Federal Real Property: Additional Authorities and Accountability Would Enhance the Implementation of the Federal Buildings Personnel Training Act of 2010
Released: 2015-11-19T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The federal government's management of its real property holdings costs billions of dollars and has been on GAO's High Risk List since 2003. Some agencies lack the staff expertise needed to oversee building management activities. GAO was asked to report on the status of the implementation of the Act, which directed GSA to, among other things, consult with the training industry to identify core competencies for federal buildings personnel and required these personnel to demonstrate proficiency in these competencies.

This report examines (1) the progress GSA has made in implementing the Act's requirements, (2) the actions selected agencies have taken to respond to the Act, and (3) the factors that have affected implementation of the Act. To conduct this study, GAO reviewed the Act and agency documentation and studies. GAO also interviewed officials from GSA as well as DOD, DOE, DOI, DOJ, and VA. Together with GSA, the agencies GAO interviewed occupy about 90 percent of federal real property gross square footage.

section_title: What GAO Found
paragraphs: The General Services Administration (GSA) has largely met its lead-agency responsibilities for implementing the Federal Buildings Personnel Training Act of 2010 (the Act) government-wide. For example, it has identified core competencies and a recommended curriculum for federal buildings personnel. While not required by the Act, GSA has also drafted a charter for an interagency advisory board to help coordinate government-wide implementation and has developed software tools to assist agencies with compliance efforts. GSA is in the process of implementing the requirements for its own employees. GSA has identified affected personnel, directed them to inventory their qualifications, and assessed their skills. GSA must still align job descriptions and performance reviews with the Act's requirements and implement contractor compliance efforts.

Of the five selected agencies GAO reviewed, the Departments of Defense (DOD) and Energy (DOE) have taken some actions to respond to the Act, while the Departments of Justice (DOJ), Interior (DOI), and Veterans Affairs (VA) have not yet determined how to respond. For example, DOD is conducting a pilot program through its Defense Health Agency to align five positions with the core competency model GSA developed, while DOI's National Park Service has only discussed potential responses to the Act. As a result, little is known about the numbers of federal and contractor employees at these agencies covered by the Act or the status of their compliance with the Act.

The pace of implementation of the Act has been limited by at least four factors that make compliance essentially voluntary. First, the Act does not provide any agency with the authority to enforce compliance government-wide. According to GSA, it is not authorized to issue official government-wide guidance on implementation, and it has come to see its role as advisory. In addition, the Act does not provide an implementation role for the Office of Personnel Management, the agency generally responsible for government-wide personnel related issues. Second, agencies are not required to report the status of their employees' compliance with the Act, a circumstance that leaves agencies with little incentive to determine how many employees are affected or complying. Third, the Act did not provide funding for additional training, and according to agency officials, many other priorities compete for limited training resources. Fourth, no interagency group has been established that ensures consistent implementation of the Act government-wide. This gap has resulted in a lack of coordinated implementation policy and guidance. While GSA has taken steps to create such a group, this process is still in the development stage. Federal internal control standards emphasize that establishing good human capital policies and practices, including ensuring that personnel are properly trained, is critical for achieving results and improving organizational accountability. These standards also call for assessing the quality of performance over time. Such an assessment would include monitoring training practices. Further, prior GAO work has found that agencies can benefit from considering government-wide reforms when planning training programs and that the coordinated efforts of several agencies through interagency groups can help develop policy, guide program implementation, and conduct oversight and monitoring.

section_title: What GAO Recommends
paragraphs: GAO recommends that GSA develop a legislative proposal to establish agency authorities and reporting responsibilities—as well as an interagency group—to enhance accountability for implementation of the Act. GSA stated that it agreed with the report's findings and would work with the appropriate agencies to address them.

section_title: Letter
paragraphs: The federal government’s management of its real property holdings— comprising hundreds of thousands of buildings and permanent structures  across the country, and costing billions of dollars annually to operate and  maintain—has been on the Government Accountability Office’s (GAO)  High Risk List since 2003. The federal government has made advances  in real property management but continues to face long-standing  challenges. We have previously reported that some agencies lack the  staff expertise needed to oversee building management activities. For  example, some agencies lack dedicated, skilled energy managers as well  as trained staff capable of overseeing and managing energy savings  performance contracts. Ensuring that energy management staffs are well  trained is one of three effective energy management practices we  identified.

The Federal Buildings Personnel Training Act of 2010 (the Act) was  enacted in December 2010. Congressional committee reports  accompanying the Act state that it was enacted to help ensure that  federal buildings are operated to maximize their performance and retain  their values while protecting and leveraging taxpayer investment through  efficient building operations and management, as well as to help support  energy efficiency goals for federal buildings. The Act directed the  General Services Administration (GSA), in consultation with  representatives of professional societies, industry associations, and  apprenticeship training providers, to take the following actions  government-wide:  1.  Identify the core competencies necessary for federal personnel to  perform building operations and maintenance, energy management,  and safety and design functions not later than 18 months after  enactment of the Act, and update them annually thereafter;  2.  Identify a course, certification, degree, license, or registration that can  be used to demonstrate proficiency in each core competency. Also  identify ongoing training with respect to each core competency; and  3.  Develop or identify comprehensive continuing education courses to  ensure the operation of federal buildings is in accordance with  industry best practices and standards.

In addition, the Act requires GSA, along with the Department of Energy  (DOE), in consultation with the heads of other appropriate federal  departments and agencies and representatives of professional societies,  industry associations, and apprenticeship training providers, to develop a  recommended curriculum relating to facility management and the  operation of high-performance buildings not later than 18 months after the  date of the Act, and update the curriculum annually thereafter.

The requirements outlined in the Act apply to federal and contractor  employees. Individuals are to demonstrate proficiency in each core  competency related to their position not later than 1 year after each is  identified. If hired after the date of such identification, the employee has 1  year to demonstrate proficiency. You asked us to report on the status of  implementation of the Act. We reviewed (1) progress GSA has made in  implementing the requirements of the Act, (2) actions selected federal  agencies have taken in response to the Act, and (3) factors that have  affected implementation of the Act.

To determine the progress GSA and other federal agencies have made in  responding to the provisions of the Act since its passage in 2010 as well  as the factors affecting that progress, we reviewed the Act, congressional  committee and Congressional Budget Office reports, and agency  documentation and reports. We also interviewed officials from GSA and  five selected federal agencies—the Departments of Defense (DOD),  Energy (DOE), the Interior (DOI), Justice (DOJ), and Veterans Affairs  (VA)—and representatives of industry groups. We selected the five  agencies on the basis of the gross square footage of federal real property  they occupy, according to 2014 Federal Real Property Profile data, and  because they were included in initial meetings about the Act that GSA  held in 2011. Together with GSA, the agencies we interviewed occupy  about 90 percent of federal real property gross square footage. We did  not evaluate the effectiveness of the core competencies GSA established  or assess the effectiveness or results of selected agencies’ use of the  core competencies. We also discussed with the Office of Personnel  Management (OPM) OPM’s role in implementing the Act government- wide. We conducted this performance audit from February 2015 to  October 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: GSA Has Largely Met Its Lead-Agency Responsibilities and Has Begun Implementing the Act for Its Own Employees
subsections: section_title: GSA Has Completed Most of Its Requirements for Government-wide Implementation and Is Drafting an Interagency Framework for Collaboration
paragraphs: GSA has identified the core competencies—knowledge, skills, and  abilities—and related training to meet the government-wide requirements  of the Act for federal and contract employees and has begun  implementing the requirements for its own personnel but has not yet  finalized compliance methods for contractors. In 2011, GSA began  working to create an approach for federal buildings personnel to use to  satisfy the Act’s requirements by demonstrating proficiency in the core  competencies. To develop the core competencies, GSA contacted more  than 20 federal agencies and subagencies that hold and operate  buildings and coordinated meetings with officials as well as with  representatives from professional societies, industry associations, non- profit organizations, and private training groups. GSA held follow-on  consultations with agencies it identified as holding large amounts of  federal real property, since those agencies cover the vast amount of  federal real property holdings.

In June 2012, GSA published a set of core competencies for federal  buildings personnel, began creating software tools for demonstrating and  documenting proficiency in the core competencies, and announced a list  of GSA-recommended training courses linked to the core competencies  and covering the topics of facility management and the operation of high- performance buildings. Although 7 core-competency areas are called for  in the Act, in developing them, GSA expanded them to 12. In addition to  the 7 categories of building operations, building maintenance, energy  management, sustainability, water efficiency, safety, and building  performance measures, GSA identified 5 more: technology; design;  project management; business, budget and contracting; and leadership  and innovation as core competency areas. Under these 12 areas, GSA  identified 43 core competencies and 232 specific demonstrations of each  core competency that GSA called “performances.” Employees  demonstrate proficiency in the core competencies relevant to their  positions by completing performances that show they have gained skills  and knowledge through experience and training. GSA laid out all these  elements in what it calls a competency model. Under GSA’s approach,  the individual agency defines what actual compliance means for its own  particular employees. GSA envisions employees working with their  supervisors to document the tasks and training. In addition, GSA  developed—along with DOE officials and in consultation with  representatives of other federal departments and agencies, industry, and  academia—a recommended curriculum related specifically to the fields of  facility management and the operation of high-performance buildings.

To help agencies prioritize training efforts, GSA has since streamlined  this approach by designating as high-priority 9 competency areas, 21  core competencies, and 88 performances that could potentially have the  most impact on building operating efficiency and cost. GSA—working with  an informal body of facility representatives from various landholding  agencies—identified 3 career areas of responsibility most closely aligned  with the core competencies: facility management, energy management,  and facilities operations and maintenance. GSA did this to develop  consistent guidance that could help agencies whose employees may  have similar titles but perform different functions assign the appropriate  performances to the appropriate personnel. See figure 1 for a visual  representation of GSA’s competency model.

As required by the Act, GSA made annual updates to the core  competencies and recommended curriculum in 2013 and 2014. In the  2014 update, GSA created a new, more rigorous process requiring  independent subject matter experts to review potential private and  government training offerings and assess how well they aligned with the  core competencies. This effort resulted in an increase of courses in the  recommended curriculum from 12 no-cost government courses to 135  government and private courses. Currently, 107 of 135 courses—almost  80 percent—are provided by private training organizations, and 28 are  provided by or in collaboration with government agencies.

Also in the 2014 update, GSA announced recommended methods for  buildings personnel who are federal employees to both demonstrate  proficiency in the core competencies and take steps to improve   professional development. To assist in this approach, GSA has launched  two software tools, which were described and partially demonstrated for  us by the GSA official responsible for leading GSA’s implementation  efforts. The first is a basic assessment tool agencies can use to  determine whether buildings personnel have demonstrated the core  competencies related to their positions, and are therefore in compliance  with the Act. Through an online exam format, the official said the tool  allows workers to demonstrate knowledge by answering a series of  questions about the 88 high-priority performances related to their  positions. The tool was designed to take into account any existing  certificates or advanced training the employee may have already earned.  According to the official, the other tool is a professional development  system that moves beyond basic compliance by allowing employees to  plan and accomplish advanced training related to the core competencies  through creating individual training plans linked to GSA-approved  government and private training options.

According to the official responsible for leading GSA’s implementation  efforts, to potentially help coordinate government-wide implementation,  GSA has drafted a charter for an interagency advisory board composed  of facilities operations and maintenance personnel and human capital  executives at federal landholding agencies. The official said that to date  no such group has championed the implementation of the Act’s  requirements across the federal government. While GSA shares internal  guidance and procedures informally on its www.fmi.gov website and  through presentations to industry associations, the Federal Facilities  Council, and individual agencies, GSA could expand its advisory role  through such a group and, according to the official, provide examples of  best practices and guidelines for implementation, and seek consensus on  them. However, according to GSA officials, previous experience suggests  that without being formally established in law or by executive order,  participation by other agencies would likely be too low to be effective.  There is no planned GSA completion date for creating this interagency  advisory board.

section_title: GSA Has Begun Implementation of the Act for Its Own Employees
paragraphs: GSA has taken steps to implement the requirements of the Act for its  employees using its core competency approach but has yet to complete  all its planned work. In 2014, GSA directed its Public Buildings Service  (PBS) personnel in occupational series covered by the Act to take a web- based inventory of their completed training. GSA then assessed their  training against the high-priority performances for their occupational  series and identified areas where the employees needed improvement.  Specifically, GSA found that collectively, the 1,142 employees who  participated in the inventory had completed 36 percent of the required  performances for their positions. In a July 2014 report on the assessment  effort, GSA specified seven methods for PBS workers to voluntarily  improve their proficiency levels in the core competencies. For example,  GSA encouraged workers to use individual development plans to guide  their training and identified free online training for energy management  and water efficiency, which the official responsible for leading GSA’s  implementation efforts indicated were two competency areas revealed in  the PBS assessment as areas in which employees needed additional  training. In addition, GSA developed a formal on-the-job training program  that includes a guide, mentoring activities, and checklists to help reinforce  knowledge gained. GSA also updated PBS’s building manager job  descriptions for existing and new staff by (1) rewriting them to include  high-priority performances related to the core competencies and (2)  including the high-priority performances in each employee’s performance  review criteria.

GSA has started—but has yet to complete—the following tasks to  continue its implementation of the Act for its own employees:

Although GSA has rewritten job descriptions and performance  assessment criteria for approximately 640 PBS employees to include  high-priority performances, GSA has yet to determine whether the  agency is ready to transfer the employees to the new job descriptions  and performance assessment criteria. GSA plans to update previously  identified gaps in Act-related training for PBS employees by requiring  them to complete a new inventory of their training, which GSA’s  official in charge of implementation estimated will be completed after  September 2015. GSA will then assess their training against the high- priority performances for their positions.

According to the official responsible for leading GSA’s implementation  efforts, GSA is still exploring a way for PBS employees participating in  structured on-the-job training to have the training verified in person by  GSA’s subject matter experts. However, according to this official,  while the technical content for the training is complete, GSA is still  finalizing its process to select, vet, and monitor the performance of  subject matter experts, and GSA has not specified a completion date.

section_title: GSA Is Still Planning Its Implementation Approach for Contractors
paragraphs: GSA has not yet determined how many GSA contract staff are subject to  the Act and is still in the planning stages for implementing potential  methods for contractor compliance. GSA officials said they have  discussed—but have not yet begun—a number of tasks related to  contractor training. GSA has drafted standard contract language requiring  companies bidding for facility operations and maintenance work to  provide documentation. The companies would be required to describe  how certain contract employees subject to the Act who could work in  GSA-held buildings have either demonstrated the core competencies  relevant to their positions or are currently participating in continuing  education related to them. According to the GSA official responsible for  leading GSA’s implementation efforts, GSA plans to conduct a pilot  project to test the proposed language and approach using a GSA  contract, and if successful, the language could be applied later to Federal  Supply Schedule contracts and incorporated by other agencies into their  own internal operations and maintenance contracts for buildings  personnel. In addition, the official noted that GSA is committed to  implementing this approach but has not determined a target completion  date. Similarly, he said GSA has considered using contract language  related to the core competencies as a compliance mechanism for contract  workers in federally leased buildings, but added that GSA has focused on  buildings personnel who are federal and contract employees working in  federally owned facilities because the agency considers those employees  a higher priority than contractors working in leased federal facilities.

section_title: Selected Agencies Have Taken Some Action, but Overall Response to the Act Has Been Limited
paragraphs: Of the five agencies we reviewed—two, the Departments of Defense  (DOD) and Energy (DOE)—have taken some actions to respond to the  Act while three—the Departments of Justice (DOJ), the Interior (DOI), and  Veterans Affairs (VA)—have not yet determined how to respond. While all  five agencies encourage or provide training for their facilities  management staffs and participated in GSA’s early planning sessions  on government-wide implementation, three have not taken additional  action. For example, they have issued no written plans or guidance  memorandums, and none of them has moved beyond the initial  discussion phase into the planning or execution phase. As a result, at this  time little is known about the numbers of federal and contractor  employees covered by the Act at these agencies or the status of their  compliance with the Act. According to the official responsible for leading  GSA’s implementation efforts, while agencies are in charge of defining  what individual compliance means for their own employees, to fully  respond, they should be engaging in a continual process of assessing  employees’ training levels, determining where there are gaps in training,  and outlining ways to improve training for employees.

DOD is the largest holder of federal real property and because of its  ongoing efforts to comply with earlier workforce realignment mandates  and to ensure that implementation of the Act is consistent across DOD,  officials decided to embark on a pilot program with the Defense Health  Agency (DHA). For the pilot, a DOD contractor surveyed DHA  employees in five positions that had the most significant impact on the  finances and operations of facilities—central utility plant supervisor;  energy manager; facility manager; heating, ventilation, and air- conditioning (HVAC) controls technician; and project engineer—to  determine how well the competencies for those positions aligned with  GSA’s core competencies and job performances and whether there are  gaps in training. DOD completed the initial pilot at two installations in  June 2015 and published a final report of its results in July 2015. Next,  according to DOD’s program analyst for implementation of the Act, DOD  plans to integrate the applicable competencies and related training  opportunities for DHA’s employees in the five key positions into GSA’s  professional development tool. Beyond DOD’s DHA effort, the official said  DOD plans to conduct pilots for facility management positions at several  Army, Navy, and Air Force installations, and he stated that DOD has not  made any changes to position descriptions. According to officials  representing the three military services, they are waiting for the results of  these pilots before embarking on any implementation actions of their own.

DOE has identified approximately 5,500 federal and contractor  employees who are subject to the Act’s requirements and has taken steps  to assess their proficiency in the 12 competency areas. In 2013, DOE  directed program offices to report and track employees’ compliance,  identify gaps in training, and assign supervisors to document employees’  compliance. DOE surveyed these federal and contractor employees to  determine their existing training, assessed their training against the 12  competency areas, identified gaps in proficiencies, and identified training  opportunities for them. DOE provided us with the results of its summary  assessments for 41 sites, and according to the assessments, most sites  employed at least one person proficient in each competency area.  However, because DOE defined a site-level demonstration of proficiency  in a competency area to mean that at least one individual representing  that site is proficient in the competency area, the results of DOE’s  summary assessments did not provide us enough detail to determine how  many individuals were proficient in each of the 12 competency areas.

Three of our selected agencies—DOI, DOJ, and VA—have not yet  determined how to respond to the Act as none of them has moved  beyond the initial discussion phase into the planning or execution phase.

DOI delegates management of DOI’s real property to six bureaus, the  largest of which is the National Park Service (NPS). While senior DOI  officials in Facilities and Property Management and Human  Resources were generally unaware of any departmental response to  the Act, a senior NPS official told us that NPS has had internal  discussions about the Act and was trying to determine how to achieve  compliance.

Senior DOJ officials in the Justice Management Division noted that  most of the department’s buildings are correctional institutions that are  held by the Bureau of Prisons (BOP) and that the officials had not yet  determined how many staff would be subject to the Act. These DOJ  officials were awaiting a briefing and further clarification from GSA,  and senior BOP officials indicated that they were just becoming aware  of the Act.

VA holds and operates 167 medical centers through its Veterans  Health Administration (VHA). VHA officials said they participated in a  pilot project with GSA to develop competencies for professional and  trade staff in three positions at VA medical centers. The goal was to  use GSA’s competencies to help VHA develop standardized  competencies for each position and then determine if staff met them.  However, VHA officials indicated they were not able to complete this  effort before the pilot project ended. In part because officials said they  are awaiting more formal guidance or direction from GSA, VA at the  departmental level is not currently planning or executing specific  responses to the Act. However, GSA officials stated that the Act does  not provide GSA a role in providing more formal government-wide  guidance.

Although we found limited progress at the five agencies we reviewed,  officials from four of the five agencies recognized the potential benefits  from implementation of the Act. For example, DOD officials shared a  DOD memorandum that noted that DOD’s components could benefit from  an expanded training catalog, more affordable training, and stronger  justification of the need for more training funds. Officials from DOD and  VA agreed that identifying additional training and strengthening employee  competency could benefit facility operations. In addition, officials from VA  said that the Act could produce a stronger workforce and attract more  competent staff.

section_title: Various Factors Have Contributed to Limited Implementation of the Act
paragraphs: We found that the pace of implementation has been limited by four factors  that make federal buildings personnel compliance with the Act’s  requirements essentially voluntary.

No agency has the authority to enforce government-wide  compliance. Because the Act does not give any agency the authority  to enforce compliance of the Act government-wide, GSA sees its role  as advisory. For example, an official from GSA’s Office of  Government-wide Policy said that while GSA shares its internal  guidance and procedures informally with other agencies, GSA is not  authorized to issue official government-wide guidance on  implementation. In addition, no agency monitors government-wide  compliance with the Act’s requirements. We asked officials from the  Office of Personnel Management (OPM) why the agency has not  been involved in implementing the Act, and were given two reasons:  (1) the Act did not direct OPM to do so and (2) GSA did not request  OPM’s implementation assistance for any changes that would affect  policies administered under OPM’s authorities, such as the  management of government-wide position classifications. Federal  internal control standards emphasize that a good control environment  requires clearly defining key areas of authority and responsibility and  establishing appropriate lines of reporting.

Agencies are not required to report progress. The Act does not  require federal agencies to submit specific buildings personnel  training improvement plans or progress reports to GSA, or to  Congress, as has been mandated in other workforce improvement  legislation. For example, legislation enacted in 2009 included a  provision aimed at improving DOD’s civilian workforce and also  included a list of specific reporting requirements for DOD, such as  assessments of the current and future critical skills and competencies  of its civilian workforce. A U.S. Army official said that without a  similar reporting requirement, there is no “trigger” to prompt  compliance with the Act’s requirements. Furthermore, since the  language in the Act directs individuals—not agencies—to comply with  the requirements, there is no clear mandate for agencies on exactly  how to achieve individual compliance. Without a requirement for  federal agencies to report on their efforts related to the Act, there is  little incentive for them to account for how many of their employees  are subject to the Act and whether those covered employees are  complying. Federal internal control standards state that an agency’s  ongoing monitoring of its internal controls should assess the quality of  its performance over time. This assessment would include  monitoring the progress of initiatives to establish appropriate practices  for training and evaluating personnel.

Agencies report having limited training and implementation  funds. Officials generally agreed that implementation has been  limited by the current fiscal environment—including mandatory  spending cuts required by the sequestration. This fiscally constrained  environment has impacted agency training budgets, an impact that  has resulted in increased internal competition for limited training  resources. A VA official said the Act’s lack of dedicated funding has  limited large-scale implementation and resulted in an uncoordinated,  inconsistent approach. VA officials responsible for facilities operations  guidance and policies requested $15 million in additional funding for  fiscal year 2013 to fund VA’s response to the Act but were unable to  secure the funds. The VA official said that in contrast, an earlier VA  facilities workforce improvement effort included dedicated funding  targeted for specific training and education, allowing the agency to  place energy managers in field facilities and improve the knowledge  and skills of employees in leadership positions, such as maintenance  and operations supervisors and chief engineers. While there are free  training options available, the GSA official responsible for leading the  agency’s implementation efforts agreed that the Act’s lack of  dedicated funding acts as a “braking” mechanism as some agencies  may be delaying assessing employee skill levels for fear of not having  sufficient funding to provide the required training identified as a result  of these assessments. However, according to federal internal control  standards, the management of an agency’s human capital is essential  to achieving results and is an important part of internal control. This  management includes continually assessing employee skill levels and  providing training opportunities that allow employees to develop and  maintain required skills.

No interagency mechanism exists for guiding implementation.

No interagency group has been created to ensure consistent  implementation of the Act across the government, a situation that has  resulted in a lack of coordinated implementation policy and guidance.  This lack has also hindered the development of a potential formal  collaboration mechanism for sharing leading practices. We have  previously found that agencies can benefit from considering  government-wide reforms when planning their training and  development programs. In addition, our past work has shown that  one attribute of effective training and development programs is the  extent to which an agency compares its training methods with those of  other organizations, and we found that agencies benefit when they  continuously look to others to identify innovative approaches that may  relate to training and development efforts as well as lessons  learned. Furthermore, we have previously reported that many of the  meaningful results that the federal government seeks to achieve  require the coordinated efforts of more than one federal agency. Our  past work found that interagency groups are mechanisms that can be  used to develop policy, guide program implementation, and conduct  oversight and monitoring. GSA has taken steps to create such a  group, but this process is still in the development stage.

section_title: Conclusions
paragraphs: Since passage of the Act in 2010, GSA has largely met its lead-agency  responsibilities, which were designed to strengthen government-wide  training for federal buildings personnel so they can operate federal  buildings more efficiently and effectively. In consulting with others,  identifying core competencies, and supplying approved training  opportunities and a recommended method for employees to demonstrate  their proficiency levels, GSA has provided a road map for implementation  government-wide. In addition, by seeking an interagency mechanism to  further government-wide collaboration, GSA has shown a willingness to  actively encourage further federal agency participation, which is essential  to the successful implementation of the Act.

Nevertheless, the pace of implementation government-wide remains slow  because, among other things, no agency monitors or enforces  compliance of the Act government-wide, and the Act does not effectively  place responsibility for action directly on federal agencies. GSA has  already conducted extensive outreach and created a core competency  approach that agencies could use. Further steps could be taken to: (1)  provide one agency with the authority to enforce compliance of the Act  and monitor the actions agencies take to comply; (2) place responsibility  directly on agencies to report progress on implementing the Act, including  how they assess employees’ skills and improve their training; and (3)  provide agencies with a mechanism for collaboration. Such measures  could provide effective incentives for agencies to take the proactive steps  necessary to attain individual employee compliance. Until such steps are  taken, Congress cannot know the basic measures of the Act’s  effectiveness, including how many employees are subject to the Act, the  progress of its implementation, and the extent to which covered  employees are complying.

section_title: Recommendation for Executive Action
paragraphs: We recommend that the Administrator of the General Services  Administration develop a legislative proposal to enhance accountability  for government-wide implementation of the Act. GSA should consider  including the following in its proposal: establishing authorities for a single agency to monitor and enforce  implementation of the Act; establishing agency responsibilities for reporting progress on  implementation of the Act; establishing agency responsibilities for assessing employee skill  levels related to the Act and identifying training that allows employees  to develop and retain skills required by the Act; and establishing an interagency group to further government-wide  collaboration on implementation of the Act.

section_title: Agency Comments
paragraphs: We provided a draft of this report for review and comment to GSA, OPM,  and the Departments of Defense, Energy, the Interior, Justice, and  Veterans Affairs. GSA stated it agreed with the report’s findings and that it  would work with the appropriate agencies to address these findings (see  app. II). OPM and the Departments of Defense, Energy, the Interior, and  Justice had no comments. The Department of Veterans Affairs provided  technical comments which we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 14 days from the  report date. At that time, we will send copies to the Administrator of GSA,  the Acting Director of OPM, the Attorney General, and the Secretaries of  Defense, Energy, the Interior, and Veterans Affairs. In addition, the report  will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or wised@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objective was to review the status of the implementation of the  Federal Buildings Personnel Training Act of 2010 (the Act). To do so, we  addressed the following questions:  1.  What progress has GSA made in implementing the requirements of  the Act?  2.  What actions have selected federal agencies taken in response to the  Act?  3.  What factors have affected implementation of the Act?

To determine the progress GSA has made in responding to the provisions  of the Act, we reviewed the Act, congressional committee and  Congressional Budget Office reports, and GSA’s web sites and  documents—including GSA’s required annual update of its core  competencies and recommended curriculum, its www.fmi.gov web site,  and a report on the implementation of the Act by GSA’s Public Buildings  Service. We did not evaluate the effectiveness of the core competencies  and recommended curriculum that GSA developed. In addition, we  interviewed officials in GSA’s Office of Government-wide Policy, Office of  Federal High-Performance Green Buildings, Office of Human Resources  Management, and Public Buildings Service as well as representatives of  several industry groups. (See table 1.)

To determine what actions agencies have taken in response to the Act,  we selected five federal agencies—the Departments of Defense (DOD),  Energy (DOE), the Interior (DOI), Justice (DOJ), and Veterans Affairs  (VA)—on the basis of the gross square footage of federal real property  they occupy, according to 2014 Federal Real Property Profile data, and  because they were included in initial meetings about the Act that GSA  held in 2011. Together with GSA, the agencies we selected occupy about  90 percent of federal real property gross square footage, according to the  2014 Federal Real Property Profile. Our determination of agency actions  in response to the Act included interviews of agency program and human  capital officials (see table 1) and reviews of agency documentation and  reports. For example, we reviewed DOD’s report from the first phase of its  Act-related pilot at the Defense Health Agency and DOE’s report  documenting its assessment of staff’s compliance with the core  competencies. We did not assess the effectiveness or results of selected  agencies’ use of the core competencies.

To determine the factors that have affected implementation of the Act, we  reviewed the Act and agency studies and reports, including DOD’s phase  1 pilot report and DOE’s summary analysis of the proficiency of its  workforce in the 12 competency areas. We also reviewed prior GAO work  on internal controls and human capital related to enhancing agency  accountability and planning and developing training programs and  interviewed agency officials and representatives from professional  societies, industry associations, non-profit organizations, and private and  government training groups. We also discussed with the Office of  Personnel Management (OPM) OPM’s role in implementing the Act  government-wide. For the agency interviews, we used standardized data  collection instruments to maintain consistency across the interviews.

section_title: Appendix II: Comments from the U.S. General Services Administration

section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Steve Cohen, Assistant director;  Gary Guggolz, Analyst-in-Charge; Hannah Laufe; Malika Rice; Kelly  Rubin; Pamela Vines; and Michelle Weathers made key contributions to  this report.


Question-summary annotations: questions: question: To what extent has GSA met its lead-agency responsibilities?
answer: The General Services Administration (GSA) has largely met its lead-agency responsibilities for implementing the Federal Buildings Personnel Training Act of 2010 (the Act) government-wide.
child_questions: question: How has the GSA met its responsibilities?
answer: For example, it has identified core competencies and a recommended curriculum for federal buildings personnel.

question: How is GSA still working to meet its responsibilities?
answer: GSA has identified affected personnel, directed them to inventory their qualifications, and assessed their skills. GSA must still align job descriptions and performance reviews with the Act's requirements and implement contractor compliance efforts.

question: Why has GSA drafted a charter for an interagency advisory board?
answer: While not required by the Act, GSA has also drafted a charter for an interagency advisory board to help coordinate government-wide implementation and has developed software tools to assist agencies with compliance efforts.

questions: question: How have agencies responded to the Act?
answer: Of the five selected agencies GAO reviewed, the Departments of Defense (DOD) and Energy (DOE) have taken some actions to respond to the Act, while the Departments of Justice (DOJ), Interior (DOI), and Veterans Affairs (VA) have not yet determined how to respond.
child_questions: question: What specifically have agencies done?
answer: For example, DOD is conducting a pilot program through its Defense Health Agency to align five positions with the core competency model GSA developed, while DOI's National Park Service has only discussed potential responses to the Act.

question: What is the result of these responses?
answer: As a result, little is known about the numbers of federal and contractor employees at these agencies covered by the Act or the status of their compliance with the Act.

questions: question: What has been the result of the Act not providing any agency authority to enforce compliance government wide?
answer: According to GSA, it is not authorized to issue official government-wide guidance on implementation, and it has come to see its role as advisory.

question: What problem is brought up by agencies not being required to report the status of their employees'  compliance with the act?
answer: Second, agencies are not required to report the status of their employees' compliance with the Act, a circumstance that leaves agencies with little incentive to determine how many employees are affected or complying.

question: What has been the result of not having an interagency group?
answer: Fourth, no interagency group has been established that ensures consistent implementation of the Act government-wide. This gap has resulted in a lack of coordinated implementation policy and guidance.

question: What factors make compliance with the act voluntary?
answer: First, the Act does not provide any agency with the authority to enforce compliance government-wide. According to GSA, it is not authorized to issue official government-wide guidance on implementation, and it has come to see its role as advisory. In addition, the Act does not provide an implementation role for the Office of Personnel Management, the agency generally responsible for government-wide personnel related issues. Second, agencies are not required to report the status of their employees' compliance with the Act, a circumstance that leaves agencies with little incentive to determine how many employees are affected or complying. Third, the Act did not provide funding for additional training, and according to agency officials, many other priorities compete for limited training resources. Fourth, no interagency group has been established that ensures consistent implementation of the Act government-wide.

question: What do federal standards call for?
answer: Federal internal control standards emphasize that establishing good human capital policies and practices, including ensuring that personnel are properly trained, is critical for achieving results and improving organizational accountability. These standards also call for assessing the quality of performance over time. Such an assessment would include monitoring training practices.
child_questions: question: How could agencies benefit from enforcing these standards?
answer: Further, prior GAO work has found that agencies can benefit from considering government-wide reforms when planning training programs and that the coordinated efforts of several agencies through interagency groups can help develop policy, guide program implementation, and conduct oversight and monitoring.

questions: question: What has been on GAO's High Risk List?
answer: The federal government's management of its real property holdings costs billions of dollars and has been on GAO's High Risk List since 2003.
child_questions: question: What was GAO asked to report regarding this?
answer: GAO was asked to report on the status of the implementation of the Act, which directed GSA to, among other things, consult with the training industry to identify core competencies for federal buildings personnel and required these personnel to demonstrate proficiency in these competencies.

question: Why are some agencies unable to fulfill supervisory needs?
answer: Some agencies lack the staff expertise needed to oversee building management activities.

questions: question: What does this report examine?
answer: This report examines (1) the progress GSA has made in implementing the Act's requirements, (2) the actions selected agencies have taken to respond to the Act, and (3) the factors that have affected implementation of the Act.
child_questions: question: How did GAO get information for the report?
answer: To conduct this study, GAO reviewed the Act and agency documentation and studies. GAO also interviewed officials from GSA as well as DOD, DOE, DOI, DOJ, and VA. Together with GSA, the agencies GAO interviewed occupy about 90 percent of federal real property gross square footage.

question: How did GAO interact with officials and agencies?
answer: GAO also interviewed officials from GSA as well as DOD, DOE, DOI, DOJ, and VA.