site offices’

WFO policies and procedures rather than laboratories’ policies and 

 18DOE, Office of Inspector General Office of Audits and Inspections, Fiscal Year 2011 

Audit of the Work for Others Program at the Lawrence Berkley National Laboratory

(Washington, D.C.: June 2013). DOE officials told us that they do not agree with the 

Inspector General’s finding because they believe that the cost allocation methodology 

used to allocate WFO administrative costs complies with CAS.

DOE Did Not Consistently 

Conduct Required Annual 

WFO Program Reviews
Page 19 GAO-14-78 DOE's Work for Others Program

procedures. Specifically, as of May 2013, Office of Science program 

officials conducted a total of six reviews—one at each of 6 site offices—

since 2008. These generally consisted of a review of WFO program policy 

and procedure documents at the site offices including flow charts, forms, 

and correspondence. Each of the six reviews identified areas of concern 

within the WFO programs. For example, one program office review 

reported that the laboratory was dependent on funds from a single WFO 

project to support a major DOE program. The review cautioned that if the 

WFO project was discontinued, it could create a detrimental financial 

burden on the laboratory in the future, which is not consistent with DOE’s 

requirement to avoid doing so. In addition, four of the reviews found 

deficiencies related to WFO program documentation or procedures. For

example, one review reported that a DOE site office WFO program 

procedural guide was out of date and did not reflect all relevant DOE 

policy requirements or current DOE site office operating procedures. 

Although the reviews were not conducted to satisfy the annual review 

requirement in the WFO order, the reviews appeared to include useful 

information about the WFO program that was not included in the annual 

laboratory planning processes, which were focused on future WFO 

efforts. No program office reviews were conducted at the other 10 site 

offices.

DOE’s WFO order also requires that the DOE headquarters CFO prepare 

an annual summary report of WFO activities performed at its laboratories. 

DOE headquarters officials told us they have not produced this report in 

the past several years because the requirement to produce it is an 

outdated requirement that was put into place to facilitate data collection 

before the implementation of DOE’s current financial system. The officials 

said that they plan to eliminate this requirement. They also said that they 

have made better use of their limited program resources by choosing to 

fulfill requests for WFO project data from Congress and others on a caseby-case basis. For example, in the Conference Report19 to accompany 

the Energy and Water Development and Related Agencies Appropriations 

Act of 2010,20

 19H.R. Conf. Rep. No. 111-278 at 101 (2009).

DOE was directed to submit an annual report on the status 

of its WFO activities. DOE officials provided the requested information on 

WFO activities; however, this information might have already been 

20Pub. L. No. 111-85, 123 Stat. 2845 (2009).

DOE Does Not Produce 

the Required Annual 

Summary Report on 

Project Activities
Page 20 GAO-14-78 DOE's Work for Others Program

available if DOE had prepared the annual summary report as required by 

the WFO order. In addition, other DOE programs regularly need and 

collect WFO project data that could be provided by the annual summary 

report if it had been prepared in accordance with the order. For example, 

DOE’s technology transfer coordinator has been collecting data on 

nonfederal WFO project activities from each of the laboratories since 

2001 for inclusion in the Department of Commerce’s annual report on 

technology transfer.21 Choosing to report data on a case-by-case basis, 

rather than in an annual report, may make it difficult for those providing 

oversight and for some users of the data. This is because the data are not 

readily available, requiring DOE to generate it, which is time-consuming 

and, because depending on how the data are generated, they may not be 

comparable across laboratories or over time.

DOE has not measured the extent to which WFO program objectives are 

being met, even though DOE site offices are required under the WFO 

order to measure their laboratories’ WFO program performance. Some 

DOE site offices and laboratories have taken steps to evaluate WFO 

program processes, but these steps are not consistent across the 

laboratories, generally do not address the program objectives in the WFO 

order, and do not incorporate key attributes of successful performance 

measures.

DOE’s WFO order requires that DOE site offices establish performance 

goals and measures to assess field performance of the WFO program at 

the laboratories they oversee, including the effectiveness and impact of 

WFO program processes and improvements.22

 21The Energy Policy Act of 2005, Pub. L. No. 109-58, Title X, sec. 1001(a) (2005) sought 

to improve the process for transferring technologies by requiring the Secretary of Energy 

to, among other things, appoint a technology transfer coordinator for the department and 

to develop technology transfer goals and a plan for implementing them.

Moreover, in 2011, the 

President directed each agency with a federal laboratory to establish 

22In 1993, Congress enacted the Government Performance and Results Act (GPRA) to 

improve the efficiency and accountability of federal programs, among other purposes, and 

established a system for agencies to set goals for program performance and to measure 

results. Federal agencies are to comply with GPRA requirements, such as developing 

performance goals and measures, and we have previously reported that these 

requirements also can serve as leading practices for lower levels within federal agencies, 

such as individual divisions, programs, or initiatives. GPRA is a leading practice, but 

DOE’s WFO program is not subject to its requirements. 

DOE Has Not 

Measured WFO 

Program Performance 

against Established 

Objectives
Page 21 GAO-14-78 DOE's Work for Others Program

performance goals, measures, and evaluation methods related to 

technology transfer.23 Although the presidential memo does not 

specifically mention the WFO program, an objective of the program is to 

transfer technology originating at DOE facilities to industry for further 

development or commercialization. We found that, although some DOE 

site offices and laboratories have taken steps to evaluate the 

performance of the WFO program, these steps do not directly address the 

WFO program objectives. Moreover, DOE site offices’ and laboratories’

efforts to evaluate the WFO programs are focused on reviewing 

processes; including tracking the number of WFO agreements and 

improving timeliness of project selection and approval, rather than 

developing goals and measures for assessing performance against WFO 

program objectives.24

According to our discussions with officials from DOE headquarters and 

site offices and laboratory representatives, efforts to evaluate the 

performance of the WFO program at the laboratories include the 

following:

• Assessing customer satisfaction or other qualitative measures. 

Officials from 4 of the 17 laboratories told us that they have some 

mechanisms in place to collect qualitative information about WFO 

projects, such as customer satisfaction. This information is shared 

with DOE site officials. For example, officials at one laboratory send 

surveys to sponsors to assess customer satisfaction after the 

completion of WFO projects. Another laboratory reports to DOE on 

success stories about WFO projects once they are complete.

• Tracking the number of WFO agreements. Officials from 6 of the 17 

laboratories told us that they track the amount of or have set targets 

related to the number of WFO agreements in place.

• Evaluating WFO agreement processing times. Officials from 6 of the 

17 laboratories told us that they have goals to streamline the WFO 

agreement process, as measured by the time it takes from initiation to 

 23The White House, Presidential Memorandum-Accelerating Technology Transfer and 

Commercialization of Federal Research in Support of High-Growth Business (Oct. 28, 

2011).

24For example, in 2009, DOE commissioned a study of the time it takes to process WFO 

agreements and what best practices existed to streamline that process; and, in 2011, 

NNSA (which oversees three of DOE’s laboratories) commissioned a similar study of 

process time for WFOs and other interagency agreements at its laboratories.
Page 22 GAO-14-78 DOE's Work for Others Program

approval of a WFO agreement. In addition, in 2009 DOE 

commissioned a study of the time it takes to process WFO 

agreements across the laboratories and identified best practices for 

streamlining that process. Moreover, in 2011 NNSA commissioned a 

similar study of processing time for WFO and other interagency 

agreements at the 3 laboratories that it oversees.

We have previously reported on the nine attributes most often associated 

with successful performance measures,25

Table 2: Key Attributes of Successful Performance Measures

which are summarized in table 

2.

Attributes Definitions 

Potentially adverse 

consequences of not meeting 

attribute 

Linkage Measure is aligned with division 

and agencywide goals and 

mission and clearly 

communicated throughout the 

organization. 

Behaviors and incentives created 

by measures may not support 

achieving division or agencywide 

goals or mission. 

Clarity Measure is clearly stated and 

the name and definition are 

consistent with the methodology 

used to calculate it. 

Data may confuse or mislead 

users. 

Measurable 

target 

Measure has a numerical goal. Managers may not be able to 

determine whether performance is 

meeting expectations. 

Objectivity Measure is reasonably free from 

significant bias or manipulation. 

Performance assessments may be 

systematically over- or understated. 

Reliability Measure produces the same 

result under similar conditions. 

Reported performance data may be 

inconsistent and add uncertainty. 

Core program 

activities 

Measures cover the activities 

that an entity is expected to 

perform to support the intent of 

the program. 

Information available to managers 

and stakeholders in core program 

areas may be insufficient. 

Limited overlap Measure provides new 

information beyond that provided 

by other measures. 

Manager may have to sort through 

redundant, costly information that 

does not add value. 

 25GAO, Environmental Justice: EPA Needs to Take Additional Actions to Help Ensure 

Effective Implementation, GAO-12-77 (Washington, D.C.: Oct. 6, 2011); Tax 

Administration: IRS Needs to Further Refine Its Tax Filing Season Performance 

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002).
Page 23 GAO-14-78 DOE's Work for Others Program

Attributes Definitions 

Potentially adverse 

consequences of not meeting 

attribute 

Balance Taken together, measures 

ensure that an organization’s 

various priorities are covered. 

Measures may over emphasize 

some goals and skew incentives. 

Governmentwide 

priorities 

Each measure should cover a 

priority such as quality, 

timeliness, and cost of service. 

A program’s overall success is at 

risk if all priorities are not 

addressed. 

Source: GAO.

Our analysis shows, however, that the steps DOE and the laboratories 

have taken to evaluate performance did not include some of these key 

attributes. For example, while customer satisfaction surveys or other 

qualitative measures, such as success stories gathered by the 

laboratories, may provide some useful information and indicate areas for 

improvement, customer satisfaction is not included in the WFO order as a 

program goal. Furthermore, the performance measures do not directly 

link with the WFO program goals or objectives such as providing access 

to DOE laboratories to accomplish goals that may be otherwise 

unattainable by federal agencies and nonfederal entities. Without such 

linkage, DOE and decision makers may not have the needed information 

to track the program’s progress in meeting its objectives. Additionally, 

some WFO qualitative measures such as customer satisfaction may lack 

clarity and a measurable target, making it difficult to compare 

performance across laboratories. These types of qualitative measures 

also may not meet the key attribute of objectivity due to the potential for 

bias or other manipulation, depending on how the information is gathered 

and assessed. Other efforts to measure the performance of the 

program—specifically, the number of WFO agreements in place and 

WFO agreement processing time—both provide some helpful information 

but do not include all key attributes of successful performance measures. 

For example, tracking the number of agreements is clear and measurable 

and provides some information about the number of WFO projects at a 

laboratory. However, without linkage to the program’s objectives, 

measuring the number of agreements in place does not capture the 

program’s effectiveness in meeting the program’s objectives laid out in 

the WFO order, such as maintaining core competencies and enhancing

the science and technology base at the laboratories.
Page 24 GAO-14-78 DOE's Work for Others Program

As we have reported,26

Recent external and internal reviews of the DOE laboratories have 

recommended that clear performance measures are needed to measure 

laboratory WFO program performance against the WFO program 

objectives. In January 2013, the National Academy of Public 

Administration (NAPA) reported that while DOE officials at the 

laboratories have measures to assess DOE funded work; these measures 

do not always apply to non-DOE funded work such as work performed 

under the WFO program.

performance measures provide organizations with 

the ability to track the progress they are making toward their mission and 

objectives. We also have found that performance measures can create 

powerful incentives to influence organizational and individual behavior. 

Our analysis indicates that site office and laboratory performance 

measures lack these key attributes. In addition, DOE headquarters 

officials told us that there are no performance measures to assess the 

WFO program’s performance against WFO program objectives across all 

laboratories. The officials said that this is because the WFO program is 

decentralized, and laboratories are managed individually.

27

 26

NAPA also noted that DOE’s decentralized 

approach to managing the WFO program raised questions about DOE’s 

ability to oversee the program as a whole. NAPA recommended that DOE 

include measures for WFO work performed in its evaluations of laboratory 

performance. Similarly, in 2012, a working group set up by DOE 

headquarters to oversee efforts at the laboratories to share technology 

with non-DOE entities, reported concerns that measures did not exist to 

evaluate the impact and success of WFO work activities in achieving 

program objectives. DOE officials told us that, because WFO agreements 

are unique to each laboratory, they do not believe it is appropriate to 

develop one set of measures for all laboratories and that they have no 

plans to do so. However, without measures that apply to all laboratories, it 

is difficult to compare performance across laboratories in meeting overall 

program objectives.

GAO-12-77.

27NAPA, U.S. Department of Energy: Positioning DOE’s Labs for the Future: A Review of 

DOE’s Management and Oversight of the National Laboratories (Washington, D.C.: 

January 2013). NAPA was established in 1967 and chartered by Congress as an 

independent, nonpartisan organization to evaluate, analyze, and make recommendations 

on the nation’s most critical and complex public management, governance, policy and 

operational challenges.
Page 25 GAO-14-78 DOE's Work for Others Program

DOE laboratories’ highly specialized facilities, cutting-edge technologies, 

and highly trained scientists, technicians, and other staff represent a 

significant investment of public funds. DOE’s WFO program has allowed 

the department to share these capabilities with both other federal 

agencies and nonfederal entities. DOE has established WFO program 

requirements—including for project approval, cost recovery, program 

reporting, and program review—that together are intended to help DOE 

operate a successful WFO program and avoid adverse impacts on the 

laboratories’ missions and facilities and to avoid competition with the 

private sector. DOE falls short, however, in ensuring that these 

requirements are consistently met. For example, DOE has frequently 

relied on the laboratories to determine whether WFO projects selected 

meet the requirements of the WFO order, and DOE officials have 

accepted the laboratories’ determinations without taking steps to 

independently verify these determinations. Ensuring that the WFO 

projects selected meet DOE requirements is a governmental 

responsibility and, according to the WFO order, a DOE contracting officer 

or other authorized DOE designee is required to determine whether a 

proposed WFO project has met all of these requirements before 

approving the work. By relying instead on the laboratories to make these 

determinations, DOE cannot ensure that all WFO projects meet 

requirements. DOE may also not be able to ensure that the costs of WFO 

projects are recovered according to its pricing order because it has not 

required the laboratories to establish written procedures to guide 

development of project budgets or charging of costs to projects, important 

steps for determining and recovering the full costs of WFO projects’

materials and services. The department’s CFO also does not have 

assurance that the full costs of WFO projects are charged to the projects’

sponsors because field CFOs do not always conduct biennial pricing 

reviews according to requirements.

Furthermore, the WFO order does not specify what should be included in 

the annual WFO program reviews required by the order. Without clear 

and specific requirements, it may be difficult for DOE to identify WFO 

program deficiencies, if any. In addition, DOE officials told us that the 

requirement to prepare an annual summary report of WFO activities 

performed at its laboratories is outdated and has not been followed for 

several years, and that the department plans to eliminate this 

requirement. However, members of Congress have directed DOE to 

provide information on the status of WFO activities, and other DOE 

programs regularly need and collect WFO project data that would be 

available if DOE prepared the annual summary report. Choosing to report 

data on a case-by-case basis, rather than in an annual report, may make 

Conclusions
Page 26 GAO-14-78 DOE's Work for Others Program

it difficult for those providing oversight and some users of the data, and 

because the data are not readily available, DOE will need to generate 

them, which is time-consuming, and the data may not be comparable 

across laboratories or over time. Furthermore, while some site offices 

have made efforts to evaluate the performance of the WFO program, 

these efforts do not always incorporate key attributes of successful 

performance measures, such as being quantifiable or having a numerical 

goal. Moreover, these efforts generally do not directly address the 

objectives of the WFO program. Without better measures to evaluate 

program performance, DOE and decision makers will not have the 

needed information to track the program’s progress in meeting its 

objectives.

To improve DOE’s management and oversight of the WFO program, we 

recommend that the Secretary of Energy take the following six actions:

• Ensure compliance with the requirements in the WFO order for project 

approval.

• Require laboratories to establish and follow written procedures for 

developing WFO project budgets and for charging costs to WFO 

projects.

• Ensure compliance with the requirements for conducting biennial 

pricing reviews.

• Specify in the WFO order what the annual WFO program reviews 

should include.

• Ensure that annual summary reports of WFO activities are prepared 

so that data on those activities are readily available for those who 

need this information.

• Establish performance measures that incorporate key attributes of 

successful performance measures and that address the objectives of 

the WFO program.

We provided DOE with a draft of this report for its review and comment. In 

written comments, reproduced in appendix IV, DOE stated that it 

concurred with the recommendations in the report and provided 

information on planned actions to address each recommendation. We 

believe that many of the proposed actions, while good first steps, fall 

short of our recommendations, however, and may not fully address the 

issues we discussed in our report. 

For example, in response to the first three recommendations (i.e., ensure 

compliance with the requirements in the WFO order for project approval; 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 27 GAO-14-78 DOE's Work for Others Program

require laboratories to establish and follow written procedures for 

developing WFO project budgets and for charging costs to WFO projects; 

and ensure compliance with the requirements for conducting biennial 

pricing reviews), DOE stated that it will issue a policy flash, or notice, on 

the requirements of the WFO program. While reminding staff of the 

requirements of the WFO order would likely be beneficial, to improve its 

management and oversight of the WFO program, DOE also needs to take 

steps to ensure that these requirements are consistently being met by 

periodically monitoring the processes for project approval, full cost 

recovery of projects, and biennial pricing reviews. 

DOE also stated that it concurred in principle with the fourth 

recommendation to specify in the WFO order what the required annual 

program reviews should include. DOE added, however, that the current 

WFO order appropriately provides discretion to DOE program offices in 

determining the scope and extent of WFO program reviews. Again, DOE 

states that it will issue a policy flash reminding the program offices of the 

annual review requirement for the WFO program. DOE’s planned action, 

however, does not directly address our recommendation to update the 

WFO order with specific requirements for these reviews. Likewise, DOE 

stated that it concurred in principle with the fifth recommendation that it 

ensure that annual summary reports of WFO activities are prepared so 

that data on those activities are readily available for those who need this 

information. However, rather than preparing annual summary reports, 

DOE stated that the WFO order requires revision to reflect its current 

practice of providing current WFO program summary information. As we 

said in our report, choosing to report data on a case-by-case basis rather 

than in an annual report may make it difficult for those providing 

oversight, and for some users of the data, because the data are not 

readily available and DOE will need to generate them, which is timeconsuming, and they may not be comparable across laboratories or over 

time. Finally, in response to the sixth recommendation to establish 

performance measures that incorporate key attributes of successful 

performance measures and that address the objectives of the WFO 

program, DOE plans to issue a policy flash on the current requirements of 

the WFO program related to program assessments. In our report, we 

discussed that the WFO order, however, does not include specific 

requirements for program assessments and a policy flash that repeats the 

current requirements for program assessments would, therefore, not 

address the recommendation.

DOE also provided clarifying comments that we incorporated, as 

appropriate. In particular, DOE requested that we consider its laboratory 
Page 28 GAO-14-78 DOE's Work for Others Program

contractors’ Cost Accounting Standards (CAS) disclosure statements 

describing their cost accounting practices and procedures as written 

procedures for charging costs to ongoing projects. We have added 

information to our report about the CAS disclosure statements. While 

these statements describe how the laboratory plans to allocate costs, we 

do not agree that these disclosure statements constitute procedural 

guidance for developing project budgets and charging costs to projects. 

Moreover, as we point out in the report, we found that several laboratories 

have developed detailed written procedures for developing project 

budgets and charging costs to projects, which would be unnecessary if 

the disclosure statements were sufficient as guidance.

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 Secretary of Energy, 

the appropriate congressional committees, and other interested parties. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.

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

contact me at (202) 512-3841 or trimbled@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 key contributions to 

this report are listed in appendix V.

David C. Trimble

Director, Natural Resources and Environment
Appendix I: Scope and Methodology

Page 29 GAO-14-78 DOE's Work for Others Program

To determine the amount and type of work conducted at the laboratories 

under the Department of Energy’s (DOE) Work for Others (WFO) 

program, we requested and obtained DOE data on WFO costs from 

DOE’s Office of the Chief Financial Officer (CFO) for fiscal years 2008 

through 2012, including WFO program costs by sponsor and by 

laboratory, as measured in costs incurred. We also requested and 

obtained total costs incurred for each laboratory for these same fiscal 

years. We selected costs incurred as the measure of the amount of WFO 

projects performed for our purposes because WFO agreements can span 

multiple years and these costs are similar to the costs presented in 

reports by DOE and its Office of Inspector General. We used data for 

fiscal years 2008 through 2012 because our last report on DOE WFO 

projects reported data through fiscal year 2008. We interviewed DOE 

officials who oversee and collect these cost data for DOE’s Office of the 

CFO and determined that these data were obtained from DOE’s Standard 

Accounting and Reporting System (STARS) financial reporting system.

To assess the reliability of DOE’s WFO project cost data and total 

laboratory costs, we reviewed information about DOE’s STARS financial 

reporting system, as well as a recent external audit of the STARS system 

and DOE’s financial data. We also reviewed recent GAO assessments of 

the STARS system. No material weaknesses were reported. For data 

verification purposes, we obtained fiscal year 2012 cost data on WFO 

projects from each laboratory and compared that data with the fiscal year 

2012 cost data on WFO projects obtained from the DOE CFO. Although 

we identified some differences between the data, through discussions 

with the DOE CFO, we determined that those differences were the result 

of variances in the cost elements that were included in the information 

provided by each laboratory. Based on our assessment, we concluded 

that the data obtained from the DOE CFO were sufficiently reliable to 

describe the dollar amount and percentage of WFO projects performed at 

the laboratories. To determine the number of WFO projects that were 

active during fiscal year 2012, we used information from the fiscal year 

2012 WFO project lists provided by each laboratory, as the DOE CFO 

does not have the capability to identify individual nonfederal projects. To 

determine the type of WFO projects performed at DOE’s laboratories, we 

gathered data on the costs of WFO activities performed for federal versus 

nonfederal sponsors. We also reviewed the lists of WFO projects 

provided by each laboratory, we conducted interviews with DOE 

headquarters officials, and we conducted structured interviews with DOE 

site officials and officials for the 17 laboratories to gather more 

information about examples of WFO projects performed for one federal 

and one nonfederal WFO sponsor from each laboratory with activity 

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

Page 30 GAO-14-78 DOE's Work for Others Program

during fiscal year 2012. We judgmentally selected three laboratories to 

visit; including the National Nuclear Security Agency’s (NNSA) Sandia 

National Laboratory in Albuquerque, New Mexico, the DOE laboratory 

with the largest dollar amount of WFO project work conducted in fiscal 

year 2012. We also visited NNSA’s Los Alamos National Laboratory in 

Los Alamos, New Mexico, due to its size and proximity to Sandia National 

Laboratory; and Pacific Northwest National Laboratory—a larger Office of 

Science of laboratory located in Richland, Washington. We contacted 

officials at the remaining 14 laboratories by phone.

To determine the extent to which DOE ensures that WFO program 

requirements are met, we reviewed federal regulations, DOE 

requirements, and DOE and laboratories’ policies and procedures 

governing the WFO program, including for selection and approval of WFO 

projects and for cost recovery—establishing project budgets and charging 

costs to ongoing projects—for WFO projects. We discussed these 

policies and procedures and how they are carried out in practice in our 

structured interviews with DOE site office and laboratory officials 

responsible for the WFO program at each laboratory. We reviewed and 

analyzed biennial pricing reviews conducted by the DOE field CFOs 

responsible for oversight of each laboratory covering fiscal years 2010 

and 2011, the most recent data available. We discussed procedures for 

review and approval of WFO project proposals in our structured 

interviews with DOE site office and laboratory officials. We discussed 

DOE requirements for WFO project pricing, pricing reviews, and review 

results with officials from DOE’s CFO offices at headquarters and the 

seven DOE field CFOs that oversee the laboratories. We also reviewed 

DOE program office and site office review reports on laboratory WFO 

programs that were conducted from calendar years 2008 through 2012 to 

identify findings related to the WFO programs. For additional information 

applicable to all of our objectives, we reviewed external reports on the 

WFO program, including several reports issued from calendar years 2009 

through 2013 by the DOE Office of Inspector General, a December 2010 

report issued by the Department of Defense Office of Inspector General, 

a February 2012 report issued by the National Research Council, and a 

January 2013 report issued by the National Academy of Public 

Administration. We contacted officials from these external entities to 

discuss their reports.

To determine the extent to which DOE and the laboratories have 

measured WFO program performance against WFO program objectives, 

we reviewed DOE orders, performance requirements in DOE’s contracts 

with laboratory management and operating contractors, DOE evaluations 
Appendix I: Scope and Methodology

Page 31 GAO-14-78 DOE's Work for Others Program

of laboratories’ performance, and laboratories’ strategic plans. We also 

reviewed policies and procedures for establishing and for executing WFO 

projects at each laboratory. We discussed laboratories’ strategies and 

goals for their WFO programs and WFO program performance 

measurements with DOE headquarters officials, and in our structured 

interviews with DOE site office officials, and with officials from each of the 

laboratories.
Appendix II: List of the 17 Department of 

Energy (DOE) National Laboratories

Page 32 GAO-14-78 DOE's Work for Others Program

National Laboratory Location Research area DOE program office

Laboratory 

contractor

Ames Laboratory Ames, IA Rare earths and other critical 

materials, applied energy, fossil 

energy, and nonproliferation programs. 

Science Iowa State 

University

Argonne National Laboratory Argonne, IL Energy innovation, sustainable energy. Science U Chicago 

Argonne, LLC

Brookhaven National 

Laboratory

Upton, NY Physical, energy, environmental, and 

life sciences; energy technologies and 

national security. 

Science Brookhaven 

Science 

Associates, LLC

Fermi National Accelerator 

Laboratory

Batavia, IL Experimental and theoretical particle 

physics, astrophysics, and accelerator 

science. 

Science Fermi Research 

Alliance, LLC

Idaho National Laboratory Idaho Falls, ID Sustainable energy and national and 

homeland security. 

Nuclear Energy Battelle Energy 

Alliance

Lawrence Berkeley National 

Laboratory

Berkley, CA Particle and nuclear physics; physical, 

chemical, computational, biological, 

and environmental systems. 

Science University of 

California

Lawrence Livermore National 

Laboratory

Livermore, CA National defense, nuclear weapons 

stockpile stewardship, weapons of 

mass destruction, and nuclear 

nonproliferation. 

National Nuclear 

Security 

Administration

Lawrence 

Livermore 

National Security, 

LLC

Los Alamos National 

Laboratory

Los Alamos, NM National defense, nuclear weapons 

stockpile stewardship, weapons of 

mass destruction, and nuclear 

nonproliferation.

National Nuclear 

Security 

Administration

Los Alamos 

National Security, 

LLC

National Energy Technology 

Laboratory

Pittsburgh, PA Environmental stewardship, clean 

energy. 

Fossil Energy Government 

owned and 

operated by DOE

National Renewable Energy 

Laboratory

Golden, CO Renewable energy and energy 

efficiency research.

Energy Efficiency 

and Renewable 

Energy

Alliance for 

Sustainable 

Energy, LLC

Oak Ridge National Laboratory Oak Ridge, TN Neutron scattering, advanced 

materials, high-performance 

computing, and nuclear science and 

engineering.

Science UT-Battelle, LLC

Pacific Northwest National 

Laboratory 

Richland, WA Electricity management, sustainability, 

threat detection and reduction, in situ 

chemical imaging and analysis, 

simulation and analytics. 

Science Battelle Memorial 

Institute

Princeton Plasma Physics 

Laboratory

Princeton, NJ Plasma and fusion energy sciences. Science Princeton 

University

Appendix II: List of the 17 Department of 

Energy (DOE) National Laboratories
Appendix II: List of the 17 Department of 

Energy (DOE) National Laboratories

Page 33 GAO-14-78 DOE's Work for Others Program

National Laboratory Location Research area DOE program office

Laboratory 

contractor

Sandia National Laboratories Albuquerque, NM National defense, weapons of mass 

destruction, transportation, energy, 

telecommunications, and financial 

networks, and environmental 

stewardship.

National Nuclear 

Security 

Administration

Sandia 

Corporation

Savannah River National 

Laboratory

Aiken, SC Environmental stewardship, national 

and homeland security, clean energy.

Environmental 

Management

Savannah River 

Nuclear Solutions, 

LLC

SLAC National Accelerator 

Laboratory 

Menlo Park, CA Materials, chemical and energy 

science, structural biology, and particle 

physics and astrophysics. 

Science Stanford 

University

Thomas Jefferson National 

Accelerator Facility

Newport News, 

VA

Fundamental nature of confined states 

of quarks, gluons, and nucleons; 

superconducting radio-frequency 

technology. 

Science Jefferson Science 

Associates, LLC

Source: GAO analysis of DOE data.
Appendix III: Department of Energy National 

Laboratory Work for Others Costs and Total 

Costs, as Measured in Costs Incurred, in Fiscal 

Year 2012

Page 34 GAO-14-78 DOE's Work for Others Program

Dollars in thousands

WFO sponsor

Federal Nonfederal

National Laboratory

Total Work for 

Others (WFO) 

performed

WFO performed as a 

percentage of total

laboratory work 

performed Total

% of total 

WFO Total

% of total 

WFO

Sandia National Laboratories $803,313 32.9% $786,915 98.0% $16,398 2.0%

Lawrence Livermore National 

Laboratory

242,975 14.9 206,222 84.9 36,752 15.1

Oak Ridge National Laboratory 206,770 13.5 186,713 90.3 20,057 9.7

Los Alamos National Laboratory 197,770 8.6 169,847 85.9 27,923 14.1

Pacific Northwest National Laboratory 182,399 20.8 173,794 95.3 8,605 4.7

Idaho National Laboratory 148,506 17.5 144,729 97.5 3,777 2.5

Lawrence Berkeley National 

Laboratory

118,320 14.7 61,250 51.8 57,070 48.2

Argonne National Laboratory 85,132 11.3 50,017 58.8 35,115 41.2

Brookhaven National Laboratory 50,823 7.0 40,369 79.4 10,454 20.6

National Renewable Energy 

Laboratory

33,756 6.6 22,055 65.3 11,701 34.7

Savannah River National Laboratory 25,563 2.4 22,929 89.7 2,634 10.3

Thomas Jefferson National Accelerator 

Facility

8,250 4.6 5,160 62.5 3,090 37.5

SLAC National Accelerator Laboratory 8,226 2.3 2,263 27.5 5,963 72.5

Fermi National Accelerator Laboratory 5,722 1.3 95 1.7 5,627 98.3

Ames Laboratory 4,106 11.2 667 16.3 3,439 83.7

Princeton Plasma Physics Laboratory 3,227 3.9 790 24.5 2,437 75.5

National Energy Technology 

Laboratory

$1,498 0.1 $1,014 67.7% $485 32.3%

Total $2,126,357 13.0% $1,874,829 88.2% $251,527 11.8%

Source: GAO analysis of DOE data.

Appendix III: Department of Energy National 

Laboratory Work for Others Costs and Total 

Costs, as Measured in Costs Incurred, in 

Fiscal Year 2012
Appendix IV: Comments from the Department 

of Energy

Page 35 GAO-14-78 DOE's Work for Others Program

Appendix IV: Comments from the 

Department of Energy
Appendix IV: Comments from the Department 

of Energy

Page 36 GAO-14-78 DOE's Work for Others Program
Appendix IV: Comments from the Department 

of Energy

Page 37 GAO-14-78 DOE's Work for Others Program
Appendix IV: Comments from the Department 

of Energy

Page 38 GAO-14-78 DOE's Work for Others Program
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-14-78 DOE's Work for Others Program

David C. Trimble, (202) 512-3841 or trimbled@gao.gov

In addition to the individual named above, Dan Feehan and Janet Frisch, 

Assistant Directors; Joseph Cook; Elizabeth Curda; Paul Kinney; Jeff 

Larson; Cynthia Norris; Josie Ostrander; Kathy Pedalino; Tim Persons; 

Cheryl Peterson; Carl Ramirez; and Kiki Theodoropoulos made key 

contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361429)
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