ARLINGTON NATIONAL 

CEMETERY

Actions Needed to Ensure 

Lasting, Positive Changes in 

Contracting and 

Management 

Statement of Belva M. Martin

Director, Acquisition and Sourcing Management

and

Brian J. Lepore

Director, Defense Capabilities and Management

Testimony 

Before the Subcommittees on Military 

Personnel and Oversight and 

Investigations, Committee on Armed 

Services, House of Representatives

For Release on Delivery 

Expected at 11:30 a.m. EST

Friday, February 3, 2012

GAO-12-436T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-436T, a testimony 

before the Subcommittees on Military 

Personnel and Oversight and Investigations, 

Committee on Armed Services, House of 

Representatives 

February 3, 2012 

ARLINGTON NATIONAL CEMETERY 

Actions Needed to Ensure Lasting, Positive Changes 

in Contracting and Management

Why GAO Did This Study

Arlington National Cemetery (Arlington) 

is the final resting place for many of 

our nation’s military servicemembers, 

their family members, and others. In 

June 2010, the Army Inspector 

General identified problems at the 

cemetery, including deficiencies in 

contracting and management, burial 

errors, and a failure to notify next of kin 

of errors. In response, the Secretary of 

the Army issued guidance creating the 

position of the Executive Director of the 

Army National Cemeteries Program 

(ANCP) to manage Arlington and 

requiring changes to address the 

deficiencies and improve cemetery 

operations. In response to Public Law 

111-339, GAO assessed several 

areas, including (1) actions taken to 

improve contract management and 

oversight, (2) the Army’s efforts to 

address identified management 

deficiencies and provide information 

and assistance to families regarding 

efforts to detect and correct burial 

errors, and (3) factors affecting the

feasibility and advisability of 

transferring jurisdiction for the Army’s 

national cemeteries to the Department 

of Veterans Affairs (VA). The 

information in this testimony 

summarizes GAO’s recent reports on 

Arlington contracting (GAO-12-99) and 

management (GAO-12-105). These 

reports are based on, among other 

things, analyzing guidance, policies, 

plans, contract files, and other 

documentation from the Army, 

Arlington, and other organizations and 

interviews with Army and VA officials.

What GAO Recommends

In the reports, GAO made several 

recommendations to help Arlington 

sustain progress made to date.

What GAO Found

GAO identified 56 contracts and task orders that were active during fiscal year 

2010 and the first three quarters of fiscal year 2011 under which contracting 

offices obligated roughly $35.2 million on Arlington’s behalf. These contracts 

supported cemetery operations, construction and facility maintenance, and new 

efforts to enhance information-technology systems for the automation of burial 

operations. The Army has taken a number of steps since June 2010 at different 

levels to provide for more effective management and oversight of contracts, 

establishing new support relationships, formalizing policies and procedures, and 

increasing the use of dedicated contracting staff to manage and improve its 

acquisition processes. However, GAO found that ANCP does not maintain 

complete data on its contracts, responsibilities for contracting support are not yet 

fully defined, and dedicated contract staffing arrangements still need to be 

determined. The success of Arlington’s acquisition outcomes will depend on 

continued management focus from ANCP and its contracting partners to ensure 

sustained attention to contract management and institutionalize progress made 

to date. GAO made three recommendations to continue improvements in 

contract management. The Department of Defense (DOD) partially concurred 

and noted actions in progress to address these areas. 

The Army has taken positive steps and implemented improvements to address 

other management deficiencies and to provide information and assistance to 

families. It has implemented improvements across a broad range of areas at 

Arlington, including developing procedures for ensuring accountability over 

remains and improving its capability to respond to the public and to families’ 

inquiries. Nevertheless, the Army has remaining management challenges in 

several areas—managing information-technology investments, updating 

workforce plans, developing an organizational assessment program, coordinating 

with key partners, developing a strategic plan, and developing guidance for 

providing assistance to families. GAO made six recommendations to help 

address these areas. DOD concurred or partially concurred and has begun to 

take some corrective actions. 

A transfer of jurisdiction for the Army’s two national cemeteries to VA is feasible 

based on historical precedent for the national cemeteries and examples of other 

reorganization efforts in the federal government. However, several factors may 

affect the advisability of making such a change, including the potential costs and 

benefits, potential transition challenges, and the potential effect on Arlington’s 

unique characteristics. In addition, given that the Army has taken steps to 

address deficiencies at Arlington and has improved its management, it may be 

premature to move forward with a change in jurisdiction, particularly if other 

options for improvement exist that entail less disruption. GAO identified 

opportunities for enhancing collaboration between the Army and VA that could 

leverage their strengths and potentially lead to improvements at all national 

cemeteries. GAO recommended that the Army and VA develop a mechanism to 

formalize collaboration between these organizations. DOD and VA concurred 

with this recommendation.

View GAO-12-436T. For more information, 

contact Belva Martin at (202) 512-4841 or 

martinb@gao.gov or Brian Lepore at (202) 

512-4523 or leporeb@gao.gov. 
 

Page 1 GAO-12-436T 

Chairmen Wilson and Wittman, Ranking Members Davis and Cooper, and 

Members of the Subcommittees: 

We are pleased to be here today to discuss the Army’s progress in 

addressing contracting and management challenges identified at 

Arlington National Cemetery (Arlington), opportunities for collaboration 

between the Army and the Department of Veterans Affairs (VA), as well 

as steps remaining to ensure sound management of the cemetery going 

forward. Beginning in 2009, the Army’s management of Arlington came 

under intense scrutiny following the discovery of burial errors and the 

identification of serious contracting and other management deficiencies 

affecting cemetery operations. In June 2010, the Army Inspector General 

(Army IG) reported on numerous deficiencies and made more than 100 

recommendations for corrective action, which covered a span of issues, 

including cemetery policies and procedures, management and training, 

command structures, information assurance compliance, and 

contracting.1

 After the Army IG’s inspection findings were released, the 

Secretary of the Army assigned new leadership to Arlington, including the 

new position of Executive Director of the Army National Cemeteries 

Program (ANCP),2 and issued Army Directive 2010-04 requiring a 

number of changes to address the identified deficiencies and improve 

cemetery operations.3 In the time since these actions, the Army has taken 

positive steps to address critical areas and implement improvements, and 

we continue to be encouraged by these efforts. However, our work points 

to the need for further action to ensure that the positive changes made 

thus far are institutionalized and will prove lasting over the long term. 

Our statement today is based on two reports issued on December 15, 

2011, as required by Public Law 111-339.4

 

1

U.S. Army, Inspector General Agency, Special Inspection of Arlington National Cemetery 

Final Report (Washington, D.C.: June 2010).

The first discusses (1) the 

number, duration of, and dollar amount spent on current contracts used to 

support operations at Arlington and (2) the extent to which the Army has 

put processes and procedures in place to provide for the effective 

2

The Executive Director oversees Arlington National Cemetery in Virginia and the 

Soldiers’ and Airmen’s Home National Cemetery in Washington, D.C.

3

Army Directive 2010-04, Enhancing the Operations and Oversight of the Army National 

Cemeteries Program (June 10, 2010).

4

Pub. L. No. 111-339 (2010).

 
 

Page 2 GAO-12-436T 

management and oversight of contracts supporting Arlington.5 The 

second discusses (1) the Army’s efforts to address identified 

management deficiencies; (2) the Army’s process for providing 

information and assistance to families regarding efforts to detect and 

correct burial errors; and (3) factors that may affect the feasibility or 

advisability of transferring jurisdiction for the Army’s two national 

cemeteries to VA, as well as issues related to collaboration between 

these agencies.6

 

For these two reports we conducted work at Arlington and other offices 

and agencies within the Department of the Army, including the Military 

District of Washington, Joint Base Myer-Henderson Hall, the Army 

Contracting Command, the Mission and Installation Contracting 

Command (MICC), and the U.S. Army Corps of Engineers (USACE), 

among others. We also conducted work at VA and contacted veteran 

service organizations and private industry associations. We reviewed 

documents pertaining to previously identified deficiencies, including the 

Army IG’s 2010 inspection and investigation of Arlington, the results of 

two follow-up inspections conducted by the Army IG in 2011, and Army 

Directive 2010-04. We obtained information from knowledgeable officials 

about the steps taken to respond to the Army IG’s findings and to 

implement the Army’s directive. In addition, we analyzed data from 

contracting offices and other sources on contracts active during fiscal 

years 2010 and 2011 and above $100,000 and reviewed contract files; 

analyzed guidance, policies, plans, and other documentation from 

Arlington and other organizations; and interviewed agency officials to 

assess efforts to improve contract management. To identify factors that 

may affect the feasibility or advisability of transferring jurisdiction for the 

Army’s national cemeteries to VA, we reviewed our prior work on federal

government reorganization, reviewed the legislative history of the 

National Cemeteries Act of 1973,7

 

5

GAO, Arlington National Cemetery: Additional Actions Needed to Continue 

Improvements in Contract Management, 

and obtained pertinent documents and 

interviewed officials from the Army and VA, including the Secretary of the 

Army and VA’s Under Secretary for Memorial Affairs. We conducted this 

GAO-12-99 (Washington, D.C.: Dec. 15, 2011).

6

GAO, Arlington National Cemetery: Management Improvements Made, but a Strategy is 

Needed to Address Remaining Challenges, GAO-12-105 (Washington D.C.: Dec. 15, 

2011).

7

Pub. L. No. 93-43.
 

Page 3 GAO-12-436T 

work from March 2011 through December 2011 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 work. We believe that the evidence obtained provides 

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

objectives.

The Army has taken a number of steps since June 2010 at different levels 

to provide for more effective management and oversight of contracts 

supporting Arlington, including improving visibility of contracts, 

establishing new support relationships, formalizing policies and 

procedures, and increasing the use of dedicated contracting staff to 

manage and improve acquisition processes. While significant progress 

has been made, we have recommended that the Army take further action 

in these areas to ensure continued improvement and institutionalize 

progress made to date. These recommendations and the agency’s 

response are discussed later in this statement.

Arlington does not have its own contracting authority and, as such, relies 

on other contracting offices to award and manage contracts on its behalf. 

ANCP receives contracting support in one of two main ways, either by (1) 

working directly with contracting offices to define requirements, ensure 

the appropriate contract vehicle, and provide contract oversight, or (2) 

partnering with another program office to leverage expertise and get help 

with defining requirements and providing contract oversight. Those 

program offices, in turn, use other contracting arrangements to obtain 

services and perform work for Arlington. Using data from multiple 

sources, we identified 56 contracts and task orders that were active 

during fiscal year 2010 and the first three quarters of fiscal year 2011 

under which these contracting offices obligated roughly $35.2 million on 

Arlington’s behalf. These contracts and task orders supported cemetery 

operations, such as landscaping, custodial, and guard services; 

construction and facility maintenance; and new efforts to enhance 

information-technology systems for the automation of burial operations. 

Figure 1 identifies the contracting relationships, along with the number of 

contracts and dollars obligated by contracting office, for the contracts and 

task orders we reviewed.

Management of 

Arlington Contracts 

Improved, but 

Additional Steps Are 

Needed to Ensure 

Continued Progress
 

Page 4 GAO-12-436T 

Figure 1: Distribution of Arlington Contracts by Office

a

Figure represents contracts or task orders active during fiscal year 2010 and the first three quarters 

of fiscal year 2011 and above $100,000. 

b

The Mission and Installation Contracting Command as well as the National Capital Region 

contracting office are part of the Army Contracting Command. 

At the time of our review, we found that ANCP did not maintain complete 

data on contracts supporting its operations. We have previously reported 

that the effective acquisition of services requires reliable data to enable 
 

Page 5 GAO-12-436T 

informed management decisions.8

 

Without complete data, ANCP 

leadership may be without sufficient information to identify, track, and 

ensure the effective management and oversight of its contracts. While we 

obtained information on Arlington contracts from various sources, 

limitations associated with each of these sources make identifying and 

tracking Arlington’s contracts as a whole difficult. For example: 

• Internal ANCP data. A contract specialist detailed to ANCP in 

September 2010 developed and maintained a spreadsheet to identify 

and track data for specific contracts covering daily cemetery 

operations and maintenance services. Likewise, ANCP resource 

management staff maintain a separate spreadsheet that tracks 

purchase requests and some associated contracts, as well as the 

amount of funding provided to other organizations through the use of 

military interdepartmental purchase requests. Neither of these 

spreadsheets identifies the specific contracts and obligations 

associated with Arlington’s current information-technology and 

construction requirements.

• Existing contract and financial systems. The Federal Procurement 

Data System-Next Generation (FPDS-NG) is the primary system used 

to track governmentwide contract data, including those for the 

Department of Defense (DOD) and the Army. The Arlington funding 

office identification number, a unique code that is intended to identify 

transactions specific to Arlington, is not consistently used in this 

system and, in fact, was used for only 34 of the 56 contracts in our 

review. In October 2010 and consistent with a broader Army initiative, 

ANCP implemented the General Fund Enterprise Business System 

(GFEBS)9

 

8

GAO, Defense Acquisitions: Tailored Approach Needed to Improve Service Acquisition 

Outcomes, 

to enhance financial management and oversight and to 

improve its capability to track expenditures. We found that data in this 

system did not identify the specific information-technology contracts 

supported by the Army Communications-Electronics Command, Army 

Geospatial Center, Naval Supply Systems Command Weapon 

Systems Support office, and others. Officials at ANCP and at the 

MICC-Fort Belvoir stated that they were exploring the use of 

additional data resources to assist in tracking Arlington contracts, 

including the Virtual Contracting Enterprise, an electronic tool 

GAO-07-20 (Washington D.C.: Nov., 9, 2006). 

9

GFEBS is intended to improve financial, asset, and real property management and 

standardize processes across the Army. 
 

Page 6 GAO-12-436T 

intended to help enable visibility and analysis of elements of the 

contracting process.

• Contracting support organizations. We also found that Army 

contracting offices had difficulty in readily providing complete and 

accurate data to us on Arlington contracts. For example, the National 

Capital Region Contracting Center could not provide a complete list of 

active contracts supporting Arlington during fiscal years 2010 and 

2011 and in some cases did not provide accurate dollar amounts 

associated with the contracts it identified. USACE also had difficulty 

providing a complete list of active Arlington contracts for this time 

frame. The MICC-Fort Belvoir contracting office was able to provide a 

complete list of the recently awarded contracts supporting Arlington 

with accurate dollar amounts for this time frame, and those data were 

supported by similar information from Arlington. 

The Army has also taken a number of steps to better align ANCP contract 

support with the expertise of its partners. However, some of the 

agreements governing these relationships do not yet fully define roles and 

responsibilities for contracting support. We have previously reported that 

a key factor in improving DOD’s service acquisition outcomes—that is, 

obtaining the right service, at the right price, in the right manner—is 

having defined responsibilities and associated support structures.10 Going 

forward, sustained attention on the part of ANCP and its partners will be 

important to ensure that contracts of all types and risk levels are 

managed effectively. The following summarizes ongoing efforts in this 

area:

• ANCP established a new contracting support agreement with the 

Army Contracting Command in August 2010. The agreement states 

that the command will assign appropriate contracting offices to 

provide support, in coordination with ANCP, and will conduct joint 

periodic reviews of new and ongoing contract requirements. In April 

2011, ANCP also signed a separate agreement with the MICC, part of 

the Army Contracting Command, which outlines additional

responsibilities for providing contracting support to ANCP. While this 

agreement states that the MICC, through the Fort Belvoir contracting 

office, will provide the full range of contracting support, it does not 

 

10GAO-07-20. 
 

Page 7 GAO-12-436T 

specify the types of requirements that will be supported, nor does it 

specify that other offices within the command may also do so. 

• ANCP signed an updated support agreement with USACE in 

December 2010, which states that these organizations will coordinate 

to assign appropriate offices to provide contracting support and that 

USACE will provide periodic joint reviews of ongoing and upcoming 

requirements. At the time of our review, USACE officials noted that 

they were in the process of finalizing an overarching program 

management plan with ANCP, which, if implemented, provides 

additional detail about the structure of and roles and responsibilities 

for support. USACE and ANCP have also established a Senior 

Executive Review Group, which updates the senior leadership at both 

organizations on the status of ongoing efforts. 

• ANCP has also put agreements in place with the Army Information 

Technology Agency (ITA) and the Army Analytics Group, which 

provide program support for managing information-technology 

infrastructure and enhance operational capabilities. Officials at ANCP 

decided to leverage this existing Army expertise, rather than 

attempting to develop such capabilities independently as was the 

case under the previous Arlington management. For example, the 

agreement in place with ITA identifies the services that will be 

provided to Arlington, performance metrics against which ITA will be 

measured, as well as Arlington’s responsibilities. These organizations 

are also responsible for managing the use of contracts in support of 

their efforts; however, the agreement with ANCP does not specifically 

address roles and responsibilities associated with the use and 

management of these contracts supporting Arlington requirements. 

Although officials from these organizations told us that they currently 

understand their responsibilities, without being clearly defined in the 

existing agreements, roles and responsibilities may be less clear in 

the future when personnel change.

ANCP has developed new internal policies and procedures and improved 

training for staff serving as contracting officer’s representatives, and has 

dedicated additional staff resources to improve contract management. 

Many of these efforts were in process at the time of our review, including 

decisions on contracting staff needs, and their success will depend on 

continued management attention. The following summarizes our findings 

in this area:

• Arlington has taken several steps to more formally define its own 

internal policies and procedures for contract management. In July 

2010, the Executive Director of ANCP issued guidance stating that the 
 

Page 8 GAO-12-436T 

Army Contracting Command and USACE are the only authorized 

contracting centers for Arlington. Further, ANCP is continuing efforts 

to (1) develop standard operating procedures associated with 

purchase requests; (2) develop memorandums for all ANCP 

employees that outline principles of the procurement process, as well 

as training requirements for contracting officer’s representatives; and 

(3) create a common location for reference materials and information 

associated with Arlington contracts. In May 2011, the Executive 

Director issued guidance requiring contracting officer’s representative 

training for all personnel assigned to perform that role, and at the time 

of our review, all of the individuals serving as contracting officer’s 

representatives had received training for that position.

• ANCP, in coordination with the MICC-Fort Belvoir contracting office is 

evaluating staffing requirements to determine the appropriate number, 

skill level, and location of contracting personnel. In July 2010, the 

Army completed a study that assessed Arlington’s manpower 

requirements and identified the need for three full-time contract 

specialist positions. While these positions have not been filled to date, 

ANCP’s needs have instead been met through the use of staff 

provided by the MICC. At the time of our review, the MICC-Fort 

Belvoir was providing a total of 10 contracting staff positions in 

support of Arlington, 5 of which are funded by ANCP, with the other 5 

funded by the MICC-Fort Belvoir to help ensure adequate support for 

Arlington requirements. ANCP officials have identified the need for a 

more senior contracting specialist and stated that they intend to 

request an update to their staffing allowance for fiscal year 2013 to fill 

this new position. 

Prior reviews of Arlington have identified numerous issues with contracts 

in place prior to the new leadership at ANCP.11

 

11For example, see U.S. Army, Inspector General Agency, Special Inspection of Arlington 

National Cemetery Final Report (Washington, D.C.: June 2010) and Army Audit Agency, 

Contracting Operations in Support of Arlington National Cemetery: Army Contracting 

Command National Capital Region, A-2012-0021-ALC (Alexandria, Va.: 2011). 

While our review of similar 

contracts found common concerns, we also found that contracts and task 

orders awarded since June 2010 reflect improvements in acquisition 

practices. Our previous contracting-related work has identified the need to 

have well-defined requirements, sound business arrangements (i.e., 

contracts in place), and the right oversight mechanisms to ensure positive 

outcomes. We found examples of improved documentation, better 
 

Page 9 GAO-12-436T 

definition and consolidation of existing requirements for services 

supporting daily cemetery operations, and more specific requirements for 

contractor performance. At the time of our review, many of these efforts 

were still under way, so while initial steps taken reflect improvement, their 

ultimate success is not yet certain. 

The Army has also taken positive steps and implemented improvements 

to address other management deficiencies and to provide information and 

assistance to families. It has implemented improvements across a broad 

range of areas at Arlington, including developing procedures for ensuring 

accountability over remains, taking actions to better provide informationassurance, and improving its capability to respond to the public and to 

families’ inquiries. For example, Arlington officials have updated and 

documented the cemetery’s chain-of-custody procedures for remains, to 

include multiple verification steps by staff members and the tracking of 

decedent information through a daily schedule, electronic databases, and 

tags affixed to urns and caskets entering Arlington. Nevertheless, we 

identified several areas where challenges remain:

• Managing information-technology investments. Since June 2010, 

ANCP has invested in information-technology improvements to 

correct existing problems at Arlington and has begun projects to 

further enhance the cemetery’s information-technology capabilities. 

However, these investments and planned improvements are not yet 

guided by an enterprise architecture12—or modernization blueprint. 

Our experience has shown that developing this type of architecture 

can help minimize risk of developing systems that are duplicative, 

poorly integrated, and unnecessarily costly to maintain.13

 

12An enterprise architecture comprises a set of descriptive models (e.g., diagrams and 

tables) that define, in business terms and in technology terms, how an organization 

operates today, how it intends to operate in the future, and how it intends to invest in 

technology to transition from today’s operational environment to that of the future.

ANCP is 

working to develop an enterprise architecture, and officials told us in 

January that they expect the architecture will be finalized in 

September 2012. Until the architecture is in place and ANCP’s 

ongoing and planned information-technology investments are 

assessed against that architecture, ANCP lacks assurance that these 

investments will be aligned with its future operational environment, 

13GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save 

Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011).

Army Has Made 

Progress in 

Addressing Other 

Management 

Deficiencies at 

Arlington, but 

Challenges Remain
 

Page 10 GAO-12-436T 

increasing the risk that modernization efforts will not adequately meet 

the organization’s needs.

• Updating workforce plans. The Army took a number of positive steps 

to address deficiencies in its workforce plans, including completing an 

initial assessment of its organizational structure in July 2010 after the 

Army IG found that Arlington was significantly understaffed. However, 

ANCP’s staffing requirements and business processes have 

continued to evolve, and these changes have made that initial 

workforce assessment outdated. Since the July 2010 assessment, 

officials have identified the need for a number of new positions, 

including positions in ANCP’s public-affairs office and a new security 

and emergency-response group. Additionally, Arlington has revised a 

number of its business processes, which could result in a change in 

staffing needs. Although ANCP has adjusted its staffing levels to 

address emerging requirements, its staffing needs have not been 

formally reassessed. Our prior work has demonstrated that this kind of 

assessment can improve workforce planning, which can enable an 

organization to remain aware of and be prepared for its current and 

future needs as an organization. ANCP officials have periodically 

updated Arlington’s organizational structure as they identify new 

requirements, and officials told us in January that they plan to 

completely reassess staffing within ANCP in the summer of 2012 to 

ensure that it has the staff needed to achieve its goals and objectives. 

Until this reassessment is completed and documented, ANCP lacks 

assurance that it has the correct number and types of staff needed to 

achieve its goals and objectives.

• Developing an organizational assessment program. Since 2009 

ANCP has been the subject of a number of audits and assessments 

by external organizations that have reviewed many aspects of its 

management and operations, but it has not yet developed its own 

assessment program for evaluating and improving cemetery 

performance on a continuous basis. Both the Army IG and VA have 

noted the importance of assessment programs in identifying and 

enabling improvements of cemetery operations to ensure that 

cemetery standards are met. Further, the Army has emphasized the 

importance of maintaining an inspection program that includes a 

management tool to identify, prevent, or eliminate problem areas. At 

the time of our review, ANCP officials told us they were in the process 

of developing an assessment program and were adapting VA’s 

program to meet the needs of the Army’s national cemeteries. ANCP 

officials estimated in January that they will be ready to perform their 

first self-assessment in late 2012. Until ANCP institutes an 

assessment program that includes an ability to complete a selfassessment of operations and an external assessment by cemetery 
 

Page 11 GAO-12-436T 

subject-matter experts, it is limited in its ability to evaluate and 

improve aspects of cemetery performance.

• Coordinating with key partners. While ANCP has improved its 

coordination with other Army organizations, we found that it has

encountered challenges in coordinating with key operational partners, 

such as the Military District of Washington, the military service honor 

guards, and Joint Base Myer-Henderson Hall.14 Officials from these 

organizations told us that communication and collaboration with 

Arlington have improved, but they have encountered challenges and 

there are opportunities for continued improvement. For example, 

officials from the Military District of Washington and the military 

service honor guards indicated that at times they have experienced 

difficulties working with Arlington’s Interment Scheduling Branch and 

provided records showing that from June 24, 2010, through December 

15, 2010, there were at least 27 instances where scheduling conflicts 

took place.15 These challenges are due in part to a lack of written 

agreements that fully define how these operational partners will 

support and interact with Arlington. Our prior work has found that 

agencies can derive benefits from enhancing and sustaining their 

collaborative efforts by institutionalizing these efforts with agreements 

that define common outcomes, establish agreed-upon roles and 

responsibilities, identify mechanisms used to monitor and evaluate 

collaborative efforts, and enable the organizations to leverage their

resources.16

 

14The Military District of Washington coordinates all official ceremonies at Arlington, 

including wreath-laying ceremonies and state funerals. The military services provide burial 

honors for private funeral and memorial services, and the Army provides ceremonial 

support including the Sentinels at the Tomb of the Unknowns. Joint Base Myer-Henderson 

Hall, located adjacent to Arlington, provides numerous installation-support services to 

Arlington, including emergency services and ceremonial support such as facilities, bus 

transportation, and traffic control.

ANCP has a written agreement in place with Joint Base 

Myer-Henderson Hall, but this agreement does not address the full 

scope of how these organizations work together. Additionally, ANCP 

has drafted, but has not yet signed, a memorandum of agreement 

with the Military District of Washington. ANCP has not drafted 

memorandums of agreement with the military service honor guards 

15Scheduling conflicts included scheduling the wrong honor guard for a funeral and 

scheduling funerals during times that the honor guards had blocked off to enable them to 

meet their other responsibilities outside of Arlington.

16GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
 

Page 12 GAO-12-436T 

despite each military service honor guard having its own scheduling 

procedure that it implements directly with Arlington and each service 

working with Arlington to address operational challenges. ANCP, by 

developing memorandums of agreement with its key operational 

partners, will be better positioned to ensure effective collaboration 

with these organizations and help to minimize future communication 

and coordination challenges.

• Developing a strategic plan. Although ANCP officials have been 

taking steps to address challenges at Arlington, at the time of our 

review they had not adopted a strategic plan aimed at achieving the 

cemetery’s longer-term goals. An effective strategic plan can help 

managers to prioritize goals; identify actions, milestones, and 

resource requirements for achieving those goals; and establish 

measures for assessing progress and outcomes. Our prior work has 

shown that leading organizations prepare strategic plans that define a 

clear mission statement, a set of outcome-related goals, and a 

description of how the organization intends to achieve those goals.17

• Developing written guidance for providing assistance to families. After 

the Army IG issued its findings in June 2010, numerous families called 

Arlington to verify the burial locations of their loved ones. ANCP 

developed a protocol for investigating these cases and responding to 

the families. Our review found that ANCP implemented this protocol, 

and we reviewed file documentation for a sample of these cases. In 

reviewing the assistance provided by ANCP when a burial error 

occurred, we found that ANCP’s Executive Director or Chief of Staff 

contacted the affected families. ANCP’s Executive Director—in 

consultation with cemetery officials and affected families—made 

Without a strategic plan, ANCP is not well positioned to ensure that 

cemetery improvements are in line with the organizational mission 

and achieve desired outcomes. ANCP officials told us during our 

review that they were at a point where the immediate crisis at the 

cemetery had subsided and they could focus their efforts on 

implementing their longer-term goals and priorities. In January, ANCP 

officials showed us a newly developed campaign plan. While we have 

not evaluated this plan, our preliminary review found that it contains 

elements of an effective strategic plan, including expected outcomes 

and objectives for the cemetery and related performance metrics and 

milestones.

 

17GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).
 

Page 13 GAO-12-436T 

decisions on a case-by-case basis about the assistance that was 

provided to each family. For instance, some families who lived outside 

of the Washington, D.C., area were reimbursed for hotel and travel 

costs. However, the factors that were considered when making these 

decisions were not documented in a written policy. In its June 2010 

report, the Army IG noted in general that the absence of written 

policies left Arlington at risk of developing knowledge gaps as 

employees leave the cemetery. By developing written guidance that 

addresses the cemetery’s interactions with families affected by burial 

errors, ANCP could identify pertinent DOD and Army regulations and 

other guidance that should be considered when making such 

decisions. Also, with written guidance the program staff could identify 

the types of assistance that can be provided to families. In January, 

ANCP provided us with a revised protocol for both agency-identified 

and family member-initiated gravesite inquiries. The revised protocol 

provides guidance on the cemetery’s interactions with the next of kin 

and emphasizes the importance of maintaining transparency and 

open communication with affected families.

A transfer of jurisdiction for the Army’s two national cemeteries to VA is 

feasible based on historical precedent for the national cemeteries and 

examples of other reorganization efforts in the federal government. 

However, we identified several factors that may affect the advisability of 

making such a change, including the potential costs and benefits, 

potential transition challenges, and the potential effect on Arlington’s 

unique characteristics. In addition, given that the Army has taken steps to 

address deficiencies at Arlington and has improved its management, it 

may be premature to move forward with a change in jurisdiction, 

particularly if other options for improvement exist that entail less 

disruption. During our review, we identified opportunities for enhancing 

collaboration between the Army and VA that could leverage their 

strengths and potentially lead to improvements at all national cemeteries.

Transferring cemetery jurisdiction could have both benefits and costs. Our 

prior work suggests that government reorganization can provide an 

opportunity for greater effectiveness in program management and result 

in improved efficiency over the long-term, and can also result in shortFormal Collaboration 

between the Army 

and VA Could Lead to 

Improvements across 

All National 

Cemeteries
 

Page 14 GAO-12-436T 

term operational costs.18

Potential transition challenges may arise in transferring cemetery 

jurisdiction. Army and VA cemeteries have similar operational 

requirements to provide burial services for service members, veterans, 

and veterans’ family members; however, officials identified areas where 

the organizations differ and stated that there could be transition 

challenges if VA were to manage Arlington, including challenges 

pertaining to the regulatory framework, appropriations structure, and 

contracts. For example, Arlington has more restrictive eligibility criteria for 

in-ground burials, which has the result of limiting the number of 

individuals eligible for burial at the cemetery. If Arlington cemetery were to 

be subject to the same eligibility criteria as VA’s cemeteries, the eligibility 

for in-ground burials at Arlington would be greatly expanded.

 At the time of our review, Army and VA officials 

told us they were not aware of relevant studies that may provide insight 

into the potential benefits and costs of making a change in cemetery 

jurisdiction. However, our review identified areas where VA’s and the 

Army’s national cemeteries have similar, but not identical, needs and 

have developed independent capabilities to meet those needs. For 

example, each agency has its own staff, processes, and systems for 

determining burial eligibility and scheduling and managing burials. While 

consolidating these capabilities may result in long-term efficiencies, there 

could also be challenges and short-term costs. 

19

Other factors that may affect the advisability of transferring jurisdiction 

pertain to the potential effect on Arlington’s unique characteristics. These 

characteristics include the following:

Additionally, the Army’s national cemeteries are funded through a 

different appropriations structure than VA’s national cemeteries. If the 

Army’s national cemeteries were transferred to VA, Congress would have 

to choose whether to alter the funding structure currently in place for 

Arlington.

 

18GAO, Federal Land Management: Observations on a Possible Move of the Forest 

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

2009).

19Burial eligibility at VA’s national cemeteries is governed by 38 U.S.C. § 2402 and 38 

C.F.R. § 38.620. Burial eligibility at Arlington is governed by 38 U.S.C. § 2410 and 32 

C.F.R. § 553.15.
 

Page 15 GAO-12-436T 

• Mission and vision statements. The Army and VA have developed 

their own mission and vision statements for their national cemeteries 

that differ in several ways. Specifically, VA seeks to be a model of 

excellence for burials and memorials, while Arlington seeks to be the 

nation’s premier military cemetery.

• Military honors provided to veterans. The Army and VA have varying 

approaches to providing military funeral honors. VA is not responsible 

for providing honors to veterans, and VA cemeteries generally are not 

involved in helping families obtain military honors from DOD. In 

contrast, Arlington provides a range of burial honors depending on 

whether an individual is a service member killed in action, a veteran, 

or an officer.

• Ceremonies and special events. Arlington hosts a large number of 

ceremonies and special events in a given year, some of which may 

involve the President of the United States as well as visiting heads of 

state. From June 10, 2010, through October 1, 2011, Arlington hosted 

more than 3,200 wreath-laying ceremonies, over 70 memorial 

ceremonies, and 19 state visits, in addition to Veterans Day and 

Memorial Day ceremonies, and also special honors for Corporal Frank 

Buckles, the last American servicemember from World War I. VA 

officials told us that their cemeteries do not support a similar volume 

of ceremonies, and as a result they have less experience in this area 

than the Army.

During our review, we found that there are opportunities to expand 

collaboration between the Army and VA that could improve the efficiency 

and effectiveness of these organizations’ cemetery operations. Our prior 

work has shown that achieving results for the nation increasingly requires 

that federal agencies work together, and when considering the nation’s 

long-range fiscal challenges, the federal government must identify ways 

to deliver results more efficiently and in a way that is consistent with its 

limited resources.20

 

20GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save 

Tax Dollars, and Enhance Revenue,

Since the Army IG issued its findings in June 2010, 

the Army and VA have taken steps to partner more effectively. The 

Army’s hiring of several senior VA employees to help manage Arlington 

has helped to foster collaboration, and the two agencies signed a 

memorandum of understanding that allows ANCP employees to attend 

classes at VA’s National Training Center.

GAO-11-318SP (Washington, D.C.: Mar, 1, 2011).
 

Page 16 GAO-12-436T 

However, the Army and VA may have opportunities to collaborate and 

avoid duplication in other areas that could benefit the operations of either 

or both cemetery organizations. For example, the Army and VA are 

upgrading or redesigning some of their core information-technology 

systems supporting cemetery operations. By continuing to collaborate in 

this area, the agencies can better ensure that their information-technology 

systems are able to communicate, thereby helping to prevent operational 

challenges stemming from a lack of compatibility between these systems 

in the future. In addition, each agency may have specialized capabilities 

that it could share with the other. VA, for example, has staff dedicated to 

determining burial eligibility, and the Army has an agency that provides 

geographic-information-system and global-positioning-system 

capabilities—technologies that VA officials said that they are examining 

for use at VA’s national cemeteries. 

While the Army and VA have taken steps to improve collaboration, at the 

time of our review the agencies had not established a formal mechanism 

to identify and analyze issues of shared interest, such as process 

improvements, lessons learned, areas for reducing duplication, and 

solutions to common problems. VA officials indicated that they planned to 

meet with ANCP officials in the second quarter of fiscal year 2012, with 

the aim of enhancing collaboration between the two agencies. Unless the 

Army and VA collaborate to identify areas where the agencies can assist 

each other, they could miss opportunities to take advantage of each 

other’s strengths—thereby missing chances to improve the efficiency and 

effectiveness of cemetery operations—and are at risk of investing in 

duplicative capabilities.

The success of the Army’s efforts to improve contracting and 

management at Arlington will depend on continued focus in various 

areas. Accordingly, we made a number of recommendations in our 

December 2011 reports. In the area of contracting, we recommended that 

the Army implement a method to track complete and accurate contract 

data, ensure that support agreements clearly identify roles and 

responsibilities for contracting, and determine the number and skills 

necessary for contracting staff. In its written comments, DOD partially 

concurred with these recommendations, agreeing that there is a need to 

take actions to address the issues we raised, but indicating that our 

recommendations did not adequately capture Army efforts currently 

underway. We believe our report reflects the significant progress made by 

Arlington and that implementation of our recommendations will help to 

institutionalize the positive steps taken to date.

Summary of 

Recommendations for 

Further 

Improvements at 

Arlington National 

Cemetery
 

Page 17 GAO-12-436T 

• With regard to our recommendation to identify and implement a 

method to track complete and accurate contact data, DOD noted that 

Arlington intends to implement, by April 2012, a methodology based 

on an electronic tool which is expected to collect and reconcile 

information from a number of existing data systems. Should this 

methodology consider the shortcomings within these data systems as 

identified in our report, we believe this would satisfy our 

recommendations.

• DOD noted planned actions, expected for completion by March 2012 

that, if implemented, would satisfy the intent of our other two 

recommendations.

With regard to other management challenges at Arlington, we 

recommended that the Army implement its enterprise architecture and 

reassess ongoing and planned information-technology investments; 

update its assessment of ANCP’s workforce needs; develop and 

implement a program for assessing and improving cemetery operations; 

develop memorandums of understanding with Arlington’s key operational 

partners; develop a strategic plan; and develop written guidance to help 

determine the types of assistance that will be provided to families affected 

by burial errors. DOD fully agreed with our recommendations that the 

Army update its assessment of ANCP’s workforce needs and implement 

a program for assessing and improving cemetery operations. DOD 

partially agreed with our other recommendations. In January, ANCP 

officials provided us with updates on its plans to take corrective actions, 

as discussed in this statement.

• With regard to implementing an enterprise architecture, DOD stated 

that investments made to date in information technology have been 

modest and necessary to address critical deficiencies. We recognize 

that some vulnerabilities must be expeditiously addressed. 

Nevertheless, our prior work shows that organizations increase the 

risk that their information-technology investments will not align with 

their future operational environment if these investments are not 

guided by an approved enterprise architecture.

• Regarding its work with key operational partners, DOD stated that it 

recognizes the value of establishing memorandums of agreement and 

noted the progress that the Army has made in developing 

memorandums of agreement with some of its operational partners. 

We believe that the Army should continue to pursue and finalize 

agreements with key operational partners that cover the full range of 

areas where these organizations must work effectively together.

• With regard to a strategic plan, DOD stated that it was in the process 

of developing such a plan. As discussed previously, ANCP officials in 
 

Page 18 GAO-12-436T 

January showed us a newly developed campaign plan that, based on 

our preliminary review, contains elements of an effective strategic 

plan.

• Regarding written guidance on the factors that the Executive Director 

will consider when determining the types of assistance provided to 

families affected by burial errors, DOD stated that such guidance 

would limit the Executive Director’s ability to exercise leadership and 

judgment to make an appropriate determination. We disagree with this 

view. Our recommendation does not limit the Executive Director’s 

discretion, which we consider to be an essential part of ensuring that 

families receive the assistance they require in these difficult situations. 

Our recommendation, if implemented, would improve visibility into the 

factors that guide decision making in these cases.

Finally, we recommended that the Army and VA implement a joint 

working group or other such mechanism to enable ANCP and VA’s 

National Cemetery Administration to collaborate more closely in the 

future. Both DOD and VA concurred with this recommendation. As noted, 

VA stated that a planning meeting to enhance collaboration is planned for 

the second quarter of 2012.

Chairmen Wilson and Wittman, Ranking Members Davis and Cooper, and 

Members of the Subcommittees, this completes our prepared statement. 

We would be pleased to respond to any questions that you may have at 

this time.

For questions about this statement, please contact Belva Martin, Director, 

Acquisition and Sourcing Management, on (202) 512-4841 or 

martinb@gao.gov or Brian Lepore, Director, Defense Capabilities and 

Management, on (202) 512-4523 or leporeb@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this testimony. Individuals who made key contributions 

to this testimony include Brian Mullins, Assistant Director; Tom Gosling, 

Assistant Director; Kyler Arnold; Russell Bryan; George M. Duncan; 

Kathryn Edelman; Julie Hadley; Kristine Hassinger; Lina Khan; and Alex 

Winograd.

Contacts and Staff 

Acknowledgments

(121037)
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 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.