GAO-10-58R Insourcing Guidelines 

United States Government Accountability Office

Washington, DC 20548 

October 6, 2009 

Congressional Committees 

Subject: Civilian Agencies’ Development and Implementation of Insourcing Guidelines 

Federal agencies rely on a multisector workforce composed of federal employees and 

contractor personnel to perform services as they carry out their missions. Determining 

whether to obtain services through insourcing with current or new federal employees, 

outsourcing with private sector contractors, or cosourcing with a combination of the two is 

an important economic and strategic decision critical to the federal government’s effective 

and efficient use of taxpayer dollars. The executive branch has encouraged federal agencies 

since the mid-1950s to obtain commercially available services from the private sector when 

outsourcing is cost-effective. In the last 5 fiscal years, civilian agencies have on average 

annually obligated about $100 billion to obtain a range of services from contractors. 

However, in March 2009, the President issued a memorandum on government contracting 

that, among other matters, expressed concern about the federal workforce as to whether 

agencies have become overreliant on contractors and have appropriately outsourced 

services. In particular, the President noted that the line between inherently governmental 

functions—those that must be performed by federal employees—and commercial activities 

that may be contracted for has been blurred. In the memorandum, the President directed the 

Office of Management and Budget (OMB) to lead a series of contracting-related efforts, 

including clarifying when outsourcing for services is and is not appropriate. 

Congress, also concerned with the federal workforce, in March 2009 enacted section 736 of 

the Omnibus Appropriations Act, 2009,1

 which requires federal agencies, with the exception 

of the Department of Defense (DOD), to devise and implement guidelines for insourcing new 

and contracted-out functions by mid-July 2009. The statute further requires that we report on 

the implementation of section 736. In response, we identified (1) the actions taken by OMB to 

assist affected agencies as they develop insourcing guidelines and (2) the status of selected 

civilian agencies’ efforts to develop and implement insourcing guidelines.

To address our objectives, we interviewed and reviewed information provided by officials 

from OMB and nine agencies on the status of their insourcing efforts pursuant to section 736. 

The nine agencies were selected because they collectively accounted for about 80 percent of 

the fiscal year 2008 funds obligated on service contracts by civilian agencies. 2

 In addition, we 

reviewed OMB’s guidance issued in July 2009 as to whether it is consistent with statutory 

requirements for executive agencies’ guidelines. We conducted our work from July 2009 to 

October 2009 in accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, appropriate 

 

1

Omnibus Appropriations Act, 2009, Pub. L. No. 111-8, Division D, Title VII, Section 736. 2

The nine agencies were the Departments of Energy, Health and Human Services, Homeland Security, Justice, 

State, Transportation, and Veterans Affairs, as well as the General Services Administration and the National 

Aeronautics and Space Administration (NASA). 
Page 2 GAO-10-58R Insourcing Guidelines

evidence to provide a reasonable basis for our findings based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our findings based on our 

audit objectives. 

Results in Brief 

Although section 736 does not specify a role for OMB in the development and implementation 

of the civilian agency insourcing guidelines, OMB has initiated a number of efforts in 

response to the President’s March 2009 memorandum on government contracting and section 

736. In July 2009, after coordinating with key agencies, OMB issued guidance to facilitate the 

management of the federal government’s multisector workforce through an approach that 

(1) provides an initial framework for planning and managing the multisector workforce that 

is built on strategic human-capital planning, (2) requires agencies to conduct a multisector 

human-capital analysis pilot, and (3) provides criteria on how agencies can use insourcing as 

a tool to manage their multisector workforces. Specifically, the insourcing criteria explain 

what actions agencies are to take to ensure that they are giving “consideration” and “special 

consideration” to the use of federal employees, as required under section 736. The OMB 

criteria specify that agencies generally should conduct cost analyses as part of the insourcing 

process but note that there may be circumstances where full cost analyses are unnecessary. 

How cost analyses are to be conducted and what factors are to be considered in the analyses 

are left to the agencies. OMB is considering what its future role regarding insourcing will be 

but currently does not plan to formally approve agency insourcing guidelines. It does, 

however, recognize that its insourcing criteria are likely to be the first step of an iterative 

process that may be revisited periodically due to the complexity of addressing the 

multisector workforce, possible changes resulting from its review of the term “inherently 

governmental,” and lessons learned from the multisector workforce pilots. 

None of the nine civilian agencies we visited met the statutory date for developing and 

implementing their insourcing guidelines and procedures. Although one agency issued 

preliminary guidelines, and two others had drafted but not issued their guidelines as of our 

review, most of the agencies’ efforts are still in their early stages. Agency officials told us that 

they delayed their efforts to develop or issue guidelines as they were waiting for OMB’s July 

guidance to ensure their guidelines were consistent, and some officials noted that they are 

waiting on additional direction from OMB, particularly as it relates to the definition of 

inherently governmental functions and when it is appropriate to outsource. Agency officials 

also identified a number of challenges relating to insourcing such as the complexity of the 

issue within the broader context of managing the multisector workforce, the time and level of 

effort involved in coordinating relevant agency functions, and continued uncertainty about 

the meaning of key terms, such as “consideration” and “special consideration.” Agency 

officials also made some suggestions, such as multiagency working groups to share lessons 

learned, that they believe may help them in their future insourcing efforts. OMB advised us 

that the working group on multi-sector workforce management will provide ongoing support 

to agencies and that OMB will continue to provide information to agencies in response to 

inquiries. 

We provided a draft of this correspondence to OMB for its review and comment. OMB 

provided technical comments that we incorporated into the final version as appropriate. 

Additionally, the nine agencies we met with were given the opportunity to provide comments 

on a fact sheet containing information from a draft of this correspondence specific to their 

agency. Seven of the agencies had no comments on the information in the fact sheets and two 

agencies provided technical comments that have been incorporated into this 

correspondence. 
Page 3 GAO-10-58R Insourcing Guidelines

 

Background 

Section 736 of the Omnibus Appropriations Act, 2009, requires the heads of executive 

agencies, except DOD, subject to the Federal Activities Inventory Reform (FAIR) Act of 19983

to devise and implement insourcing guidelines and procedures by July 9, 2009. The statute 

specifies that the guidelines and procedures are to ensure that “consideration” is given to 

using, on a regular basis, federal employees to perform new functions and functions that are 

performed by contractors and could be performed by federal employees. The statute further 

requires that the guidelines provide for “special consideration” to be given for using federal 

employees to perform any function that is 

• performed by a contractor and 

• has been performed by federal employees at any time during the previous 

10 years; 

• is a function closely associated with the performance of an inherently 

governmental function;4

• has been performed pursuant to a contract awarded on a noncompetitive basis; or 

• has been performed poorly, as determined by a contracting officer during the 

5 years preceding the date of such determination, because of excessive costs or 

inferior quality; or 

• a new requirement, with particular emphasis given to a new requirement that is 

similar to a function previously performed by federal employees or is a function 

closely associated with the performance of an inherently governmental function. 

In addition, the statute provides that the guidelines and procedures may not include any 

specific limitation on the number of functions or activities that may be converted to 

performance by federal employees and excludes certain functions from public-private 

competition until certain conditions are met. 

Section 736 does not apply to DOD. However, section 324 of the National Defense 

Authorization Act for Fiscal Year 20085

 provided essentially the same requirement for DOD to 

develop and implement insourcing guidelines. In April 2008, DOD issued its initial insourcing 

guidelines. Then on May 28, 2009, DOD issued implementing guidance for the insourcing of 

contracted services.6

 The May 2009 guidance explains that it is designed to assist DOD 

components as they develop and execute plans to decrease funding for contract support and 

increase funding for approximately 33,400 new civilian manpower authorizations. Among 

other matters, the guidance provides a process the components are to follow in prioritizing 

and reviewing contracted services for possible insourcing and the steps they are to follow 

once the decision is made to insource a function. 

In March 2009, the President issued a memorandum that identified a number of concerns 

related to government contracting, explicitly noting that government outsourcing for services 

raises special concerns.7

 The memorandum directed the Director of OMB, in collaboration 

3

The FAIR Act of 1998, as amended (31 U.S.C. § 501 note), requires agencies to submit annual workforce 

inventories of activities that are not inherently governmental functions. Executive agencies subject to the FAIR 

Act include executive departments, such as the Department of Homeland Security, and independent 

establishments, such as NASA. 

4

Section 736 provides that the term “inherently governmental functions” has the same meaning as that in subpart 

7.5 of the Federal Acquisition Regulation (FAR), which includes extensive lists of examples of functions 

considered to be and not be inherently governmental functions. Although section 736 does not specifically refer to 

it, FAR subpart 2.1 defines “inherently governmental function” to mean “as a matter of policy, a function that is so 

intimately related to the public interest as to mandate performance by government employees” and “includes 

activities that require either the exercise of discretion in applying government authority, or the making of value 

judgments in making decisions for the government.” 

5

National Defense Authorization Act for Fiscal Year 2008, Pub. L. No. 110-181 § 324. 6

DOD Memorandum, In-sourcing Contracting Services – Implementation Guidance (May 28, 2009). 7

Presidential Memorandum, Government Contracting, 74 Fed. Reg. 9,755 (Mar. 4, 2009). 
Page 4 GAO-10-58R Insourcing Guidelines

 

with heads of executive agencies and other officials,8 to develop and issue by July 1, 2009, 

governmentwide guidance to assist agencies in reviewing and creating processes for ongoing 

reviews of existing contracts to identify contracts that are wasteful, inefficient, or not 

otherwise likely to meet the agency’s needs and to formulate corrective actions. Noting that 

agencies must operate under clear rules, the President’s memorandum further directed that 

by September 30, 2009, OMB issue guidance to clarify when governmental outsourcing for 

services is and is not appropriate. 

OMB’s Insourcing Efforts and Criteria 

Although section 736 of the Omnibus Appropriations Act, 2009, did not specify any 

responsibilities for OMB, the office has taken actions to assist agencies in the development of 

their insourcing guidelines within the context of providing overall guidance on managing the 

multisector workforce. On July 29, 2009, OMB issued guidance in response to the President’s 

memorandum as well as section 736 that addresses achieving the best mix of contractors and 

federal employees and requires agencies to begin the process of developing and 

implementing policies, practices, and tools for managing the multisector workforce. 9

 The 

memorandum outlines a three-prong approach that (1) provides an initial framework for 

planning and managing the multisector workforce built on strategic human-capital planning, 

(2) as part of a planning pilot, requires each agency to conduct a multisector human-capital 

analysis of an organization, program, project, or activity where there are concerns about 

reliance on contractors and report on the pilot in April 2010, and (3) provides criteria on how 

agencies can use insourcing as a tool to manage their multisector workforce. Also, as part of 

this guidance, OMB discussed its efforts to review the definition of an inherently 

governmental function within the context of its efforts to clarify when governmental 

outsourcing for services is and is not appropriate.10

 

The insourcing criteria issued by OMB in July 2009 are intended to provide the civilian 

agencies with a framework for consistent and sound application of the statutory 

requirements as the agencies develop their insourcing guidelines. OMB developed the criteria 

in consultation with a working group composed of officials from some of the affected 

agencies. According to a senior OMB official, OMB established four agency working groups 

to address specific issues related to the President’s March 2009 memorandum.11 He explained 

that the working group responsible for addressing multisector workforce issues helped to 

develop the insourcing criteria since OMB considers insourcing one of many tools available 

to manage the multisector workforce. OMB also involved DOD in its efforts to develop 

criteria, in part to benefit from DOD’s experience in developing and implementing insourcing 

guidelines and to promote consistency across all agencies. 

OMB’s July 2009 criteria generally address the provisions of section 736 and provide a general 

framework for agencies to craft their own insourcing guidelines. The criteria consist of four 

sections that address different aspects of the statute and describe circumstances and factors 

agencies should consider when identifying opportunities for insourcing. See table 1 for a 

description of OMB’s insourcing criteria. 

8

Other agency heads include the Secretary of Defense, the Administrator of NASA, the Administrator of the 

General Services Administration, the Director of the Office of Personnel Management, and other heads of agencies 

the Director of OMB deems appropriate.

9

OMB Memorandum M-09-26, Managing the Multi-Sector Workforce (July 29, 2009). 10OMB’s multisector workforce memorandum notes that this review is consistent with section 321 of the Duncan 

Hunter National Defense Authorization Act for Fiscal Year 2009, Pub. L. No. 110-417 (2008), which requires OMB 

to review the definitions of “inherently governmental function” and develop a single consistent definition for the 

term. 

11These four working groups were set up to address (1) the definition of the term “inherently governmental,” 

(2) managing the multisector workforce, (3) contractor inventories and information, and (4) cost determination. 
Page 5 GAO-10-58R Insourcing Guidelines

Table 1: OMB’s Criteria for Insourcing under Section 736 

Key sections Agency responsibilities/actions and factors to consider 

General Management 

Responsibilities 

• review contractor performance on an ongoing basis and where a determination is 

made that contractors are performing inherently governmental responsibilities, 

insource such work on an accelerated basis 

• monitor internal human-capital capacity to minimize the risks associated with 

overreliance or improper reliance on contractors 

• ensure that there are sufficient resources to manage and oversee contractors 

General 

Consideration of 

Federal Employee 

Performance 

• augment existing management reviews when appropriate, to consider and 

evaluate opportunities to improve performance with the use of federal employees 

o evaluations should 

 consider opportunities for new and already-contracted work 

 generally include a cost analysis that addresses the full cost of 

performance and provides “like comparisons” of relevant costs to 

determine the most cost-effective source of support 

• situations when insourcing may be justified without a full cost analysis: 

o to establish or build internal capacity or maintain control of an agency’s 

mission and operations; 

o to perform a function that is closely associated with an inherently 

governmental function and in-house performance is necessary for an agency 

to maintain control of its mission and operations; or 

o to avoid the compromise of a critical agency or administration policy 

Special 

Consideration of 

Federal Employee 

Performance 

• go beyond existing agency management reviews and evaluate the specific 

function to be performed prior to the pursuit or nonpursuit of a contract action 

o key issues and actions for evaluations 

 if an agency determines that contractor performance causes the agency 

to lack sufficient internal expertise to maintain control of its mission and 

operations, then the agency is to take actions to obtain needed in-house 

capacity 

 if a preliminary analysis suggests that public-sector performance is more 

cost-effective and it is feasible to hire federal employees for a particular 

function, the agency is to initiate a more-detailed analysis of insourcing 

options 

 extent of analysis should generally be commensurate with the 

size and complexity of the function in question and its 

importance to the agency’s mission 

 cost analysis should address the full costs of government and 

private-sector performance 

 insourcing should not be used unless performance and risk 

considerations in favor of federal employee performance will 

clearly outweigh cost considerations 

Competition 

Restrictions 

• reiterates restriction in section 736 from conducting public-private competitions 

under OMB Circular A-76 as a prerequisite to federal performance of certain 

functions 

Source: OMB. 

According to a senior OMB official, OMB is considering what its future role regarding 

insourcing will be. For example, OMB currently does not plan to formally approve agency 

insourcing guidelines but will likely play an ongoing policy role in future insourcing efforts. 

He added that OMB could possibly be involved through the agency working groups, but its 

specific role and extent of involvement will depend on the evolving nature of the issue. OMB 

recognizes that its insourcing criteria are likely to be the first step of an iterative process and 

expects to periodically revisit the guidance due to the complexity of addressing the 

multisector workforce in an ever-changing environment and culture, the need for clarification 

on the meaning of terms such as “inherently governmental,” and the fact that OMB’s efforts, 

as well as those of the civilian agencies, are in early stages. OMB also anticipates gaining 

further insight about insourcing, including an assessment of data needs, from the pilot 

studies required under the broader OMB guidance for managing the multisector workforce. 
Page 6 GAO-10-58R Insourcing Guidelines

Status of Selected Agencies’ Insourcing Guidelines 

None of the nine civilian agencies we visited met the statutory requirement to develop and 

implement insourcing guidelines and procedures by July 9, 2009. To date, one agency—the 

Department of State—has issued what department officials characterized as “preliminary” 

guidelines in late July 2009 and plans to revise its guidelines as insourcing efforts evolve. 

Officials with the remaining eight agencies informed us that they have efforts underway to 

develop insourcing guidelines. However, these eight agencies are at various stages of 

developing their guidelines. For example, two agencies recently designated the offices 

responsible for leading the effort to develop the guidelines and are in the process of deciding 

what approach they will take. In contrast, two other agencies have drafted guidelines, with 

one waiting on management approval to issue them and the other planning to finalize its 

guidelines once OMB issues additional outsourcing guidance. Table 2 gives the status of the 

nine agencies’ efforts to develop and implement insourcing guidelines pursuant to section 

736. 

Table 2: Status of Nine Selected Agencies’ Development of Section 736 Guidelines 

Department/agency Status as of September 30, 2009 

Department of 

Energy 

Guidelines drafted but not issued. Expected issuance date October 16, 2009, 

but may change based on when OMB issues additional guidance, which was 

due September 30, 2009. 

General Services 

Administration 

Guidelines not drafted. Initial draft expected in October 2009. 

Department of 

Health and Human 

Services 

Guidelines not drafted. Plan to draft based on additional OMB guidance and 

experiences with pilot study. 

Department of 

Homeland Security 

Initial incremental guidelines drafted. Expected issuance upon management 

approval. 

Department of 

Justice 

Guidelines not drafted. Established a working group to draft insourcing 

guidelines and procedures. Draft due November 30 and will be finalized by 

January 30. 

NASA Drafting interim guidelines. Expected issuance at the end of October 2009. 

Department of 

State 

Preliminary guidance issued on multisector workforce requirements on July 

30, 2009. Detailed insourcing guidelines will be issued after pilot study is 

concluded in April 2010. 

Department of 

Transportation 

Guidelines not drafted. No timeline given. 

Department of 

Veterans Affairs 

Guidelines not drafted. Initial draft expected in early fiscal year 2010. 

Source: Cited agencies. 

Officials with the nine agencies cited a number of reasons as to why they did not meet the 

statutory deadline and have not issued final insourcing guidelines. These reasons included, 

but were not limited to the following: 

• Wanting to ensure their guidelines were consistent with OMB’s guidance, which was 

not issued until July 2009, which caused them to delay either finalizing or drafting 

their guidelines. 

• Waiting for additional OMB guidance and clarification regarding outsourcing and 

inherently governmental functions, which was to be provided by September 30, 2009. 

Several officials stated that they anticipate this guidance will have a significant effect 
Page 7 GAO-10-58R Insourcing Guidelines

on their development and implementation of insourcing guidelines. Similarly, OMB 

indicated when it provided the insourcing criteria in July 2009 that it expected to 

refine the criteria as it developed guidance on when outsourcing is and is not 

appropriate. 

• Intending to use the results, best practices, and lessons learned from the multisector 

workforce pilots to better inform their insourcing guidelines and procedures. For 

example, one agency plans to use its experience with the pilot as the basis for its final 

guidelines, while another plans to issue initial guidelines to be used during the pilot 

and then revise the guidelines as appropriate based on the experiences during the 

pilot. 

• Stressing that developing effective insourcing guidelines is complex and involves 

many agency functions, including human capital, acquisition, and finance and budget, 

all of which requires a great deal of coordination and takes time. They added their 

ability to focus on the development of the guidelines has been constrained by their 

capacity to deal with multiple management initiatives in addition to their regular core 

duties. 

Insourcing Challenges

Agency officials we met with noted that while the process of developing insourcing 

guidelines can be complicated, the broader issue of insourcing within the context of 

managing the multisector workforce is complex and involves many challenges. According to 

agency officials, the complex nature of insourcing and the many functional parts of an agency 

that are involved require managers to share responsibility and coordinate activities. The 

various functions that will be involved in an agency’s insourcing efforts—such as human 

capital, acquisition, finance and budget—must be identified, as well as the roles each will 

play. Officials also stated that once identified and given roles, the functions must then work 

together to identify and resolve matters such as the types of services and number of positions 

to be insourced; the hiring timeline for federal employees; training and security clearance 

needs; budget needs for additional resources; facilities and equipment needs; and oversight 

needs and capacity. According to agency officials, another challenge of insourcing is that it 

represents a major shift in the focus and culture of the multisector workforce. Established 

processes and procedures are geared toward outsourcing and shifting to insourcing and a 

“total workforce” approach—that considers both contractors and federal employees—will 

take time and requires flexibility to meet the needs of an agency within an ever-changing 

environment. In addition to these overarching challenges, agency officials identified the 

following issues that may affect their insourcing efforts: 

• Continued uncertainty as to what is meant by terms used in section 736 and OMB’s 

criteria such as “inherently governmental,” “mission-critical,” “core competency,” and 

“consideration” versus “special consideration” makes it difficult to address them in 

agency guidelines. However, officials we spoke with were not always in agreement 

regarding the need for and level of specificity for some terms, as some officials 

preferred having greater flexibility in interpreting and applying the terms. 

• Confusion as to when a cost analysis is needed and the appropriate procedures to 

conduct one makes it hard to define what procedures are necessary to sufficiently 

address the cost issue. OMB’s criteria do not specify the procedures for conducting a 

cost analysis or define what constitutes full cost of performance. While some agency 

officials thought there should be standard cost-analysis procedures, officials with at 

least one agency preferred more flexibility in determining how it should conduct cost 

analyses when making insourcing decisions. 

• Difficulty in gathering and analyzing certain types of service-contracting data needed 

for making insourcing decisions. For example, information on the type of service 

contracts and the number of contractor-equivalent personnel may not be readily 

available, even though some officials indicated that such information may be needed 

to review contracted-out services and make insourcing decisions. Although one 
agency had already issued a data call for specific service contracting information and 

was in the process of analyzing the data, others indicated that they are waiting for the 

pilot programs to help them identify what data best inform the insourcing decisionmaking process. 

• Limited budgets and resources may constrain insourcing efforts. For example, if after 

applying its guidelines, an agency determines that a function should be insourced and 

additional government employees need to be hired, the agency must ensure the funds 

are available to pay for them. There may also be a significant time lag between the 

decision to insource and the process for reprogramming funds in an effective and 

timely manner. 

While agency officials cited many challenges to insourcing, they also offered suggestions that 

they said may help them in their efforts to address these challenges and shift the culture. 

These suggestions included OMB convening ongoing, multiagency working groups to 

encourage agencies to work together by sharing lessons learned and providing each other 

examples of how to work through both the development and implementation phases of 

insourcing plans and having a point of contact within OMB for insourcing information. In 

response, OMB advised us that the standing working group on multi-sector workforce 

management will provide ongoing support as the current special working groups complete 

their tasks and that OMB is continuing to provide information to agencies to address their 

inquiries. 

_ _ _ _ _ 

We are sending copies of this report to the Director of OMB; the Secretaries of Energy, 

Health and Human Services, Homeland Security, State, Transportation, and Veterans Affairs; 

the Attorney General; the Administrators of the General Services Administration and NASA; 

and interested congressional committees. In addition, the report will be available at no 

charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please contact me at (202) 512-

5274. Contact points for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors to this report include Johana R. Ayers, 

Assistant Director, Marie Ahearn, Greg Campbell, Mary Jo Lewnard, Rae Ann Sapp, and 

Viraphonh Vongvanith.

John K. Needham 

Director 

Acquisition and Sourcing Management 

Page 8 GAO-10-58R Insourcing Guidelines
Page 9 GAO-10-58R Insourcing Guidelines

List of Committees 

The Honorable Daniel K. Inouye 

Chairman 

The Honorable Thad Cochran 

Vice Chairman 

Committee on Appropriations 

United States Senate 

The Honorable David R. Obey 

Chairman 

The Honorable Jerry Lewis 

Ranking Member 

Committee on Appropriations 

House of Representatives 

The Honorable Joseph I. Lieberman 

Chairman 

The Honorable Susan M. Collins 

Ranking Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Edolphus Towns 

Chairman 

The Honorable Darrell Issa 

Ranking Member 

Committee on Oversight and Government Reform 

House of Representatives 

(120845) 
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