In January 2013, Congress enacted the NDAA for Fiscal Year 2013. Section 955 of the act (section 955) outlines statutory requirements for the Secretary of Defense to develop a plan to achieve savings in the civilian personnel and service contractor workforces of DOD. The act required the Secretary of Defense to develop and implement a plan to achieve savings in the total funding for civilian and contractor workforces that are not less, as a percentage, than savings in funding for basic military personnel pay resulting from reductions in military end strengths from fiscal years 2012 through 2017; ensure that the plan is consistent with policies and procedures required by 10 U.S.C. SS 129a, and to ensure that the savings are not achieved through unjustified transfers of functions between or among the military, civilian, and service contractor personnel workforces of DOD, consistent with authorities available to the department under sections 129a, 2330a, 2461, and 2463 of title 10 of the United States Code; provide an initial report including a comprehensive description of the plan to achieve savings no later than 120 days after enactment of the NDAA; provide status reports describing the implementation of the plan in the prior year as part of the budget submitted by the President to Congress for each of fiscal years 2015 through 2018; in each status report, provide a summary of savings achieved through personnel reductions and the number of military, civilian, and contractor personnel reduced; and in each status report include an explanation where any savings fall short of the annual target. DOD has submitted two reports to Congress in response to section 955. In September 2014, DOD issued its first report in response to section 955. DOD refers to the September 2014 report as its initial report. In February 2015, DOD provided a status report in budget justification materials that accompanied the President's budget request for fiscal year 2016. Both reports were developed by the Office of the Under Secretary of Defense (Comptroller) (OUSD Comptroller), which is the department's principal advisor on budgetary and financial matters and has responsibilities for developing and executing DOD's annual budget. Section 955 also requires that DOD's plan be consistent with policies and procedures required under section 129a of title 10 of the United States Code. According to 10 U.S.C. SS 129a, the Under Secretary of Defense for Personnel and Readiness (USD P&R) has overall responsibility for the development of guidance on the implementation of policies and procedures for determining the most appropriate and cost-efficient mix of military, civilian, and contractor personnel to perform the mission of DOD. In addition, USD P&R is, among other things, to provide oversight policy, assess the size and shaping of the civilian workforce, and develop policies, plans, and programs to ensure the readiness of the total force. DOD's September 2014 report outlined reductions achieved in civilian personnel for fiscal years 2012 and 2013 and planned reductions for fiscal years 2014 through 2019. The reductions in civilian personnel are further grouped by military component and civilian hiring status of direct, reimbursable, or foreign. The report also outlines reductions achieved in military personnel using military average strength by active, reserve, and National Guard status for fiscal years 2012 and 2013 and planned reductions for these personnel for fiscal years 2014 through 2019. Additionally, the report outlines reductions achieved in funding for contracted services for fiscal years 2012 and 2013 and planned reductions for contracted services for fiscal year 2014 and 2015. Section 955 gave DOD authority to exempt certain civilian and contractor functions from reductions. Most of the September 2014 report provides details on these exclusions--for fiscal years 2012 through 2017. As a result, about 70 percent of the civilian workforce was excluded from the savings goals over the period. The exclusions are categorized by personnel functions such as depots, medical, and shipyards as well as by military component and the department's defense-wide agencies such as the Defense Commissary Agency and Defense Contract Audit Agency. Similar to the September 2014 report, the February 2015 report that was included in budget justification materials accompanying the President's budget for fiscal year 2016 outlines achieved and proposed civilian personnel reductions for fiscal years 2014 through 2020 and reductions to contractor personnel spending through fiscal year 2016. In addition, the proposed reductions in civilian personnel are further categorized by hiring status, as in the initial report provided in September 2014. Further the February 2015 report details exclusions taken by the department based on the categories identified in the initial report--personnel functions, military components, and DOD's defense-wide agencies. See table 1 for an overall summary of the reductions reported by DOD for each workforce. DOD's September 2014 and February 2015 reports did not fully address most statutory requirements related to the civilian and contractor workforces. Specifically, of the six statutory requirements, DOD partially addressed three statutory requirements and did not address three statutory requirements. Table 1 summarizes the statutory requirements and our assessment of the extent to which DOD's reports addressed these requirements. During our discussions with OUSD Comptroller officials, they acknowledged that both reports did not fully address the requirements of section 955. Specifically, these officials stated that the reports did not include a comprehensive description of the implementation plan for the reductions, that they did not include savings achieved in total funding for civilian and contractor personnel, and that no specific actions were taken to ensure implementation would be consistent with workforce management laws. These officials explained that they did not fully address all of the requirements because they had to balance meeting the section 955 requirements with other competing priorities including completing the President's budget requests for fiscal year 2015 and 2016. While DOD developed a plan for reductions in the civilian workforce, it did not provide details to understand how these reductions would be achieved or any information demonstrating that the goals were being achieved. As a result, one of the deadlines for the requirements-- providing an initial report, including a comprehensive description of the plan, no later than 120 days after enactment of Act--has passed, and Congress does not have information on how the department will achieve required savings, and whether the savings will be achieved in a manner that is consistent with workforce-management laws. According to its section 955 reports, DOD has made civilian personnel reductions; however, our analysis shows that the reductions may not achieve the savings required by section 955. Section 955 requires DOD to achieve savings in the cost of the civilian and contractor workforces between fiscal year 2012 and fiscal year 2017 not less than the savings in military basic pay, in percentage terms, resulting from reductions in military end strength over the same period, and also requires DOD to report on the savings achieved in each of its annual status reports. In its reports, however, DOD provides information on reductions to civilian full- time equivalents (FTE), but does not report the civilian personnel costs associated with the reductions, and as a result it is not clear whether its reductions will achieve the savings required under section 955. According to its September 2014 report, DOD does not project either military pay or civilian personnel costs beyond the budget year. As a result, DOD did not provide the information required by section 955. According to OUSD Comptroller officials, DOD does develop 5-year plans for civilian FTEs as a part of the process for both the annual budget and Future Years Defense Program (FYDP). In addition, according to these officials, FTEs are typically the primary measure they use in managing and reporting on DOD's civilian workforce. For example, Office of Management and Budget Circular A-11, which provides guidance on the preparation of the President's budget, uses FTEs as the main measure for the size of an agency's civilian workforce in certain contexts. As a result, OUSD Comptroller chose to use civilian FTEs and military average strength--which is the closest approximation to FTEs for military personnel--for the purpose of assessing compliance with section 955's savings requirement, rather than reporting savings in the cost of the civilian workforce compared to savings in military basic pay resulting from reductions in military end strength over the same period, as section 955 requires. According to DOD's reports, it set a goal for achieving compliance with section 955 of reducing civilian FTEs less exclusions from fiscal year 2012 through fiscal year 2017 by the same amount, in percentage terms, as military average strength over the same period. As of DOD's February 2015 report, this goal amounts to approximately a 7.0 percent reduction in the civilian workforce from fiscal years 2012 through 2017. As discussed above, under section 955, DOD is permitted to exclude spending on certain portions of the civilian and contractor workforces from the required reductions. In its February 2015 report, DOD reported that of its approximately 776,000 civilian FTEs in fiscal year 2012, approximately 538,000 civilian FTEs, or about 69 percent, are covered by an exclusion. The approximately 7.0 percent reduction needed to match the reduction in military average strength applies to the remaining 238,000 civilian FTEs. In its February 2015 report, DOD reported that it had reduced civilian FTEs by 15,448 through fiscal year 2014, and has planned for an additional reduction of about 789 FTEs through fiscal year 2017. Together, these actual and planned FTE reductions represent a reduction of 6.8 percent from fiscal year 2012 to fiscal year 2017, compared to the 7.0 percent reduction in military average strength over the same period DOD set as its goal for achieving compliance with section 955. Civilian FTEs and military average strength by themselves, however, may not be reliable measures of the cost of the civilian personnel workforce and military personnel basic pay, which section 955 requires DOD to use in measuring the savings it is to achieve. As shown in table 3, from fiscal year 2012 through fiscal year 2016, DOD's total civilian personnel costs increased by 2.9 percent in current year (non-inflation-adjusted) terms even as total civilian FTEs decreased. In constant (inflation-adjusted) terms, total civilian personnel costs decreased, though not as much as civilian FTEs. As a result, reductions to civilian FTEs may not achieve commensurate savings, and larger FTE reductions may be required in order for DOD to achieve the savings required by section 955. Additionally, reductions in spending on military basic pay may have been more or less than reductions in military average strength over this period, depending on whether inflation-adjusted figures are used. As a result, using reductions in spending on military basic pay resulting from reductions in military end strength as its benchmark for savings, as section 955 requires, could mean that, depending on the treatment of inflation, either a smaller or larger reduction could be required for DOD to achieve the savings required by section 955 than if DOD were to continue to use reductions in military average strength as its benchmark. The effect of this difference over the period from fiscal years 2012 through 2016 is shown in table 3. OUSD Comptroller and military service officials told us that they do not normally project civilian or military personnel costs beyond the budget year, and therefore this information is not typically available. However, they also noted that it may be possible to estimate costs for the purpose of section 955 compliance. For example, some military service officials said they were able to estimate the cost associated with positions excluded under section 955, which, if subtracted from the total funding for the civilian workforce, could be used to help estimate the amount of savings under section 955. In addition, an OUSD Comptroller official indicated military basic pay spending could be estimated based on budget year basic pay rates and projected strength levels. Standards for Internal Control for the Federal Government note that agencies need operational and financial data to determine whether an agency is achieving its compliance requirements under various laws and regulations, monitor performance, and allocate resources. Because DOD's focus has been on making and reporting FTE reductions, not cost savings as required by 955, DOD and Congress do not have information on the extent to which the reductions will achieve savings, and DOD may risk falling short of the statutory requirement for cost savings in the civilian workforce. Its September 2014 report indicated that DOD was on track to complete a majority of the reduction in spending on the contractor workforce required to meet its stated goal by fiscal year 2017. However, in its fiscal year 2016 budget, DOD shows a planned increase in such spending for fiscal year 2016, which would leave about half of the reduction required through fiscal year 2017 still to be achieved. DOD has not provided an explanation of the reasons for the shortfall as required by section 955. Based on our analysis of DOD's section 955 reports and related documents, DOD would need to reduce its spending on the contractor workforce by about $4.1 billion between fiscal year 2012 and fiscal year 2017 in order to match the approximately 7.0 percent level of reduction in military average strength over the same period. As of its September 2014 report, DOD's planned reductions through fiscal year 2015 showed that, if they were maintained though fiscal year 2017, DOD would have been on track to achieve its stated goals for complying with section 955. In its September 2014 report, DOD reported a budgeted level of spending on its contractor workforce of about $53.1 billion for fiscal year 2015--a reduction of about $4.7 billion compared to its fiscal year 2012 spending of about $57.8 billion, which, if maintained through fiscal year 2017, would exceed its required reduction of $4.1 billion from fiscal year 2012 though fiscal year 2017. In its fiscal year 2016 budget, however, DOD has planned an increase in funding for the contractor workforce over fiscal year 2014 levels that could lead to a gap between DOD's stated goal for reductions and the reductions it has planned. As shown in figure 2, DOD reported having reduced contractor service spending between fiscal years 2012 and 2014 by about $3.2 billion, or about 80 percent of the required reduction through fiscal year 2017. Between fiscal years 2014 and 2016, however, DOD budgeted for an increase in contractor workforce spending of about $1.2 billion. If carried out, this will mean that about half the reduction to contractor workforce spending through fiscal year 2017 that DOD has identified as its goal remains to be made. An OUSD Comptroller official told us that the increase in spending on the contractor workforce between fiscal years 2014 and 2016 was driven by a number of different needs, including additional requirements for facilities maintenance and contracted services to support readiness and training needs. In addition, the official stated that complying with spending limitations under section 808 of the NDAA for Fiscal Year 2012, rather than section 955, has been a main focus of their efforts to limit spending on the contractor workforce in recent years. This was in part because, while section 955 requires that a certain level of savings be achieved by fiscal year 2017, section 808 was a recurring requirement for fiscal years 2012 through 2015, and has been a main focus for those years. The official also explained that the contracted services spending reported by DOD is volatile in part because some categories of contract services, such as maintenance of facilities and equipment, can be deferred based on the department's needs and available resources, including statutory limitations on spending such as sections 808 and 955. Section 955 requires DOD to report on the savings achieved in each of its annual status reports and that, in any case in which savings fall short of the annual targets, the report shall include an explanation of the reasons for the shortfall. As discussed above, while DOD's status report acknowledges the shortfall, it does not provide an explanation of the reasons for the shortfall as required by section 955, nor does it provide an explanation of how it plans to address the shortfall by fiscal year 2017. During our discussions, OUSD Comptroller officials acknowledged that their reports did not fully address the requirements of section 955. These officials explained that they did not fully address all of the requirements because they had to balance meeting the 955 requirements with other competing priorities including completing the President's budget requests for fiscal year 2015 and 2016. In addition, OUSD Comptroller officials stated that they had assumed that the reports addressed all statutory requirements because the officials had briefed the congressional defense committees several times as they were preparing the reports and were not aware of any concerns the committees expressed regarding the reports. Without this information, however, it is uncertain whether DOD will achieve the required section 955 savings in contractor spending or whether Congress will have the information needed to have insight into what additional actions are required to achieve this goal. At a time when the entire federal government is facing fiscal challenges that are likely to continue, DOD must plan strategically for reductions to its civilian and contractor workforces to achieve savings. Fully meeting all of the requirements of section 955 would be a step in the right direction in this regard, and would provide Congress with assurance that the department is making progress. However, DOD's 2014 and 2015 reports did not meet the statutory requirements, and DOD needs to act quickly to ensure that its remaining two reports address these requirements and provide the needed assurance. Without information on actual savings in the civilian workforce rather than reductions in FTEs, Congress and DOD will not be positioned to determine whether the reductions will support section 955's overall savings requirements. Furthermore, decision makers in Congress will not be able to assess progress on meeting the savings requirements for the civilian and contractor workforces within the statutory time frame without information in the remaining status reports on any shortfalls and actions DOD is taking to address these shortfalls. To help ensure that Congress has the necessary information to provide effective oversight over DOD's workforces, we are recommending that the Secretary of Defense direct the Office of the Under Secretary of Defense (Comptroller) (OUSD Comptroller), in collaboration with the Under Secretary of Defense for Personnel and Readiness (USD P&R), to address ongoing requirements in section 955 and include this information in status reports that accompany the President's budget request for fiscal years 2017 and 2018. The information to be included in future status reports includes a comprehensive description of a plan to achieve savings for the civilian workforce and contractor workforce for fiscal year 2012 through fiscal year 2017; a description demonstrating that the plan is consistent with policies and procedures implementing workforce-management laws and steps the department is taking to ensure that no unjustified transfers between workforces take place as part of the implementing plan; status reports to be included in the President's budget request for fiscal years 2017 and 2018 describing the implementation of the plan in the prior year; the cost of covered civilian personnel and military basic pay for fiscal years 2012 through 2017, and an assessment of these costs in regard to their compliance with the statutory requirements set forth in section 955; and an explanation for any shortfall in its reductions for the civilian and contractor workforces, and a description of actions DOD is taking to achieve the required savings. We provided a draft of this report to DOD for review and comment. In its written comments DOD concurred with all five parts of our recommendation and provided clarifying comments for three of the parts. DOD's comments are reprinted in their entirety in appendix II. We are sending copies of this report to the appropriate congressional committees; the Secretary of Defense, the Under Secretary of Defense (Comptroller); and the Under Secretary of Defense (Personnel and Readiness). In addition the report is 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) 512-3604 or farrellb@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III. To determine the extent to which the Department of Defense's (DOD) September 2014 and February 2015 reports met the requirements specified in section 955 of the National Defense Authorization Act (NDAA) for fiscal year 2013, we reviewed DOD instructions and other related documentation to identify DOD's efforts to address the statutory requirements of section 955. Specifically, we reviewed DOD instructions governing the roles and responsibilities of the Office of the Under Secretary of Defense (Comptroller) (OUSD Comptroller), Office of the Under Secretary of Defense for Personnel and Readiness (USD P&R), and the military services. We interviewed knowledgeable officials from the OUSD Comptroller, USD P&R, and Department of the Army, Navy, and Air Force offices with responsibility for section 955. We discussed roles, responsibilities, information, and assumptions involved in preparing the plan and DOD reports. Additionally, we had discussions with OUSD Comptroller, USD P&R, and service officials to determine what guidance was provided to DOD to implement the plan, as described in its September 2014 report, consistent with workforce-management laws. Also, we provided written questions to each of the services to obtain their perspectives on the roles, responsibilities, information, and assumptions involved in preparing their proposed reductions. Further, we requested documentation on the assumptions and data used to compile the September 2014 report and budget justification materials accompanying the President's budget request for fiscal year 2016. We requested documentation on DOD guidance to address section 955 requirements, but DOD officials said there were not aware of any documentation. We therefore relied on interviews with DOD and service offices to obtain this information. To determine the extent to which DOD met the requirements specified in section 955 of the NDAA for fiscal year 2013, we analyzed DOD's September 2014 report and February 2015 report and compared them to the statutory requirements in section 955. We conducted this assessment with two analysts independently reviewing DOD's September 2014 report using a scorecard methodology and assigned a score to determine whether the document (1) addresses, (2) partially addresses, or (3) does not address the statutory requirements. The analysts then met to resolve any differences in their respective independent analyses. To determine the extent to which DOD has achieved the cost savings required under section 955 and identified the savings in its September 2014 report and February 2015 report, we reviewed and analyzed the civilian and contractor workforce reductions identified in these reports and associated budget documents. To assess DOD's progress towards its goal for civilian full-time equivalent (FTE) reductions, we calculated, based on DOD's February 2015 report, (1) the FTE reduction that occurred from fiscal year 2012 through fiscal year 2014, the most recent year for which actual values are available, and (2) the additional reduction that DOD has planned through fiscal year 2017. We then compared the percentage reduction in civilian FTEs from fiscal year 2012 to fiscal year 2017 to the percentage reduction in military average strength over the same period. To assess the extent to which reductions in civilian FTEs may result in the required savings to the civilian workforce, as well as the extent to which reductions in military average strength result in a similar reduction to military basic pay, we reviewed DOD budget data on each data series for fiscal years 2012 through 2016 and calculated (1) the annual percentage change from year to year, and (2) the overall percentage change during this period. We then compared the relationships between (1) civilian FTEs and personnel costs--both drawn from DOD's annual Operations and Maintenance overview submitted to Congress as part of its budget justification, and (2) military average strength as reported in the section 955 report and military basic pay as reported in DOD and service budget documents. In comparing these relationships, we used both current year (non-inflation-adjusted) and fiscal year 2012 constant (inflation-adjusted) dollars for civilian personnel costs and military basic pay. To produce the inflation-adjusted figures, we used the following deflators, as published by DOD in its National Defense Budget Estimates for Fiscal Year 2016: for civilian compensation, the "Civilian Pay" deflator; for civilian benefits, the "Total Excluding Pay, Fuel, and Medical" deflator; for military basic pay, the "Military Pay" deflator. To assess DOD's progress towards its goal for the contractor workforce, we calculated the planned percentage reduction to military average strength from fiscal year 2012 through fiscal year 2017 that DOD included in its status report accompanying the fiscal year 2016 budget. Using that percentage reduction, we calculated the reduction that would be required to achieve an equivalent percentage reduction in contractor workforce spending. We then calculated, based on the data provided by DOD in its report and related documentation, (1) the reduction that has occurred from fiscal year 2012 through fiscal year 2014, the most recent year for which actual values are available; (3) the additional increase that DOD has planned through fiscal year 2016, the latest year for which DOD provides contractor workforce spending data; and (4) any shortfall between the required reductions and DOD's actual and planned reductions through fiscal year 2017. To the extent that our analysis identified a shortfall, we interviewed OUSD Comptroller officials to understand the reasons for the shortfall. We also interviewed OUSD Comptroller officials about how and why they chose the goals and data that were included in their reports, as well as alternative approaches to collecting the data required by section 955. According to OUSD Comptroller officials, the data on military, civilian, and contractor workforces included in their 955 reports and budget materials are based on data from the Comptroller Information System and Program Resources Collection Process. We determined that these data were sufficiently reliable for the purpose of reporting on and analyzing reductions to the civilian workforces. Specifically, we reviewed previous GAO reports that used workforce data, reviewed DOD instructions on the preparation and entering of this data, compared military and civilian personnel and funding to other data published by DOD, and discussed the reliability of the data with OUSD Comptroller officials. We conducted this performance audit from February 2015 to December 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. In addition to the contact named above, Vincent Balloon, Assistant Director; Timothy Carr; Timothy DiNapoli; Beth Reed Fritts; Amie Lesser; Daniel Ramsey; Terry Richardson; Ophelia Robinson; John Van Schaik; Allen Westheimer; Erik Wilkins-McKee; and Michael Willems made key contributions to this report.

Summary:
With long-term fiscal challenges likely to continue, DOD must operate strategically and efficiently, including through cost-effective management of its human capital. Section 955 of the NDAA for Fiscal Year 2013 required DOD to, among other things, develop and implement a plan to achieve savings in the total funding for civilian and contractor workforces from fiscal years 2012 through 2017. Section 955 also includes a provision that GAO review each of the Section 955 reports DOD submits to Congress to determine whether the required savings are being achieved and whether the plan is being implemented consistently with workforce-management laws. This report addresses the extent to which (1) DOD, as shown in its September 2014 and February 2015 reports, is meeting the requirements specified in section 955 and (2) has achieved the cost savings required under section 955 and identified the savings in these reports. GAO reviewed the two reports DOD has submitted to Congress and supporting documents and interviewed cognizant officials. The Department of Defense's (DOD) September 2014 and February 2015 reports did not fully address most statutory requirements identified in section 955 of the National Defense Authorization Act (NDAA) for fiscal year 2013. Specifically, DOD partially addressed three statutory requirements and did not address three statutory requirements. For example, DOD's September 2014 report to Congress partially addressed the requirement to develop and implement a plan for achieving savings by outlining reductions in its civilian and contractor workforces, but DOD does not describe a process for implementing the planned reductions. Also, DOD did not address savings the department intends to achieve through reductions in the number of military, civilian, and contractor personnel. Instead the report outlined reductions in full-time equivalent (FTE) positions, which may not equate to savings, and did not outline savings in funding for the contractor workforce beyond fiscal year 2015. Without this information, Congress has limited assurance on how the department will achieve required savings and whether the savings will be achieved in a manner that is consistent with workforce-management laws. Moreover, according to its reports, DOD has made civilian personnel reductions; however, GAO's analysis indicates that the reductions may not achieve the savings required by section 955, and DOD has not provided an explanation of the reasons for the projected shortfall in achieved savings in the contractor workforce. Section 955 requires DOD to achieve savings in the cost of the civilian and contractor workforces between fiscal year 2012 and fiscal year 2017 at least as large in percentage terms as the savings in military basic pay resulting from reductions in military end strength over the same period. In its section 955 reports, DOD reports on reductions to civilian FTEs, but does not report the civilian personnel savings associated with the reductions. Civilian FTEs by themselves, however, may not be reliable measures of the cost of the civilian workforce. For instance, GAO's analysis shows that from fiscal years 2012 through 2016, civilian FTEs declined by 3.3 percent, but civilian personnel costs declined by only 0.9 percent adjusted for inflation. Because DOD's focus has been on making and reporting on FTE reductions, DOD and Congress lack information on the extent to which the reductions will achieve savings, and DOD may risk falling short of the statutory requirement for cost savings in the civilian workforce. In addition, in its fiscal year 2016 budget, DOD shows a planned increase in spending on the contractor workforce that, if carried out, will mean that about half the reduction to contractor workforce spending that DOD has identified as its goal through fiscal 2017 remains to be achieved. Further, GAO's analysis shows that DOD would need to reduce its spending on the contractor workforce by about $4.1 billion from fiscal year 2012 through fiscal year 2017 in order to match the approximately 7.0 percent reduction in military average strength over the same period. DOD has not provided an explanation of the reasons for the shortfall as required by section 955, in part because complying with other statutory requirements has been a main focus of DOD's efforts to limit spending on the contractor workforce. Without this information, it is uncertain whether DOD will achieve the required section 955 savings in contractor spending, which hinders Congress's insight into what additional actions are required to achieve this goal. GAO recommends that the Secretary of Defense fully address ongoing section 955 requirements in its next two status reports to Congress. DOD generally concurred with the recommendation.