DOD’s Office of the Under Secretary of Defense for Personnel and Readiness is the adviser to the Secretary of Defense for total force management, and as such the Under Secretary, among other things, is responsible for identifying civilian requirements for Senior Executive Service, Senior Level, and Senior Technical positions. Specifically, the Office of the Under Secretary of Defense for Personnel and Readiness directed the last review of DOD’s Senior Executive Service, Senior Level, and Senior Technical positions in a 2008 baseline review. The Principal Deputy directed that the review be completed in 60 days and stated that the results would be used to respond to reporting requirements in the National Defense Authorization Act for Fiscal Year 2007. This act required DOD to, among other things, assess its requirements for senior management, functional, and technical personnel (including scientists and engineers) in light of recent trends. Similarly, the Office of the Under Secretary of Defense for Intelligence exercises overall supervision and policy oversight for human capital within the defense intelligence community. In 2007, this office sent DOD’s intelligence community guidance for a review of Defense Intelligence Senior Executive Service and Defense Intelligence Senior Level civilian leader workforce requirements. This review, according to the guidance, was intended to spur an examination and validation of senior civilian requirements, provide DOD management with evidence that resources were being used wisely, and provide an explanation of what resources the intelligence community required and why, so that officials could make budget allocations decisions and defend those requirements before Congress. The intelligence community had 120 days to conduct its review. Recently, however, a September 3, 2010, memorandum directed the department to perform a similar study of these positions to support efficiency initiatives that are expected to result in a reduction of at least 150 civilian senior leader positions. In addition to the above, the Office of the Under Secretary of Defense for Personnel and Readiness oversees the process for identifying the need for additional Senior Executive Service, Senior Level, and Senior Technical personnel. When an entity in DOD identifies a need for an additional Senior Executive Service, Senior Level, or Senior Technical allocation, the need is sent to either an executive board or office that reviews the request. Once the executive board or office has reviewed all requests, they are forwarded to an approving official, typically the secretary of the service, an under secretary, or someone in an equivalent position. Once the list is approved, it is sent to the Civilian Personnel Management Service within the Office of the Under Secretary of Defense for Personnel and Readiness, which aggregates, levels, and forwards the list to the Under Secretary of Defense for Personnel and Readiness who reviews and approves the list before it is sent to OPM. OPM, in consultation with the Office of Management and Budget, assigns Senior Executive Service, Senior Level, and Senior Technical allocations every 2 years to DOD and all other federal agencies. During the biennial review, OPM establishes guidelines for executive branch agencies to follow when requesting additional Senior Executive Service, Senior Level, and Senior Technical allocations; evaluates agency requests for new allocations; and authorizes increases in the number of allocations for each agency. OPM conducted the most recent biennial review in 2009 for allocations to be granted for fiscal years 2010 through 2011. Figure 1 depicts DOD’s process for identifying and communicating the need for additional DOD Senior Executive Service, Senior Level, and Senior Technical requirements for the services, the Office of the Secretary of Defense, the defense agencies, the Joint Staff, and DOD’s combatant commands. Because the maximum number of Defense Intelligence Senior Executive Service allocations is established by law, DOD uses a separate process to communicate the need for additional Defense Intelligence Senior Executive Service personnel. On the basis of requirements identified by the military services’ intelligence branches and the defense intelligence community agencies, the Office of the Under Secretary of Defense for Intelligence develops legislative proposals to request increases in the number of Defense Intelligence Senior Executive Service allocations. The office provides the legislative proposal to the Office of the Under Secretary of Defense for Personnel and Readiness, which submits the proposal to DOD’s General Counsel for inclusion in DOD’s general legislative proposal program. The Secretary of Defense was provided with authority to create a separate Defense Intelligence Senior Executive Service workforce by section 1632 of the National Defense Authorization Act for Fiscal Year 1997. The legislation also stipulates that the Defense Intelligence Senior Executive Service workforce is equivalent to the Senior Executive Service workforce. A DOD draft directive—which department officials said was in use at the time of our review—states that individuals serving in Defense Intelligence Senior Executive Service positions have the same administrative requirements and responsibilities as federal Senior Executive Service personnel. Figure 2 depicts DOD’s process to support requests to Congress for additional Defense Intelligence Senior Executive Service allocations. As of September 2009, DOD was authorized 2,934 allocations for its civilian senior leader workforces, representing less than 1 percent of DOD’s total civilian workforce. Table 1 provides the number of DOD Senior Executive Service, Senior Level, and Senior Technical allocations authorized by OPM, the number of Defense Intelligence Senior Executive Service allocations authorized by statute, and the number of Defense Intelligence Senior Level allocations authorized by the Under Secretary of Defense for Intelligence as of September 2009. For perspective, appendix II provides information on the number of employees working in selected federal agencies across the government and their respective number of civilian senior leader personnel, as of September 2009. Appendix III provides three tables on the number of Senior Executive Service, Senior Level, and Senior Technical allocations OPM made to selected executive branch agencies from fiscal year 2000 through fiscal year 2009. In 2008, DOD conducted a baseline review to assess and validate Senior Executive Service, Senior Level, and Senior Technical workforce requirements and reported to Congress that this was a rigorous analysis. However, while the department’s approach appears reasonable, some of the information the components submitted in response to the review was incomplete and DOD did not document and summarize the information so that it could be readily traced back to the component submissions. Standards for internal control in the federal government state that documentation of transactions and other significant events is to be complete and accurate and is to facilitate the tracing of the transaction or event and related information. This applies to the entire process or life cycle of a transaction or event—from its initiation and authorization through its final classification in summary records. DOD’s April 2008 memorandum for the baseline review provided components a key opportunity to, among other things, validate and align DOD’s civilian senior leader workforce requirements, assess gaps in resource requirements, and identify component-specific strategic priorities. This memorandum was sent to the secretaries of the military departments, the Chairman of the Joint Chiefs of Staff, the under secretaries of defense, the commanders of the combatant commands, the assistant secretaries of defense, the General Counsel of DOD, the Director of Operational Test and Evaluation, the DOD Inspector General, the assistants to the Secretary of Defense, the Director of Administration and Management, the Director of Program Analysis and Evaluation, the Director of Net Assessment, the directors of the defense agencies, and the directors of DOD field activities. We found that the 2008 memorandum presents a reasonable way to validate baseline requirements. However, during the course of our review officials provided us with available data and information obtained from 21 components, and we found that some of the components submitted information that was incomplete and not all of the components submitted information specified in the baseline review. For example, DOD provided us with the data and information received from components, including the Defense Logistics Agency, the Defense Finance and Accounting Service, the Defense Information Systems Agency, the Defense Threat Reduction Agency, the Department of the Navy, and the Joint Chiefs of Staff. However, our review of the documents provided showed that at least 6 of the 21 defense components did not submit complete responses. For example, the Office of the Joint Chiefs of Staff provided information on its civilian senior leader positions, such as the responsibility of the positions; the operation, project, or program managed; and whether the positions are responsible for managing resources. However, the Joint Staff did not provide required narrative responses, such as position validation and missions and strategies supported. Additionally, according to a DOD official the Army and the Air Force did not submit information as specified in the 2008 memorandum for the baseline review. This official stated that the Army and the Air Force chose to use assessments of their Senior Executive Service, Senior Level, and Senior Technical workforces that had been conducted in response to OPM’s 2008-2009 Biennial Review of Executive Resources Allocations. However, this DOD official was unable to provide us with copies of the assessments completed by the Army and Air Force. It is therefore unclear if these documents addressed the objectives of the baseline review, which include such elements as aligning positions with the department’s 21st Century Leader criteria and proposing any new executive categories for optimum development, management, and utilization of executive talent. Additionally, DOD did not document or summarize the information so it could be readily traced back to the component submissions. Specifically, DOD was unable to provide us with documentation of aggregate, bottom- line conclusions from the analysis the department conducted after considering the individual component submissions. Moreover, department officials stated that they did not present their aggregate analysis in a report summarizing the results of the baseline review. DOD officials with knowledge of the baseline review told us that they did not intend to summarize the baseline review analysis or provide a final report on that review. They further stated that DOD did not summarize the analysis because the information was only intended to be used to support a variety of human capital management processes taking place in the department. For example, the department said it used information from the baseline review in DOD’s 2009 update to its Civilian Human Capital Strategic Plan. This update, which was provided to Congress, stated, for instance, that “Within DOD there are more than 1,300 Senior Executive Service positions.” However, this information about the number of senior executives shows how many positions existed at the time of the update and not how many were required. In addition, because there was no summary analysis of the components’ submissions, this number was not readily traceable to information provided by the individual components. Without clearly documenting or summarizing the information in an analysis that could be readily traced back to the component submissions, DOD is not providing Congress and other stakeholders—such as those in the chain of command—clear insight and visibility into DOD’s validation of requirements for its civilian senior leader workforces and whether those validated requirements reflect the results of its baseline review. In 2007, the Office of the Under Secretary of Defense for Intelligence conducted a review to examine and validate DOD’s Defense Intelligence Senior Executive Service and Defense Intelligence Senior Level positions; however, during the final months of our review, officials from this office were unable to provide us with information submitted by the defense intelligence components or with a summary analysis. As mentioned previously, standards for internal control in the federal government state that documentation of transactions and other significant events are to be complete and accurate and facilitate the tracing of the transaction or event and related information. This applies to the entire process or life cycle of a transaction or event—from its initiation and authorization through its final classification in summary records. According to DOD, information from this review was included in DOD’s 2008 update to its Civilian Human Capital Strategic Plan. Specifically, per a September 28, 2007, e-mail from the Office of the Under Secretary of Defense for Intelligence to the military service intelligence branches and the defense intelligence agencies, the review was intended to be a serious examination and validation of senior civilian requirements. The guidance also stated that the review was intended to encourage the most effective use of limited senior civilian resources. The 2007 memorandum presents a reasonable way to validate baseline requirements. According to a responsible defense intelligence official, the Office of the Under Secretary of Defense for Intelligence received submissions from all eight of the defense intelligence components to which the 2007 guidance was sent. This official told us that the responses consisted of information and data on each of the Defense Intelligence Senior Executive Service and Defense Intelligence Senior Level positions, such as the span of control and span of influence for these positions, along with their role in supervising and managing personnel and resources. In addition, this official told us that the overall results of the review were used to provide information to DOD’s 2008 strategic human capital plan. Specifically, when referring to the 2007 defense intelligence community’s review of senior leaders, the 2008 plan that was submitted to Congress stated, among other things, that the defense intelligence components (1) confirmed their positions had been validated, (2) examined the utilization of senior leader positions, and (3) identified the impact of organization and mission change. However, we were not able to verify such statements because the information from the defense intelligence components was not provided to us during the final months of our review. A defense intelligence official responsible for this review told us that the analysis associated with the review of senior leaders resulted in several changes to requirements in the defense intelligence agencies. For example, the official told us and the 2008 human capital plan states that the National Security Agency identified about 70 positions that were categorized as Defense Intelligence Senior Executive Service positions that could be reclassified at or below the General Schedule 15 level—therefore reducing overall requirements for the agencies’ civilian senior leaders. However, as mentioned previously, without the information from DOD that clearly documents or summarizes an analysis that could be readily traced back to the component submissions, we could not verify these statements. DOD officials told us that, while they were eager to do so they were not able to respond to requests for this information during the final months of our review due to other priorities. Furthermore, without this information, DOD is not able to provide Congress and other users of the information clear insight and visibility into the defense intelligence community’s validation of requirements for its civilian senior leader workforces and whether those validated requirements reflect the results of its review. For most entities—the Army, the Navy, the Air Force, the Office of the Director of Administration and Management, the Office of the Chairman of the Joint Chiefs of Staff, and other offices—DOD conducted an analytical assessment of needs using standard criteria. Specifically, in preparation for OPM’s 2010-11 Biennial Review of Executive Resource Allocations, the Office of the Under Secretary of Defense for Personnel and Readiness provided guidance to these entities; the entities used the criteria in the guidance to identify their most urgent needs for additional Senior Executive Service, Senior Level, and Senior Technical allocations. These entities, in turn, submitted evaluations of those needs and their justifications to the Civilian Personnel Management Service within the Office of the Under Secretary of Defense for Personnel and Readiness. The criteria specified in the DOD guidance included identifying the strategic mission requirement to be addressed by the allocation, the reporting relationship of the position and where it will be placed in the component’s organizational structure, the number of personnel expected to report to the person in the proposed position, and the source of funding expected to pay for the allocation. The Civilian Personnel Management Service considered these evaluations and then used nine standard, weighted criteria to score each request for additional Senior Executive Service, Senior Level, and Senior Technical allocations. Table 2 lists these nine standard, weighted criteria. Using these criteria, the Civilian Personnel Management Service developed a final list in priority order of the additional Senior Executive Service, Senior Level, and Senior Technical allocations needed and forwarded that list to the Office of the Under Secretary of Defense for Personnel and Readiness for approval. After approving the list, the Office of the Under Secretary of Defense for Personnel and Readiness sent it to OPM for consideration during its Biennial Review of Executive Resource Allocations process. In its request, the Office of the Under Secretary for Personnel and Readiness identified the aggregate number of Senior Executive Service, Senior Level, and Senior Technical allocations needed by all of the aforementioned entities, a list of all proposed allocations in order of priority, and the justification for each proposed allocation. During this process, DOD requested an additional 51 Senior Executive Service allocations and OPM allocated it 25. During the same process, DOD requested 19 additional Senior Technical personnel and OPM allocated it 8. OPM officials told us that they did not approve all of DOD’s requested allocations because the department’s vacancy rate—the number of existing allocations DOD was authorized but were not filled—was too high. According to DOD officials, at the time of our report the department’s Senior Executive Service vacancy rate was about 8 percent and over the past 3 years the department’s average vacancy rate has been about 12 to 14 percent. From the identification of needs at the component level to the communication of those needs to OPM at the Office of the Under Secretary of Defense for Personnel and Readiness level, this process was well-defined and clearly documented. At the start of the process OPM provided all agencies, including DOD, submission timelines and guidance on how to justify allocation increases. In response, DOD generated the list of additional civilian senior leaders needed using a consistent process across the services that was clearly documented and transparent. While ultimately OPM did not allocate to DOD all of the leaders that it had requested, DOD’s approach for identifying and communicating the needs for additional civilian senior leaders allowed for informed decision making both by the senior levels of DOD and by OPM. Appendix IV provides detailed information on how many additional Senior Executive Service, Senior Level, and Senior Technical allocations DOD has requested and OPM has authorized since 2004. While DOD used OPM’s process to request additional Senior Executive Service, Senior Level, and Senior Technical allocations, for fiscal years 2007 through 2009 and 2011, DOD submitted its request for additional Defense Intelligence Senior Executive Service allocations in the form of a legislative proposal to Congress. To support the proposals requesting additional allocations from Congress, the Office of the Under Secretary of Defense for Intelligence requested the Army, the Navy, the Air Force, and the defense intelligence community agencies to identify and arrange by priority the additional Defense Intelligence Senior Executive Service allocations they needed. However, unlike the process that the Under Secretary of Defense for Personnel and Readiness used—in which DOD used common criteria—the military service intelligence branches and defense intelligence community agencies used different sets of criteria to verify their most urgent needs for additional civilian senior leaders and did not communicate the justification for those needs to congressional decision makers. Regarding the criteria used by the defense intelligence community to verify that new Defense Intelligence Senior Executive Service allocations met the minimum qualifications of the executive level, the military service intelligence branches used the same criteria, while the four defense intelligence community agencies used their own unique criteria. According to DOD officials, the Office of the Under Secretary of Defense for Intelligence reviewed the military services intelligence branches’ and defense intelligence agencies’ requests for additional positions to verify that the requests met statutory definitions. Table 3 describes the different sets of criteria used by the military service intelligence branches and agencies in the defense intelligence community to ensure any additional Defense Intelligence Senior Executive Service allocations meet statutory minimum requirement to be classified above the General Schedule 15 level. Once their needs were identified, each of the military service intelligence branches and defense intelligence community agencies reported them to the Office of the Under Secretary of Defense for Intelligence. According to defense intelligence officials, these reports had detailed justification statements that included a description of each position, its reporting relationships, the number of people directly supervised, the position’s total supervisory span of control, and a justification/mission-critical requirement statement. Unlike the process that the Office of the Under Secretary of Defense for Personnel and Readiness used—which required various DOD entities to provide justifications for additional positions—the Office of the Under Secretary of Defense for Intelligence communicated its request for positions to the Office of the Under Secretary of Defense for Personnel and Readiness only as an aggregate number without justifications. The Office of the Under Secretary of Defense for Personnel and Readiness, in turn, as part of DOD’s general legislative program, communicated that aggregated number to Congress. According to officials in the Office of the Under Secretary of Defense for Intelligence, they had detailed information on the justifications for each position needed; however, these officials stated that by communicating the need for additional allocations only as an aggregate number, they did not provide sufficient details about their need for additional Defense Intelligence Senior Executive Service allocations. When the National Defense Authorization Act for Fiscal Year 1997 authorized the Secretary of Defense to create the Defense Intelligence Senior Executive Service, it set the maximum number of allocations at 492. The current maximum is 594. As stated above, to increase the statutory cap on the number of allocations for that workforce, the defense intelligence community must submit legislative proposals. According to DOD directives, the Under Secretary of Defense for Intelligence is responsible for the overall supervision and policy oversight for human capital within the defense intelligence community. Typically, the Office of the Under Secretary for Intelligence communicates its legislative proposals to Office of the Under Secretary for Personnel and Readiness, which then approves and submits them for potential inclusion in DOD’s general legislative program. While we have not validated DOD’s Defense Intelligence Senior Executive Service requirements, we note that during the past 10 years, Congress has enacted increases to the maximum number of Defense Intelligence Senior Executive Service positions only three times—in the Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001, the National Defense Authorization Act for Fiscal Year 2002, and the National Defense Authorization Act for Fiscal Year 2006. In January 2006, for example, section 1125 of the National Defense Authorization Act for Fiscal Year 2006 increased the maximum number of positions by 50 while DOD’s legislative proposal requested an increase of 150. Our prior work has shown that when agencies are working toward a common goal establishing common criteria and communication strategies strengthens agency processes by providing stakeholders with shared expectations to guide stakeholder efforts. Because the intelligence agencies submit a single request for additional allocations, the individual components should use common criteria for making that request. Regarding the absence of common criteria used to identify the need for additional positions, in its 2008 update to DOD’s Civilian Human Capital Strategic Plan, the Office of the Under Secretary of Defense for Intelligence stated that while the criteria being used by the components are not uniform, the situation should be resolved by development of unifying guidance in a dedicated volume of the Defense Civilian Intelligence Personnel System—DOD’s overarching evaluation and performance-based pay framework for agencies and departments in the intelligence community. However, according to DOD officials, this guidance is not yet final, and the defense intelligence community continues to operate without common criteria. Without the use of common criteria and without better communication of its justifications for additional positions, requests to Congress to increase the number of Defense Intelligence Senior Executive Service personnel will not appear to be well-supported. DOD relies on several different human capital strategies when it experiences gaps in its Senior Executive Service, Senior Level, or Senior Technical workforces. It may request additional civilian senior leader workforce allocations from OPM, reassign existing civilian senior leader allocations, temporarily fill civilian senior leader positions with other DOD personnel when an allocation is not available for the position, float unused allocations to fill pressing needs throughout the department, and maintain reserve allocations. Requesting additional civilian senior leader workforce allocations from OPM: DOD may request additional civilian senior leader workforce allocations at any point between OPM’s Biennial Review of Executive Resource Allocations cycles. Reassignment of civilian senior leader workforce existing allocations: Entities within DOD can reassign existing allocations to manage their civilian senior leader workforces to meet changing mission requirements and accommodate organizational structures. Temporary filling of civilian senior leader positions with other personnel: According to DOD officials, when DOD does not have an allocation for a civilian senior leader position, it sometimes assigns a military officer or a high-level, civilian non-senior leader employee to temporarily fill the position until an allocation for the position is made available. In some cases, DOD has assigned a civilian senior leader to temporarily fill an unallocated position. Floating allocations: OPM requires currently filled Senior Executive Service, Senior Level, and Senior Technical positions to be covered by the allocations OPM grants to federal agencies. However, agencies often have positions that are vacant for reasons such as an employee’s retirement. Accordingly, agencies have some flexibility to move their vacant allocations in the periods between OPM’s biennial reviews to meet their civilian senior leader requirements. The Office of the Under Secretary of Defense for Personnel and Readiness, for example, established policy to address certain pressing needs by “floating” or borrowing unused allocations from vacant positions to cover those needs. While this is based on the assumption that some vacant positions will always exist, the policy states that the office tracks, on a monthly basis, the number of float allocations to ensure that DOD does not exceed its total OPM-authorized senior leader allocations. The policy provides specific allocations for each component and identified purpose, but in the aggregate DOD’s components are authorized 10 percent (138) of their Senior Executive Service, 6 percent (2) of their Senior Level, and 6 percent (8) of their Senior Technical allocations for use as floats. Reserve allocations: The Office of the Under Secretary of Defense for Personnel and Readiness maintains 25 of the 138 Senior Executive Service floating allocations as a reserve, which it can distribute among DOD’s components to meet emergent needs when other strategies are fully utilized or otherwise unsuitable. When the defense intelligence community has experienced gaps in its Defense Intelligence Senior Executive Service workforce, it has used three strategies to fill them. First, the defense intelligence community has reassigned existing allocations to positions of greater need. For example, in 2007, during a restructuring of the defense intelligence community, the Under Secretary of Defense for Intelligence transferred Defense Intelligence Senior Executive Service allocations within the community to meet new civilian senior leader requirements. Second, the defense intelligence community also has filled Defense Intelligence Senior Executive Service positions temporarily with Defense Intelligence Senior Level personnel when it lacked allocations. Third, officials explained that, at times, they will divide up the responsibilities of a senior leader position and distribute those responsibilities among other existing positions. In addition to identifying the need for civilian senior leaders, DOD has recently established overarching policy for managing and developing its Senior Executive Service workforce. In a directive issued in 2007 and an instruction issued in 2009, DOD noted the importance of focusing on talent management and on the exposure to enterprisewide perspectives, as part of its process, to prepare civilian personnel to move into leadership positions. The directive identified as a goal the development of a Senior Executive Service workforce that is fully integrated with other components of DOD’s executive leadership, DOD’s general and flag officers, and political leaders. The instruction defines enterprisewide perspective as a broad point of view of DOD’s missions and an understanding of individual or organizational responsibilities in relation to larger DOD strategic priorities, which is shaped by experience and education and characterized by a strategic, top-level focus on broad requirements, joint experiences, fusion of information, collaboration, and vertical and horizontal integration of information. More specifically, the instruction indicates that enterprisewide perspective is a core competency for civilian leaders, and includes, among other things, understanding DOD’s roles and responsibilities and comprehending the relationships between all elements of power. In addition, chief among DOD’s efforts to develop its Senior Executive Service workforce is DOD’s new Defense Senior Leader Development Program, which DOD established in 2008 and, according to program officials, costs an average of $6.5 million per fiscal year. According to DOD documents, the Defense Senior Leader Development Program is designed to span 2 years and support the enterprisewide effort to foster interagency cooperation and information sharing by providing opportunities for participants to understand and experience, firsthand, the issues and challenges facing leaders across DOD and the broader national security arena. Specifically, career civil service personnel at General Schedule 14 and General Schedule 15 and equivalent grades are eligible to apply for this program and, if accepted, attend seminars and a professional service school and enhance their individual development through substantive enterprise-spanning activities. Furthermore, individuals who are already members of DOD’s Senior Executive Service workforce provide feedback to participants on strengths and competency gaps. Beyond the Defense Senior Leader Development Program, DOD and the services have other programs focused on developing career civilian and current Senior Executive Service personnel. Appendix V provides examples and descriptions of some of these programs. DOD created the Defense Senior Leader Development Program to address problems identified in the Defense Leadership and Management Program—a predecessor program that was discontinued at the end of fiscal year 2010. In 2009, we reported on problems that DOD had identified with that program. In our report we noted that DOD concluded that the program lacked involvement by senior leadership in the career path or progression of potential Senior Executive Service candidates, lacked interaction and camaraderie among participants, and had no plan for how participants would be used after graduation. The House Armed Services Committee’s Subcommittee on Oversight and Investigation has also expressed concerns about the quality of the graduates produced under this program. Table 4 lists some key differences between the Defense Leadership and Management Program and the Defense Senior Leader Development Program. DOD has replaced the Defense Leadership and Management Program with the Defense Senior Leader Development Program and has emphasized a focus on developing future leaders with an enterprisewide perspective. However, according to DOD officials, the department does not have specific metrics for the program. Specifically, at the time of our review, there were metrics in place to evaluate applicants prior to their being admitted to the program and metrics in place to track their success while enrolled; however, there were no metrics to measure the success of the overall program. Without clearly defined program metrics to measure them DOD cannot determine whether the implementation of the Defense Senior Leader Development Program has been an improvement over the Defense Leadership and Management Program. Our prior work on effective strategic workforce planning has shown that high-performing organizations recognize the importance of measuring both the outcomes of human capital strategies as well as the ways that these outcomes have helped the organizations accomplish their missions and programmatic goals. Furthermore, program officials said that the department had not sought OPM certification for its new Defense Senior Leader Development Program, but is researching the requirements for OPM certification. While agencies are not required to operate an OPM-certified Senior Executive Service Candidate Development Program, federal regulations state that agencies that wish to operate OPM-certified Senior Executive Service Candidate Development Programs must obtain approval from OPM and provide training that addresses OPM’s Executive Core Qualifications. These core qualifications include leading change, leading people, being results driven, possessing business acumen, and building coalitions. Were DOD to obtain OPM certification for the Defense Senior Leader Development Program, OPM would be required by law to monitor the implementation of the program and, when appropriate, take necessary corrective action to bring the program into compliance with OPM- prescribed criteria. DOD would also be required by regulation, to recruit candidates for the program from (at a minimum) all groups of qualified individuals within the civil service. According to DOD officials, the department has not sought OPM certification for the Defense Senior Leader Development Program because the program is still in the early stages of implementation. These officials noted, however, that they will consider certification sometime in the future. The range of missions DOD faces in the 21st century is broad, and DOD is turning increasingly to its civilian workforce to perform essential functions to accomplish those missions. Accordingly, especially in light of a fiscally constrained environment, it is important for DOD to be able to identify requirements for civilian senior leaders and be able to justify and identify civilian senior leader positions of greatest need. Similarly, DOD must be able to communicate those needs in a manner that facilitates informed decision making. Where DOD has not been able to do this, key decision makers have been left with insufficient information to determine if requests for additional senior leaders are warranted. If decision makers do not have a clear understanding of the highest-priority needs across the department, they risk having a civilian senior leader workforce inappropriately sized to meet DOD’s missions. Additionally, while DOD has undertaken efforts to create a new senior leader development program, at the time of our review, it has not yet identified program measures. As a result, it is not in a position to know if its newly developed program is meeting its senior leader development needs. We are making the following four recommendations: To provide supportable information about what DOD’s requirements are for the Senior Executive Service, Senior Level, and Senior Technical workforces, we are recommending that in future reviews of the civilian senior leader workforces the Secretary of Defense direct that the Office of the Under Secretary of Defense for Personnel and Readiness document the analysis conducted. To improve the management and development of DOD’s civilian senior leader workforces, we are recommending that the Secretary of Defense take the following three actions: direct the Under Secretary of Defense for Intelligence to finalize and issue common criteria for the military service intelligence elements and the defense intelligence agencies to use in their assessments of Defense Intelligence Senior Executive Service requirements; direct the Under Secretary of Defense for Personnel and Readiness and the Under Secretary of Defense for Intelligence to better communicate key information, including justifications for each Defense Intelligence Senior Executive Service position needed, during the development and presentation of legislative proposals to congressional decision makers; and direct the Office of the Under Secretary of Defense for Personnel and Readiness to establish clearly defined metrics for the Defense Senior Leader Development Program in order to measure the overall success of the program. In commenting on a draft of our report, the Office of the Under Secretary of Defense for Personnel and Readiness partially concurred with two of our recommendations, and the Office of the Under Secretary of Defense for Intelligence fully concurred with the remaining two recommendations. Comments from both DOD offices are reprinted in appendix VI. Additionally, both offices provided general/technical comments on our draft report, which we incorporated as appropriate. In written comments, the Office of the Under Secretary of Defense for Personnel and Readiness agreed with the overall findings of our draft but stated that the report took an overly broad view of some of the areas covered by the review. The office noted that this approach affected the resulting conclusions, and as a result, they were either inaccurate or incomplete. We disagree and have addressed DOD’s comments in detail in appendix VI. DOD partially concurred with our recommendation that in future reviews of its civilian senior leader workforces the department document the analysis conducted. Specifically, the department noted that its April 2008 review was a milestone activity of DOD’s 21st Century Senior Executive Leadership initiative and was one of the department’s Top 21 Transformational Priorities. It further stated that, because of the wide application and multipurpose use of the results of the baseline review, summarizing the analysis was not the best use of resources. However, the department concurred with GAO’s recommendation to document the analysis conducted in future reviews of its civilian senior leaders when such reviews are specifically targeted for an intended outcome. For example, the department noted that a September 3, 2010, memorandum issued jointly by the Under Secretary of Defense for Personnel and Readiness and the Director of Administration and Management directed a review of all civilian senior leaders within the department in support of the Secretary’s Efficiency Initiative. According to the department, the review will include clear documentation of information and analysis that can be easily traced back to component submissions. In addition, the department explained that the results of the Civilian Senior Executive study group’s review will be summarized and presented to senior DOD officials to provide clear insight and visibility into the recommendations of the civilian senior leader review. We believe these actions, if implemented as stated, will meet the intent of our recommendation. DOD also partially concurred with our recommendation to establish clearly defined goals and metrics for the Defense Senior Leader Development Program in order to measure the overall success of the program. The department stated that our recommendation should be rewritten because the purpose and goals of the program are defined in DODI 1430.16 (Growing Civilian Leaders). We agree and have revised our recommendation accordingly. The department further noted that two types of metrics are being refined and will be used to measure the programs success. The department acknowledged that our report stated that DOD has specific metrics in place to measure applicants prior to their admission to the program as well as metrics in place to track participants’ success while enrolled in the program. The department noted that summative metrics, including return on investment for graduate utilization, are being refined and will be implemented for cohorts after the first cohort has completed the program in 2011. Although DOD did not provide or discuss documentation of these metrics during our review, we believe that DOD’s efforts to develop such metrics are a positive step. However, until additional metrics are finalized and implemented, it is unclear to what extent they will meet the intent of our recommendation. In written comments, the Office of the Under Secretary of Defense for Intelligence stated that the office appreciated the opportunity to comment on the report and that it generally agreed with the overall findings of our report. The office further stated that it believed that some facts pertaining to processes for determining defense intelligence senior civilian requirements were misstated and provided technical comments on the portions pertaining to its office. Detailed responses on these comments are provided in appendix VI. Regarding the recommendations, the Office of the Under Secretary of Defense for Intelligence fully concurred with our recommendation to finalize and issue common criteria for the military service intelligence elements and the defense intelligence agencies to use in their assessments of Defense Intelligence Senior Executive Service workforce requirements. The office also fully concurred with our recommendation to better communicate key information, including justifications for each Defense Intelligence Senior Executive Service position needed, during the development and presentation of legislative proposals to congressional decision makers. Furthermore, in its comments on our report, the Office of the Under Secretary of Defense for Personnel and Readiness stated that it will work with the Under Secretary of Defense for Intelligence to establish a framework for joint review and assessment of senior intelligence positions as part of meeting total force management requirements. We are sending copies of this report to the appropriate congressional committees and the Secretary of Defense. The report also is available at no charge on the GAO Web site at http://www.gao.gov. If you or your staffs have any questions regarding this report, please contact me at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix VII. For our first objective, to evaluate the Department of Defense’s (DOD) approach to assessing its civilian senior leader workforce requirements, we obtained and reviewed documents and information related to the Office of the Under Secretary of Defense for Personnel and Readiness’ 2008 baseline review of DOD’s Senior Executive Service, Senior Level, and Senior Technical workforces. We also interviewed knowledgeable officials within the Office of the Under Secretary of Defense for Personnel and Readiness’ Civilian Personnel Management Service about the baseline review, how the information was collected, and the results of the review. We did not, however, validate DOD’s overall civilian senior leader workforce requirements. In addition, we obtained and reviewed documents related to the Office of the Under Secretary of Defense for Intelligence’s 2008 review of DOD’s Defense Intelligence Senior Executive Service and Defense Intelligence Senior Level workforces. We interviewed knowledgeable officials in the Office of the Under Secretary of Defense for Intelligence’s Human Capital Management Office about the information collected and the results of the review. We did not, however, assess or validate DOD’s requirements for its Defense Intelligence Senior Executive Service or Defense Intelligence Senior Level workforces. Pub. L. No. 109-163, § 1125 (2006). Human Capital Management Office, the Defense Intelligence Agency, the National Geospatial-Intelligence Agency, the National Security Agency, and the Defense Security Service. For our third objective, to evaluate DOD’s approach for developing and managing civilian senior leaders capable of leading DOD’s workforce, we obtained and reviewed DOD’s civilian human capital strategic plans and workforce planning documents, analyzed applicable laws, and reviewed our prior work on DOD and federal government human capital planning efforts. During our work, we met with officials responsible for implementing succession planning and leadership development policy and programs. Specifically, we met with DOD officials in the Office of the Under Secretary of Defense for Personnel and Readiness, the Office of the Deputy Under Secretary of Defense for Civilian Personnel Policy, and the office of Civilian Personnel Management Service. At the services, we met with officials in the Office of the Deputy Under Secretary of the Army, the Office of the Army Assistant Deputy Chief of Staff for Manpower and Personnel, the Army’s Office of Civilian Senior Leader Management, the Navy’s Executive Management Program Office, the Navy’s Office of Civilian Human Resources, and the Air Force’s Airmen Development Division. We also met with the Washington Headquarters Service’s Director of Administration and Management and Program Executive Office for Executive Lifecycle Management and the Human Resources Directorate Office. Additionally, we obtained and reviewed documents related to the Defense Senior Leader Development Program and met with officials in the Civilian Personnel Management Services’ Office of Leadership and Professional Development. We obtained and reviewed policies and guidance related to the qualifications of Defense Intelligence Senior Executive Service personnel and met with knowledgeable officials in the Under Secretary of Defense for Intelligence’s Human Capital Management Office, the Defense Intelligence Agency, and the National Geospatial-Intelligence Agency. Further, we obtained and reviewed OPM documents and guidance related to the life cycle planning and development of federal government civilian senior leader workforces, Senior Executive Service qualification requirements, and Senior Executive Service candidate development programs. At OPM, we interviewed the Acting Program Manager of Enterprise Human Resources Integration and the Manager of Human Capital Officers. We also met OPM officials in the Office of the Assistant Director for Leadership and Human Resources Development, Human Resources Solutions. We also obtained and reviewed federal laws applicable to senior leader development and federal career development programs. In addition, we reviewed our prior work regarding measuring both the outcomes of human capital strategies and how outcomes have helped organizations accomplish their missions and programmatic goals through the use of program metrics. We conducted this performance audit from October 2009 through October 2010 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. For comparison across the federal government, we extracted data for civilian workforces by Chief Financial Officers Act agencies in September 2009. Section 205 of the Chief Financial Officers Act identified 23 major executive branch agencies (later expanded to 24) that as of 2009 employed 98 percent of federal employees. Table 5 shows the onboard number of non-Senior Executive Service civilian employees and Senior Executive Service, Senior Level, and Senior Technical employees for each of the Chief Financial Officers Act agencies as of September 2009. For comparison across the federal government, we extracted data from OPM’s Executive Schedule C System on the number of Senior Executive Service, Senior Level, and Senior Technical allocations OPM approved for each of the Chief Financial Officers Act agencies from 2000 through 2009. Section 205 of the Chief Financial Officers Act identified 23 major executive branch agencies (later expanded to 24) that as of 2009 employed 98 percent of federal employees. Table 6 shows the number of Senior Executive Service allocations OPM approved for each of the Chief Financial Officers Act agencies from 2000 through 2009. Table 7 shows the number of Senior Level allocations OPM approved for each of the Chief Financial Officers Act agencies from 2000 through 2009. Table 8 shows the number of Senior Technical allocations OPM approved for each of the Chief Financial Officers Act agencies from 2000 through 2009. Every 2 fiscal years, OPM asks that federal agencies reassess their need for Senior Executive Service, Senior Level, and Senior Technical allocations and request additional allocations through OPM’s Biennial Review of Executive Resource Allocations. OPM also allows agencies to make out-of-cycle requests for additional allocations if a pressing, unforeseen need arises. If OPM approves fewer allocations than the agency requested, the difference constitutes a gap that the agency must address internally. Table 9 shows DOD’s requests for additional allocations through OPM’s Biennial Review of Executive Resource Allocations process and out-of-cycle requests, the allocations approved by OPM, and the resulting gap. In addition to the Defense Senior Leader Development Program, DOD and the components have implemented other programs that are designed to train and develop future and current civilian senior leaders. For example: DOD’s Executive Leadership Development Program, established in 1985, exposes civilian employees at the General Schedule 12 through General Schedule 14 levels to the roles and missions of the entire department. The program provides these employees with an increased understanding and appreciation for the challenges DOD’s military warfighters face. Among other things, the program’s curriculum includes training in areas such as team building, problem solving, decision making, and communication skills. The Air Force Civilian Strategic Leader Program is designed to execute talent management programs for General Schedule 14 and 15 or equivalent personnel and, among other things, identifies civilians with senior leadership potential; targets developmental opportunities for those with the highest potential; places those with the highest potential, when ready, into key jobs; and fills command equivalent positions with high-potential civilian employees who have not already held a similar leadership positions. The Army Senior Fellows Program identifies high-potential civilian leaders and strengthens their executive competencies through executive education, executive leadership assignments, and executive mentoring and includes joint development assignments that vary in length from 6 to 12 months, the opportunity to attend one of DOD’s senior service colleges, mentoring from a member of the federal Senior Executive Service, and the possibility of placement (upon program completion) in positions with greater scope and responsibility. Once an individual becomes a member of DOD’s civilian senior leader workforce, he or she can continue development, training, and education by participating in development programs. For example: APEX is supported by a contract with Booz Allen Hamilton; the program provides opportunities for new Senior Executive Service personnel to interact with DOD senior leadership at the Pentagon and in the combatant commands. Among other things, APEX offers individuals an overview of DOD’s structure and the processes and opportunities to expand leadership and strategic thinking skills. The Joint Executive Management Program, which is held at the University of North Carolina, is designed to broaden the business acumen of DOD’s Senior Executive Service personnel. The course provides DOD and interagency senior leaders the opportunity to collaborate and share ideas and viewpoints in an educational setting. Program topics include the role of senior leaders in the joint environment, managing people, and driving organizational change. GAO Draft Report – Dated October 2010 GAO Code Number: GAO-10-777 “Human Capital – Opportunities Exist for DOD to Enhance its Approach for Determining Civilian Senior Leader Workforce Needs” DEPARTMENT OF DEFENSE INTELLIGENCE COMMENTS DOD appreciates the opportunity to review and comment upon GAO’s proposed report for areas related to the Defense intelligence components. Generally, DOD agrees with the overall findings of the proposed report. However, we also believe the report misstates some facts that pertain to the review of processes for determining Defense intelligence senior civilian requirements. This document provides overall technical comments on the portions of the proposed report and the recommendations that specifically reference Defense intelligence. 1. On pages 4, 15-16, and 17, the draft report states that “during the course of our review” officials were unable to provide supporting information from the defense intelligence components or analysis related the 120-day review of intelligence senior civilian requirements. Such statements do not accurately portray the circumstances or timing of the GAO request. The request to see or receive copies of such supporting information or analysis was made in late August 2010, nearly a full year after announcement of the GAO review and a full seven months after GAO met on January 26, 2010, with Human Capital Management staff of the Office of the Under Secretary of Defense for Intelligence (OUSD(I)) and executive resources officers from all of the Defense Intelligence components to conduct interviews regarding our processes for determining senior civilian requirements. We had occasional telephone contacts from GAO after the January 26, 2010, meeting to clarify their understanding of our processes, but did not receive the informal request to see or receive copies of the 120-day review supporting data and analysis until late August 2010, when our subject-matter expert was out of town on business. The subject-matter expert was needed to assemble the requested documentation from classified and unclassified systems. We regret not being able to provide access to the supporting documentation at the time it was requested and remain eager to do so. However, characterizing our inability to respond to that late August 2010 request as “during the course of our review” is misleading. We request you change all of the statements with phrase “during the course of our review” to “DoD officials were not able to respond to requests we made in the last month of our review to see or receive copies of supporting documentation.” 2. Page 17, the third sentence of the last paragraph: For the reasons described in item 1 above, this sentence should be changed to read, “We could not verify these statements, however, because DoD officials were not able to respond to requests we made in the last month of our review to see or receive copies of supporting documentation to show analysis that could be readily traced back to component submissions.” 3. Page 17, the fourth sentence of the last paragraph: This sentence assumes that certain information does not exist and declares DoD unable to provide clear insight into requirements for senior civilian senior leaders. The sentence should be replaced with “DoD’s ability to provide Congress and other stakeholders clear insight and visibility into the defense intelligence community’s validation of requirements for its civilian senior leader workforces can be improved by clearly documented analysis that can be traced back to component submissions.” 4. Page 21, the last sentence: This sentence implies the military service intelligence branches and agencies in the defense intelligence community use position grading standards as the sole measure of the need for new Defense Intelligence Senior Executive Service (DISES) allocations. That is not accurate and contradicts the last sentence of the first paragraph on page 23, which states OUSD(I) officials confirmed they had “detailed information on the justifications for each position needed.” As discussed with GAO, in addition to validating that any additional DISES requirements involve responsibilities that exceed the GS-15 level as required by statute, we also required the Defense intelligence components to submit a description and detailed justification statements for each new DISES requirement, covering the same kinds of criteria as for the Department’s SES positions, to include reporting relationships, the number of people directly supervised, the position’s total supervisory span of control, and a justification/mission-critical requirement statement. While we did not employ the weighted evaluation methodology used by the Civilian Personnel Management Service to assess the relative importance of the new SES, SL and ST requirements, our Human Capital Management staff carefully reviewed any new requirements against the statutory criteria using the detailed justification information submitted by the Components. The last half of the sentence should be changed to read “to ensure any additional Defense Intelligence Senior Executive Service allocations meet the statutory minimum requirement to be classified above the GS-15 level.” 5. Page 22, description of Table 3: For the reasons stated above, change the phrase “Evaluate the Need for” to “Validate” and add after the word “Allocations” the phrase “Meet the Statutory Requirement to Be Classified Above GS-15.” 6. Page 22, the paragraph after Table 3: For the reasons described in item 4 above, make the following changes: Add the following phrase at the end of the first sentence: “with detailed justification statements that included a description of each position, its reporting relationships, the number of people directly supervised, the position’s total supervisory span of control, and a justification/mission-critical requirement statement.” Change the remainder of the paragraph to read as follows: “The Office of the Under Secretary of Defense for Intelligence evaluated the detailed justification statements submitted by the Defense intelligence components, but did not employ the weighted evaluation methodology used for DOD’s Senior Executive Service requirements. The Office of the Under Secretary of Defense for Intelligence communicated its request for positions to the Office of the Under Secretary of Defense for Personnel as an aggregate number without submitting the detailed justifications or its analysis. The Office of the Under Secretary of Defense for Personnel and Readiness, in turn, as part of DOD’s general legislative program, communicated that aggregated number to Congress. By submitting solely the aggregate number, DOD may not have provided sufficient details about the need for additional Defense Intelligence Senior Executive Service allocations.” 7. Page 24, third, fourth, and fifth sentences : Because these sentences refers to the criteria in Table 3 (discussed in item 4 and 5 above), add the words “position grading” after the word “common” in each of these sentences. 8. Page 28, line 7 from top of page: Change the word "levels" to "and equivalent grades" and change footnote 46 to read "Equivalent grades include those under the National Security Personnel System and other authorized pay plans." Rationale: This language is adapted from DoDI 1430.16, enclosure 3, page 11, paragraph 2c(1), the official description of eligibility for DSLDP. 9. Page 30, footnote 50: Add the word “equivalent” before the word “employees”. Defense intelligence employees are not General Schedule employees, but hold equivalent positions under the Defense Civilian Intelligence Personnel System. RECOMMENDATION 2: The GAO recommends that the Secretary of Defense direct the Under Secretary of Defense for Intelligence to finalize and issue common criteria for the military service intelligence elements and the defense intelligence agencies to use in their assessments of Defense Intelligence Senior Executive Service requirements. DOD RESPONSE: Concur. RECOMMENDATION 3: The GAO recommends that the Secretary of Defense direct the Under Secretary of Defense for Personnel and Readiness and the Under Secretary of Defense of Intelligence to better communicate key information, to include justification for each Defense Intelligence Senior Executive Service position needed, during the development and presentation of legislative proposals to Congressional decision-makers. DOD RESPONSE: Concur. The following are GAO’s comments DOD’s letters. Comments 1 through 21 are on specific sections in the Department of Defense (DOD) letter dated October 25, 2010, and received by GAO on October 28, 2010. The specific section is entitled, “Department of Defense Comments to the Recommendations.” Comments 22 through 30 are on specific sections in the DOD letter dated October 23, 2010, and received by GAO on October 28, 2010. The specific section is entitled “Department of Defense Intelligence Comments to the Recommendations.” 1. DOD asserted that our statement that “some of the components’ information was incomplete” was not accurate. DOD further asserted that for its baseline review submission, certain DOD components incorporated by reference their biennial allocation activities they undertook in support of their requests for additional civilian senior leaders, rather than duplicate those efforts. The department further asserts that a copy of the component’s work in this regard was provided to the GAO review team. We disagree. As we stated in our report, a DOD official told us that the Army and the Air Force chose to use assessments of their Senior Executive Service, Senior Level, and Senior Technical workforces that had been conducted in response to OPM’s 2008-2009 Biennial Review of Executive Resources Allocations. However, this DOD official was unable to provide us with copies of the assessments completed by the Army and Air Force. Contrary to DOD’s comments, information the Army and Air Force submitted for the 2008-2009 biennial review was not provided to us. As stated in our Scope and Methodology, the only information we obtained related to the Biennial Review of Executive Resources Allocations was for 2010-2011. 2. DOD comments stated that the April 9, 2008, memorandum had a number of objectives for the baseline review. We agree. Nonetheless, we were unable to include all of those objectives on the Highlights page, which is a summary of our report. However, we have since added some of the objectives in other sections of our report. 3. DOD noted that the April 2008 memorandum results would be used to respond to the National Defense Authorization Act for Fiscal Year 2007. This information was referenced in the Background section of our report. 4. DOD explained that, given the multipronged application of results of the baseline review and intent to inform a variety of strategic human capital management initiatives, the department stands by its decision to rely on the component submissions as source material, reference material, or both, rather than summarizing and reporting the analysis for any single initiative. In light of the internal control standards, which we reference in our report, we continue to believe that the department should have documented and summarized its analysis. 5. DOD stated that the second to the last sentence on the Highlights page should be revised to read that the new program “has developed and is continuing to refine” metrics and that the new program “did not have” clearly defined metrics to measure progress or success. However, during the course of our review, DOD neither discussed metrics to measure the success of the program nor provided of such metrics. We therefore made no change to our report. 6. DOD stated that the reference to the “Senior Executive Service” on the first page of the report should be changed to say “reduce by 150 the number of senior civilian executive positions.” We have revised our report accordingly. 7. DOD noted that “Senior Technical” should be “Scientific/Professional.” We clarified our use in a footnote in our report. 8. DOD’s commented that “Under Secretary” should be “Principal Secretary.” We revised our report accordingly. 9. DOD’s commented that pages 7 and 8 of our draft report described some but not all aspects of the allocation process and failed to mention the criteria provided to the components and upon which biennial allocation requests are justified. We disagree. DOD’s comments focused on the background of the report. The criteria are clearly specified in the report on pages 17, 18, and 19. 10. DOD’s commented that pages 7 and 8 of the draft report did not mention the analysis and evaluation aspect of the leveling process utilized by the Civilian Personnel Management Service is omitted and the ability of any component to submit an out-of-cycle request for allocations outside of the biennial process is not mentioned. We disagree. Information on out-of-cycle request is clearly specified on page 25 and in appendix IV of our report. Per comment 11, we have changed “prioritized” to “leveling.” 11. DOD’s comments stated that the department objects to the characterization of the leveling process as “reprioritizes” and DOD evaluates all component biennial allocation submissions as a whole against the criteria developed for the biennial process. The department notes that the leveling process is used to ensure that all components have applied the criteria in a consistent manner and prioritized their positions in a similar manner. We have revised our report accordingly. 12. DOD’s commented that the decision to submit the combatant commands’ request for the fiscal year 2010-2011 biennial allocation process was a reflection of an increased demand on those organizations and was never intended to be a standard approach for future combatant command allocation requests. We have revised our report accordingly. 13. DOD’s comments asserted that the department’s full 2008-2009 biennial allocation request was made available to GAO. We disagree. While DOD provided 2010-2011 biennial review documents, we were not provided, even though we asked, any documents related to DOD’s 2008-2009 biennial review submissions. As indicated in our Scope and Methodology, we reviewed documents related solely to DOD’s 2010-2011 biennial review submissions. 14. DOD commented that our report stated that the department’s vacancy rate is about 20 percent but notes that the current Senior Executive Service vacancy rate is approximately 8 percent and the department’s average over the last 3 years is 12 to 14 percent. We have revised our report accordingly. 15. DOD asked that we change “levels” to “and equivalent grades” and the corresponding footnote to read “Equivalent grades include those under the National Security Personnel System and other authorized pay plans.” We revised our report accordingly. 16. DOD asked that we change “shadow professionals” to “enhance their individual development through substantive enterprise- spanning experiential activity and feedback on strengths and competency gaps from Talent Development Executives.” We paraphrased this passage in our report. 17. DOD asked that we “will be” to “was” in recognition that fiscal year 2010 has ended. We revised our report accordingly. 18. DOD asked that GAO make several minor word changes to table 4. We have revised our report accordingly. 19. DOD commented that the statement “the department does not have clearly defined goals and specific metrics for the program and has not sought OPM certification” should be changed. The department stated that its goals and purposes were identified in DODI 1430.16, enclosure 3, page 11, paragraph 2b. We have made modifications to our report to reflect this information. Further, the department acknowledged, as we stated, that it has specific metrics in place to evaluate applicants prior to their admission to its program as well as metrics to track participants. The department also stated that summative metrics were currently being refined and will be implemented for each cohort after the first cohort has completed the program in April, 2011. However, at the time of our review, DOD did not have summative metrics that are associated with the program and did not provide documentation or information on these metrics. Furthermore, the department’s comments noted that as these metrics are implemented the results would provide a more complete evaluation of the entire program. Accordingly, we made no modifications to our report. 20. DOD asked that we add the following to the end of the first sentence on page 30: “…but is researching the requirements for OPM certification.” We revised our report accordingly. 21. DOD asked us to make the following changes in our conclusion paragraph: delete the phrase “it has not yet identified program goals and measures” and add the phrase “it continues to refine the program metrics.” We made some modifications in accordance with our response in comment 20. 22. DOD commented that the statement “during the course of our review officials were unable to provide supporting information from the defense intelligence components or analysis related to the 120- day review of intelligence senior civilian requirements” did not accurately portray the circumstances or timing of the GAO request. The department stated that the request to see or receive copies of such reporting information was made in late August nearly a year after the announcement of the GAO review and 7 months after GAO met on January 26, 2010, with Human Capital Management staff of the Under Secretary of Defense for Intelligence and executive resources officers from all of the defense intelligence components. Accordingly, DOD asked that the statement be revised from “during the course of our review” to “DOD officials were not able to respond to requests made in the last month of our review to see or receive copies of supporting documentation.” We note, however, that we requested the information in July 2010 and stated at our entrance conference that the scope of our work may expand as we obtained additional information. In fact, we obtained DOD’s 2009 update to its Civilian Strategic Workforce Plan, which identified a baseline review of DOD’s civilian senior leader workforce and a 120-day review of the defense intelligence senior leader workforce requirements—both of which were key to this review. As a result, the scope of our work was expanded in July 2010. We made some revisions to clarify our report. 23. DOD asked, in light of the changes related to comment 22, that the third sentence of the last paragraph on page 17 be revised to “We could not verify these statements, however, because DOD officials were not able to respond to requests we made in the last month of our review to see or receive copies of supporting documentation to show analysis that could be readily traced back to component submissions.” In light of our response in comment 22 and the fact that we included a statement that the department needed to clearly document or summarize an analysis that could be readily traced back to the component submissions, we determined that this information would be stated twice in our report. As a result, we did not make this latter revision. 24. DOD stated that the fourth sentence of the last paragraph on page 17 assumes that certain information does not exist and declares DOD unable to provide clear insight into requirements for senior civilian senior leaders. The department asked that the sentence be changed to “DOD’s ability to provide Congress and other stakeholders clear insight and visibility into the defense intelligence community’s validation of requirements for its civilian senior leader workforces can be improved by clearly documented analysis that can be traced back to component submissions.” We disagree with the assumption that certain information does not exist, and we did not add the phrase “clearly documented analysis that can be traced back to components submissions” because it was already stated in a prior sentence in our report and would therefore be duplicative. Accordingly, we did not make this revision. 25. DOD’s comments stated that the last sentence on page 21 implies that the military service intelligence branches and agencies in the defense intelligence community use position grading standards as the sole measure of the need for new Defense Intelligence Senior Executive Service allocations. They further stated that this is not accurate and asked us to change the last half of the sentence to read: “…to ensure any additional Defense Intelligence Senior Executive Service allocations meet the statutory minimum requirement to be classified above the GS-15 level.” We agree and have changed the report accordingly. 26. DOD stated that the description of table 3 on page 22 should change the phrase “Evaluate the Need for” to “Validate” and add after the word “Allocations” the phrase “Meet the Statutory Requirement to Be Classified Above GS-15.” We agree and have changed the report accordingly. 27. DOD asked that the following changes be made to the paragraph after table 3 on page 23: at the end of the first sentence, add “with detailed justification statements that included a description of each position, its reporting relationships, the number of people directly supervised, the position’s total supervisory span of control, and a justification/mission-critical requirement statement.” We agree and have made changes to the report accordingly. The department also asked that we change the remainder of the paragraph to read as follows: “The Office of the Under Secretary of Defense for Intelligence evaluated the detailed justification statements submitted by the defense intelligence components, but did not employ the weighted evaluation methodology used for DOD’s Senior Executive Service requirements. The Office of the Under Secretary of Defense for Intelligence communicated its request for positions to the Office of the Under Secretary of Defense for Personnel and Readiness as an aggregate number without submitting the detailed justifications or its analysis. The Office of the Under Secretary of Defense for Personnel and Readiness, in turn, as part of DOD’s general legislative program, communicated that aggregated number to Congress. By submitting solely the aggregate number, DOD may not have provided sufficient details about the need for additional Defense Intelligence Senior Executive Service allocations.” We note that the only additional DOD text that was not covered in our report was the phrase, “the weighted evaluation methodology.” The focus, however, of our paragraph was the absence of detailed justifications and not the methodology. Accordingly, we did not make this latter change. 28. DOD asked that the third, fourth, and fifth sentences on page 24 be changed because these sentences refer to the criteria in table 3 (discussed in comments 25 and 26 above) by adding the words “position grading” after the word “common” in each of these sentences. We disagree. The text is referring to GAO’s prior work on human capital management and not specifically to the defense intelligence community criteria. 29. DOD asked that we change the word “levels” to “and equivalent grades” and change footnote 46 to read “Equivalent grades include those under the National Security Personnel System and other authorized pay plans.” We agree and have changed our report accordingly. 30. DOD asked that in footnote 52 on page 28 we add the word “equivalent” before the word “employees.” We agree and have changed the report accordingly. In addition to the contact named above, David Moser, Assistant Director; Marion Gatling, Assistant Director; Alysia Darjean; Scott Doubleday; Mae Jones; Brian Pegram; Steven Putansu; Amie Steele; and Michael Willems made key contributions to this report. Human Capital: Further Actions Needed to Enhance DOD’s Civilian Strategic Workforce Plan. GAO-10-814R. Washington, D.C.: September 27, 2010. High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January 2009. Human Capital: Opportunities Exist to Build on Recent Progress to Strengthen DOD’s Civilian Human Capital Strategic Plan. GAO-09-235. Washington, D.C.: February 10, 2009. Human Capital: Diversity in the Federal SES and Processes for Selecting New Executives. GAO-09-110. Washington, D.C.: November 26, 2008. Ensuring a Continuing Focus on Implementing Effective Human Capital Strategies. GAO-09-234CG. Washington, D.C.: November 21, 2008. Human Capital: Corps of Engineers Needs to Update Its Workforce Planning Process to More Effectively Address Its Current and Future Workforce Needs. GAO-08-596. Washington, D.C.: May 7, 2008. The Department of Defense’s Civilian Human Capital Strategic Plan Does Not Meet Most Statutory Requirements. GAO-08-439R. Washington, D.C.: February 6, 2008. DOD Civilian Personnel: Comprehensive Strategic Workforce Plans Needed. GAO-04-753. Washington, D.C.: June 30, 2004. Military Personnel: General and Flag Officer Requirements Are Unclear Based on DOD’s 2003 Report to Congress. GAO-04-488. Washington, D.C.: April 21, 2004. Human Capital: Key Principles for Effective Strategic Workforce Planning. GAO-04-39. Washington, D.C.: December 11, 2003. Foreign Assistance: Strategic Workforce Planning Can Help USAID Address Current and Future Challenges. GAO-03-946. Washington, D.C.: August 22, 2003. DOD Civilian Personnel: Improved Strategic Planning Needed to Help Ensure Viability of DOD’s Civilian Industrial Workforce. GAO-03-472. Washington, D.C.: April 30, 2003. Internal Control Standards: Internal Control Management and Evaluation Tool. GAO-01-1008G. Washington, D.C.: August 2001. Internal Control: Standards for Internal Control in the Federal Government. GAO/AIMD-00-21.3.1. Washington, D.C.: November 1999.

Summary: The Department of Defense (DOD) relies heavily on its civilian workforce to perform duties usually performed by military personnel--including combat support functions such as logistics. Civilian senior leaders--some of whom occupy positions that might be cut during DOD's latest attempts to reduce overhead costs--are among those who manage DOD's civilians. In 2007, Congress mandated that DOD assess requirements for its civilian senior leader workforce in light of recent trends. DOD reported its recent reply to this requirement in its 2009 update to the Civilian Human Capital Strategic Plan, which used information from a 2008 baseline review to validate its senior leader requirements. GAO was asked to review DOD's approach for (1) assessing its civilian senior leader workforce requirements, (2) identifying and communicating the need for additional senior leaders, and (3) developing and managing this workforce. GAO reviewed submissions for DOD's baseline review and requests for additional senior leaders, including DOD's intelligence agencies. GAO also interviewed DOD and Office of Personnel Management officials. DOD conducted a baseline review to assess and validate its civilian senior leader requirements but did not document its analysis or summarize the results of the review. Standards for internal controls call for significant events to be documented and summarized to facilitate tracing transactions and related information. Specifically, in April 2008, DOD issued guidance for components outside its intelligence community to conduct a baseline review of its senior leader needs. While DOD reported to Congress that this was a rigorous analysis, GAO found that some of the components' information was incomplete and DOD was unable to provide documentation of an analysis summarizing its results. DOD officials said that they did not summarize the analysis because the information was only intended to support a number of human capital management efforts, including a report to Congress on DOD's Civilian Human Capital Plan. Similarly, DOD's intelligence community, in 2007, issued guidance for assessing its workforce needs but also did not summarize its analysis. DOD officials stated that while the analysis was not summarized, it resulted in a number of key decisions--for example, a reduction in one agency's senior leader needs. However, without documenting and summarizing information in an analysis that could be traced to component submissions, DOD may not be able to provide Congress and stakeholders in its chain of command insight into how it assessed its senior leader needs. While most DOD entities used a consistent, clearly documented approach to identify and communicate needs for additional civilian senior leaders, the defense intelligence community's approach lacked similar consistency. Outside of the defense intelligence community, DOD used common criteria to identify its most urgent needs for additional senior leaders and communicated those needs and justifications through the chain of command. The defense intelligence community, however, assessed its needs for additional personnel using various sets of criteria and communicated those needs as one aggregate number without providing specific justifications to stakeholders and, ultimately, to Congress. GAO's prior work has shown that establishing common criteria and clear communication strategies strengthens agency processes. Without such criteria and a well-defined set of communication expectations, requests to increase senior leaders in the defense intelligence community will not appear to be supported and justified. DOD's approach for managing and developing civilian leaders includes policies and an executive education program but has some limitations. For example, the executive education program--which, according to program officials, costs an average of $6.5 million per year--was created to address problems of a predecessor program, including the lack of a plan for how graduates would be used in the future. The new program, however, does not have clearly defined metrics to measure the progress or success of the program. GAO previously reported that high-performing organizations recognize the importance of measuring how programs meet their goals. GAO recommends that DOD (1) document analyses and clarify assessment criteria for determining certain senior leader requirements and (2) create clearly defined metrics for its executive education program. DOD generally concurred with GAO's recommendations.