Pension Benefit Guaranty Corporation: Some Steps Have Been Taken to Improve Contracting, but a More Strategic Approach is Needed
Published: 2008-08-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Pension Benefit Guaranty Corporation (PBGC) insures the pensions of more than 44 million workers in over 30,000 employer-sponsored defined benefit pension plans. In response to growing workloads, PBGC has come to rely heavily on contractors to conduct its work. GAO was asked to report on (1) the role that contracting plays in PBGC's efforts to accomplish its mission, (2) the steps PBGC has taken to improve its acquisition infrastructure and develop a strategic approach to guide its contracting activities, and (3) the steps PBGC has taken to improve its contract oversight processes to ensure accountability. To address these issues, we interviewed PBGC officials and selected contractors, reviewed data on PBGC's contracting activities; identified changes PBGC is making to contracting procedures; and identified strategies PBGC uses to monitor contracts.
section_title: What GAO Found
paragraphs: Contracting plays a central role in helping PBGC achieve its mission and address unpredictable workloads. Since the mid-1980s, PBGC has had contracts covering a wide range of services, including the administration of terminated plans, payment of benefits, customer communication, legal assistance, document management, and information technology. PBGC's workforce currently consists of about 800 federal employees and utilizes the services of about 1,500 contract employees. From fiscal year 2000 through 2007, PBGC's contract spending increased steadily along with its overall budget and workload, and its use of contract employees has outpaced its hiring of federal employees. As its workloads have grown due to a significant number of large pension plan terminations, PBGC has relied on contractors to supplement its workforce, acknowledging that it has difficulty anticipating its workloads due to unpredictable economic conditions. PBGC is taking steps to improve its acquisition infrastructure, but the Procurement Department is not yet part of PBGC's strategic decision-making process. In 2007, PBGC began to take steps to realign its Procurement Department, update contracting policies and processes, upgrade the skills of Procurement Department staff, and better track contracting data. PBGC's efforts begin to provide an improved foundation for the contracting function; however, these efforts are early steps and more remains to be done. PBGC has not fully integrated its contracting function at the corporate level; the Procurement Department is not included in corporate-level strategic planning and does not have a presence on PBGC's relevant strategic teams. PBGC has made improvements to contractor oversight and has begun to implement performance-based contracting that offers the potential for better contract outcomes, but also creates new challenges for contract oversight and monitoring efforts. PBGC has implemented new contract monitoring activities, improved oversight activities for some of its major contracts, and developed comprehensive procedures to direct contracting activities. For its field benefit administration office contracts, PBGC developed performance measures and scorecards, providing feedback about contractor performance in terms of timeliness and accuracy of benefit payments. Despite these improvements, most of PBGC's current contracts still lack performance incentives and methods to hold contractors accountable. PBGC recently began awarding more performance-based contracts, as a means to achieve better outcomes. Although performance-based contracting is recognized as a viable way toward getting better results from contractors, GAO and others have identified common challenges agencies face when implementing this approach--from deciding which contracts are appropriate for a performance-based approach to deciding which outcomes to measure and emphasize. PBGC procurement officials recognize the benefits and challenges of performance-based contracting, and that they must provide additional oversight of contracts and a different approach to contract monitoring that focuses on outcomes rather than processes.

section_title: Letter
paragraphs: The Pension Benefit Guaranty Corporation (PBGC) insures pensions for  The Pension Benefit Guaranty Corporation (PBGC) insures pensions for  more than 44 million workers in over 30,000 employer-sponsored defined  more than 44 million workers in over 30,000 employer-sponsored defined  benefit plans—private sector pension plans where an employer guarantees  benefit plans—private sector pension plans where an employer guarantees  a benefit. PBGC’s primary responsibility is to collect premiums from the  a benefit. PBGC’s primary responsibility is to collect premiums from the  sponsors of the pension plans and provide timely and uninterrupted  sponsors of the pension plans and provide timely and uninterrupted  benefit payments when terminations or bankruptcies occur. In the event of  benefit payments when terminations or bankruptcies occur. In the event of  a distressed plan termination, PBGC assumes control of plan assets,  a distressed plan termination, PBGC assumes control of plan assets,  calculates benefit amounts, and pays recipients a guaranteed benefit. In  calculates benefit amounts, and pays recipients a guaranteed benefit. In  fiscal year 2007, roughly 611,000 beneficiaries received over $4.1 billion in  fiscal year 2007, roughly 611,000 beneficiaries received over $4.1 billion in  benefit payments. In response to growing workloads, PBGC has come to  benefit payments. In response to growing workloads, PBGC has come to  rely heavily on contractors to conduct its work. PBGC’s current workforce  rely heavily on contractors to conduct its work. PBGC’s current workforce  is made up of roughly two-thirds contractor employees and one-third  is made up of roughly two-thirds contractor employees and one-third  federal employees.  federal employees.
In July 2003, GAO designated PBGC’s single-employer pension insurance  In July 2003, GAO designated PBGC’s single-employer pension insurance  program—its largest insurance program—as “high risk,” including it on  program—its largest insurance program—as “high risk,” including it on  GAO’s list of major programs that need urgent attention and  GAO’s list of major programs that need urgent attention and  transformation; the program remains on the list today. To strengthen  pension plan funding, Congress passed the Pension Protection Act of 2006  (PPA). However, PBGC still showed an accumulated deficit of $14 billion  for its single-employer program as of September 2007.
Because of PBGC’s reliance on contracts to carry out its mission, its  acquisition infrastructure—the framework an agency must have in place to  manage its contracting activities—will in part determine whether the  agency succeeds in its mission. Previous GAO work identified challenges  facing PBGC’s contracting activities, which included PBGC’s limited  efforts to link contracting and staffing decisions to longer-term strategic  planning, placing PBGC at risk for being unprepared for future workload  changes. GAO also identified weaknesses in PBGC’s contract oversight  activities and in its contracting processes, resulting in limited competition  and an over-reliance on contracts that carry more cost and quality  assurance risks. These findings have been echoed in recent studies by  PBGC’s Inspector General. To ensure that PBGC is well positioned to  manage its workload, we were asked to review PBGC’s contracting  function to follow-up on our earlier contracting work. Specifically, this  report assesses (1) the role that contracting plays in PBGC’s efforts to  accomplish its mission, (2) the steps PBGC has taken to improve its  acquisition infrastructure and develop a strategic approach to guide its  contracting activities, and (3) the steps PBGC has taken to improve its  contract oversight processes to ensure accountability.
To assess the role contracting plays in PBGC’s efforts to accomplish its  mission, we collected and analyzed data on PBGC contracting activities, as  well as on participants, plans, employees, and budget trends. To assess the  steps PBGC has taken to improve its acquisition infrastructure and  develop a strategic approach to guide its contracting activities, we  evaluated PBGC’s acquisition infrastructure in four key areas— organizational alignment and leadership, policies and procedures, human  capital, and information management. We identified changes PBGC is  making to its contracting procedures and to specific contracts, and  reviewed progress made on these initiatives. To assess the steps PBGC has  taken to improve its contract oversight processes, we identified the  strategies PBGC uses to monitor its contracts. We reviewed  documentation and spoke to officials responsible for monitoring customer  satisfaction and the accuracy of benefit payments, and actions taken in  response to the results of these monitoring efforts. We also reviewed a  small, random sample of contract oversight files. In addition, we  interviewed PBGC senior executives, managers, and programming and  contracting staff at headquarters, as well as selected contractors. We also  interviewed officials from PBGC’s Office of Inspector General and  reviewed relevant Inspector General reports.
We conducted our work between May 2007 and August 2008 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 the evidence obtained provides  a reasonable basis for our findings and conclusions based on our audit  objectives. Appendix I discusses our scope and methodology in further  detail.
subsections: section_title: Background
subsections: section_title: Overview of PBGC
paragraphs: The Employee Retirement Income Security Act of 1974 (ERISA) created  PBGC as a self-financing, nonprofit, wholly owned government  corporation. PBGC protects participants in private pension plans from  losing guaranteed benefits due to the termination of underfunded plans.  PBGC’s primary responsibilities are to collect premiums from the  sponsors of defined benefit plans to insure against default and to assume  administration of underfunded plans that terminate. In the event of a plan  default, PBGC assumes control of plan assets (including amounts due and  payable from the plan sponsor); calculates benefit amounts due to plan  participants, commonly communicated in “benefit determination letters;”  and pays recipients as benefits are due.
Generally, pension plans under PBGC’s administration, in which final  benefit determination letters have not yet been issued, are considered  estimated plans. PBGC pays benefits in estimated amounts until final  determinations are made, routinely taking several years to complete all  benefit determinations for plans that terminate. When all letters are issued  and participant appeal periods have expired, plans are then closed and  moved to ongoing administration where they generally require limited  maintenance to reflect participants’ marital changes, address changes,  deaths, and other events. Figure 1 provides an overview of the steps  involved in processing a terminated pension plan.
Over the years, PBGC’s workloads have grown significantly. In fiscal year  1975, the first year after the passage of ERISA, PBGC administered three  pension plans with a total of 400 participants. By fiscal year 2007, PBGC  administered almost 3,800 pension plans with over 1.3 million participants.  Figures 2 and 3 show the number of pension plans and participants  administered by PBGC since fiscal year 2000—the last time GAO issued a  report on this subject. Between fiscal years 2002 and 2005, PBGC  experienced a large number of claims that contributed to its workload  growth.
section_title: Previous Assessments of PBGC Contracting
paragraphs: In September 2000, we identified a variety of challenges facing PBGC’s  contracting activities. Faced with a significant influx of large pension plan  failures beginning in the mid-1980s, PBGC chose to contract for services  rather than seek additional federal employees during a period of  government downsizing. Over time, PBGC continued contracting for  services to address backlogs, but was focused on obtaining necessary  services quickly. As a result, we found that PBGC did not adequately link  decisions to contract for services to longer-term strategic planning  considerations. We recommended that PBGC develop a strategic approach  to contracting by conducting a comprehensive review of PBGC’s future  human capital needs and using this review to better link contracting  decisions to PBGC’s long-term strategic planning process. In response to  our recommendation, PBGC commissioned a study by the National  Academy of Public Administration (NAPA). NAPA provided a six-step  model for PBGC to follow for its strategic human capital planning. Upon  completion of this study, PBGC convened a workforce planning team that  initiated some of the steps NAPA suggested.
Our work also identified weaknesses in PBGC’s contract planning and  execution processes, which may have led to overuse of labor-hour  contracts rather than fixed-price contracts and also to limited competition.  PBGC’s contractor oversight activities also exhibited weaknesses,  including a lack of data essential for monitoring performance, quality  assurance review processes and policies, and procedural guidance.  Finally, we identified a potential lack of independence on the part of the  office that was responsible for auditing and reviewing PBGC contracting  activities. Many of these findings have been echoed more recently by  PBGC’s Inspector General.
PBGC’s Inspector General issued a report on contracting trends in July  2007. The Inspector General noted that the three major areas cited most  often as needing improvements were questioned costs (unsupported and  or unauthorized costs that contractors billed to PBGC); lack of  documented contracting policies, procedures, and directives; and  inadequate contractor oversight. The leading causes for questioned costs  were that contractors: (1) did not maintain adequate documentation to  justify the costs they billed PBGC and (2) subcontracted with employees  who did not have the qualifications required under the contract. Inspector  General reports also noted that PBGC has no comprehensive contracting  directives or policy guidance available to aid contracting officials and  contractors to carry out their respective duties. The reports also identified  significant contracting problems and control vulnerabilities, often  stemming from a lack of adequate monitoring of contractor performance.  Appendix II includes a list of related GAO and PBGC Inspector General  Reports.
section_title: Acquisition Framework
paragraphs: In response to federal agencies’ increasing reliance on contractors to  perform their missions and the systemic weaknesses identified in key  areas of contracting by GAO, inspectors general, and other accountability  organizations, in 2005, we published a Framework for Assessing the  Acquisition Function at Federal Agencies. The framework enables high- level, qualitative assessments of the strengths and weaknesses of the  contracting function.
The framework consists of four interrelated cornerstones that our work  has shown are essential to an efficient, effective, and accountable  contracting process.
Organizational alignment and leadership. Organizational alignment  assures the appropriate placement of the contracting function in the  agency, with stakeholders having clearly defined roles and responsibilities.  Key elements and critical success factors include aligning contracting with  the agency’s mission and needs and organizing the contracting function to  operate strategically. Committed leadership enables officials to make  strategic decisions that achieve agency-wide contracting outcomes more  effectively and efficiently. In fact, the Services Acquisition Reform Act of  2003 requires that certain civilian executive agencies designate a Chief  Acquisition Officer that has management of acquisition as their primary  duty. An executive in this position would address acquisition workforce  needs and strategies as part of strategic planning and performance results  processes.
Policies and processes. Implementing strategic decisions to achieve  desired agency-wide outcomes requires clear and transparent policies and  processes that are implemented consistently. Policies establish  expectations about the management of the contracting function. Processes  are the means by which management functions will be performed and  implemented. Effective policies and processes govern the planning, award,  administration, and oversight of contracting efforts.
Human capital. Successfully acquiring goods and services, and executing  and monitoring contracts requires valuing and investing in the contracting  workforce. Agencies must think strategically about attracting, developing,  and retaining talent, and creating a results-oriented culture within the  contracting workforce.
Knowledge and information management. Effective knowledge and  information management provides credible, reliable, and timely data to  make contracting decisions. Stakeholders in the contracting process— Procurement Department and program staff who decide which goods or  services to buy; project managers who receive the goods and services;  managers who maintain supplier relationships; contract administrators  who oversee compliance with the contract; and the finance department  that pays for the goods and services—need meaningful data to perform  their respective roles and responsibilities.
section_title: PBGC Relies on Contractors to Address Unpredictable Workloads
paragraphs: Contracting plays a central role in helping PBGC achieve its mission and  address unpredictable workloads. PBGC’s contracts cover a wide range of  services, including the administration of terminated plans, payment of  benefits, customer communication, legal assistance, document  management, and information technology. Its contract spending has  increased steadily along with overall budget and workload, and use of  contracted staff has outpaced its hiring of federal employees. PBGC has  relied on contractors to supplement its workforce since the mid-1980s as  its workloads have grown due to a significant number of pension plan  terminations. PBGC acknowledges that it has difficulty anticipating its  workloads due to unpredictable economic conditions and relies on  contractors to expand or reduce its workforce as necessary.
subsections: section_title: PBGC’s Contract Spending Has Increased along with Overall Budget, and Growth in Contract Employees Has Outpaced PBGC Employees
paragraphs: To address the increase in the overall number of pension plans and  participants, PBGC’s budget increased steadily over the last 8 years, from  $165 million in fiscal year 2000 to $398 million in fiscal year 2007.  Similarly, PBGC’s contract spending increased from $122 million in fiscal  year 2000 to $297 million in fiscal year 2007, as shown in figure 4.  Contracting represented 71 percent of PBGC’s appropriated budget during  this period. Across the federal government, contract spending has more  than doubled since fiscal year 2000, going from about $208.8 billion to $430  billion. The Departments of Defense and Homeland Security account for  the majority of the increase, while other agencies vary in their budget  changes. In previous work on contract spending at various agencies, we  found that overall, about a quarter of agencies’ discretionary spending was  through contracts. Therefore, PBGC’s contract spending as a percentage  of its discretionary budget is relatively high, although most federal  agencies have increased their contract spending in recent years.
The number of PBGC’s contract employees has grown significantly more  than PBGC employees. As figure 5 shows, PBGC had 791 contract  employees in fiscal year 2000. By fiscal year 2007, there were over 1,500  contract employees. Conversely, PBGC’s federal employees increased  modestly from 763 in fiscal year 2000 to 811 in fiscal year 2007. The largest  increases in contractor employees correspond to the failure of several  large plans, resulting in workload increases that occurred from fiscal year  2002 through fiscal year 2005. The number of contract employees peaked  in fiscal year 2006 at 1,768, and has since fallen to 1,502 in fiscal year 2007,  as PBGC is completing the work associated with terminating these large  plans.
section_title: PBGC Contracts for a Wide Range of Services
paragraphs: PBGC contracts for a wide range of services including    operating its 10 field benefit administration offices throughout the  country—field benefit administration office contract employees perform  the majority of benefits estimation and plan administration processing;   managing PBGC’s $68 billion of assets;    paying benefits to participants;    developing, overseeing, and managing new systems and information  technology projects in support of program operations; and   handling of customer inquiries through its customer call center.
PBGC also has certain functions, such as audit and actuarial functions,  where contract employees work side by side with federal employees and  supplement their efforts. PBGC also contracts for specialized services that  may not be needed on a routine basis. For example, while PBGC has in- house attorneys who handle the majority of PBGC’s litigation and  negotiations, occasionally there are cases where it is necessary for PBGC  to retain outside counsel. According to PBGC officials, hiring lawyers with  special expertise on a full-time basis, rather than as needed, would be cost  prohibitive. When PBGC needs outside legal services, it solicits proposals  from these firms for the needed services. According to PBGC officials, this  arrangement makes it possible for PBGC to secure necessary legal  services quickly and efficiently.
section_title: PBGC Relies on Contractors to Address Unpredictable Workloads
paragraphs: To carry out its operations, PBGC has relied on contractors to address its  unpredictable workload, which is driven largely by pension plan  terminations. In 2001, PBGC convened a workforce planning team to  analyze its future service demands. The team recognized that fluctuations  in the economy, or business cycle, could result in significant fluctuations  in PBGC workloads. For example, PBGC typically sees an increase in  terminations 1 to 2 years after a decline in the economy. The team noted  that PBGC must remain flexible to rapidly expand or reduce its processing  capacity to meet changing workloads, but cautioned that it was important  to keep the highest level of expertise in-house. Figure 6 shows the number  of contract employees and federal employees at PBGC, by office.
Although PBGC is currently experiencing a decline in new terminated plan  workloads, the case processing cycle takes an average of 3 years or more.  In determining the need for contract employees, PBGC considers both the  incoming workload and the workload currently in process. A PBGC  official noted that in order to balance the current benefit determination  workload and the anticipated decline in the incoming workload, PBGC is  allowing field benefit administration office staff increases only when there  is a clear demonstration of need. See figure 7 for recent trends in pending  benefit determinations.
According to a PBGC official, PBGC doesn’t foresee large plan  terminations and bankruptcies coming in 2008 or 2009, but there are a few  plans it is monitoring that could have significant impact on PBGC. Thus,  PBGC is in the delicate position of beginning to decrease contract  resources while still remaining prepared for possible workload increases  in a time of uncertain financial conditions.
section_title: PBGC Is Taking Steps to Improve Its Acquisition Infrastructure but Has Not Yet Developed a Strategic Approach to Contracting
paragraphs: In 2007, PBGC began to realign its Procurement Department, update  contracting policies and processes, upgrade the skills of Procurement  Department staff, and better track contracting data. While these efforts  provide an improved foundation for the contracting function, they are  early steps and a strategic approach to contracting has not yet been  developed.
subsections: section_title: PBGC Is Taking Steps to Improve Its Acquisition Infrastructure
paragraphs: PBGC’s heavy reliance on contract support requires an adequate  acquisition infrastructure to ensure an efficient, effective, and accountable  contracting function. An agency’s acquisition function stands on four  interrelated cornerstones—organizational alignment and leadership,  policies and processes, human capital, and knowledge and information  management. In 2007, PBGC hired a new procurement director who has  taken steps to improve the acquisition infrastructure in the four  cornerstone areas; however, the acquisition function’s infrastructure is  still inadequate in some areas.
subsections: section_title: Organizational Alignment and Leadership
paragraphs: The appropriate placement of the acquisition function within an agency  can facilitate efficient and effective management of acquisition activities.  In our work on best practices, we learned that leading companies elevated  or expanded the role of the company’s acquisition organization—typically  assigning it greater responsibility and authority for strategic planning,  management, and oversight of the company’s services spending. These  changes transformed the role of the purchasing unit from one focused on  mission support to one that was strategically important to the company’s  bottomline. Further, recent legislation recognized the importance of  placing the acquisition function at an appropriate level and mandates that  most executive departments appoint a chief acquisition officer.
PBGC’s Procurement Department does not play a strategic role within the  corporation and does not have an active role in the strategic decision- making process, becoming involved only once a requisition is submitted to  the department. For example, the procurement director is not part of the  following three teams that focus on initiatives that support the  corporation’s strategic plan.
The Operations Integration Board, whose members include the entire  Executive Management Committee, provides a forum for the senior  leadership to commission and review corporate-wide programs, projects,  and internal policies. Significant projects that cross organizational lines  and require multiorganizational resources are presented to the board for  approval.
The Budget and Planning Integration Team is responsible for  approving corporate-wide resource allocations and aligning resources to  PBGC’s strategic objectives. This team also makes recommendations on  large funding requests that are subject to approval by the Operations  Integration Board.
The Capital Planning for Information Technology Team reviews  information technology investments to assure the alignment of  information technology capital investments with the corporate strategic  plan and to monitor and control the execution of those investments. The  team provides recommendations to the Operations Integration Board and  the Budget and Planning Integration Team as the recommendations affect  operations or budget.
As a result, the Procurement Department has no input into the decision to  acquire goods or services through contracting; it is responsible for  implementing the policy decisions made by the executive management  team but has no voice in making these decisions. The Procurement  Department’s involvement on such boards could improve strategic  planning by enabling PBGC to identify and manage relationships among  the parties involved in the acquisition process; analyze aggregate agency  needs and devise strategic acquisition plans; and take into consideration  the effects of external factors, such as the appropriations process, on the  timing and execution of major contracts. Further, while PBGC has  recently published its strategic plan and begun developing a strategic  human capital plan, the agency has not actively involved the Procurement  Department in the process. The Procurement Department’s lack of  involvement in strategic decision making is an indicator that it may be  unable to identify, analyze, prioritize, and coordinate agency-wide  acquisition needs.
section_title: Policies and Processes
paragraphs: Policies and processes govern the way an agency performs the acquisition  function. The acquisition function does not end with the award of  contracts, but continues through contract implementation and closeout.  Acquisition policies and processes should clearly define the roles and  responsibilities of all involved in the acquisition process and need to be  communicated clearly to all involved. In addition, implementing strategic  acquisition decisions to achieve agency-wide outcomes requires clear,  transparent, and consistent policies and processes that govern the  planning, award, administration, and oversight of acquisitions.
PBGC updated its contracting policies and procedures in 2008. In the past  year, with the support of executive management, the Procurement  Department updated and issued two procurement directives that spell out  roles and responsibilities of all individuals involved in the acquisition  process and outline procurement and obligation procedures. The  Procurement Department issued policies requiring high-level approval for  certain types of transactions, such as issuing labor-hour-type contracts and  making modifications to contracts. The Procurement Department has  recently completed a comprehensive procurement manual that outlines  standard operating procedures and provides examples to illustrate  guidance. The General Counsel’s Office has provided guidance on when  the legal review of acquisitions is required, and works closely with the  Procurement Department in performing legal reviews and providing legal  advice. However, it is still too early to tell what the effect of the new  policies will be. The success of any set of policies will depend on adequate  communication across the agency; internal controls to ensure they are  implemented; and clear, strong, guidance from leadership on the  importance of adhering to the new policies.
section_title: Human Capital
paragraphs: A strategic human capital management approach enables an agency to  recruit, develop, and retain the right number of personnel with the right  skills to accomplish its mission effectively. Senior managers should devote  adequate resources to recruiting, hiring, developing, rewarding, and  retaining talented personnel. This is true for all functions within an agency  and is crucial for specialized functions, such as acquisition. Succession  planning also is needed to ensure that the workforce is composed of the  right number of personnel with the necessary skills and qualifications to  perform the acquisition function into the future.
PBGC has begun to focus on developing the knowledge and skills of its  Procurement Department staff. Having the right people with the right  skills is key to making a successful transformation toward an effective  acquisition environment. Over the last decade, the emergence of several  procurement trends, including a government-wide rise in services  contracting, has created a need for an acquisition workforce with a much  greater knowledge of market conditions, industry trends, and the technical  details of the commodities and services they procure. The Procurement  Department has developed new training and certification requirements  and invested in upgrading the skills of the acquisition workforce, by  providing training to help contract specialists obtain certification.  According to PBGC, while only 2 of 12 staff in the contract specialist series  were certified in contracting as of February 2007, by January 2008, 9 of the  12 staff had been certified. The Procurement Department also is working  to enhance training and certification requirements for COTRs working  throughout PBGC.
While PBGC’s contract spending has more than doubled since 2001, the  number of staff in the Procurement Department has risen only by two FTE  employees from 2001 to 2007. PBGC Procurement Department officials are  concerned that their staff of nine certified contract specialists is not  adequate to support the mission. In May 2007, the Procurement  Department studied four comparable agencies to determine appropriate  staffing levels for PBGC’s Procurement Department. This study compared  PBGC’s contracting staff size, number of annual transactions, and value of  annual transactions to those of the other four agencies. Although PBGC  had 88 percent more transactions on average and 40 percent more  contract dollars on average than the other four agencies, it had less than  half the average number of contracting office staff. This study only  focused on the Procurement Department and did not attempt to determine  appropriate staffing levels for other acquisition professionals not assigned  to the Procurement Department, such as program managers, financial  managers, and individuals involved in contract monitoring. We did not  conduct an independent assessment of this study to validate the study’s  results.
section_title: Information and Knowledge Management
paragraphs: To make strategic, mission-focused acquisition decisions, organizations  need knowledge and information management processes and systems that  produce credible, reliable, and timely data about the goods and services  acquired and the methods used to acquire them. Such data can be used to  identify opportunities to reduce costs, improve service levels, measure  compliance and performance, and manage service providers.
PBGC’s Procurement Department uses a variety of reports to oversee  contract spending. Some reports come from the contract writing system  while others are maintained manually. According to a PBGC official, the  reports track how goods and services are acquired but do not provide  detailed data on goods and services, as well as suppliers, and spending  patterns. As a result, PBGC may not have the strategic information needed  to support effective acquisition management decisions. In addition,  PBGC’s procurement software is not integrated into its financial system,  which would allow contracting professionals to obtain real-time  information on availability of funds, status of obligations and  expenditures, and payments for the receipts of goods and services. PBGC’s  Procurement Department recently invested in new procurement software  to better track acquisition data. In addition to generating reports on  workload and procurement lead times, the new software links to the  Federal Procurement Data System to report on PBGC’s contract actions as  required by the Office of Management and Budget (OMB). This system is  able to produce some aggregate data, like dollars expended, but lacks  detailed information on goods and services purchased.
section_title: PBGC Has Not Yet Taken Steps to Develop Strategic Approach to Acquisition
paragraphs: PBGC has not yet taken all the steps needed to develop a strategic  approach to acquisition. In 2000, we recommended that PBGC do so by  conducting a comprehensive review of PBGC’s future human capital needs  and using this review to better link contracting decisions to PBGC’s long- term strategic planning process. However, PBGC’s strategic plans do not  provide sufficient detail to determine what role acquisition plays in  achieving its goals. In our work on best practices, we learned that a  strategic plan should incorporate an understanding of how acquisition will  be used to help an agency achieve its mission and goals. This would enable  PBGC to better coordinate current acquisition initiatives or serve as a road  map for identifying or prioritizing future efforts. PBGC recently issued its  strategic plan, but it is not comprehensive. Although the plan states that  one of PBGC’s strategic priorities is to align resources to meet changing  workload demands and mentions flexible staffing as an indicator of  efficient operations, it does not specify how this will be accomplished or  what role contract staff will play. PBGC recently has hired a human  resources specialist to coordinate and complete the planning process  initiated in 2002 and update its human capital succession plan. PBGC also  has drafted a strategic human capital plan that acknowledges the need for  contract support, but does not provide detailed plans for how the contract  support will be obtained.
As stated earlier, NAPA provided a six-step model for PBGC to follow for  its strategic human capital planning. In response, PBGC convened a  workforce planning team that implemented some of NAPA’s suggested  steps. Although the workforce planning team acknowledged the  importance of contract staff for meeting PBGC’s unpredictable workloads,  the team’s analysis of PBGC’s future workforce focused almost entirely on  PBGC’s federal employees and not its contractor workforce. The team  recognized PBGC’s need for improvement in the area of contracting, such  as better defining where to use contractors versus federal employees,  structuring the work to ensure that federal staff retain core competencies,  and developing stronger COTR and contract monitoring competencies.  While the team’s 2002 report included an analysis of the current  competencies of PBGC’s federal workforce and PBGC’s future needs, it  did not similarly analyze the contractor workforce, which, at the time,  made up almost half of PBGC’s total workforce and now makes up almost  two-thirds. The report did not address how the contractor workforce  should change to meet future needs or how contractors should be utilized.  Although the report included a discussion of recruitment and hiring  strategies, it did not include an analysis of strategies for adding to or  subtracting from the contractor workforce in case of increased or  decreased workloads.
Further, PBGC does not use its strategic annual performance plans to  document how the acquisition function supports the agency’s missions  and goals. It is not clear how acquisition serves PBGC’s mission, because  metrics are not linked to PBGC’s overall performance plan. While the  procurement director has developed some metrics to measure the  Procurement Department’s workload, PBGC’s strategic plan only has one  broad metric related to measuring call center customer or participant  satisfaction, but there is no specific metric that enumerates the level of  customer service to be reached. Additionally, the strategic plan only has  one broad metric related to performance-based contracting, but there are  no specific metrics that relate to acquisition efficiency, effectiveness, and  results, such as measures to track the number of contracts awarded that  include incentives for performance. Performance measurements can be  used to gain insight into the Procurement Department’s current  performance level and performance over time and set realistic goals for  improvements to the acquisition process.
Finally, PBGC has taken some limited steps toward making more strategic  contracting decisions in certain specific areas. These steps generally were  taken in reaction to concerns raised about existing contracts in an internal  report and reports by us and the Office of the Inspector General. For  example, the Inspector General and PBGC each studied the contracts for  the field benefit administration offices and concluded that there were  opportunities to increase efficiency and decrease costs. As a result, PBGC  is recompeting the contracts in an effort to consolidate the number of field  benefit administration offices.
section_title: PBGC Has Made Improvements to Contractor Oversight, but Implementation of Performance-Based Contracting May Present Challenges
paragraphs: PBGC has made improvements to contractor oversight by implementing  new contract monitoring activities, improving oversight activities for some  of its major contracts, and developing comprehensive procedures to direct  contracting activities. However, most of PBGC’s current contracts lack  performance incentives and methods to hold contractors accountable.  PBGC recently began awarding more performance-based contracts, as a  means to achieve better contract outcomes, but there are common  challenges that arise—from deciding which contracts are appropriate for a  performance-based approach to deciding which outcomes to measure and  emphasize. PBGC procurement officials acknowledge the benefits and  challenges of performance-based contracting, and must provide additional  oversight of contracts and a different approach to contract monitoring that  focuses on outcomes rather than processes.
subsections: section_title: PBGC Has Made Some Improvements to Contractor Oversight
paragraphs: PBGC has improved upon existing contract monitoring activities and  implemented new activities to strengthen contract oversight. In our 2000  report, we recommended that PBGC develop the capacity to centrally  monitor field benefit administration office contractor performance  including product quality and timeliness. In response, PBGC shifted the  responsibility for contract oversight of Benefits Administration and  Payment Department (BAPD) contracts to its Management Coordination  Unit (MCU), to consolidate its monitoring of field benefit administration  office performance. The MCU uses several different methods to monitor  contracts.
The MCU reviews the 10 field benefit administration office contractors  annually to assess the accuracy of benefit determination letters and the  security procedures in place and trains analysts in contract oversight to  conduct field benefit administration office reviews. Following each  review, the office receives a report that highlights findings and requires a  corrective action plan to address deficiencies.
The MCU conducts quarterly COTR visits to the field benefit  administration offices. During these visits, COTRs conduct interviews with  key office staff and review the office’s workplans and records. The MCU  developed the COTR site visit program and a corresponding standard  protocol to be used in conducting site visits. PBGC officials told us that,  due to COTR work activities, not all site visits are being conducted as  anticipated; only one to two are being conducted per office each year.
The MCU conducts monthly compliance and data integrity reviews of field  benefit administration case processing activities. Results of these reviews  are compiled into a scorecard that is reported quarterly to the office and  the COTR. The scorecard measures BAPD processing goals for timeliness  and quality. Noncompliant items are communicated to the offices monthly  for resolution. Field benefit administration office contractors receive  feedback on the timeliness and accuracy of benefit payments based on the  MCU’s monitoring efforts.
To improve contract oversight, the Procurement Department also has  implemented refresher training requirements for COTRs. PBGC provides  guidance and training to COTRs regarding their duties and to ensure their  compliance with Procurement Department policy, federal law, regulations  and guidance, including the Federal Acquisition Regulation. PBGC is  planning to comply with a November 2007, OMB Office of Federal  Procurement Policy (OFPP) memorandum for training directed mainly at  COTRs. The memorandum establishes a structured training program for  COTRs and calls for standardization of competencies and training across  civilian agencies. The mandate requires a minimum of 40 hours of training  to be certified as a COTR. According to the requirements, new COTRs  must be certified within 6 months of appointment and existing COTRs  within a year. The Procurement Department will ensure that all COTRs  have evidence of their certification, as required by the memorandum.
PBGC recently improved its procedural guidance. In 2000, we found that  PBGC lacked such guidance on contract oversight and a central location  for guidance and procurement policies on contract oversight. Our report  noted that due to the absence of specific procedures, staff spent  significant time seeking guidance on issues, may have received conflicting  directions, and contributed to inconsistent administration practices.  Procurement Department officials recently completed a comprehensive  procedural guidance manual for staff responsible for awarding contracts  and monitoring contractor performance. According to Procurement  Department officials, the new manual should eliminate the ad-hoc  directives, e-mail, and stand-alone memorandums previously used to  address concerns. The Procurement Department’s new procedures manual  provides uniform procedures for the internal operation of acquiring  supplies and services within PBGC. The document represents a central  repository for guidance and policies. The manual has been prepared in an  electronic format, and includes relevant Internet links wherever external  references are made, such as to OMB Circulars.
section_title: PBGC’s Move toward Performance-Based Contracting Can Add Accountability but May Present Challenges During Implementation
paragraphs: Performance-based contracting offers the government the potential for  achieving better contract outcomes by requiring that all aspects of an  acquisition be structured around the purpose of the work as opposed to  the manner in which the work is to be performed. Contracts should  include descriptions of the outcomes the agency is looking for rather than  descriptions of how services should be performed, measurable  performance standards, quality assurance plans that describe how the  contractor’s performance will be evaluated, and positive and negative  incentives, when appropriate.  However, our work has shown that the  transition to and use of performance-based contracts has proven a  challenge for government agencies deeply rooted in traditional methods of  contracting.
PBGC agreed with our 2000 recommendation that it utilize contracts and  payment arrangements consistent with best practices in performance- based contracting. In 2001, OFPP directed government agencies to award  contracts using performance-based techniques for at least 20 percent of  service contracting dollars greater than $25,000 by fiscal year 2002. In  2003, OFPP recommended that executive agencies apply performance- based techniques to at least 40 percent of service contracting dollars  greater than $25,000 by 2005. PBGC began altering its acquisition strategy  to be in line with the government-wide move toward performance-based  contracting in 2003. However, PBGC to date has awarded less than $150  million in service contract dollars in fiscal year 2008 and remains short of  OFPP’s performance-based contracting goals. According to PBGC  officials, only six of its contracts currently are performance based,  representing a yearly cost of approximately $30 million for  communication, administrative, and critical function services. PBGC is in  the process of awarding an additional $20 million in performance-based  contracts for the administration of the field benefit administration offices.  Prior to the solicitation, these offices were contracted using individual  labor-hour contracts.
According to PBGC officials, most of PBGC’s current contracts lack the  methods to hold contractors accountable for their performance. One  PBGC official said existing contracts neither include the incentives needed  to encourage contractors to achieve desired results, nor do they include  performance measures and targets. Instead, PBGC staff work directly with  the contractor to communicate necessary targets. In the event that  deliverables do not match contract descriptions or there is a problem with  contractor performance, PBGC will work with the contractor to correct  that problem. By not incorporating performance targets and other  measures, PBGC depends on contractors who have limited incentive to  provide optimal service. PBGC has the option not to renew a contract with  a poorly performing contractor, but officials acknowledge the  disadvantage it faces by not providing performance incentives to help hold  contractors accountable. PBGC also has attempted to motivate  contractors by considering assessments of the contractor’s customer  service as a part of future contract renewal and is planning to incorporate  customer service measures into its contracts through the use of the  American Customer Service Index. However, the index is not completely  effective as an incentive mechanism because it does not report results for  individual contractors and instead reports on contracts collectively.
While it is important that PBGC incorporate strong performance  incentives into its contracts, the transition to and use of performance- based contracts has proven a challenge for agencies deeply-rooted in  traditional methods of contracting. In a 2002 report, we highlighted  challenges faced by agencies during their transition to performance-based  contracting. These challenges included the lack of understanding of  performance-based contracting, lack of specific agency guidance, and  inadequate oversight of contracts with performance-based methods. In  addition, while PBGC has increased the amount of training provided to  COTRs and others, the transition to performance-based contracting will  require additional training, specific to the new contracting method. In 1998  guidance, OFPP called attention to the problems agencies face in  converting from a traditional contract’s statement of work to a  performance-based work statement. Agencies reported to OFPP that  performance work statements required an increased initial investment of  time and resources. However, according to the OFPP guidance, the  savings expected by performance-based contracting will offset such costs  and correct problems commonly associated with service contracts—cost  overruns, schedule delays, and technical challenges.
Our prior work, and the work of others, also explains that both agencies  and contractors typically find it difficult to move away from traditional  contracting methods to a method of linking payments to performance,  based on specific requirements that describe results and measurable  standards of performance. Our prior work concluded that additional  government guidance on performance-based contracting was needed to  ensure its proper and effective use. PBGC officials recognize that PBGC  may face challenges similar to those faced by other government agencies  during implementation of performance-based contracting.
section_title: Conclusions
paragraphs: With three-quarters of its operational budget currently being spent on  contracting, it is clear that acquisition plays a central role in achieving  PBGC’s strategic goals. While PBGC has made efforts to improve its  acquisition infrastructure, it has not developed a strategic approach to its  contracting process as envisioned in our 2000 report. In its role as a  support function, rather than a business partner, PBGC’s Procurement  Department is not involved in helping PBGC make strategic decisions  about contracting early in the process or in developing long-term strategic  approaches. PBGC developed its most recent strategic plan and strategic  human capital plan, the latter still in draft, without a thorough examination  of the role contracting plays at PBGC. By assessing the existing  organizational alignment of the Procurement Department against a  framework of best practices, PBGC may find that its Procurement  Department is unable to effectively identify, analyze, prioritize, and  coordinate agency-wide acquisition needs. Further, PBGC’s workload  depends on future economic conditions that are difficult to predict.  Without a strategic acquisition approach, PBGC risks being unprepared for  future workload changes and cannot be assured that it has the optimal mix  of contractor staff and federal employees.
Since our last report, PBGC also has made meaningful improvements to its  contract oversight. To continue contracting improvements, PBGC’s focus  on performance-based contracting is growing—providing additional tools  to hold contractors accountable for performance and to encourage the  achievement of desired outcomes. However, this contracting method  requires a new approach to contract oversight and has demonstrated the  need for comprehensive training and organizational culture changes.  PBGC will likely face challenges similar to those we have seen faced by  other agencies that have moved toward performance-based contracting.  PBGC needs to be aware of the common pitfalls other agencies have faced  and take steps now to avoid the same challenges.
section_title: Recommendations for Executive Action
paragraphs: To improve PBGC’s performance in an environment of heavy contractor  use, we recommend that the Director of PBGC revise its strategic plan  and, in drafting the corporation’s human capital strategic plan, reflect the  importance of contracting and PBGC’s use of contractors, project its  vision of future contractor use, and better link staffing and contracting  decisions at the corporate level. In drafting the plan, the Director of PBGC  should do the following:  Include the Procurement Department in agency-wide strategic planning.
Ensure that the Procurement Director sits on PBGC’s three strategic  teams—the Operations Integration Board, the Budget and Planning  Integration Team, and the Capital Planning for Information Technology  Team.
Broaden the Procurement Department’s May 2007 staffing study to include  as part of PBGC’s agency-wide acquisition workforce those positions  outside of the Procurement Department that have a significant impact on  procurement outcomes (i.e., requirements staff, program managers,  financial managers, and individuals involved in contract monitoring). The  study should determine appropriate staffing levels for these positions as  the May 2007 study did for Procurement Department staff.
Include in PBGC’s human capital plan detailed plans for how contract  support will be obtained.
Assess PBGC’s contract information to determine if additional information  is needed to support strategic acquisition management decisions. This  could include more complete information on goods and services  purchased, as well as suppliers and spending patterns. In addition,  contract spending information should be integrated into PBGC’s financial  system, to allow acquisition staff to obtain real-time information on the  availability of funds, status of obligations and expenditures, and payments  for the receipt of goods and services.
Develop metrics for PBGC’s annual performance plan that document how  the acquisition function supports PBGC’s missions and goals. These could  include metrics related to acquisition efficiency and customer satisfaction.
To improve PBGC’s contract management as it implements a performance- based approach to contracting, we recommend that the Director of PBGC    provide comprehensive training on performance-based contracting for  PBGC’s Procurement Department staff, managers, and acquisition-related  workforce;    develop practices to help ensure accountability for the Procurement  Department staff carrying out contract monitoring responsibilities; and    ensure that future contracts measure performance in terms of outcomes,  provide incentives for the accomplishment of desired outcomes, and  ensure payment of award fees only for excellent performance.
section_title: Agency Comments and Our Evaluation
paragraphs: We obtained written comments on a draft of this report from PBGC, which  are reproduced in appendix II. In addition, we provided a copy of the draft  report to the Department of Labor for its comments, but Labor did not  provide comments.
In response to our draft report, PBGC’s Director stated PBGC’s  commitment to managing its contracting activities to obtain the best value  for the 44 million beneficiaries of its insurance program. PBGC agreed  with most of our recommendations and mentioned various ways it  planned to address them. For example, PBGC stated it understood that  other government agencies have faced challenges in implementing  performance-based contracting and plans to take steps to avoid common  pitfalls. PBGC also stated that it will be conducting a comprehensive  review of necessary staffing levels across the agency related to  procurement functions and future contracting needs, consistent with our  recommendation.
While PBGC agreed that contracting should be part of its strategic  planning process, it disagreed with our recommendation to reflect the  importance of contracting and incorporate its vision for future contractor  use into its strategic planning documents. In its comments, PBGC  maintained that its recently issued strategic plan reflects the importance of  contracting and its vision for future use.
However, we continue to believe that PBGC’s recently issued strategic  plan is not sufficiently comprehensive. PBGC’s strategic plan only briefly  mentions performance-based contracting, flexible staffing and metrics for  specific contracts, and therefore does not fully reflect the importance of  contracting in achieving its mission. For example, among eight “strategic  priorities,” contracting is not mentioned. While the plan does state that  PBGC will implement performance-based contracting for vendors in an  effort to provide good customer service to stakeholders, it does not  provide measurable goals for converting certain contracts or any time  frames for implementation. Where the plan mentions using the American  Customer Service Index as an indicator, it does not provide any detail on  how it will use the index, what its performance goals are, and how it will  measure success. In addition, the plan lacks certain key attributes of  successful performance measures, such as measurable targets with  numerical goals, and it does not include the activities that its acquisition  function is expected to perform to support the intent of PBGC’s  acquisition program.
PBGC also disagreed with our recommendation that its Director of  Procurement should sit on certain specific corporate committees. We  believe that PBGC’s Procurement Director should be included on each of  the corporation’s three strategic teams. In its comments, PBGC stated that  its Chief Management Officer represents contracting on these teams, and  that there are greater gains to be realized by emphasizing executive-level  awareness of procurement issues in decision making than by requiring the  Procurement Director to sit on the three committees. While we appreciate  PBGC’s position that executives should be aware of procurement issues in  their strategic decision making, because PBGC relies to such a great  extent on contracting, it is critical that its Procurement Director be more  involved in the corporation’s strategic planning efforts. In addition to the  Procurement Department, the Chief Management Officer currently  oversees several additional functions, such as the Budget Department and  the Human Resources Department, each vitally important to PBGC, and  each with its own challenges. It is essential that an individual well-versed  in procurement operations be more integrated into PBGC’s planning for  the future.
As agreed with your staff, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after its  issue date. At that time, we will send copies of this report to the Secretary  of Labor and to the Director of PBGC and other interested parties. We will  also make copies available to others upon request. In addition, the report  will be available at no charge on the GAO Web site at http://www.gao.gov.  If you or your staff have any questions concerning this report, please  contact me at (202) 512-7215 or bovbjergb@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 III.
section_title: Appendix I: Scope and Methodology
paragraphs: To assess the role contracting plays in the Pension Benefit Guaranty  Corporation’s (PBGC) efforts to accomplish its mission, we collected and  analyzed data on PBGC contracting activities, as well as on participants,  plans, employees, and budget trends. We also collected data to identify  trends regarding how PBGC has relied on contractors to conduct its work.  To do this, we reviewed contracting data from fiscal years 2000 through  2007. We determined that PBGC’s data were sufficiently reliable for the  purposes of this report.
To assess the steps PBGC has taken to improve its acquisition  infrastructure and develop a strategic approach, we compared PBGC’s  acquisition infrastructure to standards outlined in GAO’s acquisition  framework. Use of the framework enabled us to conduct a high-level,  qualitative assessments of the strengths and weaknesses of PBGC’s  contracting function. Specifically, we evaluated PBGC’s acquisition  infrastructure in four key areas—organizational alignment and leadership,  policies and procedures, human capital, and information management. We  also reviewed prior GAO work on best practices in strategic approaches to  the contracting and compared PBGC’s current operations to best  practices.
To identify the strategies that PBGC uses to monitor contracts, we  reviewed applicable laws, regulations, policies and guidance regarding  contract management at PBGC. Specifically, we reviewed OFPP guidance  related to performance-based contracting to understand PBGC’s  adherence with federal policy on the subject. We also conducted a  contract file review of six contract files to assess file fitness and  completeness along with monitoring and oversight improvements. To  assess the steps PBGC has taken to improve its contract oversight  processes to ensure accountability, we reviewed our findings from our  2000 report and followed up on improvements PBGC has made since then  to its contract monitoring procedures. For each objective, we interviewed  PBGC senior executives, managers, and programming and contracting  staff at headquarters, as well as selected contractors. We also interviewed  officials from PBGC’s Office of Inspector General and reviewed relevant  Inspector General reports.
We conducted this performance audit from May 2007 to August 2008, in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
section_title: Appendix II: Comments from the Pension Benefit Guaranty Corporation
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: The following team members made key contributions to this report: Blake  Ainsworth, Assistant Director; Lara Laufer and Monika Gomez, Analysts- in-Charge; Jeffrey Bernstein; Susannah Compton; Jena Sinkfield; Najeema  Washington; and Craig Winslow.
section_title: Related GAO Products
paragraphs: Pension Benefit Guaranty Corporation: Governance Structure Needs  Improvements to Ensure Policy Direction and Oversight. GAO-07-808.  Washington, D.C.: July 6, 2007.
High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January  2007.
Framework for Assessing the Acquisition Function at Federal Agencies.  GAO-05-218G. Washington, D.C.: September 2005.
Private Pensions: The Pension Benefit Guaranty Corporation and Long- Term Budgetary Challenge. GAO-05-772T. Washington, D.C.: June 9, 2005.
Contract Management: Opportunities to Improve Surveillance on  Department of Defense Service Contracts. GAO-05-274. Washington, D.C.:  March 17, 2005.
Federal Procurement: Spending and Workforce Trends. GAO-03-443.  Washington, D.C.: April 30, 2003.
Contract Management: Guidance Needed for Using Performance-Based  Service Contracting. GAO-02-1049. Washington, D.C.: September 23, 2002.
Best Practices: Taking a Strategic Approach Could Improve DOD’s  Acquisition of Services. GAO-02-230. Washington, D.C.: January 18, 2002.
Pension Benefit Guaranty Corporation: Appearance of Improper  Influence in Certain Contract Awards. T-OSI-00-17. Washington, D.C.:  September 21, 2000.
Pension Benefit Guaranty Corporation: Contract Management Needs  Improvement. T-HEHS-00-199. Washington, D.C.: September 21, 2000.
Pension Benefit Guaranty Corporation: Contracting Management Needs  Improvement. GAO/HEHS-00-130. Washington, D.C.: September 18, 2000.
High-Risk Series: An Overview. GAO/HR-95-1. Washington, D.C.:  February 1, 1995.
High-Risk Series: Pension Benefit Guaranty Corporation. GAO/HR-93-5.  Washington, D.C.: December 1, 1992.
Related PBGC Inspector General Reports  Trend Analysis Report: PBGC Procurement Issues From 2000-2007,  2007-6/CA-0036. Washington, D.C., July 26, 2007.
Evaluation of the Field Benefits Administration Concept, 2004-9/23178.  Washington, D.C., April 30, 2004.