National Security Personnel: Committed Leadership Is Needed for Implementation of Interagency Rotation Program
Published: 2015-11-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Complex national security challenges—including nuclear proliferation and terrorist attacks—require a federal government workforce that can collaborate effectively across agency lines. Congress established the section 1107 Interagency Rotation Program in which national security personnel could be assigned to work at another agency for professional development purposes and to enhance the government's ability to collaborate and respond effectively to such challenges. Section 1107 of the NDAA for Fiscal Year 2013 included a provision for GAO to review the program. This report provides an assessment of the extent to which actions have been taken to establish and implement the Interagency Rotation Program, as required by law.
GAO analyzed actions taken by the Committee and assessed its Strategy against 17 statutory requirements; reviewed other supporting documentation; and interviewed OPM, OMB, and Departments of Defense, State, and Homeland Security officials on the status of the program.
section_title: What GAO Found
paragraphs: As required by section 1107 of the National Defense Authorization Act (NDAA) for Fiscal Year 2013, the Committee on National Security Personnel (Committee) has taken steps to establish the Interagency Rotation Program for national security personnel, including developing a National Security Human Capital Strategy (Strategy). However, implementation of the program has languished and no personnel have participated in the program as of September 2015.
The Committee was established within the Executive Office of the President and consists of representatives from the Office of Personnel Management (OPM), Office of Management and Budget, the Assistant to the President for National Security Affairs, and the Departments of Defense, State, and Homeland Security. The Committee issued the Strategy in March 2014, which addresses 13 of the 17 statutory requirements. For instance, the Strategy discusses, among other things, training and education requirements, prerequisites or requirements for participation, and performance measures to be used for personnel participating in the program. The Strategy also partially addresses 2 requirements, but does not address 2 other requirements, including providing that, at a minimum, 20 employees would participate in the section 1107 program in each of the first 4 fiscal years after the NDAA was enacted. GAO had no basis to assess 2 additional requirements, also related to the program's implementation and reporting on performance measures, because these requirements are contingent on actions that had not yet occurred.
Implementing the section 1107 Interagency Rotation Program has languished because there has been limited leadership and oversight of the program, including necessary actions to be taken by the departments, agencies, and other organizations to complete their assigned roles, responsibilities, and tasks. The Strategy and other documents specifically assign roles, responsibilities, and tasks to the Committee on National Security Personnel, OPM, the Communities of Practice, and the participating departments and agencies. For instance, OPM is tasked with issuing guidance on the rights and responsibilities of employees returning from rotational service, but OPM officials told GAO that they have not done so and could not give timeframes for completion. Similarly, participating departments and agencies are tasked with identifying particular positions and personnel for rotations, but they have not used the procedures laid out in the Strategy because officials said they needed further guidance from OPM. OPM officials stated that the departments and agencies do not need further guidance from them to proceed with their assigned roles, responsibilities, and tasks. Importantly, the Strategy specifically identifies that the Committee will work with OPM to implement the Strategy. Further, officials that GAO interviewed stated they perceive that OPM is the lead for the program. Officials also noted that differing opinions about next steps have resulted in action not being taken on some assigned roles, responsibilities, and tasks, including the issuance of guidance. Without a clear leadership and oversight structure for the section 1107 program and efforts to identify and take action on next steps for implementation, it is unlikely that implementation of the program will move forward.
section_title: What GAO Recommends
paragraphs: GAO recommends that OPM, in collaboration with the Committee, establish a clear leadership and oversight structure to guide implementation of the Interagency Rotation Program and work with the departments and agencies to identify and take action on necessary next steps for implementation. OPM generally concurred with the recommendations, but raised issues primarily about the roles and responsibilities that GAO addresses in the report.

section_title: Letter
paragraphs: The complex national security challenges of the 21st century—such as  nuclear proliferation, terrorist attacks, and natural disasters—require a  U.S. federal government workforce that can collaborate effectively across  agency lines. Effective interagency rotational assignments, in which  participants are assigned to work at another agency for the purpose of  professional development, can help achieve collaboration-related  results—for example, developing participants’ collaboration skills and  building interagency networks. More effective interagency collaboration is  key to U.S. national security and personnel involved with national security  and can help improve the government’s ability to respond efficiently and  effectively to challenges, both at home and abroad. In 2013, to help foster  greater interagency experience among executive branch personnel on  national security and homeland security matters, Congress, in section  1107 of the National Defense Authorization Act (NDAA) for Fiscal Year  2013, established the Committee on National Security Personnel  (Committee) within the Executive Office of the President and required the  development and issuance of a human capital strategy that was to  provide the policies, processes, and procedures for implementing an  interagency rotation program for national security personnel.
Section 1107 of the NDAA for Fiscal Year 2013 included a provision for  us to review the section 1107 Interagency Rotation Program and report to  Congress by September 30, 2015. Specifically, this report provides an  assessment of the extent to which actions have been taken to establish  and implement the section 1107 Interagency Rotation Program, as  required by law.
To accomplish this objective, we obtained and analyzed information on  the Committee’s actions and its strategy for implementing the section  1107 Interagency Rotation Program. The documents we reviewed  included the Committee’s The Human Capital Strategy for Interagency  Personnel Rotations (Strategy). We assessed the extent to which the  Committee’s actions and the Strategy met the statutory requirements in  section 1107 of the NDAA. To conduct this assessment, two analysts— using a scorecard methodology—independently reviewed and scored the  Strategy and identified whether it (1) addresses, (2) partially addresses,  or (3) does not address the statutory requirements. The analysts  assigned a rating of “addresses” if all elements of a legislative  requirement were cited in the Strategy, even if specificity and details  could be improved upon, or if all elements of a required action were  taken. The analysts assigned a rating of “partially addresses” if the  Strategy or associated actions did not include all of the elements of a  legislative requirement. A rating of “does not address” was assigned in  instances when no elements of a requirement were explicitly discussed or  if any implicit references were either too vague or too general to be  useful. The analysts then met to discuss any differences in their  respective independent analyses and all differences were resolved in this  manner. Subsequently, a representative from our Office of General  Counsel served as an independent third party reviewer of the analysis.  Any differences between the team’s rating and general counsel’s rating  were resolved through discussion and review of evidence. The analysts  also solicited input from a methodologist before assigning a final score.
We obtained and analyzed additional program-related documents,  including the Committee on National Security Personnel meeting minutes,  to supplement the results of our compliance assessment and identify the  progress made in implementing the program. We also interviewed  knowledgeable officials from the implementing and participating  departments and agencies—the Office of Personnel Management (OPM),  the Office of Management and Budget (OMB), the Department of Defense  (DOD), the Department of Homeland Security, and the Department of  State—about the status of the program and steps taken to address the  statutory requirements and assigned roles, responsibilities, and tasks,  among other things. We attempted to contact and meet with staff from the  Executive Office of the President through the National Security Council,  but officials were unable to meet with us and answer our questions during  the timeframes required by our review. We also interviewed three  Community Managers—Emergency Management, Federal Operations  Centers, and Defense Intelligence and Security—to identify the status of  their efforts to implement the section 1107 Interagency Rotation  Program. Specifically, we discussed the extent to which steps, such as  developing further guidance and conducting rotational assignments, have  occurred. We reviewed prior GAO work on managing for results and other  interagency coordination and collaboration efforts, as well as internal  control standards, to determine the extent to which the efforts of the  Committee, participating departments and agencies, and Communities of  Practice are consistent with identified practices for implementing  successful interagency efforts, such as clarity of roles and responsibilities,  and other programs.
We conducted this performance audit from May 2015 to November 2015  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.
subsections: section_title: Background
subsections: section_title: Statutory Requirements and Organizational Responsibilities for the Section 1107 Interagency Rotation Program
paragraphs: Section 1107 of the NDAA for Fiscal Year 2013 established the  Committee on National Security Personnel within the Executive Office of  the President. The Committee was required to include, at a minimum,  representatives from OMB, OPM, the Assistant to the President for  National Security Affairs, DOD, and the Departments of State and  Homeland Security. As part of the implementation of the section 1107  Interagency Rotation Program, the statute required the policies,  processes, and procedures included in the Strategy to provide that the  program be carried out in at least two Interagency Communities of  Interest—Emergency Management and Stabilization and  Reconstruction—and that no fewer than 20 executive branch employees  be assigned to participate in the program in each of the first 4 fiscal years  after the enactment of the NDAA for Fiscal Year 2013—fiscal years 2014,  2015, 2016, and 2017. Section 1107 indicated that the purpose of the  program was to increase the efficiency and effectiveness of the  government by fostering greater interagency experience among executive  branch personnel on national security and homeland security matters  involving more than one agency.
Section 1107 defines an “Interagency Community of Interest” as positions  in the executive branch of the government that (1) as a group, are  positions within multiple agencies of the executive branch of government;  and (2) have significant responsibility for the same substantive, functional,  or regional subject area related to national security or homeland security  that requires integration of the positions and activities in that area across  multiple agencies to ensure that the executive branch of the government  operates as a single, cohesive enterprise to maximize mission success  and minimize cost. Additionally, the Strategy defines “Community of  Practice” as a Community of Interest that has, among other things,  identified members to engage in joint activities, experiences, and  discussions and share information as an identified network. For  example, according to the charter for the Emergency Management  Community of Practice, the community will advance whole-of-government  goals pertaining to national preparedness through unified, collaborative,  interagency approaches to the prevention of, protection from, response  to, recovery from, and mitigation of manmade and natural disasters. This  will be accomplished by providing integrated education, training, and  experiential activities to promote familiarization with emergency  management missions, operations, and interagency structures across the  federal government and to optimize operational planning and execution.
section_title: The National Security Professional Development Program
paragraphs: Prior to the establishment of the section 1107 program, in May 2007,  Executive Order 13434 established the National Security Professional  Development Executive Steering Committee and designated OPM as its  chair. Executive Order 13434 also called for the development of a  strategy that set forth a framework that would become the National  Security Professional Development (NSPD) Program—we will discuss the  status of this program later in the report. The NSPD Program’s goal was  to promote the education, training, and experience of current and future  professionals in national security positions. To facilitate the  implementation of the NSPD Program, the Executive Steering Committee  established an Integration Office, which was originally housed at DOD  and staffed by employees from other departments and agencies on  temporary detail assignment. In 2012, the NSPD Integration Office was  moved from DOD to OPM. Appendix I provides key dates in the  establishment and implementation of both the section 1107 Interagency  Rotation Program and NSPD Program.
section_title: GAO’s Prior Work on Interagency Coordination and Collaboration Efforts
paragraphs: In 2010, we identified 225 professional development activities available  for national security professionals that have a goal of improving  interagency collaboration. Of the 225 activities, 7 were interagency  rotation programs. Five of these seven programs involved rotating  personnel between civilian agencies and the defense community. During  that review, many departments and agencies reported the existence of  other interagency assignments, but we found that the departments and  agencies did not manage these as professional development programs  and they lacked an explicit goal of improving interagency collaboration.  The NSPD Program, which resulted from Executive Order 13434, was  included as one of the professional development activities identified by  this review.
GAO also has a large body of work on the need for interagency  coordination and collaboration to facilitate the federal government’s  response to natural disasters and homeland security issues, among other  things. Although this body of work does not directly call for an interagency  rotation program similar to the section 1107 Interagency Rotation  Program, it highlights the continued importance of improving interagency  coordination and collaboration, more than a decade after catastrophic  events such as the terrorist attacks of September 2001 and Hurricane  Katrina in August 2005. For example, in 2006, we found that key issues  with the federal response to Hurricane Katrina—the largest, most  destructive natural disaster in our nation’s history—were reminiscent of  the issues identified in the wake of Hurricane Andrew in 1992. Among  other things, clearly defining and communicating leadership roles,  responsibilities, and lines of authority for catastrophic event response and  clarifying and applying procedures for activating the National Response  Plan could have improved the federal government’s response efforts after  Hurricane Katrina. See Appendix II for additional information on our  prior work identifying the need for interagency coordination and  collaboration.
section_title: Committee on National Security Personnel’s Strategy Addressed Most Statutory Requirements, but Implementation of the Program Has Languished
paragraphs: In March 2014, the Committee issued the Strategy required by section  1107 of the NDAA for Fiscal Year 2013. The Strategy complies with most  of the statutory requirements and describes the basic policies, processes,  and procedures for the section 1107 Interagency Rotation Program.  However, implementation of the program has languished because there  has been limited leadership and oversight of the program, and no national  security personnel had been assigned for rotations as of September  2015. The departments and agencies also cited various actions that  needed to be taken in order for the section 1107 program to be  implemented in a timely manner. Examples of these actions include the  development and issuance of guidance outlined in the Strategy.
subsections: section_title: The Committee on National Security Personnel Developed and Issued a Strategy that Addresses Most of the Statutory Requirements
paragraphs: In addition to establishing the Committee on National Security Personnel,  section 1107 of the NDAA for Fiscal Year 2013 required the Committee to  develop and issue a National Security Human Capital Strategy that  provided for the implementation of an interagency rotation program. On  March 29, 2014, the Committee issued the required National Security  Human Capital Strategy—entitled The Human Capital Strategy for  Interagency Personnel Rotations.
Our analysis of the Committee’s actions and the Strategy showed that  they address most of the statutory requirements set forth in section 1107.  Section 1107 included 19 requirements related to the development and  issuance of the Strategy and the subsequent implementation and  monitoring of the section 1107 program. However, for 2 of these  requirements we had no basis to judge, because these requirements are  contingent on actions that had not yet occurred, and, therefore, we did not  assess these requirements.
We found that the Committee’s actions and its Strategy address 13 of the  17 statutory requirements we assessed, for example, by (1) including  provisions that specifically address the requirements, such as by  including specific policy requirements; (2) assigning various departments  and agencies tasks, such as developing policy or guidance; and (3)  directing other organizations, including the Communities of Practice, to  carry out the section 1107 program. We also found that the Committee’s  actions and the Strategy partially address 2 and do not address 2 of the  17 statutory requirements we assessed. Appendix III includes our  assessment of the Committee’s and Strategy’s compliance with each of  the 17 section 1107 requirements we could assess.
Among the 13 requirements addressed, we found that the Strategy  identifies Interagency Communities of Interest for the purposes of  carrying out the section 1107 program. The Strategy specifically  identifies the two Communities called for in section 1107—Emergency  Management and Stabilization and Reconstruction—but also names other  possible Communities, including cyber-security, climate change  adaptation, and energy security, among others. We also found that the  Strategy discusses (1) training and education requirements; (2)  prerequisites or requirements for participation; and (3) performance  measures, reporting requirements, and other accountability devices  associated with participation in and evaluation of the program.
We found that the Strategy partially addresses 2 of the 17 requirements.  Those are the requirements that (1) the Committee issue a National  Security Human Capital Strategy within 270 days of enactment of the  statute and (2) the Strategy designate agencies to be included or  excluded from the program. The Committee issued the Strategy on  March 29, 2014, but it was 6 months late and, therefore, did not meet the  required deadline. In addition, the Strategy states that the Committee will  determine which departments and agencies will participate as each  Community is formed, and that a process will be described in further  detail in a subsequent part of the Strategy. We determined that these  statements make reference to a process for making decisions about  which agencies and departments will participate; however, we found that  the Strategy does not designate which departments and agencies will be  included or excluded, as called for in section 1107. The Strategy does,  however, state that agencies with national security missions will  incorporate the Strategy into their training priorities.
We found that the Strategy does not address 2 of the 17 requirements.  Specifically, it does not address the requirements for the Strategy’s  policies, processes, and procedures to provide that in each of the 4 fiscal  years after enactment of the NDAA for Fiscal Year 2013 (1) the section  1107 Interagency Rotation Program shall be carried out in at least two  Communities of Interest—one of which should be Emergency  Management and the other Stabilization and Reconstruction; and (2) at  least 20 employees should be assigned to participate in the program.  We found that the Strategy only reiterates that the statute identifies the  Emergency Management and the Stabilization and Reconstruction  Communities and allows for additional Communities to be added, subject  to approval by the Committee. However, the Strategy does not provide  that, at a minimum, the program would be carried out in at least the two  designated Interagency Communities of Interest or by at least 20  employees in each of the first 4 fiscal years after the NDAA was  enacted. Specifically, the Strategy is silent on the number of participants  that would rotate through the program and does not provide assurance  that the rotations should occur each year in at least the two named  Communities. As we discuss further in the next section, to date, no  rotations have occurred under the section 1107 program.
Finally, there were two statutory requirements for which we had no basis  to judge. These are requirements for (1) the heads of each participating  agency to help ensure that strong preference is given to those who  participate in interagency rotational service when selecting individuals for  senior positions; and (2) the Committee to assess and report on the  established performance measures by September 30, 2015. With regard  to the first requirement, because no rotations have occurred under the  section 1107 program, we cannot assess whether agency heads have  given such a preference to participants. With regard to the second  requirement to assess and report on established performance measures,  as discussed in the next section of this report, because the section 1107  program has not been implemented, we could not assess compliance  with this requirement due to the reporting date. Further, our draft report  and the report on performance measures were due on the same day.
section_title: Agencies and Organizations Have Taken Limited Steps to Address Assigned Roles, Responsibilities, and Tasks to Implement the Interagency Rotation Program
paragraphs: Agencies and organizations have taken limited steps to address the roles,  responsibilities, and tasks assigned to them in the Strategy for  implementing the section 1107 Interagency Rotation Program, and they  had not implemented that program as of September 2015. More  specifically, no rotational assignments have occurred. By September 30,  2015, at least 40 employees should have been assigned to rotational  assignments (20 each in fiscal years 2014 and 2015). Agency officials  report that, as of September 2015, no employees had been assigned to  rotations under the section 1107 program. According to officials we spoke  with and documents we reviewed, the program’s implementation is  behind schedule because (1) there has been limited leadership and  oversight over its implementation and (2) a number of actions need to be  completed to address some of the roles, responsibilities, and tasks  assigned to the departments and agencies.
As noted above, the Committee on National Security Personnel issued  the Strategy that assigned specific roles, responsibilities, and tasks to the  various entities—OPM; the NSPD Executive Steering Committee, which  OPM chairs; the participating departments and agencies; and the  Communities of Practice—to implement the section 1107 Program.
Table 1 summarizes the major roles, responsibilities, and tasks the  Strategy assigned to the departments, agencies, and other organizations,  as well as those the Committee reserved for itself.
We identified other roles, responsibilities, and tasks assigned to the  departments and agencies, among others, during our review of  supporting documentation, including meeting minutes, organization  charters, and implementation plans. For example, the charter for the  Emergency Management Community of Practice states that OPM will  lead the Committee to implement an interagency rotation system that  complies with the law. The charter also states, for example, that the  Department of Homeland Security will designate the Community Manager  for the Emergency Management Community of Practice. We also found  that assignments were made to departments and agencies during NSPD  Executive Steering Committee meetings. These assignments were  documented in the form of action items included in the minutes of the  meetings and included creating inventories of current rotational  assignment opportunities from participating departments and agencies  and developing further guidance on personnel issues from OPM.
We found, however, that implementation of the section 1107 Interagency  Rotation Program is behind schedule because there has been limited  leadership and oversight in place to guide the implementation effort and  because a number of actions need to be completed to address some of  the roles, responsibilities, and tasks assigned to the departments and  agencies to help ensure the program is implemented in a timely manner.  Officials we spoke with from OPM and the departments were not aware of  the existence of a charter or similar document for the Committee, which  we would expect to identify an organizational structure that clearly defines  key areas of authority and responsibility and establish appropriate lines of  reporting. With regard to leadership, officials we spoke with stated that  the section 1107 program has not been a priority for those individuals  currently overseeing the Committee. OPM officials also told us that they  are not responsible for the performance of the section 1107 program  because (1) they are not the lead for the Committee on National Security  Personnel and (2) the NSPD Executive Steering Committee, which holds  joint meetings with the Committee on National Security Personnel, is  more of a collaborative effort of the participants. However, officials from  multiple participating departments stated that they perceive OPM to be  the lead for the section 1107 Interagency Rotation Program and look to  the agency for leadership based on its role in the oversight of federal  government personnel issues. Neither section 1107 or the Strategy  specifies who should be the lead or chair for the Committee on National  Security Personnel; however, OPM has been designated the chair of the  NSPD Executive Steering Committee and, more importantly, the Strategy  specifically identifies that the Committee will work with OPM to implement  the Strategy.
Officials from departments and agencies we interviewed told us that an  office to oversee the section 1107 Interagency Rotation Program has not  been established, but was needed. The managers for all three currently  existing Communities of Practice also identified the need for a program  office to help oversee and ensure the accountability of the implementation  efforts, among other things. Further, officials told us that the individuals  who have been tasked with carrying out the implementation of the section  1107 program and sit on the Committee have other responsibilities. For  those individuals, responsibilities associated with the section 1107  program are collateral duties. Officials noted that the meetings of the  NSPD Executive Steering Committee, which, as noted above, are held  jointly with the Committee on National Security Personnel, are  infrequent—with meetings being scheduled with only a few weeks’ notice  or canceled. They also stated that very little communication or progress  occurs on any task between meetings, further slowing the implementation  of the section 1107 Interagency Rotation Program.
Several documents identify OPM’s leadership roles with regard to  developing further guidance and implementing the section 1107  Interagency Rotation Program, but we found that the existing leadership  structure is not providing needed oversight of the program’s  implementation. For example, OPM has an additional leadership role, in  its capacity as the chair of the NSPD Executive Steering Committee, to  provide oversight over the Communities of Practice through periodic  updates from the Communities. As of September 2015, three  Communities of Practice—Emergency Management, Federal  Operations Centers, and Defense Intelligence and Security—had been  approved by the NSPD Executive Steering Committee, which OPM  chairs, and for which the NSPD Executive Steering Committee would  have oversight responsibilities. One Community Manager stated that in  2014, when the Intelligence Community, which had previously established  the Joint Duty Assignment program, submitted a charter for the Defense  Intelligence and Security Community of Practice to be considered and  approved by the NSPD Executive Steering Committee, it took OPM—as  chair of the NSPD Executive Steering Committee—months to process the  request and move it forward to the Committee on National Security  Personnel for final approval, delaying the establishment of the  community. According to OPM officials, Community Managers’ oral  presentations at the NSPD Executive Steering Committee meetings  provide the necessary oversight of the actions of the Communities of  Practice. However, two of the three Communities’ charters require that  additional written reports be provided to the NSPD Executive Steering  Committee for oversight. One Community Manager reported that he had  only been invited to provide oversight updates at the meetings starting in  2015, despite serving in the role since December 2013. That same  manager had previously been unaware that the Strategy had been issued  and that the Strategy required the Communities to develop performance  metrics. Further, that Community Manager also stated the NSPD  Executive Steering Committee recently began requesting information on  the community’s performance metrics and first sent a document template  in mid-August 2015 that requested performance information by the end of  that month.
Department and agency officials we spoke with also cited a number of  actions that are needed in order for them to complete some of their  assigned roles, responsibilities, and tasks, including steps that need to be  taken and in what order to implement the section 1107 program. For  example, OPM officials stated that their agency has not yet issued the  personnel guidance required by the Strategy, but were unable to provide  timeframes for when the guidance would be issued. Officials from  participating departments told us they could not proceed with taking  action on their tasks because they were waiting for further guidance from  OPM. Those officials also told us that their departments have not taken  steps to update previous lists of identified national security positions and  personnel—another assigned task—because, according to officials from  one of the departments, they are waiting for further guidance from OPM  on the criteria for selecting employees and positions for participation in  the program. Department officials also told us that they are waiting for  guidance on how to develop policies for providing preference to those  employees who had previously participated in the section 1107 program  when they apply for senior level positions. DOD officials stated that  they, as well as representatives from other departments and agencies,  have requested guidance from OPM at least twice at NSPD Executive  Steering Committee meetings and had not, as of September 2015,  received such guidance. When asked about the need for such guidance,  OPM officials stated that the departments and agencies do not need  additional guidance from OPM to proceed with their assigned roles,  responsibilities, and tasks under the Strategy. Although section 1107  requires the head of each agency to take certain actions to incorporate  preference for the selection of individuals to senior positions and the  Strategy requires the departments and agencies to select personnel and  positions to participate in the program, confusion about such roles,  responsibilities, and tasks has contributed to delays in the section 1107  program’s implementation.
In 2012, we found that federal departments and agencies use a variety of  mechanisms to implement interagency collaborative efforts that can be  used to address a range of purposes including policy development,  program implementation, oversight and monitoring, information sharing  and communication, and building organizational capacity. Specifically,  we found that, to implement interagency collaborative mechanisms,  federal agencies should, among other things, consider (1) leadership; (2)  clarity of roles and responsibilities, and (3) outcomes and accountability.  Such considerations should include plans to sustain leadership over time,  clearly identified and agreed upon roles and responsibilities, and tracking  and monitoring of progress. In addition, with regard to actions not taken  by the departments and agencies to implement the program, internal  control standards state that management needs to comprehensively  identify risks and should consider all significant interactions to  accomplishing a stated objective. Risk identification methods may include  qualitative and quantitative ranking activities, management conferences,  and considerations of findings from audits and other assessments, among  other things.
Without committed leadership and oversight from all of the relevant  entities—most specifically, the Committee on National Security Personnel  and OPM—to oversee the implementation of the section 1107  Interagency Rotation Program and actions taken on necessary steps to  proceed with the program’s implementation, it is unlikely that the goals of  section 1107 of the NDAA for Fiscal Year 2013 will be addressed and that  the section 1107 program will be implemented within the specified  timeframes. Further, the executive branch will not be positioned to realize  the expected benefits of the program, which could include improved  interagency coordination and integration in preparing for and responding  to national security challenges, among other things.
section_title: Conclusions
paragraphs: Over a decade after catastrophic events such as the terrorist attacks of  September 2001 and Hurricane Katrina in August 2005, interagency  coordination and integration continue to be a challenge for the federal  government’s national security and homeland security missions.  Providing opportunities for national security personnel to gain interagency  experience can benefit not only those individuals, but also enhance  interagency coordination and integration. The section 1107 Interagency  Rotation Program for national security personnel, when implemented,  could support these goals. However, limited leadership and oversight, as  well as inaction on a number of assigned roles, responsibilities, and tasks  have caused the program’s implementation to languish. Until OPM, the  Committee on National Security Personnel, departments and agencies,  and other organizations take actions necessary to move forward with  implementation, the program is likely to remain unrealized. Without a  clear leadership structure for the Committee that can work with  departments and agencies to identify and take action on any steps that  are necessary for the program’s implementation, Congress’s intentions  for the program and the benefits that could stem from it will also remain  unfulfilled.
section_title: Recommendations for Executive Action
paragraphs: To provide greater assurance that the Interagency Rotation Program for  national security personnel will be implemented as provided in section  1107 of the National Defense Authorization Act for Fiscal Year 2013, we  recommend that the Director of the Office of Personnel Management, in  collaboration with the Committee on National Security Personnel, take the  following two actions:  (1)  establish a clear leadership and oversight structure to guide future  (2)  work with the departments and agencies to identify and take action on  necessary next steps to proceed with the program’s implementation,  including developing and issuing required guidance for  implementation within identified timeframes.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided OPM, OMB, DOD, the Department of State, the Department  of Homeland Security, and the National Security Council with a draft of  this report for comment. OMB, DOD, the Department of Homeland  Security, and the National Security Council had no comments on our draft  report. The Department of State provided technical comments, which we  considered and incorporated where appropriate. In comments on a draft  of this report, OPM partially concurred with one recommendation and  concurred with the second recommendation. OPM’s comments are  reprinted in their entirety in appendix IV.
In its response, OPM stated that our draft report made recommendations  only to OPM, despite section 1107 establishing the Committee within the  Executive Office of the President and delegating program and policy  responsibilities to the heads of participating departments and agencies.  We believe that this characterization misconstrues our recommendations.  As our report shows, OPM’s role with regard to the section 1107  Interagency Rotation Program includes responsibilities specific to OPM,  but also responsibilities to act in collaboration with other departments and  agencies based on its roles as a member of the Committee on National  Security Personnel and as the Chair of the NSPD Executive Steering  Committee. To that end, both of our recommendations were not directed  solely to OPM, but rather to OPM in collaboration with the Committee on  National Security Personnel, as a joint effort. As specified in section 1107,  the Committee is comprised of multiple departments and agencies,  including OPM, OMB, and DOD, among others. Moreover, our second  recommendation also includes working with the departments and  agencies when identifying and taking action on next steps for the  program’s implementation. OPM is not the sole recipient or target of our  recommendations, but OPM and the Committee on National Security  Personnel are both focal points because of their responsibilities.
OPM also stated that table 1 of our report oversimplifies the Committee’s  delegation of responsibilities to the various departments and agencies.   We find this table an appropriate portrayal of the roles and responsibilities  specifically outlined in the Strategy as the table describes only the major  roles and responsibilities, which was our intent. In addition, in its  response to our draft report, OPM criticized our methodology for not  including interviews with the Executive Office of the President in our  review. As we stated in our report, we made multiple attempts to meet  with the Executive Office of the President through the National Security  Council, but they were unable to meet with us during the statutory  timeframes required by our review. However, when provided the  opportunity to comment on our draft report, the National Security Council  responded that it did not have any comments on our report. As a result,  we worked with OPM, as well as the other departments and agencies, to  obtain necessary clarification on the roles and responsibilities, the  distinction between the work carried out by the two committees, and the  status of the program’s implementation, among other things.
Regarding our first recommendation to establish a clear leadership and  oversight structure to guide future implementation efforts, OPM partially  concurred. OPM stated that it agrees that a more formal system of  reporting to the NSPD Executive Steering Committee and more frequent  Executive Steering Committee review of performance metrics would  improve the program’s accountability. However, OPM added that it cannot  establish a charter or leadership structure for the program as a whole,  because it would contravene section 1107(b) of the National Defense  Authorization Act for Fiscal Year 2013, which established the Committee  as the policy lead on national security personnel rotations and specified  OPM as only one of several participating agencies.
We agree that such steps may help improve the program’s accountability,  but we disagree with OPM’s assessment of our recommendation— particularly the portion about a clear leadership structure. Specifically, we  do not intend for OPM to act unilaterally, and we reiterate that our  recommendation is directed at OPM in collaboration with the Committee.  Further, as stated in our report, the Emergency Management Community  of Practice charter—which was revised after the enactment of section  1107, approved by the NSPD Executive Steering Committee, and signed  by the Chief Operating Officer of OPM—states that OPM will lead the  Committee on National Security Personnel to implement an interagency  rotation program that complies with the law. This statement clearly  articulates OPM’s key role in the implementation of the system. Moreover,  during the course of our review, officials we met with from the  departments that comprise the Committee pointed to OPM as having a  lead role in the program’s implementation and those officials continue to  look to OPM for direction and guidance.
Regarding our second recommendation to identify and take action on  necessary next steps to proceed with the program’s implementation,  including developing and issuing required guidance for implementation  within identified timeframes, OPM concurred. OPM agreed with our  assessment that OPM has not issued two guidance documents required  by the Strategy and has agreed to develop at least two guidance  documents, including, for example, guidance specifically addressing  performance appraisals for employees participating in interagency  rotations.
We appreciate OPM’s acknowledgment of its responsibility to produce  these guidance documents, but we believe that these statements miss  the intent of our recommendation and will only address the  recommendation in part. We continue to believe that OPM—in its capacity  as both a member of the Committee and as the Chair of the NSPD  Executive Steering Committee—needs to work with the Committee and  the other departments and agencies to determine the steps needed to  proceed with the implementation of the program. These steps may  include OPM’s issuing additional guidance, but also may include, for  example, identifying timeframes for next steps to help ensure  implementation within the timeframes identified in section 1107. More  specifically, the steps we identify here and in our report, including the  aforementioned guidance documents, may not include all of the steps  necessary to help ensure the implementation of the program. Thus, we  continue to believe that OPM should work with the Committee and the  departments and agencies to determine necessary next steps.
We are sending copies of this report to the appropriate congressional  committees, the Director of the Office of Personnel Management, the  Director of the Office of Management and Budget, the Secretary of  Defense, the Secretary of Homeland Security, the Secretary of State, and  other interested parties. In addition, this report is available at no charge  on the GAO website at http://www.gao.gov.
If you or your staff has any questions regarding this report, please contact  me at (202) 512-3604 or farrellb@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 major contributions to this report  are listed in appendix V.
section_title: Appendix I: Timeline of Key Implementation Dates
paragraphs: The following timeline identifies key dates in the establishment and  implementation of the section 1107 Interagency Rotation Program and  the National Security Professional Development (NSPD) Program.  Section 1107 of the National Defense Authorization Act (NDAA) for Fiscal  Year 2013 established the Committee on National Security Personnel and  required the development and issuance of a National Security Human  Capital Strategy that was to provide for the implementation of an  interagency rotation program with the intent of increasing the efficiency  and effectiveness of the federal government by fostering greater  interagency experience among executive branch personnel on national  security and homeland security matters. Prior to the establishment of the  section 1107 program, in May 2007, Executive Order 13434 established  the NSPD Executive Steering Committee to facilitate the implementation  of a national strategy that set forth the framework for what would become  the NSPD Program.
section_title: Appendix II: Prior GAO Work on Interagency Collaboration and Coordination
paragraphs: GAO has a large body of work highlighting interagency coordination and  collaboration efforts across the federal government, as well as the need  for such efforts to facilitate national security and homeland security  operations, among other things. For example, in 2009, we highlighted  past work that identified situations in which a lack of interagency  coordination and collaboration hindered national security objectives. The  following provides summary examples of how interagency coordination  and collaboration could have been improved over the last decade and  how interagency rotations among personnel could improve collaboration  and coordination.
In the years after the terrorist attacks on September 11, 2001, we  found that multiple federal agencies took action to address challenges  and strategies in fulfilling our national security objectives, such as  instituting interagency collaboration through intelligence sharing;  however, in 2004, we continued to identify further actions that could  be taken to fully address these needs. For example, the Federal  Bureau of Investigation established a National Joint Terrorism  Taskforce to assist with information sharing between agencies.  However, we noted that a comprehensive and coordinated national  plan to facilitate information-sharing on critical infrastructure was  needed.
Between 2005 and 2008, we found that multiple federal agencies— including the Department of Defense (DOD), the Department of State,  and the U.S. Agency for International Development—participated in  efforts to build the capacity of key Iraqi ministries to govern the  country. Our work found that there was no overarching direction and  coordination from a lead entity, which contributed to U.S efforts not  meeting their goal of key Iraqi ministries having the capacity to govern  reconstruction projects.
In 2010, we found that coordination with federal partners is essential  to DOD’s homeland security mission—including homeland defense  and civil support. To improve coordination, we recommended that the  department (1) establish a timeline and update and ensure the  integration and comprehensiveness of DOD policy and guidance that  delineates the roles and responsibilities of and relationships between  DOD entities; (2) establish a timeline to develop and issue a partner  guide that identifies the roles and responsibilities of DOD entities,  processes, and agreed-upon approaches for interagency coordination  for homeland defense and civil support efforts; (3) ensure  implementation of DOD’s current instruction on the tracking of DOD  liaisons’ assignments to other federal agencies, as well as the  establishment of position descriptions for uniformed military and DOD  civilian personnel; and (4) develop and issue additional workforce  management policy and guidance regarding DOD liaisons to other  federal agencies, as well as other federal agencies’ liaisons to DOD,  to include routine staffing needs-assessments and position  descriptions, among other things. DOD concurred with all four  recommendations we made and has taken action to address those  recommendations.
In 2010, we found that the activities of U.S. Southern Command  demonstrated a number of key practices that enhance interagency  coordination and collaboration to achieve their mission objectives.  However, the military relief efforts in response to the 2008 earthquake  in Haiti challenged the organizational collaborative structure of U.S.  Southern Command. Specifically, we found that initial relief efforts  were hindered by weaknesses in the command’s organizational  structure and a lack of augmentation planning. We concluded that the  U.S. Southern Command must have a structure that is not only  prepared for military activities, but that can also be effective in  supporting other stakeholders or interagency groups in meetings  challenges like corruption, crime, and poverty in the region.
In 2012, we found that Department of State and Department of  Defense’s rotational assignment programs, which include State’s  Foreign Policy Advisor Program and the Army Command and General  Staff College Interagency Fellowship program, help achieve  collaboration-related results, as reported by program participants in a  survey. Effective interagency rotation programs can achieve  interagency collaboration results, by developing program participants’  collaboration skills and building interagency networks. To build on the  success of these programs, we made seven recommendations to the  Department of State, which included (1) expand the scope of current  efforts by routinely evaluating the Foreign Policy Advisor Program’s  effectiveness to determine if desired results are being achieved; (2)  clarify how assignments will achieve shared national security goals;  (3) work with host agency counterparts to develop orientation  materials to maximize the benefit of the rotation; (4) routinely evaluate  the effectiveness of State’s interagency rotations to other government  agencies to determine if desired results are being achieved for  participating individuals and agencies; (5) improve incentives for civil  service personnel to participate in interagency rotations by providing  guidance to supervisors on how to consider interagency experience  for, among other things, ratings and awards; (6) improve incentives for  supervisors to support civil service personnel’s participation in  interagency rotations by establishing performance expectations that  supervisors share human resources; and (7) develop guidance on  how to ensure that the knowledge, skills, and networks gained during  rotation can be used upon the personnel’s return. Additionally, we  recommended that the Secretary of Defense (1) work with host  agency counterparts to develop orientation materials to maximize the  benefits of the rotational assignment and (2) routinely evaluate the  effectiveness of the program to determine if desired results are being  achieved.
More recently, in 2014, we found that interagency collaboration is  necessary for assessing and closing capability gaps in federal  agencies’ emergency support functions for unexpected catastrophic  disasters—such as an earthquake or improvised nuclear device.
Lessons learned from the federal response to Hurricane Sandy  underscored the importance of assessing gaps in interagency  emergency response preparedness. The National Security Council’s  after action report identified challenges that delayed the federal  government’s response to the disaster. One such challenge was that  some response efforts were conducted through intra-department  approaches, rather than as part of a coordinated, integrated  approach.
section_title: Appendix III: GAO’s Compliance Assessment of the Section 1107 Requirements
paragraphs: On March 29, 2014, the Committee on National Security Personnel  issued the required National Security Human Capital Strategy—entitled  The Human Capital Strategy for Interagency Personnel Rotations  (Strategy)—in response to requirements set forth in section 1107 of the  National Defense Authorization Act for Fiscal Year 2013.  The statute  included 19 requirements related to the development and issuance of the  Strategy and the subsequent implementation and monitoring of the  section 1107 Interagency Rotation Program; however, for 2 of these  requirements we had no basis to judge because these requirements are  contingent on actions that had not yet occurred. Therefore, we did not  assess these requirements. Table 2 provides our assessment of the  extent to which the Committee, through its actions and issued Strategy,  complied with each of the 17 section 1107 requirements we could  assess.
section_title: Appendix IV: Comments from the Office of Personnel Management
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the above named contact, Vincent Balloon, Assistant  Director; Jason Bair; Clifton Douglas, Jr; Rebecca Gambler; Terry  Richardson; Justin Riordan; John Van Schaik; Jennifer Weber; Erik  Wilkins-McKee; and Michael Willems made key contributions to this  report.
section_title: Related GAO Products
paragraphs: Critical Technologies: Agency Initiatives Address Some Weaknesses, but  Additional Interagency Collaboration Is Needed. GAO-15-288.  Washington D.C.: February 10, 2015.
Managing for Results: Implementation Approaches Used to Enhance  Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.:  February 14, 2014.
Managing for Results: Key Considerations for Implementing Interagency  Collaborative Mechanisms. GAO-12-1022. Washington, D.C.: September  27, 2012.
Interagency Collaboration: State and Army Personnel Rotation Programs  Can Build on Positive Results with Additional Preparation and Evaluation.  GAO-12-386. Washington D.C.: March 9, 2012.
National Security: An Overview of Professional Development Activities  Intended to Improve Interagency Collaboration. GAO-11-108.  Washington, D.C.: November 15, 2010.
National Security: Interagency Collaboration Practices and Challenges at  DOD’s Southern and Africa Commands. GAO-10-962T. Washington,  D.C.: July 28, 2010.
Defense Management: U.S. Southern Command Demonstrates  Interagency Collaboration, but Its Haiti Disaster Response Revealed  Challenges Conducting a Large Military Operation. GAO-10-801.  Washington, D.C.: July 28, 2010.
Homeland Defense: DOD Needs to Take Actions to Enhance Interagency  Coordination for Its Homeland Defense and Civil Support Missions.   GAO-10-364. Washington, D.C.: March 30, 2010.
Interagency Collaboration: Key Issues for Congressional Oversight of  National Security Strategies, Organizations, Workforce, and Information  Sharing. GAO-09-904SP. Washington, D.C.: September 25, 2009.
Results-Oriented Government: Practices That Can Help Enhance and  Sustain Collaboration among Federal Agencies. GAO-06-15. Washington,  D.C.: October 21, 2005.