Defense Contracting: Post-Government Employment of Former DOD Officials Needs Greater Transparency
Published: 2008-05-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Department of Defense (DOD) officials who serve in senior and acquisition positions and then leave for jobs with defense contractors are subject to the restrictions of post-government employment laws, in order to protect against conflicts of interest. Congress required GAO to report on employment of such officials by contractors who received more than $500 million in DOD's 2005 contract awards. In response, this report (1) provides information on how many former DOD employees worked for contractors in 2006 and estimates how many worked on contracts that were related to their former agencies or to their direct responsibilities and (2) identifies the practices used to monitor restrictions and information challenges in monitoring post-DOD employment. To do this work, GAO matched data from DOD for all employees who left DOD over a 6 year period with data from the Internal Revenue Service (IRS) and from 52 contractors; conducted surveys; and interviewed DOD and contractor officials.
section_title: What GAO Found
paragraphs: In 2006, 52 contractors employed 2,435 former DOD senior and acquisition officials who had previously served as generals, admirals, senior executives, program managers, contracting officers, or in other acquisition positions which made them subject to restrictions on their post-DOD employment. Most of the 2,435 former DOD officials were employed by seven contractors. On the basis of a stratified random sample of contractor-supplied information, GAO estimates that at least 422 former DOD officials could have worked on defense contracts related to their former agencies and that at least nine could have worked on the same contracts for which they had oversight responsibilities or decision-making authorities while at DOD. The information GAO obtained from contractors was not designed to identify violations of the restrictions. While contractors could have employed quite a few former DOD officials on assignments related to their prior DOD positions, there could be appropriate justification for each of these situations. Most of the contractors who responded to our survey reported using a range of practices to ensure awareness and compliance with post-government employment restrictions, although GAO's request proved challenging for contractors to provide accurate information identifying their former DOD officials. According to the surveyed contractors, they can identify former DOD officials with post-government employment restrictions and track their assignments during their cooling-off periods. However, GAO's analysis found a significant under-reporting of the contractors' employment of former DOD officials. Specifically, contractor-supplied data showed they employed 1,263 former DOD officials in 2006, while IRS data showed the contractors employed 2,435. New post-government employment requirements enacted in January 2008 are likely to make written ethics opinions for former DOD officials more readily available to contractors. DOD also must now keep ethics opinions in a central database. This information was not designed to provide a mechanism for DOD to effectively monitor former DOD officials' post-government employment compliance after they begin working for contractors on specific contracts.

section_title: Letter
paragraphs: Each year, civilian and military personnel leave the Department of Defense  (DOD) and go to work for contractors that do business with DOD— sometimes the same contractors they were working with before leaving  DOD. Officials who serve in senior or acquisition positions and then leave  DOD for jobs with defense contractors are subject to laws restricting their  new employment activities. The laws seek in part to protect against  conflicts of interest—such as former DOD officials using their DOD  contacts to the benefit of the contractor to the detriment of the  government. The laws also seek to promote public trust in the integrity of  the government’s decision-making process, which facilitates the award of  contracts worth hundreds of billions of dollars each year. Violation of  these laws may result in criminal or civil penalties for former DOD  officials and, in some circumstances, the defense contractors that employ  them.
Beginning as early as 1969, efforts to maintain public trust and monitor  compliance with post-government employment restrictions have included  laws requiring certain former DOD officials to self-report their  employment with defense contractors for up to 2 years after leaving DOD  and requiring contractors to report annually on the employment of these  former officials to various DOD ethics offices. Several of our reports on  these past strategies to make post-DOD employment with defense  contractors more transparent to DOD, the most recent in 1990, found  problems with the implementation and enforcement of those reporting  requirements, and questioned the extent to which former DOD officials or  defense contractors complied with them and the effectiveness of DOD’s  monitoring. Congress repealed these reporting requirements in 1995 when  enacting new provisions to impose a 1 year compensation ban for former  procurement officials with certain contractors and provide ethics advice  and counseling concerning applicable employment restrictions for  subsequent work for contractors.
More recently, our work and the work of others have raised concerns that  the monitoring of former DOD officials’ compliance with post-government  employment restrictions may be inadequate. Congress included a  provision in the John Warner National Defense Authorization Act for  Fiscal Year 2007 requiring us to report on recent employment of former  DOD officials by major defense contractors. In response, this report        (1) provides information on how many former DOD military and civilian  personnel worked for major defense contractors in 2006 and an estimate  of how many of these were former DOD senior or acquisition officials who  worked on defense contracts for these employers that were the  responsibility of their former agency or their direct responsibility at DOD  and (2) identifies the practices used to monitor compliance with post- government employment restrictions and the information challenges that  contractors and DOD face in monitoring the movement of former DOD  employees to defense contractors.
To conduct this work and based on our analysis of DOD’s fiscal year 2005  contract award data, we focused on 52 contractors we identified for  review of post-government employment of former DOD officials. To  determine how many former DOD officials worked for these 52  contractors, as agreed with your offices, we matched personnel data from  DOD for all military and civilian employees who left DOD service in a         6 year period since January 2001 (including about 35,000 former DOD  senior and acquisition officials) with (1) taxpayer data from the Internal  Revenue Service (IRS) and (2) personnel data from the contractors on  individuals they directly compensated in 2006 as employees, independent  contractors, consultants, or members of their boards of directors. To  estimate how many former DOD officials subject to post-government  employment restrictions these contractors may have assigned to work on  DOD contracts related to their former DOD positions, we drew a stratified  random sample of former DOD officials for whom contractor-provided  information indicated direct employment in 2006 and used a questionnaire  to obtain job histories (both DOD and contractor) from their contractor  employers.
To identify practices major defense contractors report using to comply  with post-government employment restrictions, we surveyed all 52  contractors on personnel assignment record-keeping, practices for  identifying, screening, and tracking former DOD officials, and training for  employees on post-government employment restrictions. We analyzed  responses from 47 contractors who responded to the survey, but we did  not corroborate or test contractors’ self-reported practices for  effectiveness. To identify monitoring challenges, we analyzed the extent to  which contractors were able to submit sufficient information to us on how  many former DOD officials worked for them in 2006 and provide us with  copies of DOD’s written ethics opinions and related job histories for a  random sample of former DOD officials. It should be noted that there is no  statutory or regulatory requirement that a contractor collect, have, or  maintain this information. We also met with DOD ethics and procurement  policy officials in the Office of the Secretary of Defense to discuss DOD’s  practices and information challenges for monitoring former DOD officials  employed by defense contractors. We conducted this performance audit  from November 2006 through May 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. Appendix I provides additional details on our scope and  methods, including a list of the 52 contractors reviewed.
subsections: section_title: Background
paragraphs: Congress has long been concerned about the movement of government  officials from DOD to private employers who do business with their  former agencies and has passed laws that place limitations on the  employment of former government officials.  The laws include penalties  for violations by the former government employee and civil or  administrative penalties for the contractors who employ them. There are  acknowledged benefits to employing former government officials for both  DOD and defense contractors; for example, former DOD officials bring  with them the knowledge and skills in acquisition practices they have  developed at DOD which also benefit DOD when communicating with  these contractor personnel. However, a major concern with post- government employment has been that senior military and civilian officials  and acquisition officials working for defense contractors immediately after  leaving DOD could lead to conflicts of interest and affect public  confidence in the government by creating the following perceptions,  among others:    DOD personnel who anticipate future employment with a defense  contractor might be perceived as using their position to gain favor with  the contractor at the expense of the government, and  former DOD personnel who work for a defense contractor might be  perceived as using their contacts with former colleagues at DOD to the  benefit of the defense contractor and to the detriment of the public.
subsections: section_title: Implementation of Post- Government Employment Laws
paragraphs: The principal restrictions concerning post-government employment for  DOD and other federal employees after leaving government service are  found in 18 U.S.C. § 207 (post-employment conflict of interest) and            41 U.S.C § 423 (restrictions on former officials’ acceptance of  compensation from a contractor). Importantly, the laws do not prohibit an  individual from working on a contract under the responsibility of the  official’s former agency or even a contract that was under the official’s  direct responsibility if the appropriate cooling-off periods are met or if the  former officials restrict their activities to behind-the-scenes work and do  not represent their new company to their former DOD employer. The laws  are complex, and brief summaries here are intended only to provide  context for the issues discussed in this report.
The title 18 U.S.C. § 207 provision generally prohibits an individual  from representing a contractor to their former agency on particular  matters involving specific parties that they handled while working for  the federal government; for example, a specific defense contract. The  law restricts representing the contractor to the official’ s former agency  for defined cooling-off periods that vary according to the former  official’s involvement and seniority (i.e., high-level) for example:  former personnel are permanently barred from representing their  new employer to their former agencies for matters on which they  were personally and substantially involved;    even if the officials were not directly involved in the matter, former  personnel may not represent their new employer to their former  agency on matters that were pending under their official  responsibility in their last year of service for 2 years after leaving  federal service; and  former senior-level officers and employees may not contact their  former agency on particular government matters (such as a  contract) that is pending or is of substantial interest to the former  agency for 1 year after leaving federal service.
The 41 U.S.C. § 423 provision more narrowly applies to the work  former DOD and other government acquisition officials may do after  leaving federal service. The law restricts former DOD acquisition  officials from accepting compensation from a defense contractor  during a 1 year cooling-off period. Specifically, this provision prohibits  employment with a contractor if the acquisition official performed  certain duties at DOD involving the contractor and a contract valued in  excess of $10 million. However, the law permits former acquisition  officials to accept employment from “any division or affiliate of a  contractor that does not produce the same or similar products or  services” that were produced under the contract.
The laws establish penalties for individuals and contractors who do not  comply with the restrictions.
section_title: High-Profile DOD Cases Illustrate Importance of Ethics Issues
paragraphs: Recent high-profile cases involving former senior DOD officials’ violations  of these laws or related conflict of interest law on seeking post- government employment with contractors have resulted in serious  consequences for both the officials and their defense contractor  employers. Examples are as follows:  In July 2007, a retired Navy rear admiral pleaded guilty to a charge of  violating 18 U.S.C. § 207. The former admiral admitted to signing a  major contract proposal and cover letter on behalf of his new  contractor  employer and sending it to his former Navy command in  San Diego within the 1-year cooling-off period. In his plea, the former  officer admitted that his intent in sending the letter was to influence  the Navy’s decision and obtain the contract award for his new  company. The former admiral was sentenced to a year’s probation and  fined $15,000. In response to the conflict of interest, the Navy also  eliminated the contractor’s bid before awarding the contract.
In 2006, the Boeing Company was fined $615 million and had a lease  contract valued at $20 billion canceled, in part, due to the failure of Ms.  Darleen Druyun, a former senior Air Force procurement officer, to  obey conflict of interest laws that prohibit officials from continuing to  participate in work with a company while pursuing future employment.  Specifically, when she was working for the Air Force, Ms. Druyun  negotiated a job with Boeing for her daughter, son-in-law, and herself,  while Boeing was seeking a $20 billion contract to lease tanker aircraft  to the Air Force. Ms. Druyun served a prison sentence for the  violations, and the Boeing Company’s Chief Financial Officer pleaded  guilty to aiding and abetting fraud and was sentenced to 4 months in  prison, fined $250,000, and given 200 hours of community service.
section_title: Contractors May Employ a Substantial Number of Former DOD Senior and Acquisition Officials in Assignments Related to Their Former DOD Agencies or Their Direct Responsibilities
paragraphs: About 86,000 military and civilian personnel who had left DOD service in a  6 year period since 2001 were employed in 2006 by the 52 major defense  contractors, including 2,435 former DOD officials who were senior civilian  executives, generals, admirals, and acquisition officials including program  managers, deputy program managers, and contracting officers. This latter  group of contractor employees, hired between 2004 and 2006, served at  DOD in positions that made them subject to post-government employment  restrictions. Contractors’ employment of former DOD officials was highly  concentrated—1,581 former DOD officials were employed by seven of the  52 contractors.  To estimate how closely related work assignments of  former DOD officials were to their previous assignments at DOD, we  examined in greater detail the job histories of a randomly selected sample  of former DOD senior and acquisition officials employed by the  contractors.  While there may be proper justification for their post- government employment with a contractor, on the basis of this sample we  estimate that at least 422 individuals could have been working on defense  contracts directly related to their former DOD agency and we estimate at  least nine could have been working on the same defense contracts for  which they had program oversight responsibilities or decision-making  authorities while at DOD.  The information we analyzed to make this  estimate was not designed to identify, nor should this estimate be used to  suggest, that we found any violations of the restrictions on post- government employment. Moreover, contractors provided justification for  the former government employees in our sample to work on the contracts.   However, the estimated number of former DOD officials who could have  worked on defense contracts related to their prior agencies or to their  prior direct responsibility indicates why there is concern over how  contractors monitor their former DOD employees.
subsections: section_title: Contractors’ Employment of Former DOD Officials in 2006
paragraphs: The 1,857,004 military and civilian employees who left DOD service over    6 years since 2001 included 35,192 who had served in the type of senior or  acquisition official positions that made them subject to post-government  employment restrictions if they were to subsequently be hired by defense  contractors. As shown in table 1, our analysis of the major defense  contractors’ employment found that contractors employed 86,181 former  DOD military and civilian personnel in 2006. This tally includes 2,435  former senior-level and acquisition officials who one or more of the  contractors hired since 2004 and employed in 2006.
Although the number of former DOD senior-level and acquisition officials  employed in 2006 varied greatly across the 52 defense contractors, as  shown in table 2, post-DOD employment was highly concentrated at seven  contractors—Science Applications International Corporation, Northrop  Grumman Corporation, Lockheed Martin Corporation, Booz Allen  Hamilton, Inc., L3 Communications Holding, Inc., General Dynamics, and  Raytheon Company. These contractors accounted for about 65 percent of  the former DOD senior and acquisition officials hired at the 52 companies  and for over 40 percent of the value of contract awards for the 52  contractors. Employment of former DOD senior and acquisition officials at  the remaining 45 contractors was much less concentrated. Specifically, in  2006, employment of the former DOD officials totaled 10 or fewer at 24 of  the contractors, and 4 of these contractors did not employ any former  DOD senior or acquisition officials in 2006. Appendix III presents more  detail on the employment of former DOD senior and acquisition officials in  2006 for each of the 52 contractors.
To obtain an understanding of the characteristics of the major defense  contractors’ employment of former DOD senior and acquisition officials in  relationship to these officials’ prior DOD positions—i.e., military or  civilian, senior-level, or acquisition-related, and DOD employer (such as  Air Force or Army)—we analyzed contractor employment at the 52  companies to look for significant differences, if any, across categories  related to the officials’ former DOD positions.
As shown in table 3, of the total former DOD officials that the contractors  employed in 2006, we found there were nearly five times as many former  acquisition officials (2,021 individuals) as former senior officials (414  individuals). In their former DOD positions, these 2,021 acquisition  officials served in key procurement-related positions—such as program  manager, deputy program manager, or contracting officer—and generally  had the type of critical responsibilities, relationships, and influence that  characterize DOD’s business interactions with its contractors.
Also shown in table 3, in 2006 the contractors employed 414 former senior  DOD officials. Our analysis of these senior officials’ DOD positions before  their post-government employment with the contractors found they had  served in a range of high-level positions—including generals, admirals, and  civilian senior executives. As such, in their former positions, these DOD  senior officials had served in key positions that could influence DOD’s  mission-related decision-making.
We also found contractors’ post-DOD employment was almost evenly  divided across former military and civilian officials, as shown in table 4. In  addition, most of the former DOD officials employed by the contractors in  2006 had previously served in positions at the Air Force and Navy,  followed by those who had previously served in Army positions.
section_title: Estimates Are That Many Former DOD Officials Could Have Worked on Contracts Related to Their Prior DOD Agencies and a Few Could Have Worked on Contracts Related to Their Prior Direct Responsibilities
paragraphs: To provide information about former DOD officials work assignments with  contractors, we analyzed job histories and work assignments for a  stratified random sample of former DOD officials to determine if these  individuals worked on defense contracts or programs for which they had  direct responsibility at DOD or which were the responsibility of their  former DOD agency, office, or command. We estimate that many former  DOD officials could have been working on defense contracts under the  responsibilities of their prior DOD agencies and a few could have been  working on the same defense contracts for which they had program  oversight responsibilities or decision-making authorities while working at  DOD.
It is important to keep in mind, however, that post-government  employment in these instances could be lawful depending on the role the  employee had with the government, the role the employee had with the  contractor, and the length of time between government service or work  relating to the contract and the private employment. Also, contractors  responding to our survey were self-reporting on a sensitive issue dealing  with circumstances that could indicate potential conflicts of interest. As  such, the information we sought from contractors was not designed or  expected to elicit specific cases of post-government employment  violations, nor did we identify any. Further, contractors provided  justifications for the former DOD officials in our sample working on the  defense contracts.
Nevertheless, the results provide insight on the estimated magnitude of  former officials’ post-government employment with major defense  contractors tied to their prior agencies and direct responsibilities.  In our  view, the results also indicate the importance of careful monitoring to  ensure that conflicts of interest do not occur.
To estimate how many former DOD officials were working on assignments  that were the responsibilities of their former DOD agencies or for which  they had program oversight responsibilities or decision-making authorities  at DOD, we drew a stratified random sample of 125 individuals from the  former DOD senior and acquisition officials identified by contractors as  being employed in 2006. We sent a questionnaire asking the contractor  for information concerning the individual’s job history, including the  circumstances of the assignment if the job history showed that they were  working on assignments related to their former positions while they were  at DOD.  (App. IV provides a copy of the questionnaire we used.)  Extrapolating from the sample results, we estimate that at least 422  officials could have had contractor assignments working on defense  contracts that were the responsibilities of their former DOD agencies. We  estimate that at least nine could have worked on contracts for which they  had program oversight responsibilities or decision-making authority at  DOD.
The contractors reported other information about the sampled individuals  that justified why these work assignments would not involve potential  conflicts of interest or violations of post-government employment  restrictions, including the following:    The individuals’ cooling-off (i.e., restriction) periods had expired.    The individuals were performing behind-the-scenes work and did not  have direct contacts with their former DOD agencies about the  particular defense contracts.
The individuals were working on different defense projects than they  had worked on while at DOD but for the same agencies. For example,  while the contractors reported that 20 former Navy officials in our  sample worked on Navy contracts, the contractors also reported that  none of the individuals were working on the same project they were  responsible for when in the Navy.
section_title: Contractors Report Using a Range of Practices to Ensure Compliance with Post-Government Employment Restrictions, but Face Challenges in Providing Information for Monitoring Such Employment
paragraphs: Most of the 47 major defense contractors who responded to our survey on  practices related to post-government employment report using a range of  techniques to ensure awareness of and employee compliance with  restrictions, although we found contractors were challenged to provide  accurate information identifying their former DOD officials. Notably,  information from the contractors showed little more than half the level of  employment of former DOD officials than information we derived from  matching IRS and DOD data, suggesting the information challenge defense  contractors and DOD face in monitoring former DOD officials. Moreover,  what information the contractors may have on former DOD officials’  assignments on defense contracts is, for the most part, not available to  DOD. New legislation requiring former officials to obtain ethics advisory  letters and DOD to keep them in a central database could provide some  additional information, but will not give DOD the kind of information  needed—that is, the names of contractor employees who are former DOD  officials and are working on a particular contract and the contractor’s  assurance that these employees are in compliance with their post- government employment restrictions related to the contract.
subsections: section_title: Survey of Contractors’ Post-Government Employment Compliance Practices
paragraphs: Post-government employment restrictions on former DOD officials can  affect every aspect of defense contractors’ hiring practices, including  when employment discussions may occur, who may be hired, and what  tasks they may perform during a 1 to 2 year period after leaving DOD.  Post-government employment laws do not require contractors to identify,  monitor, or provide reports on former DOD employees regarding  compliance with their restrictions. However, violating existing laws may  result in civil and criminal penalties for aiding misconduct of former  government officials and thus, according to contractors’ ethics and  personnel representatives, provide an impetus for adopting a range of  practices to ensure awareness and compliance.
In initial interviews with some of the major defense contractors on the  need for and scope of corporate compliance with post-government  employment practices, ethics and personnel representatives told us about  a variety of ways and means for identifying, screening, tracking, training,  and keeping personnel records for former DOD officials. To gain a better  understanding of the scope of major defense contractors’ practices in  these areas, we surveyed the 52 contractors on their practices. The  following is a summary and analysis of information from the 47  contractors who responded. Appendix V presents detailed results from the  contractor survey.
subsections: section_title: Reported Practices to Conduct Initial Screening
paragraphs: Our survey asked contractors if they seek affirmation about a potential  employee’s previous DOD or other government status prior to offering  employment. As shown in table 5, most of the contractors reported that  they ask potential permanent hires if they were formerly a DOD official,  and a majority of contractors ask the same question of independent  contractors (e.g., self-employed consultants), temporary employees, and  members of the Board of Directors. Contractors were about evenly split on  the use of the question on a job application and use of a special form to  capture this information from job applicants. Similarly, contractors were  divided on the use of electronic or paper collection of an applicant’s  information with some contractors citing the use of both methods.
Our survey asked contractors if they request that employees provide a  copy of their written ethics advice letters and if so, how long, if at all, do  they keep these letters on file once they hire these applicants. As shown  in table 6, a majority of contractors responded that they request  permanently hired employees, temporary employees, and members of the  Board of Directors to provide a copy of their DOD ethics advice letters  from the agencies’ ethics counselors detailing their DOD experience and  providing an opinion on whether employment with a specific contractor is  permitted under post-government employment restrictions. Nearly half of  the contractors said they also ask for these letters from independent  contractors they hire. Some contractors indicated that they were not sure  if the DOD ethics advice letters were requested from applicants who are  potential job candidates. Regarding how long the DOD ethics advice  letters are kept on file, the contractors reported varying practices, with  many keeping them throughout the former DOD official’s employment and  other contractors keeping them for the period of restriction or for a  specified time.
Our survey asked contractors to describe what steps, if any, they take to  ensure that former DOD officials working for them comply with their post- government employment restrictions. As shown in table 7, a majority of  contractors cited counseling/legal review and recruitment/hiring processes  as the primary methods to ensure former DOD employees comply. Further  analysis of contractor survey responses indicates that 12 contractors track  former DOD employees’ government-project-related job assignments  electronically to ensure compliance and nine indicated that such records  are not kept. However, more than half of the contractors indicated that  they use internal and external audits to ensure the sufficiency of their  procedures to track assignments, including post-government assignments  of former DOD officials.
Our survey asked contractors about training requirements to inform  employees about policies regarding post-government employment  restrictions for former federal employees or to reinforce them. As shown  in table 8, a majority of contractors indicated that they require training for  at least some employees. Further analysis of contractor responses  indicates that their training is targeted to one or more employee groups  such as senior-level managers, human resources staff, middle-level  managers, or former federal government employees. Also, the training  varies in timing and frequency.  Training can take place initially upon  employment with refresher training, annually or every 2 years, for  example. Twelve contractors reported they mandated training for all  employees; five contractors reported mandatory annual training.
section_title: Information Challenges Defense Contractors Face in Monitoring Compliance with Post-Government Employment Restrictions
paragraphs: As noted, most major defense contractors report using a range of practices  for monitoring their DOD hires to ensure compliance with restrictions,  even though no laws or regulations require them to track or provide  reports to that effect. However, the contractors’ ability to access and  provide information on former DOD officials’ employment and work on  specific defense contracts proved challenging.
For example, contractor-provided data on the numbers of former DOD  officials working with them was significantly less than what we  determined through our match with IRS information.  Specifically, our  analysis of the status of major defense contractors’ employment of former  DOD officials in 2006, which was based on matching contractor-supplied  information with DOD personnel data, found that the contractors  employed a total of 1,263 former DOD senior and acquisition officials,  while our match of IRS information and DOD personnel data showed the  contractors employed a total of 2,435 former DOD officials, or almost  twice as many.
In addition, as shown in table 9, only 15 of the 30 major defense  contractors who responded to our questionnaire were able to provide  ethics advice letters for at least one of the individuals in our stratified  random sample. Specifically, 24 of the 30 who responded to our survey on  their practices said that they asked employees for their DOD ethics advice  letters as one of their practices for ensuring compliance with post- government employment restrictions and many reported keeping these  letters on file throughout the former officials’ employment. However, 10 of  the contractors that reported asking for the letters did not provide any  ethics advice letters in response to our questionnaire.
As noted earlier in this report, contractors are not required to keep copies  of these letters.  In the future however, information on DOD ethics advice  letters for former DOD senior and acquisition officials could be more  readily available to all DOD contractors as a result of a provision in the  National Defense Authorization Act for Fiscal Year 2008 imposing new  requirements on defense officials and contractors.  Specifically, with this  provision (enacted January 28, 2008), defense contractors may not  knowingly compensate (i.e., employ) former DOD officials who are subject  to post-government employment restrictions without first determining that  the official has sought and received a written ethics advice opinion from  DOD within 30 days of seeking the opinion. To implement this  requirement however, defense contractors are likely to face new  information challenges in keeping records that adequately document that  they did not knowingly employ a former DOD official who did not seek or  receive the applicable DOD written ethics opinion.
Contractors responding to our survey were generally able to provide  information about DOD- and contractor-job histories for most of the  former DOD officials in our sample. However, according to the corporate  headquarters staff for several contractors—who had to collect the detailed  job histories from information submitted from across their companies in  order to respond to our survey—accumulating this information was  challenging. According to these contractor staff, the absence of automated  assignment tracking or standardized personnel information systems across  their companies made it difficult for them to centrally compile the  information. That is, to respond to our survey, for some contractors it  appears the currently available information on former officials’ post-DOD  work on specific pending or awarded contracts is decentralized at the  various business units responsible for those defense contracts. We found  that the scope and quality of the job histories contractors provided to us  were sufficient for our analysis on the magnitude of post-DOD work  related to prior agencies and responsibilities. However, our questionnaire  was not designed or expected to elicit contractor information on specific  conflicts of interest or noncompliance cases, such as whether cooling-off  periods were unexpired, for example.
section_title: DOD Faces Related Information Challenges in Monitoring Compliance with Post-Government Employment Restrictions
paragraphs: Similar to the requirements of defense contractors, no laws or regulations  require DOD ethics or acquisition officials to track or monitor former DOD  employees after they begin their new contractor jobs to ensure  compliance with applicable post-government employment restrictions. As  discussed earlier in this report, past legislative requirements to make the  employment of former officials with defense contractors more transparent  to DOD by having individuals or contractors report to DOD on the post- government employment with contractors were not successful and were  repealed by 1995.  However, the changed requirements left DOD without a  mechanism to obtain information about its former senior and acquisition  officials who go to work for its contractors.  In our view, and DOD ethics  and procurement officials agree, the information currently  available to  DOD from providing written ethics opinions to former DOD senior and  acquisition officials who request them regarding prospective employment   restrictions has  limited utility for monitoring compliance with post- government employment restrictions once former DOD officials go to  work for defense contractors for several reasons:    while officials have been encouraged to seek an ethics advisory  opinion, they were not required to obtain them, nor were contractors  required to ask for them;    DOD’s record-keeping for its written ethics opinions is decentralized at  the many defense ethics offices that issued them; and    DOD lacks a mechanism for providing the information to contracting  officers or program managers for a particular contract.
Nonetheless, for DOD’s purposes, ethics advisory opinions may now be  more readily available and centrally located because of the 2008 defense  authorization act provision that requires former officials to obtain written  ethics opinions on applicable post-government employment restrictions  from their DOD ethics officials before accepting compensation from  defense contractors for a period of 2 years after leaving DOD service.  DOD also has a new record-keeping requirement to retain each request  and each written opinion provided in a central database or repository for  at least 5 years.
While this requirement may help to increase transparency over which  former officials are working with contractors and what may raise a  potential conflict of interest, its utility may be limited because information  is not being tied to specific contracts.  Senior ethics officials in DOD’s  Standards of Conduct Office and the director of Defense Procurement and  Acquisition Policy and Strategic Sourcing (DPAP), for example, told us  that DOD currently does not have a mechanism to link information on  former officials’ post-DOD work for their new employers for specific  defense contracts that are pending or awarded before their former  agencies, offices, or commands.  They believed that such a mechanism  would be valuable to program managers and contracting officers who  need to ensure that contracted work being done in their programs is free  of conflicts.  They also believed that such a mechanism would be relatively  cost-effective to implement.  After learning of the results of our data  collection efforts, in fact, these officials were concerned that current  mechanisms do not provide DOD a clear picture of how many former  officials are working with contractors and what risks of conflicts are  present.
section_title: Conclusions
paragraphs: The public needs to be assured that decisions related to the hundreds of  billions of dollars spent each year on defense contracts comply with the  applicable post-government employment restrictions and are free of  conflicts of interest.  But this task is highly challenging when it comes to  monitoring whether former DOD officials are in compliance with these  rules or have a conflict of interest by working for a defense contractor.     Our review illustrated aspects of this challenge, including difficulties  associated in collecting data on thousands of employees working for just  52 contractors.  It is likely our surveys would have been more difficult to  accomplish if they had been applied to the entire spectrum of defense  contractors, which includes hundreds of small companies that may not  have automated or complete information on their employees.
Further, requirements that have been imposed in the past to collect  information on former DOD officials working for contractors have not  been effective for a variety of reasons.  These include difficulties  associated with asking private citizens to report back to the government  on their employment for extended periods of time and disparities in the  way information was collected and reported.  Moreover, when information  was collected, its value was limited, according to DOD officials, because it  could not be tied to specific programs or contracts, where it could inform  those responsible for ensuring integrity at the front line of acquisitions.   Despite these challenges, there may be ways that more accurate and useful  information could be collected, for example, by asking potential  contractors to certify that their employees are in compliance with post- government employment restrictions when contracts are being awarded.   The results of our review—particularly results relating to the estimated  numbers of former DOD senior and acquisition officials who could be  working in areas that tie back to their work at DOD—show that examining  such options is worthwhile.
section_title: Recommendations for Executive Action
paragraphs: To provide greater transparency during the acquisition process given the  fact that former DOD officials can and do work on defense contracts  related to their prior agencies or their direct responsibilities, the risk of  conflicts of interest and the appearance of conflicts of interest, and the  need to maintain public trust in the integrity of defense contracting, we  recommend that the Secretary of Defense direct the Under Secretary of  Defense (Acquisition, Technology, and Logistics) to consider the relevant  recent statutory changes and determine if changes in procurement policy  are needed to impose additional reporting requirements or other  requirements  to guard against violations of the government’s post- employment rules.  For example, DOD could consider requiring defense  contractors who are awarded a contract, within a set number of days after  contract award, to (1) disclose to the contracting officer the names of  employees who are certain former DOD officials (e.g., civilian senior  executives, high-level military officers, or acquisition officials) who  worked on the response to the solicitation and (2) certify that these  employees are in compliance with the applicable post-government  employment restrictions. In addition, after assessing the benefits and costs  associated with the certification process, DOD could consider whether  and to what extent it should apply a similar mechanism throughout the  term of the contract.  In responding to a recent report we issued on  contractor employee personal conflicts of interest, DOD tasked its Panel  on Contracting Integrity to examine issues we raised and potential  solutions.  It may also want to do the same with regard to post- government employment reporting.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOD for comment.  The DPAP  director wrote that DOD concurs with our recommendation.  Specifically,  he wrote that the recommendation will be referred to the Panel on  Contracting Integrity for consideration and action.  DOD’s Acting General  Counsel also provided written technical comments, which we  incorporated into the report as appropriate.  DOD’s comments are  reproduced in appendix II.
We are sending copies of this report to the Secretary of Defense, the  Director of the Office of Management and Budget, the Director of the  Office of Government Ethics, and other interested parties. We will make  copies available to others upon request. We will make this report available  to the public at no charge on the GAO Web site at http://www.gao.gov.
If you have any questions about this report or need additional information,  please contact me at (202) 512-4841 or chaplainc@gao.gov. Contact points  for our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. Key contributors to this report are listed in  appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: Congress included a provision in the John Warner National Defense  Authorization Act for Fiscal Year 2007 requiring us to report on the recent  employment of former Department of Defense (DOD) officials by major  defense contractors. In response, our report objectives were to                (1) develop information on how many former DOD military and civilian  personnel recently worked for major defense contractors and develop an  estimate of how many of these were former DOD senior or acquisition  officials who worked on defense contracts for these employers that were  related to their former positions at DOD and (2) identify the practices used  to monitor compliance with post-government employment restrictions and  the information challenges that contractors and DOD face in monitoring  the movement of former DOD employees to defense contractors. This  report does not address any government employment restrictions which  might be applicable when former private sector employees are employed  by DOD or other federal government agencies. In November 2007, in part  to meet our reporting requirement, we provided an interim briefing to the  Senate and House Armed Services Committees.
Section 851 of the National Defense Authorization Act for Fiscal Year 2007  defined major defense contractors as any company that received at least  $500 million in contract awards from DOD in fiscal year 2005. To identify  those contractors, we analyzed data on the values of contracts awarded to  all companies from DOD’s Statistical Information Analysis Division. As a  result, we identified the 52 contractors meeting the major defense  contractor criteria to include in our review. As shown in table 10, which  ranks the 52 major defense contractors by the value of their fiscal year  2005 DOD contract awards, these companies accounted for more than half  of DOD’s total contract awards in 2005—$142.8 billion of the total        $269.2 billion.
We conducted this performance audit from November 2006 through        May 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.
The scope and methods we used to perform this audit are described in  greater detail in the remainder of this appendix.
subsections: section_title: First Audit Objective
paragraphs: To develop information on how many former DOD military and civilian  personnel worked for major defense contractors, section 851 required us  to report on employment during the most recent year for which data were  available. Through initial discussions with five of the major defense  contractors and the IRS, we determined that data on former DOD officials’  employment were reasonably available for 2006.  To determine how many  military and civilian personnel left DOD service, as agreed with committee  staff, we limited our analysis to data from the Defense Manpower Data  Center’s databases for all military and civilian employees who left DOD  service for any reason other than being deceased in a 6-year period  between January 1, 2001, and December 31, 2006 (N=1,857,004). We  determined that data from the data center were sufficiently reliable to  accurately support our analysis in support of this objective.
DOD’s data included personally-identifiable characteristics for each  former employee such as name, social security number (SSN), end date of  employment, branch of service, military rank, civilian grade, and if the  employee’s job specialty was coded as any of the several defense  acquisition workforce positions. To analyze defense contractors’ post- government employment for a subgroup of former DOD senior and  acquisition officials, we used DOD’s personnel data to include in the  subgroup the following range of former DOD officials: senior officials such  as military officers ranked O-7 and above (e.g., generals, admirals) and  members of the Senior Executive Service (SES) regardless of whether  they also were coded as serving in a defense acquisition workforce  position. Acquisition officials include military (from O-3 to O-6) and  civilian (from grades GS-12 through 15) officials for which DOD coded  their status as members of its acquisition workforce, including program  managers, deputy program managers, and contracting officers (N=35,192  individuals).
To determine how many of the 1,857,004 former military and civilian  personnel (including the 35,192 former DOD senior and acquisition  officials) worked for the 52 major defense contractors in 2006, we  matched DOD’s personnel data with (1) income tax data from IRS and     (2) personnel data from the contractors on former DOD senior or  acquisition officials they directly compensated in 2006 as employees or  independent contractors.
The data obtained from IRS included Form W-2 and Form 1099- Miscellaneous information. We used data from the returns identifying the  contractor who submitted the income tax data and the SSN and name for  all individual taxpayers for whom the 52 major defense contractors  reported taxable income for the 4-year period between 2003 and 2006.  Because contractor-supplied data identified DOD officials they hired  between 2004 and 2006, we compared SSNs from 2003 income tax data to  the 2006 income tax data and eliminated SSNs for individuals that matched  because this showed the contractors hired those individuals prior to 2004.
We also obtained data from 51 of the 52 contractors on individuals who we  or they matched to our criteria for former DOD senior and acquisition  officials they compensated in 2006 and hired between 2004 and 2006.  Contractors were permitted to provide the SSNs for either (1) all  individuals compensated in 2006 and hired in the 3-year period between  2004 and 2006 or (2) the individuals they identified as matching our  criteria for being a former DOD senior or acquisition official and hired  between 2004 and 2006. In either case, we analyzed the contractors’ SSN  data to match against the SSNs in DOD’s personnel data.
From the matches we determined that 1,263 individuals matched our  criteria as former DOD senior and acquisition officials. For each of the 51  contractors who provided us this SSN data, we assessed the accuracy and  completeness of their information by analyzing how many former DOD  senior and acquisition officials their information showed were employed  in 2006 (N=1,263) compared with our analysis of IRS data for the same  purpose (N=2,435). We based our analysis of demographic data for this  objective on the IRS and DOD data.
To develop an estimate of how many of the former DOD senior or  acquisition officials subject to post-government employment restrictions  the major defense contractors assigned to work on defense contracts  related to their former DOD agencies or their direct responsibilities, as  shown in table 11, we used the contractor-identified population of 1,263  individuals. To ensure that we had adequate representation of these  officials from contractors with fewer former DOD officials, we stratified  the population into two strata based on the number of former DOD  officials reported by each contractor as employees—contractors reporting  50 or more former DOD officials were assigned to one stratum and  contractors reporting less than 50 former DOD officials were assigned to  another stratum. From this population we selected a statistically based  random sample of 125 individuals who worked for 32 of the contractors.
We asked the contractors to respond to a questionnaire on related DOD  and contractor job histories for the sampled individuals. We analyzed  responses from 30 contractors on job histories and contractor work  assignments for their respective individuals in our sample. Based on the  sample size and the response rate, the estimate from the results achieves a  precision of ± 8 percent at a 95-percent confidence level.
To obtain the job histories, we used a Web-based questionnaire to collect  data on work histories of the individuals in our sample. (App. IV  reproduces the Web-based questionnaire used for this survey). The  questionnaire was designed to obtain individual information for each of  the former DOD senior and acquisition officials in our sample, such as his  or her previous DOD assignments and contractor assignments over a          3-year period as well as to request a copy of any DOD ethics advice letters.
Our questionnaire was intended to develop information on defense  contracts or programs on which former DOD officials were assigned in  order to consider whether the former officials were assigned to work on  contracts they or their agencies had previously been responsible for.   Recognizing that the contractors responding to our survey were self- reporting on a sensitive issue, the information sought from contractors  was not designed or expected to identify specific violations of post- government employment restrictions. Instead, the survey also asked  contractors for information on circumstances surrounding the post-DOD  work in relationship to prior DOD positions and responsibilities. To  protect the confidentiality of the responses concerning these individuals,  we took steps to remove personally identifiable information from our  analysis and evidentiary files.
We projected the results of our sample to estimate the extent that former  DOD officials in our study group population of 1,263 individuals engaged  in post-government employment tied to their former DOD agencies or to  their direct responsibilities. We used these estimates to assess the  magnitude of such post-DOD work tied to former DOD agencies, offices,  or commands or to direct responsibilities.
section_title: Second Audit Objective
paragraphs: To identify the practices major defense contractors report using to ensure  awareness of and compliance with post-government employment  restrictions for employing former DOD officials, we interviewed ethics and  personnel officials with five of the contractors to gain an initial  understanding of the variety and scope of information reasonably available  concerning a range of practices used for these purposes. We also  conducted a survey to collect additional information from all 52  contractors on personnel assignment record-keeping and practices for  identifying, screening, tracking, and training former DOD officials for  purposes of compliance with post-government employment restrictions  To conduct this survey, we pre-tested it with three contractors before        e-mailing a questionnaire to all 52 contractors to collect information on  their reported practices. (Appendix V reproduces the questions used for  this survey as well as the aggregated responses.) The survey was designed  to obtain information on contractors’ reported practices to ensure  awareness and compliance in various key ways such as (1) how  contractors identified new hires with potential post-government  employment restrictions, (2) how they tracked post-DOD assignments of  former DOD officials during their cooling off periods, (3) whether they  collected and maintained copies of DOD ethics advisory letters for former  DOD officials, and (4) whether they provided training in post-government  employment restrictions to various employee categories in their  workforce. We analyzed responses from the 47 contractors who  responded to the survey. This is a survey response rate of 90 percent. Our  survey results cannot be generalized for the purpose of describing  nonrespondent contractors’ practices.
To identify information challenges contractors and DOD face, we reviewed  post-government employment laws and implementing regulations, prior  GAO reports, and other studies; and held discussions with and obtained  information from officials at the Office of Government Ethics concerning  any requirements and performance problems DOD and defense  contractors have had regarding the adequacy of monitoring former DOD  officials’ compliance with restrictions.
To identify information challenges that defense contractors face in  monitoring employees’ compliance with post-government employment  restrictions, we analyzed the extent to which the 52 major defense  contractors were able to submit sufficient information to us in response to  our data requests. Specifically, we analyzed the extent to which the  contractors were able to submit sufficient data on how many former DOD  officials worked for them in 2006 and provide us with copies of DOD’s  written ethics opinions and related job histories for the pre-selected  former DOD officials sampled for our survey on post-government  employment.
We also met with and reviewed information from ethics officials in the  Office of the Secretary of Defense’s Standards of Conduct Office and  Defense Procurement and Acquisition Policy (DPAP) officials from the  Office of the Undersecretary of Defense (Acquisition, Technology, and  Logistics). We held these discussions to obtain information and views on  DOD’s practice of providing written ethics advice concerning prospective  employment and restrictions to former DOD senior and acquisition  officials who request them. We discussed the sufficiency of this  information for DOD transparency on certain former DOD officials’  compliance with post-government employment restrictions after these  officials begin their new jobs. We also discussed their views on the  sufficiency of information available to DOD’s contracting officials from  defense contractors regarding the names of former DOD senior and  acquisition officials who are working on a particular pending defense  procurement or defense contracts and whether or not they are in  compliance with their post-government employment restrictions. We used  this information to assess whether DOD has sufficient insight into post- government employment to reduce the risk for conflicts of interest or  apparent conflicts of interest that could undermine public trust in the  integrity of defense contracting.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: Contractors’ Employment of Former DOD Senior and Acquisition Officials in 2006
paragraphs: Table 12 presents our analysis of how many former DOD senior and  acquisition officials were employed by each of the 52 defense contractors  in 2006, ranked in descending order according to how many they  employed. In order to prevent reporting of information that could be used  to identify specific former officials with post-DOD employment with  contractors, the table presents summary analysis that discloses which of  the 28 major defense contractors employed 11 or more such individuals in  2006. For those 20 major defense contractors who employed fewer than 11  such individuals, the table presents a limited summary that discloses that  they employed “10 or fewer” such individuals. Also shown in table 12, four  of the contractors did not employ any former DOD senior and acquisition  officials in 2006.
Table 13 shows in greater detail our analysis of the major defense  contractors who employed more than 50 former DOD senior and  acquisition officials in 2006 and a breakout of their former status as DOD  military and civilian employees.
section_title: Appendix IV: Questionnaire for Survey of Contractors on Post-Government Employment Job Histories for Former DOD Officials
subsections: section_title: We surveyed 32 major defense contractors for a sample of the former DOD officials with regard to their job histories at the contractor and previous assignments while still in federal service along with DOD contracts for which they worked. The questions from the survey are reproduced below.
paragraphs: The purpose of the questionnaire was to understand how defense  contractors identify former DOD officials, maintain information about the  job assignments of former DOD employees, and provide training on post- government employment restrictions.
Q1.  How many individuals did your company compensate directly  either as employees, independent contractors (individuals for  whom a form 1099 was generated) or members of the board of  directors during any part of calendar year 2006?
Q2.  How many of the individuals listed in question 1, were hired  directly, engaged as independent contractor, or added to the board  of directors on or after January 1, 2001?
Q3.  For each of the following compensated positions, does your  company ask job candidates whether or not they are former DOD  military or civilian employees before offering employment? a. Permanently hired employees  38 9 47 b. Directly hired contractors (Form 1099 contractors)
Asked  Not asked  Subtotal  Not  applicable  c. Directly hired temporary employees  Asked  Not asked  Subtotal  Not  applicable  d. Members of the Board of Directors  Asked  Not asked  Subtotal  Not  applicable  47 Q3e.  If your company currently asks candidates whether they are  former DOD employees, what means does it use to collect this  information?
Application only  Form only  Other only  App and form  App and other  Form and other  All three  Subtotal  Not applicable  8 10 6 8 3 1 3 39 Q3f.  If your company does collect information on an individual’s  prior DOD employment status, in what form is this information  maintained?
Electronic  Paper only  Other only  Electronic and  paper  Electronic and  other  Subtotal  Not applicable  47 Q4.  How many of the individuals who were compensated by your  company during calendar year 2006 and who joined your company  in some capacity on or after January 1, 2001, were previously  employed by DOD?
Do not  know  Number  given  Subtotal  Not  applicable  Total  Q5.  Does your company ask individuals it is compensating or  considering for each of the following positions if they have any  restrictions on their employment as a result of being former DOD  military or civilian employees? a. Permanently hired employees  Asked  Not asked  Not sure  Total  b. Directly hired contractors (Form 1099 contractors)
Asked  Not asked  Not sure  Subtotal  Not  applicable  47 c. Directly hired temporary employees  Asked  Not asked  Not sure  Subtotal  Not  applicable  d. Members of the Board of Directors  Asked  Not asked  Not sure  Subtotal  Not  applicable  Q6.  Does your company request compensated individuals in each  of the following positions who have current employment  restrictions as a result of previous DOD employment to provide a  copy of the written advice from DOD Ethics Counselors regarding  post-government employment restrictions known as a “Safe  Haven” letter?  a. Permanently hired employees  Requested  Not requested  Not sure  Total  34 6 7 47 b. Directly hired contractors (Form 1099 contractors)
Requested  Not requested  Not sure  Subtotal  Not applicable  c. Directly hired temporary employees  Requested  Not requested  Not sure  Subtotal  Not applicable  d. Members of the Board of Directors  Requested  Not requested  Not sure  Subtotal  Not applicable  47 Q6e.  How long, if at all, does your company keep “Safe Haven”  letters on file for individuals it compensates?
Not kept  Employment  Other  Employment + Other  Subtotal  Not applicable  3 23 15 2 43 Q7.  What steps, if any, does your company take to ensure that  former DOD employees comply with their post-government  employment restrictions?   N=45 (Open-ended responses)
Personnel Record Systems for Compensated Individuals Q8.  Did your company compensate directly any INDEPENDENT  CONTRACTORS (individuals for whom a form 1099 was generated)  during 2006?
Q8a.   How, if at all, does your company maintain  records of which government project related assignments  independent contractors worked on while paid by your company?  N=42 (Open-ended responses)
Q9.  In what form does your company maintain records of which  government project related job assignments EMPLOYEES have  worked on?
Not kept  Electronic only  Paper only  Other only  Electronic and  paper  Electronic and  other  Three forms used  Subtotal  Not Applicable  Q10.  How is information on which government project related job  assignments employees’ have worked on entered into your records?  N=36 (Open-ended responses)
Q11.  What procedures, if any, are in place to ensure that the  record of government project related job assignments for each  employee accurately record ALL of the assignments the employee  has worked on?  N=35 (Open-ended responses)
Q11a.  Are any of these procedures documented?   47 Q12.  Are any audit checks performed to assure that ALL of an  employee’s government project related job assignments are  included in their record?
Yes  No  Subtotal  Not  applicable  a.  What checks are performed to assure all assignments are  included?
N=28 (Open-ended responses) b.  How often are these checks performed?  N=26 (Open-ended responses) c.  Who performs these checks?  N=26 (Open-ended responses) d.  What are the procedures to correct any errors found?  N=26 (Open-ended responses)
Q13.  How often are the records of government project related job  assignments updated?  N=36 (Open-ended responses)
Q14.  How would you characterize the completeness of your  personal data records regarding the government project related  job assignments employees have worked on at your company?
Very complete  Somewhat  complete  Not very complete  Subtotal  Not applicable  47 Q15.  What limitations, if any, are there of the government project  related job assignments data your company maintains?  N=36 (Open-ended responses)
Q16.  What reviews, if any, have there been of the integrity of your  company’s government project related job assignments record  keeping system?   N=36 (Open-ended responses)
Q17.  Does your company require training that informs and  reinforces its policies regarding post-employment restrictions for  former federal government employees?
Yes  No  Subtotal  Not  applicable    Continue to question 18.
Which groups are required to take this training?
Yes  No  Subtotal  Not  applicable  47 Q17b1.  about how often are they required to take this  training?  1 per year  < 1 per 2  yrs  Other  Subtotal  Not  applicable  Continue to question 17c.
If all employees are not required to take this training, which of the  following groups of employees are?
Yes  No  Subtotal  Not  applicable  Q17b5.   about how often are they required to take this  training?  5 2 2 3 12 1 per year  1 per 2 yrs  < 1 per 2 yrs Other  Subtotal  Not  applicable  47 Q17a6.  Other [please specify]  Yes  No  Subtotal  Not  applicable  Q17b6.   about how often are they required to take this  training?  1 per year  1 per 2 yrs  < 1 per 2 yrs   Other  Subtotal  Not  applicable  3 4 1 6 14 Q17c.  Does your company maintain records of whether people who  are required to take the training have completed it?
Yes  No  Subtotal  Not  applicable  47 Q18.  Has any government agency or independent entity assessed  the adequacy of your company’s procedures for hiring current and  former government employees?
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: Acquisition and Sourcing Management
section_title: Applied Research and Methods
section_title: Office of General Counsel