State’s Foreign Affairs Manual requires that U.S. government Foreign Service and Civil Service employees under chief-of-mission authority with assignments or short-term TDY to designated high-threat countries complete FACT training before deploying. USAID’s Automated Directives System additionally requires FACT training for USAID’s U.S. personal services contractors deploying to these posts. The 1-week course, held at a U.S. location, provides practical, hands-on instruction in topics such as detection of surveillance, familiarization with firearms, awareness of improvised explosive devices, and provision of emergency medical care (see fig. 1 for other examples of topics addressed in FACT training). To ensure that personnel are prepared to confront current risks in high- threat environments, State requires that personnel complete the course every 5 years and updates the FACT training curriculum periodically to reflect changing threats abroad. For example, in 2009, the ambassador to one high-threat country noted that personnel needed to be familiar with the sound of sirens announcing a rocket attack and with the physical features of protective bunkers, in part because personnel were injuring themselves when entering the bunkers. In response, State’s Diplomatic Security Training Center added two bunkers at its training facility and began conducting duck-and-cover exercises with recorded sirens. State also revised the FACT training curriculum in 2013 to include instruction on helicopter operations, vehicle rollover training, and evacuation from a smoke-filled environment. State initially established the FACT training requirement for personnel in one country in 2003 and extended it to eight more countries over the next 9 years. In June 2013, State doubled the number of countries for which it required FACT training. Prior to that date, the requirement applied to assigned personnel and those on short-term TDY in a designated high- threat country for 30 or more cumulative days in a 365-day period (with the exception of personnel on short-term TDY to one country, where State required FACT training for personnel with 60 cumulative days or more of TDY status). In December 2012, the Accountability Review Board, which State convened to investigate the attacks on the mission in Benghazi, Libya, recommended that FACT training be required for personnel assigned to all high-threat, high-risk countries. An independent panel established as a result of the Accountability Review Board also identified training as critical to State’s ability to ensure a safe and secure environment for employees. In response to the Accountability Review Board’s recommendation, in June 2013, State issued a memorandum notifying U.S. agencies that it was increasing the number of countries for which it requires FACT training from 9 to 18. State also required that employed eligible family members of personnel in all designated high-threat countries complete FACT training and changed the requirement for short-term TDY personnel. Under the new requirement, short-term TDY personnel must take FACT training if they spend more than 45 cumulative days in a calendar year in one or more of the designated countries. 13 FAM 322(b). training. In extraordinary circumstances, State may grant a waiver of the FACT training requirement to individuals on a case-by-case basis. Using data from multiple sources related to State and USAID assigned personnel, we determined that 675 of 708 State personnel and all of the 143 USAID personnel on assignments to the designated high-threat countries on March 31, 2013, were in compliance with the FACT training requirement. We found 33 State assigned personnel who were not in compliance with the mandatory training requirement. We were unable to assess compliance among short-term TDY personnel because of gaps in State’s data. First, State has not established a mechanism to identify the universe of short-term TDY personnel who are required to take FACT training. Second, State’s eCountry Clearance (eCC) system—the most comprehensive data source for identifying short-term TDY personnel granted country clearance to high-threat posts—has limitations. According to GAO’s Standards for Internal Control in the Federal Government, program managers need operating information to determine whether they are meeting compliance requirements. Based on our review of available data, we found that 675 of 708 State personnel and all of the 143 USAID personnel in the designated high- threat countries on March 31, 2013, complied with the FACT training requirement. We identified 33 noncompliant State personnel. According to State officials, of the 22 noncompliant individuals in one country, 18 were State personnel’s employed eligible family members who were required to take the training; State officials explained that these individuals were not aware of the requirement at the time. The officials noted that enrollment of family members in the course is given lower priority than enrollment of direct-hire U.S. government employees but that space is typically available. In addition, a senior official at the embassy in another country as of March 31, 2013, did not complete FACT training before or during his tenure. According to State officials, this resulted from a pressing situation in the country; however, this individual did not receive a waiver from the FACT training requirement. State provided a variety of reasons why the remaining 10 personnel were not in compliance with the requirement (see app. III for more information). Because State does not maintain a single source of data on assigned U.S. personnel who are required to complete FACT training, State or an independent reviewer has to obtain and reconcile information from three State databases—State’s Global Employment Management System (GEMS), Student Training Management System, and Post Personnel—as well as other sources to assess the extent of compliance among all U.S. agencies with the FACT training requirement. In addition, limitations in these various State data systems containing information needed to assess compliance make it difficult to readily identify personnel subject to the FACT training requirement. As a result, the data are not readily available for decision making and require resource- and labor-intensive efforts to determine compliance. According to internal control standards, program managers need operating information to determine whether they are meeting compliance requirements. The following is a list of the current data systems and the limitations associated with each. Global Employment Management System. GEMS—the centralized personnel database for State’s U.S. direct-hire personnel and employed eligible family members—identifies direct-hire personnel on assignments, including assignments to the designated high-threat countries. However, GEMS does not consistently identify State personnel who are required to complete FACT training. In some cases, the GEMS data that we reviewed included dates for employees’ arrival at post; in other cases, it included employees’ hire dates. As a result, to determine whether these personnel had completed FACT training within 5 years of arrival at the posts, additional employee profile information must be obtained from State’s Bureau of Human Resources. Moreover, GEMS data do not contain a field identifying whether certain personnel are subject to the FACT training requirement based on their employment type or position. For example, the GEMS data do not readily identify eligible family members, some of whom were required to complete FACT training. As a result of this limitation, additional evidence is required to verify whether they were subject to the FACT training requirement. Student Training Management System. State’s Student Training Management System is the official system of record for State, USAID, and other agency personnel’s FACT training completion dates. Although the Student Training Management System shows personnel who enrolled in FACT training, it does not consistently include training completion dates. For example, the data that we reviewed lacked FACT training completion dates for 9 of 143 assigned USAID personnel. State officials could not provide a definitive explanation for the absence of these completion dates in the training management system. For these nine records, State and USAID officials had to provide alternate forms of evidence, such as Foreign Service Institute training transcripts or FACT training rosters, to show that personnel had completed the training. Post Personnel. State’s Post Personnel system—a database managed by the overseas posts—contains information on all U.S. executive branch personnel assigned under chief-of-mission authority. Therefore, we reviewed data from Post Personnel to identify some USAID personnel who were required to complete FACT training, because USAID officials told us that data maintained in USAID’s internal staffing report for March 31, 2013, might not include all personal services contractors at the designated high-threat countries. We attempted to compare Post Personnel records for USAID personnel with FACT training completion records in State’s Student Training Management System to examine compliance among USAID personnel. However, we found that the Post Personnel data excluded 18 USAID assigned personnel who, according to a USAID staffing report, were assigned to countries for which State required FACT training on March 31, 2013. According to State officials, Post Personnel is not an official or reliable system of record for information. State is in the process of developing a new, centralized system to replace Post Personnel—the Overseas Personnel System—that will track the location of all U.S. employees stationed at overseas posts and is expected to become operational in February 2014, according to State Bureau of Human Resources officials. However, according to agency officials, the new system will not integrate data from State’s Student Training Management System or other personnel data systems. Gaps in State’s data on U.S. short-term TDY personnel at high-threat countries make it impossible for State or an independent reviewer to readily assess compliance with the FACT training requirement among State and USAID short-term TDY personnel who are required to complete FACT training. First, State does not systematically maintain data on the universe of U.S. personnel on short-term TDY status in designated high- threat countries who are required to complete the training.